UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
DISTRICT OF COLUMBIA,
400 6th Street, N.W, 10th Floor
Washington, D.C. 20001,
Plaintiff,
v.
Case No. ______________
JURY TRIAL DEMANDED
PROUD BOYS INTERNATIONAL, L.L.C.,
108 Durango Dr.
Aubrey, TX 76227,
OATH KEEPERS,
5130 Fort Apache Rd.
Las Vegas, NV 89148,
RYAN ASHLOCK,
711 S. Spruce Cir.
Gardner, KS 66030-1632,
JOSEPH RANDALL BIGGS,
114 Camino Cir.
Ormond Beach, FL 32174,
MARC ANTHONY BRU,
10013 NE Hazel Dell Ave.
Vancouver, WA 98685-5203,
THOMAS EDWARD CALDWELL,
274 Wadesville Rd.
Berryville, VA 22611,
WILLIAM CHRESTMAN,
16393 S. Sunset St.
Olathe, KS 66062-2707,
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LOUIS ENRIQUE COLON,
131 SW 27th St.
Blue Springs, MO 64015-3342,
DONOVAN RAY CROWL,
216 N Main St.
Woodstock, OH 43084-9700,
NICHOLAS DECARLO,
712 SW Sunset Ln.
Burleson, TX 76028-5220,
CHARLES DONOHOE,
2840 Cole Rd.,
Winston Salem, NC 27107-4510,
KENNETH HARRELSON,
2885 Saint Marks Dr.
Titusville, FL 32780-6743,
ARTHUR JACKMAN,
4030 N. Econlockhatchee Trail
Orlando, Fl. 32817-1327,
JOSHUA JAMES,
1463 Brashiers Chapel Rd.
Arab, AL 35016-2727,
JONATHANPETER KLEIN,
25180 SW Labrousse Rd.
Sherwood, OR 97140-8807,
CHRISTOPHER KUEHNE,
16657 S. Chalet Dr.
Olathe, KS 66062-2513,
CONNIE MEGGS,
14100 SW 101St LN.
Dunnellon, FL 34432-4700,
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KELLY MEGGS,
14100 SW 101St LN.
Dunnellon, FL 34432-4700,
ROBERTO A. MINUTA,
120 Gray LN.,
Prosper, TX 75078-3010,
ETHAN NORDEAN,
31930 169th Ave. SE
Auburn, WA 98092,
NICHOLAS ROBERT OCHS,
3245 Virginia St
Apt 56,
Miami, FL 33133-5250,
BENNIE ALVIN PARKER,
1170 Essex Gln.
Morrow, OH 45152-8486,
SANDRA RUTH PARKER,
1170 Essex Gln.
Morrow, OH 45152-8486,
WILLIAM JOSEPH PEPE,
85 Judson St.
Apt. 2
Beacon, NY 12508,
DOMINIC PEZZOLA,
4039 Lake Ave.
Rochester, NY 14612,
ZACHARY REHL,
3058 Almond St.
Philadelphia, PA 19134-5028,
JON RYAN SCHAFFER,
5162 Timber Ridge Dr.
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Columbus, IN 47201-8816,
DANIEL LYONS SCOTT,
122 W Perry LN
Englewood, FL 34223-2943,
LAURA STEELE,
249 Newcastle Ct.
Thomasville, NC 27360-7175,
HENRY “ENRIQUE” TARRIO,
5730 SW 142 Ct.
Miami, FL 33184,
JESSICA MARIE WATKINS,
2586 Hickory Mill Dr.
Hilliard, OH 43026-9464,
CHRISTOPHER JOHN WORRELL,
282 Stanhope Cir.
Naples, FL 34104-0810,
GRAYDON YOUNG,
7147 Lago St.,
Sarasota, FL 34241
AND
JOHN AND JANE DOES 1-50
Defendants.
COMPLAINT
1. The District of Columbia (the “District”) brings this action against Proud Boys
International, L.L.C. (“Proud Boys” or “PBI”), the Oath Keepers (“Oath Keepers”), their
leadership, certain of their members, and others, for conspiring to terrorize the District by planning,
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promoting, and participating in the violent January 6, 2021, attack on the United States Capitol
Building (the “Capitol”).
NATURE OF THIS ACTION
2. Following the 2020 Presidential Election, two organizations—the Proud Boys and
the Oath Keepers—through and with their leadership and certain members and affiliates, conspired
to commit acts of violence and attack the United States Congress on January 6, 2021 (the “January
6th Attack” or the “Attack”), with the express purpose of preventing members of Congress and
then Vice President Michael Pence from discharging their official constitutional duties and
declaring Joseph Biden the winner of the 2020 Presidential Election.
3. Over the course of several weeks, the Proud Boys, the Oath Keepers, their
leadership, and certain of their members and affiliates—motivated by a desire to overturn the legal
results of the election and initiate a second term of Donald Trump’s presidency—worked together
to plot, publicize, recruit for, and finance their planned attack.
4. The result of that planning, the January 6th Attack on the Capitol, was not a protest
or a rally. It was a coordinated act of domestic terrorism.
5. Would-be insurgents from across the country came to the District, marched through
its streets, and ultimately gathered at the United States Capitol, ready and eager to carry out a
violent attack on the lawful operation of government.
6. Then, as the Proud Boys, the Oath Keepers, their leadership, and certain of their
members and affiliates had planned, Defendants and others rioted, broke through police barricades,
and physically forced their way into the Capitol. In doing so, they threatened, assaulted, and
injured those who tried to stop them, including officers of the District’s Metropolitan Police
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Department (“MPD”), and incited terror among those inside and around the building, including
members of Congress who were discharging the official duties of their offices.
7. In the wake of this assault, the Capitol was left in shambles, with the District left to
deal with the aftermath of the violent disruption to what should have been the peaceful transition
of presidential power.
8. Through this action, the District seeks to hold the Defendants accountable under
federal laws and the laws of the District of Columbia for the actions committed in furtherance of
their conspiracy. The District seeks compensatory, statutory, and punitive relief, and, by filing
this action, intends to make clear that it will not countenance the use of violence against the
District, including its police officers.
PARTIES
9. Plaintiff District of Columbia: The District is a municipal corporation and is the
local government for the territory constituting the permanent seat of the government of the United
States. The District is represented by and through its chief legal officer, the Attorney General for
the District of Columbia. The Attorney General has general charge and conduct of all legal
business of the District and all suits initiated by and against the District and is responsible for
upholding the public interest. D.C. Code § 1-301.81(a)(1).
10. Defendant Proud Boys International, L.L.C.: Proud Boys is a limited liability
company organized and existing under the laws of Texas at the time of the actions and events
alleged in this Complaint.
1
PBI was created to “establish, maintain, govern, improve and promote
1
In February 2021, after it was sued for another violent attack on a church in the District that preceded the January
6th Attack, PBI’s officers sought to evade service by purporting to dissolve the entity. Under Texas law, PBI continues
to exist for three years from the time its officers filed papers with the Texas government to dissolve the entity. See
T
EX. BUS. ORGS. CODE ANN. § 11.356 (West). Therefore, for purposes of this action, PBI remains a limited liability
company organized and existing under the laws of Texas.
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the welfare of a fraternal order to be known as the ‘Proud Boys.’” The Proud Boys is a U.S.-based
group that promotes and engages in political violence, including in service of its hate-motivated
agenda. PBI is a citizen of Florida, Texas, Colorado, Georgia, Michigan, and Canada.
2
11. Defendant Oath Keepers: The Oath Keepers is a nonprofit corporation
incorporated in Nevada, with its principal place of business in Granbury, Texas. The Oath Keepers
is a militia movement group united by baseless conspiracy theories arising from the idea that the
federal government has been coopted by a nefarious group that is trying to strip United States
citizens of their rights.
Individual Defendants
12. Defendant Ryan Ashlock: Ashlock is a resident and citizen of the state of Kansas.
Ashlock is a member of the Proud Boys. Ashlock was criminally charged and indicted for his role
in perpetrating the January 6th Attack in US v. Kuehne, No. 1:21-cr-00160-TJK, (D.D.C 2021).
The Criminal Complaint (Dkt. 5), Affidavit in Support (Dkt. 5-1), and Kuehne, et al. Indictment
(Dkt. 29) filed against Ashlock are publicly available documents that are hereby incorporated into
the Complaint by reference.
3
13. Defendant Joseph Randall Biggs: Biggs, also known as “Sergeant Biggs,” is a
resident and citizen of the state of Florida. Biggs is a member of the Proud Boys. Biggs was
criminally charged and indicted for his role in perpetrating the January 6th Attack in US v.
Nordean, No. 1:21-cr-00175-TJK (D.D.C. 2021). The Criminal Complaint (Dkt. 1), Affidavit in
2
As a limited liability company, PBI’s citizenship is determined by the citizenship of its members. PBI’s members
are the eight Proud Boys “brothers” who are elected by the membership of the Proud Boys fraternal order to lead the
organization as “Elders.” The Proud Boys’ bylaws list the first chapter of Elders as including Enrique Tarrio of
Florida, Joshua Hall of Texas, Ethan Nordean of Washington, Lucas Rohlfing of Colorado, Heath Hair of Georgia,
Harry Fox of Michigan, Timothy Kelley of Canada, and Patrick William Roberts of Colorado.
3
The documents incorporated by reference can be found at https://statesuniteddemocracy.org/legal/dcvproudboys-
info-legal/, where they are identified by the paragraph number in this Complaint in which they appear.
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Support (Dkt. 1-1), and Nordean, et al. First Superseding Indictment (Dkt. 26) filed against Biggs
are publicly available documents that are hereby incorporated into the Complaint by reference.
14. Defendant Marc Anthony Bru: Bru is a resident and citizen of the state of
Washington. Bru is a member of the Proud Boys. Bru was criminally charged and indicted for
his role in perpetrating the January 6th Attack in US v. Bru, No. 1:21-cr-00352-JEB (D.D.C 2021).
The Criminal Complaint (Dkt. 1), accompanying Statement of Facts (Dkt. 1-1), and Indictment
(Dkt. 12) filed against Bru are publicly available documents that are hereby incorporated into the
Complaint by reference.
15. Defendant Thomas Edward Caldwell: Caldwell is a resident and citizen of the
state of Virginia. Caldwell is an affiliate or member of the Oath Keepers. Caldwell was criminally
charged and indicted for his role in perpetrating the January 6th Attack in US v. Caldwell,
No. 1:21-cr-00028-APM (D.D.C. 2021). The Watkins, et al. Amended Complaint (Dkt. 1),
Affidavit in Support (Dkt 1-1), and Caldwell, et al. Fifth Superseding Indictment (Dkt. 328) filed
against Caldwell are publicly available documents that are hereby incorporated into the Complaint
by reference.
16. Defendant William Chrestman: Chrestman is a resident and citizen of the state
of Kansas. Chrestman is a member of the Proud Boys. Chrestman was criminally charged and
indicted for his role in perpetrating the January 6th Attack in US v. Kuehne, No. 1:21-cr-00160-
TJK (D.D.C. 2021). The Criminal Complaint, Affidavit in Support, and Kuehne, et al. Indictment
(Dkt. 29) filed against Chrestman are publicly available documents that are hereby incorporated
into the Complaint by reference.
17. Defendant Louis Enrique Colon: Colon is a resident and citizen of the state of
Missouri. Colon is a member or affiliate of the Proud Boys. Colon was criminally charged and
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indicted for his role in perpetrating the January 6th Attack in US v. Kuehne, No. 1:21-cr-00160-
TJK (D.D.C. 2021). The Kuehne, et al. Criminal Complaint, Affidavit in Support, and Kuehne, et
al. Indictment (Dkt. 29) filed against Colon are publicly available documents that are hereby
incorporated into the Complaint by reference.
18. Defendant Donovan Ray Crowl: Crowl is a resident and citizen of the state of
Ohio. Crowl is a member of the Oath Keepers. Crowl was criminally charged and indicted for his
role in perpetrating the January 6th Attack in US v. Caldwell, No. 1:21-cr-00028-APM (D.D.C.
2021). The Watkins, et al. Amended Complaint (Dkt. 1), Affidavit in Support (Dkt 1-1), and
Caldwell, et al. Fifth Superseding Indictment (Dkt. 328) filed against Crowl are publicly available
documents that are hereby incorporated into the Complaint by reference.
19. Defendant Nicholas DeCarlo: DeCarlo, also known as “Nick DeCarlo” or “Nick
Lambaste,” is a resident and citizen of the state of Texas. DeCarlo is a member or affiliate of the
Proud Boys. DeCarlo was criminally charged and indicted for his role in perpetrating the January
6th Attack in US v. DeCarlo, No. 1:21-cr-00073-BAH (D.D.C. 2021). The Criminal Complaint
(Dkt. 1), accompanying Statement of Facts (Dkt. 1-1), and Indictment (Dkt. 17) filed against
DeCarlo are publicly available documents that are hereby incorporated into the Complaint by
reference.
20. Defendant Charles Donohoe: Donohoe is a resident and citizen of the state of
North Carolina. Donohoe is a member of the Proud Boys. Donohoe was criminally charged and
indicted for his role in perpetrating the January 6th Attack in US v. Nordean, No. 1:21-cr-00175-
TJK (D.D.C. 2021). The Nordean, et al. First Superseding Indictment (Dkt. 26) filed against
Donohoe is a publicly available document that is hereby incorporated into the Complaint by
reference.
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21. Defendant Kenneth Harrelson: Harrelson is a resident and citizen of the state of
Florida. Harrelson is a member of the Oath Keepers. Harrelson was criminally charged and
indicted for his role in perpetrating the January 6th Attack in US v. Caldwell, No. 1:21-cr-00028-
APM (D.D.C. 2021). The Criminal Complaint (Dkt. 1), Statement of Facts (Dkt. 1-1), and
Caldwell, et al. Fifth Superseding Indictment (Dkt. 328) filed against Harrelson are publicly
available documents that are hereby incorporated into the Complaint by reference.
22. Defendant Arthur Jackman: Jackman is a resident and citizen of the state of
Florida. Jackman is a member of the Proud Boys. Jackman was criminally charged and indicted
for his role in perpetrating the January 6th Attack in US v. Jackman, No. 1:21-cr-00378-TJK
(D.D.C. 2021). The Criminal Complaint (Dkt. 1), Affidavit in Support (Dkt. 1-1), and Superseding
Indictment (Dkt. 23) filed against Jackman are publicly available documents that are hereby
incorporated into the Complaint by reference.
23. Defendant Joshua James: James is a resident and citizen of the state of Alabama.
James is a member of the Oath Keepers. James was criminally charged and indicted for his role
in perpetrating the January 6th Attack in US v. Caldwell, No. 1:21-cr-00028-APM (D.D.C. 2021).
The Criminal Complaint (Dkt. 1), Affidavit in Support (Dkt. 1-1), and Caldwell, et al. Fifth
Superseding Indictment (Dkt. 328) filed against James are publicly available documents that are
hereby incorporated into the Complaint by reference.
24. Defendant Jonathanpeter Klein: Klein is a resident and citizen of the state of
Oregon. Klein is a member of the Proud Boys. Klein was criminally charged and indicted for his
role in perpetrating the January 6th Attack in US v. Klein, No. 1:21-cr-00237-RDM (D.D.C. 2021).
The Indictment (Dkt. 1) filed against Klein is a publicly available document that is hereby
incorporated into the Complaint by reference.
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25. Defendant Christopher Kuehne: Kuehne is a resident and citizen of the state of
Kansas. Kuehne is a member or affiliate of the Proud Boys. Kuehne was criminally charged and
indicted for his role in perpetrating the January 6th Attack in US v. Kuehne, No. 1:21-cr-00160-
TJK (D.D.C. 2021). The Kuehne et al. Criminal Complaint, Affidavit in Support, and Kuehne, et
al. Indictment (Dkt. 29) are publicly available documents that are hereby incorporated into the
Complaint by reference.
26. Defendant Connie Meggs (“C. Meggs”): C. Meggs is a resident and citizen of
the state of Florida. C. Meggs is a member of the Oath Keepers. C. Meggs was criminally charged
and indicted for her role in perpetrating the January 6th Attack in US v. Caldwell, No. 1:21-cr-
00028-APM (D.D.C. 2021). The Meggs et al. Criminal Complaint (Dkt. 1), Affidavit in Support
(Dkt. 1-1), and Caldwell, et al. Fifth Superseding Indictment (Dkt. 328) filed against C. Meggs are
publicly available documents that are hereby incorporated into the Complaint by reference.
27. Defendant Kelly Meggs (“K. Meggs”): K. Meggs is a resident and citizen of the
state of Florida and is the self-described leader of the Florida chapter of the Oath Keepers. K.
Meggs was criminally charged and indicted for his role in perpetrating the January 6th Attack in
US v. Caldwell, No. 1:21-cr-00028-APM (D.D.C. 2021). The Meggs et al. Criminal Complaint
(Dkt. 1), Affidavit in Support (Dkt. 1-1), and Caldwell, et al. Fifth Superseding Indictment (Dkt.
328) filed against K. Meggs are publicly available documents that are hereby incorporated into the
Complaint by reference.
28. Defendant Roberto A. Minuta: Minuta is a resident and citizen of the state of
Texas. Minuta is a member of the Oath Keepers. Minuta was criminally charged and indicted for
his role in perpetrating the January 6th Attack in US v. Caldwell, No. 1:21-cr-00028-APM (D.D.C.
2021). The Criminal Complaint (Dkt. 1), Affidavit in Support (Dkt. 1-1), and Caldwell, et al. Fifth
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Superseding Indictment (Dkt. 328) filed against Minuta are publicly available documents that are
hereby incorporated into the Complaint by reference.
29. Defendant Ethan Nordean: Nordean, also known as “Rufio Panman,” is a
resident and citizen of the state of Washington. Nordean is the self-described “Sergeant-at-Arms”
of the Seattle chapter of the Proud Boys. Nordean was criminally charged and indicted for his role
in perpetrating the January 6th Attack in US v. Nordean et al., No. 1:21-cr-00175-TJK (D.D.C.
2021). The Criminal Complaint (Dkt. 6), Affidavit in Support (Dkt. 6-1), and Nordean, et al. First
Superseding Indictment (Dkt. 26) filed against Nordean are publicly available documents that are
hereby incorporated into the Complaint by reference.
30. Defendant Nicholas Robert Ochs: Ochs is a resident and citizen of the state of
Hawaii. Ochs is a founding member of the Proud Boys Hawaii chapter. Ochs was criminally
charged and indicted for his role in perpetrating the January 6th Attack in US v. DeCarlo, No.
1:21-cr-00073-BAH (D.D.C. 2021). The Criminal Complaint (Dkt. 1), Affidavit in Support
(Dkt. 1-1), and Indictment (Dkt. 17) filed against Ochs are publicly available documents that are
hereby incorporated into the Complaint by reference.
31. Defendant Bennie Alvin Parker (“B. Parker”): B. Parker is a resident and citizen
of the state of Ohio. B. Parker is a member or affiliate of the Oath Keepers. B. Parker was
criminally charged and indicted for his role in perpetrating the January 6th Attack in US v.
Caldwell, No. 1:21-cr-00028-APM (D.D.C. 2021). The Criminal Complaint (Dkt. 1), Affidavit in
Support (Dkt. 1-1), and Caldwell, et al. Fifth Superseding Indictment (Dkt. 328) filed against B.
Parker are publicly available documents that are hereby incorporated into the Complaint by
reference.
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32. Defendant Sandra Ruth Parker (“S. Parker”): S. Parker is a resident and citizen
of the state of Ohio. S. Parker is a member or affiliate of the Oath Keepers. S. Parker was
criminally charged and indicted for her role in perpetrating the January 6th Attack in US v.
Caldwell, No. 1:21-cr-00028-APM (D.D.C. 2021). The Criminal Complaint (Dkt. 1), Affidavit in
Support (Dkt. 1-1), and Caldwell, et al. Fifth Superseding Indictment (Dkt. 328) filed against S.
Parker are publicly available documents that are hereby incorporated into the Complaint by
reference.
33. Defendant William Joseph Pepe: Pepe is a resident and citizen of the state of
New York. Pepe is a member of the Proud Boys. Pepe was criminally charged and indicted for
his role in perpetrating the January 6th Attack in US v. Pezzola, No. 1:21-cr-00052-TJK (D.D.C.
2021). The Criminal Complaint (Dkt. 1), accompanying Statement of Facts (Dkt. 1-1), and
Superseding Indictment (Dkt. 34) filed against Pepe are publicly available documents that are
hereby incorporated into the Complaint by reference.
34. Defendant Dominic Pezzola: Pezzola, also known as “Spaz” or “Spazzo,” is a
resident and citizen of the state of New York. Pezzola is a member of the Proud Boys. Pezzola
was criminally charged and indicted for his role in perpetrating the January 6th Attack in US v.
Pezzola, No. 1:21-cr-00052-TJK (D.D.C. 2021). The Criminal Complaint (Dkt. 1), Affidavit in
Support (Dkt. 1-1), and Superseding Indictment (Dkt. 34) filed against Pezzola are publicly
available documents that are hereby incorporated into the Complaint by reference.
35. Defendant Zachary Rehl: Rehl is a resident and citizen of the state of
Pennsylvania. Rehl is the president of the Philadelphia Proud Boys chapter, and a member of the
Proud Boys. Rehl was criminally charged and indicted for his role in perpetrating the January 6th
Attack in US v. Nordean, No. 1:21-cr-00175-TJK (D.D.C. 2021). The Nordean, et al. First
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Superseding Indictment (Dkt. 26) filed against Rehl is a publicly available document that is hereby
incorporated into the Complaint by reference.
36. Defendant Jon Ryan Schaffer: Schaffer is a resident and citizen of the state of
Indiana. Schaffer is a founding, lifetime member of the Oath Keepers. Schaffer was criminally
charged and indicted for his role in perpetrating the January 6th Attack in US v. Schaffer, No. 1:21-
cr-00306-APM (D.D.C. 2021). In connection with a promise to cooperate with investigators and
potentially testify in criminal cases related to the conspiracy to commit the January 6th Attack,
Schaffer pleaded guilty to the entire Statement of Offense in the criminal action brought against
him, which included two felony offenses: (1) trespass of the Capitol while armed with a deadly
or dangerous weapon and (2) obstruction of an official proceeding of Congress. The Criminal
Complaint (Dkt. 1) filed against Schaffer—as well as Schaffer’s Plea Agreement (Dkt. 29) and the
accompanying Statement of Offense (Dkt. 30) describing his conduct—are publicly available
documents that are hereby incorporated into the Complaint by reference.
37. Defendant Daniel Lyons Scott: Scott, also known as “Milkshake,” is a resident
and citizen of the state of Florida. Scott is a member of the Proud Boys and has a tattoo of the
organization’s name on his upper arm. Scott was criminally charged and indicted for his role in
perpetrating the January 6th Attack in US v. Scott, No. 1:21-cr-00499-EGS (D.D.C. 2021). The
Criminal Complaint (Dkt. 1), accompanying Statement of Facts (Dkt. 1-1), and Indictment (Dkt.
18) filed against Scott are publicly available documents that are hereby incorporated into the
Complaint by reference.
38. Defendant Laura Steele: Steele is a resident and citizen of the state of North
Carolina. Steele is a member of the Florida chapter of the Oath Keepers. Steele was criminally
charged and indicted for her role in perpetrating the January 6th Attack in US v. Caldwell, No.
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1:21-cr-00028-APM (D.D.C. 2021). The Meggs et al. Criminal Complaint (Dkt. 1), Affidavit in
Support (Dkt. 1-1), and Caldwell, et al. Fifth Superseding Indictment (Dkt. 328) filed against
Steele are publicly available documents that are hereby incorporated into the Complaint by
reference.
39. Defendant Henry “Enrique” Tarrio: Tarrio is a resident and citizen of the state
of Florida. Tarrio has been a member of the Proud Boys since 2017 and has been the Chairman—
the most senior role in, and the face of, the organization—since November 20, 2018. As the Proud
Boys’ Chairman, Tarrio, in coordination with the Proud Boys Elders, acts as the voice of the
organization on matters of public concern, according to the Proud Boys’ Bylaws.
40. Defendant Jessica Marie Watkins: Watkins is a resident and citizen of the state
of Ohio. Watkins is a member of the Oath Keepers. Watkins was criminally charged and indicted
for her role in perpetrating the January 6th Attack in US v. Caldwell, No. 1:21-cr-00028-APM
(D.D.C. 2021). The Watkins et al. Criminal Complaint (Dkt. 1), Affidavit in Support (Dkt. 1-1),
and Caldwell, et al. Fifth Superseding Indictment (Dkt. 328) filed against Watkins are publicly
available documents that are hereby incorporated into the Complaint by reference.
41. Defendant Christopher John Worrell: Worrell is a resident and citizen of the
state of Florida. Worrell is a member of the Proud Boys. Worrell was criminally charged and
indicted for his role in perpetrating the January 6th Attack in US v. Worrell, No. 1:21-cr-00292-
RCL (D.D.C. 2021). The Criminal Complaint (Dkt. 1), accompanying Statement of Facts (Dkt.
1-1), and Indictment (Dkt. 31) filed against Worrell are publicly available documents that are
hereby incorporated into the Complaint by reference.
42. Defendant Graydon Young: Young is a resident and citizen of the state of Florida.
Young is a member of the Florida chapter of the Oath Keepers. Young was criminally charged
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and indicted for his role in perpetrating the January 6th Attack in US v. Caldwell, No. 1:21-cr-
00028-APM (D.D.C. 2021). Young subsequently pleaded guilty to the entire Statement of Offense
in the criminal action brought against him. The Criminal Complaint (Dkt. 1) and Affidavit in
Support (Dkt. 1-1) filed against Young—as well as Young’s Plea Agreement (Dkt. 249) and the
Statement of Offense (Dkt. 250) describing Young’s conduct—are publicly available documents
that are hereby incorporated into the Complaint by reference.
43. Defendants John and Jane Does 1−50: Upon information and belief, Defendants
John and Jane Does 1−50 are individuals whose names and addresses are unknown and who
planned, conspired to carry out, and executed the January 6th Attack. The District expressly
excludes from John and Jane Does 1−50 any citizens of the District.
44. Defendants Ashlock, Biggs, Bru, Caldwell, Chrestman, Colon, Crowl, DeCarlo,
Donohoe, Harrelson, Jackman, James, Klein, Kuehne, C. Meggs, K. Meggs, Minuta, Nordean,
Ochs, B. Parker, S. Parker, Pepe, Pezzola, Rehl, Schaffer, Scott, Steele, Tarrio, Watkins, Worrell,
Young, and John and Jane Does 1−50 are collectively referenced herein as the “Individual
Defendants.”
45. As alleged more fully below, the Individual Defendants conspired together and
participated in planning, promoting, financing, organizing, and carrying out the January 6th
Attack. Defendants Proud Boys and Oath Keepers also participated in the conspiracy, playing a
key role in the planning, promotion, financing, organizing, and carrying out of the January 6th
Attack by lending their experience—and in some cases, organizational resources—to the planned
January 6th Attack.
46. The Defendants are jointly and severally liable for the damages suffered by the
District as a result of their unlawful conspiracy.
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JURISDICTION AND VENUE
47. The Court has jurisdiction over this action under 28 U.S.C. § 1331 and over the
District’s state law claims under 28 U.S.C. § 1367.
48. Additionally, and in the alternative, this Court has jurisdiction over this entire
action under 28 U.S.C. § 1332 because there is complete diversity among the parties and the
amount in controversy exceeds $75,000.
49. Venue is properly in this District pursuant to 28 U.S.C. § 1391(b) because a
substantial part of the events giving rise to Plaintiff’s claims occurred in this District.
FACTUAL ALLEGATIONS
I. Both the Proud Boys and the Oath Keepers Have a Long History of Inciting and
Engaging in Coordinated Violence.
50. The violence perpetrated by the Proud Boys, Oath Keepers, their leadership, and
certain of their members and affiliates through the January 6th Attack—while unique in its severity
and scope—is far from an isolated occurrence. Violence is an inextricable part of both
organizations and a common link between them.
A. The Proud Boys’ Organization and History of Violence
51. The Proud Boys is a U.S.-based group that has repeatedly and persistently
instigated, incited, and executed acts of violence and intimidation against their perceived enemies.
The Canadian government has designated the Proud Boys as a terrorist entity.
52. Violence has been a key component of the Proud Boys’ mission and conduct since
its creation. PBI’s original Constitution and Bylaws, which set forth the rules and procedures
governing the Proud Boys fraternal order, mandated that membership be limited to men who
undergo violent initiation rituals, including getting beaten by other members. The highest level of
membership, for example, required “a material sacrifice or service,” which Proud Boys founder
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Gavin McInnes has described as getting arrested or committing a violent act in support of the
Proud Boys.
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53. As a result, when Proud Boys members assemble in large groups at public
demonstrations, violence becomes more likely.
54. The Proud Boys members have a long-standing practice of instigating and
committing acts of violence under the guise of self-defense by responding to small slights with
coordinated, brutal force.
55. For example, on October 12, 2018, 10 men connected to the Proud Boys were
arrested following violent attacks on protestors outside of the Metropolitan Republican Club on
the Upper East Side of Manhattan. The Proud Boys involved in those attacks punched, kicked,
and “stomped” four protestors who were wearing black clothes and masks. The Proud Boys later
claimed that their members were assaulted by these protestors, but security camera footage
revealed that a Proud Boys member initiated the street violence.
56. Similarly, in April 2019, Proud Boys members used messaging platforms to
coordinate and plan violence in advance of an April 2019 rally in Providence, Rhode Island. As
one of the Proud Boys instructed before that rally on the encrypted chat service, Telegram: “If
any contact is made with you, that’s assault. If they take your hat, spray you with silly string, spit,
push . . . . It’s assault. We need to have all our guys there before we retaliate though if we can.
The cops aren’t going to let us fight long. We need to inflict as much damage as possible in the
time we have.”
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In October 2018, as law enforcement sought members of the Proud Boys for their role in a fight outside the
Metropolitan Republican Club, Proud Boys leadership released a “clarified” set of bylaws that purported to contradict
the Proud Boys’ prior, violent rhetoric. The new language asserts: “Any requirement that a brother commit a violent
or illegal act as a condition precedent to receiving a fourth degree is, by this bylaw, abolished.”
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57. A few months later, in advance of an August 2019 rally in Portland, Oregon,
Defendant Biggs suggested that his cohort arm themselves and be prepared for violence. He posted
videos of himself holding a spiked baseball bat, telling the camera: “We’re going to put this to
good use.” He also posed wearing a t-shirt reading: “I’m Just Here for the Violence.”
58. On several occasions in August 2020, Proud Boys members violently confronted
protestors and others in Portland, Oregon, following the police killing of George Floyd in
Minneapolis. The Proud Boys came to the Oregon protests armed with bear mace, clubs, and
firearms. Proud Boys members engaged in multiple acts of violence at the protests, including, on
August 15, 2020, spraying a journalist with bear mace and, on August 22, 2020, charging and
severely beating protestors affiliated with the movement against police brutality.
59. The Proud Boys’ acts of violence are often anticipated, instigated, coordinated, and
encouraged by those elected to the organization’s leadership.
60. Under the group’s Bylaws, eight “brothers” are elected by the membership of the
Proud Boys fraternal order to lead the organization as “Elders.” These eight Elders (together, the
“Elders Chapter”) are tasked with taking “legal action on behalf of the fraternity,” holding
“property in the name of the national fraternity and collect[ing] suggested voluntary dues for the
benefit of the fraternity or for charity,” “establish[ing] organizations, funds or trusts to which both
members and non-members of the fraternity could contribute for charitable purposes,” and
generally serving as “the final authority on chapter status, membership criteria, and rituals of the
fraternity.”
61. The Elders Chapter is also responsible for electing the “Chairman of the Proud
Boys,” and, “through the Chairman, serving as the voice of the fraternity as a whole on matters of
public concern.”
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62. The Chairman holds the most senior role in the organization. The Bylaws of PBI
vest the Chairman with the sole authority to speak for the Proud Boys fraternal order, which
includes PBI, the Elders Chapter, and all other chapters established throughout the country.
63. The Proud Boys’ membership is controlled by local chapter leadership that reports
to national leaders. While the organization’s membership is not publicly disclosed, members
frequently self-identify on social media or by appearing at events organized by Proud Boys or their
affiliates, often in apparel that displays their affiliation, including clothing in the Proud Boys’
official colors, black and yellow.
B. The Oath Keepers’ Organization and History of Violence.
64. Oath Keepers is a militia movement group united by the view that the federal
government has been coopted by a nefarious group trying to strip United States citizens of their
rights.
65. Oath Keepers and its members galvanize their supporters by perpetuating perceived
threats posed by the federal government, including that the federal government will use a major
destabilizing event—like a pandemic or terrorist attack—as an excuse to institute martial law,
force citizens into detention camps, and strip them of their right to keep and bear arms in order to
enslave them under a one-world socialist government, which its members refer to as the “The New
World Order.”
66. Oath Keepers and its members present themselves as a bulwark and a militia against
these imagined and manufactured threats. The group’s members are known for being heavily
armed, and for being willing to engage in armed confrontations with the government and with
people and groups they perceive as supporting government actions, including people who have
political beliefs that differ from those of Oath Keepers.
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67. The rules and procedures governing Oath Keepers are set forth in the group’s
Bylaws.
68. Oath Keepers leadership—including the Board of the Oath Keepers, which is made
up of the founder of the organization, Stewart Rhodes, and at least 10 additional trustees—has
repeatedly urged its members to be prepared to fight in what they perceive to be an impending
civil war.
69. In addition to national leadership, on the local level, many Oath Keepers self‐
organize and form official, semi‐official, or informal groupings of Oath Keepers. Rhodes
described the “action arm of the Oath Keepers” to be county-level and urged local militias to self-
organize.
70. Oath Keepers members and affiliates often demonstrate their commitment to the
organization by evincing a willingness to engage in armed confrontation. One Oath Keepers
member justified the use of these tactics, noting: “I like to use the Revolutionary War as an
example. The militias were there, well-armed and organized, not looking to pick a fight but ready
when it happened.”
71. Like members and affiliates of the Proud Boys, members and affiliates of Oath
Keepers have been arrested in connection with, and convicted of, a wide range of violent criminal
activities, including various firearms violations, conspiracy to impede federal workers, possession
of explosives, and threatening public officials.
72. In 2010, Oath Keepers member Matthew Fairfield was sentenced to 20 years in
prison for storing a live napalm bomb at his home and for storing other explosives at his friend’s
home in Ohio.
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73. In 2014, members of Oath Keepers participated in an armed standoff at the Bundy
Ranch in Nevada. Members came from Arizona and New Hampshire to take up an armed defense
of Cliven Bundy, a Nevada rancher who was defying an order from the federal Bureau of Land
Management to remove his animals from federal land. The members of Oath Keepers who joined
Bundy aimed their weapons at Bureau of Land Management agents until the agents retreated from
the standoff.
74. The same year, members of Oath Keepers came to Ferguson, Missouri, when the
city was under a state of emergency after the police shooting of Michael Brown. Oath Keepers
members in Ferguson claimed to be protecting private businesses from looting and arson. They
took tactical positions on top of buildings while armed with firearms in positions across the city.
The group eventually dispersed, but only after local police threatened arrest.
75. Members of Oath Keepers reconvened in Ferguson on the anniversary of Michael
Brown’s death in 2015, dressed in military garb and openly brandishing firearms in the streets after
officials had declared a state of emergency.
76. Also in 2015, a federal grand jury indicted a member of Oath Keepers, Daniel
Hayden, for tweeting threats of a violent attack on Oklahoma state government officials, writing
“the WAR wWIL [sic] start on the stepes [sic] of the Oklahoma State Capitol. I will cast the first
stone…” and “START THE KILLING NOW!”
77. On August 8, 2018, Oath Keepers announced and began to raise funds for its new
“Spartan Training Group,” which was established to train as a vigilante force. As Oath Keepers
described:
Our goal is to form training groups in as many states as possible. To
join your local training group, membership in Oath Keepers will not
be required, but will be encouraged. In the era of the Founding
Fathers, they formed “training bands” with the express goal of
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training the public up to the high standards of the militia. The
Spartan program is the modern equivalent. Our qualified and
experienced military, law enforcement and first responder veterans
will train the American people up to a similar high standard. Such
individuals will form a pool of trained, organized volunteers who
will be able to serve as the local militia under the command of
a patriotic governor loyal to the Constitution, or if called upon by
President Trump to serve the nation.
Short of being called upon by the President, governor, local Sheriff,
or to provide disaster relief, members will be trained to serve as
volunteer security for local events, churches and effective
neighborhood watches for their communities.
78. During the summer of 2020, Oath Keepers leader and founder Stewart Rhodes
encouraged members of Oath Keepers to make a showing of force at demonstrations against police
brutality. Oath Keepers who attended those events were a self-appointed vigilante force to protect
businesses and private property, wearing military gear and carrying weapons in an effort to
intimidate the demonstrators.
79. A founding, lifetime member of Oath Keepers—Defendant Jon Ryan Schaffer—
was the first person to plead guilty to criminal charges arising from the January 6th Attack.
Schaffer pleaded guilty to two felony offenses: (1) trespass of the Capitol while armed with a
deadly or dangerous weapon, and (2) obstruction of an official proceeding of Congress.
80. In connection with his plea deal, Schaffer admitted to the contents of a Statement
of Offense, which included an admission that he unlawfully entered the Capitol building on
January 6th “with the purpose of influencing, affecting, and retaliating against the conduct of
government by stopping or delaying the Congressional proceeding by intimidation or coercion.”
II. The Proud Boys’ and Oath Keepers’ Efforts to Incite Coordinated Violence
Coalesced around the 2020 Presidential Election.
81. The Proud Boys and Oath Keepers used the lead-up to the 2020 Presidential
Election—and the immediate aftermath of former President Donald Trump’s loss—to recruit new
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members, threaten their detractors with violence, and mobilize forces to engage in acts of violence,
including in connection with their ultimate conspiracy to commit the January 6th Attack.
A. Before the Election, the Proud Boys, Oath Keepers, Their Leadership, and
Some of Their Members and Affiliates Readied Themselves to Incite
Violence.
82. In the weeks leading up to the 2020 Presidential Election, the Proud Boys, Oath
Keepers, their leadership, and certain members and affiliates of both groups openly advertised
their willingness to use violence to support their political agenda, including their efforts to reelect
then-President Trump.
83. On September 29, 2020, during the first presidential debate of his reelection
campaign, President Trump specifically addressed the Proud Boys, stating: “Proud Boys, stand
back and stand by, but I’ll tell you what, somebody’s got to do something about Antifa and the
left, because this is not a right-wing problem. This is a left-wing problem.”
84. During and following the debate, the Proud Boys leadership immediately took to
the social media application Parler to show support for a violent response following President
Trump’s statement.
85. Consistent with the organizational Defendants’ plan to leverage President Trump’s
rhetoric to mobilize the groups’ followers, Defendant Biggs, a prominent Proud Boys leader,
publicly interpreted President Trump’s words on Parler, suggesting that the President’s words
should be interpreted to encourage violence: “Trump basically said to go fuck them up! [T]his
makes me so happy.” Proud Boys’ Chairman Enrique Tarrio echoed Biggs’s sentiment, posting:
“Standing by sir.”
86. Oath Keepers saw its members as a militia that could be “called forth ‘to execute
the Laws of the Union, suppress Insurrections and repel Invasions,’” including to preserve former
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President Trump’s power: “All he has to do is call us up. We WILL answer the call.” Consistent
with this messaging, Oath Keepers pledged to have “volunteer security teams” at Trump rallies
and on Election Day to “protect” Trump voters.
87. Based on past behavior, Oath Keepers members were willing to uphold that pledge
using violence. On October 20, 2020, in an online chat room for members of Oath Keepers,
members discussed their course of action if President Biden were to be elected. As one member
made clear, the plan would include “[c]hoos[ing] a side and fight[ing], looking down the sights of
a rifle at our fellow Americans.”
88. Oath Keepers publicly trumpeted the idea that members were standing ready to
engage in a civil war, tweeting from the group’s account: “We ARE on the verge of a HOT civil
war. Like in 1859. That’s where we are. And the Right has ZERO trust or respect for anything
the left is doing. We see THEM as illegitimate too.”
B. After the Election, The Proud Boys, Oath Keepers, Their Leadership, and
Some of Their Members and Affiliates Used President Trump’s Loss to
Recruit New Members.
89. On November 4, 2020, President Trump falsely declared that he had won the
presidential election, even though a significant number of votes had yet to be counted. On
November 7, 2020, most media outlets began projecting President Biden as the winner of the 2020
presidential election.
90. After President Trump’s loss, the Proud Boys and Oath Keepers immediately began
trumpeting their plans to bring terror and violence to the District and recruiting others to join their
efforts.
91. On November 7, 2020, the Proud Boys’ Chairman, Enrique Tarrio, posted to Parler,
“we’re rolling out” and stated that former President Trump’s “Standby order has been rescinded.”
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Also on November 7, 2020, Proud Boys member Daniel Goodwyn, who would eventually join the
Defendants on January 6, 2021, posted on Twitter: “Stand back and stand by! Show up at your
state Capitol at noon today local time. Await orders from our Commander in Chief.
#StopTheSteal!”
92. The Oath Keepers also increased efforts to recruit new members. On November 9,
2020, Oath Keepers member Defendant Watkins sent text messages to individuals who had
expressed interest in joining the paramilitary group she formed, which she called the “Ohio State
Regular Militia.” In these messages, Watkins stated, among other things, that the militia had a
week-long “Basic Training class coming up in the beginning of January,” and Watkins told one
recruit, “I need you fighting fit by innaugeration [sic].” Watkins told another individual: “It’s a
military style basic, here in Ohio, with a Marine Drill Sergeant running it.” The same day, Watkins
also asked a recruit to download Zello, an app that allows a cellphone to operate like a push-to-
talk walkie-talkie, saying her group uses it “for operations.”
93. Also on November 9, 2020, several Oath Keepers members attended an online
meeting on GotoMeeting where Oath Keepers leader Rhodes said: “We’re going to defend the
president, the duly elected president, and we call on him to do what needs to be done to save our
country. Because if you don’t guys, you’re going to be in a bloody, bloody civil war, and a bloody
– you can call it an insurrection or you can call it a war or fight.” Rhodes further called upon his
followers to go to the District to let President Trump know “that the people are behind him.” He
continued, “I do want some Oath Keepers to stay on the outside, and to stay fully armed and
prepared to go in armed, if they have to. . . . So our posture’s gonna be that we’re posted outside
of DC, um, awaiting the President’s orders. . . . We hope he will give us the orders. We want him
to declare an insurrection, and to call us up as the militia.”
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94. Oath Keepers member Hackett and Defendants Harrelson, Watkins, K. Meggs, and
others attended the meeting hosted by Rhodes. After Rhodes finished speaking, Watkins and K.
Meggs asked questions and made comments about the types of weapons that were legal in the
District of Columbia. The same day, K. Meggs posted on Facebook, lamenting that he saw people
“talking” but not “doing.” K. Meggs invited others to contact him if they wished to “join the
fight”: “This fight is face to face, not far away. If your [sic] ready to really join the fight [direct
message] me.”
95. On November 16, 2020, Defendant Nordean posted that “[a]ny militia groups” in
the Pacific Northwest area should contact him on an encrypted social media application to
coordinate.
96. On November 17, 2020, an Oath Keepers’ recruit asked Defendant Watkins what
she thought would happen in 2021. Watkins responded that “Biden may still yet be our President.
If he is, our way of life as we know it is over. Our Republic would be over. Then it is our duty as
Americans to fight, kill, and die for our rights.”
97. On November 23, 2020, Defendant Caldwell sent a text message to Defendant
Watkins previewing the violence to come. Caldwell remarked: “I don’t know what will happen
but like you I am very worried about the future of our country.” He continued: “I believe we will
have to get violent to stop this, especially the antifa maggots who are sure to come out en masse
even if we get the Prez for 4 more years. Stay sharp and we will meet again. You are my kinda
person and we may have to fight next time. . . .”
98. On December 3, 2020, Defendant Young emailed a membership application to the
Oath Keepers’ Florida chapter, writing that he was “looking to get involved in helping.” Another
Oath Keeper, Joseph Bernard Hackett, responded on December 19, 2020, stating: “I believe we
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only need to do this when important info is at hand like locations, identities, Ops planning.”
Hackett attached a photo to the email of a notepad with cursive writing stating: “Secure Comms
Test. Good talk tonight guys! Rally Point in Northern Port Charlotte at Grays if transportation is
possible. All proton mails [(a type of encrypted email service)]. May consider a [rally point] that
won’t burn anyone. Comms – work in progress. Messages in cursive to eliminate digital reads.
Plans for recruitment and meetings.”
99. On December 19, 2020, Young started to recruit new Oath Keepers members
himself, posting in a Facebook group: “Please check out Oath Keepers as a means to get more
involved. Recruiting is under way. [Direct message] me if you want more info.”
C. The Proud Boys, Oath Keepers, Their Leadership, and Certain of Their
Members and Affiliates Used Coordinated Violence at Post-Election Events
to Intimidate the Public and the Government.
100. The Proud Boys’ and Oath Keepers’ coordination efforts escalated with both groups
mobilizing large forces to wreak havoc on the District at post-election events that previewed the
January 6th Attack.
101. The first of these events was the “Million MAGA March,” which was held on
November 14, 2020, and attended by Oath Keepers, Proud Boys, and members and affiliates from
both groups. Violent clashes between self-identified Proud Boys members and protestors broke
out that night.
102. The violence increased at the next event: the “Stop the Steal” rally held on
December 12, 2020. Oath Keepers and Proud Boys attended the rally in droves. In one
particularly disturbing incident on the National Mall, a large group of Proud Boys surrounded a
man and punched and kicked him.
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103. After engaging in violence against protestors, law enforcement, and others, the
Proud Boys fanned out across the city to steal and deface anti-racism signs that had been posted
by District residents and businesses. They publicly vandalized and destroyed these signs—
including at least one that Defendant Tarrio took credit for lighting on fire—while their supporters
celebrated. See Figure 1.
Figure 1. Proud Boys members burn racial justice banners in the District
104. During the “Stop the Steal” rally, Oath Keepers leader and founder Stewart Rhodes
gave a speech on behalf of Oath Keepers in which he called on President Trump to invoke the
Insurrection Act to prevent President Biden from taking office.
105. He threatened that if President Trump failed to do so, “[w]e’re going to have to do
it ourselves later, in a much more desperate, much more bloody war.”
III. Defendants Conspire to Deploy Violent Forces in the District in an Effort to
Frustrate and Undermine the Formal Process Required to Declare a Presidential
Election Winner.
106. Following the Stop the Steal Rally, Proud Boys and Oath Keepers members openly
acknowledged an alliance between their two groups and began to plan and coordinate violence,
hoping to maximize their impact through joint efforts on January 6th.
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A. The Defendants Agreed to Form an Alliance and Coordinate Their Actions
for the Planned January 6th Event.
107. On December 19, 2020, at 1:42 a.m., President Trump announced a January 6,
2021, rally in the District, tweeting: “Big protest in D.C. on January 6th. Be there, will be wild!”
108. The date of the rally was not a coincidence: January 6, 2021, was the date on which
members of Congress and the Vice President, as President of the Senate, were required by certain
provisions of the U.S. Constitution and Electoral Count Act of 1887 to count the certified electoral
votes and formally declare the winner of the presidential election.
109. President Trump’s supporters, including Defendants and Defendants’ affiliates,
took to social media, amplifying President Trump’s message, interpreting the tweet as “marching
orders” for Defendants’ scheme to frustrate the final process in the presidential election:
• “Well, shit. We’ve got marching orders, bois [sic].”
• “That’s a marching order if I ever heard one…”
• “THE COMMANDER IN CHIEF HAS ISSUED HIS ORDERS. JANUARY
6TH. WASHINGTON D.C.”
• “No excuses . . . GEOTUS [“God Emperor of the United States”] ISSUED US
OUR MARCHING ORDERS!”
• “If you’ve been waiting for a signal, THAT’S IT.”
110. The Proud Boys and Oath Keepers immediately began working together to
coordinate their efforts at the planned January 6th Attack. On December 19, 2020, Defendant K.
Meggs of the Oath Keepers stated that he had formed an alliance with the Proud Boys and other
groups to “work together” and “shut this shit down.” See Figure 2.
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Figure 3. Defendant K. Meggs discusses plans for violence, including that he is in contact with
the Proud Boys.
114. On the same day, K. Meggs further stated that he would be going to the Capitol to
“make it WILD” and encouraged other members to join him, saying “Gentlemen we are heading
to DC pack your shit!!”
115. On December 25, 2020, Defendant K. Meggs posted another Facebook message
discussing communications with Proud Boys leadership and how Oath Keepers had “orchestrated
a plan with the [P]roud [B]oys.” See Figure 4.
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and weapons, and planning and organizing travel for themselves and their co-conspirators. These
efforts began well before January 6th.
6
1. The Defendants Recruited Participants for the Attack.
118. The Defendants’ efforts to recruit co-conspirators—which began following the
2020 Presidential election—intensified as January 6th approached.
119. Between December 12, 2020 and January 3, 2021, Oath Keepers member
Defendant K. Meggs organized approximately 10 online meetings on GoToMeeting, titled “se
leaders dc 1/6/21 op call,” “dc planning call,” and “florida dc op planning chat.” K. Meggs used
the code name “Gator 1” in these meetings. Oath Keepers member Defendant Harrelson also
participated in these meetings.
120. At the same time, Proud Boys Chairman, Defendant Tarrio, began identifying
himself as a “war time” leader and changed his Parler display name to “Wartime Tarrio.” By the
end of the month, in posts on Parler and Telegram, Tarrio bragged that Proud Boys had already
stopped using a particular hotel as a “hub” in light of the group’s growing size: “With the new
ability I’ve been able to put 1000 boots on the ground we outgrew any single hotel.”
121. Defendant Nordean also used social media to recruit Proud Boys members and
supporters. In early December, he posted, “You can take a hard stand now, or watch as everything
we’ve all built crumble before your eyes and have nothing to leave your children. Enough is
enough.” By the end of the month, Nordean’s message on social media was clear: “Fight now, or
lose everything.”
6
For example, a video posted online by Proud Boys leader Defendant Biggs on January 3, 2021, described the Proud
Boys’ approach to planning its events as follows: “When we set out to do an event, we go alright, what is our main
objective? And that’s the first thing we discuss. We take three months to plan an event. And we go, what’s our main
objective? And then we plan around that, to achieve that main objective, that goal that we want.”
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2. Defendants Coordinated Strategies to Disguise Their Identities and
Plans for the Attack.
122. Defendants’ coordination was not limited to recruiting participants for the Attack;
they also planned strategies to allow them to blend into the crowd and to communicate privately
about the Attack. These efforts were intended to give Defendants a tactical advantage against law
enforcement when they convened in the District on January 6, 2021.
123. In December 2020 and January 2021, the Proud Boys announced on social media
that they would attend the January 6, 2021, rally “incognito.” As Proud Boys leader Defendant
Biggs explained in a social media post in December 2020, the Proud Boys would come to the
District not “in colors” (i.e., the traditional black and yellow worn by Proud Boys members), but
disguised to blend in with other demonstrators in the District.
124. Other members of the Proud Boys made similar posts promoting the same
“incognito” tactic.
125. On December 29, 2020, Proud Boys Chairman Tarrio posted to Parler announcing
that members of the Proud Boys would “turn out in record numbers on Jan 6th but this time with
a twist . . . . We will not be wearing our traditional Black and Yellow. We will be incognito and
we will be spread across downtown DC in smaller teams. And who knows . . . . we might dress in
all BLACK for the occasion.” Law enforcement investigating the January 6th Attack have
attributed Tarrio’s statement about dressing in black as a reference to dressing like “antifa,” whom
the Proud Boys have pegged as their enemy and who are often depicted in the media as dressing
in all black when attending demonstrations.
126. In the same post, Tarrio instructed Proud Boys members to (i) “spread across
downtown D.C. in smaller teams” than in the past, (ii) “conceal your intentions,” (iii) “pose as a
friend, work as a spy,” (iv) “crush your enemy totally,” and (v) “keep others in suspended terror.”
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127. The same day, Defendant Biggs, another Proud Boys leader, posted a similar
message on Parler: “[W]e will not be attending DC in colors. We will be blending in as one of
you. You won’t see us. You’ll even think we are you . . . . We are going to smell like you, move
like you, and look like you. The only thing we’ll do that’s us is think like us! Jan 6th is gonna be
epic.”
128. Defendants also coordinated their strategic methods for secret communication
before and during the Attack. For example, on or around January 3, 2021, Defendants Watkins,
K. Meggs, Young, and Harrelson and other Oath Keepers joined an invitation-only encrypted
Signal group message entitled “OK FL DC OP Jan 6.” Similarly, Defendant James acknowledged
communicating with a fellow Oath Keeper using a burner phone.
7
129. Defendant Young later admitted in his plea agreement that he and others conspiring
to thwart the certification of the presidential election “discussed the need to maintain operational
security and accordingly used encrypted messaging applications to communicate with one
another.”
3. The Defendants Coordinated Collection of Weapons and Tactical
Supplies for the Attack.
130. On December 25, 2020, Defendant K. Meggs shared a list of provisions on
Facebook regarding how to prepare for the planned violence in the District on January 6th. K.
Meggs wrote: “DC is no guns. So mace and gas masks, some batons. If you have armor that’s
good.” In the same post, K. Meggs said: “You can hang with us [Oath Keepers] we will probably
7
A burner phone is an inexpensive, prepaid mobile phone that can be discarded or destroyed when it is no longer
needed. Burner phones can be used to avoid detection by authorities and are difficult to trace and track. They are
commonly purchased with cash to avoid creating a paper trail that would tie the phone number to a specific person.
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be guarding [redacted] or someone during the day but then at night we have orchestrated a plan
with the proud boys. I’ve been communicating with [redacted] the leader[.]”
131. Defendant Rhodes told Defendants K. Meggs, Watkins, and other Oath Keepers to
bring “collapsible batons,” “good hard gloves,” “eye protection,” and helmets. Similarly, K.
Meggs messaged at least one other participant to tell them to bring “mace,” “gas masks,” “batons,”
and “armor.”
132. Other co-conspirators—including Defendants Watkins and Caldwell and their Oath
Keepers cohorts—discussed transporting guns across state lines. And on January 1, 2021, Oath
Keepers member Defendant James messaged an individual on Signal inquiring about bringing
guns into the District. James wrote: “We[’]re working on a Farm location[.] Some are bringing
long rifles some sidearms. . . . I’m bringing sidearm.”
133. The Oath Keepers also created the Quick Reaction Force as a way to bring
additional weaponry and firearms to the Capitol in the event that violent clashes broke out or if
they were called to act by President Trump. Before January 5, 2021, Oath Keepers member
Jonathan Conrad Walden applied to be part of the January 6th Oath Keepers operation, emailing,
“I am interested in the [Quick Reaction Force] team in D.C. I am a former Firefighter, EMT-B
and have a K-9 trained for security patrol (82 lb. German Shepherd named ‘Warrior’). I have a
Jump Bag with Trauma supplies and have ALL the necessary [Second Amendment] gear that the
situation may require. PLEASE ADVISE. As soon as I hear from you I can hit the road to join
up!”
134. Additionally, in the days leading up to the January 6th Attack, Proud Boys members
and affiliates also obtained tactical vests and military-style communications equipment which
could be used during the siege on the Capitol. At the same time, self-described Proud Boys
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“Sergeant-at-Arms” Defendant Nordean used social media to solicit donations of “protective gear”
and “communications equipment” for use in the Attack.
4. The Defendants Coordinated Travel to the District.
135. Defendants and their co-conspirators also coordinated their plans to travel to and
stay in or near the District for the Attack, including by using coordinated efforts to raise money
online to cover transportation and accommodations costs.
136. Defendants’ planning, promotion, and coordination efforts leading to the January
6th Attack also extended to travel logistics, as they sought to ensure that the co-conspirators
traveled together or had nearby hotel accommodations to allow for additional in-person
coordination before convening near the Capitol on January 6, 2021.
137. Defendants Caldwell, Watkins, S. Parker, B. Parker, K. Meggs, and C. Meggs
coordinated their travel, convening at the Comfort Inn Ballston in Arlington, Virginia, each
reserving and paying for hotel accommodations for multiple individuals traveling with them to
join in the January 6th Attack. In a social media message, Defendant Caldwell confirmed that this
is where he would be “Meeting up with Oathkeepers [sic] from North Carolina and Patriot group
from the Shenandoah Valley.”
138. On December 31, 2020, an individual contacted Defendant James via Signal stating
“i have friends not far from DC with a lot of weapons and ammo if you get un trouble i ca. [sic]
Coordinate help.” James responded: “That might be helpful, but we have a shitload of [Quick
Reaction Force] on standby with an arsenal.”
139. Later that day, Defendant James messaged another individual and asked if they
“have a farm location for weapons[.]” The individual responded, “Not that I am aware of yet. If
nothing else, my hotel is in VA and has secured underground parking. About 15-20 minutes
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outside DC, less if you really don’t care about speed limits… would be great if we had someone
with an enclosed truck type vehicle and had a quick response unit just outside the city.” Defendant
James responded, “I agree.”
140. On January 1, 2021, Defendant Caldwell sent a message to Defendant Crowl
recommending a room at the Comfort Inn Ballston for January 5-7, 2021, writing: “This is a good
location and would allow us to hunt at night if we wanted to. I don’t know if Stewie has even
gotten out his call to arms but its [sic] a little friggin late. This is one we are doing on our own.
We will link up with the north Carolina [sic] crew.”
141. Oath Keepers member Defendant Crowl wrote to Defendant Caldwell: “Happy
New year, to you Sir!! Guess I’ll be seeing you soon. Will probably call you tomorrow…mainly
because…I like to know wtf plan is. You are the man Commander.” Around that time, Defendant
Crowl was traveling to the Washington, D.C. area from Ohio, along with Defendants Watkins, S.
Parker, and B. Parker. In another message, Defendant Crowl separately confirmed the reason for
his trip: “been busy planning for this week. . . . We are enroute [sic] to DC right now for a few
days on an Oathkeepers Op.”
142. On January 2, 2021, Defendant Caldwell wrote to Defendant Crowl: “Check with
Cap. I recommended the following hotel to her which STILL has rooms (unbelieveble) [sic].”
Defendant Caldwell then sent a link to the Comfort Inn Ballston, the same hotel that he
recommended to others.
143. As Defendant Caldwell explained further: “Sharon and I are setting up shop there.
Paul has a room and is bringing someone. He will be the quick reaction force. Its [sic] going to
be cold. We need a place to spend the night before minimum. . . . I will probably do pre-strike on
the 5th though there are things going on that day. Maybe can do some night hunting. Oathkeeper
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[sic] friends from North Carolina are taking commercial buses up early in the morning on the 6th
and back same night. Paul will have the goodies in case things go bad and we need to get heavy.”
8
144. Defendant C. Meggs has since confessed that she attended a firearms class with
Defendants K. Meggs and Harrelson in preparation for the January 6th Attack.
C. As January 6th Neared, the Defendants’ Promotion of the Attack Became
Increasingly Fervent.
145. Defendants’ promotion of the January 6th Attack reached a fever pitch as the day
approached.
146. Defendant Caldwell took to social media: “It begins for real Jan 5 and 6 on [sic]
Washington D.C. when we mobilize in the streets. Let them try to certify some crud on Capitol
Hill with a million or more patriots in the streets. This kettle is set to boil.”
147. On January 1, 2021, Defendant Caldwell explained on social media that he would
no longer make efforts to act peacefully: “I swore to support and defend the Constitution of the
United States against all enemies foreign and domestic. I did the former, I have done the latter
peacefully but they have morphed into pure evil even blatantly rigging an election and paying off
the political caste. We must smite them now and drive them down.”
148. On January 3, 2021, Proud Boys Chairman, Defendant Tarrio, shared a post to
7,000 followers on the app Telegram, asking: “[w]hat if we invade it?” The first reply answered:
“January 6th is D day in America.”
149. Proud Boys leader Defendant Biggs also posted to Parler: “Every law makers [sic]
who breaks their own stupid Fucking laws should be dragged out of office and hung.”
8
Among others, Defendants Young and Steele traveled to the District together from North Carolina.
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150. On January 3, 2021, Defendant K. Meggs stated that people should “tell [their]
friends this isn’t a Rally!” making explicit that he was preparing for something other than a mere
protest.
151. On January 4, 2021, K. Meggs followed up his January 3 message by expressing
his contempt for District police officers on Facebook, writing, “Fucking DC cops protect those
antifa fuckers though pisses me off.”
152. Also on January 4, 2021, Oath Keepers issued a public call on the group’s official
website for “patriots” to come to the District “to stand tall in support of President Trump” and
“[p]repare to do whatever must be done to honor our oaths to defend the Constitution against all
enemies, foreign and domestic . . . whatever happens.”
153. By January 5, 2021, members of the Proud Boys and Oath Keepers made good on
their plans and descended on the District.
154. That night, Defendant Biggs sent instructions to his co-conspirators using the
secure “Boots on the Ground” channel—an encrypted messaging channel with more than 60 users
used to disseminate orders and otherwise engage in acts of coordination—telling them to “avoid
getting into any shit” the night before the planned attack, because “[t]omorrow’s the day.” Biggs
continued, “Just trying to get our numbers. So we can plan accordingly for tonight and tomorrow’s
plan.” Later, he reiterated: “We have a plan.”
D. The Defendants Were Not Deterred by Law Enforcement Efforts to Control
and Prevent Their Planned Violence.
155. In response to the Defendants’ rhetoric and messaging around the January 6th
“rally,” including the many promises for violence, law enforcement officials made substantial
efforts to disrupt and prevent the planned violence in advance.
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156. For example, on January 4, 2021, as Defendant Tarrio arrived in the District for the
January 6th Attack, MPD officers arrested him for his role in the burning of a church banner after
the December 12, 2020, Stop the Steal Rally. While arresting Tarrio, MPD officers discovered
two illegal high-capacity firearm magazines bearing the gold Proud Boys insignia. Defendant
Tarrio’s high-capacity magazines were compatible with AR-16 and M4 rifles. Defendant Tarrio
was immediately ordered to stay away from the District pending his criminal trial.
9
This prevented
him from being in the District on January 6th—and should have deterred those intent on
committing violent acts at the January 6th “rally.”
157. Law enforcement officials in surrounding areas also advised residents not to engage
in or join the planned “rally.” For example, the County Executive for Montgomery County,
Maryland, which neighbors the District, released a statement on the morning of January 5, 2021,
warning residents not to put themselves in harm’s way by joining what “w[ould] not be ordinary
protests,” explaining: “Protest organizers and the groups they represent have shown an alarming
affinity for violence. Sadly, they have not been shy about suggesting the need for violence. There
is talk of disrupting the counting of votes in Congress, which would require extreme actions. This
could create a volatile situation that may get out of hand, and we do not want people putting
themselves in harm’s way. . . . If there is an effort to disrupt the vote count, which would require
an attempt to prevent the actual counting in Congress, there will be a confrontation.”
158. Similarly, on January 5, 2021, the Federal Bureau of Investigation (“FBI”) issued
a warning that it had intelligence that extremists from several states would be traveling to the
District to commit violence and “war” on January 6, 2021.
9
In litigation concerning that order, the D.C. Court of Appeals observed that Defendant Tarrio’s “conduct and
statements in this case evince an inability to appreciate the difference between lawful protest and criminal activity
under the laws of the District of Columbia; he has telegraphed his intentions to incite or participate in further criminal
activity if permitted to return to the District. . . .”
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159. The FBI’s Norfolk, Virginia field office warned that these individuals had been
sharing a map of the Capitol and its tunnels and were convening in the areas from several states.
160. Proud Boys leaders proceeded with their plans. Although advised by a Proud Boys
member in an ongoing group chat on Telegram that participants “[s]houldn’t be typing plans to
commit felonies into your phone,” those on the chat demonstrated the Proud Boys members’ intent
to coordinate their activities on January 6th. Proud Boys member Defendant Donohoe explained
in the chat that “details will be laid out at the pre-meeting.”
161. In another Parler message group, which included Proud Boys leaders and members
including Defendants Nordean, Biggs, and Donohoe, the parties continued to convey their intent
to cause violence in the District on January 6th, suggesting that they planned to “smash” police to
dust and “burn [the] city to ash today.” Defendant Donohoe responded, “I’m leaving with a crew
of 15 at 0830 to hoof it to the monument no colors.”
E. The Defendants Launched the January 6th Attack To Target Officials
Charged with Certifying Electoral College Votes and Declaring a
Presidential Election Winner.
162. The Defendants’ conspiracy, which culminated in the January 6th Attack, targeted
in part a process established by federal law to count the certified electoral votes and formally
declare the winner of the Presidential election.
163. Once popular votes for President and Vice President have been cast, certain
provisions of the U.S. Constitution together with the Electoral Count Act of 1887 create official
duties both for members of Congress and the Vice President, as President of the Senate.
164. Specifically, after voting for the presidency has concluded, and after presidential
Electors compile, sign, and certify lists of votes, the certified lists are transmitted to the seat of the
government of the United States, directed to the President of the Senate. U.S. Const. amends. XII,
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XXIII. At that point, “[t]he President of the Senate shall, in the presence of the Senate and House
of Representatives, open all the certificates and the votes shall then be counted.” Id. amend. XII.
165. The Electoral Count Act of 1887 provides that “Congress shall be in session on the
sixth day of January succeeding every meeting of the electors.” 3 U.S.C. § 15. The statute sets
out a detailed process that requires a joint meeting of the “Senate and House of Representatives . . .
in the Hall of the House of Representatives at the hour of 1 o’clock in the afternoon on that date”
during which “the President of the Senate [opens] all the certificates and papers purporting to be
certificates of the electoral votes . . . ” of each State. Id.
166. After pre-appointed tellers from the Senate and House of Representatives read the
certificates of electoral votes “in the presence and hearing of the two Houses,” the law provides
that the tellers “shall make a list of the votes as they shall appear from the said certificates.” Id.
§ 15. Once the votes have been “ascertained and counted” pursuant to this process, “the result of
the same shall be delivered to the President of the Senate, who shall thereupon announce the state
of the vote, which announcement shall be deemed a sufficient declaration of the persons, if any,
elected President and Vice President of the United States[.]” Id.
IV. Defendants Assemble Forces in the District for Their January 6th Attack.
167. On January 6, 2021, the Proud Boys, Oath Keepers, and their members and
affiliates—including the Individual Defendants—attended President Trump’s rally and prepared
for violence.
168. Earlier that morning, the vast majority of the Individual Defendants and other
currently unidentified John and Jane Doe Defendants, along with their Proud Boys and Oath
Keepers co-conspirators, traveled together or otherwise convened in the District, congregating in
groups and readying themselves for action.
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169. At approximately 11:25 a.m., a YouTube video from Proud Boys member and live-
streamer Eddie Block showed members of the Proud Boys lining up before the Attack, shouting
out their home states. Proud Boys leader Defendant Biggs is shown organizing Proud Boys
members and speaking into a walkie-talkie. Defendant Nordean is shown speaking to the group
through a bullhorn. Defendant Scott is captured in Block’s video footage shouting “let’s take the
fucking Capitol!” In response, another Proud Boys member chastised Defendant Scott for talking
about their plan, saying “don’t yell it, do it.”
Figure 5. Image from video capturing Defendant Scott’s direction to other Proud Boys on
January 6th
170. At 12:17 p.m., President Trump directed his supporters to the Capitol. “We’re
going to walk down to the Capitol—and we’re going to cheer on our brave senators and
congressmen and women, and we’re probably not going to be cheering so much for some of them,”
President Trump said.
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171. At this point, the Defendants, who were stationed throughout the crowd, began to
tell others that the time to break into the Capitol had come, yelling: “YEAH! LET’S TAKE THE
CAPITOL!”
172. For his part, President Trump called the crowd to action, using his position to echo
and amplify the message Defendants had already started to send out: “You’ll never take back our
country with weakness. You have to show strength, and you have to be strong.”
173. Again, the crowd responded: “YES! STORM THE CAPITOL! INVADE THE
CAPITOL BUILDING! Let’s take the Capitol! Right now!!”
174. Twenty minutes before President Trump’s speech concluded, members of Oath
Keepers, including Defendant Watkins, left the “rally” and began marching toward the Capitol.
175. As President Trump’s comments neared their conclusion, his rhetoric fanned the
flames that Defendants had ignited, imploring the crowd to “fight like hell” or risk losing the
country: “Something is wrong here, something is really wrong, can’t have happened and we fight,
we fight like hell, and if you don’t fight like hell, you’re not going to have a country anymore.”
The crowd chanted in response: “FIGHT LIKE HELL!”
176. At 1:11 p.m., President Trump concluded: “So let’s walk down Pennsylvania
Avenue.” Proud Boys member and live-streamer Eddie Block filmed his co-conspirators’ actions
during President Trump’s speech, including Proud Boys leader Defendant Biggs’ efforts directing
the march of approximately 60 Proud Boys on the Capitol. Biggs shouted orders to the group to
“tighten up,” “hold,” and “turn.”
177. As President Trump concluded his speech, other Individual Defendants, including
dozens of members of the Proud Boys in military-style tactical gear, marched toward the Capitol
building.
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178. Oath Keepers member Defendant Watkins posted a message on an audio app,
saying, “Trump’s been trying to drain the swamp with a straw. We just brought a shop vac.”
179. Meanwhile, Proud Boys members coordinated their movements using handheld
radios and encrypted communication channels, including the “Boots on the Ground” channel,
which was used by Proud Boys leaders Biggs and Nordean. In preparation for the January 6th
Attack, the Proud Boys created the New Ministry of Self Defense (“New MOSD”) channel to
coordinate their members. The group included Defendants Nordean, Biggs, Donohoe, Rehl, and
others. Donohoe posted in the channel to meet at the Washington Monument and that details
would be explained at the “pre-meeting.” Leaders and members of the Proud Boys, including
Defendants Nordean and Biggs, also directed the mob with a bullhorn.
180. As they approached the Capitol, members of the Proud Boys encouraged and
directed the group. Consistent with the plans articulated by Proud Boys Chairman Defendant
Tarrio, members of the group were not wearing typical Proud Boys colors of black and yellow,
but were instead dressed “incognito” in dark clothing, and several held walkie-talkie-style
communication devices.
181. Although the Proud Boys were told not to wear Proud Boys indicators, photos and
video footage show some of them, including Defendant Pezzola, wearing clothing with the Proud
Boys slogan “Fuck Around and Find Out,” or “FAFO.”
182. Members and affiliates of Oath Keepers donned paramilitary equipment, helmets,
reinforced vests, and clothing with Oath Keepers paraphernalia. Specifically, before arriving at
the Capitol building, together with several other currently unidentified John and Jane Doe
Defendants, Defendants Crowl, Watkins, Caldwell, S. Parker, B. Parker, Young, Steele, K. Meggs,
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and C. Meggs equipped themselves with communication devices and donned reinforced vests,
helmets, and goggles.
V. Defendants Attacked the Capitol Using Coordinated Violence.
A. Defendants Stormed the Capitol and Forced Their Way Inside.
183. None of the Defendants had authorization to enter the U.S. Capitol, which is
secured 24 hours a day by U.S. Capitol Police, has permanent and temporary security barriers and
posts manned by Capitol Police, and permits only authorized individuals to enter.
184. The District’s MPD also provides security for the Capitol from time to time.
185. Nonetheless, by approximately 11:30 a.m., a large group had congregated outside
the Capitol, including Proud Boys and Oath Keepers leadership and certain of their members and
affiliates.
186. Outside the Capitol, members of the Proud Boys and Oath Keepers, including
Defendant Biggs, provided tactical direction to fellow Defendants, including other currently
unidentified Defendant John and Jane Does.
187. Defendants and their cohort began violently clashing with the MPD and Capitol
Police officers who tried to prevent them from entering the building. During the clash, Defendants
screamed at the police, repeating messages like those Defendants promoted before the mob
convened, such as: “We were invited here! We were invited by the President of the United States!”
and “Our president wants us here. We wait and take orders from our president.” As Officer
Aquilino Gonall, a Capitol Police officer, later testified before the House Select Committee to
Investigate the January 6th Attack on the U.S. Capitol (“House Select Committee”): “[a]ll of
them—all of them were telling us [the police officers] ‘Trump sent us.’”
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Figure 6. The crowd clashes with MPD and Capitol Police officers outside the Capitol.
188. By 12:53 p.m., the Defendants, including Proud Boys Individual Defendants Biggs,
Chrestman, Colon, Kuehne, Bru, and other currently unidentified John and Jane Doe Defendants,
overwhelmed the police and breached the outermost barricade that had been erected to protect the
Capitol.
189. At 1:00 p.m., a joint session of the U.S. Congress (the “Joint Session”) convened
at the Capitol for members of Congress and Vice President Pence to carry out their Constitutional
and statutory duties of receiving and counting the Electoral College votes.
190. At approximately the same time, Capitol Police and MPD officers in riot gear
arrived to reinforce the line of officers on the Capitol steps.
191. Undeterred, Defendants and others in the crowd climbed the barriers, while an
unidentified John Doe Defendant with a bullhorn instructed the crowd to push forward. Members
of the Proud Boys led the charge at the front of the mob trying to breach the Capitol. Other
members of the crowd even scaled the walls of the Capitol Complex. See Figure 7.
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Figure 7. Members of the crowd scale the walls of the Capitol Complex.
192. Members of the Proud Boys and Oath Keepers forced their way past the barricades,
assaulted officers, and rushed toward the Capitol building.
193. Proud Boys member Defendant Bru grabbed a police barricade in an attempt to
wrench it from law enforcement protecting the Capitol. See Figure 8.
Figure 8. Defendant Bru and others attempt to wrestle control of the
barricades away from police as they march on the Capitol.
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194. After pushing their way past another barricade, Proud Boys member Defendant
Klein obtained and used the police barricade to help others climb the Capitol walls and gain access
to an external stairwell. Proud Boys member Defendant Worrell, equipped with a tactical vest and
communications equipment, sprayed a noxious substance (seemingly pepper spray gel) toward a
line of police officers guarding an entryway to the Capitol on the west side.
195. By approximately 1:30 p.m., the House and Senate adjourned to separate chambers
to resolve an objection to the vote count, with Vice President Pence presiding over the Senate
chamber. As the proceedings continued in both the House and the Senate, the crowd outside the
Capitol continued to grow in size and became more restless.
196. By approximately 1:37 p.m., Defendant Scott and others made it to the lower
western part of the plaza, just outside the Capitol. A line of law enforcement officers stood on the
steps leading to the Capitol building. As is clear from videos of this scene posted to the social
media site Parler, Defendant Scott pushed two Capitol Police officers backwards, up the steps to
the Capitol. This violent act instigated a broader violent confrontation with the police. Defendant
Scott grabbed and pulled a police officer toward the mob, until another officer ultimately
intervened.
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Figure 9. Defendant Scott (man in green jacket and blue hat) pushing an officer
Figure 10. Defendant Scott confronting an officer, while a second officer attempts to intervene
197. Shortly past 2:00 p.m., Defendant Caldwell sent Defendant Watkins a text message
stating: “Where are you? Pence has punked out. We are screwed. . . . I am here at the dry fountain
to the left of the Capitol.”
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Figure 11. Storming the Capitol Complex
198. At approximately 2:15 p.m., the mob, led by several individual Defendants,
breached the Capitol by breaking windows and climbing inside the building, opening doors for co-
conspirators to follow. See Figure 12.
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Figure 12. Defendant Pezzola uses a stolen Capitol Police riot
shield to break a window of the Capitol.
199. Defendants Biggs and Nordean were among the first to enter, along with a large
group of other Proud Boys-affiliated Individual Defendants and unidentified John and Jane Doe
Defendants.
200. As seen in Figure 12, Proud Boys members Biggs and Pezzola entered the Capitol
building by breaking a window using a police shield stolen from a Capitol Police officer.
201. At approximately 2:16 p.m., Defendants James, Minuta, and other members of Oath
Keepers heard that individuals had breached the Capitol. Defendant Minuta stated: “Now we’re
talking, that’s what I came here for!” Defendant James instructed the group to gather their gear
and head towards the Capitol. Minuta had on tactical gear, including hard-knuckles, ballistic
goggles, a tactical vest, a radio with an earpiece, and bear spray.
202. Oath Keepers member Walden and Defendants Minuta and James, along with other
associates, then drove golf carts towards the Capitol, swerving around law enforcement as they
rushed to join the assault. As they drove, Defendant Minuta declared: “Patriots are storming the
Capitol building; there’s violence against patriots by the D.C. Police; so we’re en route in a grand
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theft auto golf cart to the Capitol building right now . . . it’s going down, guys; it’s literally going
down right now Patriots storming the Capitol building . . . fucking war in the streets right now . . .
word is they got in the building . . . let’s go.”
203. Oath Keepers leader Rhodes, who coordinated logistical details for many involved
in the Attack in real time, messaged another Oath Keepers leader, informing him that members of
the team had “taken ground at the capital [sic],” instructing that “[w]e need to regroup any
members who are not on mission.” Rhodes instructed his group to report to the “South Side of the
Capitol,” suggesting that they had strategically planned to simultaneously (or near-simultaneously)
enter the Capitol from a different entrance than the Proud Boys in order to weaken the building’s
defense by forcing law enforcement to defend multiple doors.
204. Around the time that direction was given, Oath Keepers Defendants Crowl,
Watkins, S. Parker, Young, Steele, K. Meggs, and C. Meggs joined together with other currently
unidentified John and Jane Doe Defendants to form a “military stack” (“the Stack”) formation of
individuals wearing Oath Keepers clothing, patches, insignia, and battle gear. At least one of the
Oath Keepers members wore a patch that warned: “I don’t believe in anything. I’m just here for
violence.”
205. At 2:22 p.m., Defendants Crowl, Watkins, S. Parker, B. Parker, Steele, K. Meggs,
C. Meggs, Oath Keepers member Hackett, and others, entered the Capitol grounds. Upon entering
the grounds, they gathered in a circle.
206. At 2:24 p.m., Defendant K. Meggs received the message from Oath Keepers
founder Rhodes to come to the south side of the Capitol. At 2:25 p.m., Rhodes forwarded a
message to the Signal group chat with the same instructions and posted a photograph showing the
southeast side of the Capitol.
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207. At around 2:32 p.m., Rhodes exchanged a 97-second telephone call with Defendant
K. Meggs, who was in the Oath Keepers Stack.
208. At 2:35 p.m., the Stack maneuvered together in an organized and coordinated
fashion up the steps of the Capitol, with each person keeping a hand on the shoulder of the person
in front of them, as depicted in Figure 13.
Figure 13. Oath Keepers advance on the Capitol in stack formation.
209. Towards the top of the steps, Oath Keepers member Dolan and Defendant
Harrelson joined the Stack.
210. At approximately 2:40 p.m., Oath Keepers members Hackett and Dolan and
Defendants Crowl, Harrelson, Watkins, S. Parker, Young, Steele, K. Meggs, and C. Meggs,
together with other currently unidentified John and Jane Doe Defendants in their group, forcibly
entered the Capitol through the Rotunda door in the center of the east side of the building. The
group assaulted police officers guarding the door in order to breach the building, including by
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throwing objects at the officers and deploying chemical irritants against them. This group of
Defendants—each suited up in protective combat gear—continued to maintain their Stack
formation as they entered, as depicted in Figures 13 and 14.
Figure 14. Oath Keepers in protective combat gear breach the Capitol Building.
211. As Defendant Watkins later confirmed when challenged about whether she had
actually forced her way into the Capitol: “Forced. Like Rugby. We entered through the back
door of the Capitol.” Another of Defendant Watkins’s posts confirmed: “Yeah. We stormed the
Capitol today. Teargassed, the whole, [sic] 9. Pushed our way into the Rotunda. Made it into the
Senate even. The news is lying (even Fox) about the Historical Events we created today.”
212. Defendant Young later admitted in his plea agreement that “[a]t the time he forcibly
entered the building, [Young] believed that he and [certain Oath Keepers] co-conspirators were
trying to obstruct, influence, and impede an official proceeding, that is, a proceeding before
Congress, specifically, Congress’s certification of the Electoral College vote.”
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213. Around the same time, Proud Boys member Garcia uploaded a video to his
Facebook account filmed from the inside of the Capitol building. He narrated his actions for his
social media followers, stating: “We just went ahead and stormed the Capitol. It’s about to get
ugly.” Later in the video, Proud Boys member Garcia can be observed directing those around him
to overtake law enforcement in the Capitol. As officers attempted to stop him from advancing, he
yelled, “USA! Storm this shit!” See Figure 15.
Figure 15. Garcia uploads a video on Facebook showing him directing the crowd to storm the
Capitol.
214. Nearly simultaneously, Oath Keepers member Isaacs joined a mob advancing on
the Columbus Doors at the central east entrance to the Capitol. The mob, including Isaacs, then
assaulted the officers who were guarding the Columbus Doors, throwing objects and spraying
chemical irritants at the officers as they violently pulled on the doors. At approximately 2:39 p.m.,
Isaacs and the mob breached the Columbus Doors and entered the Capitol.
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215. On January 7, 2021, Defendant Crowl confirmed that the Defendants had agreed to
simultaneously attack the Capitol building through separate doors, stating: “Yes. . . we went in
through the east ‘back’ door. Just as they broke through the front door. I’ll have to tell you about
it. . . . It. . . was. . . EPIC!!!”
216. By 2:48 p.m., Defendant Caldwell sent a social media message stating: “We are
surging forward. Doors breached.”
217. Proud Boys, Oath Keepers, and their members and affiliates—including the
Individual Defendants—continued to force their way into the building. At 3:15 p.m., Defendants
James, Minuta, and others forcibly entered the Capitol through the east side of the Rotunda—the
same path that members of the Stack had used to enter the Capitol earlier that day. Defendant
Minuta was armed with bear spray and other tactical gear. Walden brought his 82-pound security
dog into the building.
218. Proud Boys member Eddie Block livestreamed the actions of those around him as
they assaulted the Capitol building, telling viewers that “flash bombs [were] going off. Rubber
pellets were flying everywhere. Tear gas was everywhere.” Block positioned himself on the
second-level balcony of the Capitol grounds where he would continue livestreaming until the
police dispersed the crowd later that night.
B. Once Inside the Capitol, the Defendants Continued to Use Violence as They
Moved Toward the Congressional Chambers.
219. Once inside, Defendants continued their violent rampage, actively seeking out the
official election certification proceedings and individuals with official functions in an effort to
disrupt the election certification process with threats and violence.
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Figure 16. Defendants and their cohort marching through the halls of the Capitol
220. Defendants Bru, Pepe, and Jackman were captured on video and in photographs
walking in the crowd among other Defendant John and Jane Does and others within the Capitol
building after overtaking law enforcement outside of the building. See Figure 17.
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Figure 17. Defendants, including Bru, and their cohort, breach the Capitol and storm its halls.
221. Proud Boys member Defendant Chrestman was also in the crowd, carrying a
wooden axe handle. Chrestman threatened a Capitol Police officer, telling him, “You shoot and
I’ll take your fucking ass out!” See Figure 18.
Figure 18. Defendant Chrestman carrying a wooden axe handle through the Capitol
222. Oath Keepers members Hackett and Dolan, and Defendants Crowl, Watkins, S.
Parker, Young, Steele, K. Meggs, and C. Meggs, as well as other unidentified John and Jane Doe
Defendants in the group, also joined the larger crowd, pushing past law enforcement who
attempted to stop them.
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223. Similarly, Oath Keepers Defendants Minuta and James joined other attackers in
pushing a line of law enforcement officers who had formed a barrier between the Rotunda and the
Capitol lobby. During this altercation, Defendant James yanked and pushed several police officers
while repeatedly yelling, “Get out of my Capitol!” and “This is my fucking building! This is not
yours! This is my Capitol!” Defendant Minuta recorded these events on camera while yelling,
“This is what’s bound to happen, just get out! Get out! Get these cops out! It’s our fucking
building! Get ’em out, get out!”
Figure 19. Defendant Schaffer shouting as he marches through the Capitol
224. Defendant DeCarlo, who wore a t-shirt reading “Murder the Media,” etched those
same words into the Memorial Door on the East Front of the Capitol. The door was intended to
honor two Capitol Police officers who died in the line of duty in 1998. At the same door, Defendant
DeCarlo stole a pair of flexible handcuffs from a Capitol Police officer’s bag.
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C. Defendants Breached Congressional Chambers in Pursuit of Their Goal of
Disrupting Certification of the Election Results.
225. When the mob first broke into the Capitol, members of the House of
Representatives and the Senate were tallying the votes cast by members of the Electoral College
in the 2020 Presidential Election.
226. Vice President Pence was also at the Capitol in his capacity as the President of the
Senate, to preside over the tally of the Electoral College ballots. Having declined to suspend the
Electoral College vote tally, Vice President Pence became a target of the mob’s violent threats.
They chanted, “Hang Mike Pence!”
227. As the events unfolded, the risk to the Vice President and members of Congress
increased.
228. Police and security personnel barricaded the doors to the House chamber, where
lawmakers and others were forced to take cover on the ground as the Defendants and others beat
on the doors and attempted to force their way through the barricades. See Figure 20.
Figure 20. Capitol security barricades the House Chamber with weapons drawn.
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Figure 21. Rep. Jason Crow of Colorado, center, comforts Rep. Susan Wild of Pennsylvania
while taking cover as the Defendants and others storm the Capitol.
229. At approximately 2:30 p.m., Defendants’ unlawful attack on the Capitol had
become so disruptive and such a threat to safety and security that congressional staff, members of
Congress, and Vice President Pence were evacuated. The Joint Session was halted while law
enforcement officers worked to restore order and clear the Capitol of the unlawful occupants,
including Defendants.
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Figure 22. Evacuation of Members of Congress
Figure 23. Evacuees wear gas masks as they flee the Capitol.
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Figure 24. Vice President Pence in the process of being evacuated from the Capitol
230. Many individuals, including Defendants, breached the House and Senate chambers,
continuing to flaunt their activities on social media. For example, Defendant Jackman broke into
the Capitol with Defendants Biggs and Rehl, entered the gallery of the Senate chamber, and was
videotaped walking up a flight of stairs in the Capitol with his hand on Proud Boys leader
Defendant Biggs’ shoulder. Jackman entered the Senate chamber and proceeded to take a picture
of himself.
Figure 25. Posing for pictures after storming the Senate chambers
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231. Several members of the Defendants’ cohort, including some of those who entered
the Congressional chambers, carried plastic zip handcuffs for the purpose of capturing and
detaining persons, including members of Congress. See Figure 26.
Figure 26. Standing on the Senate floor, holding several plastic zip handcuffs
232. For hours that day, Defendants and thousands of others entered and occupied the
grounds of the Capitol building using violence.
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Figure 27. The Capitol on the afternoon of January 6th
233. The Joint Session could not reconvene until approximately 8:00 p.m. At
approximately 3:40 a.m. on January 7th, Vice President Pence affirmed the election results,
formally declaring now President Biden the President-elect.
234. Following the Attack, the Defendants celebrated the havoc they had wrought on the
Capitol, in some cases even proudly admitting to the conspiracy between the Proud Boys, the Oath
Keepers, their leadership, and certain of their members and affiliates to carry out the January 6th
Attack.
D. Defendants Attacked Law Enforcement Officers Throughout Their Attack
on the Capitol.
235. Several Defendants attacked police officers who attempted to defend the Capitol
and members of Congress. See Figures 28 and 29.
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Figure 28. The crowd attacked police as they began to breach the Capitol building.
Figure 29. The crowd clashed with police inside the Capitol building.
236. Members of the crowd sprayed law enforcement officers with bear mace, a pepper
spray designed to deter bear attacks that is more concentrated than self-defense products meant to
deter human attacks. When sprayed into the face, it causes temporary loss of sight, nasal
congestion, and, in some, difficulty breathing.
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237. Others dragged and kicked law enforcement officers, pushed them down stairs,
trampled them, punched them, and ran over them in a stampede.
238. One MPD officer was beaten by members of the crowd with sticks and crutches,
including by one person wielding an American flag. See Figure 30. The MPD officer later recalled
during his testimony before the House Select Committee that attackers were lunging at him and
trying to grab his gun while chanting “kill him with his own gun.”
Figure 30. The crowd of Defendants and others dragging and beating
an MPD Officer on the Capitol steps
239. Defendant Pezzola participated in at least one group attack on another police
officer. Defendant Pezzola ripped away a Capitol Police officer’s riot shield while the officer was
physically engaged with others.
240. Shortly after breaching the Capitol in stack formation, Defendants Crowl, Watkins,
S. Parker, Young, and Steele, along with Oath Keepers member Isaacs, moved from the Rotunda
through the northbound hallway and attempted to enter the Senate’s wing of Congress.
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241. In advancing towards the Senate, Oath Keepers member Isaacs waved the crowd
down the hallways to the Senate and yelled “the fight’s not over.”
242. At 2:45 p.m. and afterward, Defendants Crowl, Watkins, S. Parker, and Young,
along with Oath Keepers member Isaacs, joined a mob pushing against a line of riot police officers
guarding the hallway connecting the Rotunda to the Senate. Defendant Watkins commanded those
around her to “push, push, push,” and to “get in there, get in there,” while insisting, “they [the
police officers] can’t hold us.”
243. Additional unidentified John and Jane Doe Defendants were involved in similar
attacks.
244. Proud Boys member Defendant Nordean later posted a photo on Parler showing a
U.S. Capitol Police officer, under siege, using pepper spray during the January 6th Attack, opining
that “if you feel bad for the police, you are part of the problem.”
E. Defendants Coordinated Communications During the Attack.
245. The Individual Defendants and some or all of the currently unidentified John and
Jane Doe Defendants kept in communication throughout the January 6th Attack, including through
the use of two-way walkie-talkie-style radios, cellular telephones, and social media to coordinate
their actions.
246. Many of the Individual Defendants used a Signal chat to discuss the ongoing attack.
At 2:41 p.m. that day, a co-conspirator wrote to the group chat, attaching a picture of the southeast
side of the Capitol and adding, “South side of US Capitol. Patriots pounding on doors.” Around
the same time, Defendants K. Meggs, Crowl, Watkins, S. Parker, Young, Steele, and C. Meggs
were breaching the doors to the Capitol.
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247. Oath Keepers member Defendant Watkins also communicated with other members
of Oath Keepers during the Capitol breach over a Zello channel called “Stop the Steal J6”:
• Watkins: “We have a good group. We have about 30-40 of us. We are
sticking together and sticking to the plan.” (emphasis added).
• Unknown male: “We’ll see you soon, Jess. Airborne.”
• Unknown male: “You are executing citizen’s arrest. Arrest this assembly, we
have probable cause for acts of treason, election fraud.”
• Watkins: “We are in the mezzanine. We are in the main dome right now. We
are rocking it. They are throwing grenades, they are fricking shooting people
with paint balls. But we are in here.”
• Unknown male responds, telling Watkins to be safe, and states: “Get it, Jess.
Do your fucking thing. This is what we fucking [unintelligible] up for.
Everything we fucking trained for.” (emphasis added).
248. Defendants also exchanged information about the location of members of
Congress, who by that point had begun to hide from the mob that was hunting them.
249. When Defendant Caldwell posted a Facebook message that read, “Inside,” he
received the following messages, among others:
• “Tom take that bitch over”;
• “Tom all legislators are down in the Tunnels 3 floors down”;
• “Do like we had to do when I was in the core start tearing out floors go from
top to bottom”; and
• “Go through back house chamber doors facing N left down hallway down
steps.”
250. One co-conspirator communicated to Defendant Caldwell: “All members are in the
tunnels under capital [sic] seal them in. Turn on gas.”
251. Another affiliate, Keith Lee, reported on a podcast during the Attack that “backup”
was arriving at the Capitol, including members of the Proud Boys.
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252. In an indictment, prosecutors revealed that Rhodes, his deputy, and three additional
members of Oath Keepers who acted as guards for the political consultant Roger Stone on January
6th exchanged 19 phone calls during the January 6th Attacks totaling over three hours.
VI. The District of Columbia Answered the Call to Provide Support during the January
6th Attack—and Was Injured as a Result.
253. In response to concerns leading up to January 6th, MPD deployed its officers on
12-hour shifts around the District. No officers were permitted to take leave on that day.
254. Other law enforcement partners such as the Metropolitan Transit Police and non-
law enforcement agencies such as the District’s Homeland Security and Emergency Management
Agency and the Fire and Emergency Medical Services Department were also supporting these
efforts.
255. The measures taken by MPD and others to prepare for January 6th were
unprecedented: never before had the certification of an election required such significant
allocation of law enforcement resources.
256. Nonetheless, these resources were insufficient to counter the unprecedented violent
assault on the U.S. Capitol by Defendants in an attempt to halt the counting of the electoral ballots,
an essential step in the peaceful transfer of the presidency.
257. As the events described above began to unfold, the Capitol Police quickly
discovered that they could not defend the Capitol alone. Accordingly, at 12:58 p.m. on January
6th, the Chief of the Capitol Police asked for MPD’s assistance at the Capitol.
258. MPD responded immediately, deploying several Civil Disturbance Unit Platoons.
259. By the time MPD officers arrived at the Capitol, the area was in chaos.
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260. MPD officers were engaged in a battle for hours. Many were forced into hand-to-
hand combat to prevent even more of the Defendants and their cohort from gaining entry into the
Capitol.
261. By 2:30 p.m., MPD resources were so overwhelmed that the District had to request
additional police officers from as far away as New Jersey.
A. MPD Officers Suffered Physical and Mental Injuries as a Result of the
Defendants’ Attack
262. At least 65 MPD officers reported sustaining injuries as a direct result of the
January 6th Attack.
263. The officers’ physical injuries varied, ranging from bruised arms and legs, swollen
ankles and wrists, and lacerations, to more serious damage such as irritated eyes and lungs from
bear and pepper spray, cracked ribs, shattered spinal discs, wounds from being hit with a metal
fence stake, and concussions from head blows from various objects, including metal poles ripped
from inauguration-related scaffolding and an American flag pole.
264. One MPD officer reported being hit on the back of his head with a pole, and that
the attackers had wrenched his head back. The officer sustained a concussion, which necessitated
visits to neurologists and therapists.
265. One MPD officer testified before the House Select Committee regarding the
physical and mental injuries he sustained as a result of the Attack. He described suffering a heart
attack (caused by being repeatedly hit with a stun gun), a concussion, a traumatic brain injury, and
post-traumatic stress disorder.
266. The MPD officer was electrocuted multiple times as he was beaten unconscious by
the crowd while screaming for help. While the crowd was beating him with fists and hard metal
objects, they shouted “kill him with his own gun” and stripped his badge, radio, and ammunition
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from his body. As a result of his injuries, the MPD officer lost consciousness for more than four
minutes.
267. The MPD officer was finally driven to MedStar Washington Hospital by his MPD
partner, who was also heavily injured. The officer continues to suffer psychological trauma and
anxiety from the attack.
268. A second MPD officer also testified before Congress. During the Attack, that
officer was crushed between a doorframe and a clear plastic shield that was wielded by someone
in the crowd. As he has described publicly, attackers threw items at his head, attempted to wrest
away his baton, and teargassed him. At one point, someone tried to gouge out his eye. Eventually,
while he was pinned against the door, another attacker beat his head against the wall. Another
man wrested away the officer’s baton and beat him in the face with it, leaving him with a ruptured
lip and cranial injuries.
Figure 31. The second MPD officer as he is crushed between a doorframe and a police shield
269. The group also pulled another MPD officer into the mob where they kicked him,
beat him with poles, and stomped on him. The MPD officer eventually escaped from the mob,
bleeding from his head, and was treated for a laceration that required two staples.
270. Other MPD officers sustained injuries that are not yet formally reported, including
scratches, bruises, and eyes burning from bear mace.
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271. The effects of the January 6th Attack have continued. MPD officers continue to
suffer the effects of complex physical and emotional trauma.
272. Dr. Beverly Anderson, a therapist who serves as the clinical director of the
Metropolitan Police Employee Assistance Program, has worked with nearly 1,000 officers since
the January 6th Attack in an effort to help them cope with the physical and emotional trauma
caused by the Defendants and their cohort. During the course of her work, Dr. Anderson
discovered that some officers suffered head traumas as a result of the Attack that had previously
gone undiagnosed.
273. The Attack’s impact on MPD and its officers has been long-lasting and severe.
274. As of mid-July, more than six months after the Attack, some of the officers who
responded to the Attack were still on leave as a result of the trauma they suffered at the Defendants’
hands.
B. The District Has Incurred Significant Damages as a Result of Defendants’
Unlawful Actions
275. For the District, the fiscal costs of this Attack—which are directly attributable to
the Defendants’ calculated, pre-planned, and coordinated actions—have been steep.
276. The Defendants’ actions necessitated an unprecedented deployment of MPD
resources. During the height of the Attack, approximately 850 MPD officers were at the Capitol;
by the day’s end, approximately 250 additional MPD officers were in the area to support the
response and aftermath. These numbers far exceed the number of officers necessary for the MPD’s
usual duties, including usual duties carried out during non-violent rallies and protests, and the costs
to the District arising from this expansive deployment of MPD resources was significant.
277. The District also incurred costs related to the emergency and other medical care
provided to MPD officers who were injured as a result of the Defendants’ actions. Dozens of MPD
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officers formally reported and were treated for injuries resulting from the Defendants’ Attack.
Many MPD officers also required—and in some cases, still require—mental health care following
the traumatic events that unfolded during the Attack. The District expects to pay for continued
medical care for these officers as necessary going forward, including care related to the impact of
the Attack on MPD officers’ mental health.
278. While the costs to the District are still being investigated and tallied, the District
has preliminarily estimated that MPD incurred millions of dollars in costs during the week of
January 6th alone.
COUNT I: 42 U.S.C. § 1985(1)
(ALL DEFENDANTS)
279. Plaintiff reincorporates by reference the allegations contained in all preceding
paragraphs.
280. Plaintiff states Count One, under 42 U.S.C. § 1985(1), against all Defendants.
281. Defendants agreed and entered into a conspiracy amongst themselves and with
other co-conspirators, in the United States, to storm the Capitol building violently and unlawfully
on January 6, 2021 (the “Section 1985 Conspiracy”).
282. The object of the Section 1985 Conspiracy was to prevent, interrupt, hinder, and
impede, through force, intimidation, and threat: (i) United States officials from discharging
official duties of their offices and positions of trust as part of the formal process for counting and
certifying the count of electoral votes for the 2020 presidential election and declaring a winner of
the 2020 presidential election; (ii) President Biden and Vice President Kamala Harris from
accepting or holding the offices of President of the United States and Vice President of the United
States, respectively; and (iii) President Biden and Vice President Harris from discharging any
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duties of the offices of President of the United States and Vice President of the United States,
respectively.
283. Defendants also conspired to injure Vice President Pence’s person and property on
account of his lawful discharge or performance of his duties as Vice President of the United States
and President of the Senate with respect to the election.
284. In furtherance of the conspiracy, Defendants and their co-conspirators:
a. engaged in preparations and took steps to advance the goals of their
conspiracy against United States officials in advance of and on January 6,
2021, and
b. violently overran federal and District police forces as Defendants forced
their way into the Capitol building, where Defendants used force,
intimidation, and threats to prevent Congress from following the
constitutional process set out by the Twelfth Amendment and 3 U.S.C. § 15
for counting and certifying electoral votes for, and declaring a winner of,
the 2020 presidential election.
285. Through these actions, Defendants and their co-conspirators perpetrated malicious
and unlawful acts in furtherance of their conspiracy, including, but not limited to:
a. unlawfully obstructing federal officials in the performance of their
constitutional duties;
b. unlawfully trespassing on federal property;
c. physically threatening or attempting to cause physical injury to federal,
state, and municipal police officers, including MPD officers employed by
Plaintiff who were acting in the line of duty to protect the Capitol; and
d. engaging in harmful bodily contact against federal, state, and municipal
police officers, including MPD officers employed by Plaintiff, injuring
many.
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286. As a direct result of Defendants’ and their co-conspirators’ unlawful conspiracy
and the actions taken in support of that conspiracy, the District suffered extraordinary damages
and costs, including but not limited to:
a. costs to dispatch hundreds of MPD officers to defend the Capitol and its
surroundings against the Defendants’ attack, including transportation,
coordination, and overtime expenses;
b. costs for emergency and other medical treatment for injured MPD officers;
and
c. costs for paid leave for MPD officers who could not work as a result of their
injuries.
287. Based on the foregoing, Defendants are jointly and severally liable to Plaintiff
under 42 U.S.C. § 1985(1) for the harms suffered by the District.
COUNT II: 42 U.S.C. § 1986
(ALL DEFENDANTS)
288. Plaintiff reincorporates by reference the allegations contained in all preceding
paragraphs.
289. This Count is brought by Plaintiff against all Defendants.
290. Defendants had actual knowledge of the conspiracy among the Defendants and their
unnamed co-conspirators described in Count I, supra.
291. As alleged in Count I, the District suffered damages as a result of Defendants’
Section 1985 Conspiracy.
292. Defendants were well aware that the wrongs pled in Count I were about to and
would be committed, as Defendants were present and participated actively in the conspiracy and
the actions taken in furtherance of the conspiracy that resulted in the injuries suffered by the
District. Thus, each of the Defendants had the power to prevent or aid in preventing the
commission of the same.
Case 1:21-cv-03267 Document 1 Filed 12/14/21 Page 79 of 84
80
293. Despite this awareness, Defendants neglected or refused to prevent the conspiracy.
To the contrary, Defendants spread misinformation, fanned the flames of the conspiracy, actively
encouraged and participated in the actions that left the Capitol in shambles, threatened a vital
component of our democracy, and injured law enforcement.
294. Based on the foregoing, Defendants are liable to Plaintiff under 42 U.S.C. § 1986
for the harms they caused to the District.
COUNT III: ASSAULT
(CIVIL CONSPIRACY BY ALL DEFENDANTS)
295. Plaintiff reincorporates by reference the allegations contained in all preceding
paragraphs.
296. This Count is brought by Plaintiff against all Defendants.
297. As set forth above, Defendants agreed to participate together in a common scheme
to commit unlawful acts, or to commit lawful acts by unlawful means, including, but not limited
to, unlawfully obstructing federal officials in the performance of their constitutional duties,
unlawfully inciting and carrying out a riot, unlawfully trespassing on federal property, and
committing numerous acts of intimidation, threats of violence, and violence.
298. Pursuant to and in furtherance of that common scheme, the Defendants’ intentional
acts caused individuals in and around the Capitol, including MPD officers, to suffer immediate
apprehension of harmful or offensive bodily contact.
299. Based on the foregoing, all Defendants are liable to the District as civil co-
conspirators for the resulting damage.
Case 1:21-cv-03267 Document 1 Filed 12/14/21 Page 80 of 84
81
COUNT IV: BATTERY
(CIVIL CONSPIRACY BY ALL DEFENDANTS)
300. Plaintiff reincorporates by reference the allegations contained in all preceding
paragraphs.
301. This Count is brought by Plaintiff against all Defendants.
302. As set forth above, Defendants agreed to participate together in a common scheme
to commit unlawful acts, or to commit lawful acts by unlawful means, including, but not limited
to, unlawfully obstructing federal officials in the performance of their constitutional duties,
unlawfully inciting and carrying out a riot, unlawfully trespassing on federal property, and
committing numerous acts of intimidation, threats of violence, and violence.
303. Pursuant to, and in furtherance of that common scheme, the Defendants’ intentional
actions caused harmful and offensive bodily contact with individuals in and around the Capitol,
including MPD officers.
304. Based on the foregoing, all Defendants are liable to the District as civil co-
conspirators for the resulting damage.
COUNT V: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(CIVIL CONSPIRACY BY ALL DEFENDANTS)
305. Plaintiff reincorporates by reference the allegations contained in all preceding
paragraphs.
306. This Count is brought by Plaintiff against all Defendants.
307. As set forth above, Defendants agreed to participate together in a common scheme
to commit unlawful acts, or to commit lawful acts by unlawful means, including, but not limited
to, unlawfully obstructing federal officials in the performance of their constitutional duties,
Case 1:21-cv-03267 Document 1 Filed 12/14/21 Page 81 of 84
82
unlawfully inciting and carrying out a riot, unlawfully trespassing on federal property, and
committing numerous acts of intimidation, threats of violence, and violence.
308. Pursuant to, and in furtherance of that common scheme, Defendants exhibited
extreme and outrageous conduct that went beyond all possible bounds of decency. This conduct
intentionally or recklessly caused MPD officers to suffer from severe emotional distress, as
described supra.
309. Based on the foregoing, all Defendants are liable to the District as civil co-
conspirators for the resulting damage.
PRAYER FOR RELIEF
Wherefore, Plaintiff respectfully requests an award of the following relief:
A. A declaratory judgment that the actions described herein constitute a violation of
42 U.S.C. § 1985(1); 42 U.S.C. § 1986; and the torts of assault, battery, and intentional infliction
of emotional distress.
B. Injunctive relief enjoining Defendants from engaging in future violations of
42 U.S.C. § 1985(1); 42 U.S.C. § 1986; and the torts of assault, battery, and intentional infliction
of emotional distress.
C. Compensatory and statutory damages in an amount to be determined at trial as to
damages incurred by the District resulting from the events alleged above.
D. Punitive damages at an amount to be determined at trial.
E. Attorneys’ fees and court costs under 42 U.S.C. § 1988.
F. Such other relief as the Court deems just and proper.
JURY DEMAND
The District demands a trial by jury for all claims so triable.
Case 1:21-cv-03267 Document 1 Filed 12/14/21 Page 82 of 84
83
Dated: December 14, 2021
Counsel for Plaintiff District of Columbia:
KARL A. RACINE, ATTORNEY GENERAL
FOR THE DISTRICT OF COLUMBIA
By: /s/ Kathleen Konopka
Kathleen Konopka (D.C. Bar 495257)
Vikram Swaruup (D.C. Bar 1670692)
400 6th St. NW
Washington, DC 20001
Tel: 202-724-6533
Email: vikram.swa[email protected]
STATES UNITED DEMOCRACY CENTER
By: /s/ Norman Eisen
Norman Eisen (D.C. Bar 435051)
1420 K Street NW
Washington, DC 20005
Tel: 202-656-8178
Email: norm@statesuniteddemocracy.org
By: /s/ Christine Sun
Christine P. Sun*
Katherine Reisner*
3749 Buchanan St., No. 475165
San Francisco, CA 94147-3103
Tel: 615-574-9108
Email:christine@statesuniteddemocracy.org
By: /s/ Aaron Scherzer
Aaron Scherzer*
572 Valley Road, No. 43592
Montclair, NJ 07043
Tel: 862-367-6480
Email: aaron@statesuniteddemocracy.org
DECHERT LLP
By: /s/ Matthew Larrabee
Matthew L. Larrabee*
1095 Avenue of the Americas
THE ANTI-DEFAMATION LEAGUE
By: /s/ Eileen Hershenov
Eileen B. Hershenov*
605 Third Avenue
New York, NY 10158-3650
Tel: 212-885-5805
Email: ehershe[email protected]
PAUL, WEISS, RIFKIND, WHARTON &
GARRISON LLP
By: /s/ Jeannie Rhee
Jeannie S. Rhee (D.C. Bar 464127)
2001 K Street, NW
Washington, D.C. 20006-1047
Tel: 202-223-7300
Fax: 202-223-7420
Email: jrhee@paulweiss.com
By: /s/ Daniel Kramer
Daniel J. Kramer*
Andrew J. Ehrlich*
Erin J. Morgan*
1285 Avenue of the Americas
New York, NY 10019-6064
Tel: 212-373-3000
Fax: 212-757-3990
Email: dkramer@paulweiss.com
aehrlich@paulweiss.com
Case 1:21-cv-03267 Document 1 Filed 12/14/21 Page 83 of 84
84
* Pro hac vice application forthcoming
New York, NY 10036-6797
Tel: 212-698-3500
Fax: 212-698-3599
Email: matthew.larrabee@dechert.com
By: /s/ Vincent Cohen
Vincent H. Cohen, Jr. (D.C. Bar 471489)
D. Brett Kohlhofer (D.C. Bar 1022963)
1900 K Street, NW
Washington, D.C. 20006-1110
Tel: 202-261-3300
Fax: 202-261-3333
Email: vincent.cohen@dechert.com
By: /s/ Michael Doluisio
Michael S. Doluisio*
2929 Arch Street
Philadelphia, PA 19104-2808
Tel: 215-994-2000
Fax: 215-994-2222
Email: michael.doluisio@dechert.com
Case 1:21-cv-03267 Document 1 Filed 12/14/21 Page 84 of 84
CIVIL COVER SHEET
JS-44 (Rev. 11/2020 DC)
I. (a) PLAINTIFFS
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF _____________________
(EXCEPT IN U.S. PLAINTIFF CASES)
DEFENDANTS
COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT _____________________
(IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED
(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) ATTORNEYS (IF KNOWN)
II. BASIS OF JURISDICTION
(PLACE AN x IN ONE BOX ONLY)
III. CITIZENSHIP OF PRINCIPAL PARTIES (PLACE AN x IN ONE BOX FOR
PLAINTIFF AND ONE BOX FOR DEFENDANT) FOR DIVERSITY CASES ONLY!
o
1 U.S. Government
Pla intiff
o 2 U.S. Government
Defenda nt
o
3 Federal Question
(U.S. Government Not a Party)
o 4 Diversity
(Indica te Citizenship of
Parties in item III)
Citizen of this State
Citizen of Another Sta te
Citizen or Subject of a
Foreign Country
PTF
o 1
o 2
o 3
DFT
o 1
o 2
o 3
Incorporated or Principal Pla ce
of Business in This Sta te
Incorporated and Principal Place
of Business in Another State
Foreign Nation
PTF
o 4
o 5
o 6
DFT
o 4
o 5
o 6
IV. CASE ASSIGNMENT AND NATURE OF SUIT
(Place an X in one category, A-N, that best represents your Cause of Action and one in a corresponding Nature of Suit)
o
A. Antitrust
410 Antitrust
o
B. Personal Injury/
Malpractice
310 Airplane
315 Airplane Product Liability
320 Assault, Libel & Slander
330 Federal Employers Liability
340 Marine
345 Marine Product Liability
350 Motor Vehicle
355 Motor Vehicle Product Liability
360 Other Personal Injury
362 Medical Malpractice
365 Product Liability
367 Health Care/Pharmaceutical
Personal Injury Product Liability
368 Asbestos Product Liability
o
C. Administrative Agency
Review
151 Medicare Act
Social Security
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))
Other Statutes
891 Agricultural Acts
893 Environmental Matters
890 Other Statutory Actions (If
Administrative Agency is
Involved)
o
D. Temporary Restraining
Order/Preliminary
Injunction
Any nature of suit from any category
may be selected for this category of
case assignment.
*(If Antitrust, then A governs)*
o
E. General Civil (Other) OR
o
F. Pro Se General Civil
Real Property
210 Land Condemnation
220 Foreclosure
230 Rent, Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property
Personal Property
370 Other Fraud
371 Truth in Lending
380 Other Personal Property
Damage
385 Property Damage
Product Liability
Bankruptcy
422 Appeal 27 USC 158
423 Withdrawal 28 USC 157
Prisoner Petitions
535 Death Penalty
540 Mandamus & Other
550 Civil Rights
555 Prison Conditions
560 Civil Detainee – Conditions
of Confinement
Property Rights
820 Copyrights
830 Patent
835 Patent – Abbreviated New
Drug Application
840 Trademark
880 Defend Trade Secrets Act of
2016 (DTSA)
Federal Tax Suits
870 Taxes (US plaintiff or
defendant)
871 IRS-Third Party 26 USC
7609
Forfeiture/Penalty
625 Drug Related Seizure of
Property 21 USC 881
690 Other
Other Statutes
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
400 State Reapportionment
430 Banks & Banking
450 Commerce/ICC Rates/etc
460 Deportation
462 Naturalization
Application
465 Other Immigration Actions
470 Racketeer Influenced
& Corrupt Organization
480 Consumer Credit
485 Telephone Consumer
Protection Act (TCP )
490 Cable/Satellite TV
850 Securities/Commodities/
Exchange
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of State
Statutes
890 Other Statutory Actions
(if not administrative agency
review or Privacy Act)
Case 1:21-cv-03267 Document 1-1 Filed 12/14/21 Page 1 of 5
o
G. Habeas Corpus/
2255
530 Habeas Corpus – General
510 Motion/Vacate Sentence
463 Habeas Corpus – Alien
Detainee
o
H. Employment
Discrimination
442 Civil Rights – Employment
(criteria: race, gender/sex,
national origin,
discrimination, disability, age,
religion, retaliation)
*(If pro se, select this deck)*
o
I. FOIA/Privacy Act
895 Freedom of Information Act
890 Other Statutory Actions
(if Privacy Act)
*(If pro se, select this deck)*
o
J. Student Loan
152 Recovery of Defaulted
Student Loan
(excluding veterans)
o
K. Labor/ERISA
(non-employment)
710 Fair Labor Standards Act
720 Labor/Mgmt. Relations
740 Labor Railway Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Empl. Ret. Inc. Security Act
o
L. Other Civil Rights
(non-employment)
441 Voting (if not Voting Rights
Act)
443 Housing/Accommodations
440 Other Civil Rights
445 Americans w/Disabilities –
Employment
446 Americans w/Disabilities –
Other
448 Education
o
M. Contract
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of
Judgment
153 Recovery of Overpayment
of Veteran’s Benefits
160 Stockholder’s Suits
190 Other Contracts
195 Contract Product Liability
196 Franchise
o
N. Three-Judge
Court
441 Civil Rights – Voting
(if Voting Rights Act)
V. ORIGIN
o
1 Original
Proceeding
o
2 Removed
from State
Court
o
3 Remanded
from Appellate
Court
o
4 Reinstated
or Reopened
o
5 Transferred
from another
district (specify)
o
6 Multi-district
Litigation
o
7 Appeal to
District Judge
from Mag.
Judge
o
8 Multi-district
Litigation –
Direct File
VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.)
VII. REQUESTED IN
COMPLAINT
CHECK IF THIS IS A CLASS
ACTION UNDER F.R.C.P. 23
DEMAND $
JURY DEMAND:
Check YES only if demanded in complaint
YES NO
VIII. RELATED CASE(S)
IF ANY
(See instruction)
YES NO
If yes, please complete rela ted case form
DATE: _________________________
SIGNATURE OF ATTORNEY OF RECORD _________________________________________________________
INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET JS-44
Authority for Civil Cover Sheet
The JS-44 civil cover sheet and the information conta ined herein neither replaces nor supplements the filings and services of pleadings or other papers as required
by la w, except as provided by loca l rules of court. This form, approved by the Judicial Conference of the United Sta tes in September 1974, is required for the use of the
Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed.
Listed below a re tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the cover sheet.
I. COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence: Use 11001 to indicate plaintiff if resident
of Washington, DC, 88888 if plaintiff is resident of United States but not Washington, DC, a nd 99999 if plaintiff is outside the United States.
III. CITIZENSHIP OF PRINCIPAL PARTIES: This section is completed only if diversity of citizenship was selected as the Basis of Jurisdiction
under Section II.
IV. CASE ASSIGNMENT AND NATURE OF SUIT: The assignment of a judge to your case will depend on the ca tegory you select tha t best
represents the prima ry cause of action found in your complaint. You ma y select only one ca tegory. You must also select one corresponding
nature of suit found under the category of the case.
VI. CAUSE OF ACTION: Cite the U.S. Civil Sta tute under which you a re filing and write a brief sta tement of the primary cause.
VIII. RELATED CASE(S), IF ANY: If you indicated tha t there is a related case, you must complete a rela ted ca se form, which may be obta ined from
the Clerk’s Office.
Because of the need for accurate and complete information, you should ensure the a ccuracy of the information provided prior to signing the form.
Case 1:21-cv-03267 Document 1-1 Filed 12/14/21 Page 2 of 5
ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1 50.
Case 1:21-cv-03267 Document 1-1 Filed 12/14/21 Page 3 of 5
ATTACHMENT B
Counsel for Plaintiff District of Columbia
KARL A. RACINE, ATTORNEY GENERAL FOR THE DISTRICT OF
COLUMBIA
Kathleen Konopka (D.C. Bar 495257)
Vikram Swaruup (D.C. Bar 1670692)
400 6th St. NW
Washington, DC 20001
Tel: 202-724-6533
Email: [email protected]
STATES UNITED DEMOCRACY CENTER
Norman Eisen (D.C. Bar 435051)
1420 K Street NW
Washington, DC 20005
Tel: 202-656-8178
Email: norm@statesuniteddemocracy.org
Christine P. Sun
3749 Buchanan St., No. 475165
San Francisco, CA 94147-3103
Tel: 615-574-9108
Email:christine@statesuniteddemocracy.org
Aaron Scherzer
572 Valley Road, No. 43592
Montclair, NJ 07043
Tel: 862-367-6480
Email: aaron@statesuniteddemocracy.org
THE ANTI-DEFAMATION LEAGUE
Eileen B. Hershenov
605 Third Avenue
New York, NY 10158-3650
Tel: 212-885-5805
Email: [email protected]
Case 1:21-cv-03267 Document 1-1 Filed 12/14/21 Page 4 of 5
2
PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
Jeannie S. Rhee (D.C. Bar 464127)
2001 K Street, NW
Washington, D.C. 20006-1047
Tel: 202-223-7300
Fax: 202-223-7420
Email: jrhee@paulweiss.com
Daniel J. Kramer
Andrew J. Ehrlich
Erin J. Morgan
1285 Avenue of the Americas
New York, NY 10019-6064
Tel: 212-373-3000
Fax: 212-757-3990
Email: dkramer@paulweiss.com; [email protected]; ejmorgan@paulweiss.com
DECHERT LLP
Email: mi[email protected]
Matthew L. Larrabee
1095 Avenue of the Americas
New York, NY 10036-6797
Tel: 212-698-3500
Fax: 212-698-3599
Email: matthew.la[email protected]
Vincent H. Cohen, Jr. (D.C. Bar 471489)
D. Brett Kohlhofer (D.C. Bar 1022963)
1900 K Street, NW
Washington, D.C. 20006-1110
Tel: 202-261-3300
Fax: 202-261-3333
Email: [email protected]; d.brett.kohlhofer@dechert.com
Michael S. Doluisio
2929 Arch Street
Philadelphia, PA 19104-2808
Tel: 215-994-2000
Fax: 215-994-2222
Case 1:21-cv-03267 Document 1-1 Filed 12/14/21 Page 5 of 5
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-2 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Proud Boys International, L.L.C.
c/o Henry "Enrique" Tarrio
Chairman
DCDC No. 376128
1901 D Street, SE
Washington, DC 20003
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-2 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-2 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-3 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Oath Keepers,
5130 Fort Apache Rd,
Las Vegas, NV 89148
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-3 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-3 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-4 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Ryan Ashlock,
711 S. Spruce Cir.,
Gardner, KS 66030-1632
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-4 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-4 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-5 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Joseph Randall Biggs
Inmate No. 202100002744
c/o Seminole County Jail (G)
211 Eslinger Way
Sanford, Florida 32773
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-5 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-5 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-6 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Marc Anthony Bru,
10013 NE Hazel Dell Ave. #2,
Vancouver, WA 98685-5203
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-6 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-6 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-7 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Thomas Edward Caldwell,
274 Wadesville Rd.,
Berryville, VA 22611-1821
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-7 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-7 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-8 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
William Chrestman
c/o Correctional Treatment Facility (CTF)
DCDC No. 376975
1901 E St SE
Washington, D.C. 20003
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-8 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-8 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-9 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Louis Enrique Colon,
131 SW 27th St.,
Blue Springs, MO 64015-3342
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-9 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-9 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-10 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Donovan Ray Crowl,
216 N Main St.,
Woodstock, OH 43084
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-10 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-10 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-11 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Nicholas DeCarlo
712 SW Sunset Lane
Burleson, TX
76028-5220
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-11 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-11 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-12 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Charles Donohoe
c/o NC Detention Center
125 Court Street
Hillsborough, NC 27278
Orange County
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-12 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-12 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-13 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Kenneth Harrelson
c/o Seminole County Jail,
211 Eslinger Way,
Sanford, FL 32773
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-13 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-13 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-14 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Arthur Jackman,
4030 N. Econlockhatchee Trail
Orlando, Fl. 32817-1327
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-14 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-14 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-15 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Joshua James,
1463 Brashiers Chapel Rd.,
Arab, AL 35016-2727
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-15 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-15 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-16 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Jonathanpeter Klein
c/o 21 SE 10th St.
Pendleton, OR 97801-2401
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-16 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-16 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-17 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Christopher Kuehne,
16657 S. Chalet Dr.,
Olathe, KS 66062-2513
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-17 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-17 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-18 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Connie Meggs,
14100 SW 101st Ln.,
Dunnellon, FL. 34432-4700
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-18 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-18 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-19 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Kelly Meggs
DCDC # 376780
c/o Correctional Treatment Facility,
1901 E. St., SE,
Washington, D.C. 20003
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-19 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-19 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-20 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Roberto A. Minuta,
120 Gray LN
Prosper, TX 75078-3010
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-20 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-20 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-21 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Ethan Nordean
Inmate No. 28596-509
c/o Federal Detention Center
2425 S 200th Street
Seatac, WA 98189
King County
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-21 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-21 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-22 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Nicholas Robert Ochs
3245 Virginia St
Apt 56,
Miami, FL 33133-5250
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-22 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-22 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-23 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Bennie Alvin Parker,
1170 Essex Gln,
Morrow, OH 45152
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-23 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-23 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-24 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Sandra Ruth Parker,
1170 Essex Gln,
Morrow, OH 45152
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-24 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-24 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-25 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
William Joseph Pepe,
85 Judson St.,
Apt. 2,
Beacon, NY 12508
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-25 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-25 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-26 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Dominic Pezzola
c/o Correctional Treatment Facility (CTF)
DCDC No. 376366
1901 E Street SE
Washington, DC 20003
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-26 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-26 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-27 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Zachary Rehl
Inmate No. 34945-509
c/o Philadelphia Federal Detention Center
700 Arch St.
Philadelphia, PA 19106
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-27 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-27 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-28 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Jon Ryan Schaffer
5162 Timber Ridge Dr.,
Columbus, IN 47201-8816
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-28 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-28 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-29 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Daniel Lyons Scott
122 W Perry LN
Englewood, FL 34223-2943
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-29 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-29 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-30 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Laura Steele,
249 Newcastle Ct.,
Thomasville, NC 27360
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-30 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-30 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-31 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Henry "Enrique" Tarrio,
c/o The Central Detention Facility
DCDC No. 376128
1901 D Street, SE
Washington, DC 20003
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-31 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-31 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-32 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Jessica Marie Watkins
DCDC # 376520
c/o Correctional Treatment Facility,
1901 E. St., SE,
Washington, D.C. 20003
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-32 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-32 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-33 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Christopher John Worrell
282 Stanhope Circle
Naples, FL 34104-0810
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-33 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-33 Filed 12/14/21 Page 3 of 3
AO 440 (Rev. 06/12; DC 3/15) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
)
)
)
)
)
Plaintiff(s)
v. Civil Action No.
Defendant(s)
SUMMONS IN A CIVIL ACTION
To:
(Defendant’s name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff’s attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
ANGELA D. CAESAR, CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Case 1:21-cv-03267 Document 1-34 Filed 12/14/21 Page 1 of 3
District of Columbia
District of Columbia
See Attachment A
Graydon Young,
7147 Lago St.,
Sarasota, FL 34241
Jeannie S. Rhee
Paul, Weiss, Rifkind, Wharton & Garrison LLP
2001 K Street, NW
Washington, DC 20006-1047
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for
(name of individual and title, if any)
was received by me on (date) .
’ I personally served the summons on the individual at
(place)
on (date) ; or
’ I left the summons at the individual’s residence or usual place of abode with
(name)
, a person of suitable age and discretion who resides there,
on
(date) , and mailed a copy to the individual’s last known address; or
’ I served the summons on
(name of individual) , who is
designated by law to accept service of process on behalf of
(name of organization)
on (date) ; or
’ I returned the summons unexecuted because ; or
’ Other
(specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc:
Case 1:21-cv-03267 Document 1-34 Filed 12/14/21 Page 2 of 3
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ATTACHMENT A
Defendants
Proud Boys International, L.L.C.
Oath Keepers
Ryan Ashlock
Joseph Randall Biggs
Marc Anthony Bru
Thomas Edward Caldwell
William Chrestman
Louis Enrique Colon
Donovan Ray Crowl
Nicholas DeCarlo
Charles Donohoe
Kenneth Harrelson
Arthur Jackman
Joshua James
Jonathanpeter Klein
Christopher Kuehne
Connie Meggs
Kelly Meggs
Roberto A. Minuta
Ethan Nordean
Nicholas Robert Ochs
Bennie Alvin Parker
Sandra Ruth Parker
William Joseph Pepe
Dominic Pezzola
Zachary Rehl
Jon Ryan Schaffer
Daniel Lyons Scott
Laura Steele
Henry “Enrique” Tarrio
Jessica Marie Watkins
Christopher John Worrell
Graydon Young
John and Jane Does 1−50.
Case 1:21-cv-03267 Document 1-34 Filed 12/14/21 Page 3 of 3
