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MOTION FOR GOVERNMENT TO TURN OVER INVESTIGATIONS FILES AND OTHER INFORMATION AND TO PROVIDE ASSISTANCE NECESSARY TO IDENTIFY WITNESSES, REVIEW FILES FOR BRADY INFORMATION AND TO FACILITATE WITNESS ASSESSMENT, TRIAL PREPARATION AND SERVICE OF SUBPOENAS
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
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UNITED STATES OF AMERICA Complainant,
v.
KEN HARRELSON
(Styled as USA v. Rhodes et al. incorporating cases
against multiple Defendants)
|
|
|
Defendant
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Criminal Case No.
1:22-cr-15
Assigned to the Honorable
Amit Mehta, District
Court Judge
INFORMATION REQUESTED
New video evidence, as a practical matter only reviewable in
the last eight (8) weeks, suggests that individuals referenced in Attachment 1
were all material witnesses, some of whom also were Suspicious Actor’s (SA’s),
that witnessed or engaged in the following conduct, including:
a. Attacking police and others.
b. Attacking Oath Keepers and
others.
c. Entering Capitol doors in the
West with apparent permission or acquiescence of government actors.
d. Opening the Columbus Doors in
the East from the inside, possibly with even further assistance of government
actors.
e. Deploying sophisticated crowd behavior techniques,
orienting themselves at signs, barriers, and
fencing, sometimes while being observed by Police, to deny others of
consciousness of guilt
f. Sabotaging
the day’s activities by inflating participation into a “spectacle event” to
where attendance levels outstripped physical space and effectiveness of
understaffed US Capitol Police (USCP)and the Metropolitan Police Department compromising
its response, confusing rally attendees and imposing on all concerned a
dangerous public safety posture which resulted in injury and death.
g. Associating,
conferring and traveling with others engaging in behavior to confuse law
enforcement through body masking, facial masking, clothing changes, and
disorienting skirmishing behavior.
h. Using ear-pieces and
communications equipment to coordinate and confer, to divide labor and work
together towards common objects. This cannot be dismissed, because the
Government makes these same allegations against the Defendants and these very
same attributes are used by the Government to try to show advance planning by
these Defendants to achieve goals we now are learning they do not appear on
video to be pursuing these goals while others are clearly depicted on video
pursuing these goals. Therefore, the fact that it was others—not these
Defendants--who exhibit these behaviors and coordinated use of this equipment
cannot be merely brushed aside by the Government. Presumably, these phones were
contained in geo-fencing collections obtained by the government. Often it
appears that these communications devices do not seem to be affected by capacity
restriction or sophisticated jamming that was evident throughout the day.
CONCLUSION
Attachment
1 is a first attempt to aggregate and identify these material witnesses, some
of whom may be Suspicious Actors (SAs) who pursued motives, goals and plans
that have been mistakenly imputed to the Oath Keepers or who even may have set
out to frame the Oath Keepers. We go the extra step of setting forth a factual
basis in Attachment 1 to establish clearly that this is undeniably Brady information.
Dated: May 5, 2022 RESPECTFULLY SUBMITTED
/s/ Brad Geyer
Bradford L. Geyer, PHV
PA 62998
Brad@FormerFedsGroup.Com
