If you do not know about the Oath Keepers and Watkins, here is a response that will tell you all those details you missed.

DISTRICT OF COLUMBIA, Plaintiff, v. Case No. 1:21-cv-03267 (APM) PROUD BOYS INTERNATIONAL, L.L.C., et al., Defendants. 
RESPONSE TO PLAINTIFF DISTRICT OF COLUMBIA’S MOTION TO COMPEL RESPONSES TO PLAINTIFF’S INTERROGATORIES

Pursuant to Rules 26, 33, and 37 of the Federal Rules of Civil Procedure, I am responding this one and only time to the Compelling motion to submit my interrogatories to the Plaintiff’s requests. I have no Counsel, and due to my indigent and incarcerated state, I will be unable to obtain Counsel in my defense; neither will I be able to defend myself pro se. Given the restrictive nature of my incarceration, I am providing this reply on the TruLincs System provided by the Federal Bureau of Prisons (FBoP). Furthermore, the FBoP does not provide a Law Library for defense in Civil Litigation or for tort claims. As such, my capability to provide for my own defense has been even further handicapped by this incapacity. As such, I request that the Court, as well as the Counsel for the Plaintiff’s consider this reply with some degree of leniency. The TruLincs system charges us 1 TruUnit per minute, and 3 TruUnits per page to be printed. As such, simply drafting this response and then sending it certified mail will be a costly venture. I beg your understanding as you consider my reply; not merely just for formatting issues, but also for legal compliance with the Federal Rules of Civil Procedure.

STATEMENT OF FACTS

I was incarcerated on 18 January, 2021 and have been incarcerated ever since; resulting from my limited participation in the January 6th, 2021 riot that occurred at the US Capitol Building. This Statement of Facts is to explain briefly my participation in those events that occurred that day. The events named in this Civil Complaint against the Defendants occurred nearly entirely on the Lower West Terrace and in the Tunnel. At no time did I ever attend these locations; I was unaware of any/all activities that occurred there, and I did not at any time communicate with individuals during those events; most of which occurred long before my arrival. This Statement of Facts is to articulate clearly my personal involvement with the events of January 6th, 2021.

I am a US Army Infantry veteran and a paratrooper, having served in Afghanistan as a US Army Ranger (1st Bn/75th Rangers). After my military service, I eventually became a Firefighter, Rescue Technician, and an Emergency Medical Technician (EMT-b) with Stoney Point Fire Department. It is these qualifications that led me to I attend the Save America Rally on January 6th with the Oath Keepers. I had coordinated with the Oath Keepers previously, providing contracted Security for small businesses in Louisville, KY during the Breyonna Taylor and George Floyd Riots, as well as for the Million MAGA March Rally at Freedom Plaza on November 14th, 2020. I attended the Save America Rally on January 6th, 2021 in a similar capacity, as the Oath Keepers were contracted to provide a sanctioned Private Security Detail (PSD) by Rally Organizers; to protect VIP’s and Dignitaries including Roger Stone, Ali Alexander, podcaster personalities, as well as to provide security for US Congressmen. The events were planned by the Save America Rally Event Staff; a contract was drafted and signed between Event Staff and Leadership of the Oath Keepers, and a permit was issued to protect the stage at Area 8 of US Capitol Building. This Permit for 1st Amendment Activities was issued by US Capitol Police. It was these facts that led me to join the PSD; to serve as a Medic for Roger Stone, and then later to escort US Congressmen on the Security Detail; to escort the Congressional Detail from the Rally at the White House Ellipse to the Speeches to be delivered at Area 8 on Capitol Grounds.

At the Rally in the White House Ellipse, we watched the Speech given by President Trump, and then coordinated with Event Staff to escort our VIP’s to the US Capitol. It was then that the issues began to mount. After the Oath Keepers met with Event Staff, we attempted to coordinate the PSD to escort the US Congressmen from the White House Ellipse to the Speeches at Area 8 on Capitol Grounds. But, with the US Secret Service being restrictive on our equipment, we immediately ran into issues and the Congressmen left without us. The remaining VIP’s were escorted by 2 PSD groups of Oath Keepers to the events scheduled at Area 8 on Capitol Grounds; I was in the 2nd PSD group. Both of the PSD’s were captured on video, as members of the Oath Keepers escorted our VIP’s through the streets. It is this PSD of which I spoke on a Zello recording, when I stated “…We’re stickin’ together, and stickin’ to the plan…”. The plan I mentioned in this statement was merely to escort our VIP’s to the Stage at Area 8 outside the US Capitol Building. This fact was proven beyond reasonable doubt during the course of my Criminal Trial. At the Ellipse, the tone of the protest shifted, when individuals in the crowd began to look at their phones in anger. Again, I discussed this moment when I stated on the Zello recording that, “…it spread through the crowd like wildfire. It’s over. Pence betrayed us…” At this time, we believed that the 2020 Election had been completely Certified, and that the crowd, outraged by this, sped off to the Capitol Building in protest. Once the streets cleared out, we gathered our remaining VIP’s, and eventually followed behind the crowd. The Oath Keeper PSD arrived at the fringe of the US Capitol Grounds at roughly 2:26pm.

Once the VIP’s had departed, the Oath Keeper PSD followed the fence line, complying with the Restricted Area signs, as we followed the crowd to the steps on the East Side of the US Capitol. As shown on Event Brochures, the protest was scheduled to occur on the steps of the Capitol. As we made our way to that location, we had no idea that anything was awry. As visible on video, the US Capitol Police could be seen standing around in riot gear as the peaceful crowd kept their distance from the Officers conducting their duties on the perimeter. This can be corroborated by timestamped CCTV Surveillance Camera footage. The Oath Keepers walked up the Capitol Steps and joined the crowd as we sang the National Anthem. The Oath Keepers walked up the steps and saw the crowd walking through an open door. As shown on CCTV Surveillance Camera footage, the Oath Keepers entered the US Capitol through the open door at 2:41pm; during that time I did not witness nor participate in any assaults on Police Officers, and I perceived my actions as merely an exercise of my 1st Amendment. This can be seen on camera, as I chanted slogans and waved my arm in sequence with members of the crowd. As stated in my Criminal Trial, I felt “…I got swept up in the moment and lost all objectivity. I felt disenfranchised by the fraud of the 2020 Election and I merely wanted my voice to be heard.”

During my protest activities, I wandered about the Rotunda taking selfies, and I stopped vandalism by a rioter that was smashing glass in a hallway. Eventually I joined a crowd as we chanted slogans. It was at this time that I was injured in a hallway as the crowd surged; pinning me between protesters and injuring my broken arm and ribs. In extreme pain, I reacted briefly by screaming in outrage. This fact was stipulated during my Criminal Trial, during my testimony when I accepted responsibility for my actions before the Hon. Judge Amit P. Mehta. I told my Jury that accept responsibility for Impeding Officers Responding to a Civil Disorder; a charge I still accept culpability for having committed. However, during this incident, I did not attack Officers, nor was it ever alleged that I had done so. When Officers deployed pepperspray to disperse the crowd, I ran as soon as I was able to get free. I did this, despite members of the crowd encouraging me to return by stating “We need a second wave”. I opted rather to obey the verbal and lawful commands of two Capitol Police Officers, and treated them with courtesy and respect as I obeyed their orders to return to the Capitol Rotunda area. It was there that I encountered an injured protester, dragging him from the building; politely requesting directions from a Capitol Police Officer. I left the US Capitol Building voluntarily at 3:05pm. Outside, I established a triage and a Casualty Collection Point with the other members of the Oath Keepers, beside a Riot Line of Capitol Police. In this area, I treated the Officers with courtesy and respect; even thanking them for their service. During this time, I dragged and injured man to an Ambulance nearby. After only an hour on Capitol Grounds, I left the area voluntarily. During our return to our vehicle, we were stopped by US Metropolitan Police. I complied with their commands courteously, providing my personal information. After our release, I told the Officers “God Bless you, and thank you for everything you do!” This was my only contact with Metropolitan Police Officers on January 6th, 2021, as captured on Body Worn Camera.

I was incarcerated on January 18th, 2021 following an FBI Raid on my home by a Joint Terrorism Task Force. I was not home, but surrendered myself to Authorities at the Urbana Police Department in Ohio. I have been incarcerated ever since. It was in the DC Jail where I was served with this Civil Complaint. My capacity for response has been limited. During my incarceration, I have spent nearly a year in Solitary Confinement, had limited or no access to a Law Library, and had sporadic motions mailed to my person by Counsel from the Plaintiff’s. Furthermore, My current address is still listed at the DC Department of Corrections (DCDOC-CTF) #260509, 1901 D. St., Washington, DC 20003; I currently stay in the FCI Tallahassee prison under the FBoP in Florida, Address Unknown, P.O. Box 5000, Tallahassee, FL 32314. During my transit to this facility, I have changed locations numerous times, and I believe that many of the motions mailed to me were sent to the DCDOC rather than my current facility. Regardless, I intend to reply to the Interrogatory Request I have currently in my possession, to the best of my ability.

REPLY TO INTERROGATORIES

REQUEST NO. 1:
With the exception of my incarceration in the DCDOC-CTF, I had never encountered anyone who identified as a Proud Boy. I make this statement to the best of my knowledge; no Proud Boy has ever come in contact with my person, prior to my incarceration; including the events of January 6th or prior to. During my stay in DCDOC-CTF, I was housed in the January 6th Unit (C2B) with William Chrestman, Dominick Pezzolla and Christopher Worrell. To my knowledge, these three individuals were the only Proud Boys I have met in my entire life, and I had only met them as a result of my incarceration. During my stay in the DCDOC-CTF, my contact with these individuals was still very limited, as I spent half my time in DCDOC-CTF in Solitary Confinement conditions (23 hours in my cell, 1 hour on Recreation – eventually extended to a 22/2, or eventually a 19/5.) As a Transgender Woman, after roughly a year and several months I was eventually transferred to a Women’s Unit (E2B) where I had no contact with any of the men from in C2B any further.

REQUEST NO. 2:
As stated in REQUEST NO. 1, I have had no affiliations with the Proud Boys, prior to incarceration or since my transfer to the Women’s Unit (E2B) in the DCDOC-CTF.

REQUEST NO. 3:
As stated in REQUEST NO. 1, I have had no affiliations with the Proud Boys, prior to incarceration or since my transfer to the Women’s Unit (E2B) in the DCDOC-CTF.

REQUEST NO. 4:
As stated in REQUEST NO. 1, I have had no affiliations with the Proud Boys, prior to incarceration or since my transfer to the Women’s Unit (E2B) in the DCDOC-CTF.

REQUEST NO. 5:
As stated in REQUEST NO. 1, I have had no affiliations with the Proud Boys, prior to incarceration or since my transfer to the Women’s Unit (E2B) in the DCDOC-CTF. Furthermore, I have no knowledge of the funding, organization, LLC Companies, or any other function of the Proud Boys, their subsidiaries if any, or any partnerships, unincorporated associations, nonprofits or any other affiliation.

(continued on Part 2.)