(Continued from Part 1.)

As stated in REQUEST NO. 1, I have had no affiliation with the Proud Boys, prior to my incarceration or since my transfer to the Women’s Unit (E2B) in the DCDOC-CTF. Furthermore, I am unaware of any Organizational structures within the Proud Boys or any hierarchy within that organization.

As stated in REQUEST NO. 6, I am unaware of any Organizational structure or hierarchy within the Proud Boys.

I am unaware of any financial information, net worth, income, assets or any financial or property affairs, cash flows, or tax returns concerning the Proud Boys or the Oath Keepers.

I have never communicated with any person with signing authority or account owner of any bank accounts affiliated with members of the Proud Boys.

To the best of my knowledge, I am unaware of any communication with anyone within the Proud Boys. If there was any person online that was a member of the Proud Boys that I communicated with unintentionally, that was never disclosed to me at any point, and I never deliberately communicated with any person on behalf of the Proud Boys. As far as I am aware, I have never communicated with anyone online that was a Proud Boy, or who was affiliated with that group.

I have no affiliation with the Proud Boys, online or elsewhere.
I was incarcerated 3.5 years ago, and as such I cannot recall with any accuracy my screennames, User ID’s or assumed names that I used online. That being stated, all of this information is however available as part of my Criminal Trial – as each was used for/against me during the course of Evidentiary Exhibits. Furthermore, I provided the FBI and the Department of Justice all my account information – including passwords – during the course of my debriefings and proffer sessions. I do regret that I cannot recall this information perfectly, however I refer you to the Department of Justice (AUSA) and the FBI for the majority of this information. My Criminal Defense Counsel, Jonathan Crisp Esq., can also provide this information should he be compelled to do so by the Court.

I have never attended any training or meetings with any Proud Boys, and am unaware of any training or meetings that have occurred. I have also never attended any training with the Oath Keepers. The only meeting I have ever attended with the Oath Keepers occurred on (I believe) November 9th, when I attended a Go2Meeting Conference Call. The purpose of this Conference Call was to prepare for our upcoming Private Security Detail; to protect the Stage and VIP’s like General Michael Flynn, Alex Jones and others while they delivered speeches at the Rally that occurred on November 14th, 2020 at Freedom Plaza. To my knowledge, the Proud Boys had no attendees at the November 14th Rally (Million MAGA March), and if they did attend, the Proud Boys were not in communication with the Oath Keepers to my knowledge, nor did any Proud Boys attend the November 9th, 2020 Go2Meeting Conference Call to my knowledge. The transcript for the Go2Meeting Conference Call can be obtained from Evidentiary Exhibits released during the course of my Criminal Trial; the focus of the Oath Keeper’s Conference Call was to provide protection for VIP’s, protesters and attendees from attacks by Antifa, Black Lives Matter, and other violent Far-Left Extremist Groups that tended to attack innocent protesters at Trump Rallies. It was these attacks that led us to defend VIP’s and protesters from potential violence. During our attendance at the November 14th Million MAGA March, the events were entirely peaceful until after the Oath Keepers left the area. After our departure, members of Antifa attacked the elderly and families with children; burning their American Flags, beating them, and spraying noxious chemicals.

As previously stated in REQUEST NO. 12, the Conference Call on November 9th was in preparation for the Rally at Freedom Plaza on November 14th, 2020. That event was attended by myself, my fiance Montana Siniff, and my codefendant Donovan Crowl. We partnered with the Oath Keepers to provide Security and Medical Services to those in need. My involvement on November 14th was the same purpose as I served on January 5-6, 2021 – I attended to provide Medical Services to any injured persons; Law Enforcement, Bystanders, and Protesters. On January 5th, 2021 – Donovan Crowl, Bennie and Sandra Parker, and myself provided Security for the Stage perimeter at the Freedom Plaza Rally; we protected the Backstage VIP Area as General Michael Flynn, Alex Jones and other VIP’s gave speeches to the crowd. The November 14th and January 5th events were the only events in Washington DC, Maryland, Virginia or anywhere adjacent to Washington DC prior to January 6th. For the events of January 6th itself, I refer you to my initial STATEMENT OF FACTS, in Part 1.

I did not attend the event on December 12th, 2020 with the Oath Keepers, and I had not intended to do so. Several days prior to that event, my arm and ribs were broken when a foundation wall collapsed on me. As such, I was bedridden, in severe pain, and completely uninterested and incapable of attending any events. My attendance at events on January 5th/6th was even semi-coerced. I had initially declined to attend the January 5th/6th Events as a result of my injuries, but was eventually talked into attending by codefendants. I was excited about the prospect of being a Medic for Roger Stone and Congressmen, and this is what ultimately encouraged me to capitulate and attend the events on January 5th and 6th. My involvement in Washington D.C. (or adjacent states/counties/municipalities) between November 14th and January 6th have been detailed between the STATEMENT OF FACTS and REQUEST NO. 12-13. However, out of an abundance of caution, I will reply to each of your lettered requests with further clarity.

a.) I attended each event (November 14th, January 5th, and January 6th) as a member of a contracted Private Security Detail with the Oath Keepers; to protect attendees and VIP’s from attacks by violent Left-Wing Extremist groups like Antifa and Black Lives Matter, who often attacked innocent Conservative Protesters as they left the Trump Rallies. These attacks by violent Left-Wing Agitators have been thoroughly documented; stabbings, beatings of the elderly, using pepperspray and bear mace on families with children, stealing the protesters’ Trump Flags/Hats or American Flags and burning them in the streets. These Left-Wing groups also threw Fireworks and Molotov Cocktails at Police Officers, as well as Bricks, Bottles, and other dangerous objects. These attacks on Law Enforcement and Conservative Rally Attendees is what motivated me to attend the Security Details, as well as the reason why we have Personal Protective Equipment (PPE) like helmets, body armor and protective gloves. Given my history as an EMT-b, I was there to provide Medical attention to anyone in need, including to members of Law Enforcement. All of this was clearly stated repeatedly and often in text messages and on Social Media.

b.) My fiance Montana Siniff drove Donovan Crowl and myself to the Caldwell Farm in preparation for the November 14th Million MAGA March. A convoy of vehicles drove the Oath Keepers, ourselves included, from the Caldwell Farm to the DC Area for the Million MAGA March. For the January 5th and 6th Events, Donovan Crowl drove himself and me to Bennie and Sandra Parker’s home. From there, Bennie and Sandra Parker drove their vehicle to the Washington, DC area for both the events of January 5th and January 6th. On January 6th, the Parkers parked their vehicle at a garage at the intersection of G St. and 21st St., and we proceeded on foot to the Rally at the White House Ellipse. After the Rally at the White House Ellipse, the Oath Keepers escorted our VIP’s on foot from Constitution Ave, took a left on 15th St. and then a right down Pennsylvania Ave toward the US Capitol Building.

c.) I attended the November 14th Million MAGA March with my fiance Montana Siniff, Donovan Crowl, Stewart Rhodes, Doug Smith and various other unknown members of the Oath Keepers. I attended the January 5th and January 6th Events with Donovan Crowl, Bennie and Sandra Parker, Kelly and Connie Meggs, Kenneth Harrelson, Joseph Hackett and various other named codefendants that are listed within the Oath Keeper Criminal Indictments. However, that being stated, many of those on the Criminal Indictments were never at the Capitol Building with me, I have never met them (even to this day), and I have no knowledge of their actions, statements, or culpability. Our group consisted of merely 8-10 individuals; less than half of those who were Indicted. For instance, I was unaware that Stewart Rhodes was at the January 6th Event. Many others, like Robert Minuta and those with him, were part of a completely separate PSD and I had never spoken with, or met those individuals. On January 6th, Thomas Caldwell merely assisted Bennie and Sandra Parker in finding a parking spot and to help us get into Security for the Rally at the White House Ellipse and we never saw him again until the following day.

d.) As articulated during my STATEMENT OF FACTS, my interactions with Law Enforcement on January 6th were minimal at best, and entirely courteous. With the exception of when I was crushed by the crowd in the Senate hallway, my actions were entirely beneficial or benign. I was merely were exercising my 1st Amendment, stopping vandalism, and rendering aid to the injured. A previously articulated in the STATEMENT OF FACTS, my actions were laid out chronologically and thoroughly. Should clarity be required, I have added the emails for each Plaintiff’s Counsel to my TruLincs Contact List, and will gladly answer your questions on that system, to the best of my ability. I encourage Plaintiffs’ Counsel to reach out to me on that system should clarity be required. I request that the Court compel any such communication between myself and Plaintiff’s Counsel be released as part of Discovery to the Counsel for the Defense.

e.) I did document my activities on January 6th; video, audio (Zello), Social Media posts on Parler, text messages, etc. All video/audio/messages and photographs of the events from January 6th were published as Evidentiary Exhibits during the course of our Criminal Trial. I refer Plaintiff’s Counsel to the FBI, the Department of Justice, and to Exhibits from the Criminal Trial. As I am currently incarcerated, I have no capacity to provide any of this Discovery, nor do I have any such materials in my possession. Should the Court compel my Criminal Defense Counsel to provide Discovery, my attorney Jonathan Crisp Esq. can accommodate that request.

I had very limited communication regarding the 2020 Election, and the validity of the results. Those Communications can be found as part of Published Evidentiary Exhibits during the course of our Trial, or be provided by the FBI or Department of Justice. The handful of texts indicate that, up to and including January 6th itself, it was my belief that President Trump was pursuing legal options (lawsuits, etc) to contest the results and compel the States to conduct audits on their ballots. To this day, I still doubt the veracity of the claims that the 2020 Election was “the most secure election in history”; given the untested and untried use of mail-in ballots during the COVID-19 crisis, unsecure drop boxes, Unconstitutional changes to Electoral Systems without the Legislative Branch, multiple ballots sent to individual voters, and numerous instances of voter fraud, ballot harvesting and other unscrupulous methods of election tampering.
However, I never at any point communicated any intent to protest, contest, subvert or otherwise attempt to reverse the results of the 2020 Election. It was my belief that January 6th was the final lawful remedy to investigate systemic voter fraud in 2020, and that the purpose of the Save America Rally on January 6th was to support members of Congress; to give them courage to reject the Certification of the 2020 Election and to return the ballots to the States with systemic voter fraud, and to have 10-Day audits conducted. That plan was thoroughly articulated in President Trump’s speech to us at the White House Ellipse on January 6th, 2021, and I remained hopeful that would occur. If not, it was my belief that “…Biden might get ‘the steal’…” and that potential unlawful actions could occur during a Biden Presidency; including illegal actions that might subvert US Sovereignty by China or the UN; similar to what occurred with the Chinese Spy Balloon situation.

(continued on Part 3.)