(Continued from Part 2.)

As stated in previous Requests, I have never communicated with any member of the Proud Boys. My communications with members of the Oath Keepers was very limited, using an app called Signal, and strictly for the purpose of coordinating the Private Security Details. The communication between the Oath Keepers and myself was strictly professional in nature, and did not include any mention of politically charged rhetoric, discussions on the validity of the 2020 Election, memes, or any other off-topic discussions. The messages were strictly concerning the Private Security Details that we were contracted to provide. As aforementioned, the communications between the Oath Keepers and I can be obtained from Published Evidentiary Exhibits, from the FBI and the Department of Justice, or by my Criminal Defense Attorney if he were compelled to do so by the Court.

I have had three legal actions filed against me; the Criminal Indictment in United States v. Stewart Rhodes III et al. (No.22-cr-15) , the Civil Litigation Case of Smith v. Trump et al. (No. 21-cv-2265, ECF No. 213), and this Civil complaint (1:21-cv-03267-APM); each of which I was a named Defendant.
The Criminal Case No. 22-cr-15 against me I was charged with Seditious Conspiracy and found NOT GUILTY, Destruction of Government Property and found NOT GUILTY, Obstruction of an Official Proceeding and found GUILTY, Conspiracy and found GUILTY, Conspiracy to Obstruct an Official Proceeding and found GUILTY, and Impeding Officers Responding to a Civil Disorder and found GUILTY.
In the first 3 of the 4 Guilty verdicts – as stated by the AUSA with the Department of Justice – the claim was that I allegedly “…agreed to walk through the door, and as such was part of the crowd that must be cleared, in order to continue to Certify the 2020 Election…” This was the gist of the claim against me; that I walked through an open door with the Oath Keepers, and that in so doing that I inadvertently interrupted an Official Proceeding which I believed had already ended prior to leaving the White House Ellipse. Because I did so with a group, this constituted a Conspiracy. As stated by AUSA Jeffery Nestler during the Closing Arguments, there was no plan to do so. The fact that we believed the Certification had ended prior to leaving the White House Ellipse was corroborated repeatedly by audio recordings, video, and Social Media posts. In the final of the 4 Guilty verdicts, I told my Jury that I accept responsibility for Impeding Officers Responding to a Civil Disorder, for being in their way while we protested in the Senate Hallway, and the subsequent actions by Officers in order to get protesters to disperse.
It was never my intent to Obstruct an Official Proceeding, on January 6th or at any other time. Furthermore, it is not within my legal capacity to keep President Trump in power, or to “overturn the results of the Presidential Election”, to “subvert” or “otherwise delay”, “to hinder” or “impede the results”. I have no authority to Certify an Election, and it is logistically impossible to “Obstruct the Peaceful Transfer of Power” on January 6th itself. The “Peaceful Transfer of Power” does not occur on January 6th, it occurs at the Presidential Inauguration, which was not to be conducted for another 2 weeks, on January 20th. By spending a mere 24 minutes within the US Capitol Building, I was not engaged in any meaningful delay of the Peaceful Transfer of Power nor was it my intent to do so.
As corroborated by CCTV Surveillance Camera footage, I left the US Capitol voluntarily, while I rendered aid to injured protesters. I also stopped acts of vandalism twice; once by making a protester get off a Police vehicle, and again when I stopped a rioter that was smashing glass inside the US Capitol. Furthermore, it is the actions of my Oath Keeper codefendants that sheds light on our intent to provide aid to those in need, including to members of Law Enforcement. Kelly Meggs, Connie Meggs, Kenneth Harrelson and other members of the Oath Keepers came across Capitol Police Officer Harry Dunn as he was being harassed by the crowd. Kelly and Connie Meggs, Kenneth Harrelson and others heroically placed themselves bodily between Officer Dunn and the crowd and created a barrier to protect him, at risk of drawing the ire of the crowd upon themselves. Kelly and Connie Meggs then later assisted US Capitol Police as they pushed protesters out of the doors of the US Capitol at the behest of Capitol Police Officers, and with their gratitude. After leaving the US Capitol Grounds and while returning to our vehicle, Donovan Crowl, Bennie and Sandra Parker and myself came across a Trump Supporter that was being beaten by Black Lives Matter activists at BLM Plaza. We four Defendants rescued this innocent man, and allowed him to escape. These facts and others by Oath Keeper Defendants show that it was our intent, desire, and stated purpose to provide security, render medical attention, and protect Government property from damage, on January 6th and all previous rallies and protests. The fact we left Capitol Grounds voluntarily after a curfew was announced by Mayor Muriel Bowser also indicates our desire to obey lawful orders.
It was never our intent to Obstruct an Official Proceeding on January 6th. The January 6th Congressional Electoral Certification was our final legal option to Raise Objections to the results of the 2020 Election, to have the results returned to the States of Georgia, Pennsylvania, Michigan, Arizona, and Minnesota in order to have 10-day ballot audits conducted. This was initiated in the US House of Representatives and brought before the US Senate; cosponsored by Reps. Marjorie Taylor Green, Paul Gosar, Matt Gaetz and others, as well as Senator Ted Cruz and others. It was my belief that this would be our final legal remedy to “clear up” any questions to the 2020 Election; thereby ensuring the validity of the Electoral results. Interrupting the January 6th Electoral Certification by members of the crowd would be entirely counterproductive to our purpose – to support Congress as they raised Objections to the 2020 Election. Had I known that the Certification had yet to be finalized, I would not have participated in the events at the US Capitol at all. We desperately needed the January 6th Certification in order to pursue our final legal remedy. It was my belief that the 2020 Election had been Certified by Congress, that Pence had betrayed us by refusing to have ballot audits conducted, and that the Certification was over. This fact is what led me to feel disenfranchised, to lose objectivity, and to get swept up in the 1st Amendment protest activities at the US Capitol. Having never witnessed violence of any kind, I had no indication that there was anything amiss and I allowed myself to be led along by the crowd, to enter the US Capitol and expose myself to numerous legal actions including this Civil Claim against me.

Any requests for Discovery can be obtained from the Published Evidentiary Exhibits during our trial, from the Federal Department of Justice, from the FBI, and if compelled to do so by the Court, from my Criminal Defense Attorney Jonathan Crisp Esq. I do however urge caution when using Published Evidentiary Exhibits that were presented by the AUSA’s with the Federal Department of Justice during the Criminal Trial No. 22-cr-15. Many of the Government Exhibits are false, fabricated, incomplete or inaccurate representations of events and documentation. This was proven during the course of our trial; that the DOJ and AUSA’s falsified testimony, fabricated evidence, and potentially withheld Brady materials in order to obtain a Guilty verdict. As such, I refer Counsel for the Plaintiffs to the Court Transcripts for full details. I do not make this allegation lightly, and this statement can be corroborated by comparing the Government’s presented Trial Exhibits against the raw data, including by that obtained from the CellBright analysis, as well as against the sworn testimony by FBI personnel.


I request that these statements be weighed for their merits; that each can be corroborated by any/all Discovery that you may obtain, and that the claims against me are false. I request that I be removed from this Legal Action against me, as I did not inflict any harm or PTSD or any other impact on the aforementioned named Plaintiffs. My interactions with US Metropolitan Police Officers on January 6th was strictly professional and courteous. I did not coordinate with any Proud Boys, nor did I know any members of the Proud Boys prior to my incarceration. The Hon. Judge Amit P. Mehta presided over our Criminal Trial, and has seen the statements made in this RESPONSE TO PLAINTIFF’S INTERROGATORIES to be true and accurate statements. I respectfully request that the Court to grant the request to Sever Defendant Jessica Watkins from this Civil Action.

Additionally, as I have no assets of any worth and I am indigent, that there is no financial benefit to be gained by continuing this action against me. This Civil Action serves only to malign and defame my character, but can serve no other purpose. I respectfully request Counsel for the Plaintiffs to remove me from their Claim. Should the Counsel for the Plaintiffs need any further statements, I am happy to provide those statements on the TruLincs system. Each Counsel has been added to my Contact List and I am available there if needed further.

FBoP REG. NO. 26050-509

A copy of this RESPONSE TO PLAINTIFF’S INTERROGATORIES has been sent by Certified Mail by my fiance Montana Siniff to the DISTRICT COURT and to Hon. Judge Amit P. Mehta via Certified Mail, and to the Counsel for the Plaintiffs by myself to the following contacts:

to: /s/ Brendan B. Downes
Brendan B. Downes (D.C. Bar 187888)
400 6th St. NW
Washington, DC 20001
Tel: 202-724-6533
Email: Brendan.downes@dc.gov

to: /s/ Norman Eisen
Norman Eisen (D.C. Bar 435051)
1101 17th St NW, Suite 250
Washington, DC 20036
Tel: 202-999-9305
Email: norm@statesuniteddemocracy.org

to: /s/ James Pasch
605 Third Avenue
New York, NY 10158
Tel: 212-885-5806
Email: jpasch@adl.org

to: /s/ Vincent H. Cohen
Vincent H. Cohen, Jr. (D.C. Bar 471489)
1900 K. St, NW
Washington, DC 20006
Tel: 202-261-3300
Fax: 202-261-3333
email: vincent.cohen@dechert.com

to: /s/ Jeannie S. Rhee (D.C. Bar 464127)
2001 K Street, NW
Washington, DC 20006
Tel: 202-223-7300
Fax: 202-223-7420
Email: jrhee@paulweiss.com