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Fourth Superseding Indictment: U.S.A. v. Thomas Caldwell, et al.Case No. 21-cr-28-APM
by Channing D. Phillips, Acting Attorney for the U.S. in and For the District of Columbia
May 30, 2021
-- ‘A Total Failure’: The Proud Boys Now Mock Trump: Members of the far-right group, who were among Donald Trump’s staunchest fans, are calling him “weak” as more of them were charged for storming the U.S. Capitol, by Sheera Frenkel and Alan Feuer-- Facebook's fight club: how the Proud Boys use the social media platform to vet their fighters: Want to join the far-right group the Proud Boys? Simply apply to your nearest regional vetting page on the world’s largest social network, Facebook, by Southern Poverty Law Center-- Fight Club at 20: A vision of Trump’s United States: David Fincher’s film, starring Brad Pitt and Edward Norton, was eerily prescient, by Scott Tobias-- New "Fight Club" Ready for Street Violence: A new fight club “fraternity” of young white, pro-Trump men is being formed, its organizers claim, to defend free-speech rights by “Alt-Right” leaders and engage in street fighting, by Bill Morlin-- Proud Boys Call For Disguises, Violence At Biden Inauguration, by Michael Stone-- Proud Boys leader ordered to stay away from D.C. after arrest, by Clare Hymes, Caroline Linton
-- Proud Boys Leader Secretly Cooperated With F.B.I. and Police: Enrique Tarrio, the chairman of the far-right nationalist group, which is under increasing scrutiny for its role in the Capitol riot, helped to convict more than a dozen people, by Alan Feuer-- This "Oath Keeper" Says She Met with Secret Service BEFORE The Capitol Riot, by Ana Kasparian, Cenk Uygur
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
Holding a Criminal Term
Grand Jury Sworn in on January 8, 2021
UNITED STATES OF AMERICA
v.
THOMAS CALDWELL, (Counts 1,2,4,9)
DONOVAN CROWL, (Counts 1,2,3,4,6)
JESSICA WATKINS, (Counts 1, 2, 3, 4, 6)
SANDRA PARKER, (Counts 1,2,3,4,6)
BENNIE PARKER, (Counts I, 2, 4)
GRAYDON YOUNG, (Counts 1,2,3,4,6, 10)
LAURA STEELE, (Counts 1,2,3,4)
KELLY MEGGS, (Counts 1,2,3,4, II)
CONNIE MEGGS, (Counts I, 2, 3, 4)
KENNETH HARRELSON, (Counts 1,2,3,4,12)
ROBERTO MINUTA, (Counts 1, 2,4)
JOSHUA JAMES, (Counts 1,2,4,7,8,13)
JOSEPH HACKETT, (Counts 1, 2, 3, 4)
JASON DOLAN, and (Counts 1, 2, 3, 4)
WILLIAM ISAACS, (Counts 1, 2, 3, 4, 5, 6)
Defendants.
CRIMINAL NO. 21-cr-28-APM
VIOLATIONS:
18 U.S.C. § 371
(Conspiracy)18 U.S.C. §§ ISI2(c)(2), 2
(Obstruction of an Official Proceeding and Aiding and Abetting)18 U.S.C. §§ 1361, 2
(Destruction of Government Property and Aiding and Abetting)18 U.S.C. § I752(a)(1)
(Entering and Remaining in a Restricted Building or Grounds)18 U.S.C. §§ 231 (a)(3), 2
(Civil Disorder and Aiding and Abetting)19 U.S.C. § 111(a)(1), 2 (
Assaulting, Resisting, or Impeding Certain Officers and Aiding and Abetting)18 U.S.C. § 1512(c)(1)
(Tampering with Documents or Proceedings)FOURTH SUPERSEDING INDICTMENTThe Grand Jury charges that, at all times material to this Indictment, on or about the dates and times stated below:
IntroductionThe 2020 United States Presidential Election and the Official Proceeding on January 6, 20211. The 2020 United States Presidential Election occurred on November 3, 2020.
2. The United States Electoral College ("Electoral College") is a group required by the Constitution to form every four years for the sole purpose of electing the president and vice president, with each state appointing its own electors in a number equal to the size of that state's Congressional delegation.
3. On December 14, 2020, the presidential electors of the Electoral College met in the state capital of each state and in the District of Columbia and formalized the result of the 2020 U.S. Presidential Election: Joseph R. Biden Jr. and Kamala D. Harris were declared to have won sufficient votes to be elected the next president and vice president of the United States.
4. On January 6, 2021, a Joint Session of the United States House of Representatives and the United States Senate (“the Joint Session”) convened in the United States Capitol (“the Capitol”) building. The purpose of the Joint Session was to open, count, and resolve any objections to the Electoral College vote of the 2020 U.S. Presidential Election, and to certify the results of the Electoral College vote (“Certification of the Electoral College vote”) as set out in the Twelfth Amendment of the Constitution of the United States and 3 U.S.C. §§ 15-18.
The Attack at the U.S. Capitol on January 6, 20215.
The Capitol is secured 24 hours a day by United States Capitol Police (“Capitol Police”). The Capitol Police maintain permanent and temporary barriers to restrict access to the Capitol exterior, and only authorized individuals with appropriate identification are allowed inside the Capitol building.6. On January 6, 2021, at approximately 1:00 p.m., the Joint Session convened in the Capitol building for the Certification of the Electoral College vote. Vice President Michael R. Pence, in his constitutional duty as President of the Senate, presided over the Joint Session.
7.
A large crowd began to gather outside the Capitol perimeter as the Joint Session got underway. Crowd members eventually forced their way through, up, and over Capitol Police barricades and advanced to the building’s exterior façade. Capitol Police officers attempted to maintain order and stop the crowd from entering the Capitol building, to which the doors and windows were locked or otherwise secured. Nonetheless, shortly after 2:00 p.m., crowd members forced entry into the Capitol building by breaking windows, ramming open doors, and assaulting Capitol Police officers. Other crowd members encouraged and otherwise assisted the forced entry. The crowd was not lawfully authorized to enter or remain inside the Capitol, and no crowd member submitted to security screenings or weapons checks by Capitol Police or other security officials.8. Shortly thereafter, at approximately 2:20 p.m., members of the House and Senate (including Vice President Pence)—who had withdrawn to separate chambers to resolve an objection—were evacuated from their respective chambers. The Joint Session was halted while Capitol Police and other law-enforcement officers worked to restore order and clear the Capitol of the unlawful occupants.
9. Later that night, law enforcement regained control of the Capitol. At approximately 8:00 p.m., the Joint Session reconvened, presided over by Vice President Pence, who had remained hidden within the Capitol building throughout these events.
10.
In the course of these events, over 100 members of law enforcement were assaulted. The Capitol suffered millions of dollars in damage—including broken windows and doors, graffiti, and residue from pepper spray, tear gas, and fire extinguishers deployed both by crowd members who stormed the Capitol and by Capitol Police officers trying to restore order. Additionally, many media members were assaulted and had cameras and other news-gathering equipment destroyed.The Oath Keepers Militia11.
Members and affiliates of an organization known as the Oath Keepers were among the individuals and groups who forcibly entered the Capitol on January 6, 2021. The Oath Keepers are a large but loosely organized collection of individuals, some of whom are associated with militias. Some members of the Oath Keepers believe that the federal government has been coopted by a cabal of elites actively trying to strip American citizens of their rights. Though the Oath Keepers will accept anyone as members, they explicitly focus on recruiting current and former military, law enforcement, and first-responder personnel. The organization’s name alludes to the oath sworn by members of the military and police to defend the Constitution “from all enemies, foreign and domestic.” The Oath Keepers are led by PERSON ONE.12.
On January 4, 2021, PERSON ONE posted an article to the Oath Keepers website encouraging Oath Keeper members and affiliates to go to Washington, D.C., for the events of January 5-6, 2021, stating: “It is CRITICAL that all patriots who can be in DC get to DC to stand tall in support of President Trump’s fight to defeat the enemies foreign and domestic who are attempting a coup, through the massive vote fraud and related attacks on our Republic. We Oath Keepers are both honor-bound and eager to be there in strength to do our part.”
13. In his January 4 post, PERSON ONE also observed: “As we have done on all recent DC Ops, we will also have well armed and equipped QRF1 [quick reaction force] teams on standby, outside DC, in the event of a worst case scenario, where the President calls us up as part of the militia to to assist him inside DC. We don’t expect a need for him to call on us for that at this time, but we stand ready if he does (and we also stand ready to answer the call to serve as militia anytime in the future, and anywhere in our nation, if he does invoke the Insurrection Act).”An Act authorizing the employment of the land and naval forces of the United States, in cases of insurrections.
Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, That in all cases of insurrection, or obstruction to the laws, either of the United States, or of any individual state or territory, where it is lawful for the President of the United States to call forth the militia for the purpose of suppressing such insurrection, or of causing the laws to be duly executed, it shall be lawful for him to employ, for the same purposes, such part of the land or naval force of the United States, as shall be judged necessary, having first observed all the pre-requisites of the law in that respect.
APPROVED, March 3, 1807.
14. PERSON ONE named PERSON TEN to be the leader of his group’s operations in Washington, D.C., on January 6, 2021.
Conspirators15. THOMAS CALDWELL was a 65-year-old resident of Berryville, Virginia.2
CALDWELL used the monikers “CAG,” “Spy,” and “CAG Spy.”16. DONOVAN CROWL was a 50-year-old resident of Woodstock, Ohio.
17. JESSICA WATKINS was a 38-year-old resident of Woodstock, Ohio.
18. SANDRA PARKER was a 60-year-old resident of Morrow, Ohio, and the wife of BENNIE PARKER.
19. BENNIE PARKER was a 70-year-old resident of Morrow, Ohio, and the husband of SANDRA PARKER.
20. GRAYDON YOUNG was a 54-year-old resident of Englewood, Florida, and the brother of LAURA STEELE. YOUNG used the moniker “GenXPatriot.”
21. LAURA STEELE was a 52-year-old resident of Thomasville, North Carolina, and the sister of YOUNG.
22. KELLY MEGGS was a 52-year-old resident of Dunnellon, Florida, and the husband of CONNIE MEGGS. KELLY MEGGS used the moniker “Gator 1” or “OK Gator 1.”
23. CONNIE MEGGS was a 59-year-old resident of Dunnellon, Florida, and the wife of KELLY MEGGS.
24. KENNETH HARRELSON was a 40-year-old resident of Titusville, Florida. HARRELSON used the moniker “Gator 6.”
25. ROBERTO MINUTA was a 36-year-old resident of Prosper, Texas.
26. JOSHUA JAMES was a 33-year-old resident of Arab, Alabama. JAMES used the moniker “Hydro.”
27.
[DELETE]28. JOSEPH HACKETT was a 50-year-old resident of Sarasota, Florida. HACKETT used the moniker “Ahab.”
29. JASON DOLAN was a 44-year-old resident of Wellington, Florida. DOLAN used the moniker “Turmoil.”
30. WILLIAM ISAACS was a 21-year-old resident of Kissimmee, Florida.
COUNT ONE
(Conspiracy—18 U.S.C. § 371)31. The introductory allegations set forth in paragraphs 1 through 30 are re-alleged and incorporated by reference as though set forth herein.
The Conspiracy32. From at least as early as November 3, 2020, through January 6, 2021, in the District of Columbia and elsewhere, the defendants,
THOMAS CALDWELL,
DONOVAN CROWL,
JESSICA WATKINS,
SANDRA PARKER,
BENNIE PARKER,
GRAYDON YOUNG,
LAURA STEELE,
KELLY MEGGS,
CONNIE MEGGS,
KENNETH HARRELSON,
ROBERTO MINUTA,
JOSHUA JAMES,
[DELETE]JOSEPH HACKETT,
JASON DOLAN, and
WILLIAM ISAACS,
did knowingly combine, conspire, confederate, and agree with each other and others known and unknown, to commit an offense against the United States, namely, to corruptly obstruct, influence, and impede an official proceeding, that is, the Certification of the Electoral College vote, in violation of Title 18, United States Code, Section 1512(c)(2).Purpose of the Conspiracy33.
The purpose of the conspiracy was to stop, delay, and hinder the Certification of the Electoral College vote.Manner and Means34. CALDWELL, CROWL, WATKINS, SANDRA PARKER, BENNIE PARKER, YOUNG, STEELE, KELLY MEGGS, CONNIE MEGGS, HARRELSON, MINUTA, JAMES,
[DELETE], HACKETT, DOLAN, and ISAACS, with others known and unknown,
carried out the conspiracy through the following manner and means, among others, by:
a. Agreeing to participate in and planning an operation to interfere with the Certification of the Electoral College vote on January 6, 2021 (the “January 6 operation”);
b. Attending or scheduling trainings to teach and learn paramilitary combat tactics in advance of the January 6 operation;
c. Using websites, social media, text messaging, and messaging applications to recruit other individuals to travel to Washington, D.C., to support the January 6 operation;
d. Coordinating in advance with others, including members of the Oath Keepers from other regions, and joining forces with these individuals and groups to further the January 6 operation;
e. Traveling to Washington, D.C., for the January 6 operation;
f. Bringing and contributing paramilitary gear and supplies—including firearms, camouflaged combat uniforms, tactical vests with plates, helmets, eye protection, and radio equipment—for the January 6 operation;
g. Donning clothes with the Oath Keepers insignia for the January 6 operation;
h. Changing into paramilitary gear—including helmets—before participating in the January 6 operation;
i. Moving together in a military “stack” formation while utilizing hand signals to maintain communication and coordination while advancing toward the Capitol as part of the January 6 operation;
j. Forcibly storming past exterior barricades, Capitol Police, and other law enforcement officers, and entering the Capitol in executing the January 6 operation; and
k. Using secure and encrypted communications applications like Signal3 and Zello4 to develop plans and later communicate during the January 6 operation.Overt Acts
Planning for January 6, 202135.
At a GoToMeeting5 held on November 9, 2020, PERSON ONE told those attending the meeting, “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.” PERSON ONE called upon his followers to go to Washington, D.C., to let the President know “that the people are behind him.” PERSON ONE told his followers they needed to be prepared to fight Antifa, which he characterized as a group of individuals with whom “if the fight comes, let the fight come. Let Antifa – if they go kinetic on us, then we’ll go kinetic back on them. I’m willing to sacrifice myself for that. Let the fight start there. That will give President Trump what he needs, frankly. If things go kinetic, good. If they throw bombs at us and shoot us, great, because that brings the president his reason and rationale for dropping the Insurrection Act.” PERSON ONE 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.” WATKINS, KELLY MEGGS, HARRELSON, HACKETT, PERSON THREE, PERSON TEN, and others known and unknown attended this GoToMeeting. After PERSON ONE finished speaking, WATKINS and KELLY MEGGS asked questions and made comments about what types of weapons were legal in the District of Columbia.
36. On November 9, 2020, WATKINS, the self-described “C.O. [Commanding Officer] of the Ohio State Regular Militia,” sent text messages to recruit a number of individuals who had expressed interest in joining the Ohio State Regular Militia. In these messages,
WATKINS mentioned, among other things, that the militia had a week-long “Basic Training class coming up in the beginning of January,” and told one recruit, “I need you fighting fit by innaugeration.” In describing the program to PERSON TEN, WATKINS said, “It’s a military style basic, here in Ohio, with a Marine Drill Sergeant running it. An hour north of Columbus Ohio[.]”
37. On November 9, 2020, WATKINS asked a recruit if he could “download an App called Zello” and stated, “We all use Zello though for operations.”
38. On November 17, 2020, when a recruit asked WATKINS for her predictions for 2021, WATKINS replied, among other statements:
I can’t predict. I don’t underestimate the resolve of the Deep State. 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.
and:
[I]f Biden get the steal, none of us have a chance in my mind. We already have our neck in the noose. They just haven’t kicked the chair yet.
39. On November 23, 2020, CALDWELL sent a text message to WATKINS stating:
Hi, CAP! Wanted to tell you it was great to have you here in Virginia. Don’t know what [PERSON ONE] is cooking up but I am hearing rumblings of another Maga March 12 December.6 I don’t know what will happen but like you I am very worried about the future of our country. Once lawyers get involved all of us normal people get screwed. 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. I have my own gear, I like to be ON TIME and go where the enemy is, especially after dark. Keep the faith! Spy.
40. On December 3, 2020, YOUNG emailed the Florida chapter of the Oath Keepers a membership application and wrote, “looking to get involved in helping….”
41. On December 19, 2020, HACKETT sent an email to YOUNG with a subject line “test.” The body of the email stated: “I believe we only need to do this when important info is at hand like locations, identities, Ops planning.” The email had a photo attached; the photo showed cursive handwriting on a lined notepad that stated: “Secure Comms Test. Good talk tonight guys! Rally Point in Northern Port Charlotte at Grays if transportation is possible. All proton mails.7
May consider an RP8 that won’t burn anyone. Comms – work in progress. Messages in cursive to eliminate digital reads. Plans for recruitment and meetings.”
42. On December 19, 2020, YOUNG wrote to a Facebook group: “Please check out Oath Keepers as a means to get more involved. Recruiting is under way. DM me if you want more info.”
43. On December 22, 2020, YOUNG made plans to fly from Florida to North Carolina on January 4, 2021, with a return trip on January 8, 2021.
44. On December 22, 2020, KELLY MEGGS wrote a series of messages on Facebook to another individual that read in part:
a.
“Trump said It’s gonna be wild!!!!!!! It’s gonna be wild!!!!!!! He wants us to make it WILD that’s what he’s saying. He called us all to the Capitol and wants us to make it wild!!! Sir Yes Sir!!! Gentlemen we are heading to DC pack your shit!!”
b. “Nice, we will have at least 50-100 OK9 there.”
45. On December 25, 2020, KELLY MEGGS wrote a message on Facebook that said in relevant part: “I was named State lead of Florida today.”
46. On December 25, 2020, KELLY MEGGS wrote a message on Facebook that said in relevant part:
“We are all staying in DC near the Capitol we are at the Hilton garden inn but I think it’s full. Dc is no guns. So mace and gas masks, some batons. If you have armor that’s good.”47. On December 26, 2020, YOUNG wrote an email to a Florida company that conducts training on firearms and combat. YOUNG wrote, in part, “I trained with you not long ago. Since then I have joined Oath Keepers. I recommended your training to the team. To that effect, four of us would like to train with you, specifically in your UTM10 rifle class.”
48. On December 26 and 27, 2020, WATKINS and BENNIE PARKER exchanged text messages relating to preparations for the trip to Washington, D.C., on January 6, 2021. BENNIE PARKER also texted WATKINS, “I may have to see what it takes to join your militia, ours is about gone.”
49. On December 29, 2020, WATKINS sent text messages to CROWL sharing her plans to go to Washington, D.C., for the events of January 6, 2021.
50. On December 29 and 30, 2020, WATKINS and BENNIE PARKER exchanged text messages in which they discussed Oath Keeper membership and meeting in advance to prepare for the trip to Washington, D.C., on January 6, 2021.
51. On December 30, 2020, CALDWELL wrote in a Facebook post: “THIS IS OUR CALL TO ACTION, FREINDS! SEE YOU ON THE 6TH IN WASHINGTON, D.C. ALONG WITH 2 MILLION OTHER LIKE-MINDED PATRIOTS.”
52. On December 30, 2020, WATKINS and CALDWELL exchanged the following text messages:
WATKINS: Looks like we are greenlight to come to DC on the 6th. The Rally Point still at your place?
CALDWELL: Not that I am aware. Have been contacted by NO ONE. Typical [PERSON ONE]. Here’s the rub: [PERSON TWO] and I will be in a hotel within striking distance of the city starting on the 4th so we won’t even BE here. There will be some stuff going on during the 5th and we want to be a part of that whenever it shakes out. Also we want to be in D.C. very early on the 6th, hence closer/virtually no commute time.
WATKINS: We planned on arriving on the 5th. We want to be in DC by 9am on the 6th. I will reach out to [PERSON THREE], and see if NC boys are coming. If [PERSON ONE] isn’t making plans, I’ll take charge myself, and get the ball rolling. I think the Metro is smarter than convoy/parking issues. Do you want us to stage ourselves vehicles elsewhere, seeing how you’re going to be gone? We can go to a KOA Campground or something...
CALDWELL (about two hours later): Talked to [PERSON THREE]. At least one full bus 40+ people coming from N.C. Another group (unclear if Mississippi guys) also a bus. Busses have their own lane on the 14th street bridge so they will be able to get in and out. [PERSON THREE] is driving plus 1 and arriving nite before. As we speak he is trying to book a room at Comfort Inn Ballston/Arlington because of its close-in location and easy access to downtown because he feels 1) he’s too broken down to be on the ground all day and 2) he is committed to being the quick reaction force anf bringing the tools if something goes to hell. That way the boys don’t have to try to schlep weps on the bus. He’ll bring them in his truck day before. Just got a text from him he WAS able to book a room in that hotel I recommended which is on Glebe Road in Arlington. However it goes it will be great to see you again! I sure hope your arm is getting better!
53. On December 31, 2020, CALDWELL replied to a Facebook comment, writing,
“It begins for real Jan 5 and 6 on 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…”54. On December 31, 2020, when invited to a “leadership only” conference call on Signal for the “DC op,” WATKINS said she would try to make it if her work obligations permitted.
55. At least as early as December 31, 2020, WATKINS, KELLY MEGGS, JAMES, MINUTA, PERSON ONE, PERSON THREE, PERSON TEN, and others known and unknown joined an invitation-only encrypted Signal group message titled “DC OP: Jan 6 21” (hereinafter the “Leadership Signal Chat”).
56. On December 31, 2020, KELLY MEGGS wrote a series of messages to another person on Facebook that said,
“You guys Gonna carry?” and “Ok we aren’t either, we have a heavy QRF 10 Min out though.”57. On December 31, 2020, another individual contacted JAMES via Signal and stated:
“i have friends not far from DC with a lot of weapons and ammo if you get un trouble i ca. Coordinate help.” JAMES responded, “That might be helpful, but we have a shitload of QRF on standby with an arsenal.”58. On December 31, 2020, KELLY MEGGS and JAMES attended a 4-participant GoToMeeting titled “SE leaders dc 1/6/21 op call.” KELLY MEGGS was the organizer of the meeting.
59. On December 31, 2020, KELLY MEGGS and HARRELSON attended a GoToMeeting titled “florida dc op planning chat.” HARRELSON was the organizer of the meeting, which had about 15 participants.
60. On December 31, 2020, JAMES messaged PERSON NINETEEN and asked,
“Do we have a farm location for weapons?” PERSON NINETEEN 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 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.” JAMES replied, “I agree.”61. On January 1, 2021, PERSON FOURTEEN messaged JAMES on Signal and asked,
“Hey we told to bring guns and maybe stage them in VA?? But you are showing hotels in DC for Alabama. Are we bring guns or no if so how will that work?” JAMES responded, “Were working on a Farm location Some are bringing long rifles some sidearms… I’m bringing sidearm.”62. On January 1, 2021, CALDWELL replied to a Facebook comment, writing,
“I accept that assignment! 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.”63. On January 1, 2021, CROWL sent CALDWELL a Facebook message stating, “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.”
64. On January 1, 2021, CALDWELL wrote to CROWL, “Check with Cap. I recommended the following hotel to her which STILL has rooms (unbelieveble).” CALDWELL then sent a link to the Comfort Inn Ballston, the same hotel that he recommended to others on January 1. CALDWELL continued, “[PERSON TWO] and I are setting up shop there. [PERSON THREE] has a room and is bringing someone. He will be the quick reaction force. Its going to be cold. We need a place to spend the night before minimum. [PERSON ONE] never contacted me so [PERSON TWO] and I are going our way.
I will probably do pre-strike on the 5th though there are things going on that day. Maybe can do some night hunting. Oathkeeper friends from North Carolina are taking commercial buses up early in the morning on the 6th and back same night.
[PERSON THREE] will have the goodies in case things go bad and we need to get heavy.”65. On January 1, 2021, CROWL and WATKINS made plans to travel by car to Washington, D.C., to attend the events of January 5-6, 2021.
66. Beginning on January 1, and continuing into January 2, 2021, CALDWELL and CROWL exchanged messages about the hotel where they planned to stay in Arlington, Virginia, and CALDWELL told CROWL:
“This is a good location and would allow us to hunt at night if we wanted to. I don’t know if [PERSON ONE] has even gotten out his call to arms but its a little friggin late. This is one we are doing on our own. We will link up with the north carolina crew.”
67. On January 2, 2021, PERSON FIFTEEN messaged JAMES on Signal and asked,
“So, I guess I am taking full gear less weapons? Just reading through all the posts. Would rather have it and not need it.” JAMES responded, “Yeah full gear... QRF will have weapons Just leave em home.”68. On the evening of January 2, 2021, at about 5:43 p.m., KELLY MEGGS posted a map of Washington, D.C., in the Leadership Signal Chat, along with the message, “1 if by land[,] North side of Lincoln Memorial[,] 2 if by sea[,] Corner of west basin and Ohio is a water transport landing !!” KELLY MEGGS continued, “QRF rally points[.] Water of the bridges get closed.”
69. On January 3, 2021, STEELE emailed the Florida chapter of the Oath Keepers a membership application and wrote, “My brother, Graydon Young told me to submit my application this route to expedite the process.” Later in the day, STEELE emailed KELLY MEGGS and wrote, “My brother, Graydon Young told me to send the application to you so I can be verified for the Events this coming Tuesday and Wednesday.” The following day, STEELE sent an email to an Oath Keepers address, copying both YOUNG and KELLY MEGGS, attaching her Florida Oath Keepers membership application and vetting form, and writing, “I was just requested to send my documents to this email.”