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REOUEST FOR MUTUAL LEGAL ASSISTANCE IN CRIMINAL MATTERS

Requested authority:

Home Office, UK Central Authority,2 Marsham Street, Home Office, Sth Floor, Fry BuildingLondon

The application is also submitted tc the Republic of Ecuado!'.

Your Ref:

l, Requesting Prosecutor:Director of Public Prosecution Marianne NyAklagarmyndigheten (Swedish Prosecution Authority), UtvecklingscentrumGteborg,Box 128401 22 GteborgSweden

Telephone nr: +46 10 5627101Fax nr: +46 10 56271 41E-mail address: marianne.ny@aklagare.seOur Ref: AM-131226-10Document lD: 212

2. Criminal investigation is conducted against following suspects:

Surname Assange

First names: Julian Paul

Nationality: Australia

Date of Birth: 3 July 1971

Place of Birth: Townsville, Australia

Currently located at the Ecuadorian embassy, London

3. Urgency:

The alleged crimes detailed at points 1-3 below are subject to statutory limitationin August 2015. lt would therefore be desirable for any possible interview and

other investigative measures with the suspect to take place as soon as isreasonably possible.By agreement with Julian Assange we want to conduct the investigation matterson two consecutive days during June-July 2015, and primarily in June 2015.Julian Assange has suggested 1 7-18 June 2015

Applied conventions and/or agr6ements:

- European Convention of 20 April 1959 on Mutual Asisfance /, Criminal Matters

- 1978 Additionat Protocot to the 1959 European Convention on Mutual Assistance in CriminalMatters

- Eu Convention on Mutuat Assistance in Criminal Matters of 29 May 2000.

- 2OOl Protocol to the EU Convention on Mutuai Assistance in Ciminal Matters of 29May 2000

5. Legal qualification ofthe facts:

1. UNLAWFUL COERCIONOn 13-14 August 2010

Section of LawChapter 4 Section 4 Paral Swedish Penal Code

Section of LawChapter 6 Section 10 Para 2 Swedish Penal Code

3. SEXUAL MOLESTATION

Section of LawChapter 6 Section 10 Para 2 Swedish Penal Code

2, SEXUAL MOLESTATIONOn 13-14 August 2010

Section of LawSection 1 Chapter 6 Para 3 Swedish Penal Code

6. Statement of the facts:

The allegations were reported to the police in Stockholm on 20 August 2010 and Julian Assangewas detained in his absence suspected of rape and molestation. On 25 August the prosecutordecided to discontinue the preliminary investigation into the rape. The victim's representativerequested a review of this decision. On 1 September 2010 the preliminary investigation concerningthe rape was reopened by a senior proseculor and the case was widened to include unlawfulcoercion and sexual molestation.Julian Assange was detained in his absence by Stockholm District Court on 18 November 2010.The Court of Appeal affirmed this decision on 24 November 2010. On 2 Decemt er 2010 thec..^,aaa ,\^t,,+ rr^1,.1 +h-r L,ti^^

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lnterview with Julian Assange as suspect to the crimes listed in points 1-4 andtake a sample of his DNA.

7b) Link between the facts and the requested activities:An interview needs to be performedproceed. The prosecutor decrded on

with the suspect for the investigation to27 September 2010 that a DNA sample

7c) The activities requested are to be executed as follows:

Great Britain's permission is requested for the Assistant Prosecutor and aninrr6+i^er^r fr^m tha

^,rli^a in St^.kh^lm l^ .r^, ^r!! the 2[6r.rq-mqntipngdin\,'esiigai;ve mesuies at the Ecuador';ail el',rbassy in L+rd'on.

The interview regarding the suspected crimes will be performed by DetectiveSuperintendent Cecilia Redell of the Stockholm police with the aid of an Englishinterpreter and in the presence of Chief Prosecutor lngrid lsgren of the PublicProsecution Office in Vsters. The interview is to be recorded and written outin dialogue form in Stockholm. At the interview Julian Assange will have legalrepresehtation from advocate Thomas Olsson, Stockholm and advocate Per ESamuelsson, Stockholm.At the interview regarding lhe suspected crimes, Julian Assange will have theopportunity to freely explain the events in question. The investigator will thenpose questions based on the information we have in the case file and anyinlormation provided by the suspect in the main interview.

The defence will have the opportunity to pose questions once the DetectiveSuperintendent has finalized the main interview. Once the defence hascompleted its questioning, further complementary questions might then beposed to Julian Assange at the discretion of the Chief Prosecutor, lngrid lsgren.As well as interviewing the suspect, it is requested to take a DNA sample by theinvestigator, a so-called swab. The sample will be collected using a cotton budto swab saliva from the suspect's mouth.The form of the interview and taking of a DNA sample have been agreed byJulian Assange via his legal representation.

7d) Partial transmission:

should be taken from the suspect.

8) lnvolved Swedish investigators/others and their presence:Assistant ProsecutorChief Prosecutor lngrid lsgrenAklagarkammaren i VstersBox 21721 03 VstersTelephone +46 10-562 53 29

Police investioatorDetective Superintendent Cecilia Redell

Utredningsenheten Region Stockholm106 75 Stockholm

Telephone: +46 10-5633479 , +46 761-296757

cecilia.redell@polisen.se

It is desirable that Chief Prosecutor lngrid lsgren and Detective SuperintendentCecilia Redell could perform the requested investigation measures at theEcuadorian Embassy in London.

Prosecutor responsible for the preliminarv investioationDirector of Public Prosecution Marianne Ny, Utvecklingscentrum Gteborg, Box128, 401 22 Gteborg, will not be present.

9) The request is confidential for the following reasons:Due to the risk that the investigation can be jeopardized or damaged there is aneed for confidentiality- Hence, the statements of the criminal acts

- but not the

crime classifications nor the sections of law -

in point 5 and the requestedarrangements in point Z are classifled. -!-here !s also a !'isk that the victims'-eafelyand private lives can be impacted, and for this reason there is a need forconfidentiality regarding their identities, personal relationships and detailsregarding the suspected crimes.

For security reasons, it is desirable for the timetable of the upcoming actions tobe kept confidential. The case has received a great deal of attention and there isa risk that the carrying out ofthe requested investigative measures at theembassy could be disrupted by the mass media and members of the public.

10. Other involved persons/authorities:

Annexes:

fi Legisiationflotner

l, Marianne Ny, am competent to authorize the equivalent measure in Sweden

May 29th 2015

lnternational Division, National Operations DepartmentP.O. Box 12256SE-102 26 StockholmSWEDEN

Chapter 4On Crimes against Liberty and PeceSection 4A person who, by assault or otherwise by force or by threat ofa criminal act, compcls another to do, submit to oromit to do something, shall be sentenced for unlawful coercion to a fine or imprisonment for at most two years.Anyone who to such effect exercises coercion by threatening to prosecute or report another for a crime or givedetrimental infomation about another, shall also be sentenced for unlawful coercion. provided that the coe.cionis wrongful.

Ifthe crime referred to in the first, paragraph is gross, imprisonment lor at lcasL six oloolhs alld at nlost six yealsshall be imposed. [n assessing whether the crime is gross specia] consideration shall be given to whether the actincluded the infliction ofpain to force a confession. or other torture.

Chapter 60n Sexual CrimesSection IA person who by assault or otherwise by violence or by threat ofa criminal act forces another person to havesexual intercourse or to undertake or endue another sexual act that, having regard to the nature ofthe Yiolationand the circumstances in general, is comparable to sexual intercourse, shall be sentenced for rape toimprisonment for at last two and at most six yea6.

This shall also apply ifa person engages with another person in sexual intercourse or in a sexual act which uoderthe first paragraph is comparable to sexual intercourse by improperly exploiting that the person, due tounconsciousness, sleep, iltoxication or other drug influence, illness, physical injury or mental disturbance, orotherwise in view ofthe circumstances in general, is in a helpless state.

Il in view ofthe circumstances associated with the crime, a crime provided for in the lirst or second paragraph isconsidered less aggravated, a sentence to imprisonment for at most four years shall be imposed for npe.

Ifa crime provided for in the first or second paragraph is considered gross, a sentence to imprisonment for atleast four and at most ten years shall be imposed for gross rape. [n assessing whether the crime is gross, specialconsideration shall be given to whther the violence or tlreat was ofa particularly serious nature or whethermore than one person assaulted the victim or in any other way took part in the assault or whether the perptratorhaving regard to the method used or otherwise exhibited particular ruthlessness or brutality.

Section l0A person who, otherwise than as previously provided in this Chapter, sexually touches a child under fifteen yearsofage or induces the child to undertake or participate in an act with sexual impliaations, shall be sentcnced forsexual molestation to a fine or imprisonme[t for at most two years.

This also applies to a person who exposes himselfor herselfto another penon in a manner that is likely to causediscomfort, or who otherwise by word or deed molests a person in a way that is likely to violate that person'ssexual inXegrity.

Chapter 35On Limitations on Sanctions

Section INo sanction may be imposed unless the suspect has been remanded in custody or received notice ofprosecutionfor the crime within:1. two years, ifthe crime is punishable by at most imprisonment for onE year,

I Z. five years, ifrhe most severe punishment is imprisonment for more than one but no more than rwo years II lt[:T#;i? *. ,nosr severe punishment is imprisonment for more than two but no more than eight yea.sJ

4. fiftee[ years, ifthe most severe punishment is imp sonment for a fixed term ofmore than eight years,5. twnty-five years, iflife imprisonment can be imposed for the crime.

ifan aci inciudes several ciimes, a\eii, iegaiiss of wiiai is siaaa,j abo-re, a sa,-,ciion ,-'ai be imposed for ali ofthe crimes, provided that a sanction can be imposed for any one of them.

ANNEX TO REQUEST FOR MUTUAL LEGAL ASSISTANCE IN CzuMINAL MATTERS

Avsndare: Ny MarianneMottagare: olsson@friaadvokater.seSkickat: 20 I 5-03-13 08:43mne: Ang Assange-rendet

As per our telephone conversation a moment ago, we would like to obtain JulianAssange's consint to conduct the following investigative measures - all providd thatthe necessary permissions are obtained tiom the United Kingdom and Ecuador.

o Interview with Assange at the Ecuadorian embassy in London, provided that thenecessary pcrmissions arc obtaincd lrom thc Unit.'d Kingdom and Ecuedcr'

. Follow-up examination the day after the first examination. in case an,v supplementaryquestions need to be asked by the prosecution or defence.

o The examinations (main questioning) will be held by investigator Cecilia Redell withthe help ofan interyreter, in the presence of the Deputy Investigation Officer, ChiefPublic Prosecutor Ingrid Isgren and Julian Assange's defence counsel. No one else maybe present during the examination.

o In direct connection to the main examination, the defenders and the investigator will beallowed to ask supplementary and clari!ing questions, in the order determined by ChiefPublic Prosecutor Ingrid Isgren. The same order will apply for any follow-upexamination the following day.

o The examination(s) will be recorded and transcribed verbatim uPon our return toStockholm.

. Before the first examination, Julian Assange will be swabbed for a DNA sample'

Marianne Ny

Frn: Per E Samuelsson [mailto:PerAss\,r'.se]

Skickatr den 16 april 2015 13i09

Till: Ny Marianne; lsgren Ingid

Kopia: Per E Sarnuelssoni Thomas Olsson (olsson@fiiaadvokater.se)

mne: FRHR I LoNDoN

Julian Assange conents to thc swcdish Prosccution Authority's decision to question him in the Ecuadorian emba-ssyin London, where he has been Sriitlted political asylum,

Julian Assange assumes that the terms stated in your e-mail are in accordance with the provisions ofthe swdishCode ofJudicial Procedure, and with correspondlng regulatioos ofEuropean, English and Ecuadorian law lntheevenl that any excptions from these regulations are applicable, we ask that you clariiy them at your earliestconvenience,

Funhermore, Julian Asange wO!ld Iike to stress the importance ofhaving the examination documented in its entiretyby means ofrecording.

Julian ^ssange

reminds the prosecutors that he has already provided a DNA sample as part olthe prliminaryinvestigation. This took place on 7 December 2010. We have access to the sample's rcfercnce numbcr, should you

need it. Despite this facr, Julian Assangc conscnts to the takinS ofa DNA sample in connection to the intrview. ifthis is cailed fbr.

Julian Assange may wish to exercise his right to have legal counsel from re lev ant j urisd ictions prcscnt during thcinterview.

We wish to .emind the prosecutors that the extreme and outdrawn isolatio( that Julian Assan8e has been andcontinues to bc subjcctcd to will not bc remedicd becausc the Swedish Prosecution Authodty has now changed itsposition. Julian

^ssange will participate in the preliminttry investigation with reservations for any and atl legal

measures that Julian Assange takes, or may take in the future, in regard to this matter and the coercive oalure ofhisarbitrary deprivation of liberty.

In accordance with instructions from our client, rve will send a sopy ofthis e-mail and your coftespondence to theEcuadorian Mlinistry ofForeign AfFairs and Human Mobility to keep them infb.med ofthe ongoing process.

Plcase inform us at your earliest conve[ience olthe measures that will be iaken in this matter.

D-. I- qi-,,alc^h l-l-,,. --

a!::.1,

frn: Ny MarianneSkickat: dcn 17 april 2015 09:20'l iII: 'Per Fi Samuelsson'Kopia: ThomasOlsson(olsson@friaadvokater.se);lsgrenlngrid(lngrid.lsgren@aklagare.se)

mnc: sv: FRHR I LoNDoN'l hank you for responding to our query of 13 March. However, we find the response unclear on three points andwould be grateful ifyou could provide some clarification at your earlist conveniencc.

What is thc intended meaning ofthe following statements?

a/ " Julian Assangs assumes that the terms siated in your e-mail are in line with thc provisions ofthc Swedish CodeofJudicial Procedure, aod with corresponding regulations ofEuropean, English and Ecuadorian law. [n the event thatany exceptions lrom these regulations are applicabl, we ask thalyou clari& them at your earliest convenience." ?

As stated in our qucry, we witl scnd pcrmission applications lor the .equested measures to both the United Kingdomand Ecuador. Your answer will be appended to the appiications fbr legal assistaooe in a ctiminal maller. ls JulianAssange conditioning his consent on any other form of legal assessme[t olthe requested measures?

b/ "Julian Assange may wish to exercise his right to have legal counsel from relevant j urisd ictions present during theinterview."?

What does rhis condition e[tail in practicc? For rcasons olsecrccy, only his delence counsel in the crimioalinvestigation may be present during any questioning regifding the crimes he is suspectd of committing

c/ " Julian Assaoge will participate in the preliminaiy invBstigation with reservations for any and all legal meauresthat Julian Assange takes, or may take in the future, in regard to this mattr and the coercive nature ofhis arbiharydeprivation ofliberty." ls this some form oioondition, and ifso, what does it entail?

In ref'erence ro the condition that the examination be recorded in its entirery, we would once again like to cladfy thatthis will be the case, and that the examination will be transcribed upon our retum to Stockholm. We would also liketo clarify that there are two reports fi1ed in the case: ooe lor each ofthe injured pafties. A separate examination willlherelore be conducted in rel'erence to eash reporl. AccordinB to Swedish practice, Julian Assange will be gircn aaopporfunity to give an accouot ofthe events in his own words at the start ofthese idterviews before the inte(ogatingofficer, and then you and Thomas Olsson will be aflorded the opportuniry to ask him questions.

The request to take a DN,\ sample is due to thc English practice ofnot transferring any samples taken in England. Aswe understand from your reply, Julian Assange has no objection to us taking a DNA sample.

ln concllrsion, we would Iike to point out that, as has been stated in our petitioN to thc Slockholm City Court und theSvea Court ofAppcal, we are not ofthe opinion that Julian Assange's voluntary stay at the Ecuadorian embasy canbe equated to a deprivation of liberty. Furthermore. we strongly object to ths allegation that the English and S\redishcourts that have tried the matter of a surrender pursuant to a[ EAW and the matter of detention wou Id be gui]tl o fconducti ng an arbitrar)' examination.

Marianne Ny Ingrid Isgren

!rn: Per E Samuelsson lmailto:Per@ssw.se]

Skickat: den 28 apri120l5 l6:5,1

'lill: Ny Marianne; Isgren lngrid

Kopia:'fhomas Olsson (olsson@liiddvokater.se); Per E Samuelsson

mne: FRHR I LoNDoN

In your e-mail of 17 April 2015, you claim that Julian Assange laid down a number ofconditions lor his consent to anexamination with him at the Ecuadorian embassy in London. This is not the case. No conditions have been laid down.

In our letter we simply emphasised our assumption that your proposal for how the exami[ation is to be condLlcted isin accordance with the legal requi.ements imposed by applioable legislation, and asked you to point out anyincongruities. Otherwise, we have simply maintained that Julian Assange gives his consent with reservations for thelegal rneasures that he has taken, is cunently taking or may lakc in the future. in regard to this legal matter.

Respectlirl regards

Per E Samuelson Thomas Olsson

Fmn: Ny Mariaone

Skickat: den 5 maj 2015 14:14

Till: Per E Samuelsson

Kopia: Christina vikstrm

mner sv: FRHR I l.oNDoN

Hello!

We have assessed our request based on Swedish legislation. Whether our request is in ascordance with the legislationofthe receiving countries, and whether the measurcs are thus pennissible, is a matter to be dctcrmincd by thc UnitedKingdom of Grcat Britain and Northem lreland and lie RepobLic of Ecuador respectively. Does Iulian

^ssangeconsent io this prooedute?

Does Julian Assaflgc wish lor anyone other than his lawyers Thomas Olsson and Per E Samuelsson to be present atthe interviews?

W would be grateful ifyou eould indicate, at this point in time, two consecutive days before Midsummer's Eve whenyou are avaiLable for the investigative medsures in London.

WouLd ir be possible to .each one ofyou today, or in the next few days, to get a verbal reply to thse questions so thatwe can move on lo the next step?

Respectful .egards

Marianne Ny tngrid Isgren

Frn: Per E Safiuelsson Skickal den 6 maj 2015 06:39Till: Ny MarianneKopia:'thomasOlsson(olsson(@friaadvokater.se)mne: sv: FRHR I LoNDoN

Hello Mariannc,

'lhaJlk you for youre-rnail. We have been instmcted by our client to only commuflicate with you in writing We haveforwarded youi e-mail from yesterday to our client aod will get back to you with a written rsponse z soon as wccar,

Respectfui regards

Per E Samuelson

Frn: Per E Samuelsson Skickat: den 18 maj 2015 17:44Till: Ny MarianneKopia: Thomas Olsson (olsson@friaadvokater.se); Per D Samuelssonmne: FRHRI LoNDoN

In regard to your e-mail ofs May 2015, our reply is as follows.

Juliari Assange is anxious for the application for legal assistance to be made as soon as possible.

We would appreciate a copy ofyour request lor our knowlodge in conjunction with i1 being sent to the concemedparties.

We propose that the interviews be conducted in London on l? and l8 June 2015, when we are both able t0partic ipat.

In rcsponse to your question ofwhich lawyers Julian Assange would like to have present duling the questioning, inaddition to the two of us, this will depeod on Ecuador and the United Kingdom's positions oo the matter ofapplicablelaw.

Respectlulregards

Per E Samuclson fhomas Olsson