KALASHNIKOV and AFANASYEVA Begin Operations at TENETMEDIA

31. As TENETMEDIA prepared to launch in the fall of 2023, consistent with PersonaOne‘s instruction to Chen to work with the “Russian firm we agreed to hire,” Chen introduced KALASHNIKOV to TENETMEDIA employees and affiliates as an outside editor hired by TENETMEDIA ‘s investor. In this role, KALASHNIKOV monitored TENETMEDIA ‘s internal communications and edited content published by TENETMEDIA , without disclosing that he was an RT employee. KALASHNIKOV also introduced his fellow RT employee AFANASYEVA to provide additional day-to-day direction to TENETMEDIA employees and commentators, as set forth below.
32. On or about August 2, 2023, Chen created a Discord server for use by TENETMEDIA employees, associates, and contributors (the “TENETMEDIA Discord Server”). In the weeks that followed, Chen subdivided the TENETMEDIA Discord Server into various Discord channels, including channels for individual contributors and their teams to discuss production-related matters, a channel to discuss pitches and story concepts, and channels for the production team to post videos for publication by TENETMEDIA . Chen added KALASHNIKOV to most of these Discord channels, typically introducing KALASHNIKOV as an editor. For example:a. On or about August 7, 2023, Chen created a Discord channel for the production of videos by one of the six commentators listed on TENETMEDIA ‘s website (“LAUREN SOUTHERN“) and told LAUREN SOUTHERN that KALASHNIKOV “is heading up the editing team, so you and him can start to discuss how to get started working together.” Through this channel on the TENETMEDIA Discord Server, KALASHNIKOV requested raw footage from LAUREN SOUTHERN and later shared an edited version of LAUREN SOUTHERN‘s first video for TENETMEDIA .b. KALASHNIKOV similarly participated in a Discord channel on the TENETMEDIA Discord Server for another commentator listed on TENETMEDIA ‘s website (“TAYLER HANSEN“). Communications on that channel included, among other things, KALASHNIKOV requesting raw footage from TAYLER HANSEN and sharing an edited video.c. On or about November 9, 2023, Chen messaged Producer-2 on Discord, in part, that “Eduard hired Kostya’s team”—in other words, that “Eduard Grigoriann” had hired KALASHNIKOV’s purported editing team.

33. On or about August 17, 2023, KALASHNIKOV informed Chen that he had added “Helena Shudra,” whom KALASHNIKOV described as a member of “my team” who would be “coordinating the editing team,” to the TENETMEDIA Discord Server.a. Digital forensic evidence confirms that “Helena Shudra” was, in truth and in fact, AFANASYEVA, an employee of RT. For example, the email account used to register the “Helena Shudra” Discord account bears a Russian web domain and the email handle “afalenal1997,” which is composed of the first three letters of AFANASYEVA’s surname (“afa”), a variant of AFANASYEVA’s first name ELENA (“lena”), and AFANASYEVA’s birth year (“1997”). Moreover, between in or about February 2024 and in or about March 2024, the “Helena Shudra” Discord account was accessed approximately 173 times from a Moscow-based IP address that was also used to access AFANASYEVA’s personal Gmail address on approximately 12 occasions. On approximately 163 occasions, that same IP address was also used to access the “Victoria Pesti” Discord account, which, as set forth below, was another fake persona used by AFANASYEVA.b. AFANASYEVA (as “Helena Shudra“) initially adopted a similar editorial role as KALASHNIKOV; for example, in communications on the TENETMEDIA Discord Server, “Helena Shudra” solicited raw footage from and circulated edited videos for review by LAUREN SOUTHERN. After the public launch of TENETMEDIA , however, AFANASYEVA used the “Helena Shudra” persona and the “Victoria Pesti” persona to push RT messaging through TENETMEDIA and expand its viewership, as set forth below.