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conjunction with an event designated as a special event of national significance; and |
c. 40 U.S.C. § 5104(e)(2) (D), which makes it a crime for an individual or group |
of individuals to willfully and knowingly (A) enter or remain on the floor of either |
House of Congress or in any cloakroom or lobby adjacent to that floor, in the Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 16 of 1817 |
Rayburn Room of the House of Representatives, or in the Marble Room of the |
Senate, unless authorized to do so pursuant to rules adopted, or an authorization |
given, by that House; (B) enter or remain in the gallery of either House of Congress in violation of rules governing admission to the gallery adopted by that House or pursuant to an authorization given by that House; (C) with the intent t o disrupt the |
orderly conduct of official business, enter or remain in a room in any of the Capitol Buildings set aside or designated for the use of — (i) either House of Congress or a |
Member, committee, officer, or employee of Congress, or either House of Congress; or (ii) the Library of Congress; (D) utter loud, threatening, or abusive language, or engage in disorderly or disruptive conduct, at any place in the Grounds or in any of the Capitol Buildings with the intent to impede, disrupt, or dist... |
conduct of a session of Congress or either House of Congress, or the orderly cond uct |
in that building of a hearing before, or any deliberations of, a committee of Congress or either House of Congress; (E) obstruct, or impede passage through or within, the Grounds or any of the Capitol Buildings ; (F) engage in an act of physical violence |
in the Grounds or any of the Capitol Buildings; or (G) parade, demonstrate, or picket |
in any of the Capitol Buildings ; and |
25. As such, I respectfully request that the court issue an arrest warrant for SULLIVAN . |
The statements above are true and accurate to the best of my knowledge and belief. |
_________________________________ SPECIAL AGENT MATTHEW B. FOULGER |
FEDERAL BUREAU OF INVESTIGATION |
Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 17 of 1818 Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by |
telephone, this 13th day of January, 2021. |
___________________________________ |
HON. ROBIN M. MERIWEATHER |
UNITED STATES MAGISTR ATE JUDGE Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 18 of 18 |
1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, V. No. 21-cr-78 (RCL) JOHN EARLE SULLIVAN OPPOSITION TO MOTION IN LIMINE TO PRECLUDE IMPROPER STATEMENTS OF DEFENDANT AND TO PRECLUDE FIRST AMENDMENT DEFENSE Defendant... |
1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, V. No. 21-cr-78 (RCL) JOHN EARLE SULLIVAN REPLY TO MOTION IN LIMINE (Security Related Topics) Defendant, by and through undersigned counsel, does hereby file the f... |
although government obviously n eed make st atutory showing obstruction overall concept obstruction instructive in case government made atte mpt argue serious risk sullivan would threaten injure intimidate prospective witness attempt thing instead th e government focused risk obstruction in support claim government poi... |
additional material provided entry protective order case i recognize government discovery obligation brady maryland progeny rule i provide timely disclosure material come light consistent giglio ruiz u i provide information government witness prior trial compliance court tr ial management order i request reciprocal dis... |
prior p rotests riot sullivan organized multiple protest utah course on june defendant sullivan organized counter protest police event group drove car around provo police station sullivan seek permit hold counter specifically sullivan group blocked police car street traffic instruction sullivan also damaged several car... |
the supreme court self emphasized first amendment concern misplaced forfeiture statute oblivious expressive nonexpressive nature asset alexander united state case document filed page violation count one in sum court reach issue ample probable cause supporting traceability defendant proceeds crime by targeting defendant... |
is reason think whether covered previous question could sit fairly attentively impartially juror case case document filed page attachment b list of standard final jury instruction these instruction taken current edition september release criminal jury instruction district columbia red book general instruction function ... |
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