TABLE OF CONTENTS I. Executive Summary ...........................................................................................................1 II. Background ........................................................................................................................5 A. DOJ’s Current Review of the Biden Administration’s FACE Act Enforcement............5 B. Overview of the FACE Act ............................................................................................6 III. The Biden DOJ Largely Ignored Pro-Life Groups While Closely Coordinating with Pro-Abortion Groups ................................................................................................7 A. Interactions with Pro-Life Groups .................................................................................7 B. Interactions with Pro-Abortion Groups .......................................................................10 i. The Biden DOJ Was Committed to Protecting Abortion Access under the FACE Act ...............................................................................................................10 ii. The Biden DOJ Sought and Relied on Information from Abortion NGOs, Including Ongoing Monitoring of Pro-Life Americans .........................................11 iii. DOJ Provided NAF Internal Department Information and Coordinated with NAF on Pro-Abortion Outreach and Civil FACE Act Litigation ..................16 iv. The Biden DOJ Helped Abortion NGOs Obtain Third-Party Grants ....................19 IV. The Biden DOJ’s Inappropriate Prosecutorial Conduct .............................................20 A. United States v. Gallagher: The Biden DOJ Claimed to Defense Counsel That It Did Not Keep Information Requested for a Selective Prosecution Defense, Despite Giving Materially Identical Information to NAF.........................................................20 B. United States v. Zastrow: The Biden DOJ Allowed Abortion NGOs to Drive Charging Decisions and Engaged in Blatant Anti-Christian Bias in the Jury Pool .....22 C. United States v. Houck: The Biden DOJ Used Aggressive Arrest Tactics Against a Pro-Life Defendant Who Was Subsequently Acquitted ...........................................29 V. The Biden DOJ’s Charging and Sentencing Disparities ..............................................31 VI. The Trump Administration’s Work to Right Prior Wrongs ........................................36 I. EXECUTIVE SUMMARY The Department of Justice was tasked with implementing E.O. 14202, Eradicating AntiChristian Bias, and Attorney General Pamela Bondi’s February 5, 2025 Memorandum, Restoring the Integrity and Credibility of the Department of Justice. 1 Both of those leadership instructions charged DOJ with assessing the underlying prosecutorial decisions under the Freedom of Access to Clinic Entrances (FACE) Act. Separately, President Trump pardoned numerous peaceful, prolife defendants. 2 In response to these directives and following those pardons, DOJ conducted a thorough review of internal discussions, case files, and prosecutorial decisions. DOJ has concluded that the Biden DOJ weaponized the FACE Act in several key ways. Key Finding 1: The Biden DOJ violated the rights of Americans by its biased enforcement of the FACE Act. Former Attorney General Merrick Garland revived the National Task Force on Violence Against Reproductive Health Care Providers (Task Force) to weaponize the FACE Act. 3 Though the FACE Act was supposed to protect both pro-choice and pro-life facilities, Biden DOJ senior leadership 4 and Task Force Members provided extensive support to abortion clinics, 5 yet the Biden DOJ often ignored and downplayed vandalism and attacks against pregnancy resource centers or houses of worship. The Task Force, composed primarily of DOJ’s Civil Rights Division (CRT) career attorneys, oversaw the FACE Act and related outreach. Task Force leadership handled most of DOJ’s communication with outside groups and victims of alleged FACE Act violations. The Task Force Director was in regular, ongoing contact with pro-abortion non-governmental organizations (NGOs) and the clinics they represented, but disregarded pro-life groups. Pro-abortion groups capitalized on their relationship with the Task Force to gain internal information and push targets for FACE Act enforcement. The Task Force Director was on texting terms with the National Abortion Federation’s (NAF) Security Team and regularly communicated with Planned Parenthood Federation of America and the Feminist Majority Foundation (FMF). The Task Force viewed NAF’s Security Team as an “MVP” at flagging protests for DOJ’s “attention, often in real-time, which usually result[ed] in an investigation/prosecution.” Executive Order 14202, Eradicating Anti-Christian Bias, 90 Fed. Reg. 9365 (Feb. 12, 2025); Memorandum For All Department Employees, Restoring the Integrity and Credibility of the Department of Justice (Feb. 5, 2025), https://perma.cc/KB3W-A8SS. 1 2 Donald J. Trump, Executive Grant of Clemency (Jan. 23, 2025), https://perma.cc/2GJ9-L6Q7. 3 See Archives: U.S. Dep’t of Just., Reproductive Rights (2022), https://perma.cc/9YQ3-L7HZ. See Archives: U.S. Dep’t of Just., Justice Department Announces Reproductive Rights Task Force (July 12, 2022), https://perma.cc/542N-UQ6R (announcing the establishment of the Reproductive Rights Task Force, chaired by former Associate Attorney General Vanita Gupta, to formalize existing DOJ efforts to “protect access to reproductive health care in anticipation of the Supreme Court overturning Roe v. Wade). 4 See, e.g., “Resource Booklet for Reproductive Health Care Providers and Their Staff,” National Task Force of Violence Against Reproductive Health Care Providers (Nov. 7, 2022), available at https://perma.cc/CMJ6-3EC6, at 11 (describing the FACE Act only in terms of protection to abortion clinics). 5 1 Task Force attorneys did not communicate with any pregnancy resource center groups or representatives until September 2022, well after the increase in violence after the Supreme Court’s decision in Dobbs. 6 After that time, CRT identified possible contacts for pregnancy resource centers via a quick Google search and directed Task Force leadership to schedule meetings. The Task Force then had several meetings with the pro-life groups identified through that initial outreach and periodically sent them press releases. However, internally, CRT attorneys questioned whether to provide pregnancy resource centers with the same resources as abortion clinics, questioning whether these facilities fall under the FACE Act’s scope. Key Finding 2: The Biden DOJ collaborated with pro-abortion groups to track pro-life activists’ First Amendment activity. The Task Force affirmatively asked the abortion groups about pro-life individuals’ travel and constitutionally protected advocacy. The pro-abortion groups even asked the Biden DOJ to target a pro-life religious order, the Franciscan Brothers of Peace. The FBI flagged that the abortion groups’ outreach tracked pro-life groups’ “1st Amendment protected activity.” Yet, the Task Force did not relent, even after this warning. Abortion NGOs routinely contacted CRT about protests at clinics and possible, alleged FACE Act violations across the country. The Task Force Director “monitored” pro-life activists for years before charging them. This monitoring included three of the pardoned defendants. During the investigations of the later pardoned cases, the NGOs sent DOJ “security reports” or “dossiers” on the activities of the pro-life activists and their personal information. For example, in 2021, before an annual conference by a pro-life group, one pro-choice NGO sent the Task Force Director and the FBI a 137-page memorandum on the conference schedule, lodging, and multi-page dossiers on numerous “anti-choice individuals,” including many of the pardoned defendants. These dossiers contained personally identifying information, such as addresses, photographs (including of spouses and minor children), names of associates and affiliated ministries, information about their upcoming travel plans or planned protests, and even drivers’ license numbers. NGOs repeatedly complained about one of the pardoned defendants, provided real-time updates of her pro-life activism, and requested that DOJ pursue nationwide injunctions against pro-life activities, citing this woman’s protests as justification. The Biden DOJ investigated this woman’s conduct around the country until one of the United States Attorney’s Offices brought charges. After her conviction and lengthy sentence, the NGOs stopped complaining about her. In each of the later-pardoned FACE Act cases, DOJ and the FBI learned of the possible FACE violations from abortion NGOs, rather than from the purported victims or local law enforcement. NAF typically informed the Task Force Director in real time of ongoing protests, often before local law enforcement could fully respond. At his request, NGOs compiled evidence that ultimately gave rise to search warrants and charges. The Task Force also coordinated with the abortion NGOs on civil actions against pro-life activities at clinics. 6 Dobbs v. Jackson Women’s Health Organization, 597 U.S. 215 (2022). 2 Key Finding 3: Biden DOJ prosecutors engaged in inappropriate conduct and comments. The Biden DOJ prosecutors knowingly withheld evidence that defense counsel requested to prepare an affirmative defense. The Biden DOJ prosecutors falsely claimed to not have such information available. In United States v. Gallagher (Middle District of Tennessee), defense counsel contacted federal prosecutors, requesting historical data on FACE Act prosecutions to prepare their selective prosecution defense. The Task Force Director declined, stating that he did not “keep the[se] kind of records” and did not believe that the Department “will provide them.” Notably, he had this information readily available and decided not to share it with the defendants, despite sharing substantially identical information with NAF. The Biden DOJ prosecutors tried to screen out jurors based on religion. In United States v. Zastrow (Eastern District of Michigan), Assistant United States Attorneys (AUSAs) looked for ways to screen possible jurors based on their conservative or religious views, while not inquiring about liberal counterviews. They referred to Christian pro-life views as “culty” and lambasted the defendants’ beliefs in the courtroom. The AUSAs also complained that they “ended up with a very Catholic magistrate on duty this week and he was very particular about the bond conditions and not infringing on [defendants’] first amendment rights.” The Biden DOJ used the FACE Act to prosecute a father whose minor son was attacked by an abortion clinic worker—and DOJ lost. In United States v. Houck (Eastern District of Pennsylvania), prosecutors considered and declined a request for the defendant to self-surrender. Rather, 16 FBI agents arrested the defendant at his home. When faced with public backlash about the aggressive arrest, the Task Force Director attempted to blame the FBI, rather than address the Biden DOJ’s lack of initial guidance to law enforcement. The jury ultimately found Houck not guilty, and DOJ settled a civil claim to compensate for the Biden DOJ’s misconduct. Key Finding 4: The Biden DOJ pursued more severe charges and significantly harsher sentences for peaceful pro-life defendants than violent pro-abortion defendants. The Biden DOJ requested an average sentence of 26.8 months for pro-life defendants, compared to 12.3 months for pro-choice defendants. The Biden DOJ pursued significantly higher sentences (near the top range of sentencing guidelines) for pro-life defendants, while pursuing more lenient sentences against the handful of pro-abortion defendants that it charged. Pro-life defendants were ultimately sentenced to an average of 14 months, while pro-abortion defendants were sentenced to an average of 3 months. Key Finding 5: The Biden DOJ sought to provide funding to pro-abortion groups. The Task Force Director served as a reference on NAF’s application for a large, private grant. We found no record of ethics approval for a DOJ attorney to take an interest in the financial outcome of a party having business before the Biden DOJ. Indeed, it is doubtful that the Biden DOJ could validly give any such ethical clearance for this conflict of interest. 7 See U.S. Dep’t of Just., Ethics Handbook for On and Off-Duty Conduct (Nov. 2024), https://perma.cc/53NYNQBW. 7 3 Current Actions: The Biden DOJ’s actions were wrong. The Trump Administration and Department of Justice are committed to rectifying these harms. President Trump issued full and unconditional pardons to many of the pro-life Christians unfairly targeted by the Biden DOJ. And DOJ leadership dismissed, with prejudice, three of the civil lawsuits against non-violent pro-life demonstrators and issued a directive that, moving forward, DOJ prosecutors may only bring FACE Act civil actions and prosecutions in extraordinary circumstances or in cases presenting significant aggravating factors. 8 This report does not disclose any findings regarding internal misconduct investigations of any of the employees alleged to have been involved in the weaponization of the FACE Act. DOJ governs the conduct of its current employees through an internal disciplinary investigative system. Where appropriate, DOJ may refer current or former employees for criminal prosecution. Likewise, DOJ may refer current or former employees to the relevant bar association or highest judicial authority of the jurisdictions in which they are licensed to address compliance with applicable Rules of Professional Conduct. Here, appropriate internal referrals have been made as required by the Justice Manual. 9 DOJ adheres to the use of these separate systems to address allegations of misconduct. U.S. DEP’T OF JUST., OFF. OF THE ASSOCIATE ATTORNEY GENERAL, FACE ACT CHARGING POLICY (Jan. 24, 2025), https://perma.cc/U7HK-37PT (directing CRT to dismiss, with prejudice, the following FACE Act cases: United States v. Connolly, No. 2:24-cv-04467 (E.D. Penn.); United States v. Zastrow, et al., No. 2:24-cv-00576 (M.D. Fla.); United States v. Citizens for a Pro-Life Soc’y, et al., No. 1:24-cv-00893 (N.D. Ohio)). 8 9 U.S. Dep’t of Just., Just. Manual § 1-4.000 - Standards Of Conduct, https://perma.cc/L3GU-6SPS. 4 II. BACKGROUND A. DOJ’s Current Review of the Biden Administration’s FACE Act Enforcement On January 23, 2025, President Trump issued full and unconditional pardons of pro-life defendants in five different matters, raising concerns that during the Biden Administration, DOJ had unevenly applied its enforcement authorities. 10 DOJ is tasked with implementing Executive Order 14202, Eradicating Anti-Christian Bias, and Attorney General Pamela Bondi’s Memorandum, Restoring the Integrity and Credibility of the Department of Justice. 11 Both of those leadership instructions charge DOJ with assessing the underlying prosecutorial decisions under the FACE Act. In response, DOJ reviewed past cases and conduct for possible anti-Christian bias or broader weaponization concerns. DOJ leadership invited feedback from the United States Attorney’s Offices (USAO) that handled the pardoned FACE Act cases and the Houck matter. Reviewers asked open-ended questions and received substantive feedback from one USAO, which reviewed its prosecution file and flagged concerns that the prosecution may have been overly politicized in response to the Texas Heartbeat law. 12 The office noted that several in-court AUSA statements suggested that religious discrimination played a role and merited further review. Based on initial findings and this feedback from the USAO, DOJ conducted a search for responsive documents from possible custodians in CRT. Those search terms yielded about 700,000 results. Both career attorneys and political appointees reviewed the documents and compiled these findings based on the full scope of the data set. The reviewers proceeded with several guiding presumptions: First, DOJ presumed that attorneys followed the chain of command and did their jobs. Second, DOJ recognized that components regularly interact with outside groups and receive leads regarding possible criminal violations or areas for civil involvement. Likewise, investigations of possible crimes necessarily require back-and-forth communications with victims or their representatives. Third, because changing administrations have different policy preferences and goals, DOJ did not find it surprising or notable that the types of prosecutorial priorities may shift over time. Rather, DOJ’s review asked if there were notable departures from past practices or departmental policies for the purpose of using prosecutorial power as a weapon or to target specific persons or groups for improper reasons. This report shares key findings, including citations to numerous internal documents containing predecisional and deliberative discussions where necessary, to demonstrate where weaponization occurred. The exhibits also include correspondence with outside groups on both sides of the abortion issue. 10 Donald J. Trump, Executive Grant of Clemency (Jan. 23, 2025), https://perma.cc/2GJ9-L6Q7. Exec. Order 14202, Eradicating Anti-Christian Bias, 90 Fed. Reg. 9365 (Feb. 12, 2025); Memorandum For All Department Employees, Restoring the Integrity and Credibility of the Department of Justice (Feb. 5, 2025), https://perma.cc/KB3W-A8SS. 11 12 Senate Bill 8, 87th Leg., Reg. Sess. (Tex. 2021). 5 Because of the Trump Administration’s commitment to transparency, Acting Attorney General Blanche has approved disclosure of documents revealing the abuse of the deliberative process privilege in these prosecutions. 13 DOJ strived to keep redactions minimal, focusing on personal identifying information, including email addresses, phone numbers, and physical addresses and locations. The exhibits are representative of DOJ’s full findings regarding implementation of the FACE Act. B. Overview of the FACE Act The FACE Act is a viewpoint neutral law that protects access to religious institutions and certain healthcare facilities, including abortion clinics and pregnancy resource centers, regardless of whether the views or services align with an administration’s policy preferences regarding abortion. Specifically, the FACE Act makes it unlawful to: (1) by force or threat of force or by physical obstruction, intentionally injure[], intimidate[] or interfere[] with or attempt[] to injure, intimidate or interfere with any person because that person is or has been, or in order to intimidate such person or any other person or any class of persons from, obtaining or providing reproductive health services; (2) by force or threat of force or by physical obstruction, intentionally injure[], intimidate[] or interfere[] with or attempt[] to injure, intimidate or interfere with any person lawfully exercising or seeking to exercise the First Amendment right of religious freedom at a place of religious worship; or (3) intentionally damage[] or destroy[] the property of a facility, or attempt[] to do so, because such facility provides reproductive health services, or intentionally damage[] or destroy[] the property of a place of religious worship. 14 FACE Act violations are punishable by criminal fines and/or terms of imprisonment, including a maximum term of up to six months for a first “offense involving exclusively a nonviolent physical obstruction” and up to one year for any other first offense. 15 DOJ is responsible for prosecuting crime in a manner that is consistent with its mission “to uphold the rule of law, to keep our country safe, and to protect civil rights.” 16 It must act with All discussion, citation, and provision of internal information in this report is disclosed pursuant to the authority and approval of the Attorney General. The limited release of this information does not constitute the waiver of privilege beyond the limited disclosure here. The limited release of information in this report does not constitute an authorization to any current or former employee to discuss internal or privileged information or to be subject to serve as a witness. DOJ’s Touhy regulations continue to apply. 28 C.F.R. §§ 16.21, et seq.; United States ex rel. Touhy v. Regan, 340 U.S. 462 (1951). 13 14 18 U.S.C. § 248(a)(1)-(3). 15 18 U.S.C. § 248(b)(1)-(2). 16 About DOJ, U.S. DEP’T OF JUST., https://www.justice.gov/about (last visited Jan. 7, 2026). 6 independence, impartiality, honesty, integrity, excellence, and respect, valuing “differences in people and in ideas and treat[ing] everyone with fairness, dignity, and compassion.” 17 The FACE Act is also subject to civil enforcement. DOJ may secure injunctive relief such as establishing buffer zones. DOJ may also seek monetary damages. 18 III. THE BIDEN DOJ LARGELY IGNORED PRO-LIFE GROUPS WHILE CLOSELY COORDINATING WITH PRO-ABORTION GROUPS DOJ and its attorneys regularly communicate with individuals and groups outside the federal government. DOJ and the FBI regularly receive tips and leads regarding possible criminal violations. Aggrieved individuals file complaints about possible violations of their civil rights. Groups reach out with requests for federal involvement in their civil litigation. It is unremarkable that DOJ was in touch with both pro-life and pro-abortion groups during the Biden Administration. However, although both groups contacted CRT with concerns of possible criminal violations, the Biden DOJ treated the groups and their concerns unequally. A. Interactions with Pro-Life Groups The Biden DOJ’s interactions with pro-life groups were limited. In August 2022, several months after Dobbs, the American Center for Law and Justice sent a letter to DOJ raising concerns that pregnancy resource centers had been “firebombed and vandalized” across the nation, and reiterating that such facilities are covered by the FACE Act. 19 A CRT attorney circulated the letter, after which Deputy Assistant Attorney General (DAAG) Robert Moossy inquired on the status of a Task Force meeting for pro-life clinics. 20 The Task Force Director, CRT Trial Attorney Sanjay Patel, responded that he was waiting for the FBI to set up a call with the U.S. Conference of Catholic Bishops to put CRT in touch with pro-life facilities. 21 DAAG Moossy did a “quick google [sic] search,” identified Care Net as a potential lead, and asked if an intern could do some further searches. 22 Patel sent an outreach request through Care Net’s general information email address, and after briefly connecting, asked Care Net to identify other similar pro-life organizations. Care Net identified three other organizations—Heartbeat International, National Institute of Family and Life Advocates (NIFLA), and Birthright. Care Net did not have contact information at Birthright, 23 and 17 Id. 18 18 U.S.C. § 248(c)(2)(A)-(B). Letter from Jordan Sekulow, Am. Ctr. for L. & Justice, to Attorney General Merrick Garland (Aug. 8, 2022) (Exhibit 001). 19 20 E-mail from Sanjay Patel, to Criminal Chief Jim Felte (Aug. 17, 2022) (Exhibit 002). 21 Id. 22 Id. 23 E-mail from Vincent DiCaro, Chief Outreach Officer, Care Net, to Patel (Sept. 9, 2022) (Exhibit 003). 7 from that point on, DOJ only interacted with Care Net, Heartbeat International, NIFLA, and the U.S. Conference of Catholic Bishops. Patel set up a Task Force meeting with representatives from those pro-life groups and invited Assistant Attorney General (AAG) Clarke, 24 despite her prior public statements regarding the “fake” clinics these organizations supported. 25 CRT’s attorneys recommended that AAG Clarke omit the phrase “life affirming care” from her talking points. 26 AAG Clarke and Patel ultimately met with Care Net, Heartbeat International, and NIFLA. 27 Patel handled the meeting with the U.S. Conference of Catholic Bishops, as his supervisors decided AAG Clarke did not need to attend a meeting with such a small number of outside participants. 28 The Biden DOJ handled the outside groups’ requests differently. One of CRT’s representatives on a different initiative, the Reproductive Rights Task Force, Robert Weiner, advised against providing a copy of DOJ’s FACE Resource Booklet to pregnancy resource centers because: the vast majority of FACE Act violations have involved anti-abortion efforts . . . the booklet naturally focuses more on those activities. There are thus a number of aspects of the booklet that may militate against pushing it out during a meeting with Pregnancy Counseling Centers. . . . [T] the booklet refers to “clinics” throughout. Are “Pregnancy Counseling Centers” typically and appropriately described as “clinics”? Mostly, the booklet refers to “reproductive healthcare” and “reproductive healthcare providers,” which arguably can include the anti-abortion centers, though some might dispute whether they dispense health care. 29 The Task Force nevertheless opted to share these resources with pregnancy resource centers. After reviewing the Resource Booklet, Care Net raised concerns that the Department’s treatment of reproductive health centers seemed one-sided. 30 Weiner reacted internally: “To some extent, it is entirely justified to refer to anti-abortion extremism, as that is a significant part of what the FACE Act and the Booklet covers. But it is also true that the list of references . . . includes Meeting Invitation from Patel (Oct. 7, 2022) (Exhibit 004); AAG Talkers for Clinic Violence TF Meeting with Pro-Life NGOs (Oct. 7, 2022) (Exhibit 005). See also Talking Points (Sept. 14, 2022) (Exhibit 006). 24 See, e.g., Kristen Clarke (@KristenClarkeJD), X (June 26, 2018, 1:14 PM), https://perma.cc/JB2D-XLCR (last visited Jan. 7, 2026) (“Make no mistake, today’s decision at the #SCOTUS striking down a CA disclosure requirement for crisis pregnancy centers is part of a coordinated strategy to tear down #RoevWade. The anti-choice movement will stop at nothing. #EndTheLies #ExposeFakeClinics”). 25 26 AAG Talkers for Clinic Violence TF Meeting with Pro-Life NGOs (Oct. 7, 2022) (Exhibit 005). See E-mail from Patel, to Aryele Bradford (June 22, 2023) (Exhibit 007) (identifying the four pro-life groups with whom CRT met). But see Invite for Meeting with Reproductive Justice Groups (Sept. 26, 2022) (Exhibit 008) (meeting with numerous pro-abortion groups). 27 28 See E-mail from DAAG Robert Moossy, to Criminal Chief Felte (Oct. 7, 2022) (Exhibit 009). 29 E-mail from Robert Weiner, to Rebecca Bond (Aug. 17, 2022) (Exhibit 010) (emphasis added). 30 E-mail from Weiner, to DAAG Moossy (Oct. 7, 2022) (Exhibit 011) (attaching an annotated copy of the Resource Booklet (Exhibit 012)). 8 NGOs Planned Parenthood, National Abortion Federation, and Feminist Majority Foundation— only.” 31 The Biden DOJ ultimately pursued three FACE Act prosecutions involving pro-life victims and informed these pro-life groups. Because AAG Clarke and CRT attorneys were unfamiliar with these groups, they struggled to identify how to describe the victims: AAG Clarke was unsure “whether the anti-abortion folks called themselves Pregnancy Centers or Pregnancy Resource Centers.” 32 Weiner questioned whether to refer to these clinics as “pregnancy resource centers” or health services facilities that “[p]rovide [a]bortion [a]lternatives.” 33 Once the press releases were published, AAG Clarke forwarded them to the pro-life groups, asserting that DOJ would continue to enforce the FACE Act to “protect the rights of all patients and all providers, including pregnancy resource centers.” 34 But, as described below, these cases were not treated equally. In 2024, a representative at Care Net also questioned the disparity in sentences for pro-life protestors compared to pro-choice protestors. 35 He thought there appeared “to be a double standard in these cases and not equal treatment under the law,” and asked for more information about the sentences in FACE Act matters. 36 Patel responded that he would be happy to schedule a meeting to discuss and noted that there were “distinguishing factors” in the cases. 37 The pro-life group was skeptical and requested to “see a listing of charges/convictions sorted by those charged related to pro-life facilities and those related to abortion facilities.” 38 Patel responded that he could only provide general information at the meeting, and that the information requested would “have to be routed through the Department’s Freedom of Information Act Unit.” 39 31 Id. 32 E-mail from Weiner, to Bradford (Jan. 18, 2023) (Exhibit 013). 33 See E-mail from Weiner, to AAG Clarke (Jan 17, 2023) (Exhibit 014). 34 See, e.g., E-mail from AAG Clarke, to Dan Balserak, U.S. Conf. of Cath. Bishops (Jan. 25, 2023) (Exhibit 015); E-mail from AAG Clarke, to Balserak (Sept. 13, 2024) (Exhibit 016); E-mail from AAG Clarke, to Jor-El Godsey, Heartbeat Int’l (Dec. 9, 2023) (Exhibit 017); E-mail from AAG Clarke, to Balserak (Dec. 9, 2023) (Exhibit 018); Email from AAG Clarke, to Tom Glessner, NIFLA (Dec. 9, 2023) (Exhibit 019); E-mail from AAG Clarke, to Roland Warren, Care Net (Dec. 13, 2023) (Exhibit 020); E-mail from AAG Clarke, to Balserak (Dec. 20, 2024) (Exhibit 021); E-mail from AAG Clarke, to Glessner (Dec. 20, 2024) (Exhibit 22); E-mail from AAG Clarke, to Godsey (Dec. 20, 2024) (Exhibit 023); E-mail from AAG Clarke, to Warren (Dec. 20, 2024) (Exhibit 024). 35 E-mail from Patel, to President Warren, Care Net (Oct. 16, 2024) (Exhibit 025). 36 Id. 37 Id. 38 Id. Id. For discussion of similar requests from pro-abortion NGOs, see infra, at 16 ̶17, and from pro-life criminal defendants, see infra, at 20 ̶ 21. 39 9 B. Interactions with Pro-Abortion Groups In comparison, the Biden DOJ remained in continual contact with pro-abortion groups regarding the FACE Act. Both political leadership and career attorneys drove this relationship. Information flowed two ways. The outside groups provided information, often at DOJ’s request. The Biden DOJ committed to pursuing FACE Act cases to support these group’s interests. The outside groups provided information, often at DOJ’s request. DOJ prosecutors shared information with these groups that they withheld from pro-life groups. And the Biden DOJ provided connections and contacts. Patel even agreed to serve as a reference for NAF on a grant application. i. The Biden DOJ Was Committed to Protecting Abortion Access under the FACE Act. After the Texas Heartbeat Law went into effect, then-Attorney General Merrick Garland proposed issuing a statement or letter “reminding everyone and reassuring clinics that the FACE Act is there.” 40 AAG Clarke and her staff reached out to abortion providers and pro-abortion advocacy groups. 41 AAG Clarke also emailed the president of Planned Parenthood about “FACE Act Compliance,” flagging that “we are on high alert when it comes to ensuring freedom of access to clinics; we are committed to using the FACE Act to hold accountable those who may seek to obstruct access to clinics.” 42 Likewise, after the Supreme Court overruled Roe v. Wade, 43 CRT’s Criminal Chief Jim Felte forwarded an announcement from Attorney General Garland to both Task Force members and contacts at NAF, Planned Parenthood, and FMF. 44 In the message, Attorney General Garland reminded that, under his leadership, “[t]he Justice Department will work tirelessly to protect and advance reproductive freedom.” 45 A month after the Dobbs decision, Attorney General Garland, Deputy Attorney General Lisa Monaco, and Associate Attorney General Vanita Gupta met with numerous pro-abortion groups about DOJ’s response to the decision. 46 The outside groups included NARAL Pro-Choice of America, Planned Parenthood, the Center for Reproductive Rights, and about 10 other NGOs. 47 Speakers from the NGOs “uniformly expressed gratitude for 40 E-mail from Principal Deputy Assistant Attorney General (PDAAG) Pamela Karlan, to Criminal Chief Felte and Principal Deputy Chief Fitzgerald (Sept. 2, 2021) (Exhibit 026). 41 Calendar Hold for AAG Clarke (Sept. 2, 2021) (Exhibit 027). 42 E-mail from AAG Clarke, to Alexis McGill Johnson, Planned Parenthood (Sept. 2, 2021) (Exhibit 028). 43 Dobbs, 597 U.S. at 215. Shortly after the May 2, 2022 Dobbs leak, the FACE Task Force agreed to meet “to discuss potential fallout before [hosting] any larger meeting with providers, which [they] suspect[ed] would be loaded with questions.” E-mail from Patel, to [Redacted] (FBI) (May 4, 2022) (Exhibit 029); E-mail from Patel, to Laura Cowall (May 4, 2022) (Exhibit 030). 44 E-mail from Criminal Section Chief Jim Felte, to Patel (June 24, 2022) (Exhibit 031). 45 Id. E-mail from Weiner, to Bond (July 25, 2022) (Exhibit 032). See also E-mail from ASG19 Schedule, to Saeed Mody (Sept. 26, 2022) (Exhibit 008) (circulating a meeting invitation to numerous “reproductive justice groups”) 46 47 Id. 10 DOJ’s strong commitment to reproductive rights, to the point that [the moderator] asked them to dispense with the thanks because it was taking up too much time.” 48 AAG Clarke continued this outreach, including meeting with NAF. In the meeting request, NAF praised the “amazing relationship with [] NAF Security Director Michelle Davidson and members of the DOJ Civil Right Division,” and highlighted its involvement in “several FACE Act investigations, working with AUSAs and FBI in TN, FL, VA, CA, NY, MD and NC[.]” 49 ii. The Biden DOJ Sought and Relied on Information from Abortion NGOs, Including Ongoing Monitoring of Pro-Life Americans. NAF’s characterization of its relationship with the Biden DOJ was accurate. The Biden DOJ closely coordinated with abortion providers and NGOs, particularly NAF, to identify potential pro-life targets for investigation and build cases against them. Coordination primarily took place between Patel, as Task Force Director, and NAF Security Director, Michelle Davidson, who remained in routine communication. Patel described Davidson as an “MVP” at bringing incidents to his “attention, often in real-time, which usually result in an investigation/ prosecution.” 50 He viewed NAF as a “great resource for any investigation we have that involves clinic violence,” and a “wonderful contact for [him] as it relates to FACE Act investigations.” 51 Patel’s supervisor, Principal Deputy Chief Paige Fitzgerald, described the relationship as follows: National Abortion Federation [is] one of the three main reproductive health care provider (RHCP) groups in the country (the others are Planned Parenthood and Feminist Majority). We have worked with NAF for decades. NAF regularly refers potential FACE Act violations and other threats to RHCPs, helps us liaise with clinics and staff, lets us know about upcoming events that might result in security concerns so we can notify FBI and USMS, etc. Because they are NGOs, they can poke around on the internet in ways we can’t, and they have shared leads with us, etc. 52 At Patel’s request or encouragement, NAF provided the Biden DOJ with substantial information that aided in identifying investigation targets and substantiating warrants and 48 Id. E-mail from AAG Clarke, to Robert Ledogar, NAF (Jan 10, 2023) (Exhibit 033); Invitation from Bridget CheungSmith, to AAG Clarke and Ledogar (Jan 17, 2023) (Exhibit 034); E-mail from Weiner, to Ledogar, NAF (Jan. 17, 2024) (Exhibit 035); E-mail from Weiner, to Principal Deputy Chief Fitzgerald (Jan. 17, 2024) (Exhibit 036). 49 50 See E-mail from Patel, to [Redacted], FBI (Nov. 17, 2021) (Exhibit 037). Id.; E-mail from Patel, to Davidson (July 16, 2021) (Exhibit 038) (“Michelle is an all-around superstar who has been a valuable resource for me in my role as the national FACE Act guy.”). 51 52 E-mail from Principal Deputy Chief Fitzgerald, to John Buchko (Oct. 31, 2023) (Exhibit 039). 11 prosecutions. 53 NAF alerted Patel to social media posts that made violent threats against clinics 54 and concerns about protest activities that could constitute blockades in violation of the FACE Act. 55 In the Handy matter, Patel emailed NAF: “I can’t recall if you ever shared anything with me (either through an attachment or via Dropbox) about Jonathan Darnell’s arrest . . . If you did, can you resend that to me?” 56 NAF, Planned Parenthood, and FMF not only flagged concerns about possible violations of the FACE Act, but also monitored the activities and locations of pro-life activists and shared updates about their First Amendment activities with the Biden DOJ and FBI in case chargeable conduct occurred. The Biden DOJ later charged many of the individuals surveilled by abortion NGOs. The types of information provided to DOJ for law enforcement efforts included, for example: • In advance of a national event by Operation Save America, NAF compiled a law enforcement resource guide on the group and its event. 57 The guide broke down the schedule of events—including protests and meetings at local churches—before providing detailed dossiers of “anti-choice individuals” expected to attend, including pro-life pastors and speakers. These dossiers included significant amounts of personal identifying information, such as birthdates, addresses, contact information, physical descriptions and photographs, names of family and close associates (including photographs of minor children), affiliated groups, history of pro-life and faith-based activities, and drivers’ license numbers. 58 The guide included information about prior protests that ultimately were the basis for the Biden DOJ’s FACE Act charges. 59 • NAF forwarded DOJ “anti-choice social media posts” by Cal Zastrow. 60 The posts included statements such as: “This is what loving your doomed preborn neighbor looks like . . . Sacrificial love, as an act of worship to Jesus.” “Greater love has no one than this, that someone lay down his life for his friends.” 61 See, e.g., E-mail from Patel, to Megan Healy (Nov. 16, 2020) (Exhibit 040) (“NAF is obtaining the security video from the vandalism for me.”). 53 54 E-mail from Patel, to Emma Goldberg (NAF) (Apr. 12, 2021) (Exhibit 041) (flagging that Patel forwarded the information to the FBI immediately and noting that he was “designated as the DOJ National FACE Act Task force director” and wanted to call about exploring outreach initiatives). E-mail from Fleisher, to Patel (Aug. 18, 2020) (Exhibit 042) (responding to a NAF alert about Handy’s pro-life activities in Washington, D.C., a CRT attorney asked NAF to let him know “[i]f she actually ends up causing any obstruction,” and noted that while he could not speak for the Criminal Section, “we on the civil side might be interested in looking further”); E-mail from Davidson, to [Redacted], FBI (Jan. 30, 2021) (Exhibit 043) (alerting DOJ to Handy’s activities in Maryland). 55 56 E-mail from Patel, to Davidson (Dec. 8, 2020) (Exhibit 044). 57 See Operation Save America National Event Resource Guide (2021) (Exhibit 045). 58 Id. 59 Id. 60 E-mail from Goldberg, to Patel (May 13, 2021) (Exhibit 046). 61 Id. 12 • Davidson forwarded news articles about Handy from “Right Wing Watch” and her social media posts. 62 In response, Patel asked for names and case numbers of her associates who had local cases pending in D.C. 63 Davidson then compiled information for Patel about Handy, Fr. Christopher Moscinski, and William Goodman, along with others. 64 The email included local case numbers involving these individuals and “some articles on Moscinski that go pretty far back,” such as an ACLU news article from 1997 and a law review article by Professor Michael W. McConnell. 65 Patel forwarded the case numbers to the U.S. Attorney’s Office for the District of Columbia, flagging the information regarding “activists whom I’ve been monitoring over the past few years.” 66 • Davidson forwarded the FBI social media posts from Handy about pro-life protests and noted that NAF was planning to alert other facilities in the area. 67 The FBI flagged NAF’s outreach to DOJ and the local USAO, noting that her activities “[a]ppear[] to all be 1st Amendment protected activity, so [we are] being mindful of that, but figured it made sense to pass along the email.” 68 • Davidson notified Patel that Cal Zastrow and other pro-life activists had traveled to Montana. Davidson said, “I would bet they might try to block a clinic this week so I’m reaching out to clinics and my few local PD contacts to see if I could bring some awareness.” 69 A week later, Patel responded asking if NAF had “any info on Zastrow and Co’s travel to Montana.” 70 • NAF obtained an audio recording of Handy speaking to pro-life activists and corresponding documents from the Progressive Anti-Abortion Uprising. NAF forwarded them to Patel and other DOJ attorneys. 71 • Planned Parenthood provided DOJ and FBI with a Request for Information about a prolife activist who belongs to a pro-life religious order, the Franciscan Brothers of Peace. 72 The Request for Information explained that the subject “is a devout Catholic” and that the penalties for his pro-life protests had so far been “limited to fines or community service.” 62 E-mail from Davidson, to Patel (Aug. 20, 2020) (Exhibit 047). 63 E-mail from Patel, to Davidson (Aug. 20, 2020) (Exhibit 048). 64 E-mail from Davidson, to Patel (Aug. 18, 2020) (Exhibit 049). 65 Id. 66 E-mail from Patel, to Joseph Cooney (Sept. 1, 2020) (Exhibit 050). 67 E-mail from Davidson, to [Redacted], FBI (Dec. 29, 2020) (Exhibit 051). 68 Id. E-mail from Davidson, to Patel (Sept. 9, 2021) (Exhibit 052) (notifying Patel that Cal Zastrow was in Montana, along with other pro-life activists). 69 70 Id. 71 E-mail from Eduardo Serrano, NAF, to Patel (Jan. 31, 2023) (Exhibit 053). 72 Planned Parenthood, Request for Information re: [Redacted] (Aug. 27, 2021) (Exhibit 054). 13 • Planned Parenthood compiled a Security Advisory on “Red Rose Rescues,” which it characterized as “trespass/blockade” “tactics used by the anti-abortion movement designed to avoid federal FACE Act violations.” 73 The advisory flagged its assessment that this prolife group was likely to recruit like-minded “opposition.” Planned Parenthood assessed that “should this movement grow, it will have a direct impact on Planned Parenthood operations.” The advisory highlighted Handy, Goodman, and Fr. Moscinski as some of the “core group of organizers and participants.” The advisory concluded with a list of arrests at abortion clinics across the country, including many of the individuals whom the Biden DOJ later charged. 74 • FMF sent a letter and memorandum “urging the DOJ to pursue criminal charges and nationwide injunctive relief to prevent ongoing and future violations” of the FACE Act. 75 Both documents cited the activities of Bevelyn Beatty Williams, Handy, Darnell, Fr. Moscinski, along with all of the Gallagher defendants, as supporting evidence for their request. 76 Principal Deputy Chief Fitzgerald thought the request for nationwide injunctions “seems like a good idea to me.” 77 FMF called Patel, flagging that she was “getting ready to make some noise” about the letter, after which the Biden DOJ “tr[ied] to move things along on our end.” 78 CRT then pursued a consent decree against a different pro-life activist that would have imposed a nationwide injunction. AAG Clarke approved the effort, but the consent order ultimately was never imposed. 79 DOJ later charged many of these same individuals with FACE Act violations. In each of the six FACE Act cases that President Trump pardoned, DOJ had learned of the underlying acts from the three abortion NGOs. 80 Biden DOJ attorneys forwarded information from the abortion NGOs to the FBI (when the FBI was not already included in the communications), and the Task Planned Parenthood Global Safety and Security, Overview of Emerging Trend: “Red Rose Rescues” and blockade tactics (July 14, 2019) (Exhibit 055). 73 74 Id. 75 E-mail from duVergne Gaines, FMF, to Patel (Aug. 25, 2022) (Exhibit 056); Letter from FMF, to AG Garland (Aug. 25, 2022) (Exhibit 057); Memorandum from FMF (Exhibit 058). 76 Memorandum from FMF at 20 (Exhibit 058). 77 E-mail from Principal Deputy Chief Fitzgerald, to DAAG Moossy (Sept. 8, 2022) (Exhibit 059). 78 E-mail from Laura Cowall, to Patel (Feb. 27, 2023) (Exhibit 060). See Request for Settlement Authority under the FACE Act, 18 U.S.C. § 248 (Feb. 14, 2024) (Exhibit 061) (requesting authorization from AAG Clarke for a consent decree to resolve FACE Act claims to “ensure both [defendants] maintain distance from clinics nationwide and are prohibited from violating FACE in the future”). 79 E-mail from NAF Security Department, to Patel (Oct. 22, 2020) (Exhibit 062) (alert about Handy); E-mail from Davidson, to Patel (Mar. 5, 2021) (Exhibit 063) (alert about Gallagher); E-mail from Davidson, to Fleisher (Aug. 27, 2020) (Exhibit 064) (alert about Zastrow Sterling Heights protest); E-mail from Patel, to Carlson (Apr. 16, 2021) (Exhibit 065) (forwarding NAF’s alert about Zastrow Saginaw protest); E-mail from Patel, to [Redacted] (Oct. 18, 2021) (Exhibit 066) (forwarding an e-mail from Planned Parenthood alerting him to Houck-related activities); Email from Patel, to David Kennedy (July 14, 2022) (Exhibit 067) (forwarding alert about Moscinski). 80 14 Force relied on information from NAF to identify demonstrators 81 and compile evidence that DOJ used to investigate and charge pro-life demonstrators. 82 Abortion NGOs sent DOJ more information about one pro-life activist than all the rest: Bevelyn Beatty Williams. Based in large part on this outreach, the Biden DOJ and FBI monitored Beatty’s activities across jurisdictions and several considered whether her conduct was chargeable under the FACE Act. The USAO in the Southern District of New York ultimately charged her with a felony violation. After Beatty was sentenced, Patel updated his contacts at NAF, FMF, and Planned Parenthood, who were “[g]rateful for the update and hard work behind the case.” 83 The NGOs’ ongoing requests to the Biden DOJ about Beatty included: • On January 8, 2021, Davidson flagged for Patel and the FBI that NAF was “gathering and compiling a lot of video and intel from Wednesday’s events at the Capitol,” along with the Abortion Access Front. 84 Davidson explained that with the upcoming March for Life, NAF was “very concerned that the individuals that participated in the invasion at the Capitol will continue similar actions at this event,” and they wanted to provide as much information as possible in light of “growing concerns that these types of extremists now pose an even greater threat to Homeland Security than [Foreign Terrorist Organizations].” Several days later, NAF followed up with a dossier listing “the names of our well known antis” as “[p]eople of interest,” including Beatty. 85 Patel looked for the correct contacts at the FBI with whom to share the information from NAF. 86 An hour later, Principal Deputy Chief Fitzgerald signed off on one of Patel’s proposed FACE Act grand jury memoranda, reacting that “[t]his is a great case to be bringing now . . . we should make sure that the extremists know that we still have this tool and will use it.” 87 • On January 28, 2022, an intelligence analyst for Planned Parenthood contacted her local sheriff’s office about a demonstration in Florida, to which she appended several advisories compiling information about the views, activities, and known whereabouts of several Christian pro-life activists, including Beatty, Cal Zastrow, Eva Zastrow, and Chet Gallagher. 88 In her email, she emphasized: “What can we do to push FACE Act charges 81 See, e.g., E-mail from Patel, to Aloi (Aug. 9, 2022) (Exhibit 068) (flagging that NAF was trying to identify individuals involved in demonstrations in Grand Rapids, Michigan); Email from Davidson, to [Redacted], FBI (Jan. 4, 2021) (Exhibit 069) (identifying pro-life activists involved in the DC matter at the FBI’s request). See also E-mail from Davidson, to [Redacted], FBI (Oct. 18, 2022) (Exhibit 070). 82 See, e.g., E-mail from Patel, to James McNally (Sept. 14, 2020) (Exhibit 071); E-mail from Patel, to Healy (Nov. 16, 2020) (Exhibit 041). 83 E-mail from Gaines, to Patel (July 24, 2024) (Exhibit 072). 84 E-mail from Davidson, to Patel (Jan. 8, 2021) (Exhibit 073). 85 E-mail from Gannon, to [Redacted], FBI (Jan. 12, 2021) (Exhibit 074) (emphasis added) (enclosing attachment “Anti_Abortion_Insurrectionists_at_US_Capitol_Overview.docx” (Exhibit 075)). 86 E-mail from Patel, to Principal Deputy Chief Fitzgerald (Jan. 8, 2021) (Exhibit 076). 87 E-mail from Principal Deputy Chief Fitzgerald, to Patel (Jan. 8, 2021) (Exhibit 077). 88 E-mail from Alicia Davis, Planned Parenthood, to Sheriffs (Jan. 28, 2022) (Exhibit 078). The email enclosed advisories from March 22, 2021 (Exhibit 079); January 7, 2022 (Exhibit 080); and January 27, 2022 (Exhibit 081). 15 again for those involved…?” 89 Those materials were shared with the FBI, who in turn sent them to Patel. 90 Planned Parenthood’s January 27, 2022 advisory noted that Beatty and Edmee Chavannes were not arrested and did not blockade. 91 Nonetheless, it appended a photo of them, along with other pro-life activists, and labeled Beatty and Chavannes as their “opposition identified.” 92 • On July 7, 2022, NAF notified the FBI and Patel about Beatty’s recent activities, 93 attaching a dossier containing Beatty’s photograph, contact information and address, information about her husband and infant child, her affiliated ministries, and a list of her arrests. 94 • A week later, a representative for the Georgia clinic emailed Patel at the Clinic Violence email account, copying the FBI and a long list of abortion NGOs and providers, to ask for help to “stop these [ ] habitually criminal extremists from coming onto our properties,” inquiring whether Beatty was on a domestic terror watchlist. 95 Patel addressed the concerns over a telephone call and stayed in touch with the clinic contact, who thanked Patel in real time for obtaining convictions in the Handy matter. 96 iii. DOJ Provided NAF Internal Department Information and Coordinated with NAF on Pro-Abortion Outreach and Civil FACE Act Litigation. Patel provided significant amounts of information to NAF, seemingly unbeknownst to CRT supervisors who thought that the “information flow ha[d] always been a one-way street.” 97 • When NAF requested a list of all active FACE charges, “including [crisis pregnancy centers] and churches,” Patel sent a complete list back within the hour. 98 • When NAF and FMF requested information about the “Terms of Release for several OSA extremists (Gallagher, Cal, James, and Eva Zastrow, Edl, and Place) as well as the DC ([Progressive Anti-Abortion Uprising]) crew Terms of Release,” Patel and AUSAs shared 89 E-mail from Alicia Davis, Planned Parenthood, to Sheriffs (Jan. 28, 2022) (Exhibit 078) (emphasis in original). 90 Id. 91 Planned Parenthood Advisory from January 27, 2022, supra note 88 (Exhibit 081). 92 Id. 93 E-mail from Davidson, to Patel (July 7, 2022) (Exhibit 082). 94 NAF Dossier on Beatty (Exhibit 083). 95 E-mail from [Redacted], to Patel (July 14, 2022) (Exhibit 084). Compare E-mail from [Redacted], to Patel (Aug. 29, 2023 3:38PM) (Exhibit 085), with E-mail from Criminal Chief Felte, to Weiner (Aug. 29, 2023 3:28PM) (Exhibit 086). 96 97 E-mail from Principal Deputy Chief Fitzgerald, to Buchko (Oct. 31, 2023) (Exhibit 039). 98 E-mail from Patel, to Davidson (May 15, 2023) (Exhibit 087). 16 it quickly. 99 Two days later, NAF shared those terms for the Gallagher defendants with its membership Security Update email list. 100 After sharing this information, NAF flagged protests by defendants as possible violations of their sentencing terms. 101 • At NAF’s invitation, Patel attended its national conference and presented an update to abortion clinics and providers about the FACE Act. In his read-out of the NAF Conference, he noted that his presentation on FACE Act was “well received.” “The big takeaway – many providers are scared with the Dobbs anniversary fast approaching; and they are frustrated that we are using FACE to protect ‘fake clinics.’ There were many other providers who fired back during some cross-audience debating, recognizing that if we don’t enforce the statute even-handedly, we’ll likely lose it.” 102 • NAF asked Patel whether the defendants in Zastrow would plead and for information about why the case schedule was shifted. Patel responded, “I’m pretty sure the continuance was to accommodate the attorneys’ schedules, and to provide sufficient time before trial . . . The part regarding pleas might be standard language . . . I’ll check with the prosecutors about that.” 103 The Task Force also coordinated with NAF when preparing for meetings with outside advocacy groups. 104 For example, before a meeting with numerous pro-abortion groups, Patel consulted with NAF about questions from clinics that he could raise with his supervisor, including ideas about how to possibly extend the scope of the FACE Act’s protections to “constructive phys[ical] obstruction.” 105 NAF specifically flagged that meeting guests would want to talk about pro-life activist Bevelyn Beatty and recent case updates in state court. 106 Additionally, the Task Force coordinated with NAF on civil, private-party litigation against many of the pardoned defendants, which ultimately resulted in the United States filing a statement of interest on behalf of the clinic. In February 2022, Patel, NAF, and FMF discussed the local 99 E-mail from Patel, to Davidson (Oct. 31, 2022) (Exhibit 088); E-mail from Klopf, to Gaines (Oct. 11, 2022) (Exhibit 089) (sharing the terms of pre-trial release with NAF and FMF). 100 Email from NAF Security Department, to Fitzgerald (Oct. 13, 2022) (Exhibit 090). E-mail from Patel, to Laura-Kate Bernstein (Aug. 29, 2024) (Exhibit 091) (forwarding questions from NAF about whether Eva and Cal Zastrow were violating their house arrest by “protesting outside a NAF member facility in Flint, MI”); E-mail from Serrano, to Patel (May 11, 2023) (Exhibit 092) (forwarding a social media post from Lauren Handy about a training on pro-life activity in case it was a violation of her terms of release). 101 102 See E-mail from Patel, to DAAG Moossy (May 12, 2023) (Exhibit 093). 103 E-mail from Patel, to Davidson (Apr. 19, 2023) (Exhibit 094). See E-mail from Davidson, to Patel (Nov. 29, 2021) (Exhibit 095); E-mail from Davidson, to Patel (Nov. 9, 2021) (Exhibit 096); E-mail from Patel, to Principal Deputy Chief Fitzgerald (Nov. 26, 2021) (Exhibit 097) (attaching meeting agenda for Task Force meeting with abortion NGOs and clinics (Exhibit 98)). 104 105 E-mail from Davidson, to Patel (Nov. 29, 2021) (Exhibit 095). 106 Id. 17 proceedings stemming out of the Mt. Juliet demonstration, 107 and Davidson reached out to Patel separately to request time on his calendar to discuss FACE Act strategies and get an “update on the TN briefing.” 108 DOJ ultimately took a two-pronged approach, bringing criminal FACE Act charges and supporting Carafem in its civil FACE Act suit when many of the same pro-life individuals returned to protest there the following year. On July 29, 2022, Carafem filed a complaint against Beatty, Chavannes, Gallagher, Operation Save America National Inc., and Operation Save America’s President Jason Storms, among others. Carafem alleged that defendants violated the FACE Act on July 26, 2022, when Coleman Boyd protested at Carafem with approximately 150 members of Operation Save America. 109 Carafem obtained a temporary restraining order and a preliminary injunction preventing any of the defendants from entering the property where Carafem is located during its business hours or otherwise obstructing those seeking reproductive health service from the facility. 110 Through NAF, the ACLU and Carafem informed Patel first that they were considering filing the motion for a temporary restraining order, 111 discussed possible coordination, 112 and then notified him of the filing. 113 In a related exchange, a CRT attorney explained that “[c]ivil FACE doesn’t give us any remedies that they cannot get, so I’m not sure filing our own suit makes sense,” but flagged that “I would love to file a[] [statement of interest] to show our support.” 114 On September 1, 2022, DOJ filed a Statement of Interest, asserting its “interest in enforcing federal laws that protect access to reproductive health services, including, but not limited to, abortion care,” and seeking “to make clear that the FACE Act prohibits temporary physical obstructions or incomplete blockages of clinic access to reproductive health facilities.” 115 See E-mail from Patel, to Gaines (Feb. 3, 2022) (Exhibit 099); Id., E-mail from Gaines, to Patel (Feb. 3, 2022) (attaching Exhibit 100). See also E-mail from Patel, to Klopf (May 10, 2022) (Exhibit 101) (discussing update from Tennessee law enforcement about the resolution of the local proceedings). 107 108 E-mail from Davidson, to Patel (Feb. 9, 2022) (Exhibit 102). 109 Memorandum Order, Femhealth USA, Inc. v. Williams, No. 3:22-cv-00565 (M.D. Tenn. Sept. 14, 2022), dkt. no. 65. Id. at 2-3, 12; Temporary Restraining Order, Femhealth USA, Inc. v. Williams, No. 3:22-cv-00565 (M.D. Tenn. July 29, 2022), dkt. no. 9; 110 111 See E-mail from Davidson, to Patel (July 29, 2022) (Exhibit 103). 112 See E-mail from Brigette Amiri, ACLU, to Patel (July 29, 2022) (Exhibit 104). 113 E-mail from Ryan Mendias, ACLU, to Patel (July 29, 2022) (Exhibit 104). 114 E-mail from Kerry Dean, to Patel (Aug. 1, 2022) (Exhibit 104). 115 Statement of Interest of the United States, Femhealth USA, Inc. v. Williams, No. 3:22-cv-00565 (M.D. Tenn. Sept. 1, 2022). 18 iv. The Biden DOJ Helped Abortion NGOs Obtain Third-Party Grants. When abortion NGOs raised concerns about possible violations or requests for contacts with the FBI, the Task Force Director immediately helped and connected NAF with contacts around the country. 116 In late 2020, NAF asked if Principal Deputy Chief Fitzgerald would serve as a reference on “a fund proposal (that supports, among other things, their training and threat monitoring services).” 117 Patel forwarded the request to her, suggesting that NAF “may be able to list me in your place,” and then followed up stating that absent objection, he would have “NAF use [him] as the reference for their grant application.” 118 Before his supervisor responded, Patel agreed to serve as NAF’s reference. 119 When his supervisor eventually responded, she recommended that Patel “ask our ethics person[] what we are allowed to do/say re: an NGO with whom we interact.” 120 DOJ’s review of all custodian emails did not reveal any email where Patel contacted his ethics officer on this matter or retracted his offer to NAF. Two years later, NAF requested that Task Force Director Patel help them with another grant application, asking that he “write a short impact statement, on DOJ letterhead, and in your own words, on the importance of the NAF Security Departments work and the impact on provider safety in the DMV. You could also talk about how we work together and some of the outcomes of our efforts if you feel inclined.” 121 Patel flagged that he would have to get permission from Principal Deputy Chief Fitzgerald “to write a statement for you (which you know I am otherwise happy to do for you).” 122 There was no further correspondence on this topic in DOJ records. E-mail from Patel, to Davidson (July 16, 2021) (Exhibit 038) (responding to a request from Davidson for an FBI contact in West Virginia); E-mail from Patel, to [Redacted], FBI (Nov. 17, 2021) (Exhibit 037) (connecting NAF with a California-based FBI contact). 116 117 E-mail from Patel, to Principal Deputy Chief Fitzgerald (Dec. 23, 2020) (Exhibit 105) 118 Id. 119 E-mail from Patel, to Tara Gannon (Dec. 23, 2020) (Exhibit 106) (agreeing to serve as a reference). According to its website, the “the Lisa and Douglas Goldman Fund is a private foundation committed to providing support for charitable organizations that enhance our society.” See ABOUT US, LGDFUND.ORG (last visited Feb. 17, 2026), https://perma.cc/25C8-VXN6. NAF ultimately received $90,000 in grant funding from the Lisa and Douglas Goldman Fund in 2021 and $100,000 in grant funding in 2022. Grants Database, LGDFund.org (last visited Feb. 17, 2026), https://perma.cc/5LA9-FVLS. Davidson later informed Patel that this foundation was one of “the main funder[s] of [NAF’s] security work.” E-mail from Davidson, to Patel (Nov. 9, 2021) (Exhibit 096). 120 E-mail from Principal Deputy Chief Fitzgerald, to Patel (Dec. 30, 2020) (Exhibit 105). E- mail from Principal Deputy Chief Fitzgerald, to John Buchko (Nov. 1, 2023) (Exhibit 039); E-mail from Davidson, to Patel (Oct. 31, 2023) (Exhibit 107). 121 122 E-mail from Patel, to Davidson (Oct. 25, 2023) (Exhibit 107). 19 IV. THE BIDEN DOJ’S INAPPROPRIATE PROSECUTORIAL CONDUCT DOJ prosecutors engaged in inappropriate conduct and comments directed toward pro-life defendants. Prosecutors disparaged defendants’ religious beliefs, Catholic judges, and defense counsel. Prosecutors sought to exclude religious jurors. They declined to allow some defendants to self-surrender, instead authorizing aggressive arrest tactics. And, when defense counsel requested data on historic FACE Act prosecutions, Patel asserted that he did not maintain those records, referring counsel to the FOIA process, although he had the data on hand and had provided similar information to abortion NGOs a year prior. The following three examples provide case studies of these inappropriate prosecutorial decisions and conduct. A. United States v. Gallagher: The Biden DOJ Claimed to Defense Counsel That It Did Not Keep Information Requested for a Selective Prosecution Defense, Despite Giving Materially Identical Information to NAF. On March 5, 2021, Gallagher, Heather Idoni, Calvin Zastrow, Davis, Paul Vaughn, Eva Edl (an approximately 87-year-old Soviet death camp survivor), Eva Zastrow, James Zastrow, and Paul Place gathered in the hallway outside Carafem Health Center, in Mt. Juliet, Tennessee. They met at approximately 7:45 a.m., before the facility opened. Dennis Green and Boyd subsequently joined them. 123 NAF alerted Patel that there was an “active blockade at Carafem in Mt. Juliet, TN” while it was still ongoing, and that NAF would monitor and download the demonstrator’s live stream. 124 The Task Force reengaged on the matter shortly after the Dobbs leak. 125 On October 3, 2022, DOJ secured a two-count indictment. It charged Gallagher, Idoni, Calvin Zastrow, Boyd, Davis, Vaughn, and Green with violating 18 U.S.C. § 241 (conspiracy against rights). And it charged each defendant with violating the FACE Act. 126 In January 2023, one of the defense counsel contacted the AUSA requesting information about “how many FACE Act criminal prosecutions there have been in the last ten years, including both reproductive right clinics, churches etc.” 127 The counsel flagged that “[i]t is no secret that we will make a selective prosecution type argument,” and anticipated that this information would be necessary to help the judge assess the defense. 128 The Biden DOJ prosecutors had this information readily available, having compiled it before defense counsel’s request. They refused to share it. A month later, after several more requests as defendants’ filing deadline was approaching, Patel responded, stating: 123 Indictment, United States v. Gallager, No. 3:22-cr-00327 (M.D. Tenn. Oct. 3, 2022). 124 E-mail from Davidson, to Patel (Mar. 5, 2021) (Exhibit 063). 125 Patel e-mailed the USAO to “get the [grand jury] memo moving [on this case] so that we can figure out what our likely target indictment date is.” E-mail from Patel, to Klopf (May 8, 2022) (Exhibit 101). 126 Indictment, United States v. Gallager, No. 3:22-cr-00327 (M.D. Tenn. Oct. 3, 2022). 127 E-mail from Jodie Bell, to Klopf (Jan. 27, 2023) (Exhibit 108). 128 Id. 20 As the national clinic violence coordinator, I do not keep the kind of records you requested and, as a result, I do not believe that we will provide them to you. However, I expect that much of what you seek is publicly available. For example, there are press releases on the DOJ’s public website that address FACE Act prosecutions. With those press releases, you would be able to obtain additional materials through the courts’ online databases. 129 Patel’s representation to defense counsel was false. 130 At Patel’s request, in October 2022, CRT compiled a spreadsheet of all DOJ actions under the FACE Act. 131 The FBI provided him monthly updates about the number of FACE Act investigations and prosecutions, broken down by pro-life and pro-choice valence. 132 Additionally, he had previously compiled and shared a full list of FACE Act prosecutions to NAF when that team requested similar data. 133 The First Assistant United States Attorney was inclined to provide the data, but Patel decided “we should not provide her with anything,” reasoning that “[p]roviding her with the requested information may open gates we will struggle to close later.” 134 129 E-mail from Patel, to Bell (Feb. 22, 2023) (Exhibit 108). 130 Under the Rules of Professional Conduct, attorneys are obligated to truthfulness: “In the course of representing a client, a lawyer shall not knowingly [] make a false statement of material fact or law to a third person.” Am. Bar Ass’n, Model Rules of Professional Conduct 4.1(a) (2019). The Justice Manual mandates that DOJ employees “must comply with the rules on Government ethics” and “applicable rules of professional conduct.” U.S. Dep’t of Just., Just. Manual § 1-4.010, https://perma.cc/L3GU-6SPS. 131 E-mail from Miller, to Patel (Oct. 19, 2022) (Exhibit 109). E-mail from [Redacted], FBI, to Patel (May 31, 2024) (Exhibit 110); E-mail from Patel, to Criminal Chief Felte (May 28, 2024) (attached as Exhibit 111) (summarizing the FACE Act charges brought since January 2021). 132 133 See supra, at 16 & n.98. 134 E-mail from Patel, to Klopf (Feb. 2, 2023) (Exhibit 112). 21 B. United States v. Zastrow: The Biden DOJ Allowed Abortion NGOs to Drive Charging Decisions and Engaged in Blatant Anti-Christian Bias in the Jury Pool. On August 27, 2020, Calvin Zastrow, Gallagher, Idoni, Davis, Joel Curry, Justin Phillips, Edl, and Eva Zastrow demonstrated at a women’s clinic in Sterling Heights, Michigan. Before the demonstration, the Defendants and other demonstrators gathered near the clinic and prayed. The Defendants then walked to the clinic’s entrance area while others demonstrated from the public sidewalk, carrying signs, singing hymns, and praying. Several defendants spoke to women at the clinic, and several stood or sat in front of the doors while praying or singing hymns. Law enforcement officers responded and asked the Defendants to move. When the Defendants refused to move, they were arrested and charged with a 30-day misdemeanor trespass offense by the local prosecutor. On August 27, 2020, while the demonstration was still underway, Davidson notified Patel that there was an active “blockade” occurring and that Gallagher was among the demonstrators “sitting in front of the doors.” 135 Davidson’s colleague forwarded Patel videos of the demonstration the next day, which Patel immediately sent to his deputy chief in CRT, noting that he would be “happy to jump on this if you’d like.” 136 On September 1, 2020, Patel contacted Frances Carlson, an AUSA from the United States Attorney’s Office for the Eastern District of Michigan and forwarded her an e-mail chain that he received from NAF, containing an earlier e-mail from the clinic’s owner to the FBI describing the demonstrators as “terrorists;” explaining that the demonstration was “distressing, illegal[,] and [the clinic was] not happy with the way it was handled[;]” and noting that they “want[ed] to move forward with a FACE prosecution and are sending all this information over to the Department of Justice.” 137 Patel told Carlson that he thought there was a good misdemeanor FACE Act charge for each demonstrator who blocked the entrance. 138 He reached out to Davidson to ask her to “help coordinate” getting him copies of witnesses statements, video footage, and photographs the clinic gathered. 139 In December 2020, the United States Attorney’s Office declined to bring federal misdemeanor charges because the prosecution was being handled via local arrests. On April 16, 2021, Idoni and Edl sat in front of an abortion clinic doors in Saginaw, Michigan. Idoni wanted to stay there as long as possible “to prevent babies from dying.” Edl wedged a door stop under the door, and Idoni chained herself to a second door using a bike lock. 135 E-mail from Davidson, to Fleisher (Aug. 27, 2020) (Exhibit 064). 136 E-mail from Patel, to CRT Deputy Chief Bobbi Bernstein (Aug. 28, 2020) (Exhibit 113). 137 E-mail from Patel, to Carlson (Sept. 1, 2020) (Exhibit 114). 138 Id. E-mail from Patel, to Davidson (Sept. 1, 2020) (Exhibit 115). On September 14, 2020, Davidson, who received a copy of the police report from the August 27, 2020, arrest, forwarded it to Patel, noting that he should please “let [NAF] know if [they] can assist with anything else.” E-mail from Fleisher, to Patel (Sept. 14, 2020) (Exhibit 116). 139 22 The police arrested Edl and Idoni for misdemeanor trespassing after they refused to leave. A local prosecutor charged Idoni and Edl with misdemeanor trespassing, a state jury found them both guilty, and the state court fined each $225. On April 16, 2021, shortly after the Saginaw demonstration ended, Davidson notified Patel about the clinic “blockage.” Patel forwarded the information to the U.S. Attorney’s Office asking whether it is a good time to “revisit the Sterling Heights blockade.” 140 Carlson responded that she does “not have the support of [her] unit chief. This may change, however, if the same actors are involved in the Saginaw incident.” 141 The Biden DOJ Pursued More Significant Charges after the Texas Heartbeat Bill and Dobbs In December 2021—a year after the USAO’s initial declination—Patel contacted Carlson again about the Sterling Heights case. Carlson e-mailed her supervisor, explaining that Patel’s “management [wa]s very eager to pursue the prosecution now given some events that have occurred since then [Carlson believed this referred to Texas’s Heartbeat Law].” 142 Carlson acknowledged her supervisor’s “strong opinions” against charging the misdemeanor case when it first happened because “there was no violence or damage to the clinic.” 143 But Carlson explained that she agreed with CRT that the case should be reopened “[g]iven the recent directive from [Deputy Attorney General Lisa Monaco] . . . .” 144 Several days later, Carlson confirmed that Patel “[wa]s not aware of any FACE Act prosecutions involving non-violent violations yet. But the posture of the administration and his particular office has changed so he expects that there will be. His office definitely plans on moving forward with this and would prefer to do it with us.” 145 In January 2022, Carlson informed her supervisor that CRT “would like to know if our office will do the prosecution with them. I think we should. Either way, CRT will proceed with the prosecution.” 146 Shortly after, Carlson met with her USAO leadership. The then newly confirmed United States Attorney (USA) Dawn Ison expressed concerns about delay, the current state prosecution, and being the first non-violent FACE Act prosecution in the country. USA Ison explained that, if the USAO could maintain some control over the case and CRT obtained a Petite 140 E-mail from Patel, to Carlson (Apr. 16, 2021) (Exhibit 065). 141 Id. 142 E-mail from David Gardey, to Carlson (Jan. 4, 2022) (Exhibit 117). 143 Id. Id. On October 21, 2022, DAG Monaco issued a protocol for high-profile civil rights incidents, which included “the use or threat of force against a person seeking to provide or obtain reproductive health services” under § 248. See U.S. Dep’t of Just., Just. Manual § 8-3.135, https://perma.cc/7ASB-DKN8 (last visited Feb. 27, 2026). There was, however, no evidence of force or threats of force for the Sterling Heights or Saginaw demonstration. 144 145 Id. 146 Id. 23 waiver, 147 she would approve joining the prosecution. Carlson relayed USA Ison’s position to Patel, and, on January 28, 2022, the USAO decided to join the prosecution. In early May 2022, shortly after the Dobbs leak, Deputy Chief Bobbi Bernstein contacted Patel about the status of this matter. 148 Shortly thereafter, Patel, Laura-Kate Bernstein, Principal Deputy Chief Fitzgerald, and Deputy Chief Bernstein sought authorization from Deputy Assistant Attorney General Moossy to charge misdemeanor FACE Act violations for both demonstrations. On May 19, 2022, Deputy Chief Bernstein notified Patel that she had spoken with Principal Deputy Chief Fitzgerald, and that “[Fitzgerald] is very much inclined to” bring charges under 18 U.S.C. § 241, “so that the Ds will have felonies and will be barred from possessing firearms.” 149 Patel initially disagreed, stating that the “best play” would be to pursue FACE Act charges against these defendants because they could proceed to trial quickly and five of the defendants were already facing 18 U.S.C. § 241 charges in Tennessee. 150 Principal Deputy Chief Fitzgerald, however, explained that “Detroit seems like it would have a jury pool that would be more accepting of the FACE Act than TN,” ultimately persuading Patel to move forward with the 18 U.S.C. § 241 charges. 151 In early June, Carlson told her supervisor, [The CRT] bosses feel strongly about the felony charges. If we feel differently, they plan to go forward on their own with the prosecution. Of course, they would prefer to do the case with us so if it would be helpful, they would like to have a call with you and our “front office.” 152 Around this time, Carlson’s supervisor recused himself and stopped supervising the case. 153 CRT reached out again to the AUSA, reminding that DOJ wanted to charge everyone in the conspiracy if there was evidence of concerted conduct, which was what the Middle District of Tennessee planned to do with their case. 154 In mid-June, USA Ison explained to her staff that, if CRT wanted to go forward with the felony, then she felt the United States Attorney’s Office had to join them. 155 USA Ison requested a new prosecution memorandum, to lay out the facts of the case, potential charges and defenses, 147 See discussion of Petite policy, infra at 25. 148 E-mail from Deputy Chief Bernstein, to Patel (May 6, 2022) (Exhibit 118). 149 E-mail from Deputy Chief Bernstein, to Principal Deputy Chief Fitzgerald (May 19, 2022) (Exhibit 119). 150 Id. 151 Id. 152 E-mail from Gardey, to Carlson (June 2, 2022) (Exhibit 120). 153 E-mail from Gardey, to Carlson (Jan. 4, 2022) (Exhibit 117). 154 See generally E-mail from Patel, to Carlson (Jun. 13, 2022) (Exhibit 121). 155 See generally id. 24 and the Government’s ability to meet its burden of proof at trial. 156 Carlson drafted the memorandum with help from CRT, which sought approval to charge nine defendants with felony conspiracy against rights (18 U.S.C. § 241) violations and two misdemeanor FACE Act violations. Petite Waiver Request As previously mentioned, Idoni and Edl were convicted in state court for actions in connection with the Saginaw demonstration. Accordingly, pursuant to DOJ’s Petite Policy, DOJ attorneys could only pursue federal charges against these defendants if they obtained approval from AAG Clarke and could demonstrate that: (1) the matter involved a substantial federal interest; (2) the prior prosecution left that interest demonstrably unvindicated; and (3) the government believed that the defendants violated a federal statute and that the admissible evidence probably would be sufficient to sustain and maintain a conviction by an unbiased trier of fact. 157 In October 2022, Patel submitted a Petite waiver request to charge Idoni and Edl with a federal misdemeanor FACE Act violation for the Saginaw demonstration. 158 Patel explained that the matter involved substantial federal interests, regardless of the state convictions, because the defendants “will continue to engage in obstructive conduct that interferes with the provision of abortion care because of their strongly held ideologies.” 159 He explained that “[t]hrough this prosecution, we may be able to bring future felony charges” against them. 160 Patel reasoned that The Clinic and their corresponding national Non-Governmental Organizations (NGO) stakeholders are very committed to pursuing a federal prosecution. . . . Similarly, NGOs, including the National Abortion Federation and Feminist Majority Foundation, have on several occasions contacted federal authorities and expressed their and the Clinic’s strong interest in the Department of Justice pursuing a federal FACE Act prosecution here. 161 In November 2022, CRT transmitted a revised version of its Petite waiver request to AAG Clarke for her approval. 162 Among other modifications, the revised request omitted this language from Patel’s draft, downplaying the role that pro-abortion advocacy groups played in CRT’s decision to pursue these charges against the Defendants. He cited to Attorney General Merrick Garland’s statements about DOJ’s post-Dobbs commitment to “tirelessly protect and advance 156 See E-mail from L. Bernstein, to Carlson (Oct. 18, 2022) (Exhibit 122). 157 See U.S. Dep’t Just., Just. Manual § 9-2.031. 158 See Draft Memorandum from Criminal Chief Felte, to AAG Clarke (Oct. 28, 2022) (Exhibit 123). 159 Id. 160 Id. 161 Id. 162 Compare Memorandum from Criminal Chief Felte, to AAG Clarke (Nov. 30, 2022) (Exhibit 124), with Draft Memorandum from Criminal Chief Felte, to AAG Clarke (Oct. 28, 2022) (Exhibit 123). 25 reproductive freedom” and use the FACE Act “to protect healthcare providers and individuals seeking reproductive health services.” 163 Felony Indictment and Arraignment Patel, Carlson, and a second AUSA, Sunita Doddamani, presented the case to the grand jury. The indictment charged Calvin Zastrow, Gallagher, Idoni, Curry, Phillips, Eva Edl, and Eva Zastrow, with conspiracy against rights, in violation of 18 U.S.C. § 241, and clinic access obstruction, 18 U.S.C. § 248, for their involvement in the Sterling Heights demonstration. 164 It also charged Idoni and Edl with clinic access obstruction under the FACE Act for their involvement in the Saginaw demonstration. In March 2023, the Defendants were arraigned. Carlson complained about the magistrate judge overseeing the arraignment: Unfortunately, we ended up with a very Catholic magistrate on duty this week and he was very particular about the bond conditions and not infringing on their first amendment rights. At the end, we ended up with overly lawyered bond conditions that would be difficult to enforce! 165 Jury Selection The Biden DOJ prosecutors sought to identify and screen Christian jurors from the jury pool simply because they were Christian, without imperiling pro-abortion jurors. The first effort was in May 2024, when they prepared a proposed voir dire to submit to the court. In preparing the document, the trial team struggled with what questions to ask, with a CRT Deputy Chief at one point cautioning his subordinate that “conservative judges” could be “upset by some of” questions they were considering as some “seem very one-sided.” 166 The Biden DOJ trial team considered ways of asking about potential jurors’ religion, with Bernstein noting that she could not think of an “anodyne way to ask” questions about “religion, how often people go to services, etc.” 167 They contemplated asking whether potential jurors had ever “contributed to any group” that “advocates for any aspect of reproductive health care,” but a CRT attorney ultimately expressed concern that the question could lead to the “court excusing forcause” individuals with pro-abortion views. 168 The team ultimately did not raise those specific 163 Memorandum from Criminal Chief Felte, to AAG Clarke (Nov. 30, 2022) (Exhibit 124). 164 Indictment, United States v. Zastrow, No. 2:23-cr-20100 (E.D. Mich. Feb. 15, 2023). 165 E-mail from Carlson, to Patel (Mar. 10, 2023) (Exhibit 125) (emphasis added). 166 E-mail from Deputy Chief Bernstein, to L. Bernstein (Mar. 17, 2024) (Exhibit 126). 167 E-mail from L. Bernstein, to Carlson (May 15, 2024) (Exhibit 127). The use of peremptory strikes to exclude a potential juror on the basis of actual or perceived protected classes violates the Equal Protection Clause. See Batson, 476 U.S. at 89; J.E.B. v. Alabama ex rel. T.B., 511 U.S. 127, 143 (1994). Strikes based on purposeful discrimination “undermine public confidence in the fairness of our system of justice” and violate the defendants’ right to “be tried by a jury whose members are selected pursuant to nondiscriminatory criteria.” Batson, 476 U.S. at 86-87. 168 See Draft Proposed Voir Dire Questions, United States v. Zastrow, No. 2:23-cr-20100 (Exhibit 128). 26 questions in the voir dire filed with the court, reasoning that they could be “less concerned about the proposed voir dire” once the judge allowed a jury questionnaire, which would give the information they wanted. 169 The judge adopted questions into the jury questionnaire that the Biden DOJ proposed. While the final phrasing was unremarkable, internal drafts indicate what types of information the trial team hoped to glean from the answers, such as how frequently the jurors attend services 170 or whether their children attend religious schools. 171 Throughout the process, they searched for “an indirect way to get some more info about religion without directly asking it.” 172 The trial notes are consistent with this approach. The Biden DOJ prosecutors flagged several Christian jurors for peremptory and for-cause strikes from the jury pool because of their faith. 173 Trial The trial team requested that the court limit the defendants’ ability to wear “Jesus buttons” to the trial. 174 For example, on the day that Carlson asked for a limiting instruction, C. Zastrow was wearing a button that says, “Jesus is Lord.” Doddamani raised concerns about “improper messaging” to the jury. The judge was skeptical, as the trial testimony and exhibits offered by both sides would involve the defendants’ religious views. 175 In closing argument, Carlson made the following numerous statements about the Defendants’ religious beliefs and pro-life views: • “If the defendants were looking for meaningful conversation, they sure didn’t act like it. [] What the defendants cared about was their own version of reality. What they cared about was depriving the women in the parking lot of their right to obtain reproductive health services. What they cared about was the supremacy of their beliefs about women who came to reproductive health clinics and their -- the supremacy of their beliefs over the law. What they cared about was deciding for women, deciding for women that they should not be able to exercise a legal right that they have. [ ] The defendants were in that parking lot 169 E-mail from L. Bernstein, to Carlson (May 15, 2024) (Exhibit 127). 170 Draft Proposed Juror Questionnaire Instructions, United States v. Zastrow, No. 2:23-cr-20100 (Exhibit 129). 171 Id. 172 Id. The responses to juror questionnaires are sealed for juror privacy. See Juror Questionnaire Instructions, United States v. Zastrow, No. 2:23-cr-20100 (E.D. Mich. May 15, 2024), dkt. no. 254 (“The questions are not intended to unnecessarily inquire into personal matters; all information obtained will be kept confidential.”). As a result, DOJ is treating internal deliberations and summaries of the responses as subject to the same seal as the juror questionnaire responses. 173 Transcript of Hearing Regarding Potential Juror Responses to Questionnaires, at PageID.2351-56, United States v. Zastrow, No. 2:23-cr-20100 (E.D. Mich. Aug. 19, 2024), Dkt. No. 371. 174 175 Id. 27 because they believed they knew better. They knew better than [Patient 1] about the choices that she should make in her life. The defendants didn’t care about [Patient 1] and they certainly did not care about the law. They didn’t care about anything but their own beliefs.” 176 • “We are here today because the defendants believed that they are above the law. [ ] We are here because they believe that they have a right to oppress and intimidate by imposing their will on others and that they can violate the law without being held accountable.” 177 During rebuttal argument, Doddamani made the following statements: • “And like when the defendants were taking video of people in their cars without their permission, it’s an expected result that that would make them feel fearful and that they would turn away from that clinic. I’d be turning away from that if I saw that at the grocery store. Let alone a medical clinic. The same thing with the people who they were calling baby murderers or telling them to repent for their sins.” 178 • “There’s a version of the argument we heard from the defense. These women basically overreacted to what we were politely doing. Right? They’re essentially here calling the witnesses, the employees, and the patients snowflakes. Right? In their view, these women were just overreacting. Like women do. Right? Which is stereotypical nonsense.” 179 While drafting her rebuttal, Doddamani compared pro-life Christians to cult members, describing them and the terms they used as “culty.” 180 176 Transcript of Jury Trial, Volume 10, at PageID.4283-84, United States v. Zastrow, No. 2:23-cr-20100 (E.D. Mich. Aug. 19, 2024), Dkt. No. 382 (emphasis added). 177 Id. at PageID.4288-89 (emphasis added). Id. at PageID.4391-92 (emphasis added). Inviting jurors “to place themselves in the victim’s shoes violates the ban on Golden Rule arguments.” United States v. Hall, 979 F.3d 1107, 1119 (6th Cir. 2020). A “Golden Rule” appeal asks the jury “to put itself in the [victim’s] position” and “is universally recognized as improper because it encourages the jury to depart from neutrality and to decide the cases on the basis of personal interest and bias rather than the evidence.” Id. (emphasis in original) (internal quotations omitted). 178 179 Id. at PageID.4392 (emphasis added). 180 E-mail from L. Bernstein, to Carlson (Aug. 18, 2024) (Exhibit 130). 28 C. United States v. Houck: The Biden DOJ Used Aggressive Arrest Tactics Against a Pro-Life Defendant Who Was Subsequently Acquitted. On October 13, 2021, Mark Houck, “a devoted pro-life Catholic and father of seven,” took his twelve-year son with him to speak outside of a Planned Parenthood location. 181 While speaking outside of the facility, Houck encountered a Planned Parenthood escort. When the clinic escort confronted his son with ridicule and profanity, Houck stepped in to protect his child and pushed the escort, scraping his arm. 182 That week, Planned Parenthood’s local Senior Director of Security contacted the FBI, requesting assistance and stating the “objective of this would be to obtain an injunction similar” to a 2011 civil action filed by DOJ. 183 The FBI forwarded this email to Patel, 184 who forwarded the Planned Parenthood inquiry to one of the deputy chiefs, saying that this “looks like a good felony FACE matter” and that he would open a new matter and assign it to himself. 185 Patel spent the next several months persuading his supervisors to allow him to file charges against Houck. Supervisors voiced concerns that the incident seemed unrelated to any intent to interfere with clinic access. 186 They agreed that Patel’s additional investigation mitigated litigation risk and noted that the “USAO really wants to proceed in this matter, and the FBI is on board.” 187 In other exchanges, AUSAs in the Eastern District of Pennsylvania wanted to confirm that the Houck matter would be the “first post-Dobbs FACE indictment.” 188 In an email chain discussing the plan to arrest Houck and prep press releases, an AUSA disparaged Houck’s defense counsel, expecting them “to be particularly . . . Unpleasant.” 189 In a separate email chain, Patel derogatorily described these attorneys—a pro-life public interest law firm—as “quite the racket.” 190 Houck’s attorneys offered to accept a summons and bring him in voluntarily if DOJ proceeded with a criminal case, 191 but DOJ and the USAO declined to pursue a summons and 181 Indictment, United States v. Houck, No. 2:22-cr-00323 (E.D. Pa. Sept. 20, 2022). 182 See E-mail from Patel, to Principal Deputy Chief Fitzgerald (Nov. 19, 2021) (Exhibit 131). E-mail from [Redacted], FBI, to Patel (Oct. 18, 2021) (Exhibit 066) (forwarding e-mail from Planned Parenthood). 183 184 Id. 185 E-mail from Patel, to Sheldon Beer (Oct. 18, 2021) (Exhibit 132). 186 E-mail from Principal Deputy Chief Fitzgerald, to Patel (Nov. 18, 2021) (Exhibit 133). E-mail from Beer, to Principal Deputy Chief Fitzgerald (Aug. 10, 2022) (Exhibit 134); E-mail from Principal Deputy Chief Fitzgerald, to Beer (Aug. 18, 2022) (Exhibit 135). 187 188 E-mail from Patel, to Eve (Aug. 31, 2022) (Exhibit 136). 189 E-mail from Gibson, to Eve (Sept. 16, 2022) (Exhibit 137). 190 See E-mail from Patel, to Ashley Martin (Jan. 21, 2023) (Exhibit 138). 191 E-mail from Matt Heffron, Thomas More Soc’y, to Eve (June 9, 2022) (Exhibit 139). 29 allow Houck to self-surrender, instead deferring to the FBI’s plan to arrest. 192 DOJ, the USAO, and the FBI coordinated in advance and approved of the plan to arrest. 193 On September 20, 2022, the USAO for the Eastern District of Pennsylvania secured a twocount indictment against Houck under the FACE Act. 194 At 7:03 A.M. on September 23, 2022, sixteen FBI agents arrived at Houck’s home in seven vehicles. The officers were visibly armed. They arrested and handcuffed Houck outside his front door while his family watched from inside. 195 Shortly after the arrest, the Special Agent notified Patel and the AUSA that Houck was in custody. 196 Public outcry about the arrest and show of force was swift. When CRT leadership wanted to understand what happened, the Task Force Director pointed at the FBI, stating that he and the USAO “urged FBI to allow [Houck] to self-surrender.” 197 No emails in the contemporaneous record support that statement. In a later assessment of lessons learned for upcoming Tennessee FACE indictments, Patel gave his view that the FBI’s “main reason” for arrest rather than allowing self-surrender was to seize phones for search warrants, but that “I think the unspoken reason is bc the FBI really likes to make arrests.” 198 When the DOJ team began to receive emails from the public about the arrest, one AUSA complained about the defendant’s family: “The tragedy is that Mrs. Houck is attempting to taint the public’s view of the arrest and prosecution.” 199 At trial, Houck’s attorneys argued that the abortion escort was the aggressor in the encounter, and, on January 30, 2023, the “jury returned a verdict of ‘not guilty,’ acquitting Mark Houck.” 200 Houck and his wife subsequently filed lawsuits “against the FBI and DOJ for malicious and retaliatory prosecution, abuse of process, false arrest and assault.” 201 The United States recently reached a settlement agreement with Houck. 202 192 E-mail from Patel, to Eve (Sept. 17, 2022) (Exhibit 140). E-mail from [Redacted], FBI, to Eve (Sept. 20, 2022) (Exhibit 141); E-mail from [Redacted], FBI, to Eve (Sept. 22, 2022) (Exhibit 142). 193 194 Indictment, United States v. Houck, No. 2:22-cr-00323 (E.D. Pa. Sept. 20, 2022). 195 See E-mail from Sparkle Sooknanan, to Anders Folk (Sept. 27, 2022) (Exhibit 143). 196 E-mail from Patel, to [Redacted], FBI (Sept. 23, 2022) (Exhibit 144). E-mail from Patel, to Criminal Chief Felte (Oct. 17, 2022) (Exhibit 145). See also E-mail from Patel, to Criminal Chief Felte (Oct. 18, 2022) (Exhibit 146). 197 198 E-mail from Patel, to Criminal Chief Felte (Oct. 4, 2022) (Exhibit 147). 199 E-mail from Eve, to Patel (Sept. 26, 2022) (Exhibit 148). Docket, United States v. Houck, No. 2:22-cr-00323, at Dkt. No. 68 (E.D. Pa.); Judgment of Acquittal/Not Guilty, United States v. Houck, No. 2:22-cr-00323 (E.D. Pa. Jan. 30, 2023), Dk. No. 70; E-mail from Patel, to Criminal Chief Felte (Jan. 30, 2023) (Exhibit 149); E-mail from DAAG Moossy, to Sooknanan (Jan. 30, 2023) (Exhibit 150). 200 Peter Pinedo, Mark Houck and Wife Sue FBI and DOJ for Malicious Prosecution: Era of Targeting Pro-Lifers ‘Is Over’, NAT’L CATHOLIC REG. (Nov. 8, 2023), https://www.ncregister.com/cna/mark-houck-and-wife-sue-fbi-anddoj-for-malicious-prosecution-era-of-targeting-pro-lifers-is-over. 201 202 Amended Joint Status Report of Parties, Houck v. United States, No. 25-1433 (3d Cir. Jan. 7, 2026). 30 V. THE BIDEN DOJ'S SENTENCING DISPARITIES The Biden DOJ routinely pursued comparatively harsher sentences against pro-life FACE Act defendants. In cases involving non-violent conduct under the FACE Act, DOJ pursued significantly higher sentences against pro-life defendants than pro-choice defendants: on average, 26.8 months for the fo1mer versus 12.3 months for the latter. The individual sentencing requests and sentences are summarized in the following chaii: 203 P r oLife Request Sentence Defendants (in months) (in months) United States v. Handy 57 Handy 78 Darnel 51 34 24 Haifow 41 24 Marshall 41 Hinshaw 33 21 24 Idoni 41 Goodman 41 27 27 Bell 41 Geraghty 41 27 United States v. Gallagher Gallagher 20 Idoni 18 C. Zastrow 24 Boyd 15 Vaughn 12 Green 15 Edl 0 E. Zastrow 0 J. Zastrow 0 Place 0 16 8 6 0 0 0 0 0 0 0 United States v. Moscinski Moscinski 6 6 United States v. Williams Beatty 46 41 Average 26.8 months 14.7 months P r oAbortion Request Defendants (in months) Florida/Jane's Revenge Freestone 12 Smith-Stewai1 16 Rivera 16 Oropesa 24 Sentence (in months) 12 1 1 4 United States v. Durant Durant 0 0 United States v. Skorick Skorick 6 0 Average 12.3 months 3 months See Table Notes. 204 203 Cf E-mail from Patel, to L. Bemstein (Sept. 3, 2024) (Exhib it 151) (providing sentencing data but noting they lack reliable statistics on "criminal activity targeting reproduction health providers" because "NGOs, particul arly NAF who tracks these stats, won't admit clinic criminal activity is trending down (even though it actually is)"). 204 This chrut does not include the sentencing recommendations of PACE Act defendants who collllllitted violent attacks, but rather assesses the closest possible comparators, whose cases this repo1t discusses. The data presents the Biden DOJ's high-end sentencing request. Vaughn and Green were sentenced to time served. Boyd, Dav is, Edl, Eva Zastrow, James Zastrow, and Place were sentenced to probation. For purposes of calculating average sentences, Vaughn and Green were treated as if they had served sentences of zero days. 31 Several of the pardoned cases had additional relevant notes regarding sentencing: • United States v. Calvin Zastrow, et al., Case No. 2:23-cr-20100 (E.D. Mich.): The jury returned guilty verdicts on all counts in August 2024. After the 2024 presidential election, the judge sua sponte stayed the post-trial briefing given the possible likelihood that DOJ’s position on the issues in the case could change. On January 23, 2025, President Trump issued a full and unconditional pardon for all Defendants, and the United States Attorney’s Office for the Eastern District of Michigan moved to dismiss the case. • United States v. Christopher Moscinski, Case No. 2:22-cr-00485 (E.D.N.Y.): Fr. Moscinski’s attorney requested a sentence of time served, given his “lifetime of service to the poor and lack of any personal benefit from the offense of conviction,” but DOJ prosecutors asked the court to “impose the maximum term of six month’s imprisonment,” highlighting Fr. Moscinski’s “long history of violating the law.” 205 The court sentenced Fr. Moscinski to six months’ imprisonment. • United States v. Bevelyn Beatty Williams et al., Case No. 1:22-cr-00684 (S.D.N.Y.): Beatty was sentenced to 41-months in prison. 206 Patel congratulated the team on the “incredible result” and the “top end guidelines sentence.” 207 In total, during the four years under President Biden, DOJ charged “more than 45 [pro-life] defendants in over 20 cases” with violating the FACE Act in connection with pro-life demonstrations. 208 This was a significant increase in FACE Act prosecutions compared to prior administrations. 209 CRT’s Special Litigation Section also brought numerous civil FACE Act cases against many of these same pro-life Christians. 210 The Special Litigation Section did not bring any Regarding E. Zastrow, DOJ stated that, “[b]ut for the sentencing disparity it would create with other defendants [due to the court’s downward variance in imposing sentences], the government would submit that a sentence of three months of incarceration and no fine would be sufficient.” DOJ requested a sentence of probation. The Biden DOJ requested that the court sentence Durant to at least one year of probation. Government’s Sentencing Memorandum, United States v. Moscinski, No. 2:22-00485 (E.D.N.Y. Jun. 20, 2023), Dkt. No. 28; Sentencing Memorandum of Christopher Moscinski, United States v. Moscinski, No. 2:22-00485 (E.D.N.Y. Jun. 22, 2023), Dk. No. 29. 205 206 E-mail from Patel, to Criminal Chief Felte (July 24, 2024) (Exhibit 152). E-mail from Patel, to Jacqueline Kelly (July 24, 2024) (Exhibit 153); see also E-mail from Patel, to Mitzi Steiner (July 24, 2024) (Exhibit 154). 207 208 E-mail from Patel, to Criminal Chief Felte (May 28, 2024) (Exhibit 111) (summarizing the FACE Act charges the Department of Justice had brought since January 2021). See Leif Le Mahieu, Biden‑Harris DOJ Seeks Jail Time for Pro‑Lifers Convicted Over Peaceful Protest, DAILY WIRE (Aug. 5, 2024), https://perma.cc/S2VT-8Z7P (last visited Feb. 27, 2026) (“[T]he Biden-Harris administration has brought a grand total of 25[] percent of all the FACE cases ever brought since its inception in 1994 in the last two years[.]”) (internal quotations omitted). 209 See Amended Complaint, United States v. Zastrow, No. 2:24-cv-00576 (M.D. Fl. Jun. 27, 2024) (seeking injunctive relief against C. Zastrow, Gallagher, and E. Zastrow); Complaint and Jury Demand, United States v. Citizens for a Pro-Life Society, Inc., No. 1:24-cv-00893 (N.D. Ohio May 20, 2024) (seeking injunctive relief against Handy, Fr. Moscinski, and Smith and highlighting their non-violent demonstrations throughout the country). 210 32 civil FACE Act cases in response to protests or destruction at pregnancy centers or houses of worship during the Biden administration. At the same time, the Biden DOJ largely ignored attacks on pro-life pregnancy resource centers, only charging five people for vandalism and attacks against these healthcare facilities. 211 Based on DOJ’s review of the related correspondence, it appears that CRT began following up on “allegations of criminal conduct involving abortion alternative facilities” in earnest after the significant public outcry and congressional response to Houck’s arrest. 212 Patel wrote about the Florida matter that, “[f]rom my perspective, I have a very strong interest in charging a Jane’s Revenge subject.” 213 In response to a concern about his bandwidth, Patel explained that “I definitely need to keep the new MDFL FACE matter bc it may be the first FACE case we bring with a pro-life victim.” 214 In preparation for the Criminal Chief’s upcoming meeting with DAG Monaco, Patel flagged that he was “glad to report that we are actively working … on three separate Jane’s incidents … in hopes of bringing charges soon.” 215 The Freestone indictment was unsealed on the first day of Houck’s FACE Act trial, January 23, 2023. 216 The three FACE Act prosecutions of destruction to pregnancy resource centers involved the following facts: Florida Attack: Between May and July 2022, Caleb Freestone, Amber Smith-Stewart, and Annarella Rivera engaged in a series of targeted attacks on pro-life pregnancy help centers in Florida,” spray painting the facilities with messages, including “’If abortions aren’t safe than niether [sic] are you,’ ‘YOUR TIME IS UP!!,’ ‘WE’RE COMING for U’ and ‘We are everywhere.’” 217 Below is a photo of one of the threatening messages left by defendants: 218 211 E-mail from Principal Deputy Chief Fitzgerald, to DAAG Moossy (Sept. 17, 2021) (Exhibit 155) (circulating a list of the “FACE-related cases” CRT has “done over the past 10 years”; none involved a house of worship or pregnancy resource center). 212 See E-mail from Patel, to Criminal Chief Felte (Oct. 17, 2022) (Exhibit 145). 213 E-mail from Patel, to Samantha Trepel (Oct. 3, 2022) (Exhibit 156). 214 See E-mail from Patel, to Gibson (Oct. 6, 2022) (Exhibit 157). 215 See E-mail from Patel, to Criminal Chief Felte (Oct. 17, 2022) (Exhibit 145). Compare Press Release, U.S. Dep’t of Just., Two Defendants Indicted for Civil Rights Conspiracy and FACE Act Offenses Targeting Pregnancy Resource Centers (Jan. 24, 2023), https://perma.cc/YV3M-6HXJ, with Minute Entry: Jury Trial Day 1, United States v. Houck, 2:22-cr-00323 (E.D. Pa. Jan. 24, 2023), dkt. no. 64. 216 Press Release, U.S. Dep’t of Just., Three Defendants Plead Guilty to a Civil Conspiracy Targeting Pregnancy Resource Centers (June 14, 2024), https://perma.cc/AH8X-FYGS. 217 218 Greg Wehner, 3 Charged in Attacking Florida Pro-Life Pregnancy Center Plead Guilty: DOJ, FOX NEWS (June 16, 2024), https://perma.cc/DM2T-B444. 33 Freestone, Smith-Stewart, and Rivera were charged with violating the FACE Act, and all three pleaded guilty. Freestone was sentenced to one year and a day in prison, and Smith-Stewart and Rivera each received sentences of 30 days in prison and 60 days in home detention. 219 Ohio Attack: On April 15, 2023, Whitney Durant vandalized “a reproductive health services clinic located in Bowling Green, Ohio, because the clinic offers pregnancy counseling, free pregnancy testing and ultrasounds, but not abortion services.” 220 Specifically, Durant spray painted the words: “LIARS,” “FAKE CLINIC,” “Fund Abortion,” “Abort God,” and “Jane’s Revenge.” 221 Below is a photo of Durant’s graffiti attack on the clinic. 222 Press Release, U.S. Dep’t of Just., Florida Man Sentenced for Civil Rights Conspiracy Targeting Pregnancy Resource Centers (Sept. 12, 2024), https://perma.cc/5EZU-XU9H. 219 Press Release, U.S. Attorney’s Off., N.D. Ohio, A Ohio Woman Sentenced for Violation of Freedom of Access to Clinic Entrances (FACE) Act Violation for Damaging Pregnancy Center (Apr. 12, 2024), https://perma.cc/2CNAGLJZ. 220 221 Id. Joe Bukuras, FACE Act Charges Brought Against College Student in Ohio Pregnancy Center Attack, CATHOLIC NEWS AGENCY (July 11, 2023), https://perma.cc/N59J-HCWQ. 222 34 DOJ charged Durant with a misdemeanor FACE Act violation. 223 Whitney pleaded guilty and was sentenced to two years of probation and a $2,000 dollar fine. 224 Texas Attack: On May 7, 2022, Ethan Skorick “intentionally damaged the property of pregnancy resource centers located in Denton, Texas,” by spray painting the following on the “clinics’ buildings, doors and security cameras:” “NOT A CLINIC,” “FORCED BIRTH IS MURDER,” and “PRO BIRTH [does not equal] PRO LIFE.” 225 Skorick pleaded guilty to a “misdemeanor charge under the” FACE Act. Skorick was sentenced to five years’ probation and ordered to pay $2,989.05 in restitution. 226 Notably, the FACE Act also prohibits interfering with access to houses of worship. During the Biden Administration, there were numerous violent attacks against religious institutions in connection with those organization’s pro-life views. 227 Indeed, in light of that violence, members of the U.S. Senate specifically requested that Attorney General Garland use the FACE Act to protect houses of worship. 228 Despite the increased hostility faced by houses of worship, the Biden DOJ did not pursue a single FACE Act case involving houses of worship during this time. Press Release, U.S. Attorney’s Off., N.D. Ohio, Bowling Green State University Student Charged with FACE Act Violation (July 5, 2023), https://perma.cc/9DZN-XPHN. 223 Press Release, U.S. Attorney’s Off., N.D. Ohio, Ohio Woman Sentenced for Violation of Freedom of Access to Clinic Entrances (FACE) Act Violation for Damaging Pregnancy Center (Apr. 12, 2024), https://perma.cc/2CNAGLJZ. 224 Press Release, U.S. Dep’t of Just., Texas Defendant Pleads Guilty to Freedom of Access to Clinic Entrances (FACE) Act Violation (Jan. 16, 2025), https://perma.cc/KPZ3-ZEVF. 225 226 Judgment in a Criminal Case, United States v. Skorick, No. 4:24-cr-00255 (E.D. Tex. May 28, 2025). Expressing the sense of the House of Representatives condemning the recent attacks on pro-life facilities, groups, and churches, H.R. Res. 1233, 117th Cong. (July 19, 2022), https://perma.cc/Q7YP-NL3G. 227 Letter from Sens. Michael S. Lee and Ted Cruz to Attorney General Merrick Garland (Sept. 23, 2022), available at https://perma.cc/6SM7-3HDM (pages 16-28). See also E-mail from Patel, to Criminal Chief Felte (Oct. 18, 2022), supra 30 n.197 (Exhibit 145). 228 35 VI. THE TRUMP ADMINISTRATION’S WORK TO RIGHT PRIOR WRONGS The Biden DOJ’s actions were wrong. The Trump Administration took immediate steps to restore the public’s confidence in the Department and to address the Biden DOJ’s unequal application of the FACE Act. On January 23, 2025, President Trump issued full and unconditional pardons 229 to numerous pro-life defendants, including: Lauren Handy Jonathan Darnel Paula Harlow Jean Marshall John Hinshaw Heather Idoni William Goodman Joan Bell Herb Geraghty Chester Gallagher Coleman Boyd Paul Vaughn Dennis Green Eva Edl Eva Zastrow James Zastrow Paul Place Joel Curry Justin Phillips Bevelyn Beatty Williams Calvin Zastrow Fr. Christopher Moscinski DOJ is working to restore these defendants’ civil rights that were curtailed as a result of their laterpardoned convictions. DOJ also recently settled claims stemming from a couple of these criminal prosecutions. 230 On January 24, 2025, the DOJ’s new leadership acknowledged that the Biden DOJ’s effort to enforce the FACE Act was not an “even-handed administration of justice,” issuing a memorandum to guide prosecutorial decisions under the FACE Act going forward: 231 [T]o ensure that federal law enforcement and prosecutorial resources are devoted to the most serious violations of federal law, future abortion-related FACE Act prosecutions and civil actions will be permitted only in extraordinary circumstances, or in cases presenting significant aggravating factors, such as death, serious bodily harm, or serious property damage. Cases not presenting significant aggravating factors can adequately be addressed under state or local law. Additionally, until further notice, no new abortion-related FACE Act actions— criminal or civil—will be permitted without authorization from the Assistant Attorney General for the Civil Rights Division. 232 229 Donald J. Trump, Executive Grant of Clemency (Jan. 23, 2025), https://perma.cc/2GJ9-L6Q7. See, e.g., Amended Joint Status Report of Parties, Houck v. United States, No. 25-1433 (3d Cir. Jan. 7, 2026). A stipulation has been negotiated with a family of impacted individuals and is awaiting judicial approval. 230 231 U.S. DEP’T OF JUST., OFFICE OF THE ASSOCIATE ATTORNEY GENERAL, FACE ACT CHARGING POLICY (Jan. 24, 2025), https://perma.cc/U7HK-37PT. Id. (directing CRT to dismiss, with prejudice, the following FACE Act cases: United States v. Connolly, No. 2:24cv-04467 (E.D. Penn.); United States v. Zastrow, et al., No. 2:24-cv-00576 (M.D. Fla.); United States v. Citizens for a Pro-Life Soc’y, et al., No. 1:24-cv-00893 (N.D. Ohio)). 232 36 The memorandum also directed CRT to “immediately dismiss, with prejudice,” three civil lawsuits against peaceful, pro-life demonstrators. These civil cases had involved several of the same pro-life activists that the Biden DOJ had monitored for years and criminally charged, including Calvin Zastrow, Chester Gallagher, Eva Zastrow, Lauren Handy, and Christopher Moscinski. CRT promptly dismissed United States v. Connolly, United States v. Zastrow, et al., and United States v. Citizens for a Pro-Life Society. DOJ has taken appropriate personnel action to address this report’s findings. This report does not disclose findings regarding internal misconduct investigations of any of the employees alleged to have been involved in the weaponization of the FACE Act. DOJ governs the conduct of its current employees through an internal disciplinary investigative system. Where appropriate, DOJ may refer current or former employees for criminal prosecution. Likewise, DOJ may refer current or former employees to the relevant bar association or highest judicial authority of the jurisdictions in which they are licensed to address compliance with applicable Rules of Professional Conduct. Here, internal referrals have been made as required by the Justice Manual. Going forward, CRT will pursue meritorious cases under the FACE Act, when the facts and law support civil or criminal action, including obstruction and threats toward pregnancy resource centers and houses of worship. For example, in February 2025, CRT filed a statement of interest supporting the plaintiff in Pollak v. Codepink Women for Peace, 233 the first time that DOJ applied the FACE Act to a place of worship despite frequently applying it to the alleged obstructions of abortion clinics. In this case, plaintiffs alleged that protestors terrorized Jewish congregants outside their synagogue, blocked access, trapped others inside, and even attacked some worshippers with bear spray. 234 DOJ argued that the plain language of the FACE Act prohibits these kinds of physical obstructions of places of worship. 235 DOJ is committed to prosecuting crime in a manner that is consistent with its mission “to uphold the rule of law, to keep our country safe, and to protect civil rights.” 236 DOJ must act with independence, impartiality, honesty, integrity, excellence, and respect, valuing differences in people and in ideas and treating everyone with fairness, dignity, and compassion. Should other affected individuals have concerns about prosecutions pursued against them, DOJ will assess their allegations without fear or favor. 233 Press Release, U.S. Dep’t of Just., Justice Department Files Statement of Interest Supporting Access to Places of Worship (Mar. 3, 2025), https://perma.cc/WS9P-H2QR. Statement of Interest of the United States of America, Pollak v. Codepink Women for Peace, No. 2:24-cv-06253 (C.D. Cal. Feb. 28, 2025), dkt. no. 119. 234 235 Id. 236 About DOJ, U.S. Dep’t of Just., https://www.justice.gov/about (last visited Jan. 7, 2026). 37 EXHIBIT 001 AMERICAN CENTER _/i11· LAW S, J Us TICE l\ugu'lt 8. 2022 J\llorncy General Mt.:rril'k B. C,urlamJ l 1.S. Department uf Justice 950 Penn�ylvnniu /\ \'e .. N � Washington. DC ::!.\)530-000 l R£: "Executive Order on Prokctin� ,1\(•cess to Reproductivl' Healthcare St'rVice:-" Dl'Ur Attorney ( ,enaal <.,url.rnd: Thl' lt' 11luw111g letter is 1111 bdrnll ol' the _1\n1eric:.rn Center for La\.\ &. Jusucl' t/\CU) and ·n and supnort proli k Pn:gnancy Re$ourtc Centers across nver 236.0UO nf its memha:-; who ,aluc 1 tht: �ountry. Tht> Americ..tn ( '1:ntt'r !'or Lm & Justice- ("/\CL.I") i), an mganizat1on Jcdical!:d to the defense or CllnstiLulillnal libenie:-- -.ccure sanctit) ol' human life-. Counsel for the ,\CU ha,'e prescnteJ l'Xf)t.'rt Lestinmn� bdurc stall' and k<.kral leg1slativ1: bnral Ul'!,!Umcnt. repr�sented parties. and suhmittcd umit:ll'.1.:uriac hrit:1:-; before thc Supn:ml'. Cnun \lfthc l 1nitl'd St.:ttt:s am1 numeroL1:-. state and teJcnil t:11urt!" in l.'.ase� involving a ,arict� ut' isi-ucs. including Lhc right to life .'ice, e,g, f'/ew'{(II/ I l.i-.1 v1,1lt!ll Aug -I �112�1 ud1 111w 111 ti Ith' ·,lllJI 1h1.-.�h11tJtl\\11 I. I NTRODU TI ON On July 8. 20 2. President B iden i ued an Ex uti e Ord r on Protecting ccess to Reproductive Healthc re erv ices. Wh i le the entire ecutive Ord r is of concern to the A LJ and its member . of parti u)ar concern are the p rtions of the E ec utive Order that call on the ltomey eneraJ to first. addre potential hei ghte n d safety and ecurity risks related to the provi ion of reproductiv heal thcare , ervice [ .] [T}he tt m y Gen ral and the ecretary of Homeland Security shal l con ider acti ns. as appropriate and consistent with appl i cable law, to ensure the safet of patient . provider , and third parties, and to protect the ecurity of cl inics ( i nc lud ing mobi le clinjcs). pharmacies. and other enti t i provid ing. dispensi ng. or delivering reproducti e and rel ated hea lthcare erv1 es. 2 econd. [t]he er tary of Health and H uman ·ervices shal l, in con u ltation with the ttorne General and the Chair of the T . con ·ider oplions to addres. deceptive or raudulent practices related lo reproductive healthcare servke. . including onl i ne. and ro pr tect access to accurate infi rmation.(3 And fi nal ly, The Secretary of H ealth and Human rvices and the Director of the Oend r Po licy ouncil shall e tabli h and co-chai r an Interagen Task Force on R productive Healthcare Ace Task Force). Additional member shall incl ude the Attorne Genera l and the heads of other agencie as d term ined by the ecretary of Health and Human ervice and the Di rector of the ender Po l i y oun i i . The Task Force shall work to iden tify and coordinate activitje to protect and trengthen access to essent ial reprod uctive heal thcare ervices. In addition, the Task Force shal J coordinate Federal imeragenc polic makinK, program development. and o utreach effort.,; to address barriers that individual. and entities may face in seeking and pro idin reprodu tive heulth are sen(; ·es .'1 2 Presiden l J oseph R. Biden, J r., xecut ive Order on Protecting Access to Reproductive 1-teallhcare rvices (J uly 8. 2022). hnp ://w w .white house.gov/briefing-ro m/pres1dential-act ions/2022/07/08/execut i ve-order-on-protectinga ce -to-repr duct ive- healthcare- ervice [here i na fter xec utive Order] . , fd, ( emphasi added , 4 Id. (emphasi added). ') I I. . MMARY OF MAI N O CE R ' Recentl y . Pre gnanc y R sour e nters. also known as Cri sis Preg nanc y enter . have been under increasi n g attack. both by p ro-aborti on acti v ist who have fir bomb d and vandal i zed Pre g nanc Re our e Centers across the nat ion 5 with ut an y condemnation from Presid nt Biden, your Dep art ment. other p ro-abortion su pporter . or by p ro-abortio n pol ilicians or state nomey s eneral. P resident B iden 1 s Executi ve rder poses yet another threat to Pre mancy R sourc Centers b y cal l i n g on the ecretary of l--lealth and H uman ervices, the U.S. Attorne. General, and the Chai r of the FTC to "addre de eptive or fraudulen t p ractices rel ated to re p roduct ive healthcare servi ces." 6 As we have detailed below. this lan gua ge is freq uent! used in direct referenc to P re g nanc y Resource n ter . and it is the concern of the AC LJ that the admini trat ive officials will use the lan g uage in the ecut i e Order as a bas is to j usti fy potentiall y mcon tituti onal targetin g of Pr g nanc y e o urce enter for �nsor hi p and for el i m ination. The LJ oppo e any such action, and stand read , to ri g rousl de fend Pregnancy Re ource enters across the country . II I. IMPORT N E OF PREG ANCY RE. OlJ RCE CE TER R I G H T TO PROT ECT I ON AND T H E I R ln direct res pon e to President B i de n ' s xecu ti ve Order. on Jul y 29, 2022. you deli v ered remark stat in g amon g other th i n g �. that: "The Ju tic De partment is working relentle. . I 1 • • • (and ) has a tremendous respon ·ibility to do everything in our power to prute ·t access to reproductiv services. That is what we Intend to do." 1 Moreover. y ou stated that "th'e De p artment will cont inue to eofor the FACE Act and p rotec t hea lthca re p ro id er and indi id u a l eek i ng re p roductiv hea lth ervi c . . . .'' 11 F inal l y , you stated that " [ t] he Justic De partm m's R produ t i ve R i g hts Task Force . . . is vigilant/_ monitoring state laws and e,�forc:ement uc1 ion.\· 10 ensure thal states do nol in ringe upon these rights."Q As is defi ned in Pre i dent B iden 's xecuti e Order, '' ' reproducti healthcare s1::rvices· means medical. surgical . c:otm • ling, or referrul erl'ices relating to the human repr ductive ystem, including ·ervice. relating to pregnuncr or the tenn i nation of a pregnancy :• 1 0 , Emma hon. New York Pm-life Pn•g11an9 1 Center 11/lt!gedly 'Firehombed-' by left- Wing Group, Fux N EWS lnwst,garion larmched (Jun . 7, 2022, 3 ·5 1 PM ), lntp- :l/www . foxnew- .com/u /pro- L i le-pregnancy- (j rcbo mbed- le ft­ w i ng; Jessica hasmur, .4 t least 5 Pro-life Pregmmcy Centers Vandali:ed Wilhm a Week of COTUS p,mon Leak., Fox N EWS (May 1 1 , 2022, I :37 PM), hn ps: 1/w w . foxnews.cow po l itics/5-pro-l i fe-pregnancy-cente�­ vandalized- cow - leak " xe uti ve Order. supra note-:! 7 Me1Tick B. Gar land, U .S. Att' y Gen .. Remarks at Lhe W h ite House Con veni ng of Lawyers in Defense or Re product ive Rights (July 29, 2022), https://www .j u t ice .govlopa/speech/attomey-general-merr ick -1>-garland­ de l i ver -remarks-whi1e-hou e-con en ing-law ers-de fense ( emphasis added) lhere inaller tatemenr by AG Garland \ . 11 Id. ( emphasis added) 9 Id. (emphasi added). w [xe utt e Order. supra note 2 ( emphasis adde l i rst, while Pr ident Biden, the ecret ry of Health and Human erv ic . and your office have made it quite clear that the overarching purpose of the Executive Order is to advane abortion and access to abortjon, the ACU would like to take this opportunil to poi m out that prolife Pr gnancy Re ·ource C nters clearly fall under the Exe ut ive rder's definition of ··reproducti e healthcare serv ice .'' Con equent ly, the Depanment of J ustice should ensure that Pregnanc Re ource Centers are i nc l uded as part of the Department' s enforcement of the FAC E Act and provide protection to those faciJ i ties as well as do anythi ng in its po er to bring to justice those who have vandal ized and threatened Pre mancy R source enters across the c untry.'1 1 Pregnanc Resource enter play a criticaJ role in pro iding choice to women experiencing unplanned pregnancies, such as the support nece sary for ke ping the baby, adoption etc ., that extend wel l beyond the one option that abortion clinics provide for women - end ing the life of their un born child. As we d tailed in our brief before the u preme Court in Li, ingwe/1 Med. /inic, Inc, v. Becerra. 1 3 8 S. Ct. 270 1 (20 1 8), Pregnancy Re ource Center provide es entiaJ and profe sional erv ice at no or. on occa ion. nom i nal cost, such as: "pregnancy opti n ed ucation and consultation; pregnancy te t ing and veri fication; lim ited bstetri cal ultra ound ; Tl/ TD testi ng, education. and treatment; past ab rtion healing retreats: community education pre ntations; and materi al support. "'1 2 Other ervic PregnW1c Re ource ent r pr i de ··help[l women deal with unpl anned pregnanci s by o fferi ng. free of charge. a variety of edu tional. medical. and material resources. i n l uding ultrasounds. counsel ing and emotiona l uppo rt, and ma1ernity and bab • items." 1 3 I n fact, Pregnancy Resource enter'· pro id free or nom inal cost assi stance t o mi Iii n o f women ann ual ly, including hundreds o f thousand of free ultra unds each year (over 48 .000 i n 20 1 9) along with medical erv ices, education. and referraJ . 1 4 In 20 1 9. over I 0.000 licensed med ica l profess ional ser ed as paid or vo l unt er worker in 2,700 Pregnancy Resource Center across the nited tate .'1 5 Thousand more pc pie serve voluntarily at Pregnancy Resource enters on an annua] basis. Pregnanc Resource enters save taxpay r ountJe m i J l ions of dol lar each year, again becaus many of the'. r ices that they provide for free-through the work of vo lunteer and the upport of donors-w uJd lherwis have to be provided by go er nm nt agencie through publicly funded program .' 1 6 tatement by AG Garland, supra note 7. Petition for \ rit of ertiorari. Livingwefl Med Clinic. Inc v Becerra. 1 3 8 S . Ct . 270 I (20 1 8), 4. avai lable at http;/fmed ia.aclj . org.lpd f/L I v ing- Wel l-Pel ii ion- Fina 1-w o- App _ Reda ted. pdf. 11 11 I] 14 Jd. at 6. Fac.·1 Sheet: Pregnancy Center - Serwng Women and Suwng Lives (2020 t11dy}. CHAR LOTT-· LOZIER lN. 1 m /TE (July 202 1 ). https ://s27 89.pcdn. o/wp-conten upload /202 1 /07 /20::!0-f'regnancy- enters-Fact- heet_FINA L7 .23 .2-1-.pdf , , Id. 1 1' Id 4 P regnancy Resource ent �r pr tde invaluabl infi rmati on and res urces that help ensure that a woman is fully aware of all the facts and options avai I able to her - to help inform her de is ion and tru ly give her 1..'hoices� includi ng the fact that abortion is intended to pennanen t ly end the life of an un born ch i ld. an act that is e, tr me l grave, groes me, and i rreve rsible. Thu , a woman's decision should be ful ly i n formed. and hould be made only after areful co n ideration of all the facts . One opti n does not constitute choic . and. th refore. Pregnancy Re ource enters play a v ital role in prov id i ng the al temati es to the only opt ion pushed by abortion l i n i cs. Moreover, Pregnancy Re ource enters pn vide material as istance and upport bey ond merely ·on ultation or medical serv i e . As such, we respectfu l ly request that Pregnancy Re ource enter . their healthcare v orkers and pati ent b e pro ided the same " igilant protection that the Department of Justice is dedicated to pro id ing abortion I inic and those women e ing abortion i n the week and mon th ahead . IV. POTENT I A L TARG T I N C OF PREG ANCY RE OU R FOR CE OR H I P A N D EL l M J ATI O CENT ru econd. the CLJ finds the language of the ., ec u i e Order directing action lo be taken gurdin 1 ··deceptive or fraudul nt pract ices·· of great concern not only because of current and extreme!, charged political rhetori<.: regard ing Pr gnancy Resource enter . but because of the hi tory pro-abortion go ernments have of government overr ach that has re u lted in the abri dgement of the con st ituti onal rights of Pregnanc Reso ur e ·eaters . On J une 1 7. 2022 pro-abortion mern b r o f ongre sent a letter to the Chief E, ecutive flicer of oogle. In t hat letter the Members of ongres referred to ·•cri i pregnancy cen t rs." or "pregnancy resou rce centers." as ''fake c l i nic .'' 1 7 The letter goes on to can on Google to. inter alia, ..l i mi t the appearance of'. . fake cl i nics or -cal led 'crisis pregnancy emer ' in G gle search results. oogl Ads, and on Go gle Maps . . ' 1 8 The tlice of L titia James, Att rney en ral of the State of New York, wrote a im i lar letter to General oun I for ogl e. tating: [O]rgan izat ion known as ··crisis pr gnancy enter ··· (CPCs) are not heal th care pro v i der . . . C P exist solel to intercept and di uade pregnant people fro m making fu l ly ·nfo rmcd deci " ion about thei r healt hcare such as the cho ice to obta in an ab rlion . I n luding these organizations in a list for an ind i idual eeki ng abortion services is an gerou and mi leading. . . For e amp! . a oogl Map. earch for .. bo rtion B i nghamto n. N Y'" lists several crisis pregnan,J1 cemer.,· mch m Life Choic -� Center and Women 's Life . r 1 i ·e • 1,,1/ ng with legitimate health 1 1 Letter from M mber of ongress to Sundar Pichai, Chief . ecu t i e Officer of oogle ( June 1 7. 2022 ), awJ,/ahlt' 21 http :/ 1 w\ . warner. e n ate.govlpub hc l_cache1 fi les/ 5/6/56Q8 724 -cc0d-J2 fo-bbb6b0 5e4 n b4564/26F26B B28 4 1 042A 793 1 EE 'iR " 8DF.0R ,anu-abor1ion- lc11cr-10-goo • lc-fina l .pdf. IK Id, care p ro iders who offer a borti n and ab rt ion coun l ing . . . it is i mper tiv that p re gn ant peo p l are rece i i ng a u rate i n i rmat ion and are able to obtai n the m dical services they need eflicientl and with m i n i mal n fusion .-1 atlahle al hnps://ag. ny.gov/. ite. defaul fi les/2 0::12.06.28_-1etter_-to__google _-re cpcs.pd f (cmpha 1s added ). 10 Greg Price ( @greg-_price 1 1 }, TWJ'ITER (July 1 2. 2022. 4:4-1 PM ). https://twitter.com/greg-_-pri e 1 1 /status/ 1 546957961 4 3Q969280. 1 '· Kate el ig. Eli=abeth Warren Coils for Action Aga111sr 'Crisis Pregnancy Centers-· ,n Walce of upreme Co11rl lh•erhirnin Roe (June 29 202- ), ht1 ps;/fwW\ . msn .com/en- us/news/poli1 ics/el izabe1h -warrcn-calls- for-ac1 ion­ again ·1 -cri sis•pregnancy-centers- i n-wake-of- upreme-court-overtunung-ro ar-AAZOwK6 . .u RNC Research (@ R CResearch l. Twr nu (July 6, 2022, 1 1 :39 A M ). https://tw itter.co m/RNCResearch/statusl 1 544 7075 I I 906930690?s= 20&1= 1um Dj tgeo BXV KCh V lo2Zjg. 1 ' l sabeJ B ro, n . enator £/i.=alie1h Warren Calls/or Crisis Pregnonq· Centers to be Shut Down. Tt lR NIN P INT U A, https.1/w ww .tpu. a,comi l ive/senator-tl iz.abeth- , arrcn-ca l ls-for-crisis-pregmm . -ce111ers-1 -be-shut-down (las, visited July 2 1 . 2022). 6 alifomia permanent l y blo ked the State of al i fomia from iolating the ri ghts of Pregnan y Resource encers as g uar anteed under the First mendment of the on tituti n . It is hereby ORDE RE D that Defendant . a ier Becerra. in his offi cial capacit as the ttome y G eneral of al i fom ia. shal l be permanentl y nj ined from enforcin g the Re p roducti ve FACT Act, ali fornia Health and fer I Code ection 1 23470, et seq . ( "the Act" lt is further ORD D that j ud g ment is entered in favor of P lai nti ffs and again t D ti ndanl on Plaintiff ' claim under the free peech cl ause of the First mendment. 24 ln New York . tbe ACLJ ucces fu ll y sued on behal f of two or 1 anization that run Preg nan y Re ource enter in New York Cit y . Evergreen Ass ·n. v. City of New York. 140 F. 3d 23 3 ( 2d C ir. 20 1 4 ) . In that case. the . econd ircu i t con ·1dered New York Ci ty 's mi g uided ttern p t to re g ulate the centers on the same p rete t as that appearin g in the current Executive Order, i.e. trum ped u p , p olit ical l y mot iv ated char e of "dece pti e p ract i ces." The Court held that by req uirin g Pre g nanc Resource ·enter to d isclo e at the be g i nn_in g of contact with po t ntial c lient whether they p rovided re ferrals for abortion . emergenc y contrace p tion or p renatal care and to di sc lose that the New York City De partmt:nt of Health and Mental H yg iene en uraged p re g nant women to con ult w ith a l i censed pro ider was verl burdensome in iolat ion of the First Am endment . V. CO L USI ON The ACLJ g reatl al ue and app rec iates the im ponan t role of Preg nanc Re ource em r m provi d in g health are, c unsel i n g , and m ateri al resources and u pport. am ng other thin g . to women. babies. and fam ihe across the n i ted tales. N ot onl y is this work itall im portant, it i s p rotected under the law, as we have ucct: d ed in esta blish in g in liti gat ion on more than one occa ion. Because of the ACLJ ' s concern that Pre idem Biden· s el:utive Order may be i nte rp reted in a way that cou l d lead to' g ernment overreach and an unco nstitutional targelin g of Pre gnanc y Resource enters, we will be I 1 . m nit rin g the re p ns. recommendation , and trate gies that the you, the nomey enera l. and the De part ment of J ustice' s Re rr ducti e Ri ,hts Task Force de elop and im p lement in fu l fil lment of the � x ec uti ve Order. The ACLJ will al o be prepared lo i mmt:di tely chat l nge in court any uidan e. order. or oth r form of regu lation. that the A Ord Re g nrd i n • Permanent In j unct i on . Li in g we l l Med C l inic . I n c v. R� erra, Nov. 26. 20 1 8 . 1 :-1-5-rv-(M Q J Q ­ J S W. htt p ://medm. ac ij . org/ pdfl L1 vin g ell- ourt- rder. pdf. 0 7 Department of Justice. or any other administrative department. promulgates that constitutes an abridgement of the rights of Pregnancy Resource Centers. Sincerely. �frW Jordan Sekulow ExecLHive Director American Center for Law & Justice �Ce Heil Senior Counsel American Center for Law & Justice Olivia F. Summers Associate Counsel for Public Policy American Center for Law & Justice 8 EXHIBIT 002 From: "Patel, Sanjay (CRT)'' To: "Felte, James (CRT)" Cc: "Fitzgerald, Paige (CRT)" Subject: RE: ECATS- Letter from Jordan Sekulow dtd 8/8/2022 Date: Wed, 1 7 Aug 2022 l 7:05 :47 -0400 Importance: Normal I've never heard of them. I'll get some research done and reach out to them. SP From: Felte, James (CRT) � Sent: Wednesday, August 17, 2022 4:58 PM io: Patel, Sanjay (CRT) � Cc: Fitzgerald, Paige (CRT) Subject: RE: ECATS-Letter from Jordan Sekulow dtd 8/8/2022 I was not aware of them and I'm assuming that we haven't reached out to them, correct? From: Felte1 James (CRT) <> Sent: Wednesday, August 17, 2022 4:57 PM To; Patel, Sanjay (CRT) � Cc: Fitzgerald, Paige (CRT) Subject: FW: ECATS- Letter from Jordan Sekulow dtd 8/8/2022 Sanjay, Feel free to reach out to Gamondi for any intern help you need on this. Thanks, Jim From: Moossy, Robert (CRT) Sent: Wednesday, August 17, 2022 4:54 PM To: Felte, James (CRT)�; Fitzgerald, Paige (CRT) � Subject: RE: ECATS- Letter from Jordan Sekulow dtd 8/8/2022 ; Patel, Sanjay (CRT) A quick google search found this, have we reached out to them? Maybe an intern could do some on-line searching? I'd very much like to get this TF meeting done by early September. �(care-net.org) "Founded in 1 975, Care Net is a 501 (c)3 nonprofit organization that supports one ofthe largest networks of pregnancy centers in North America and runs the nation's only rea 1-time call center providing pregnancy decision coaching.'' Since 2008. Care Net has put our mission and vision mto practrt:e and saved n10re than 823,000 babies from abo11ion by: . Supporting one of the largest networks of pregnancy centers in North America. With more than 1 , 100 affiliates and 30,000 volunteers, we provide immediate support to women and men considering abortion so they can choose life. Last year alone, our pregnancy centers provided clients with 1nore than $62 million in free services. From: Felte, James (CRT) Sent: Wednesday, August 17, 2022 11:16 AM To: Moossy, Robert (CRT) Subject: FW: ECATS From Sanjay below From: Patel, Sanjay (CRT)n._ Sent: Wednesday, August 17, 2022 10:14 AM To: Felte, James (CRT)n._ Cc: Fitzgerald, Paige (CRT) Subject: RE: ECATS- Letter from Jordan Sekulow dtd 8/8/2022 FBI is communicating with the Conference of Bishops to set up a call. (The Bishops would not respond timely to calls and emails from me). I discussed with FBI the urgency of scheduling the call during our last TF meeting (Aug 5) and I've followed up with FBI twice since then. Nothing on the books yet, but hope to have an answer from FBI before the end of this week. From: Felte, James (CRT)n._ Sent: Wednesday, August 17, 2022 10:08 AM To: Patel, Sanjay (CRT)n._ Cc: Fitzgerald, Paige (CRT) Subject: FW: ECATS You Sanjay, I know Robert's question pertains to one of the items on which you plan to brief the AAG. From the draft game plan agenda you sent yesterday, I know the date for such a meeting with pro-life groups has not yet been scheduled. Do you have an idea as to roughly when such a meeting may take place? Thanks, Jim From: Moossy, Robert (CRT) Sent: Tuesday, August 16, 2022 4:33 PM To: Patel, Sanjay (CRT)n._; Felte, James (CRT)n._; Fitzgerald, Paige (CRT) ; Rosenbaum, Steven (CRT) ; Cowall, Laura (CRT) Subject: FW: ECATS- Letter from Jordan Sekulow dtd 8/8/2022 Please see attached letter. Where are we on the FACE TF meeting for pro-life clinics? From: Weiner1 Robert (CRT) Sent: Tuesday, August 16, 2022 4:30 PM To: Moossy, Robert (CRT) Subject: FW: ECATS- Letter from Jordan Sekulow dtd 8/8/2022 Of interest From: Morse, Jodie (OASG) � Sent: Tuesday, August 16, 2022 4:21 PM ; Bond, Rebecca (CRT) To: Sooknanan, Sparkle (OASG} Weiner, Robert (CRT) Subject: FW: ECATS- Letter from Jordan Sekulow dtd 8/8/2022 Please see attached. From: Maltby, Jeremy (ODAG) Sent: Tuesday, August 16, 2022 12:21 PM To: Morse, Jodie (OASG) � Subject: Fwd: ECATS- Letter from Jordan Sekulow dtd 8/8/2022 This is the letter that I mentioned Sent from my iPhone Begin forwarded message: From: "Thomas, Tina M. (ODAG)" Date: August 15, 2022 at 10:59:56 PM GMT+2 To: ODAG INFO COPIES , "Braden, Myesha (ODAG)" Cc: "Chandler, Adam (ODAG)" "Maltby, Jeremy (ODAG)" Subject: RE: ECATS- Letter from Jordan Sekulow dtd 8/8/2022 1 + Jeremy Tina M. Thomas Deputy Chief of Staff and Counsel Office of the Deputy Attorney General U.S. Department of Justice (o I (.m From: ODAG INFO COPIES Sent: Monday, August 15, 2022 4:53 PM To: Braden, Myesha (ODAG) Cc: Thomas, Tina M. (ODAG) ; Chandler, Adam (ODAG) Subject: FW: ECATS Letter from Jordan Sekulow dtd 8/8/2022 From: Nfckens, Rayna (JMD) > Sent: Friday, August 12, 2022 4:42 PM >; ODAG INFO COPIES > mallto Subject: ECATS- Letter from Jorda, n Sekulow dtd 8/8/2022 Please see attached documehts for Info. Thank you, Rayna Nickens Correspondence Management Analyst Correspondence and Communications Control Team Departmental El To: "Patel, Sanjay (CRT)" Cc: Roland Warren �care-net.org>, Brin Forsythe �care-net.erg>, Christine Quann �car e -net.erg> Subject: Re: [EXTERNAL] Fwd'. Outreach meeting request Date: Fri, 09 Sep 2022 I 5 : I 1 :53 -0400 Importance: Normal Hello Sanjay. The best perso11 to contact at Heartbeat is Jor-El Godsey, their president, atn�heartbeatinLernaLi0nal.org. The cunt11c1 at NLFLA is their 11resident, Tom Gle�sner alI�«nifla.mg . We do Dot bave a good contact nt J3i.Jthright. Vince Vincent DiCaro On Thu. Sep 8, 2022 at 3: 19 PM Patel, Sanjay (CRT) wrote: Good afternoon Care Net team 1 want to thank you for your time last week. I really appreciate you for c01mecti.ng with me, and for assisting with my Task Force's outreach efforts. I will c i rcle back with you soon about attending an upcoming Task Force meeting, and about the FACE Act tra.ining/infonnation session you requested for your affiliates. ln the meanwhile, can you share with me the contacts for the other orgaJ1izations like yours with whom l can similarly connect with about outreach? I remember Vince mentioned BirthRight and Heartbeat as examples? Thanks again! Sanjay From: Roland Warren �g> Sent: Friday, August 1 9, 2022 4:46 PM To: Patel, Sanjay (CRT) Cc: Vince DiCaro �care-net.org>; Erin Forsythe �care-1-1et.org>; Christine Quann �g> Sub,ject: [EXTERNAL] Fwd: Outreach meeting request Mr. Patel, Thank you for contacting Care Net We would be very interested in having a conversation with yoLt about tbe violence and threats to Care Net and its affiliated pregnancy centers. Please advise re next steps. Best regards, Roland Rolanc:1 C. Warren V -- F·-- E· �rg W. care-net.erg ---------- Fotwarded message ------- From: Patel, Sanjay (CRT) Date: Wed, Aug 17, 2022 at 6:05 PM Su� 9utreacb meet�e9uest To:�care-ncl.org �carc-net.or0> CC: Taskforce, Clinicviolence (CRT) Dear Care Net personnel- [ would like to schedule a meeting with a manager from your organization to explore outreach efforts by the U.S. Department of Justice with pregnancy centers that are being targeted by i.ncidents of c1ime. A H reproductive health care providets, patients, and facilities are protected by federal laws, inclurung the FACE Act ( 1 8 USC 248). from violence, threats, obstruction, and damage. Please contact me by email or phone to further discuss. [ look forward to hearing back from a Care Net official. Regards, Sanjay Patel Sanjay Patel DirectoT National Task Force on Violence Against Reproductive Health Care Providers Criminal Section Civil Rights Division U.S. Department of Justice Washington, D . C. Care Net Team EXHIBIT 004 Event: Monthly Cli nic Violence Task Force meeting Start Date: 2022-10-07 1 1 :00:00 -0400 End Date: 2022-1 0-07 1 2:00:00 -0400 Organizer: Patel, Sanjay (CRT) Location: SWITCHING TO ZOOM Class: X-PERSONAL Date Created: 2024-1 1 -07 09:09:49 -0500 Date Modified: 2024-101 -07 09:09:49 -0500 Priority: 5 DTSTAMP: 2022-100-07 07:107:54 -0400 Taskforce, • , Ta Weiner, Robe Attach: TF_meeting_0agenda_1 0-7-22.docx AJarm: Display the following message 1 Sm before start I Reminder Good morning TF members, Agenda attached for our 11am this morning. Thanks, Sahjah TF membersiSimilar to our outreach efforts to the abortion provider community following the SCt's Dobbs decision, I have invited officials from three pro-life NGOs to attend our meeting Oct 7, T) Many pro-life pregnancy centers across the country have been targeted by pro-abortion extremists, including the Jane's Revenge movement. I'd like: to let these stakeholders know that their clinics are also protected by federal law from violence/threats/obstruction. The organizations I have invited lnclude: Care Net, Nat'! Institute of Family and Life Advocates (NIFLA), and Heartbeat International. These three NGOs likely represent approx. 85% of all life-affirming providers. I'm switching our meeting from Teams to Zoom (see below). I will send around an agenda next week, and may call upon some of you to speak (I'll let you know in advance). Thanks, SP Sanjay Patel (USDOJ) is inviting you to a scheduled ZoomGov meeting. Topic: Clinic Violence Task Force meeting Time: Oct 7, 2022 11:00 AM Eastern Time (US and Canada) Joln ZoomGov Meeting Meeting I D One tap mobile San Jose) (New York) Dial by your location Meeting ID: Find your local number: Joln by SIP Join by H.323 Task Force members We are due for a monthly meeting. Please forward this invitation to other necessary attendees from your components. I will circulate an agenda early in the week prior to the meeting. Please let me know if you have anything that needs to be added. Thank you, Sanjay Microsoft Teams meeting Join on your computer or mobile app Or call in (audio only) Phone Conference ID: I Find a local number Reset PIN Learn More I Meeting..QP-tions EXHIBIT 005 AAG talkers for Clinic Violence 1F meeting with pro-life NGOs (1 • • • • • • • • • • • on/22) Thank you for being here today_ You all are providing important work, and I am grateful that you made time to join today's meeting We convened the call to descnbe to this group of leaders and advocates the Department's authority to enforce the Freedom of Access to Clinic Entrances Act {"FACE Act"). The FACE Act makes it a crime and a civil law violation to injure. , intimidate, or interfere with a person seeking to obtain or provide reproductive health services_ The FACE act empowers the Justice Department to prosecute criminal violations of the ACT, and allows private parties, the State Attorney Generals and the Justice Department to bnng civil suits under the Act for injunctive relief, damages, and penalties_ Reproductive health .services covered under the Act includes providers of life{-affirming . The FACE Act protects your patients, providers and facilities (such as the thousands of pregnancy centers across the country) from violence and obstruction. Violence, threats of violence, physical obstruction, or property damage in violation of the FACE Act will not be tolerated by this Administration_ We are committed to ensuring that the rights of our nation's reproductive health care providers are fully enforced and protected. My hope is that you all can carry this reminder back to your colleagues and community partners_ We encourage you to reach out to your clinics and health centers around the cOlllltry to reassure them of our support. During this call we will provide you with resources that you can use to educate your providers aud clinics about the FACE Act. [ Can we share the FACE resource book, any downside?] The Civil Rights Division stands ready to enforce the FACE Act, through criminal and civil remedies. We do this work in close partnership with officers of the United States Attorney's Offices and the FBI in Districts around the country_ Additional federal law enforcement partners including A1F, USMS, and USPIS [spell out]_ Criminal FACE penalties include imprisonment and fines. The severity of the punishment depends upon the nature of the offense and whether or not a person is a repeat offender. The Justice Deparlment stands ready to prosecute anyone who is found to have criminally targeted a pregnancy center because of the life affinning care provided_ On the civil side, the Department has filed multiple FACE actions in more than a dozen states, and there are on-going investigations in other states_ The Justice Department has obtained injunctive relief and restraining orders under the FACE Act, and is actively investigating incidents at several life affirming care centers, including incidents where the phrase "Jane's Revengen was graffitied on clinic walls. Reporting a potential FACE Act violation is critically important to the Department's ability to hold offenders accountable. To report an offense targeting any of your affiliates, please let them know to notify their local FBI or USAO_ This Task Force can assist you with identifying who/where, your affiliates should report incidents to. You will learn more about that today. Additionally, you can reach out to Sanj ay, with whom I know your organizations have been in contact with. Before I close, I welcome the opportunity to hear from you - the reports of what you are seeing on the ground, ideas for ways the Department can identify new cases, your recommendations for how we can amplify the federal government' s coordination on these issues, and more_ I cannot promise that we will be able to undertake every action you suggest, but I can assure you that we will listen and do our best to act swiftly and appropriately_ Thank you in advance for your candor and your time_ Cammmted [MR(l): Kristen, this i5 the worlc the groups use. Query whether we just say ""indudes all reproductive health services dinics, induding those that you represent.• Moossy, Robert (CRT) 2022-10--04 12 :09:00 EXHIBIT 006 TPs re: CRTs (CRM) pro-life FACE work (as of9-!4-22) • TPs (public): o The Department ofJustice enforces the Freedom of Access to Clinic Entrances (FACE) Act, which prohibits anyone from obstmcting access to reproductive health services through violence, tlu-cats of violence, or property damage. o Despite the Suprerne Comt's decision in Dobbs v. Jackson Women ·s Health Organization, which eliminated the Constitutional right to abortions, the FACE Act continues to protect reproductive health rights. Under Dobbs, the Supreme Court allowed states to regulate abortion care and pregnancy termination services. The Dobbs decision does nol affect the Deprutmenl 's enforcement obligations under the FACE Act to protect reproductive healthcare providers, patients, and facilities across the country, including in those states where abortion care remains legal. o The FACE Act is not about ab01tions. lt protects persons seeking or providing-any type ofreproductive health care, including infertility treatment. prenatal care, breast cancer screening, pregnancy counseling services, vasectomies, and abortion services. Therefore. the fACE Act is content neutral because it protects facilities providing life affirming care through termination services. • Historical Prosecutions (public): o Historically, incidents targeting pro-life or life affirming pregnancy centers have rarely occurred, and even fewer have been reported to federal law enforcement authorities. o Neve11heless, one case has been prosecuted by DOJ under FACE re: attack against a pro­ life pregnancy center • U.S. v. Mathi:rnn (EDWA 95-cr-085) • ti indicted for making series of threatening calls to pro-life counseling centers. • Ii threatened he bad a gun and would kill office workeTs. • I':!. charged with FACE Act and § 875 violations • Ii PG to FACE Act offense and sentenced to 5 yrs probation with 30 days home detention • Case cited in published 2d opinion U.S. v. Weslin, 1 56 F.3d 292, 296- 97 (2d Cir. 1 998) o Thus, "pro-choice" protestors as well as "pro-l1fe" protesrors come within the tenns of the statute. It applies to those who would *297 ioterfore with the provision of cotmseling at a clinic in which patients at'e encouraged not to have abortions. Not. only are such persons subject to prosecution in theory, but at least one pro-choice activist has. in fact, been prosecuted for violating FACE. See United States v. Mathison, CR-95-085-FVS (E.D.Wa. 1995) (defendant prosecuted for threatening workers at pro-life faciJitjes). • More TPs ( public): o DO.I will investigate all incidents of force, threats of force, obstruction, and propercy damage that interferes with reprodt1ctive health care. o DOJ will enforce the FACE Act wnere appropriate, regardl�ss of viewpoint. o DOJ is aware of the uptick nation-wide in potentially criminal incjdents targeting life affirming pregnancy centers following the Set's Dobhs decis-1on. o These incitlents have Largely involved incidents of vandalism and properly damage targeting facilities. • Examples of the vandalism include sptay painted messages such as: • "if abortions aren't safe, then you aren't eitherr • "forced birth i s murder" • '·pro birth does not equal pro life" • ''nol a clinic'' or "fake clinic" 1 ·Jane's Revenge'' • • Examples of damage include: • Broken windows • Fire damage • Red paint left on building doors/walls/windows • IJ1cidents have occurred nation-wide • First reported incident was early May 2022 o Generally, these incidents are attributed to a gronp calling ilself ''Jane's Revenge" (the group's name is believed to be a reference to the l 970's era Jane Collective, an underground service that provided abortions when it was illegal prior to Roe v. Wade) o Federal authorities ate investigating all repo1ted in.cidents, and working to identify subjects. o DOJ will take appropriate action at tbe conclusion of these on-going investigations, which may include prosecution under the FACE Act. ■ • Cui:rent Enforcement Efforts (LE sensitive): on-going nation-wide investigations of damage/vandalism/arsons of pro-Iife o pregnancy centers (predomimmtly ''Jane's Revenge'· attacks (i.e. ''lf abortions aren't safe then neither are you")) o Incidents are being jointly investigated by • Outreach (public): o DO.I has made outreach efforts to life affomjng and pregnancy centers tli.rough several national parent organizations, including: • Clinic Violence. TF has contacted ofticjals from national organizations • FBI FOs identifying and contacting pregnancy centers tlu-oughout country • Statements {pub!ic ): o DOJ Journal FACE Act article (https://www.justice.gov/usao/page/file/149285 l /down load) o Clinic Violence Task Force website (https://www.justice.gov/c1i/protecting­ patients-and-health-care-providers) o TF resource booklet for reproductive health care providers (https://www.justice.gov/c1t/securitv-recommendations-enhance-safety-and­ protection-providers) EXHIBIT 007 From: "Patel, San ·a CR To: Subject: RE: FACE Stats Date: Thu, 22 Jun 2023 l 3:29:40 -0400 Importance: Normal Sure - The task force met separately with Care-Net, Heartbeat I nternational, NIFLA, and USCCB. Then we had a larger meeting with all the NGOs (CareNet, Heartbeat, and NIFLA) and have occasionally had calls with them separately as issues/incidents arose. The lines of communication cire open with them, and we have offered to meet with the providers they represent if they so desired. No response on that offer since it was made. We also updated our resource booklet after meeting with them and soliciting feedback. From: Bradford, Aryele (PAO) Sent: Thursday, June 22, 2023 1:17 PM To: Felte, James (CRT)�; Patel, Sahjay (CRT)e�; Fitzgerald, Paige {CRT) Cc: Moossy, Robert (CRT) Subject: RE: FACE Stats ; Weiner; Robert (CRT) +·weiner. Does anyone have the most -recent info1mation about our engagement with pro-life/crisis providers? I recall a meeting or two, but any relevant information you can pass my way that we can share 011 background with a repo1ter? From: Bradford, Aryele (PAO) Sent: Wednesday, June 21, 2023 3:34 PM To: Felte, James (CRT)e�; Patel, Sanjay (CRT)e�; Fitzgerald, Paige (CRT) Cc: Moossy, Robert (CRT) Subject: RE: FACE Stats Thank you! from: Felte, James (CRT)e� Sent: Wednesday, June 21, 2023 3:28 PM To: Patel, Sanjay (CRT)e�; Bradford, Aryele (PAO) (CRT) Cc: Moossy, Robert (CRT) Subject: RE: FACE Stats Thanks Sanfay. From: Patel, Sanjay (CRT)e� Sent: Wednesday, June 21, 2023 3:23 PM ·; Fitzgerald, Paige To: Felte, James (CRT)�; Bradford, Aryele (PAO) (CRT) Cc: Moossy, Robert (CRT) Subject: RE: FACE ?tats ; Fitzgerald, Paige Yes, those numbers are accurate. Only one of those cases ienvolve facilities that are crisis pregnancy centers (1 charged case (US v. Freestone)e-4 -defendants). The other charged cases are all abortion providers. Yes, you can share the link to the website. It was recently updated. SP From: Felte, James (CRT)e� Sent: W�dnesday, June 21, 2023 3:21 PM To: Bradford, Aryele (PAO) (CRT) Cc: Moossy, Robert (CRT) Subject: RE: FACE Stats ; Patel, Sanjay (CRT)e�; Fitzgerald, Paige Arvele, The below stats are accurate. Sanjay can correct me if I'm wrong, but the only case to date to charge interference with "anti-abortion" facilities, often referred to as pregnancy resource centers, is the cas.e U.S. v. Freestone, et al.. which is described in the first bullet point in the link you provided. As far as sharing the page in the link, I believe the link is public (?) so I have no issue sharing it. Jim From: Bradford, Aryele (PAO) Sent: Wednesday, June 21, 2023 2:56 PM To: Patel, Sanjay (CRT)e�; Fitzgerald, Paige (CRT) � Cc: Moossy, Roberte(CRT) Subject: FACE Stats i Felte, James (CRT) Hi all - I'm checking in to see ifthe stat below is still accurate? Also, is there a way to determine if any of these prosecutions are related to violence targeting institutions that both support and oppose abo1tion access? Finally, is it oltay to share this page with reporters as it seems to have been updated at the end of May? httP-s:L/www.justice.gov/crt/t·cc�nt-r.uses-violcnce- agaio::.-t- reproductive-beallb-care-P-roviders • Since Jan 2021, the Department has charged 1 8 cases involving a total of 48 defendants with FACE Act­ related violations. At-yele N. Bradford Spokeswoman I Office o-f Public Affairs De artment of Justice EXHIBIT 008 From: ASGI9 Schedu "Morse, Jodie (OASG)" latioainstitute.org>, edpi.com' 1 rge.org>, e.org" , apawf.org" ahouston. ghar.org> printny.or eafiyacen awomenunited.org" rg" �urge.erg>, 11ail�chj.org" . , •�niwrc.org" bwhi.org>, cvapnaghar.org" ahouston.or rintny.org" bluepriotny.org>1 .theaflyacenter.org'' ri□tny.org>, ' omenand irls.org" kanwin.org>, >, Cc: I• "' !ill "' "' empoweredpi.com> Subject: Meeting with Reproductive Justice Groups Date: Mon, 26 Sep 2022 16: 09: 19 -0400 Importance: Nonna! Attachments: unnamed ... •I "' "' •• • stersong.net" · .org> ngelo, Matthew ., J ..., "Patel, 1poweredpi.corn'' Nota: This meeting is limited to the Invited attendees onl You are not authorized to forward this invitatlori. Ifyou believe l)ther individuals should be included, please contact Tracy Washington (� y. Note: THIS IS A CLOSED PRESS AND OFF-THE-RECORD MEETING. **Attendees on this email who RSVP'd to come in-person, you will receive an email with the logistics for location and building access.•• - L,, 1 1 IHI-' D cha1gu any ot 111 ·c•llc,wui,1 e>i., When it's time, join your Webex meeting here. Join meeting More ways to join: Join from the meeting link Join by meeting number Meeting password: attendees only) United States Toll (Washington D.C.) Join b phone Join using Microsoft Lyne or Microsoft Skype for Business If you are a host-o view host informatlon. Need help? Go t EXHIBIT 009 From: "Moossy, Robert (CRT)" To: "Felte, James (CRT)" Subject: Re: Outreach ro USCCB Date: Fri, 07 Oct 2022 16:35:28 -0400 Jmportance: Normal Good for Sanjay to handle, she will not join. Sent from my iPhone wrote: On Oct 7, 2022, at 3:22 PM, Felte, James (CRT) Robert, See below. It appears that the only person from the USCCB for Tuesday wHI be their General Counsel. Does Kristen still want to rnake opening remarks? It seems like this could be more of a conversation that Sanjay and a smaller group has? Thanks, Jim From: Patel, Sanjay (CRT)e� Sent: Friday, October 7, 2022 1:34 PM To: Fe' lte, James {CRT)e�; Fitzgerald, Paige {CRT) Subject: FW: Outreach to USCCB Jim/PaigeeSee below re: next week's bishops meeting. SP From : - � Sent: Friday, October 7, 2022 1:24 PM To: Patel, Sanjay {CRT)e� Cc:- (CID) (FBI}._,; Subject: RE: Outreach to USCCB {CID) (FBI) ._, Sanjay, Our Offce ie of Partner Engagement just informed me that for the call with USCCB, the only person that will be in attendance is the General Counse l - so one person. Come to find out they purposely did this, to eliminate scheduling issues. With that being said, do you still want to have the call? And do you still want the MG to make opening rernarks? Thank you, Unit Chief CTD/DTOS/Northeast (Cell) (Desk) From: Patel, Sanjay (CRT)n� Sent: Thursday, October 6, 2022n1:50 PM To: (CTD) (FBI ) � Subject: [EXTERNAL EMAIL] - RE: Outreach to USCCB Yes, it's AAG Clarke. I'll find out and let you know. Thanks I SP From:n- � Sent: Thursday, October 6, 2022 1:49 PM To: Patel, Sanjay (CRT)n� Subject: RE: outreach to USCCB Of course. How long would the AAG need? And is this AAG Kristin Clarke? (I hope I got the name correct). thanks! Unit Chief CTD/DTOS/Northeast (Cell) (Desk) From: Patel, Sanjay (CRT)n� Sent: Thursday, October 6, 2022 1:39 PM To: (CTD) (FBI ) � Subject: [EXTERNAL EMAIL] - Re: Outreach to USCCB Stephanie Some of my managers, including the AAG, are planning to attend the USCCB meeting (or at least for the beginning of the meeting). May I adjust the agenda so that I can allow the AAG to speak at the beginning of the meeting? SP Sent from my iPhone On Oct 4, 2022, at 2:19 PM, Patel, Sanjay (CRT)e� wrote: Yes, Tues Oct 11 works great. My day is wide open. From: � Sent:' Tuesday, October 4, 2022 1 :11 PM To: Patel, Sanjay (CRT)e� Subject: Fwd: Outreach to USCCB Sanjay, See below. Monday is a holiday; would Tuesday work for you? Thanks! Stephanie From : - (OPE) (FBI)e� Sent: Tuesday, October 4, 2022e12:50:36 PM To: {CTD) (FBI) �; Subject: RE: Outreach to USCCB {OPE) { FBI) � Hi, Would next Monday or Tuesday work? It seems they plan to cut down on the number of attendees on their end to avoid the schedulihg hiccups. From: . (CTD) (FBI)e� Sent: Monday, October 3, 2022 8:23 AM To:e-(OPE}(FBI)�; Subject: Outreach to USCCB (OPE) (FBI}e� Alicia, Just touching base to see if you have heard anything from the USCCB yet? Just FYI, DOJ is hosting a meeting on Friday October 7, 2022 with the. following groups which represent 85'¾ of pro- Jifo providers: Care Net, Nat'I Institute of Family and Life Advocates (NIFLA), and Heartbeat International. Thanks! Uhlt Chief CTO/OTOS/Northeast - (Cell) - (Desk) EXHIBIT 010 From: "Wei,ner, Robert (CRT)" To: "Bond, Rebecca (CRT)" Subject: FACE Resource Booklet and Pregnancy Counseling Centers Date: Wed, 17 Aug 2022 1 1 : 12:39 -0400 Importance: Normal Attachments: FACE_ Resource_Booklet_FINAL_l (002).docx Rebecca, The hardening recommendations in this Resource Booklet apply to any organization offering services related to pregnancy. But, as the vast majority of FACE Act violations have involved anti-abortion efforts directed at abortion providers and patients, the booklet naturally focuses more on those activities. There are thus a number of aspects of the booklet that may militate against pushing it out during a meeting with Pregnancy Counseling Centers. P. 2 - Affirming the breadth of the recommendations, the booklet states at the outset: "This instructional booklet is intended to provide reproductive healthcare providers and other similar organizations with practical information and proactive security measures that can be used tq reduce risk and prevent violence against personnel and facilities." P. 2, passim -the booklet refers to "clinics" throughout. Are "Pregnancy Counseling Centers" typlcally and appropriately described as "clinics"? Mostly, the booklet refers to "reproduGtive healthcare" and "reproductive healthcare providers/' which arguably can include the anti.abortion centers, though some might dtspute whether they dispense health care. P. 4- "Anti-abortion extremist activitv. is not always confined to public places." Pp. 4 and 5 -cites National Abortion Federation. P. 9 - cites 2015 attack on Planned Parenthood clinic that killed a police officer and two civilians. P. 11- Cd i tes murder of Dr. David Gunn during an antiabortion protest in 1993. P. 11 - "The FACE Act does not reach all forms of abusive conduct directed at reproductive health care providers. For example, patients and staff may often feel 'intimidated' or 'interfered with' h_y_���g anti-abortion views." P. 18 - The references list under HNon-Governmental Organizations," Planned Parenthood, National Abortion Federation, and Feminist Majority Foundation. Rob EXHIBIT 011 From: "Wei.ner, Robe1t (CRT)" To: "Moossy, Robert (CRT)" Subject: Abortion references in Resource Booklet Date: Fri, 07 Oct 2022 12: 16:47 -0400 Importance: N01mal Attachments: Resource_Booklet_for_Reproductive_Health_Care_Providers_and_Their_Staffs_-­ -abortion_refere11ces.pdf Robert, I have highlighted the references that Roland Warren was citing in the Resources Booklet for Reproductive Health. There aren't very many, but they are obvious. To some extent, it is entirely justified to refer to anti-abortion extremism, cis that is a significant part of what the FACE Act and the Booklet covers. But it is true that the list of references in Appendix B, includes NGOs Planned Parenthood, National Abortion Federation, and Feminist Majority Foundation-only. It should not be a heavy liftto make the document more inclusive from t he perspective of the pro-life organizations. Rob EXHIBIT 012 Resource Booklet for Reproductive Health Care Providers and Their Staffs National Task Force on Violence Against Reproductive Health Care Providers 3/17/2022 Table of Contents Introduction................................................................................................................................... 2 Reducing Risk................................................................................................................................ 3 Reducing Risk at Places of Business ...................................................................................... 3 Reducing Risk at Home .......................................................................................................... 4 Reducing Risk of Cyber Attacks............................................................................................. 5 Threats ........................................................................................................................................... 7 Suspicious Packages and White Powder Letters........................................................................ 8 Active Shooters.............................................................................................................................. 9 Federal Statutes........................................................................................................................... 11 Appendix A: The FACE Act ...................................................................................................... 15 Appendix B: References ............................................................................................................. 18 Appendix C: Example Checklists ............................................................................................. 19 1 Introduction This instructional booklet is intended to provide reproductive healthcare providers and other similar organizations with practical information and proactive security measures that can be used to reduce risk and prevent violence against personnel and facilities. Please share this booklet with all staff members. A series of forms and checklists with important phone numbers and procedures are included in the appendices. These can be printed out and should be placed where they are most needed. On November 9, 1998, the Department of Justice established the Task Force on Violence Against Health Care Providers. The Assistant Attorney General for the Civil Rights Division of the Department of Justice chairs the Task Force, and the Task Force Director is an attorney with the Criminal Section of the Civil Rights Division. The Task Force is staffed by attorneys and other staff from the Civil Rights, Criminal and National Security Divisions of the Department of Justice, and by investigators and other representatives from the Federal Bureau of Investigation (FBI), the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF), the United States Postal Inspection Service (USPIS), and the United States Marshals Service (USMS). For additional information please visit the National Task Force on Violence Against Health Care Providers website https://www.justice.gov/crt/national-task-force-violenceagainst-reproductive-health- care-providers. You can contact the National Task Force on Violence Against Health Care Providers at: Clinicviolence.Taskforce@usdoj.gov A digital copy of this resource booklet can be found at: https://www.fbi.gov/investigate/civilrights 2 Reducing Risk Since the passage of the Freedom of Access to Clinic Entrances (FACE) Act, 18 U.S.C. §248, in 1994, the number of large-scale clinic blockades has declined. However, incidents of violence and threats towards reproductive health care providers and their staff members have continued. Although laws exist to combat and address this behavior, providers and their staff members are encouraged to take active steps to reduce their own risk of victimization. Forging a relationship with law enforcement in your area is an important step in reducing risk to your facility. Contact the FBI and U.S. Attorney’s office in your area to establish a liaison should you have legal questions or concerns. The U.S. Marshal’s Service can provide information on improving your physical security. It is also important to establish a relationship with your local law enforcement agencies to ensure that they understand your concerns. Reducing Risk at Places of Business Clinics have been targets of arson, bombing, vandalism and other dangerous and disruptive activities. Below is a list of suggestions to reduce and mitigate the risks of such activities: • • • • • • • • • • • • • • • • • • Install dead bolt locks on office doors leading to hallways and other public areas. Consider installing a "buzzer" entry door system. Consider installing a perimeter fence. Managers should issue and control keys, conduct regular inventories, and have locks changed when keys are missing. Have offices cleaned during business hours. Ensure that cleaning personnel do not have access to security alarm codes. Instruct all employees on operation of your security system. Do not allow visitors access to secure areas. Immediately report persons who appear unannounced in your work area. Be cognizant of suspicious individuals loitering in public areas outside of your facility. • Take note of extra baggy clothing and nervous behavior. • Record description of suspicious persons or vehicles including license plates. Do not admit unexpected repair or delivery people. Check with a security company for information on available equipment and services. Install video surveillance and exterior lighting. Control exterior vegetation to eliminate hiding places. Develop a comprehensive inventory including serial numbers, pictures and values. Keep a list of suppliers with phone numbers, addresses and points of contact. Develop a list of minimum equipment and supplies needed to reestablish the clinic. Keep a copy of all important documents in a safe, off-site location. 3 • • • • Evaluate the need for a security guard. Develop a written emergency response plan for threats and refresh employee training. Information can be found at: https://www.ready.gov/business/implementation/emergency. Ask local police and/or U.S. Marshal Service to evaluate your emergency response plan. Keep bomb threat/personal threat checklists by each telephone and ensure staff is familiar with the forms found at: https://www.cisa.gov/publication/dhs-bomb-threat-checklist. Reducing Risk at Home Anti-abortion extremist activity is not always confined to public places. Reproductive healthcare providers and their staff members have also been targeted for protest activity at their private residences. Most often, this activity consists of picketing, leafleting, or posting flyers in residential neighborhoods. Many cities and towns have enacted residential picketing laws in order to restrict or prevent picketing at private residences. The National Abortion Federation compiled a list of such injunctions and ordinances and listed them by state. The list is not exhaustive and is current as of 2017. To obtain a copy of this legal remedies resource, contact the National Abortion Federation: http://www.prochoice.org. In addition to picketing, some anti-abortion extremists have also engaged in stalking, vandalism and even murder. The following is a list of safety measures providers and their staff members may want to incorporate in order to reduce their risk of being victimized at home: • • • • • • • • • • • • • • • Do not put your name on the outside of your residence or mailbox. Install an appropriate security system. Have good outside lighting. Control vegetation to eliminate hiding places. Entrances should have deadbolt locks and one way peep-holes. Account for all copies of house keys. Change locks if keys are lost or stolen and when moving to a new residence. Keep doors locked, even if you are at home. Develop friendly relationships with neighbors. Arrange for unlisted/unregistered home and mobile telephone numbers. Use a timer to turn lights on and off at varying times and locations. Leave a radio playing while you are away (best with a timer). Notify the police or a trusted neighbor of your absence. Report and maintain a record of all suspicious activity. Ensure law enforcement is aware of any concerns you may have. 4 Reducing Risk of Cyber Attacks According to National Abortion Federation statistics, between the years 2010 and 2019 reproductive healthcare providers reported over 128,000 incidents of either hate email or internet harassment. In addition to threats and harassment, providers and their staff members have had their photographs and personal information posted online, making them targets for cyber stalking and other types of cyber crimes. As uses of the internet and social media continue to increase, ideologically driven individuals may choose to target reproductive healthcare centers, providers and their staff for a variety of cyber attacks. These attacks can include phishing (attempts to obtain financial or other confidential information from internet users, typically by sending an email that looks as if it is from a legitimate organization, but contains a link to a fake website that replicates the real one); denial of service attacks (attacks designed to incapacitate a network by flooding it with useless traffic); defacement of websites (attacks changing the visual appearance of a website); and computer intrusion to either steal or demand ransom for clinic data about staff and patients. Following these tips on your work and home computers and internet connected devices will help reduce the risk of victimization: Users • Verify the spelling of web addresses, websites, and email addresses that look trustworthy but may be imitations of legitimate election websites. • Update anti-malware and anti-virus software and conduct regular scans. • Do not enable macros on documents downloaded from an email unless absolutely necessary, and after ensuring the file is not malicious. • Do not open emails or attachments from unknown individuals. Do not communicate with unsolicited email senders. • Never provide personal information of any sort via email. Be aware that many emails requesting your personal information may appear to be legitimate. • Disable or remove unneeded software applications. • Verify the website you visit has a Secure Sockets Layer (SSL) certificate. IT Administrators • Require multi-factor authentication for remote access to IT networks. • Enable strong spam filters to prevent phishing emails from reaching end users. Filter emails containing executable files from reaching end users. • Implement a user training program and simulated attacks for spear phishing to discourage users from visiting malicious websites or opening malicious attachments and reinforce the appropriate user responses to spear phishing emails. • Filter network traffic to prohibit ingress and egress communications with known malicious IP addresses. Prevent users from accessing malicious websites by implementing URL blocklists and/or allow lists. • Update software, including operating systems, applications, and firmware on IT network assets, in a timely manner. Consider using a centralized patch management system; use a risk-based assessment strategy to determine which OT network assets and zones should 5 participate in the patch management program. Victim Reporting and Additional Information The FBI encourages the public to report information concerning suspicious or criminal activity to their local field office (www.fbi.gov/contact-us/field-offices) or the FBI's Internet Crime Complaint Center (www.ic3.gov). 6 Threats Although certain behaviors can be upsetting, the FACE Act criminalizes only those threats that are “true threats.” A true threat is defined as a serious communication of an intent to commit an act of unlawful violence against an individual or group. Absent additional circumstances, carrying graphic signs, videotaping patients or doctors, writing down license plates, and even screaming or shouting would not typically rise to the level of a being considered a true threat. With the explosion of internet use and social media, cyber threats are no longer limited to just threats received via email. Threats can be posted on message boards, social media pages, and comments sections. These threats don’t have to be posted on the provider’s sites or social media to be considered threats. Threats can be posted on the comments section of a news story or in issue-specific chat rooms. Regardless of where the threat is found, it should be taken very seriously. The following steps should be taken for threats: • • • • • Notify local law enforcement if there is any reason to believe the threat is imminent. For cyber threats: - Take a screen shot, print a copy, and/or download an electronic copy if possible. - Immediately notify your IT and security professionals. - Do not delete the threat message. For threats received by telephone: - Use a bomb checklist to record information (see example in Appendix C below). - Do not hang up – even if the caller does. - Stay calm and ask the caller as many questions about the threat as possible. - Note as many details about the caller as possible. - Record the telephone number of the caller. For threats received by mail: - Limit the number of people that handle the letter to preserve evidence. - See the below section on Suspicious Packages Notify the local FBI office. 7 Suspicious Packages and White Powder Letters Characteristics of a suspicious package: • • • • • • • • • • • • • Packages that you are not expecting or from businesses/people you are not familiar with Words spelled incorrectly Return address and postmark do not match Envelope is addressed generically to “Medical Director” or “Security Director” No return addresses or return address typed on adhesive labels Possibly mailed from outside the U.S. Envelopes or packages from businesses with no business stationary Protruding wires Strange odor, oily stains, discolorations, or crystallization on wrapper Excessive tape or string Excessive postage Granular material in the package Rigidness or bulkiness If you discover a suspicious letter or package: • • • • • Do not open it. Treat it as suspect. Isolate it—don’t handle. Contact building security, if available. If there is a medical emergency or chemical reaction with a letter or package, call 911. If you suspect a bomb: • • • Evacuate immediately. Call 911 for police, fire and hazmat unit. Move to designated meeting area away from the building. If there is a release of gas or powder: • • • • • • Turn off fans or ventilation units and shut down the air handling system in the building. Leave area immediately. Close the door or section off the area to prevent others from entering. Notify your building security official or a supervisor and call 911. List all people who were in the room or area. Give the list to public health authorities. FBI will conduct a thorough risk and threat assessment. The item will then be transported by the FBI laboratory for testing. 8 Active Shooters On November 27, 2015, Robert Lewis Dear, Jr. attacked a Planned Parenthood clinic in Colorado Springs, Colorado. A police officer and two civilians were killed; five police officers and four civilians were injured. After a standoff that lasted five hours, police SWAT teams crashed armored vehicles into the clinic’s lobby and the attacker surrendered. An “active shooter” is an individual who is engaged in killing or attempting to kill people in a confined and populated area; in most cases, active shooters use firearms and there is no pattern or method to their selection of victims. When an active shooter is in your vicinity, you must be prepared both mentally and physically to deal with the situation. You have three options: RUN • • • • • • • • Wherever you go, be aware of alternate exits. Quickly and cautiously evacuate in a direction away from the attacker. Don’t hesitate. Seconds matter. Remember windows and emergency exits. Leave belongings behind. Keep empty hands raised and clearly visible. Follow all instructions from the police. Don’t stop until you are sure you have reached a safe location. HIDE • • • • If there is no safe escape route, find a good hiding place. Lock and barricade the door. Silence cell phones. Prepare a defense plan. FIGHT • • • • Fight only as a last resort. Use available objects as improvised weapons. Use teamwork and surprise, a coordinated ambush can incapacitate an attacker. You are fighting for your life, don’t fight fair! Information to provide to 911 operations: • • Location of the active shooter (provide street address if possible) Number of shooters 9 • • • Physical description of shooter Number and type of weapons shooter has Number of potential victims at location When law enforcement arrives (typical law enforcement response is three minutes): • • • • • • • Remain calm and follow instructions. Drop items in your hands (e.g., bags, jackets). Raise hands and spread fingers. Keep hands visible at all times. Avoid quick movements toward officers, such as holding on to them for safety. Avoid pointing, screaming or yelling. Do not ask questions when evacuating. The first officers to arrive on scene will not stop to help the injured. Responding officers will move to the sounds of gun fire with the intent to neutralize the shooter. Expect rescue teams to follow initial officers. These rescue teams will treat and remove the injured. Once you have reached a safe location, you will likely be held in that area by law enforcement until the situation is under control and all witnesses have been identified and questioned. Do not leave the area until law enforcement authorities have instructed you to do so. More information including a video to show employees can be found on the FBI website at. https://www.fbi.gov/about/partnerships/office-of-partner-engagement/active-shooter-resources. Another good source of information is the DHS website at https://www.cisa.gov/active-shooterpreparedness. 10 Federal Statutes From the mid-1980s through the 1990s, clinic violence and harassment escalated across the nation. Clinics experienced increased blockades, arsons, bomb threats, death threats, vandalism, and harassment. On March 10, 1993, the first murder of a reproductive health care provider occurred. Dr. David Gunn, a physician who provided abortion services, was murdered during an anti-abortion protest at a Pensacola, Florida clinic. In response to the alarming trend of increased violence, the U.S. Congress enacted the Freedom of Access to Clinic Entrances (FACE) Act, Title 18 of the U.S. Code, Section 248, in May of 1994. In addition to the FACE Act, the below laws and others not listed may be used in the investigation and prosecution of illegal acts against reproductive health care providers and their staffs. Freedom of Access to Clinic Entrances (FACE) Act, 18 U.S.C. § 248 The FACE Act makes it a federal crime to use force, threat of force, or physical obstruction to intentionally injure, intimidate, or interfere with persons because they are seeking or providing reproductive health services, or to intimidate others or attempts to injure, intimidate, or interfere with any person because they are seeking or providing such services. In addition, the law prohibits damage or destruction of the property of a facility because the facility provides reproductive health care services. Violators of the FACE Act are subject to criminal penalties, including imprisonment and fines. The severity of the punishment depends upon the nature of the offense and whether or not the person is a repeat offender. The FACE Act also allows providers and seekers of reproductive health care services, the United States Attorney General, and State Attorneys General to sue for civil remedies against conduct which violates the Act. The civil remedies can include injunctions, including buffer zones, and monetary damages. The full text of the FACE Act is set forth in Appendix A. The FACE Act does not reach all forms of abusive conduct directed at reproductive health care providers. For example, patients and staff may often feel “intimidated” or “interfered with” by people expressing anti-abortion views. However, absent use of force, threat of force, or an act of physical obstruction, offensive conduct is not prohibited by the FACE Act. Nonetheless, the FACE Act is an important means of combating and deterring violence and threats of violence against reproductive health care providers. If you feel that you have been a victim of conduct in violation of the FACE Act, notify your local FBI or U.S. Attorney’s Office. Contact information for your local FBI office can be found here: https://www.fbi.gov/contact-us/field-offices. Contact information for your local U.S. Attorney’s Office can be found here: https://www.justice.gov/usao/us-attorneys-listing. 11 Conspiracy Against Rights, 18 U.S.C. § 241 Section 241 of Title 18 establishes a federal criminal offense where two or more persons to conspire to injure, oppress, threaten, or intimidate any person in the exercise or enjoyment of any right or privilege secured to him or her by the Constitution or laws of the United States, which includes a violation of the FACE Act. The charge carries a penalty of up to 10 years imprisonment; or, if death results from the acts or if such acts involve kidnapping or an attempt to kidnap, aggravated sexual abuse or attempt to commit aggravated sexual abuse, or an attempt to kill, the offender may be sentenced to any term of years, or for life, or in certain cases may be sentenced to death. Damage or Destruction of Property Used in Interstate Commerce, 18 U.S.C. § 844(i) Section 844(i) of Title 18 establishes a federal criminal offense where an individual “maliciously damages or destroys, or attempts to damage or destroy, by means of fire or an explosive, any building, vehicle, or other real or personal property used in interstate or foreign commerce or in any activity affecting interstate or foreign commerce.” Since many reproductive health services clinics serve patients from other states and order medical supplies from other states, clinics may qualify as property used in interstate commerce. Charges under § 844(i) frequently have been brought in cases of arson or bombing of reproductive health services clinics. The charge carries a penalty of 5 to 20 years in prison absent physical injury and 7 to 40 years if injury results. Where death results from a violation of this statute, the offender may be sentenced to death. Use of a Firearm in the Commission of a Felony, 18 U.S.C. § 924(c) Section 924(c) of Title 18 establishes a federal criminal offense where an individual uses or carries a firearm during or in relation to a crime of violence or drug trafficking crime prosecutable in federal court, or, in furtherance of any such crime, possesses a firearm. The mandatory minimum penalty is 5 years imprisonment. The penalty increases to 7 years if the firearm is brandished during the offense, and 10 years if it is discharged. Penalties for subsequent offenses are significantly increased, as are penalties for the use of certain illegal and proscribed firearms and silencers. The use of a firearm in the commission of a felony offense related to a clinic might warrant prosecution under § 924(c). Use of the Mails or Commerce for Bomb or Fire Threats, 18 U.S.C. § 844(e) Section 844(e) of Title 18 establishes a federal criminal offense to use the United States Mail, a telephone, or other instrument of interstate commerce to communicate a threat or to convey false information concerning a threat. Cases brought under § 844(e) generally involve bomb or arson threats. This offense carries a penalty of up to 10 years imprisonment. 12 Threats Made by Use of Interstate or Foreign Commerce, 18 U.S.C. §§ 875 and 876 These statutes prohibit the use of interstate or foreign commerce, generally telephones, internet communications and electronic mail, and the mails, to convey threats to kidnap or injure another. Increased penalties are provided where the threat is made with the intent to extort a “thing of value.” Courts have found that actions taken for the purpose of harming a business (including a clinic) may demonstrate an intent to extort a thing of value. The Department of Justice has used § 875 to prosecute a case involving computer-generated threats made by electronic mail to, among others, reproductive health care providers. Violations of this statute carry a penalty of up to 20 years in prison. Interference with Commerce by Threats or Violence, 18 U.S.C. § 1951 Section 1951, more commonly referred to as the “Hobbs Act,” prohibits conduct that obstructs, delays or affects commerce by means of robbery or extortion. The statute also covers attempts to commit these acts, conspiracy to commit the acts, and any threats made to cause injury or damage to a person or property in order to commit these acts. Attempts to coerce a reproductive health care provider to limit or halt operations may constitute a violation of this statute. Violations carry a penalty of up to 20 years in prison. Interstate Travel or Transportation to Aid in Racketeering Enterprises, 18 U.S.C. § 1952 More commonly referred to as the “Travel Act,” Section 1952 sets a penalty of up to 5 years for persons who either travel in interstate or foreign commerce, or use the mails or other facility in interstate or foreign commerce, to commit any crime of violence in furtherance of some unlawful activity, or to promote, manage, establish, carry on or facilitate the promotion, management, establishment or carrying on of any unlawful activity. In sum, this statute makes it illegal to travel between states, or between another country and the United States, in order to commit certain illegal acts. Traveling across state lines to perpetrate a crime of violence against a reproductive health care provider might warrant prosecution under § 1952. Use of Certain Weapons of Mass Destruction, 18 U.S.C. § 2332a Section 2332a prohibits the use, threat of use, or attempted or conspired use of a weapon of mass destruction, including a biological agent, toxin, or vector against any person within the United States the results of which affect interstate commerce. The term “weapon of mass destruction” is also defined under this section and includes any destructive device as defined under § 921 of this title, any weapon that is designed or intended to cause death or serious bodily injury through the release, dissemination, or impact of toxic or poisonous chemicals, or their precursors; any weapon involving a disease organism; or any weapon that is designed to release radiation or radioactivity at a level dangerous to human life. Use or threatened use of a chemical weapon is covered under 18 U.S.C. § 229. The offender is eligible to be sentenced to any term of years, or for life, or in certain cases may be sentenced to death. 13 Concurrent Jurisdiction with State and Local Authorities Many criminal activities that affect reproductive health care providers constitute crimes at the federal, state, and local level. Many jurisdictions have local ordinances for trespassing and disorderly conduct, for example, which may prohibit conduct not covered by a federal statute. Some states have adopted statutes almost identical to FACE, providing for concurrent jurisdiction in many cases. Charging decisions involving offenses related to reproductive health care providers generally are made by the Civil Rights Division’s Criminal Section in consultation with United States Attorney’s Office (USAO) and in cooperation with state and local authorities. Per a July 31, 2009, directive from the Attorney General, USAOs must notify the Criminal Section of the Civil Rights Division immediately upon learning of any potential FACE Act violations within their district and to consult with the Criminal Section prior to making any charging or non-charging decisions. Civil Remedies In addition to criminal penalties that may arise in relation to conduct affecting reproductive health care providers, federal law provides for civil remedies where private parties or the federal or state governments bring suit. Civil actions under the FACE Act may be brought by an aggrieved private party (such a health care provider), the United States Attorney General, or the Attorney General for any state. As a general matter, establishing a civil violation under the FACE Act requires proof of the same elements outlined in the criminal discussion of the statute. However, the remedies available in the civil context differ, and may include injunctive relief, civil penalties, actual or statutory damages, punitive damages, and attorney fees for actions that are not brought by a government. Additionally, in a civil case, the private or public plaintiff need only prove the case by a preponderance of the evidence, rather than beyond a reasonable doubt. The United States Department of Justice, through the Special Litigation Section of the Civil Rights Division, has secured a number of important decisions using the civil remedies of the FACE Act to win permanent injunctive relief against persons who violated the Act in the context of blockades, “lock-and-blocks,” threats, and other obstructive conduct. The government has secured judgments that bar specific defendants from entering the property of certain clinics, and the government has secured rulings requiring “buffer zones” around clinics in order to balance the interests of legitimate and protected protest and the rights of clinics to operate their legal businesses. - For more information regarding the civil aspects of the Freedom of Access to Clinic Entrances Act, visit the Special Litigation Section’s webpage at https://www.justice.gov/crt/speciallitigation-section. 14 Appendix A: The FACE Act Freedom of Access to Clinic Entrances (FACE) Act of 1994 –Title 18 U.S. Code, Section248 (a) PROHIBITED ACTIVITIES- Whoever(1) by force or threat of force or by physical obstruction, intentionally injures, intimidates or interferes with or attempts to injure, intimidate or interfere with any person because that person is or has been, or in order to intimidate such person or any other person or class of persons from, obtaining or providing reproductive health services; (2) by force or threat of force or by physical obstruction, intentionally injures, intimidates or interferes with or attempts to injure, intimidate or interfere with any person lawfully exercising or seeking to exercise the First Amendment right of religious freedom at a place of religious worship; or (3) intentionally damages or destroys the property of a facility, or attempts to do so, because such facility provides reproductive health services, or intentionally damages or destroys the property of a place of religious worship, shall be subject to the penalties provided in subsection (b) and the civil remedies provided in subsection (c), except that a parent or legal guardian of a minor shall not be subject to any penalties or civil remedies under this section for such activities insofar as they are directed exclusively at that minor. (b) PENALTIES- Whoever violates this section shall (1) in the case of a first offense, be fined in accordance with this title, or imprisoned not morethan one year, or both; and (2) in the case of a second or subsequent offense after a prior conviction under this section, be fined in accordance with this title, or imprisoned not more than 3 years, or both; except that for an offense involving exclusively a nonviolent physical obstruction, the fine shall be not more than $10,000 and the length of imprisonment shall be not more than six months, or both, for the first offense; and the fine shall be not more than $25,000 and the length of imprisonment shall be not more than 18 months, or both, for a subsequent offense and except that if bodily injury results, the length of imprisonment shall be not more than 10 years, and if death results, it shall be for any term of years or for life. (c) CIVIL REMEDIES(1) RIGHT OF ACTION (A) IN GENERAL - Any person aggrieved by reason of the conduct prohibited bysubsection (a) may commence a civil action for the relief set forth in subparagraph (B), except that such an action may be brought under subsection 15 (a)(l) only by a person involved in providing or seeking to provide reproductive health services, and such an action may be brought under subsection (a)(2) only by a person lawfully exercising or seeking to exercise the First Amendment right of religious freedom at a place of worship or by the entity that owns or operates such a place of worship. (B) RELIEF- In any action under subparagraph (A), the court may award appropriate relief, including temporary, preliminary or permanent injunctive relief and compensatory and punitive damages, as well as the costs of suit and reasonable fees for attorneys and expert witnesses. With respect to compensatory damages, the plaintiff may elect, at any time prior to the rendering of final judgment, to recover, in lieu of actual damages, an award of statutory damages in the amount of $5,000 per violation. (2) ACTION TAKEN BY ATTORNEY GENERAL OF THE UNITED STATES (A) IN GENERAL - If the Attorney General of the United States has reasonable cause to believe that any person or group of persons is being, has been, or may be injured by conduct constituting a violation of this section, the Attorney General may commence a civil action in any appropriate United States District Court. (B) RELIEF - In any action under subparagraph (A), the court may award appropriate relief, including temporary, preliminary or permanent injunctive relief, and compensatory damages to persons aggrieved as described in paragraph (1)(B). The court, to vindicate the public interest, may also assess a civil penalty against each respondent— (i) in an amount not exceeding $10,000 for a nonviolent physical obstruction and $15,000 for other first violation; and (ii) in an amount not exceeding $15,000 for a nonviolent physical obstruction and $25,000 for any other subsequent violation. (3) ACTIONS BY STATE ATTORNEYS GENERAL (A) IN GENERAL- If the Attorney General of a State has reasonable cause to believe that any person or group of persons is being, has been, or may be injuredby conduct constituting a violation of this section, such Attorney General may commence a civil action in the name of such State, as parens patriae on behalf of natural persons residing in such State, in any appropriate United States DistrictCourt. (B) RELEF- In action under subparagraph (A), the court may award appropriate relief, including temporary, preliminary or permanent injunctive relief, 16 compensatory damages, and civil penalties as described in paragraph (2)(B). DEFINITIONS—As used in this section: (1) FACILITY- The term 'facility' includes a hospital, clinic, physician's office, or other facility that provides reproductive health services, and includes the building or structure in which the facility is located. (2) INTERFERE WITH- The term 'interfere with' means to restrict a person's freedom of movement. (3) INTIMIDATE- The term 'intimidate' means to place a person in reasonable apprehension of bodily harm to him/herself or to another. (4) PHYSICAL OBSTRUCTION- The term 'physical obstruction' means rendering impassable ingress to or egress from a facility that provides reproductive health services or to or from a place of religious worship, or rendering passage to or from such a facility or place of religious worship unreasonably difficult or hazardous. (5) REPRODUCTIVE HEALTH SERVICES- The term 'reproductive health services' means reproductive health services provided in a hospital, clinic, physician's office, or other facility, and includes medical, surgical, counseling or referral services relating to pregnancy or the termination of a pregnancy. (6) STATE- The term 'State" includes a State of the United States, the District of Columbia, and any commonwealth, territory, or possession of the United States. 17 Appendix B: References Government Agencies Department of Justice Civil Rights Division Federal Bureau of Investigation US Marshals Service Bureau of Alcohol, Tobacco, Firearms US Postal Inspection Service Federal Emergency Management Agency https://www.justice.gov/crt https://www.fbi.gov http://www.usmarshals.gov https://www.atf.gov https://postalinspectors.uspis.gov http://www.fema.gov Non-Governmental Organizations Planned Parenthood National Abortion Federation Feminist Majority Foundation https://www.plannedparenthood.org http://prochoice.org http://feminist.org Information on Cyber Threats Department of Homeland Security Cyber Security Information https://www.dhs.gov/topic/cybersecurity More information of Cyber Crimes https://www.fbi.gov/investigate/cyber Internet Crimes Complaint Center http://www.ic3.gov Information on Bomb Threats DHS Bomb Threat Checklist https://www.cisa.gov/publication/dhs-bomb-threat-checklist FBI suspicious package info sheet https://www.fbi.gov/file-repository/suspicious-package-indicators.pdf/view FEMA Emergency Response Plan https://www.ready.gov/explosions More information on Emergency Response Plans https://www.ready.gov/business/implementation/emergency Information on Active Shooters FBI Active Shooter Video https://www.fbi.gov/about/partnerships/office-of-partner-engagement/active-shooter-resources DHS Active Shooter resources https://www.cisa.gov/active-shooter-preparedness 18 endix C: Exam le Checklists The National Explosives Task Force (NETF) coordinates rapid Integration of explosives expertise with intelligence and law enforcement information ta support operational octlvities. Products ore peer-reviewed by explosives expertsfrom partlclpoting agencies. National Explosives Task Force Suspicious Package Indicators and Recommended Response Procedures Package bombs, which include letters, parcels, and anything delivered by postal or courier service, are not a new technique and have been used by te1rnrists and anarchist groups. Many of these bombs are triggered when victims handle or open the packages, although they can be initiated i n other ways. Package bombs come in a variety of shapesand sizes, and they may look hannless. TI1ere are a number of characteristics that may lead you to become suspicious of a letter or package. If you believe a letter or package is suspicious: • Stop. Do not handle or open. • Do not use cell phones, pagers, or two-way radios near suspected devices. • Be aware of secondary devic.es. • Evacuate and isolate the immediate area. • If applicable, activate the facility's emergency plan. • Make note of the characteristics that caused suspicion. • Call 911. Protect yourself, your business, and your mailroom. IfyotJ receive a suspicious letter or package: • Stop. Don' t hanOle. • 1,01a1e t 1mmedtately •ArJJvaleyoUJ emergancv plan. rloUfy 3 SU08fVISQt Formal Screening Procedures Commercial or govemment entities with mail screening procedures are advised to review existing procedures for screening packages, identifying suspicious items, andinstituting the appropriate safety protocols. If no cmTent procedures are in place, guidance should be If you suspect the mal l or package contains a bomb (e�ploslve), or radiological, biological, or chemical threat: • ISOiate area lrrmechte1S, • Call 911 • Wash your nanus with soap and watw sought from local, state, and/or federal resources. Planning considerations shouldinclude (but not be limited to) recurring training for screeners, an understanding of the standards and limitations for operating times, and regularly scheduled maintenance of screening equipment, such ascalibration, updates, and testing. Response Procedures The NETF prepared this document to raise awareness of package bombs and the need for diligence and safety procedures in evaluating suspected improvised explosive devices. If a suspicious package is found, call 911. Any diagnostic or render safe actions should be performed only by FBI HazardousDevices School (HDS) certified public safety bomb technicians or current U.S. military explosive ordnance disposal technicians. The U.S. government has resources on mail security available to citizens and businesses. More information can be found at http://about.usps.com/securing-the-mail/mail-security-center.htm To report suspicious activity, call 911 or contact local law enforcement. Suspicious activity reports (SARs) will be forwarded to the appropriate fusion center and FBI Joint Terrorism Task Force for further action. For more information on the Nationwide SAR Initiative, visit: https://nsi.ncirc.gov/resources.aspx. March 2018 20 21 BOMB THREAT PROCEDURES � TIils quicl< reference checklist is designed to help emplOyees and decision makers of commercial facilities, schools, etc. respondto a bomb threat in anorderly and controlled manner with the first responders and other stakeholders. Most bomb threats are received IJy phone. Bomb threats are serious until proven otherwise. Actquickly, butremain calm and obtain information withthe checklist on the reverse of this card. BOMB THREAT CHECKLIST DATE: TIME: TIME CALLER HUNG UP: PHONE NUMBER WHERE CALL RECEIVED: Ask Caller: • If a bombthreat is received by phone: 1_ Remain calm. Keepthe calleron file line foras long as possible. DO NOT HANG UP, even ie f the caller does. 2 . Listen carefully. Be polite and show interest. Where is the bomb located? (building, floor, room, etc.) • When will ie t go off? 3. Try to keep the caller talking to learn more information. • What does it look like? 4. If possible, write a note to a colleague to call the authorities or, as soon as . the caller hangs up, immediateiynotifythem yoursele f 5 . Ifyour phone has a display. copythe number andfor letters on the window dispay le • What ke t? i nd of bomb is ie • What will make it explode? • Did you place the bomb? Yes No 6. Complete the Bomb Threat Checklist immediately. Write down as much • Why? detail as you can remember. Try to get exact words. 7. Immediately upon tennination of call, DO NOT HANG UP, but from a different nfonnalion and await instructions. phone. contact authorities i mmediately with ie • What is yourname? Exact Words of Threat: If a bomb threat is recee ved by handwritten note: ie • Call __________________ • Handle note as minimallyas possibe le. If a bomb threat is received by e-mail: • Call __________________ • Do not deletethe message. Information About Caller: Signs of a suspicious package: • Where is the caller located?(background/level ofnoise) • No return address • • Excessive postage sspelled words • Mie • Estimated age: • Stains • Incorrect titles • Is voice farni liar If so, who does itsound like? • Strange odor • Foreign postage • Other points: • Strange sounds • Restrictive notes Poorly handwritten ? • Unexpected delivery •Refer to your focal bomb threatemergency response plan forevacuation criteria DO NOT: Use two-way radeos or cellular phone. Radio signals have the potential to • detonate a tiomb.i • Touch or move a suspicious package. WHO TO CONTACT (Select One) • 911 • Follow your local guidelines For more information about this form contact the Office for Bombing Prevention at: OBP@cisa.dhs.gov 22 Caller's Voice Background Sound Threat Language D Female D Mal e D Accent D Angry D Cam l D Clearing throat D Coughng ie D CrackingVoice D Crying D Deep D Deep breathng ie D Disgui sed D Disti nct D Excited D laughter D lisp D loud D Nasal D Normal D Ragged D Rapid D Raspy □ SloW D Slurred D Soft D Animalnoises D House noises D Ktchen noe ses i ie D Streetnoses ie D Booth D PAsystem D Conversation D Music D Motor D Ctear D Static D Officemache nery ie D Factory machnery ie D local D Incoherent D Message read D Taped message D Irrational □ Stutter D longde stance ie Other Information: D Profane D We�poken le EXHIBIT 013 From: "Weiner, Robert (CRT)" To: "Bradford, Aryele (PAO)" Subject: RE: MD Fl01ida FACE fi1dictment ( l/J8) Date: Wed, 18 Jan 2023 19;14:08 -0500 Importance: Nonnal Kristen asked whether the antf-abortlondiolks calledthemselves Pregnancy Centers or Pregnancy Resource Centers. Sanjay says both, but more often the fortner: But apart form the question, I didn't get a clear answer from KC as to whether she signed off, so I've re-upped it with an indication that you'd like to get it to leadership. Will let you know. R From: Bradford, Aryele (PAO) Sent: Wednesday, January 18, 2023 4:22 PM To: Bernstein, Laura-Kate {CRT) ; Gibson, Rose (CRT)d�; ; Morris, Catherine (PAO) Weiner, Robert (CRT) Cc: Moossy, Robert (CRT) ; Felte, James (CRT)d�; Patel, Sanjay (CRT) �; Fitzgerald, Paige {CRT) Subject: RE: MD Florida FACE Indictment (1/18)· Hey Team - I need to elevate this to the leadership offices, so do we have a final from KC? Thanks! From: Bernstein, Laura-Kate (CRT) Sent: Tuesday, January 17, 2023 3:41 PM To: Gibson, Rose {CRT)d�; Bradford, Aryeie (PAO) ; Weiner, Robert (CRT) ; Morris, Catherine (PAO) Cc: Moossv, Robert (CRT) ; Felte, James (CRT)d�; Patel. Sanjay (CRT) �; Fitzgerald, Paige (CRT) Subject: RE: MD Florida FACE lndictment {l/18) The case agent has advised that we should consider mentioning the substantial a!)sistance of tne - Police Department,d- Police Department, and the- Police Department in the investigation. Thanks, laura-Kate Laura-Kate Bernsteir, Trial A/lomey Criminal Section Civil Rights Division U.S. Oe artment of Justice From: Gibson, Rose (CRT) -­ Sent: Tuesday, January 17, 2023 3:32 PM ; Morris, To: Bradford, Aryele (PAO) ; Weiner, Robert (CRT) Catherine (PAO) Cc: Moossy, Robert (CRT) ; Felte, James (CRT)n�; Bernstein, Laura• ; Patel, Sanjay (CRT)n�; Fitzgerald, Paige (CRT) Kate (CRT) Subject: RE: MD Florida FACE Indictment (1/18) Just heard from the trial team that the indictment will remain under seal until 1/23. Rose Gibson Deputy Chief, Criminal Section Civil Rights Division U.S. De artment of Justice She/her/hers From: Bradford, Aryele (PAO) Sent:nTuesday,. January 17, 2023 2:41 PM • • To: (PA Cc: ; Gibson, Rose (CRT)n--; Morris, Catherine ; Felte, James (CRT)n�; Bernstein, Laura; Patel, Sanjay (CRT)n�; Fitzgerald, Paige (CRT) Subject: RE: MD Florida FACE Indictment (1/18) Fair point. Is thete a reason we can't say "p-r,egnancy resomce center" I think that might make it clearer for the public, but let me know if I'm missing something. From: Weiner, Robert {CRT) Sent:nTuesday, Jahuary 17, 2023 2:38 PM To: Bradford, Aryele (PAO) Catherine (PAO) Cc: Moossy, Robert (CRT) Kate (CRT) ; Gibson, Rose (CRT)n--; Morris, ; Felte, James (CRT)n�; Bernstein, Laura­ ; Patel, Sanjay (CRT) �; Fitzgerald, Paige (CRT) Subject: RE: MD Florida FACE Indictment (1/18) Given that this is the first prosecution of its kind we have done, how about adding at the end of the headline, "That Provide Abortion Alternatives"? So the full headline would read, "Two Defendants Indicted for Civil Rights Conspiracy and FACE Act Offenses Targeting Reproductive Health Services Facilities Tat Provide Abortion Alternatives." From: Bradford, Aryele (PAO) Sent:nTuesday, January 17, 2023 12:27 PM To: Gibson, Rose (CRT)n�; Morris, Catherine (PAO) ; Weiner, Robert (CRT) (CRT)n�; Bernstein, Laura-Kate (CRT) �; Fitzgerald, Paige (CRT) Subject: RE: MD Florida FACE Indictment (1/18) Cc: Moossy, Robert (CRT) ; Felte, James ; Patel, Sanjay (CRT) Thanks, Rose. Sharing additional edits. Flagging that Leadership will likely want to see this, so Rob can we get KC to sign off as soon as possible? AB From: Gibson, Rose (CRT)n� Sent: Tuesday, Jahuary 17, 2023 12 :17 PM To: Bradford, Aryele (PAO) Cc: Moossy, Robert (CRT) ; Weiner, Robert (CRT) (CRT)n�; Bernstein, Laura-Kate (CRT) �; Fitzgerald, Paige (CRT) Subject: RE: MD Florida FACE Indictment (1/18) ; Felte, James ; Patel, Sanjay (CRT) Please use this version instead. Thank youl Rose Gibson Deputy Chief, Crituinal Sectim1 Civil Rights Division U.S. De artment of Justice She/her/hers From: Gibson, Rose (CRT) Sent: Tuesday, January 17, 2023 6:02 AM To: Bradford, Aryele (PAO) Cc: Moossy, Robert (CRT) ; Weiner, Robert (CRT) (CRT)n�; Bernstein, Laura-Kate (CRT) �; Fitzgerald, Paige (CRT) Subject: MD Florida FACE Indictment (1/18) ; Fette, James ; Patel, Sanjay (CRT) Greetings, Attached please find a draft press release for U.S. v. Freestone et al. We expect to present this indictment tomorrow Wednesday January 18, 2023. We do not yet know when the indictment will be unsealed. The trial team will keep us up to update. This matter is being prosecuted by Laura-Kate Bernstein and Sanjay Patel from the Criminal Section in partnership With the USAO in the Middle District of Florida. Please let us know if you have questions. Thanks! Rose Gibson Deputy Chief, Criminal Section Civil Rights Division U.S. De artment of Justice She/her/hers EXHIBIT 014 From: "Wei.ner, Robe1t (CRT)" To: "Clarke, Kristen (CRT)" Cc: "Moossy, Robert (CRT)" Subject; FACE Act -- Pregnancy Resource Center Press Release Date: Tue, 17 Jan 2023 1 5 :08:30 -0500 Importance: Normal Attachments: MDFL_Freestone_and_Smithn_stewart_Press_Release_RGjf_OPA.docx Kristen, Attached is a press release for i ndictment expected tomorrow of a two Florida people for vandalizing a pregnancy resource center, one of the "pro- l ife" facilities that counsel patients to pursue alternatives to abortion. The defendants vandalized three facilities in Florida with spray painted threats such as, "If abortions aren't safe than niether [sic] are you," "YOUR TIME IS UP!!," "WE'RE COMING for U," and "We are everywhere." The defendants are accused of using threats of force to intimidate and interfere with the employees of a reproductive health facility and intentionally damaging and destroying the facility's property because the employees and the facility were providing reproductive health services. The charges include FACE Act violations and conspiracy. I proposed adding the words, "That Provide Abortion Alternatives/' at the end of the headline, which Aryele prefers. CRM prefers Aryele's alternative initial suggestion of "Two Defendants Indicted for Civil Rights Conspiracy and FACE Act Offenses Targeting Pregnancy Resource Centers." I'm fine either way, so long as we make dear in the headline that this case deals with anti-abortion centers. Aryele thinks Department le.adership should also review this release. The text of the release is reproduced below. Please let me know if you have any changes or questions. Thanks. Have a good trip back. Rob Two Defendants Indicted for Civil Rights Conspiracy and FACE Act Offenses Targeting Reproductive Health Services Facilities That Provide Abortion Alternatives WASHINGTON - Two Flo1·ida residents were indicted for federal offenses in connection with the alleged vandalism ofreproductive health services :facilities in the state. The indictment, renirned by a federal grand jrny in the Middle District of Florida, alleges that Caleb Freestone, 27, and Amber Smith-Stewart, 23, engaged in a conspiracy to prevent employees of reproductive health services facilities from providing those services. According to the indictment, as part of the conspiracy, the defendants targeted reproductive ]1ealth services facilities that provide abortion alternatives and vandalized those facilities with spray-painted threats. According to the indictment, Freestone and Smith-Stewart, and otbe1· co-conspirators, arc alleged to bavc spray painted threats, including "lf abortions aren't safe than nietber [sic] are you," "YOUR TJME rs lJP!!," "WE'RE COMING for U," and "We are everywhere" on a reproductive health services facility Florida. The indictment further aUeges that facilities in - Flotida and in Florida were also targeted. Tbe indictment also alleges that F'reesLOne and Smith-Stewart violated the FACE Act by u� force. to intimidate an,d interfere with the employees of a reproductive health services facility Lil -- because those employees were providing or seekmg to provide reproductive bealth services. The indictment further alleges that Freestone and Smith-Stewart violated the FACE Act by intentionally damaging and destroying the facility's property because the facility provides reproductive health services. If convicted of the offenses, Freestone and Smith-Stewart each face up to a maximum of 1 2 years in p1;son, three years of supervised release .ind tines of up to $350,000. Assistant Attorney General Kristen Clarke of the Justice Department's Civif Rights Division, U.S. Attomey Roger B. Handberg for the Middle District of Florida and LJNSERT FBI SACJ made U,e arn1ouncement. f The FBI Tampa Field Of ice investigated the case. Assistant U.S. AttOLney Lisa Tbelwell for the Middle District of Florida and Trial Attomeys, Sanjay Patel and Laura-Kate Bernstein of 1hc Civil Rights Division's Cr iminal Section arc prosecuting the case. Anyone who has infonnacton about incidents of violence, threats, and obstrnction that target a patient or provider of reproductive health services, or damage and destruction of reproductive health care facilities, shoufd report that infonnation to the FBI at www.tip�.fb1.gov. For more information about clinic violence, and the Department of Justice's efforts to enforce FACE Act violations, please visit wwwJ�gov/crl/naLional-lask- force-violence­ �gamst- reP-roductive-health-care-providers. An indictment is merely allegation. All defendants are preswned innocent until proven gzdlty beyond a reasonable doubt in a cow1 oflaw. EXHIBIT 015 From: "Clarke, Kristen (CRT)" To: " usccb.org" �usccb.org> Subject: FYI Date: Wed, 25 Jan 2023 12:00:01 -0500 Importance: Nonnal Mr. Balserak, I wanted to bring this matter to your attention. Thank you for your work. Two Defendants Indicted for Civil Rights Consi:1iracv. and FACE Act Offenses Targeting Pregnancv.Resource Centers I OPA I, DeJ:!artment of Justice Kristen Clarke Assistant Attorney General Civil Rights Division U.S. Department of J ustice EXHIBIT 016 From: "Clarke, Kristen (CRT)" To: "Dan Balserak." �usccb.org> Cc: "Anthony Granado" ausccb.org>. " Michelle Gress" "William Quinn" l usccb.org>, "Michael Moses" Subject: Update Date: Fri, l 3 Sep 2024 1 5:02:28 -0400 Importance: Normal c usccb.org>, e, usccb.org> Director Balserak, I am writing to flag an announcement regarding our ongoing efforts to address issues facing pregnancy resource centers. As always, please be in contact with the Justice Department at any time regarding these issues. A core principle underlying the Justice Department's enforcement of the FACE Act is that violence or threats of violence against patients or providers of reproductive health services is simply unacceptable. The Department will continue enforcing the Act evenhandedly to protect the rights of all patients and all providers, including pregnancy resource centers. Office of Public Affairs_ I Florida Man Sentenced for Civil Rights ConsP-1racyTargeting Pregnancy Resource Centers I United States DeP-artment of Justice Thanks to you and your colleagues for your work. Kristen Clarke Assistant Attorney General Civil Rights Division U.S. Department of Justice EXHIBIT 017 From: "Clarke, Kristen (CRT)" To: "�heartbeatinternational.org" Subject; New Matter Date: Sat, 09 Dec 2023 1 1 :32:30 -0500 Importance: Normal President Godsey: I am writing to inform you that a defendant in U.S. District Court for the Northern District of Ohio pied guilty plea yesterday to a violation of the FACE Act for attacking a pregnancy resource center. In her plea, Whitney M . Durant admitted that on April 15, 2023, she used spray paint to vandalize a pregnancy resource center, HerChoice, in Bowling Green, Ohio, Ms. Durant could receive up to a year in prison for her offense. The sentencing will occur at a later date. You can find further detail regarding this development here: Office of Public Affa irs I Ohio Woman Pleads Guilty to Freedom of Access to Clinic Entrances(FACE) Act Violation for Damag[ng Pregnancy Center I United States DeP-artment of Justice As I have previously said, the key principle underlying Justice Department's enforcement of the FACE Act is that violence or threats of violence against patients or providers of reproductive health services is unacceptable. The Department will enforce the Act evenhandedly to protect the rights of alf patients and all providers, including pregnancy resource centers. If you or your colleagues or members at Heartbeat International have information about incidents of violence, threats, or obstruction that target a patient or provider of reproductive health services or about efforts to damage reproductive health care facilities, please encourage them to report that information to the FBI at www.tiRs.fbi.gov. Providers needing assistance i n enhancing the security of their facilities should visit Civil Rights Division I Security, Recommendations to Enhance the Safety and Protection of Providers (justice.gov) or contact their local FBI Field Office. And, of course, if you or any of your colleagues or members face imminent danger, call 911. Kristen Clarke Assistant Attorney General Civil Rights Division U.S. Department of Justice EXHIBIT 018 From: "Clarke, Kristen (CRT)" To: "�usccb.org" �usccb.org> Subject: Important Development Date: Sat, 09 Dec 2023 1d1 :22:24 -0500 Importance: Normal Dear Mr. Balserak: I am writing to inform you that a defendant in U.S. District Court for the Northern District of Ohio pied guilty plea yesterday to a violation of the FACE Act for attacking a pregnancy resource center. In her plea, Whitney M . Durant admitted that on April 15, 2023, she used spray paint to vandalize a pregnancy resource center, HerChoice, in Bowling Green, Ohio. Ms. Durant could receive up to a year in prison for her offense. The sentencing will occur at a later date. You can find further detail regarding this development here: Office of Public Affairs I Ohio Woman Pleads Guilty to Freedom of Access to Clinic Entrances(FACE) Act Violation for Damaging Pregnancy Center I United States DeRartment of Justice As 1 have previously said, the key principle underlying Justice Department's enforcement of the FACE Act is that violence or threats of violence against patients or providers of reproductive health services is unacceptable. The Department will enforce the Act evenhandedly to protect the rights of al/ patients and all providers, including pregnancy resource centers. If you or your colleagues or members have information about incidents of violence, threats, or obstruction that target a patient or provlder of reproductive health services or about efforts to damage reproductive health care facilities, please encourage them to report that information to the FBI at www.ti�gm,i. Providers needing assistance in enhancing the security of their facilities should visit Civil Rights Division I Secuntv. Recommendations to Enhance th e Safety and Protection of Providers (justice.gov) or contact their local FBI Field Office. And, of course, if you or any of your colleagues or members face imminent danger, call 911. Kristen Clarke Assistant Attorney General Civil Rights Division U.S. Department of Justice EXHIBIT 019 From: "Clarke, Kristen (CRT)'' To: "�nifla.org" �nifla.org> Subject: New Matter Date: Sat� 09 Dec 2023 1 1 :26:05 -0500 Importance: Nonna! Mr. Glessner: I am writing to inform you that a defendant in U.S. District Court for the Northern District of Ohio pied guilty plea yesterday to a violation of the FACE Act for attacking a pregnancy resource center. In her plea, Whitney M . Durant admitted that on April 151 20231 she used spray paint to vandalize a pregnancy resource center, HerChoice, in Bowling Green, Ohio. Ms. Durant could receive up to a year in prison for her offense. The sentencing will occur at a later date. You can find further detail regarding this development here: Office of Public Affairs I Ohio Woman Pleads Guilty to Freedom of Access to Clinic Entrances (FACE) Act V!olation for Damagi.!Jg Pregnancy Center I United States DeP-artment of J ustice As I have previously said, the key principle underlying Justice Department's enforcement of the FACE Act is that violence or threats of violence against patients or providers of reproductive health services is unacceptable. The Department will enforce the Act evenhandedly to protect the rights of off patients and all providers, including pregnancy resource centers. If you or your colleagues or members at NIFLA have information about incidents of violence, threats, or obstruction that target a patient or provider of reproductive health services or about efforts to damage reproductive health care facilities, please encourage them to report that i nformation to the FBI at www.ti12s.fbi.gov. Providers needing assistance in enhancing the security of their facilities should visit Civil Rights Division I Security Recommendations to En hance the Safety and Protection of Providers (justice.gov) or contact their local FBI Field Office. And, of course, if you or any of your colleagues or members face imminent danger, call 911. Kristen Clarke Assistant Attorney General Civil Rights Division U.S. Department of Justice Kristen Clarke Assistant Attorney General Civil Rights Division U.S. Department of Justice EXHIBIT 020 To: "Roland Warren" Cc: "Patel, Sanjay (CRT)" Subject: RE: [EXTERNAL] Re: New Development Date: Wed, 13 Dec 2023 15:59:40 -0500 Jmportance: Normal lollne-lmages: ~WRD0000.jpg President Warren, Thank you for your response. I am connecting you with SanJay Patel who I know the organization has been in touch with concerning your request for an update on outstanding cases. I look forward to remaining in touch, Kristen Clarke Assistant Attorney General Civil Rights Division From: Roland Warren-..il@care-net.org> Sent! Saturday, December 9, 2023 9:44 PM To: Clarke, Kristen (CRT) Subject: [EXTERNAL) Re: New Development Ms. Clarke, Thank you for making me aware of this. I appreciate the 0OJ holding this woman accountable for her actions. That said, as you know, there have been many attacks on pregnancy centers, including firebombings. I am hopeful that these perpetrators will be prosecuted as well. Is there a way that we can get a more comprehensive update on outstanding cases? Best regards, Roland Roland C. Warren On Sat, Dec 9, 2023 at 11:23 AM Clarke, Kristen (CRT) wrote: Dear Mr. Warren: I am writing to inform you that a defendant in U.S. District Court for the Northern Distrkt of Ohio pied guilty plea yesterday to a violation of the FACE Act for attacking a pregnancy resource center. In her plea, Whitney M. Durant admitted that on April 15, 2023, she used spray paint to vandalize a pregnancy resource center, HerChoice, in Bowling Green, Ohio. Ms. Durant could receive up to a year in prison for her offense. The sentencing will occur at a later date. You can find further detail regarding this development here: Office of PublicAffairs I Ohio Woman PleadsGuiltv. to Freedom of Access to Clinic Entrances(EAC.E).fil.t Violation for Damag[ng Pregnancy Center I Un ited States Degartment of Justice As I have previously said, the key principle underlying Justice Department's enforcement of the FACE Act is that violence or threats of violence against patients or providers of reproductive health services is unacceptable. The Department will enforce the Act evenhandedly to protect the rights of all patients and all providers, including pregnancy resource centers. If you or your colleagues or members have information about incidents of violence, threats, or obstruction that target a patient or provider of reproductive health services or about efforts to damage reproductive health care facilities, please encourage them to report that information to the FBI at www.tiP-s.fbi.gov. Providers needing assistance in enhancing the security of their facilities should visit Civil Rights D ivision I. Security Recommendationsto Enhance the Safetyand Protection of Providers(justice.gQY). or contact their local FBI Field Office. And, of course, if you or any of your colleagues or members face imminent danger, call 911. Kristen Clarke Assistant Attorney General Civil Rights Division U.S. Department of Justice EXHIBIT 021 From: "Clarke, Kristen (CRT)'' To: "�usccb.orgd"' Subject: FYl Date: Fri, 20 Dec 2024 22:37:52 -0500 lmportance: Normal Mr. Balserak, I am writing to flag a new development in one of our cases concerning a pregnancy resource center in Florida. Please see below. The Justice Department will continue to ensure access to the full spectrum of reproductive health services afforded to the public, whether those services include abortion or counseling on alternatives to abortion. Office ofpublic Affairs I Florida Woman Convicted of Civil Rights ComP-iracv. Targeting Pregnancy Resource Centers I United States DeP-artment of Justice If you or your colleagues or members at Heartbeat International have information about incidents of violence, threats, or obstruction that target a patient or provider of reproductive health services or about efforts to damage reproductive health care facilities, please encourage them to report that information to the FBI at www.tiRs.fbi.gov. Providers needing assistance in enhancing the security of their facilities should visit Civil Rights Division I Secuntv. Recommendations to Enhance the Safety and Protection of Providers(justice.gill{) or contact their local FBI Field Office. As always, if you or any of your colleagues or members face imminent danger, call 911. Thank you for your leadership and advocacy. Kristeh Clarke Assistant Attorney General Civil Rights Division U.S. Department of Justice EXHIBIT 022 From: "Clarke, Kristen (CRT)'' To: "-nifla.org"' �ifla.oTg> Subject: FYl Date: Fri, 20 Dec 2024 22:37:02 -0500 Importance: Normal Mr. Glessner, I am writing to flag a new development in one of our cases concerning a pregnancy resource center in Florida. Please see below. The Justice Department will continue to ensure access to the full spectrum of reproductive health services afforded to the public, whether those services include abortion o r counseling on alternatives to abortion. Office of Public Affairs I Florida Woman Convicted of Civil Rights ConsP-iracy Targeting Pregnancy Resource Centers I United States DeP-artment of Justice If you or your colleagues or members at Heartbeat International have information about incidents of violence, threats, or obstruction that target a patient or provider of reproductive health services or about efforts to damage reproductive health care facilities, please encourage them to report that information to the FBI at www.tiRs.fbi.gov. Providers needing assistance in enhancing the security of their facilities should visit Civil Rights Division I Se curity Recommendations to Enhance the Safe!Y. and Protection of Providers(justice.gov) or contact their local FBI Field Office. And, of course, if you or any of your colleagues or members face imminent danger, call 911. Thank you for your leadership and advocacy. Kristen Clarke Assistant Attorney General Civil Rights Division U.S. Department of Justice EXHIBIT 023 From: "Clarke, Kristen (CRT)" To: '�heartbeatintemational.org'" �beartbeatintemational.org> Subject: FYI Date: Fri, 20 Dec 2024 22:35:32e-0500 Importance: No1mal President Godsey: I am writing to flag a new development in one of our cases concerning a pregnancy resource center in Florida. Please see below. The Justice Department will continue to ensure access to the full spectrum of reproductive health services afforded to the public, whether those services include abortion or counseling on alternatives to abortion. Office of Public Affairs I Florida Woman Convicted of Civil Rights ConsP-ira� Targeting Pregnancv. Resource Centers United States DeP-artment of Justice I If you or your colleagues or members at Heartbeat International have information about incidents of violence, threats, or obstruction that target a patient or provider of reproductive health services or about efforts to damage reproductive health care facilities, please encourage them to report that information to the FBI at www.tiP-s.fbi.gov. Providers needing assistance in enhancing the security of their facilities should visit Civil Rights Division I SecurityRecommendations to Enhance the Safety and Protection of Providers(justice.gov) or contact their local FBI Field Office. And, of course, i f you or any of your colleagues or members face imminent danger, call 911. Thank you for your leadership and aqvocacy. Kristen Clarke Assistant Attorney General Civil Rights Division U.S. Department of Justice EXHIBIT 024 From: "Clarke, Kristen (CRT)" To: "�care-net.org" �care-net.erg> Subject: FYI Date: Fri, 20 Dec 2024 22:34:20 -0500 Importance: No1mal President Warren, I am writing to flag a new development in one of our cases concerning a pregnancy resource center in Florida. Please see below. The Justice Department will continue to ensure access to the full spectrum of reproductive health services afforded to the public, whether those services include abortion or counseling on alternatives to abortion. Office of Public Affairs I Florida Woman Convicted of CJvil Rights ConsQiracy Targeting Pregnancy Resource Centers I United States Oegartment of Justice Thank you for your leadership and advocacy. Kristen Clarke Assistant Attorney General Civil Rights Division U.S. Department of Justice EXHIBIT 025 From: "Patel, Sanjayn(CRT)'' To: Roland Warren �care-net.org> Cc: Dan Bfllserak ccb.org" org>, Vin t.oro>, ' " • nifla a usccb.org" �usccb.org>. Michelle Gress >, ...a@care- net.orf' c. nifla.org>, Tom Glessner . rg>, rnational.org atinternational.o!'g>, ''Trudden, artbeatinternational.org>, cvbeartbeatinternational.org" ternational.or >, Danielle \\'hite • Taskforce, Clinicviolenoe (CRT)" , "Channapati, Anita (CRT)" Subject: RE: [EXTERNAL] Re: FL defendants sentenced for targeting pregnancy resow-ce centers Date: Wed, 1 6 Oct 2024 08:21:32e-0400 Iuline-Images: ~WRD0002.jpg [E.\."TERNAL EMALLI DO NOT CLLCK llnks or op�1, ntta�hmtnls unless J"liU rc�ognizc thia scucl,crand know the cu111eo1 is safe. Good morning, Roland Your request for a report and FACE Act prosecution listing would have to be routed through the Department's Freedom of Information Act Unit (FOIA). I'm including a link below where you can submit the request. At our meeting, Anita and I can share with you some general information about the Department's FACE Act prosecutions following Dobbs, including those brought against defendants who targeted pro-life facilities. Bestj SP httP-s://www.justice.gov/olP-lmake-foia-reguest-doj From: Roland Warren� Sent: Tuesday, October 15, 2024 7:40 PM To: Patel, Sanjay (CRT)e� Cc: Dan Balserak �usccb.org>; -@usccb.org-@usccb.org; Michelle Gress �usccb.org>; Vince Dicaro �care-net.erg>; -@care-net.org; lllllll@nifla.org; Totn Glessner �;-@nifla.org�hear:beatinternational.org; Trudden, Andrea �@heartbeatinternational.org>; -@heartbeatinternational.org; Danielle White <11111@heartbeatintemational.org>; Taskforce, Clinicviolence (CRT) ; Ct,annapati, Anita (CRT) Subject: Re: [EXTERNAL] Re: FL defendants senten.ced for targeting pregnancy resource centers Sanjay, Thanks for your willingness to meet to discuss this. However, to ensure that this meeting is fact-based and a good use of time, I would like to see a report regarding the enforcement of the FACE Act since the overturning of Roe. Specifically, l would like to see a listing of charges/convictions sorted by those charged related to pro-life facilities and those related to abortion facilities. Moreover, I would like a description of the charges and, if convicted or not, and the resulUng sentence. Please advise. Thanks, Roland Roland C. Warren On Sun, Sep 1 5, 2024 at 2:12 PM Patel, Sanjay (CRT) wrote: Hello, Roland I really appreciate your email, and would invite you to discuss the concerns you raised. There are many distinguishing factors that account for ar,y sentence imposed by a federal court judge. The case you mentioned, like others, are quite distinguishable from each other, and from the Freestone case that I shared with you. I'm happy to convene a meeting to discuss. Pl.ease let me know what date/time works best for you. Best, SanJay From: Roland Warrene�> Sent: Friday, September 13, 2024 10:30 PM To; Patel, Sanjay (CRl) � Cc: Dan Balserak �; �usccb. b.org; Michelle Gress • iCaro �care-net.org>; -nifla.org; Tom Glessner > · === nifia.org ·oternational. org; Trudden, Andrea • • ====""'--'-'=io=n=a=l.o=rg>; bea in erna • • • iolence (CRT) llllllll@heartbeatinte • • Channapati, Anita (CRT) Subject: [EXTERNAL) Re: FL defendants sentenced for targeting pregnancy resource centers Sanjay, Thank you for the update. However, I would be remiss if I did not point out that pro-choice activists doing acts that violate the FACE Act are getting significantly less severe punishment than pro-life people. A case i n point is the treatment of Paulette Harlow, a 75 year old woman who was praying i n a DC abortion clinic. She was sentenced to 24 months i n prison. Others with her received similarly severe treatment: Harlow's sister Jean Marshall, 74, was sentenced to 24 months in prison. Also sentenced: Heather ldoni, 59 (24 months in prison); Lauren Handy, 30; John Hinshaw, 69; William Goodman, 54 (27 months in prison); Joan Bell, 76 (27 months in prison); and Herb Geraghty, 27 (27 months in prison). There are many other cases with similar and longer sentences given to pro-life people for violating the FACE Act. The bottom line is that there appears to be a double standard in these cases and not equal treatment under the law. So, I would like to know why this is happening and what will be done to deal with the seemingly biased admin istration of the law. Regards, Roland ,. Roland C. Warren ' On Fri, Sep 1 3, 2024 at 8:26 AM Patel, Sanjay (CRT) wrote: AlleI hope this email finds you well. Passing along an update about the Department's Florida prosecution against defendants who targeted pregnancy resource centers throughout the state. In June, I shared news that three of the four defendants charged had pleaded guilty to felony civil rights offenses for their involvement in vandalizing these clinics with threatening graffiti. Yesterday, those three defendants were sentenced in federal court. More information about that is available here: Office of Public Affairs I Florida Man Sentenced for Civil Rights Consgiracy Targeting Pregnancy Resource Centers I United States Department of Justice Regardless of viewpoint, the Department is committed to prosecuting anyone who uses violence to violate access to reproductive health care. Such conduct will not be tolerated. and the Department will vigorously prosecute those who violate civil rights, which includes access to reproductive health care free from violence and obstruction. Please feel free to contact me or my partner, Anita Channapati (cc'd) should the need arise. Best, Sa njay Sanjay Patel Director National Task Force on Violence Against Reproductive Health Care Providers U . S . Department of Justice Civil Rights Division --· C. https://www.justice.gov/crt/national-task-force-violence-against-reproductive-health-care­ P-roviders EXHIBIT 026 From: "Karlan, Pamela (CRT)" To: "Felte, James (CRT)" Subject: Texas and the FACE Act Date: Thu, 02 Sep 2021 10:28: 13 -0400 Importance: Nonnal Dear Jim and Paige, Sparkle and Adam from OASG came to me to say that the AG raised the possibility at the morning leadership meeting whether DOJ should put out some kind of statement or letter today reminding everyone and reassuring clinics that the FACE Act is there. I'm not sure exactly what he's looking for, but thought you might be the right person to discuss this with them because of CRM's FACE Act work. I'm looping in the other DAAGs (I'm coming straight to you in CRM, because Robert may be offline this morning.) So now that I've connected everyone, I fear I'll be out of pocket shortly for my trip to the backcountry. But I'll be able to check email for another hour or so if something comes up. Take care, Pam Pamela S. Karlan Principal Deputy Assistant Attorney General Civil Rights Division �ent of Justice -- (mobile) EXHIBIT 027 Event: HOLD-- Calls to NGOs, Marsha ll Service & TX US Attys Start Date: 20210-09-02 1 6:00:00 -0400 End Date: 2021 -09-02 1 7:00:00 -0400 Organizer: Clarke, Kristen (CRT) Class: X-PERSONAL Date Created: 2024-101 - 1 0 09:42:40 -0500 Date Modified: 2024-101 - 1 0 09:42:40 -0500 Priority: 5 EXHIBIT 028 'From: "Clarke, Kristen (CRT)" To:t" ppfa.org" -ppfa.org> Subject: FACE Act Compliance Date; Thu, 02 Sep 2021 1 8 : 0 l :56 -0400 Importance: Nonnal Alexis, I wanted to connect with you briefly regarding the situation in Texas. Note that we are on high alert when it comes to ensuring freedom of access to clinics; we are committed to using the FACE Act to hold accountable those who may seek to obstruct access to clinics. Please call me at your convenience. I can be reached aKristen Kristen Clarke Assistant Attorney General Civil Rights Division U.S. Department of Justice Tel : EXHIBIT 029 Subject: RE: FACE ACT TF Meeting Date: Wed, 04 May 2022 08:08:23 -0400 Importance: Nonnal Good morning, - Apologies for the delay responding (I've been in transit bw cities for work). You read my mind, and I was planning to convene a meeting of the TF only to discuss potential fallout before any larger meeting with providers, which I suspect will be loaded with questions. I'll send ,i n invite out shortly for a meeting Fridqy morning. SP From: � Sent: Tuesday, May 3, 2022 11:37 AM {CID) (FBI)i.-;i-. To: Patel, Sanjay (CRT)i--; (CTD) (FBI)i�;i- (CTD) (FBI)i� Subject: FACE ACT TF Meeting Sanjay, On our last FACE Act Task Force meeting in March, you indicated you wanted to host a NGO Security Director meetlng for late April, early May. In light of everything going on, it seems like a good opportunity to touch base and get ahead of any would-be threa.ts. Do you still plan to set up a call? If so, when? Thank you! Unit Chief CTD/DTOS/Northeast - (Cell) (Desk) EXHIBIT 030 From: "Patel, Sanjay (CRT)" Sub.iect: Clinic Violence Task Force meeting Date: Wed, 04 May 2022 09:52:20 �0400 Importance: Normal Attachments: unnamed Given the leaked SCOTUS opinion, I would like to convene a meeting to discuss questions/concerns I've been receiving from the provider community and our local federal partners. This meeting will be TF only, and not .include any providers or NGOs. This is very short notice, and l understand if some of you are unavaih\blc. If you cannot make it, please let me know if there are any topics/concerns you believe the TF should discuss. Thank yo11, Sanjay Microsoft Tea ms meeting Or call in. (audio only) I Find a local number Reset PIN Learn Mme I Meeting...Qi;itions EXHIBIT 031 From: "Felte, James (CR'T To: "Taskf (CRT)" • . , Clinicviotence " ", Daniel pis.gov>. ) (FBI)" ·chelle t.org>, "Noah, ilson" ' (CRT)" TY' "Fitzgerald, Paige (CRT)" Subject: FW: Attorney General Merrick B. Garland Statement on Supreme Court Ruling i.n Dobbs v. Jackson Women's Healtll Organization Date: Fn, 24 Jun 2022 16:36: 15 -0400 Importance: Normal All, In light of the Supreme Court's ruling today in Dobbs, I wanted to share the below statement from Attorney General Garland. Jim Felte Chief, Crrminal Section Civil Rights Division U.S. Department of Justice The U nited States Department of Justice FOR IMMEDIATE RELEASE V..TWW.JUSTICE.GOV/NEWS June 24, 2022 Atton1ey General Merrick B. Garland Statement on Supreme Court Ruling in Dobbs v. Jackson Women's Health Organization WASHINGTON - Attorney General Merrick B. Garland today released the following statement following the Supreme Court's decision in Dobbs) State Health Officer of the Mississippi Department of Health, et al. v. Jackson Women's Health Organizah"on et at: "Today) the Supreme Court overturned Roe v. Wade and Planned Parenthood V­ easey and held that the right to abortion is no longer protected by the Constitution. "The Supreme Court has eliminated an established right that has been an essential component of women's liberty for half a century - a right that has safeguarded women's ability to participate fully and equally in society. And in renouncing this fundamental right, which it had repeatedly recognized and reaffirmed, the Court has upended the doctrine of stare decisis, a key pillar of the rule of law. "The Justice Department strongly disagrees with the Court's decision. This decision deals a devastating blow to reproductive freedom in the United States. It will have an immediate and irreversible impact on the lives of people across the country. And it will be greatly dispropmtionate in its effect - with the greatest burdens felt by people of color and those of li.Jnited financial means. *** "But today's decision does not eliminate the ability of states to keep abortion legal within their borders. And the Constitution continues to restrict states' authority to ban reproductive services provided outside their borders. "We recognize that traveling to obtain reproductive care may not be feasible in many circumstances. But under bedTock constitutional principles, women who reside in states that have banned access to comprehensive reproductive care must remain free to seek that care in states where it is legal. Moreover, under fundamental First Amendment principles, individuals must remain free to inform and counsel each other about the reproductive care that is available in other states. �'Advocates with different views on this issue have the right to, and will, voice their opinions. Peacefully expressing a view is protected by the First Amendment. But we must be clear that violence and threats of violence are not. The Justice Department will not tolerate such acts. ''The Justice Depa1tment will work tirelessly to protect and advance reproductive freedom. "Under the Freedom of Access to Clinic Entrances Act, the Department will continue to protect healthcare providers and individuals seeking reproductive health services in states where those services remain legal. This law prohibits anyone from obstructing access to reproductive health services through violence, threats of violence, or property damage. "The Department strongly supports efforts by Congress to codify Americans' reproductive rights, which it retains the authority to do. We also support other legislative effo1ts to ensure access to comprehensive reproductive services. "And we stand ready to work with other arms of the federal government that seek to use their lawful authorities to protect and preserve access to reproductive care. In particular, the FDA has approved the use of the medication Mifepristone. States may not ban Mifepristone based on disagreement with the FDA's expert judgment about its safety and efficacy. "Furthermore, federal agencies may continue to provide reproductive health services to the extent authorized by federal law. And federal employees who carry out their duties by providing such services must be allowed to do so free from the threat of liability. It is tbe Department's longstanding position that States generally may not impose criminal or civil liability on federal employees who perform their duties in a manner authorized by federal law. Additionally, the Department's Office of Legal Counsel has determined that federal employees engaging in such conduct would not violate the Assimilative Crimes Act and could not be prosecuted by the federal government under that law. The Justice Department is prepared to assist agencies in resolving any questions about the scope of their authority to provide reproductive care. ''The ability to decide one's own future is a fundamental American value, and few decisions are more significant and personal than the choice of whether and when to have children. "Few rights are more central to individual freedom tban the right to control one's own body. "The Justice Department will use every tool at our disposal to protect reproductive freedom. And we will not waver from this Department's founding responsibility to protect the civil rights of all Ameiicans." ### OAG 22-663 Do not reply to this message. If you have questions, please use the contacts in the message or call the Office of Public Affairs at 202-514-2007. EXHIBIT 032 'From: "Weiner, Robert (CRT)" To: "Bond, Rebecca CRT)" , "Clarke; Kristen (CRT)" Subject: RE: Leadership Conference Meeting on Reproductive Rights Date: Mon, 25 Jul 2022 21 :45 : 1 0 -0400 Importance: Normal The speakers uniformly expressed gratitude for DOJ's strong commitment to reproductive rights, to a point that Maya Wiley asked them to dispense with the thanks because. it was taking up too much time. The AG, DAG and Associate all spoke. Vanita said that you wanted to be there but you were in transit. She point out that CRT was represented in the meeting. All three DOJ speakers referred to the post-Dobbs response as a core civil rights issue. I will focus primarily on what the groups had to say, with some indication of DOJ responses, but I c<;1n provide. further readout of the leadership statements if you want. The speakers from the groups hewed fairly closely to the agenda. of NARAL Pro-Choice America asked about the Task Force and how the groups could stay connected to DOJ's work. Vanita identified Jodie Moore as the point of contact and said that there would be a series of calls with different collections of the groups. of Planned Parenthood reported that they had seen increased harassment of providers. She is grateful for our FACE Act enforcement and the local briefings we have done. She said that there needed to be more trainings of local law enforcement, and the FACE Act needed to extend to all sorts of threats, including cybersecurity and doxing. She also noted that there was a tremendous influx of patients into states where abortion is legal. She said it was important to ensure patients have the right to travel. The AG responded that the right to travel is "core" and is protected by multiple constitutional provisions. He referred to the upcoming pro bona convening as a way to get representation for women whose rights are infringed. of the National Health Law Project acknowledged our issuance of the 1557 NPRM. She also said that federal law requires states to provide abortions that fall within the Hyde. Amendment exceptions, but that states were not complying even before Dobbs, Recognizing the litigation risks, she urged DOJ and HHS to pursue those issues. of the National Women's Law Center focused primarily o n whether the Administration would declare a medical emergency under the PREP Act (Public Readiness and Emergency Preparedness Act) to deal with the crisis i n access to abortion. HHS could use the PREP Act to require that states not interfere with the use of medication abortions as a way to ameliorate the crisis. The AG said that DOJ was advising HHS on the issue, but he could not disclose the substance of our advice. There· was no push back on that point, but Maya Wiley added that the groups wanted DOJ to be aggressive and to take risks in dealing with the crisis. of the Center for Reproductive Rights said that there were three dozen pending abortion rights cases, and that states were trying to claw back rights previously granted. - of the National Action Network expressed concerns about the criminalization of abortion, but said they would discuss the issue in more detail with the DOJ Task Force. of the National Latina Institute for Reproductive Justice expressed concern a pout abortion rights for imrnigrants. They are unable to travel to get healthcare. Moreover, immigrants are concerned that OHS will treat abortion convictions as grounds for deportation. The DAG said that she had held a quarterly meeting with immigration rights groups earlier in the day and was focused on the problem. Vanita said she would flag the issue as an area of concern in the interagency task force. Rodriguez also expressed concern about vigilante actions against immigrants under S88. She said that there was potential for communities of colo-r to be targeted under such statutes. The AG said that the absence of judicial review enabled discrimination in enforcement and was incompatible with the rule of law. - of the National Action Network pointed out that blacks were more likely to be criminally prosecuted for abortion. Vanita said that it was Important for the groups to keep us informed as they see specific threats to individual rights and discrimination. - of the National Council of Jewish Women accused the Supreme Court of legislating one religion's conception of when life begins. That belief is inconsistent with Jewish theology. In fact, Jewish law requires abortions in some circumstances (e·.g., to save the life of the mother). She said that rabbis were worried about going to jail, but were also talking about setting up religious-based reproductive clinics. The clergy want further dialogue. She also noted that the threats under the FACE Act were intersecting with white supremacists' activities. The AG said that the Department was very focused on that issue, and that the FBI was tracking attacks on religious institutions. Vanita said that CRT was dealing with violence against religious groups. of the Human Rights Campaign expressed fear that the closure of clinics would deny transgender people gender-affirming care. She is also concerned about the legality of IVF, which LGBTQ+ people rely on. The AG said that we would do everything we can to protect these rights. of In Our Own Voice, a group focused on the reproductive rights of black women, asked how DOJ would protect women who get an abortion in a state where it is legal but are prosecuted in the state where they live. The AG said that the Constitution protected the right to travel to another state to get a legal abortion, but that did not guarantee the absence of prosecutions. He said that DOJ would not bring such cases. of the Lawyers' Committee expressed concern that criminalization of abortion would lead to people being denied access to public housing because of abortion convictions. He also note the prospect of discriminatory enforcement in school systems. The AG said that H U D and DOE are tracking these issues, and we are advisirig them. - of the National Partnership for Women and Families said that the groups cannot easily access the data necessary to show discrimination. She wondered whether DOJ could help on that issue. - of the National Urban League expressed concern that criminalization of abortion might affect the ability of entrepreneurs to get SBA loans, or impede the ability of some to get security clearances. The AG saict that we h ad not thought about those isst.1es, but that they merited attention. Maya Wiley said that the meeting itself was a signal of DOJ's commitment to working with the groups and the priority It is giving the issue of reproductive rights. I think their gratitude for DOJ's commitment is heartfelt. Please let me know if you have questions or would like elaboration on any of the issues above. Best, Rob > From: Bond, Rebecca (CRT) Sent: Monday, July 25, 2022 6:32 PM To: Clarke, Kristen (CRT) Cc: Weiner, Robert (CRT) Subject: Leadership Conference Meeting on Reproductive Rights Hi Kristen, I hope that your speech went well and that you have a safe flight home. Attached please find the agenda and list of attende.es for this afternoon's Leadership Conference meeting with the Attorney General. Rob is preparing a read.out. For the most part, the groups hewed closely to the topics idehtifled on the agenda and expressed much appreciation for the Department's efforts, including the Division's FACE-related work. Maya Wiley also acknowledged that the Division had met with the Leadership Conference recently. Although not listed on the attached agenda, both Lisa Monaco and Vanita gave opening remarks. Lisa's remarks focused on safety issues, and Vanita's focused on the work of the Reproductive Rights Task Force. Vanrta also explained that you were in transit and highlighted that we were there to represent the Civil Rights Division. Thanks, Rebecca EXHIBIT 033 From: "Clarke, Kristen (CRT)" To: " Robert Ledogar" �prochoice.org> Cc: "Cheung-Smith, Bridget (CRT)" Subject: RE: NAF Secttrity DC area trlp - March for Life Date: Tue, 10 Jan2023 22:37:43 -0500 Importance: Normal lnline-Images: image002.jpg Mr. Ledogar, Thank you for your message. I would be pleased to meet with you during your time in D.C. I have copied my assistant who will help us coordinate. Regards, Kristen Clarke Assistant Attorney General Civil Rights Division U.S. Department of Justice From: Robert Ledogar .::allllll@prochoice.org> Sent: Monday, January 9, 2023 12:47 PM To: Clarke, Kristen {CRT) Subject: [EXTERNAL] NAF Security DC area tri p • March for Life Good Day Ma'am, I'm not sure if we meet, I am Robert Ledogar at NAF Security. I hope the holiday season was good and the New Year is going well. For this year's March for Life events, I'll be in the DC area on Sl!nday 1/5 thru Sunday 1/22. I will be visiting with several NAF members facilities to discuss security awareness and offer any assistance needed. My back ground is 32 years of military and federal law enforcement. I served for almost 7 years in the US Navy with security, investigations and instructor. Then went onto the U S Marshals Service, where I served 25 years in E/NY as a Deputy and then a Supervisory Deputy US Marshal. I had quite a n amazing and tough career. I was fortunate enough to develop great relationships with AUSA's In E/NY, mainly the criminal division. In my position at NAF, I am the Southeast Regional Security Manager; which has me conducting training and assessments. In order to fully support the members of NAF, attending conferences and rally's such as the March for Life, so that we can identify and witness the extremists that find the need to prevent reproductive health care. Over the past two (2) years that I have been with NAF Security, I have witnessed a n amazing relationship with the NAF Security Director Michelle Davidson and members of the DOJ Civil Right Division AUSA Sanjay Patel, AUSA Katelyn Smith, AUSA La[.lra Cowall and Supervisor AUSA Paige Fitzgerald. The past year, NAF Security has been part of several FACE Act investigations, working with AUSA's and FBI in TN, FL, VA, CA, NY, MD and NC. the guidance from the team i n DC has been nothing short of superb. If I may request, as I mentioned I will be in DC for the week of January 1s t\ if time permits with your schedule I would be honored to meet with you and Thank You in person. I am available at your convenience. Respectfully, Robert Ledogar NAF Secuntv. SE Security Manager Conffdentlallty Nollce: This e-mail message, including any attachments, is for the sole use of the intended recipient, and may contain confid'ential and privileged information. Any unauthorized review, use, disclosure_, or distribution Is prohibited. If you have received this e-mail in error, please rmmediately notify the sender by e-mail at the address shown. Please delete it from your filesif you are not the intended recipient. Thank you For your compliance. EXHIBIT 034 From: "Ch.ettng-Smith, Bridget (CRT)" To: "Clarke, Kristen (CRT " Subject: Meeting - AAG Clarke and NAF Secuirty Robert Ledogar Date: Tue, 1 7 Jan2023 13:45:02 -0500 Importance: Nonnal Attachments: mmamed EXHIBIT 035 From: "Weiner, Robert (CRT)" To: "Robert Ledogar" �prochoice.org> Subject: RE: FYSA: NAF Secmity Ale.rt 2024 March fot Life Protests in D.C. & Nationwide - Jan. 19 (Jan-Mar) Date: Wed, 1 7 Jan 2024 1 5 :57: 1 8 -0500 Importance: Norn1al lnline-(mages: imageOOl .j pg; image002.jpg; image003.jpg; image004.jpg; image005.jpg; image006.jpg; image007.jpg; image008.jpg; image009..jpg; imageOl O.j pg; image01 1 .jpg; image0 12.jpg; image013.jpg; in1age014.jpg; image015.jpg; imageOl 6.jpg; imageO l 7.jpg; image018.jpg; imageOJ 9.jpg; image020.jpg; image02 I .j pg; image022.jpg; image023.jpg; i.mage024Jpg; image025.jpg; image026.jpg; image027.jpg; image028.jpg; image029Jpg; image030.jpg; image03 l jpg Mr. Ledogar, Paige Fitzgerald and I are looking forward to meeting you at 3 PM tomorrow. Please come to the Justice Department entrance on Constftutlon Ave between 9 th and 10th Streets, N.W. After you get through securfty there, someone from the Civil Rights Division Front Office will come escort you to our conference room. Best regards, Rob Weirier From: Robert Ledogar�@prochoice.org> I Sent: Friday, January 12, 2024 1 :28 PM To: Weiner, Robert (CRT) Subject: [EXTERNAL) FYSA: NAF Security Alert: 2024 March for Life Protests in O.C. & Nationwide - .Ian. 19 (Jan-Mar) Good day Sir, I would like to share this with you, as this information Is pushed over to our organization, members, law enforcement and community officials; all for security awareness. Best Bob - Robert Ledogar NAF Security, SE Region For Your Situational Awarenes ... The i;1 ,t �nnual Marrh for Lift> (M4L) has been scheduled to occur on Friday. January 19, 2024, in Washington D.C. The annual event garners significant attention and support from pro-life members, with hundreds to thousands of participants possibly attending. According to the event webpage1 Marchfor Life 2024, it does not appear that the group plans on protesting outside NAF or Planhed Parenthood facilities in the area on the day of the event; however, due to the large number of protesters and counter-protesters that typically attend this event, the probability of this occurring remains highly likely, The event page also urges, participants to remain peaceful and not to engage counter-protesters. The event in Washington, D.C. is planned to begin at approximately 11:00am local time and occur until approximately 4:00pm. The rally itself will take place at 12:00pm local time and will begin at 12th St. on the National Mall, between Madison Drive and Jefferson Drive. Following the rally, the march will begin on Constitution Avenue between 12th and 14th Streets at approximately 1:00 pm local time. Participants will then march to the steps of the U.S. Capitol Building. Additionally, multiple protests have been planned to occur at the Supreme Court of the United States (SCOTUS) and other venues in Washington, D.C in the days before, during, and after the main March for Life events. Several known groups of interest GOI), including the Progressive Anti-Abortion URris1ng (PAAU), among others, are expected to participate in the protest activity. At this time, a Facebook event for the "2024 March for Life" lists 43 people as attending and 72 people as interested in attending the protest on Friday, January 19. Participants are encouraged to RSVP on the M4L website. and the number of those expected to attend the protest is expected to rise as the event date approaches. In addition to the main March for Life event in Washington, D.C., additional protests at various locations across the U.S., and on different days, have also been planned to coincide with the March for Life protests in Washington, D.C., some of which are planned to occur outside Planned Parenthood locations or other women's medical health facilities. Known groups of interest (GOls) Priests for Life and known person of interest (POI)- have once again planned to conduct a "£rnerand Protestat Planned Parenthood" protest event on the day before the march, Thursday, January 18, at the Planned Parenthood, . The protest is planned to begin at approximately 9:00am local time and is expected to be peaceful; however, this cannot be confirmed. Additionally, this protest will very likely inspire counter-protests from pro-choice supporters that will increase the possibility of violence at the location. At this time, it is unclear how many people Intend on attending the protest as no Face book event page for the demonstration has been discovered at this time. Protests associated with March for Life are planned to occur until at least March 2024, with additional events occurring between April and October. According to M4L's locationswebpage., upcoming March for Life protests are scheduled in Virginia, MD, Atlanta, GA, Denver, CO. Springfield, IL, Sacramento, CA. Phoenix, AZ, Hartford. CT. Additionally, Facebook event pages have been discovered for several March for Life protests this month, including Dallas,n, Carthag�,n, Saint Petersburg,__fl, -and Togeka, KS. The protests are intended to be peaceful but have inspired counter-protests from pro­ choice supporters that will Increase the possibility of violence at some locations. In addition, some locations could have up to 100 protesters or more, but this is currently difficult to determine. OTTOM l!I -1 � Thi �unn,d Vla•;hlll�!OII, flt: IIWil!1 :;; w,..,� Hw,,• ,t -!. < CJ CJ PENN OUAR ER [,'ST E�O t'J I; 3S min L. l , ,. � CAPllOl Hill l!J M4L website Images: MAR�LIFE NEW ROUTE tnord-!-r tonurKnot onJyourvic.tClrv •nc::JolJlnbut �.soot.r nHa11i,erson to or�I re.nclpro•m«t,ontes,sl:;to,s 3!<��- holpini;lh-:fP7f.le-..�o:r&'E.;intheft,:nii• ,.,._,.a,n,o!'T;,t·'!;!\C'iC...P,-tulM ;;-, tnt1....,,.•.wur,ortht.S,.1P-8M.<:1»1:1t97?Roe1rW>dtrvi0t�,k.:,..\I� � �.,. i I SOst.l�t,S. ,t�s.tM br,e-t IN'I'"- �nNfil.::s�ll'IOtd!tJt.�•1\ t� WO'\d.6\Jtctl, so«.(� "l.avcw-L i"t)C£'tt4!.li.,Vlt.CA.Tl-lflt70ctLf=&AAT! Uft Wtt'!"!t�ltU:.l\��M�fl'l;lffl,thc�t-o-t��\•,t�:t� -.w.,I .Sw\c.>•_....,., �-.i :a!•bo-1-td .--.�4.,..P'CCtY.r.-.t !, W•N"lollC4"', >V-C,fl.i� ..,�,.,....._tc:,V11�• *.bnt� V�:...a,d .-.li,:"v�b't t',trt.tor!·-OQCh, , !,":.bl Of'l\•tt u:,to,Md ll'ltht Ol.lbi<�'- WHY WILL WE CONTINUE TO MARCH? Evel'lwith thewol'ICferftJI blessing of Ree\ W.ade being ovefturned. which .allows more frttdom at the state level to enact pro-life laws, the nem. inch.iding even keeping longstandirro Hyde pr-ot�tioru. wl, ch limit government funding for .ibortionon annua appropriation bills. The HydeAmendmenthas saved over 2 million lives .nd 1s arguably the most impactfulpro-life policy in ownation's history. but now onnot: be t:aken for granted. Last. 01Jr most important wo� is changing he.iru and minds. Thego.ii of theo.tioo.11 Milrch for t.;fe is to not ooly change l.rws at the stiite .ind federal IC'Vel. but to change the culture to ultimately make abonion umhink.lbl e. With the ro'e of the states being more imporunt.we are also growing, strong state march for life initi.ative quickfy. however. wewill continue to m:.rch every J;;inuary at the nationc1\ levei until 1 culture of lr.e is restored in the United S�t.ES ofAmerica. 2024 SCH DU .L E W d nesday, January 1 7, 2024 h po: T ursday, anuary 1 8, 202 Friday, Ja nuary 1 9, 202 :00 .m. ose o· G la: EVENTS Wed nesday, Jan uary 1 7 March for Life Expo e arch or L1 e E is pen to he public ,md no char e to anend. e Expo 1s an op rtuni •or marchers o connect v.rith pro-life or .inizations and mi 1stnes. pie up pro-Ii e swai- a d rl'ttt o er pro-l ifers trom .;cross he c unoy. - Leam More Thu rsday, Jan uary 1 8 Marching lOI : Pro- life Advocacy Workshop arching 0 1 is a FREE advocacy wo rkshop, givrng oa ici make and policy experts on how to effectively na • ate st.ite ap1 ol - nts the opportunitY to learn how to 1r voices eard by their e ecte-J repr en a •ves Hear rom a panel o op pro· l i e obbyists Register Today e l�1slative system, from Capitol Hill to your Friday, January 19 March for Lile Rally Join us nWashington, DC for the March for life Rally, Thrs FREE event fe.1tures ;live concert.1nd inspirinispeeche.s from pro- ife leaders- sh.iring how to stayinvolved in the pro-l"fe movement .all year loni,-The R.allywill begin at 12 pm ET on the National M.all. You = also vr.itch die liv-e­ streamed event on oun·:ebsite. Facebook. .andVouTube ch.innel. March for life This ,s the main event! The March for Lifewill beg,n immed·ately followsni the R..Jly - usually around lp.m. - staning between !2th and 14th Streets. We will m.arch pe-cefully up Constitution Ave. to the stel" of the U.S. c-pitol Building. Aftermarc.hing. consider attending the Silent ��o More testimonies outside the Supreme Court. visitini your Rel)(esemative to advocate tcr life. or proceeding cast The C.ap·tol to help me'lcw ol oncomilli marchers. - See Wtry People March Rose Dinner Gala All eventni of inspir.ition and fel ,o\•JShip. the Rose Dinner is the perfect vay co concludeyour March for Life experience in our I J.;ition's upit.11. - l..eamM0etoc/.m �ri;nze - «ft�p:.ss torr'e:cn �Wll9\,njloo R�4tJoJ1S vinu.l f,y�r nnuarv 18-TheRacelsOn1 fhe: Great Elcpt-cfr t,on! t...ike?n Th�Atr.;..:,,vR;,c-r,ycur goup w,11 o,m�� to-s:-, ve clues :ind ccmp/ett =ks chrOtJil,outthe =NJm ,ndudini oorScriorure .:ind SCten<:e �,t.t Add, l>Otul S4.?9 ,,,.. the Gre.t Elq:,edtti0(10� 1t 1� Museum :idml5s.iolljustSlO wlthdlscourtuode MFl Learnmore ,It wwwmuseumofthebl�org LIFE IS VERY GOOD Jaooary 111-19.2024 �leb.lnl¢�e:na 1 7�30PM -9:45 PM� 9:00AM- 11:00 AM Friday The Oocese Of MlllitOOtnVlteS yoo tO)Oinlhous.ioos ?f 1)4rtit1p..nts from .cross tne:coontry �, life ItS VERY Gooclcm J.lf>ll-'V lS�d 19 2024.l.lfeisVER.YGcnclwillbe"�d-tE�t� .... 11!(AfeN.wh, cM,,s�c..p,;c,t)0etos�voo ;;,1 one orboth�th� �1fencstoll(OCl.imttia1 Life isVERY�• Le.rn mare .i:.rllngtOldiocese.orglllvg LAW OF LI FE SUMM IT (11TH ANNUAL) January 18. 2024 We5tin Downtown 0.C.. PotomiK 8;,llroom 1l 100 P - 4:00 PM e Summ; haslbe'!II retured oolas e besit � ?.ecretldurin<> • 1'/ill hear from le. m.l 14'-"IV8S. medi:i per :ill e Hl'Mlh�t Ci = The .20.l.l • ., 1.,t, SUmma I nclud!. . •.mous � rehose 2SS•on providini a sn.pshot cro- ,fe Amiu,c.z • ·th in1t 1n media, and ni ov �e p;nel hosted by the Thorru,;lMort' mul alt: �-spea iVIP � fOf s«,e-ryfearurin:i. n;,1;go,.I eoo(O:zed dist,n,;:u,s ih mey5 fu I pro .m viii be c;-nnaunte:I n e;ar", J:.l Af f1)0!1 -J,, C,vst>I cny,Vk'"" S n,ltts from .iown,�w,, O.C Buses Ct,.1,tl!f busu .ill'1! Alto a �e..a! W.it\tO,i&t to O.C MowftlH_ l"i:!>y ptlk4!-ntt.o@r-t3;npar\:li-.gpe5(:an�p�rl lnw-ested InorpnlJlng• bus trlp! Speclal Evem Mal'l8gemen1e11ano1esVIP tr.rupY131lon ror t�e M&rth for Ure .na 11asarrnnged nunareCJJ or bus trips fer gr04'ps coming10 the Ma"h trom all ovcrtl•e US, To re<•ille acustom� <1.uo�. plMse r,;>acl\ out to Chuclr.Ge,irichat. Phoo•TOll•frthe­ mttrO10 one of lh� 1!1fttstops ,v1thfi,an�v.�U,-lf\g orruiu from th� '*lil'fnS IO>Atlon: Fedenl Triangle,Smithsonian. Metro Center. HOTEL I FORMATION I M PORTANT OTE: On Octo ber 6. 2023. our host ho e . the Renaissance DC Oownto-, Hotel Hotel. officiall be ebranded and r nam II The es In DC Down ovm o el {pre iausl named Renaissance DC Down own Ho elJ is loca ed across trom he ashing on Conven ion Cen er. be ee Capl I Hill and · he Whi e ouse, e I o el is 25 miles rom Washi o D lies 'rp and S miles rom onald Reagan Washin on a ional. WEST! DC DOW 99 OW HOTEL (Formerly Renaissance Ho el) S NW Washin on. .C. 2000 fl Reservations: I ndividual Reserva ions: BOOK HERE ! e r o loca ion: GalJery PlacelChinatovm The a c.h or Li e has guarante-€<1 he bul o ur rooms -or hree nigh Wed nesday January 7. Thursday. January 8. and J:riday, J anua ry 9. 20 4. e also a er ese d · es or ose wishi ng o end GET INVOLVED WITH PRO-LIFE EVENTS AT THE LOCAl LEVEL -;•:'-'M':r.b-tr� -lh1. iti. 1�0!'\C..C.:::U\e �:'1',r:=:��� ¢ir)- 7c t.c�n,- -e,...tt�ti:.�t:..•cr"" 1\-'l�""-�:,,c s�:-ro.. "Vtio:.1t-,,;.. �,o..rs�,-. ..., '•��e::�r,,r-t�tl.:ft. ..�-0-,t::.'( 71� :�o:'tr--� :,,.,!" -:r::tc.V..r:nf.-,1,.11.:.�� .:. :- .::'Ii:,..,:!1'!-::r.:� :ro- '= !X!cTS!.c.;tlir:,�:,!._a.!til'\�L..�:. KENTUCKY MARCH FOR UFE MICHIGAN MARCH FOR LIFE NEW JERSEY MAqCH FOR UFE NORTH DAKOTA MARCH FOR llf( OHI O MARCH FOR UFE P E N NSY LVAN IA MARCH FOR LIFE ARIZONA MARCH FOR LIFE CALIFORNIA MARCH FOR UFE COLORADO MARCH FOR UFE C ON NECTI CUT MA RCH FOR ll FE G E ORO IA MARCH FOR LIFE VIRGI NI A t.lARCH FOR IUIN OIS MARCH FOR LIFE LIFE Priests for Life - Website Images: 2024 March for Life, Washington, DC and Walk for Life, San Francisco Pt Planned Par<.'nl i'IC«l Pro1es1 H1e Nallonal P1ayer �'Ice lheYOUfh Ron l lny af'.d l� Sll�nr fllo More Gathi'ron!)s. ReC1' ln.v. vou v.dl find lrtfom,:,t,on alloul !hose :md �111111ar "vents and how voucan conned Wllh ,w PJ�asespread the word' for thOse wt,o cannot attend lht events toll(>W ihe evenb llve at www,8'ct.1U>or-t.lo11.TV and on the various socio/ media pmlfo,r,,, /u1Attl from th��/ 2024 March for Life, Washington, DC Thursday, January 18 Parenthood killing center m ln)C at 9· 11 a.m.: Prayer and protest at Panned l 12:30 - 2:00 l'.m.: Activist event an haur andn• han lnf after Planned P.orent•hood event end,. Co-sp,;111,ore While Rosi! Res,stlOC&and Createl1 E.Qual '>oeake,s conto1med � far will be 8ryan Kemp(,. F1anlr. f'a11011e,AJ Hurley Pat Mahcmev More spe;i�e� a11d exact 1orn11on to Ill' announced. Friday, January 19 8;30 •10:30 a.m. • National Prayer SerVice �I OAR Co1n11tu11011 Hall, I/T6 D St r-:-H (18th and O SI) CathOllc man at 7!30 t.ll"JI, r0' r1,011: 1,.,rQrmaUo,,. see , "'" "',.f ,P -, �� .,rr.-.._ ,, fran.fc Pavone will dt-Uver-., strong pro�llfe m<1«•!l" to rally thc, crowd .lnd w" will honor Bi�hop Josc,ph Strickland, M•rk L"" Dickson, Sr. O..idrc, Byrnes. POSC and Mark Houck.. Adm»�on 1s free Help us nu Ille beat.ltflul hall 'N!lhptayers and song as•:,e p,epare 10 90 out and match ,n defense of the mo,t delenselessamonq us. lhe event consis1s c�ch.mvenlny of two worship s�rvi(e-s: The MMs and the inlei •bO'rtlon, ,., 1vdl •� by otti,:r f•m,ly l'T11!�C brave ,,,;,mf!fl ,1nc1 ,npr, wl\o (1,�,. their 1e,t.monnln �� and 10 spread those te�monniswhfch can bt> touod .tnw� i• J, ·,01 ,,, t' HMnr�,m l Saturday, January 20 s:oo a.m. -7:00 p.m.: Plit>5lS fo1 Lile isa co-sponsor orlhe NollOnal Pro-file Sufllm•t Gr,mcl Hyall 1000 H Stteet NW wa�hlt,gtpn, DC l>top lly to meet <.l0t le�ders anct stalle1s Monday, January 22 (The actual anniversary of Roe v. Wade) 1 1 a.m. to 1 p.m. r, �yersillll:I 1e111 embtrlog Ille v"Unis ofRot v. waoe• u; hom 01 me5up,E'11e coun Flow�r -s w,11 u" laid on11,.-.icps of tile Supremv courl •I lh<> rondu,,o,, A�e;/;� s,.,. F R ,. " c,, c o 2024 West Coast Walk for Life, San Francisco, CA Saturday1 January 20 8'00-9:00 am: Pl;,nneo Parenlhood Protest, ,su Bosh s11eq1e11ta1 v..,1 Nt»Av�nue. �an Fran<•S'-O F,ao� IIMone a"d other leddl!r) will spe.ik 8:30-9:30 am: Pro-llfe Leader Frank Pavone wlll be 011 the Pat.a le of St. Mary's Cathedral, l111 Gougtt S1ree1, San Francisco. 9re,e1ln11 .111d tallringw1tt1 umch"'� prior io In,! 1UOAM Walk 101 Lite Mass 10:45 a.m. •12:15 p.m. • Civic Centtr Plazae- Pro-life ltader Frank Pavone. Pastoral Director of tht Siltnt No More Aw,mmess Campaign, will address the crowd and lead the members of Silent No More who 'MIi s•1�1e 1hi:l1 testimonies ol the pain U1dt lole1eUW$ab011lon anrJ th� ll�ael, ng lhal i$ avaitabe lee Th;s is (he Sarne l<,u1loo astl,e Walk lo, li fe Rall)• 12:30 • 1:30 pm• Walk for Ute Rally at Ille CIVIC Ce11ter Plaz,, S.lll �ranmto. 1:30 pm • West Coast Walk for Lite•• Memben of the Silent No Mor.C. 'or tr.e YJ•c· for �i'� a: :� Nev: Yolk p· ,ri,r; \A.;,3 3: !0.l03rr: a: 5t Pa:rd: ! Church March for Life. Washington D.C. January 19. 2024 @ 10;30AM NV P I LG R I M MASS St. Patrick's Church 61910th St NW Washington AR(J fl)fOCE\E Nnv rORK o.c. Opportunities for Local Prayer and Witness •rou a:-e n0:.1i, e:o a::��.; theM.:1rcn •or Lfe •• i::>C. :-" •)·ur \lie int0ur¾i-eyw tc :Jr: a�J:£ n l!Y� pr.J)e,I' �-!-i:s orc�t�"-'e · P'.l)·Erf.l w,:ness ou:.f!SH >'in J.�:>rtivr,.:I nic r�ar ):.r. J.ll'i.�1' 21nd r.1:me!n! :r,e �:ooal 03'1 o' ;JrJter Jnd FJs: ns for the l�i pr�:trn:,r, ct the unocr Bronx Manhauan White Plains Newburgh Sprina Valley Staten Island Life Fest Life Fest 1s a Mass and !Ully hosted by the S sters of Lite on tile morning of the March for Life. January l 9tll. from 7:J0am·l0:30 11m in W.uh1 ng1on, D.C. It includes music prayer and dynamic speakers. Perfect foryouth .and young adults For more inform.at1 on, visi t \w1whfefestrially.com WHY Liff fESr> 6fCAU5E EVEfiY HUMAN PERsor, IS MADE IN GOOnS IMAGE. BECAUSE OUR WORLD IS CRYING OUT FOR HEALING. BECAUSE lOVE IS THE AtISWER. YOU HAVE BEEN CHOSEN FOR THIS TIME.A NEW MOVEMEI-IT IS RISING UP. WILL YOU> National Prayer Vigil for Life The tJ;,tion;,l P�yer Vigil for L,fe is;, pro-life pr;,yer vigil held on the eve of thl! March for Life �.ich January It ,. held at the su:iic.i of the llation�I Shrine of the Immaculate Concept,on ,n Washington O.C. ihe Openin,: Mass will be celebrated by Bishop Burbidgeon Tllursday,January 18th at 5:00 p.m and willbe immediately followed by .i 7:00•8;00 pm. Holy Hour for We Throughout theniahL Hon y Hours wi'I be led byv�rious bishops throuehout the countryand ln available on hve·stre.im. Adosini M.issfor the Vigil w1tl be celebr.ited at 8am on Fnd.ly morning. Typically.over 20.000 pili:rims �om across the nation pray through the night for an end to abortion .ind .iii-eater respect for..i, hurrnn life The Vigi Progr.im w•II be te!ev,std by EWTtl .ind livestreamed on the 6as lica's web�e so marori-s c.an part•CJ pate remotely. Facebook Images: (;l.11).\V: JANUAlf lt.10l1 Ufe 0 W•lhnjlOII 0C \, 4' P\lo:tlt o\tl)'Or,e,Of\Ofefr,.KtOOOll _t,-,, ..�n.,• fkt\flfwle 1 '( Yt1��0,.c,n O\lt"'°il ::t�ri.s,,,,,, ,�\llf'i\11\ �l!'f.t Hf'IUII\ 19..?. O.N ff i,,,t nu'°'".,' n:ws:ups: tO'ltl'dS f'l.1\1111:,.-�u: .aboft,of\�U'ifH NICA!i.l-' ,.., 1� ....... .¥t ., ... .... ....... M..1 Your Host Wa.shncuon DC i �,-.u,-f'J • ,;w rHJ GuM-ts The 2024 Marchfor life Theme Reveal -..... ,r_11, What ,s PAAU dotr,q for tl1e M41? It's all In thi s post. !lE TllEREI!!! RSV? for Aff1nify Launch event t,ere; https;//forms.91enSXQxhftT0Kiu-!h78 BUI D. L: PRO�LIFE POWER WITH USAT HE MARCH FOR- LI E- � UfeSiteNews O \iii61 @LifeSite FULL LIST: Events surroundfngthe 2024 March for Life f/Marchfo, Ltfe 1fP1ol1te !T;:;bortion 11:30 AM • Jan 3. 2024 • 506 Views 0 EXHIBIT 036 From: "Weiner, Robert (CRT)" To: "Fitzgerald. Paige (CRT)" Subject: Emails from the person we're meeting with tomorrow Date; Wed, 1 7 Jan 2024 1 5:53:07 -0500 Importance: Nonnal Embedded: �YSA:_lntel - Social_Media_Alert:_GOI_ _Protest_at_Fort_Myers,_FL-­ : , _ _18 Jan. __ [EXTERNAL]_Social_Media_Alert:_GOI_Protest_at in_Washingto n,_ DC_-_Jan._1 8; [EXTERNALJ_FYSA:_NAF_Security_Alert:_2024_March_for_Life_Protests_in_D.C._&_Na tionwide_-_Jan._ 19_ (Jan- Mar) From: Robert Ledogar �prochoice.org> To: "Weiner, Robert (CRT)" Subject:n� FYSA: Intel Social Media Alert: GOl Protest at Fort Myers, - - Jan.n18 Date: Fri, 1 2 Jan 2024 1 3:·3 l :00 -0500 Importance: Nonnal lnJine-lmages: image002.jpg; image003.jpg Sir, This group, OSA is the group that is announcing protests in support of members being prosecuted in TN and this information is apout the group attending a conference in Ft Myers, FL and organi2ing a protest at a local clinic. Best, FYSA- we believe that members of OSA, will drive from Nashville, TN to Ft Myers, FL. They may attempt to perform an unannounced protest in GA. • " Known group of interest (GO ls) Qgeration Save America (OSA) has or •. ce Abortion Mill Outreach" pro-life conference and rotest events to occur on local time at Planned Parenthood's located at According to the Facebook eventQBg� at this time, at least 5 people are confirmed to attend and 11 others have expressed interest. It is unclear how many people were invited to the protest due to Facebook's privacy settings. The events will feature known persons of interest (POI) and current and former leaders of OSA, Jason Storms, Derin Stidd, - and more. Due to the relatively large following of OSA, as well as the aforementioned POis and other GOls involved, it is likely that the event and subsequent protests will gather a significant amount of support and participants; however, this cannot be confirmed. The protests are Intended to be peaceful but are expected to garner a sizeable group of demonstrators, and ate also likely to inspire counter-protests from pro-choice supporters that may increclse the possibility of disturbances or violence. Additionally, it is possible that extreme or more radiGal pro-life supporters could use this as an excuse, reason or motivation to conduct acts of violence against NAF or their affiliates. The descriptions from the OSA Facebookevem p_age state the following: ''Join us as we bring the Church to the gates of hell to intercede for those stumbling to the slaughter... We will have an extended time of prayer, worship, a series of rally talks, and sidewalk advocacy as we plead with morhers and fathers not to take the lives of their precious children." Focebook Jmages: TtlURSDAY IA!-1\l�RV t& 202• U � &"4 Founders Conference Abortion Mill Outreach i>laor>.ar,;,flthood - C, lnleresttd Details ._,at·o.!"t&l ;O.,if'l��r-s COl'\�f"tr°'Cf' A.OCt"tNef' .. O.,t't!6ct1 en-ta·0'1 S!\t- �f'lcl Jor-u� 41 '"f t,fI"� U'ttC-"W'tn-tO:�, 92:tMO' N to ntt-���Cf :r.cS�itvn"'O,ttg(O ff\,t s r..,gNtr SN- mort Meet Your Host Guests Oper.nlon S..ve Amt(1ca Twitter Images: Looking forward to doing this outreach at the Founders Natrona! Conference next month! Huge thanks t o @tomorrow, and the brothers and sisters at r.-·fou11Je, Min 101 opening the door fo1 us to host this outreach at their event! Love to see you there! AllorAL FOUNOfM co .�� r.e Abonion Mill Outreach �� FOUNDERS 4:19 PM Dec 28. 2023 2.215 Views ..t Regards, 0 Golno Cl lnvrtt /; From: Robe1i Ledogar �prochoice.org> To·: " Weiner, Robe1t (CRT)" Subject: [EXTERNAL] Social Media Alert: GOl Protest at DC - Jan. 18 Date: fri, 12 Jan 2024 13:28:54 -0500 Importance: Nonnal lnline-lmages: imageOl O.jpg; imageOl 1 .jpg; image0 12.jpg; image013.jpg in Washington; Sir, Additional information on a specific group, PAAU, This information is also shared with our organization, members, law enforcement and community offlclals. Best, Bob This is the group that raises so many concerns for all of us, they were the one's who attempted last year to schedule fake appointments, walk ins at several clinics and disruption outside of clinics. Several of the groups' members were found guilty at trial when they committed felony acts against clinics in the DC area. This group just recently traveled to NY, NH and MA to disrupt clinic operations at four centers. Known group of interest (GOI) Progressive Anti-Abortion U,:irising (PAAU) has planned a "DC Planned Parenthood Protest" to occur on Thursday, January 18, 2024, at Planned Parenthood's Center, lo0ated at� rotest activity is scheduled to begin at approximately 12:00pm local trme and wil� "sidewalk counseling" and "community defense." According to the i:acebook event l,@gg, at this time, at least two people are confirmed to attend and one other has expressed interest. The number of expected participants will likely increase as the protest date draws clos12r. PAAU's Facebook event P-f!g� states the following: - ''Join us on one of DC's late- term abortion days to participdte in sidewalk counseling, protest, and community defense. During the busy March for Life week, take a moment to spend time where the killing is happening. PAAU will provide literature, chalk, signs, and megaphones. Come as you ore and participate how yov want See you there!✓' While the protest is expected to be peaceful, there is the potential that protesters may employ tactics, such as causing disturbances, trespassing or attempting to illegally enter the facility, due to PAAU's Involvement and commitment to "Red Rose Rescue" (RRR) and "Pink Rose Rescue" (PRR) events. The protest may also inspire counter-protests from pro-choice supporters that could increase the possibility of violence during the demonstrations. At this time, PAAU has not publicly -expressed a n intent to protest any other women's health centers in the Washington, DC area, but impromptu or planned actions at local facilities remain likely. The protest comes ahead of the 51 �t annual March for Life (M4L) on Friday, January 19, 2024 in Washington, DC. PAAU has created a "March for Life wtth PAAU !'' event, in which its members will gather with other pro-life groups- and walk to the M4L rally location on the National Mall. PAAU has also org,mized a "PAAU Mixer" event to occur on Thursday, January 18, 2024, the night before the March for Life in N.E Washington, DC. The event is RSVP only, and the address and details will only be sent to registered attendees. Google MaP.,s Images: F Nat,onols Pa� Facebook Images: THURSDAY, JANUARY U. 2-01-4 AT ,.Z PM • 1 PM DC Planned Parenthood Protest ,C, Interested O@tails ;. 3 peo!,'le respol'ICled • e.-ent by Progres�lve And-Aboruon Uprising 0 0 °'1ratJM: l hr � Pllbllc An)'Ol>C ono, offfaceboo� JOeM)IM.'lrdl forL,feWQQ", t;ire4mof!IQ<>ttospv,dtimt\\Ntethe 1,mn9 is hap� PAAU w,I ptOVlde fitemurt. chall:, silJM and �iphM� CO: ,._-.i, n:a�11: ;co-us Vut ?MU ,ft'wntt/:._i,., 5.�•Cou!•t:h•tn.:!e!!llt •11��• ,\e .JJ 1111 M>mt. uW:<11• a,,c mite�, :e� :ht w"botn �-:,;t:h1r �s ,.,. a! 1cr J..1r...a fer thfl r.u. tot Ptpt.t ,, ::.:..c,: Jrto ;'lrtb¢ffl,___Cf1"1:;Q"n Suprem� Counof 1he VoitNI Stat.ff ts: ',t ,\.U" '-'r�" :,::: n,Sup,t-"'t c..:..n r,• :•el.r,,� Su:u 'l !hf�;hu: 1,ara1 «:J?. e• :he vrll !-C-,d: $:,1�1-:.. cJU.ct1.1t,-r,.::i _puis:1,1.n-� tQ ¼.d_ SH t,\ON- Gue:sts ittllf'.SO�V t.\N\/1\llV It 20Z4 Al 8 PM•10 rM PAAU Mixer O tnvrw Details Gvests ,� �Sp�pi.,.. 3 3 Gel,-«; • EV½nt o; Pr09rnsr.-. Anu,Aboft>on � 0 Oin-:cn 2Ill � \. -\ ;>ub£-c "·"?'OtltS0.,0fvf''� ..::,.nurSro,a it,.t1� �1M:..1t :tlf'� Attt.'11tr..o...lt, in -.i; OC!n..J r"V'l: &b')• �\.�ON"/ tc O!Htt o--nct !Ila"! :r-t.d�rm rntl',ohe!Tt' Stt less .Id I> From: Robert Ledogar �proohoice-.org> To: "Weiner, Robert (CRT)" Subject: [EXTERNAL] FYSA: NAF Security Alert: 2024 March for Life Protests in D.C. & Nationwiden- Jan. 19 (Jan-Mar) Date: Fri, 12 Jan 2024 13:27:39 -0500 Importance: Nom,al Attachments: IMG_l41I .jpg lnline-Images: image002.jpg; image003.jpg; image004.jpg; image005.jpg; image006.jpg; image007 Jpg; irnage008 .jpg; image009 .jpg; image0 1 0.jpg; image0 1 1.jpg; image0 1 2.jpg; i mage0 1 3 .j pg; image0l 4.jpg; image0 l 5.jJJg; image0J 6.jpg; image0 1 7 jpg; image0 1 8.png; image019.jpg; image020.jpg; irnage021.jpg; image022.jpg; image023.jpg; image024.jpg; image025.jpg; image026jpg; image027.jpg; image028jpg; image029.jpg; im,age030.jpg; image03n1 .jpg; image032.jpg; image033 .jpg Good day Sir, I would like to share this with you, as this information is pushed over to our organization, members, law enforcement and community offidals; all for security awareness. Best, Bob - Robert Ledogar NAF Security, SE Region For Your Situational Awarenes ... The Slslannual March for Life (M4L) has been scheduled to occur on Friday, January 19, 2024, in Washington D.C. The annual event garners significant attention and support from pro,life members, with hundreds to thousands of participants possibly attending. According to the event webpage, !Vlarch for Life 2024, it does not appear that the group plans on protesting outside NAF or Planned Parenthood facilities in the a rea on the day of the event; however, due to the large humber of protesters and counter-protesters that typically attend this event, the probability of this occurring remains highly llkely, The event page also urges participants to remaln peaceful and not to engage counter-protesters. The event in Washington, D.C, is planned to begin at approximately 11:00am local time and occur until approximately 4:00pm. The rally itself will take place at 12:00pm local time and will begin at 12th St. on the National Mall, between Madison Drive and Jefferson Drive. Following the rally, the march will begin on Constitution Avenue between 12th and 14th Streets at approximately 1:00 pm local time. Participants will then march to the steps of the U.S. Capitol Building. Additionally, multiple protests have been planned to occur at the Supreme Court of the United States {SCOTUS) and other venues in Washington, D.C. in the days before, during, and after the main March for Life events. Several known groups of interest GOI), including the ProgressJve Anti-Abortion UP-rising { PAAU), among others, ar.e expected to participate in the protest activity. At thfs time, a Facebook event for the "2024 March for Ufe" lists 43 people as attending and 72 people as interested in attending the protest on Friday, January 19. Participants are encouraged to RSVP on the M4L website. and the number of those expected to attend the protest is expected to rise -as the event date approaches. In addition to the main March for Life event in Washington, D.C., additional protests at various locations across the U.S., and on different days, have also been planned to coincide with the March for Life protests in Washington, D.C., some of which are planned to occur outside Planned Parenthood locations or other women's medical health facilities. Known groups of interest {GOls) Priests for Life and known person of Interest {POI)- have once again planned to conduct a "Prav.er and Protest at Planned Parenthood" protest event on the da before the march Thursday, January 18, at the Planned Parenthood, The protest is planned Center, to begin at approximately 9:00am local time and is expected to be peaceful; however, this cannot be confirmed. Additionally, this protest will very likely inspire counter-protests from pro-choice supporters that will increase the possibility of violence at the location. At this time, it is unclear how many people intend on attending the protest as no Facebook event page for the demonstration has been discovered at this time; Protests associated with March for Life are planned to occur until at least March 2024, with additional events occurring between April and October. According to M4L's locations web�gg_, upcoming March for Life protests are scheduled in Virginia, MD, Atlanta, GA, Denver, CO, Springfield, IL, Sacramento, CA. Phoenix, AZ, Hartford, CT. Additionally, Facebook event pages have been discovered for several March for Life protests this month, including Dalla s,..IX, Carthag!;, TX, Saint Petersburg,e_fl, and ToReka,�. The protests are intended to be peaceful but have inspired counter-protests from pro­ choice supporters that will increase the possibility of violence at some locations. In addition, some locations could have up to 100 protesters or more, but this is currently difficult to determine. Cowaa r1a.,11 11t10n,OC . 1· OTTOM "� C!l PENN OLIAR Ell .., ,. CJ Washington, OC 200,04 M,1rt Q:itl N.11tonaJ Mall Kllljl JI Mt•rr1101 M4L website Images: '°" LIFE -LCfp MARCH � ID EAS1£>10 "'t1:l Q •• S"t ,:r e �:li u AA �TANT ON P/4RK . a.....■:e •••••• •• ,,,,. � 34,nln • t. TOl •e a m CAPITOL Hill Cl NEW ROUTE --- o --­ --- lo order to m:.rkrot ootyourVfctcf):·1nllobrMbut.;,,� ournetd tom..:n�,n; o<'f's:en:e 1nW.;,sh:nj_ton.th.ts \'e,.r s,. M.rch for Lfe•» ha.....,r.,;hllyd, rv•S c,p;,01 �dS.,ptem� UO-it'er..c.<.ffl.�r-°"thtli.t.47".- t.•a M\;jm.,rcf\o,C,p.1;,,!H !Jr, �ann,�ry«tht'Sutltttn!:G"-#1-Jl97JP.O! Wffl.rubtq'Mkl"ltZJli.::H �•a j !•1HtJ1t$ rnht lJti't"...lWW'h,}J/ �"'""�oe111iO�trJ:.:.,ti'\ ?tw �e,,1t.hiS�"4.-...-v,I �•·� l�""""""'�-•�v .. ........<"' l'N:""d-\,"'.eter.:,v ..tSt�C��:�,?� f, l"dotot�ttd: Y.'C:tfMPQnJ\'O'��-thticf'nCfflc_l'l5.ii(l:C� ehn!.� v•�-�Df'O',c,.'itdbi, cvc:J'r�W"'�U-.flf'.-.,tt�•�¥-dW1V)OC:��csc. WHY WI LL WE CONTI NUE TO MARCH? Eve vitn he wonderiul blessin of Roe v. W.ule be,ng ove umed. which a ows more freedom at he state level to en :act 1>ro•li e laws. he necess-ary w10rk to build a cv1ture o I' e in St.a es o America is not finished_ Rather. i is •oc:used ditfe�ntly. Sad . annual rou e uo· ed e number of abortio ns is s ·1 v. 11 over 900.000 exh year. and ha number is expected to decre� only by ly 200.000 each year in.a pcst-RoeAmerica. Many �c·on;i1 egisla ·ve b.i ties loom. " even �ping longstanding Hyde pro ec -ons. wh•ch !imi govemmer1 undi uding or abortion o annua appropri:a ion bills. The Hyde Amendment h3S s.1ved over 2 mt lion l'ves and is arguably the most imp:actful pro-life policy ·n our nation's history. but tlO\V can ot be taken for granted. Las , OtJr most.important wo • ch.an_ging hearu and.minds. e go o the na ·om Mi!l'ch or • e is to.no only change la•.ns .t he sme a ederal level. bu o ch:mge the rulture co ut imately ma� abortion u hinkable. e mites beini more impcrtan we are also growin ° a s cng s. ate march tor li'e 1nitiati e qui . howe r. we will continue o !Mtch every January at the na ional level until a culture or e is restored in he un· ed States of America. 2024 SCHED LE Wedn sday, January 7, 2024 T ursday, anuary 1 8, 2024 rch o rch· .m .- 1 . .m. .m. Friday, January 1 9, 202 rch o L. e e-Ral l a ch rch G la: Ros o· :00 .m. - n EVENTS Wednesday, January 17 Marc h for Life Expo he 1.rch 'or L • e Expo ;s open t •or mare ers to he l)\Jblic and n charge :o attend. e Expo :s an opportuni nnect 11th pr -life or aniz.ati ns wd ministries. ick up p -Ir e SWoi- 3 d mee· other pro-l ifers from .icross the c untry. - leam.More Thu rsday, January 1 8 Ma.rc h i ng 1 0 } : Pro- Life Ad vocacy Workshop arching 01 is a F REE ad oucy wor hop, giving par ·cipants the opportun, ry learn how to m-ke t eir voices heard by their elected repre:s ..n auves, Hear IT ffN:nt n t'om,l Mall You c.an a. so vatch the Ii er website. Facebook. and You Tube chann . M a rc h for Life This is m.iin e en ! The March for Ute !iitl be 5in immed 1ate1 follow'n 5 the Ra! .iround 1 p.m. - st.ming between 2th and 1 - usuatl Streets. We \viii march peacefully up Comti io Ave. to the steps o the U.S. Capitol Bui d i ng . A r m.irchini. ons1der attending he Si nt o , .ore te.s 1mome5 outside t Suprem Court. visi · ng y our Represent.itive o advocate or life, or p roceedin g o.ist C.;i p · l to el p the ov, of g n oncomi marchers. - See Why People arch Rose D i n n er Gala evening of inspira ion and el lowsh,p. Rose Dinner is he perfKt way o conclude your arch f r Li e experience 1n our ti ;iti l'l s upit.il. - Lea rn More about the Rose Dinner M"1Ch for Ufe Rally SPEAKERS •alt¥°� L.QfrtO ood Cca1!oo \"""' J.OJIMo.,.Oovlt �= m.nr events h.pper,ni;;,oundW.ish- "lt(lll. oc_ surrooJncling1he Mirchror wre.These e.i-e.nts �� not sponsored � W t-...urch#or Lrft!'..butWI! w.ant!dtonuk!: Yt)IJ .;iw;ir@ofth!md.lnnJ l'04,,rtnplot1'e mc.otisC;p,ul Cheek bade In �wcdts le.ldlngupto the March f«life as rel�� ewt'ltsare contlnu.-ally�to this p;ge! lo haveycurellffltn,,ed please�xii outtoO.iwl'I Flap;atridt. MUSEUM OF THE BIBLE Janiarv 17•21. 202.: 4004th St. SW W;ashl"ltOf\. O.C. j 10:00AM - S:00 PM W'Mhingtcn R�; A �bl �J'ie-< HuntotSibkal Prop«tions 5---=c h out &bh�• QfYen<:ts dv�hout D.C. tofindwhere tt.eBib' ehldes ,.,p;�,ns,jht. Ptus, t>r d� cluesa:,d =�ete U$l24 E.;z�nlcAl'en., f7:30PM -9:45 PM� 9:00AM- UOOAMfnd� mv,"'s '\OJ to,o, n lncus.ods o' P.mclNl13 rom .).. Thf Oloc� olkl"i(CO 'TC� thfCClUOlf)I :.t ,1.1fe 1 5 VERY Gt.>.xl 00 , Janu.,,,, 1&and 19 2<)24 Lfell VE!!VG_'Y)dw:,llbe�dat �eB.ir,kArero, whthts coonuv TheP..,,onz R;;tlyonJ;nu;iv l9p,eo.res us towke to then•�ts o• Wishmi{co DC t., fllcl,� our v,:, c,::s t,,_.n;I as we procl«'rn the�· oflite We tr.,petosre-e�ou ,;;,t one orbotho•tt>os• �""'-'lOUOGlOirntl>lt ' L '½ .sVEPYG>Od! LAW OF LIFE SUMMIT (11TH ANNUAL) J¥1U�18, 2024 Westin Oowntown O.C. PwJtom.lc 8.lllroomI 1!00 PM-A!OO PM Th'! uwa• L ·c 5umm, th.is� �f!rred 1o;a5th-!best � secretd..no;th�wev:.:slhc"1arch f(Jf Life />s. the 5Lnvnit 't')IJ ,w1 he-¥ tro1111e.1<1cers l.1v1yers ma:1e 1 .1� iues .nd ;.d\,ooteS Th! SUmm,tties t')-i!lMr i;we , m?C11• .1!1dsir.n� lOCflerJ!lC.il,y,j •1151,,re,� �1,n �OH � ...,.,,..,te. Th« :02.J L_,,.,.-,L:fe �"' o•twfl l ,ocludet/le '•-i'lr�,e =s,� Ol"O'VIPpar�•f;y mtSSSli "lit! _t,. • ,-cl r,...,,iy OUkeyt,cu �� i..�tcted �the Tltcrrus},.�,; Ser�,� f!!Jtur, njn.r,ro.tly reoogn,::_� W O.St1lli).IIS!'l!d il tO='S Th! full Po11cM2S:1 ..t 7.30�f'll W�Wlil -nt the Pro-lrfe RKOl"ition AW;,rd tc 61$hoc Jo�Strid,;1:ano cf Ty,u -r,._ "'brltL� Didson foor,.:!e.r o.fthe S.nc:tun Cihes Jo, the Unbom •n 11;;we. 5r O&ir.ir� Byn,e. POSC ,.,., M,;r,: Houck ll,..,;11 b'!; t•IY'e of�r. Qr:.,� ITI'JSKand 1nsP1nnnpe�s.Pro·L.feLeader fraN F>avc;� w, ddr.er a PQ\wrlul pro-',fe messa-;� S�ed by Pnests for!.ite.ino the Nat Olli, Pro-Life R�•il()IISCOI.I0:11 AdrnlSS!?tllifr� Formore.ir,tomut,oo 1�wv.w.NaiioMl?r�� TRAVEL Airports Tne mouconven1e,mvay tog� roo.c. .. D¥ nyI iigfl�re. n.e,ear• tv.o aIrporuse,v1ng en" o.c �rea.D0111..tt Metro&eces�,01�: • Wasllif\llO!l Dulles All'J)(lrt-In Dull�. VAl a��asv 2S•m11E 0,1,e from o�,...,nu,wn o.c. • Roniil Crynol Ory,VA.l•ot SmHo trom dowmo"'11 o� Buses Ch.lr·ter \>�$ES .;,re al so 3gr�\ 'flAYto!§ettoO.C. HoN�r. t.hey p Sutionor :he B.lSil!CI ofthe Natio� 5hr1neofthe lmmacut,IAl Conaolioo - Obllll n vour bus pe1mlts Interested loo,pt\l,;ng a bustrlpl es VIPtrm5'l)(d't;it10<1 tort� Mtn:11tor lite ;t1e- Pl•r,r,!"1 P•ren1hocd Pro\es\, tlie Nu\lonal Prayer �e1Y1ce the Vouth Ril ly ancl lhe 511tflt No More Gathl'tlt\� s.-tow you IMII lin,J mloflllation about thme .nd surntlta, evetlt> and how you can coMecl w11h un Ple.aSE>spread me word! Fo• t�ose wllo r.onoot aner\d the event;. follow lhe e>enr1 live a1 www. llld1Ulot1lon.TV a11d on the varlou� soc/at med/o p/o(fom:u llnkt'd (10111 therrl 2024 March for Life, Washington, DC Thursday, January 18 9· 11 a.m.: Prayer and protest at Pt ltanned P.irenthood killing center 111 DC al 12:30 . 2:00 .,.m.: Activist QYl>nl an haur and • hall after Planned Parenthood ,wont end,. Co-spontored by Prn•IN 118tl\ �nd D St). Cathalfc mass at 7:30 am. For m01t"lr\lormarH1n, iel' :-.a,, ,1,01 f-•� <-r-:,• ,,,:.,• " Frank Pi\Vont will dell�, a strong pro-life message to nilly the crowd �nd wewill honor Bishop Joseph strickland. Maril Lee Dickson, Sr. Deidre Byrnes. POSC and Mark Houck. Ad1T11Ssio� 1t, tree Ht!lp 11s fill the beautllul nall with prayers and song dS w.e ll'C!POell\c., hold1nq their s>QI\SShOW11\ Supreme CQIJ•1. lest1mon,�s dre gl�e,1 oy motl•ers and fathers who na11e lostchlklren lo abo1t1on �• w.-11 •• by olher ,.,-.,,tr mtfflb<� -,ho hove been •mo�tl� by oltort,on. rnc pubk •s4sktd to corn• and �uppart lh�9ive th"" 1e<�mo11l,e,s. and to ,prc.ld lhose terior rtJ lh'! 9J0AM w.�lk tor life Mass. 10:45 a.m. •11:15 p.m. • Civic Cen1u Plaza- Pro-Ille Luder FrankPavone. Pastor.ii Directorof tht Silent No More Awar<>ness Camp;1lgn, will iddress Uie tr,;,wd •nd lead the members or Silent No More wllo �II sha•� lh�lr tt>sl• monies of the P•"' ti,.,,t follows �bOrton rn i Mid the 111,01'119 thatis ava,lable n11,is (he sa�11, lncatlon as u, e Walk ro, lle RaUy 12:JO • 1:30 pm• Walk for Ute Rally at tt1e Civic Center Plaza, Sill\ F1anC1Sco. 1:30 pm • West Coast Walk forLlfe •· Membert of the Silent No More Awar�ness C..n1palgn will march tcg.C. 'or tr.e YJ•c· for �i'� a: :� Nev: Yolk p· ,ri,r; \A.;,3 3: !0.l03rr: a: 5t Pa:rd: ! Church March for Life. Washington D.C. January 19. 2024 @ 10;30AM NV P I LG R I M MASS St. Patrick's Church 61910th St NW Washington AR(J fl)fOCE\E Nnv rORK o.c. Opportunities for Local Prayer and Witness •rou a:-e n0:.1i, e:o a::��.; theM.:1rcn •or Lfe •• i::>C. :-" •)·ur \lie int0ur¾i-eyw tc :Jr: a�J:£ n l!Y� pr.J)e,I' �-!-i:s orc�t�"-'e · P'.l)·Erf.l w,:ness ou:.f!SH >'in J.�:>rtivr,.:I nic r�ar ):.r. J.ll'i.�1' 21nd r.1:me!n! :r,e �:ooal 03'1 o' ;JrJter Jnd FJs: ns for the l�i pr�:trn:,r, ct the unocr Bronx Manhauan White Plains Newburgh Sprina Valley Staten Island Life Fest Lile Fest ,s a Mass and Rally hoscfi! by the S scers of Li•e on the morn:ngor the March for Ufe. January 19th. from 7:30am-l0:30 am in W�hIngton, O.C. It includes mus,c.prayer and dynamnin c speakers. Perfect for youth and young adults For more information. visit IM'I\V ,ifefestrally.com WHY Liff f'fST> 6£CAUSf EVERY HUMAN PERSON IS MAOf IN GOO S IMAGE 6fCAUSf OUR WORLD IS CRYING OUT fOR HEALING. BECAUSE LOVE IS THE AlISWER YOUHAVE BE EN CHOSEN FOR THIS TIME.A NEW MOVEMENT IS RISING UP Will YOU' National Prayer Vigil for Life The M.itional Prayer Vigil for Life is a pro-life prayer vigil held on th!! eve of the March tor Liff! !!.ich January. It ts held al the Sasil1ca of the I lattonaShrtne ol th!! lmrnac_ulate Conception ,n Washin&ton. O.C. The Opening Mass viii be celebrated by Bishop Surbidje on Thursday. January 18ch at S:OO p.m and 1·1111 be 1mmed1 atety followed by a 7:00�:oo o.m Holy Hour ror L!'e Throu&t,out theni2ht. Honlny Hours wi'I be led by v;;rious bishops throu2hout the country and avail.;ble on live-stream A closing Mass for the Vigil will be .:elebrated at 8am on Ffid.-ay mornit'lg Typically over 20,000 pilerimsrromacross the nation pray through the night for an e_nd to abortton and a ereater respect for all human life The Vigi Program wrll be televised by EWTN and livestreamed on the Bas,lic.i s webp.4ie so millions can participate remotely. Facebook Images: F�I:OiiY,: JAt,UJA,l't' t,,:l0l4At n t,.M 2024 March for Life Details .. .., !!(� J,; IIS-w.OO,Or:AY�} J�N1U1A]iv· 1��· �·: .. • • - - - �-· Cornet of 12th and Const;t1r.1tfon Ave.. . ..._ ' :10 0pm - :1DOpn1 ,; _ P�A u 1lally a.t sCorus Meet PAAU thete. after the Mar.;chl Marchi For L'i fe Expo Tabl1 in g: Rock Creek .B1 allroo,m, West11 n D.C. oo,wnt1own Hote/, 999 9th St. NW, Washington o,�c. 20001 1I 2:00pm - 1:00pm PAAU Planned P1aren'thood Pra'f esf and Sidewalk Couns,elin :001 pm pm 8 'B :00 am - 11:0 0am, 4:00e , , March tor Life E�po Ta'bling .. _ Rock Creek Ballroo1m, Westin D1.C. Do'W ntown Hotel, 999 8'/J S t ..Al�a­ Washfngto1n D.C. 2DOOJ 1 1 ta J _S:1O O _ -rn - 4:00pm • Cardinal O'Connor Conferein ce E po Healy Hall, Georgetown Universitye· 1rconferenc e.co1m Reg/ if,er b� sconno • • Fin1d our tableJ . 8: Opm - 10:QO pm PMU Mixer _ · • _,. �.. • RS_VP at !fie 9fl�70'ifJe belowl ,. i 9:00am - 8: D0 pn • Ma1rch For life-�xpo Ta1b l 1ing Rock Cieek 8ollroom, West1' n 0.,C. D01 wntown Hotel, 9199 9th St NW, wasf)ington D, � iooo1 . 1 1 1 %:- 1 .. - 1 EXHIBIT 037 From: "Patel, Sanjay (CRT)" To: " (SF) (FBI)" prochoice.org> Subject: FW: F B I Contact Needed - California Date: Wed, 1 7 Nov 2021 1 3:03:07 -0500 Importance: High , "Michelle Davidson" -How the heck are you? I want to connect you with Michelle Davidson (cc'd)1• who is the Security Director for the National Abortion Federation [NAF] (Michelle - did I get your title correct?). Among other things, NAF provides security services fot abortion clinics nationwide. Michelle has been a wonderful contact for me as it relates to FACE Act investigations. She has been an MVP bringing incidents to my attention, often in real-time, which usually result in an investigation/prosecution. She's multi-talented, super smart, and a great resource. for �iny investigations we have that involve clinic violence (in which we've seen a recent: spike). I wanted to connect you with Michelle while she is in SF doing some good work. Michelle- is a bona fide super-agent (I know this from personal experience). I'm confident you can lean on him for anything FACE Act related, for outreach, and for additional contacts beyond SF. Let m e know if either of you need anything. Thanks, SP From: Michelle Davidson �@prochoice.org> Sent: Wednesday, November 17 1 2021d11:59 AM To: Patel, Sanjay (CRT) Subject: [EXTERNAL) FBI Contact Needed - California Importance: High Hey Sanjay, I'm i n northern California. to try to connect with University of California/California State University campus police and other local LE. Can you help me with the agents responsible for FACE in California? It would be great if I could get a contact for the San Francisco and Sa£r-amento area while I'm here. {I leave on Friday) Sorry for the last minute request. It would be so helpful to cohnect with a few of them while I'm here s o I can facilitate conhections with the clinics. I meant to ask for this awhile a_go and here I am, scrabbling. Seems to be a theme lately as there is so much going on. I know you're super busy as well and appreciate any help. An intro to US Marshals would be really helpful as well if possible. Background -California passed a bill recently requiring UC/SCU student health centers to provide medical abortion services and I'm here to help thern mitigate potential anti-abortion harassment. Thanks! -Michelle Also- did you see my email on a RRR in Alexandria? I'm looking for more info on that for you. EXHIBIT 038 From: "Patel, Sanjay_(CRT)'' To: "Michelle Davidson" �prochoice.org> Cc:n" (PG) (FBI)"_� Subject: RE: WV FBI Contact Date: Fri, 1 6 Jul 2021 L6:47:45 - 0400 Jmportance: Nonna! lollne-Images: image004.png; image0Ol .jpg Hey, MichelleCC'd on this email ls Special Agen� He is the rock star FBI agent whom you can connect with about the letters sent to the clinic in Charleston. I fwd'd the letters and email to Jim that you sent me. -- Michelle is the Security Director for the National Abortion FederatioA. Michelle is an all-around superstar who has been a valuable resource for me in my role as the national FACE Act guy. I'll let the both of you connect re: Charleston, and if anything pops, definitely let me khow! Thanks, SP From: Michelle Davidson-@prochoice.org> Sent: Wednesday, July 14, 2021 9:37 AM To: Patel, Sanjay (CRT)e� Subject: WV FBI Contact Hey Sanjay, Can you help me get in touch with the right poc for West Virginia? Ties into the letters they received and they want to meet the new person. Thanks I Stay safe,. Michelle Davidson Director, Security All pronouns are respect;ful/y accepted (They/Them, He/Him, She/Hers) Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this e-malf in error, ple,;1se immediately notify the sender by e-mail at the address shown. Please delete it from your files if you are not the intended recipient. Thank you for your compliance. EXHIBIT 039 From: "Fi�gerald, Paige (CRT)" To: "Buchko, John (CRT)" Subject: RE: Ethics question Date: Wed, 01 Nov 2023 14:22:48 -0400 Importance: Nonnal Joline-Images: image00l .png I don't know for sure, but my strong guess is that it is not a federal grant. From: Buchko, John (CRT)d._ Sent: Wednesday, November 1, 2023 1:54 PM To: Fitzgerald, Paige (CRT) Subject: RE: Ethics question Paige, Do you know wheth�r they are seeking a federal grant? John From: Fitzgerald, Paige (CRT) Sent: Tuesday, October 31, 2023 5:22 PM To: Buchko, John {CRT)d._ Subject: Ethics question Importance: High Hi, John We received the below request from our POC with the National Abortion Federation, one of the three main reproclucti\le health care provider (RHCP) groups in the country (the others are Planned Parenthood and Feminfst Majority). We have wor�ed with NAF for decades. NAF regularly refers potential FACE Act violations and other threats to RHCPs, helps us liaise with clinics and.staff, lets us know apout upcoming events that might result in security concerns so we can notify FBI and USM$, etc. Because they are NGOs, they can poke aro1,md on the internet in ways that we can't, and they have shared leads With us� etc. The informatior, flow has always been a one-way street, and they have always been respectful, cooperative, and are frequently quite helpful. I'm guessing we probably can't do what they are asking, b�t is there anything that we can do to tell grant folks that they are totally legit and they have been valuable to our law enforcement efforts? Happy to jump 011 a call if that would be easier. Sanjay was in trial, and just sent this to me today and their response fs due tomorrow. . . Thanks, Paige From: Michelle Davidson �Qrochoice.org> Sent; Tuesday, October 24, 2023 5:37 PM To: Patel, Sanjay (CRT}d._ Subject: [EXTERNAL) Req1.1est Importance: High Hey Sanjay, I have a request that I hope you could squeeze into your very busy schedule. We have the opportunity to submit a proposal for grant funds that would support the already existing secur1ty work I do in the DMV for providers. I'm hoping you could write a short impact statement, on DOJ letterhead, and in your own words, on the importance of the NAF Security Departments work and the impact on provider safety in the OMV. You could also talk about how we work together and some of the outcomes of our efforts if you feel inclined. I know you have a lot going on but a statement from you would have a big impact on the proposal. I also completely understand if it's not possible so don't worry or stress - just let me know. Hope your good - looking forward to any updates on the next trial you may have. Let's chat soon! -M Michelle Davidson Director, Security Pronouns; Any (no preference) or just Michelle NAF Security •This /me ts no£ reliable for tt?J Sent: Monday, November 2, 2020 11:43 AM ; Fitzgerald, Paige (CRT) · To: Fleisher, Aaron (CRT) Sanjay (CRT) Cc; Tara Gannon �prochoice.org>; Emma Goldberg �ptochoice.org> Subject:- Fargo - Vandalism (FW) From: Sent: Monday, November 2, 2020 11:40 AM To: Michelle Davidson --@prochoice.org>; �;d­ llllll@cityoffargQ&.Q.ill. Subject:- - Fargo - Vandalism ; Patel, (MP)(FBI)�;­ �; On Saturday, October 31 st a t 12�32am a _climbed the fire escape at Clinic & did serious damage to the fire escape, broke a storm window accessible to that fire escape and apparently may have done some damage to an electrical box that doesn't belong to our building, but the one adjacent. The Fargo Police Department was notified on Saturday afternoon when the damage was disc0vered. Case #�as initiated by Office- It's possible that the suspect may have damaged a vehicle parked in the -lot across the street from the clinic. The suspect can be seen, although not well, from our video cameras near the vehicle that was damaged. I am in the process of backing up the video footage showing the individual approach by way of the east side of the building. There are multiple camera angles, so it takes some time to back up. After he left the fire escape, he left the c1rea by heading south, he turned toward the building & spent some time gesturing, apparently yelling & flipped his middle finger (with his left hand) toward the building. He then spent quite some time in the drive-up area of the Alerus bank building behind our building, also gesturing wildly & seeming to yell a lot towards their teller window. I am sure they likely have better footage of his face. We also discovered that there is a camera attached to the building next door to us on the west side that likely caught the entire incident of him doing the damage (our cameras. are not facing the fire escape) . ■ He . Honestly, it looked lik avenue around 12:50am. l a m hopeful that other cameras downtown caught him left via the south & turned west onto or that he interacted with another officer in some way. Officer - is out until Wednesday of this week. Please let me know if you have any questions or want copies of the footage. I generally have to share it via dropbox as files I have shared in the past are too large for any other medium. - Thanks, She/Her/Hers ) Abortlon � Hetworlt • I Board Member, ND WfN (Women in Need) Abortion Access Fund EXHIBIT 041 From: "Patel, Sanjay (CRT)'' To: "Emma Goldberg" �prochoice,org> Cc: "Michelle Davidson'' �prochoice .org> Subject: RE: Concerning tweet regarding Planned Parenthood - NAF Date: Mon, 12 Apr 2021 1 8:5 1 :54 -0400 Importance: Normal Ioline-Images: image001 .Jpg; irnage002.jpg; image003.jpg Thanks, Emma/Michelle. I've fwd your email to FBI HQ, and asked for their immediate attention to this. Also, I wanted to let you both know that I have been designated the DOJ National FACE Act Task force director. If you have time later this week for a call, I'd like t0 chat about what this means, and explore outreach initiatives. Fdday works best for me. Also, you can take Paige off of the email distribution list. now that I have been given this position. Thanks, SP From: Emma Goldberg �prochoice.org> Sent: Monday, April 12, 20214:38 PM To: Patel, Sanjay (CRT).._; Fitzgerald, Paige (CRT) i Smd (CRT) ldth, Katelyn (CRT) Cc: Michelle Davidson �@prochoice.org> Subject: Concerning tweet regarding Planned P.arenthood - NAF ; Cowall, Laura Hi all, We wanted to make you aware of a concerning tweet that was posted this morning and pass along the alert we rece1ved below. We're not familiar with this individual and do not know where he is located, but are alarmed by the language used. Please reach out if you have any questions or if we can assist further. Twitter user 111111' ( posted the following; "There are 3 P-!P-e bombs hidden inside my: clos6t !Jlanned garenthood,�V.oll have 12 hours." The post was not in response to any previous tweets, nor does it mention any other Twitter users, and appears unprovoked, , , The username . (- was not connected to arw other usernames and a public records of the user did not reveal any information. An thorough scrub of the user's profile did not uncover any previous mentions of Planned Parenthood or the topic of abortion. The user currently has less than 1,000 tweets and their profile appears to have been created sometime in February 2021. No other potential identifiable information was found on the user's profile. The user often posts support of Neo-Nazi beliefs, as well relatively threatening language against those of different political views or religious beliefs; however, these posts often appear to be ml')de in jest. Although the user's mention of Pl�nned Parenthood is threatening and co11cerning, the post does not mention anv specific locations or personnel, and the user does not appear to intend to act on their statements; however, this cannot be confirmed. While it does not appe-ar that the users intend to act on their hostile comments, this type of language does have the ability to evo,ldve and motivate individuals to take direct action in various forms such as protests, disruption ordviolence. Twitter Images: There are 3 pipe bombs hidden inside my closest planned parenthood, you have 1 2 hours 1�45 AM Apr l, l02l 11111UeJ wen App 0 C 0 Gen � Joined February 2021 26 Following 26 Followers Emma Goldberg Pronouns: she, her, hers Security Operations and Opposition Research Coordinator National Abortion Federation (T) (E) Confidentialit'{. Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this e-mail in error, please immediately notify the sender by e-mail at the address shown. Please delete it from your files if you are not the intended recipient. Thank you for your compliance. EXHIBIT 042 From: "Fleisher, Aaron (CRT)" To: "Patel, Sanjay (CRT)" Subject: RE: Obstruction Post-Lauren Handy-DMV D�te: Tue, 1 8 Aug 2020 1 J :39:42 -0400 Importance: Normal lnline.-lmages: image00J .png; image002.png; image003.png Great-thanks, Sanjay! Aaron Fleisher Trial Attorney Special Litigation Section, Civil Rights Division U.S. Department of Justice Phone:eFrom: Patel, Sanjay (CRT) Sent: Tuesday, August 18, 2020e11:38 AM To: Fleisher, Aaron (CRT) Cc: Fitzgerald, Paige (CRT) Subject: RE: Obstruction Post-Lauren Handy-OMV ; Mody, Saeed (CRT) Hey, Aaroh. I've been in touch With Michelle and I'm looking into this. 11 11 keep you posted. SP From: Fleisher, Aaron (CRT) Sent: Friday, August 14, 2020 9:43 PM To: Michelle Davidson -@P-rochoice.org>; Fitzgerald, Paige (CRT) Sanjay (CRT) Cc: Tara Gannon �Rrocnoice.org>; Emma Goldberg �P-roc:hoice.org> Subject: RE: Obstruction Post-Lauren Handy-OMV ; Patel, Hi, Michelle. If she actually ends up causing any obstruction, please let me know. I can't speak for Paige and Sanjay, but we on the civil side might be interested in looking further at that. Thanks, Aaron Aaron Fleisher Trial Attorney Special Litigation Section, Civil Rights Division U.S. Department of J ustice Phone: From: Michelle Davidson �@.P.rochofce.org> Sent: Friday, August 14, 2020 4:08 PM ; Fitzgerald, Paige (CRT) To: Fleisher, Aaron (CRT) ; Patel, Sanjay (CRT) Cc: Tara Gannon �Rrochoice.org>; Emma Goldberg �@P.rochoice.org> Subject: Obstruction Post-Lauren Handy-DMV Hi DOJ Team, Please see the following post below. Handy's hearing for her previous RRR arrest is scheduled for 8/18. I wonder if there is any way we can get this to the prosecuting attorney? We will alert our members and LE contacts in the OMV area. Let us know if we can do anything else. I hope yo·u all have a good weekend. -Mlchelle Because I'm ei Sent: Saturday, January 30, 2021d10:06 AM To: (WF) (FBI) � Fleisher, Aaron (CRT) ; Patel, 5 Cc: Emma Goldbergd._@prochoice.org>; Melissa Fowler �@prochoice.org> Subject: Invasion- Silver Spring Importance: High (WF) (FBI) ) httgs: www.facebook.com Plannin There is an active invasion/blockade at have spoken wit� and everyone inside is in lock down and sheltering in place. Police- were called 20 minutes ago have not arrived yet. Lauren Handy and unknown others are inside. Patients are not able to access. s live streaming. Stay safe, Michelle Davidson Director, Security All pronouns are respectfully accepted (They(Them, He/Him, She/Hers) National Abortion Federation Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient, and may, contain confidential and priVileged information, Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this e - mail in error, please immediately notify the sender by e -mail at the address shown. Please delete it from your files if you are not the intended recipient. Thank you for your compliance. EXHIBIT 044 'From: Michelle Davidson To: "Patel, Sanjay (CRT)" Subject: RE: .Jonathan Darnell Date; Tue, 08 Dec 2020 14:42:01 -0500 Importance: Normal Working on this now. From: Patel, Sanjay (CRT)d� Sent: Tuesday, December 8, 2020 2:14 PM To: Michelle Davidson �@prochoice.org> Subject: Jonathan Darnell Hey, MichelleI Ccln't recall if you ever shared anything with me (either through an attachment or via Dropbox) about Jonathan Darnell's arrest at the other/second clinic from 1111117 If you did, can you re-send that to me? Thanks. SP EXHIBIT 045 O pe ration Save America N atio n a l Eve nt Reso u rce G u i d e PHOENIX, ARIZONA JUNE 23 - 26, 2021 1 A T I O A L l' A B O R f I O N F E D E RA T I 0 1 Contents General Information ..................................................................................................................... 4 Schedule of Events .................................................................................................................... 4 Hotel I nformation ......................................................................................................................4 Relevant Arizona Ordinances and Statutes .......................................................... ...................... 5 Facility Ordinance .................................................................................................................. 5 Residential Picketing Statutes ................................................................................................ 5 Freedom of Access to Clinic Entrances (FACE) Act Fact Sheet ....................................................... 6 Anti-Choice lndividuals ................................................................................................................ 13 ........................................................................................................ 13 ..................................................................................................... 16 ....................................................................................................................... 2 1 - ..............................................................................................................................2 3 ··········~··········..······························ . . ········· ......................................... 25 ........................................................................................................................ 27 ........................................................................................................................... 30 ......................................................................................................................... 32 ....................................................................................................................... 34 ........................................................ , ........................................................... 36 ............................................................................................................... 38 - ............................................................................................................................... 41 Eva Edi ..................................................................................................................................... 44 ......................................................................................................................... 47 ..................................................................................................................... 5 1 ............................................................................................................................ 54 ····················......................................................................................... 56 - ····························································································································· 59 ................................................................................................. 61 ......................................................................................................................... 65 ..................................................................................................................... 67 SENSITIVE INFORMATION. Do not disseminate without prior written consenl NATIONAL ABORTION FEDERATION 2 Heather ldoni .......................................................................................................................... 70 ........................................................................................................ 72 ················································.......................................................74 -·······························································································································77 ......................................................................................................................... 80 .................................................................................................................. 82 .............................................................................................................. 84 ................................................................................................................ 86 ............................................................................................................... 88 -................................................................................................................................... 90 -·····················.. ·········· .. ···· ....................................................................................... 92 ....................................................................................................................... 94 .................................................................................................... 96 Derin Stidd ............................................................................................................................... 98 Jason Samuel Storms ............................................................................................................. 101 .................................................................................................................. 104 ............................................................................................................. 107 ............................................................................................................... 111 ..................................................................................................................... 113 ....................................................................................................................... 115 Calvin "Cal" Zastrow ............................................................................................................... 117 ........................................................................................................................ 120 Eva Zastrow ........................................................................................................................... 122 James "Jimmy" Zastrow ......................................................................................................... 125 Violence and Disruption Statistics Reports ............................................................................... 127 ........................................................................................................ 127 -Family Planning ................................................................................................... 128 - Family Planning ................................................................................................... 129 .......................................................... 130 ......................................................................................................................... 131 SENSITIVE INFORMATION. Do nol disseminate without prior written consenl NATIONAL ABOKTION FEDE.RAl ION 3 Appendix A ................................................................................................................................ 132 Freedom of Access to Clinic Entrances (FACE) Act ................................................................. 132 SENSllIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERA1ION 4 Gene1 al lnforni at1on Schedule of Events. Wednesday, June 23: 6:30pm: Opening rally at Church of the Redeemer - Thursday, June 24: Morning: Protest at local clinics 2:30pm: Afternoon session at Desert Hills Bible Church ( 6 :30pm: Evening rally at Desert Hills Bible Church ( Friday, June 25: Morning: Protest at local clinics 2:30pm: Afternoon session at Desert Hills Bible Church ( 6 :30pm: Evening rally at Desert Hills Bible Church - Saturday. June 26: Morning: Protest at local clinics 2:30pm: Afternoon session at Desert Hills Bible Church ( 6 :30pm: Evening rally at Church of the Redeemer OSA has blocked off rooms at the Hotel Informat,on in Mesa -) .:,[JIISrflVt:. INFUKMATION: Do not dissen,111ate w1l11ou1. pr,01 w1itle11 consefll NATIONAL AOOR IION F-EDERATION 5 Relevant Arizona Ordinances and Statutes Faollty Ordinance - - PHOENIX, ARIZ., CODE OF ORDINANCES.§ 23-10.1 (2010). Relevant Provisions: Creates an eight-foot cease-and-desist bubble zone within a 100-foot buffer zone around any health care facility. The ordinance makes it unlawful for a demonstrator to fail to withdraw, upon a clear request, beyond eight feet from any person in the buffer zone. Relevant Cases: Sabelko v. City of Phoenix, 68 F.3d 1169 (9th Cir. 1995), reversing 846 F. Supp. 810 (D. Ariz. 1994), vacated and remanded, 519 U.S. 1144 (1997), aff d 120 F.3d 161 (9th Cir. 1997) (ordinance ruled u nconstitutional because it was not narrowly tailored); but see Hill v. Colorado, 530 U.S. 703 (2000} (finding constitutional an eight-foot cease-and-desist bubble zone within a 100-foot buffer zone outside of health clinics). Residential Picketing Statutes Arizona -ARIZ. REV. STAT..§ 13-2909 (2015). Relevant Provision: Prohibits residential picketing, defined as "demonstrating before or about the residence or dwelling place of an individual...with intent to harass, annoy, or alarm another person." Relevant Cases: State v. Baldwin, 908 P.2d 483 (Ariz. Ct. App. 1995) (statute ruled constitutional). MESA - MESA, ARIZ., CODE OF ORDINANCE §§ 6-12-4, 9-2-1 Relevant Provisions: Prohibits gatherings of two (2) or more people from creating noise which "disturbs the peace and quiet of a neighborhood or a reasonable person of normal sensibilities". Also prohibits the obstruction of any public walkway with personal property. StNSITIVE INFOKMATION. Do not d1ss�rrnnate without prior written consent NI\ I IONAL ABOIHION FEDEKATION 6 Free d o m of Acc ess to Cl i n ic E n tra n ces ( FACE ) Act Fact S h eet What is the Freedom of Access to Cli nic Entrances Act? The FACE Act ( see Append ix.(A fo r fu l l text) esta blishes that it is a fe dera l crime to co m m it a range of vi olent, obstru ctive an d threate ning activities towa rd rep rod uctive h ea lth care providers a nd their pati e nts. FACE a lso a u tho rizes rep rod uctive hea lth care provid ers, the state attorney ge nera l, an d/or the fe deral government to bri ng ci vi l lawsuits to get injunctions against these activitie s 1 or to obtain mo netary d a m a ges. Why was FACE passed? D uri ng the 1980s a n d e arly 1990s, cl inic protests a n d b l oc kades we re o n the rise . Violence a g·a i nst abortion prov i ders was esca lati ng across the country, cu lm inating in the m u rder of Dr. G u n n in M arch of 1993 outsi d e a P e nsacol a, FL cl i n i c, a n d the atte m pted murder of Dr. Ti ller i n August of 1993 outside his Wi ch ita, KS cl inic. These inc idents propelled Con gress t o pass new fede ral legis lati on to address the viole nce aga inst re prod u ctive hea lth care provi ders and the denial of access to people see k i n g the i r services. When was FACE pa ssed? FACE was pas sed by the U . S . Co ngress and signed i nto law by fo rmer Presi dent Cli nton in May of 1994 . What does FACE proh ibit? FACE m a kes it i l legal to i nte nti ona lly use fo rce, the t h reat of force, or physica l obstruction to i nj u re, i ntim idate, interfere with, or attempt to inju re, inti m i date or interfere with somebody who provides or is obtain i n g re prod u ctive health services. FACE a l so pun ishes anyo ne who i nte ntio na lly d a m a ges or d e stroys a faci lity th.a t provi des repro ductive hea lth service s. 1 What/Who does FACE protect? • A fac i lity or a ny person that works at a fac ility that provides re prod uctive hea lth se rv ice s. • Patients of facil ities t hat p rovide rep roductive health services . • Peo ple acco m p anying patie nts, su ch as a pa rent, pa rtner, or cl i nic escort. What is incl uded in "reproductive health se rvices"? FACE covers m ore than j u st a bortion services. /(R epro d uctive hea lth se rvi ces" inc l u de medica l, s urgical, co u n seling, or refe rra l se rvices related to pregn a n cy or the termination o f preg na ncy provid ed in a hosp ita l, cl i n ic, p hysi cia n's office, o r other fa cil ity that provides re prod uctive hea lth s ervi ces. l 18 USC.A-§ 248(a ) . S E. N S I T I V l::. I N FO H MATI ON . Do n ot d 1 sse1rnnate w ithout p r i or writ ten rnns ent NI\ I IONAL ABOlfflON F E D E .R ATION 7 Who is a "reproductive health care provider"? Any person t hat p rovi des reprodu ctive health services . Tra ined professio nals who wa r� i n facil ities a re covered by FACE, as are staff necess ary fo r the safe fu n cti o n i ng of a fac ility, s uch as secu rity gua rds, m a i ntena nce staff, a nd patient escorts . Peo ple who work in a nti-cho ice re productive hea lth fa c i lities, such as crisis pregn a n cy ce nte rs, are a l so covered by FACE. Protesters an d si d ewa l k co u n selors w ho try to give i n formatio n to wo men o utsi de of re prod u ctive hea l th care fa cil ities are not cove red. 2 What does the phrase "i nterfere with" mean ? Congre ss incl uded specifi c defi n itions in the Act to cla rify the mea n l n g of th e law. "I nterfe re with" m ea n s to re strict a pe rson's freedom of movement. W hat d oes the term "i ntimidate" mean? P l aci n g a person in reason a bl e a p p re he nsion of bod i ly injury to him o r herself o r anot her. What is consi dered a "physical obstruction"? Ren d ering the e ntra nce or exit of a fa cility that provi des reprod uctive health services impass a ble, or m a king access into and out of such a faci lity u n reaso n a bly d i fficult or haza rdo us. What is considered a "th reat"? A statem ent is a true th re at if a reasonable person m aking the state m ent wo u ld foresee that it would be i nte rpreted by the person to whom it is m ade as a se rio us expression to inflict h a r m o r assa u lt . 3 I n assessing whethe r a state ment i s an un lawful t h reat, the context in w h ich the state m ent was m ad e m u st be consid ered, including the reaction of th e listener. What are some exa mples of conduct that FACE prohibits? • Any a ct i vity that bl ocks access to the entra nce o r obstructs the exit of a faci lity; blocking people trying to wa l k towa rds doors o r t h ro ugh parking lots; or ma king getting in and out of the fac il ity u n reason ab ly d i fficult or da ngero us. • Acts of physical vi ol e nce, such as shovi ng, d i rected towards clinic staff, escorts or patients. • Va n d a l iz ing a re pro d uctive hea lth care faci lity by glu ing locks or butyric ac id attac ks. • Th reats of vio lence. In one case , a ma n was fo und to h ave threatened fo rce u n der FACE when he pa rke d a Ryd e r truck outs ide of a cl i n ic shortly after the bo mb ing of a fed eral bu i ld i n g in Okl ah om a Ci ty w he re a Ryd er truck had ca rried the explosives. 4 • Sta lking a n d t h reate n ing a cl in ic e m p l oyee o r a reprodu ctive hea lth provid er. 2 Raney v. Aware Woma n Ce nter for Choice, I nc., 2 24 F .3d 1 266 ( 1 1th Cir. 2 000). 1 P l a nned Parenthood vs. ACLA, cert. denied. � U .S. v, Hart, 2 1 2 F .3d 1067 (8th Cir. 2000) , SE.NSITIVE I N FO RMAT IO N . Do not d1sst>1T11nate, w ithout µr\ur written rnns r wrllten consent NI\l lONAL ABOI�flON FEDERAT ION so "Jesus Christ has not called me to murder the abortionists. Jesus has called me to block the doors so no one is killed." - Abortion Foes in Boot Camp Mull Doctor's Killing, N.Y. Times, Mar. 19, 1993 (quoting Chet Gallagher). SE.NSITIV[ INFORMATION. Do not disseminate without prior written consent NA IIONAL ABORTION FEDE.R.l\l ION 51 AKAs:008:d­ Last Known Address: Previous Addresses: Phone Number: Website: Email: - Social Media: Facebook: Twitter: lnstagram: Linkedln: VouTube:d- and- is married to - They have at least -children, __l_ wife cohosts Podcast with him, and they frequently discuss their anti-abortion views and activities. SENSITIVE lNFOKMATIDN; Do not disseminate without prior written consen1 NATIONAL ABORTION FEDERATION 52 Apologia Studios Franklin Classical School King's Meadow Study Center New College Franklin Operation Rescue U.S. Taxpayers Party of Tennesse� - April 16, 2021:.- acted as a preacher for a Gideons International Conventioh. April 10, 2021 : - spoke at God and Government online conference hosted by Cruciform Ministries. August 2020: - was a featured speaker at the 2020 For God and Truth Conference, titled "A Biblical Response to Crisis". 2018: - was a guest on Planned Parenthood. Apologia Radio podcast to speak about the history of 1998: - acted as a witness for defendant Operation Rescue in N.O.W v. Scheidler 1994: - spoke at an annual conference of the BC Pro-Life Society 1991: - spoke at an annual conference of the BC Pro-Life Society - is the author of a number of pro-life books, including: - He has also written many books on Christian family values, ''biblical" alternatives to SENSITIVE INFORMATION: Do not disseminate without prior wnlten conseni NA I ICJNAL ABORTION FEDERATION 53 state welfare, other conservative topics. He has also written several other anti-abortion materials and created books and video curricula for classical Christian education. He and his wife - host a Christian podcast called Podcast and frequently discusses prolife topics. He also hosts a podcast called SENSITIVE INFORMATION. Do not d1sserrnnate without prior written consent N/\ I IONAL ABORTION FEDERATION 54 AKAs : DOB: Last Known Address: Previous Addresses: Phone Number: Website : ­ Email: Social Media: Facebook: Twitter:­ lnstagram: Linkedln: YouTube:.- - who is also engaged in anti-choice activities. They have at - is married to least -children, _ _ _ _ and.- is closely associated with and SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 55 Living Hope Min istry Operation Save America Parents as First Educators September 19-22, 2019: -was a speaker at the Church Arise conference ind-· May 3-5, 2019: - was a speaker at the Evangelism Conference (SOEC) in -may drive a _wit� license plates : - March 18, 2019: "The Church at Planned Parenthood" - Saved Magazine YouTube video SENSITIVE. INFORMATION : Do not disseminate without priur written consent NATIONAL ABORTION FEDERATION 56 AKAs: D08: Last Known Address: Previous Addresses: Phone Number: Website:­ Email: Social Media: Facebook: Twitter:­ lnstagram: Linkedln: ­ VouTube : - Jason Storms, and.- SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 57 Nationwide Abolish Human Abortion Operation Save America - is extremely engaged in anti-choice activities. In addition to protesting outside of reproductive health care facilities, he also protests outside of churches, schools, and major public areas. Additionally, - is known to drrve a "truth truck," cross-country, making stops at schools and reproductive health care facilities. June 22, 2019: - was detained with pride parade. the for trespassing at On February 15, 2012 - protested outside the with a sign that stated "Where's Your Church?" - reportedly traveled to clinic in August 2009 after to protest at . He has also protested at - "truth truck'': St.NSITIVE INFORMATION: Do not dtssermnate without prior written consen1 NA I IONAL ABORTION FEDERATION 58 SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 59 AKAs:­ DOB: Last Known Address: Previous Addresses: Phone Number:._ Website: ­ Email:. Social Media: Facebook:. ­ Twitter:­ lnstagram: Linkedln: VouTube:.- - is closely associated with SENSITIVE IN FORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 60 Nationwide Operation Save America Spirit One - States o f Refuge - - travels nationally for Operation Save America events. ■ July 2011: - attended the annual Operation Save America national event in July 2010: - attended the annual Operation Save America national event i n - ■ July 2012: - attended the annual Operation Save America national event in - SENSITIVE INFORMATION: Do not d1ssem1nate without prior written consenl NAIIONALABORllON FEDE-RATION 61 AKAs:.­ DOB: Last Known Address: Previous Addresses: Phone Number: Website:­ Email:. Social Media: Facebook:. ­ Twitter:­ lnstagram: Linkedln: VouTube: - SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 62 - is married to who is also engaged in anti-choice activities. - is closely associated with and - previously voiced criticisms of- but in recent years he has teamed up with Operation Save America to target clinics. Nationwide Army of God Missionaries to the Prebon-­ Operation Save America srns, rive INFORMATION. Do not disseminate without prior written consent NATIONAL ABORTION FEDE-RAl ION 63 - is a "Moderator" for the Missionaries to the Preborn Facebook page. 2014: -traveled to-to attend court hearing for- 2001: -attended the White Rose Banquet and gave an introduction for Driver's License Numbers: SE.NSI rlVE INFORMATION. Do not disseminate without prior written consent N/\l lONAL ABOIUION FEDE.RAl ION 64 SENSIrlVl INFO�MA rjON. Do not disseminate without pm1r written consent NI\ I IUNAL ABOHnoN FLDlRAl ION 65 AKAs: DOB: Last Known Address: Previous Addresses: Phone Number: Website:­ Email: Social Media: Facebook: ­ Twitter:­ lnstagram: Linkedln: YouTube: - - is married to SENSITIVE INFORMATION: who is also engaged in a nti-choice activities. Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 66 Nationwide Abolish Human Abortion (AHA) Army of God Missionaries to the Preborn - SENSIflVE INFORMATION: Do not disseminate without prior wr tten consent i NATIONALABORTION FEDE-RATION 67 AKAs: __ _ DOB: Last Known Address: Previous Addresses: Phone Number: Website: ­ Email:. Social Media: Facebook: Twitter:lnstagram: Linkedln:­ YouTube: SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 68 - is married to (nee __ They have at leastllll children together. The whole family travels together for a nti-choice protests and events with AHA. - is associated with - -- - - Jason Storms, 1111 Abolish Human Abortion Abolitionist Society of_ Apologia Studios The Ekklesia ofFree the States - - creates and distributes pamphlets and fliers for Abolish Human Abortion (AHA). He assists in organizing AHA events, protests, and rallies. abortion "abolitionist." after becoming convinced that God chose him to be an He draws a sharp distinction between "pro-life leaders" and "abolitionists," mainly that the pro­ lifers make too many compromises on abortion, like in the case of rape or incest. November 16, 2019: - and his family participated in the Abolish Abortion Conference in - SENSITIVE INFORMATION: Do not disseminate without prior written consent NA I IONAL ABOR rtON FEDfRATION 69 March 8, 2014: Meet the rebels of the anti-abortion movement - MSNBC SENSlilVE INFORMATION: Do not disseminate wi1hout prior wrltten consent NATIONAL ABORTION FEDERATION 70 Heather ldoni AKAs: DOB: Last Known Address: Previous Addresses: Phone Number: Website: ­ Email: Social Media: Face book: Twitter:­ lnstagram: Linkedln: YouTube: . They have at least ldoni is closely associated with Zastrow, and Eva Edi. ■ children together,_ Dennis Green, Joel Curry, Cal Zastrow, Eva Red Rose Rescue ONElife for Life SENSITIVE INFORMATION. Do not disseminate without prior written consent NA I IONAL ABOfUIUN FEDERATION 71 Citizens for a Pro Life Society Abolitionist Society of Central - in April 16, 2021: ldoni was arrested during a blockade at Saginaw, Ml, with Eva Edi. March 5, 2021: ldoni was arrested during a blockade at - in Mt. Juliet, TN, with Dennis Green, (minor), Eva Zastrow, James Zastrow, Cal 11111 Zastrow, Eva Edi, and three other minors. August 27, 2020: ldoni was a rrested in a blockade at Joel Curry, Heights, Ml, with Justin Phillips, Cal Zastrow, Eva Zastrow and Eva Edi. April 24, 2020: ldoni attended the national Red Rose Rescue conference in ldoni frequently protests outside of reproductive health care facilities in June 4-5, 2021: ldoni travelled and protested during a Red Rose Rescue for an invasion at the in - SENSITIVE INFORMATION: Do not d1ssem1nate without prior written conseni NA I IONAL ABORl ION FEDERArtON 72 AKAs: DOB: Last Known Address: Previous Addresses: Phone Number: Website: Email:dSocial Media: Facebook: Twitter: tnstagram : Linkedln: YouTube: - is separated from They have. at least. children. The entire family is engaged in anti-choice activities. - is the -of the Association of Pro-life Physicians and the - Person hood 1111- SENSITIVE INFORMATION: II Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 73 1111 Nationwide 1111 Personhood Operation Save America - July 2019 : - and her family participated in the annual Operation Save America national event in February, 2019: - published a book, under attack. about religious liberty being - was a featured speaker at the 2018 OSA National Event in - and her husband organize protests at the annual conference of the American College of Obstetricians and Gynecologists. Previous attendees include and 1111 - his wife, - and their children participated in OR/OSA's national events in The- became involved in anti-abortion activities when they were in college at ­ in the __ - took part in formal campus debates on abortion while - was the - of the campus' anti-abortion organization. - SENSI rJVE INFORMATION: Do not d1ssen1inate without prior written consen1 NA I IONAL ABORTION FEDERATION 74 AKAs: DOB:. ­ Last Known Address Previous Addresses: Phone Number: Website: ­ Email:. Social Media: Facebook: Twitter:­ lnstagram: Linkedln: VouTube: - SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 75 -is married to Ill- has at least 1111 children. At least - of their children, 1111 is also engaged in anti-choice activities. She is closely associated with Army of God American Coalltion of Life Activists (ACLA) il Red Rose Rescue frequently brings one or more of her children when she demonstrates at clinics. She in - She continues to protest regularly at the January 24, 2019: - attended the national March for Life in Washington 1 DC. She claims she was there as part of a documentary on abortion. 1111 entered a reproductive health care facility in September 5, 2019: - and her daughter - posing as a patient and her mother. On the same morning, Joan And rews Bell, Jonathan Darnel, and Lauren Handy entered another reproductive health care facility in -and carried out a "Window of Opportunity Rescue." This type of invasion SlN5rl IVl- 1NFORMATtON. Do nol disseminate without. prIur written consent NA I I ONAL ABOM noN FEDERA110N 76 involves anti-choice individuals entering a facility, speaking with patients, and leaving the property before police arrive. In 2014, - entered a reproductive health facility in osing as a patient. -was honored at the- Rose Banquet in 1998, a gatherihg for anti-abortion extremists organized by and Army of God. -joined was jailed in-. and others to picket in support of-while he - attended the White Rose Banquet in the in January 1996. - S[N'ilflV{ INFOflMf\ TlON. Do nol ci1ss�m1n.ile will 10111 prim WIit.ten consent N/1 l lONAL ABOri rtON FEDE.RA1ION 77 AKAs: DOB:. Last Known Address: Previous Addresses: Phone Number:_ Website: ­ Email:. Social Media: Facebook:.­ Twitter:­ lnstagram: Linkedln: YouTube:.- . They have - children:and . They have several grandchildren. - wife is vocal in her support for her husband and acts as president of- Christian legal organization . At least - of- children have also been SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 78 employed by the - While some of- children remain out of the spotlight, his son - is affiliated with Jason Storms, -· a n d llll - American Family Association -Operation Save America Personhood USA - SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONALABORl ION FEDE-RATION 79 "You know, some told me 'you know they're a radical group.' I said yeah. They are radical for God." - defending his affiliation with Operation Save America. SE.NS! rlVL INFORMATION. Do not disseminate without prior written consent NA IIONAL ABORTION FEDE.RAl ION 80 AKAs:.DOB: Last Known Address: Previous Addresses: Phone Number:._ Website:­ Email:. Social Media Twitter: lnstagram: Linkedln:. ­ Reddit: Kik: Usperson Ask.fm: SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 81 - mother, also participate i n anti-choice activities. - is closely associated Jason Storms, -family, Abolish Abortion Operation Save America � - - (September 2018 - Present) - is known to protest at various reproductive health facilities in - including_ Additionally, he travels for Church Arise conferences and Operation Save America events. - participates in Project Frontlines, protesting abortion outside of schools with graphic images, with March 15, 2017: - and members of Abolish Abortion- delivered a letter to Governor Scott Walker December 8, 2018: Operation Save -Facebook live- outside FPA in - SlNSI rlVE INFORMATION: Do not disseminate without prior written conseni NA I IONALABORl ION FEDERAnuN 82 AKAs:.­ DOB: Last Known Address: Previous Addresses: Phone Number: Website : ­ Email: Social Media: Twitter: lnstagram: Linkedln: YouTube:.- - who is also engaged in anti-choice activities. They have at -is married to least 1111 children together, 1111, 1111, a n d -· - is closely associated with - SENSITIVE INFORMATION: Do not disseminate without prior written consent and NATIONAL ABORTION FEDERATION 83 The.Ekklesia.of- - ­ Operation Save America - - frequently protests outside of the facility. He also participates in training anti-choice individuals to protest abortion and recruit others. November 2, 2019: - attended the anti-choice "Repent With Us" conference in that was cohosted by the Ekklesia o- and Operation Save America. January 25 - 26, 2019: - attended the Ekklesia of- first statewide gathering. November 2017: -founded the Ekklesia of- an anti-choice organization, with -· - SENSITIVE INFORMATION: Do not disseminate without prior wrillen consent NA110NAL ABORTION FEDERATION 84 AKAs:DOB: Last Known Address: Previous Addresses: Phone Number: Website: ­ Email:.Social Media: Facebook: Twitter:lnstagram: Linkedln:. ­ VouTube:.- 1111 is married to who is also engaged in anti-choice activities. - frequently participates in OSA activities with him and has made threatening statements against local providers in They have at least - son, - and - daughter, SENSITIVE INFORMATI ON: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 85 Operation Save America - in - - leads weekly OSA protests at a -· - has traveled to NYC and elsewhere to protest with - and OSA. July 2019: - participated in a n d helped to lead the annual Operation Save America national event in January 24, 2019: -protested outside of -with dozens of other anti-choice individuals, including Jason Storms, and in He participated in the OR/OSA Leadership Meeting in - in February 2010, a n d he helped lead the July 2010 OR/OSA National Event i n October 2009: -protests outside of a reproductive health care facility in- ■ May 20, 2019: Extremists Are Winning the War on Abortion -Vice News SENSl1JVI: lNFORMATION . Do not dtsseriilnate wtlhout prh..11 wrrtten consenr NATIONAL ABORTION FEDERATION 86 AKAs:­ DOB: Last Known Address: Previous Addresses: Phone Number: Website: ­ Email: Social Media: - is married to SENSITIVE INFORMATION: (nee_, who is also engaged in anti-choice activities. Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 87 Apologia Studios End Abortion Now Cross Politic Studios - June 2018: - attended the Biblical Worldview Student conference as a speaker. 2017 - 2018: - was the Executive producer of.' created with -- ".which he May 4 - 6, 2017: Now - National Leadership Conference" in - in Apologia Studios' "End Abortion 2014: ­ Murdered Here" 2004 - 2006: - attended - SENSITIVE INFORMATION: Do not disseminate without prior written consent the Apologia Studios a nti-choice film, "Babies Are in NA I IONALABORTION FEDERATION 88 AKAs : DOB: Last Known Address: Previous Addresses: Phone Number:._ Website: ­ Email:. Social Media: Facebook:. ­ Twitter: ­ lnstagram: Linkedln: YouTube:.- SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 89 who also participates in Abolish Human Abortion events. -is married to They have at least- children together. - is closely associated with Abolitionist Society of Fort Worthd_ Abolish Human Abortion - attends many Abolish Human Abortion protests and events. He sometimes participates in "Project Frontlin es,'' which involves protesting abortion outside of local middle ,rnd high schools. Portrait of an Anti-Abortion 'Abolitionist' SENSnlVE INFORMATION. Do not disseminate without prior wrltten consenr NA TIONAL ABORlION FED ERAlION - 90 AKAs:­ DOB: Last Known Address: Previous Addresses: Phone Number: Website: ­ Email: Social Media: Facebook:. ­ Twitter:­ lnstagram: Linkedln: -· YouTube:.- - ■ 1111 is married to-. They have children. -wife has been active with Person hood- efforts and other anti-abortion activity. -children also participated in anti-abortion activity when they were younger. 1111 is associated with Dennis G reen, Jason Storms, and Cal Zastrow. SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 91 Morning Center Ministries Operation Save America Person hood Alliance Person hood - - •. • . • I •,I I , '.' I • Ill According to the Person hood Alliance, has been involved in anti-abortion work since 1991, ranging from sidewalk counseling to advocacy. August 2020: Ill Ill became of Personhood Alliance. 2011: which would have helped write and campaign for defined life and person hood as beginning at fertilization in the - state constitution. The amendment did not pass, but continued his work with Person hoodd- and Person hood Alliance. Ill September 2011: 'We think that God has already told us when life begins, and science has confirmed it, and the court has just not dealt with it. We hope the -voters will force them to take another look at that decision." _ .., in an interview with Huff Post about the-Personhood movement. SENSHJVI: INFORMATION, Do not disseminate without prlur written con�ellt NATIONAL ABORTION FEDERATION 92 AKAs:.­ DOB: Last Known Address: Previous Addresses: Phone Number: Website: ­ Email:. Social Media: Facebook: Twitter: lnstagram: Linkedln:. ­ VouTube:.- who is also engaged in anti-choice activities. They have - is married to children together, _ _ _ and.- The kids also appear to be engaged in anti- SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 93 choice events. There are photos of them singing at "abortion-free" events, sitting on the OSA camper, and praying outside of reproductive health facilities. The-family is associated with the _ _ _ a n d - families. Nationwide Operation Save America - - is known to travel to participate in Operation Save America protests and events. - and his wife, - are regular protests at facilities. reproductive health care SENSITIVE INFORMATION: NAflONAL ABORTION FEDERATION - Do not disseminate without prior written consent 94 AKAs: DOB: Last Known Address: Previous Addresses: Phone Number: Website:­ Email:. Social Media: Face book: Twitter: lnstagram: Linkedln: VouTube: - - is married to - who is also engaged in anti-choice activities. They have children together, - - - and-· The kids also appear to be engaged in antiSENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 95 choice events. There are photos of them singing at "abortion-free" events, sitting on the OSA camper, and praying outside of reproductive health facilities. The-family is associated with the _ _ _ a n d - families. Nationwide Operation Save America - - is known to travel to participate in Operation Save America protests and events. - and her husband, Ill, are regular protests at facilities. reproductive health care - SENSll IVE INFORMATION: Do not disseminate without prior written consent NAflONAL ABORTION FEDERATION 96 AKAs:DOB: Last Known Address: Previous Addresses: Phone Number:._ Website:­ Email:. Social Media: Facebook:. ­ Twitter: lnstagram: Linkedln: YouTube: - - is closely associated with SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 97 Missionaries to the Preborn Operation Save America July 2019: - participated in the annual Operation Save America national event in As of 2015, � was registered to - wit� license plates: 1990: - moved to.- to join Missionaries to the Preborn - SENSITIVE INFORMATION: Do not disseminate without prior written consent NA I IONAL ABORTION FEDE.RAl ION 98 Derin Stidd AKAs:.DOB: Last Known Address: Previous Addresses: Phone Number:._ Website:.­ Email:. Social Media: Facebook: Twitter:­ lnstagram: Linkedln: YouTube:.- SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 99 The have 1111 kids: Stidd is married to children. Both - and.- participate in anti-abortion activity. frequently accompanies his father to a nti-abortion events, has participated in events for Abolish Abortion - and uses Facebook as a platform to encourage other kids to participate as well.- is not as actively involved in a nti-abortion preaching or protest but is vocally anti-abortion and has volunteered with Operation Save America. Stidd and his wife frequently bring their younger children to protest outside of abortion clinics with them. Stidd is associated with Jason Storms, - Cruciform Ministries Free the States Church - Paster Operation Save America - Assistant National Director as of June 2021 - Stidd has been involved with Operation Save America since at least 2017 and was tapped to serve as Assistant National Director under Jason Storms when stepped down in 2021. He consistently attends national and regional events with OSA, as well as leadership conferences, and occasionally drives an OSA trailer decorated with anti-abortion messages. Stidd also serves as a pastor in April 2021: Stidd and his family took a road trip to conduct anti-abortion outreach April 10, 2021: Stidd spoke at a conference titled "God and Government" hosted by Cruciform Ministries. Several other a nti-abortion leaders spoke, including and .. -· SENSITIVt INFOHMATION. Do not chssemmate without prior written conser11 NATIONAL ABORTION FEDEHATION 100 October 22, 2020: Stidd spoke at a conference titled "Holiness and the Sanctity of Human Life'' hosted by Cruciform Ministries. July 24, 2020: Stidd spoke at the 2020 Operation Save America National Event in.-· February 10, 2020: Stidd gave a talk titled "What Can Southern Baptists do to Abolish Abortion?" at an event with Free the States and.- Baptists for Abolishing Abortion. July 2019: Stidd participated in Operation Save America's 2019 National event in April 5, 2019: Stidd and other local anti-abortion leaders hosted the Abolish Abortion Conference. Jason Storms and spoke at the conference. January 22-23, 2019: Stidd and his family traveled to -for the 16th anniversary of Roe v. Wade. They joined OSA members and other anti-abortion leaders at a rally outside of the - State House and participated in protests outside of a local clinic. July 2018: Stidd participated in a Justice March with Operation Save America in - S[NSITIVt INFORMATION. Oo not dtsserrnnate without pnur written conrnnt N/1 I IONAL ABOIHION FEDEHArlON 101 Jason - Storms AKAs: ­ DOB: Last Known Address: Phone Number: Website:­ Email: Social Media: Facebook: Twitter:­ lnstagram: Linkedln: YouTube: - SENSITIVE IN FORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 102 Jason is married to- (nee_, the daughter of who is also engaged in anti-choice activities. They have at least 1111 children together. Their oldest daughter, - also participates i n anti-choice activities and mission trips. Storms is closely associated with the-family, - Church.­ Missionaries to the Preborn Operation Save America - National Director (anticipated June 202 1 - Present), Former Assistant Director, Former Director of Campus Outreach Storms holds anti-choice protests at- reproductive health care facilities, schools, and public areas such as parks and highway overpasses. June 2021: Storms will officially succeed the OSA national event in-· as the National Director of OSA during July 2019: Storms attended and helped lead Operation Save America's annual anti-choice "Summer of Mercy" event i n Storms and hi s wife .. along with the help of created the Faithful Soldier School of Evangelism, which is dedicated to Biblical discipleship, academic training, and evangelism and outreach. Storms worked as a substitute teacher in the - Public School system in 2018, where he admittedly spent hours preaching to students and "making disciples." SlNSITIVE INFOKMATION. Do not disseminate without prior written consem NA I IUNAL ABORrlON FEDERATION 103 - SENSITIVE INFORMATION: license plate:- Do not disseminate without prior written consent NATIONALABORTION FEDERATION 104 AKAs:­ DOB: Last Known Address: Previous Addresses: Phone Number: Website:­ Email: Twitter: lnstagram : Linkedln: YouTube:l- -is married to . They have are also engaged in anti-choice activities. He also associates with SENsrnvE INFORMATION: I and Do not disseminate without prior written consent ■ children. -and many of their children of Abolish Human Abortion. NATIONAL ABORTION FEDERATION 105 Nationwide Christ in Action -­ Elijah Ministries -­ March for Jesus Missionaries to the Unborn Operation Rescue Operation Save America - - plans to step down from OSA leadership at the end of the June 2021 summer national event in - is a regular protester at the facility in - -· - participates in most Operation Save America events, including the annual national summer event, "Summer of Mercy,'' and other smaller regional protests and conferences. SENS!nv1: INFORMAf!ON. Do not disseminate without prior written consent NATIONAL ABOI� rtON FEDERATION 106 - participated in clinic protests and pickets of providers' homes (including the in July 1995. distribution of "wanted" posters) with Operation Rescue in - appears frequently with and appeared to be a major participant and organizer during the Operation Rescue activities at the Republican National Convention in August 1996. -was in for Operation Save America's "Summer of Mercy Renewal" in 2001. He seems to have a leadership role in Operation Save America protests around the country. - S[NSITIVE INFOKMATION. Do not dtsserrnnate without prior written consent NA I IONAL Al30RTION FEDERATION 107 AKAs:­ DOB: Last Known Address: Previous Addresses: Phone Number: Website: Email: Social Media: Facebook: Twitter:­ lnstagram: Linkedln: YouTube:.- ■ lll is married to-. The- have children, the entire family is engaged in anti-choice activities. SENSITIVE INFORMATION: Do not disseminate without prior written consent NA'flONAL ABORTION FEDERATION 108 - daughter - is married to -· Nationwide - with a focus on the Free the States Gun Owners of America Lesser Magistrates Missionaries to the Preborn Church - Pastor Oklahomans United for Life Tell The Truth Ministries U.S. Taxpayers Party Youth for America, Defensive Action SENSITIVC INFORMATION. Do not disseminate without prior written consenl NATIONAL ABORTION FEDERATION 109 of Missionaries to the Preborn, he and his followers have mounted a relentless for years. In addition, they conduct campaign against abortion providers in several "show the truth" tours each year in cities across the-. - often organizes his followers and members of Missionaries to the Preborn to canvass and protest personal residences and neighborhoods of physicians of abortion clinics. January 9-11, 2020: - attended the Church Arise Alaska conference in November 5 - 8, 2019:e- attended the "Defenders of life -- Freedom Rally" in July 2019: Participated in and helped lead Operation Save America's annual national event in ' that advocates for the defiance of local/state/federal laws that are deemed "unjust'' by religious teachings. In May 1994, - {alohg with Operation Rescue- Randall Terry) addressed the - state U.S. Taxpayers' Party convention. In September 1995, -was sighted in with Operation Rescue leader - recruiting for the U.S. Taxpayers Party and promoting militia causes. - attended the 2001 White Rose Banquet - is a signatory of the Defensive Action Statement. ■ Drivers License:. -. . . . ' . - - ,. . .. ,' . ' StNSITIVE INFOHMATION. Do not disseminate without prior wrillen const!nt NATICJNAL A BOil !"ION FEDEHA IIUN 110 -Trying To Convince Elected Officials That Women Who Have Abortions Should Be 'Tried For Homicide' "It has long been established in law, not to mention Holy Scripture, that it is legitimate to use force in order to defend other persons from bodily harm. Therefore, this idea that the use of force or violence on behalf of the preborn is 'unthinkable' or 'wrong' is nonsense." - - Executed, Missionaries to the Preborn, http://www.missionariestopreborn.com/mtp articles.html#paulhill 1111 -Executed, Missionaries "Hate is good. God loves and God also hates." to the Preborn, http://www.missionariestopreborn.com/mtp artides.htmf#paulhill "[The government] are low-life swine and they aim to disarm us. What should we do? We should do what thousands of people across this nation are doing. We should be forming militias. Churches can form militias today and teach their men how to fight." Email to the National Abortion Federation (citing Broadcast, Nation Public Radio, May 2, 1995) (on file with the National Abortion Federation). "This Christmas I want you to do the most loving thing and I want you to buy each of your children an SKS rifle and 500 rounds of ammunition." Editorial, Protest Poisoned by Fanaticism, Milwaukee Sentinel, Aug. 19, 1994, at A14 (quoting "We are living under socialism . . . the reason we should have guns is because we are Christians, and we have a biblical view of man. The reason we should have guns is because of our government." WVCY radio broadcast, Milwaukee, Wisconsin (Jan. 28, 1993) (quoting -· November 2019 - 1111 children, with spouses, and grandchildren: SEN5111Vt INFORMATION: II Do not disseminate Without prior written consent NATIONAL ABORTION FEDERATION 111 AKAs: DOB: ­ Last Known Address: Previous Addresses: Phone Number: Website: ­ Email : Social Media: Facebook: Twitter:­ lnstagram: Linkedln: VouTube: - - is closely associated with SENSITIVE IN FORMATION: Do not disseminate without prior written consent and -· NATIONAL ABORTION FEDERATION 112 Nationwide Abo lish Human Abortion (AHA) Operation Save America (OSA) - frequently protests outside of reproductive health care facilities, strip clubs, pride parades, and churches. He often brings large posters with images of products of conception to these protests and uses a megaphone. September 2019: - attended the a nti-choice Church Arise conference i n -· July 2019: - attended the annual Operation Save America "Summer of Mercy" event in July 2018: - attended the annual Operation Save America "Summer of Mercy" event in 2015: Graduated from - SEN5rrlVE. lNFORMATION . Do not dissemmate without prior written consent with a degree in NATIONAL ABOKTION FEDERATION 113 AKAs:­ DOB:. Last Known Address: Previous Addresses: Phone Number:_ Website: Email: Social Media: Facebook: Twitter:.­ lnstagram: Linkedln: VouTube: - - is married t� They have- young children. - wife has also expressed anti-abortion views. is the son of who is also active i n the anti-abortion movement. - is associated wit� Derin Stidd and SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 114 For God and Truth Operation Save America Youngliving Essential Oils - - runs a blog where he regularly posts his thoughts on "faith, family, and business.'' H e does not appear to participate in direct anti-abortion activism such as sidewalk counseling and has not explicitly discussed abortion on his blog. However, he expresses anti-abortion views openly on social media and has expressed his opposition to Roe v. Wade and other abortion protections. August 2020:l- spoke at the 2020 For God and Truth Conference, November 2019: - and other members of his local church climbed Mt. Kilimanjaro to raise money for an anti-human trafficking organizatron. - SENSIHVI: INFORMATION: Do not d1sseoiinate w1Lhout prior w, ltten conseni NATIONAL ABORTION FEDERATION 115 AKAs : ­ DOB: - Last Known Address: Previous Addresses: Phone Number:_ Website : ­ Email:. Social Media: Facebook: Twitter:­ lnstagram: Linkedln: YouTube: - participates in anti-abortion activities. - is associated with SENSITIVE INFORMATION: Do not disseminate without prior written consent Derin Stidd, and NATlONAL ABORTION FEDERATION 116 - Right to life For God and Truth National Right to Life Operation Save America - - does communications and development work at - Right to Life and has contributed to National Right to Life News. October 4, 2019: - spoke at 10 Talents Conference, a Christian networking conference in SENSITIVE INFORMATION: Do not disseminate without prior written consent NA I IONAL ABORTION FEDE.RATION 117 Calvin "Cal" Zastrow AKAs:DOB: Last Known Address: Previous Addresses: Phone Number:._ Website: ­ Email: Social Media: Facebook: Twitter:lnstagram: Linkedln:. ­ VouTube:.- SENSITIVE IN FORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 118 , , Cal is married to_. ,.. Zastrow. They have.illchildren:.- - James, and Eva. The whole Zastrow family is engaged in anti-choice activities. refers to his family as the "Zastrow Holiness Revival Team," II -Heather ldoni, Coleman Boyd, Dennis Green, 1111 Nationwide and International Constitution Party­ Operation Rescue Operation Save America (OSA) Pastors' Emergency League Personhood USA­ Voice for Life Ministries March 5, 2021: Zastrow was arrested for trespassing while participating in a blockade at - in Mt. Juliet, TN, with Eva Edi, Dennis Green, - (minor), Heather ldoni, Eva Zastrow, James Zastrow, and three other minors. August 27, 2020: Zastrow was arrested for trespassing while participating in a blockade at i n Sterling Heights, Ml, with Joel Curry, Eva Edi, Heather ldoni, Justin Phillips, and Eva Zastrow. SENSITIVE INFORMATION. Do not chsseminate without prior wrllten consem NA I IONAL AHOIHION FEDE"HAl ION 119 Zastrow frequently protests outside of reproductive health care facilities in and around Saginaw and.- Ml. Additionally, Zastrow is known to travel nationwide for anti-choice events and clinic blockades, and internationally for mission trips with his family. July 2019: Zastrow participated in Operation Save America's annual anti-choice protests outside of in for Operation Save America's annual "Summer of Mercy" antiZastrow was in choice rally and has participated in several other national OSA events since then. Zastrow relocated to - in 2011 to promote the passage of a Person hood Amendment to the state constitution. SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 120 AKAs:­ DOB: Last Known Address: Previous Addresses: Phone Number: _ Website:­ Email: Social Media: Facebook: Twitter:­ lnstagram: Linkedln: YouTube : - SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 121 (_), who was engaged in anti-choice activities in - is married to - prior to meeting-. They h a ve at le ast- child togethe r - is the one of Ca l an�a strow's.-child ren. Hisllll siblings a re - Eva, a nd James Zastrow. The entire Zastrow family is engaged in anti-choice activities and they sometimes refe r to themselves a s the "Zast row Holiness Reviva l Team.".- siblings a nd father have been arrested fo r anti-choice activities in the past. Zastrow is closely associated with and-. Michigan, Kentucky ONElife for Life Operation Save Ame rica - in -a n d- D-'-ra J a nu a ry 26, 2019: "'" �-=-"="""'--""""-'--'--'�"'--""-="-'--"-""""""""-'-'--"'-'"""-'""-"'-'""-'--"'-'-=-="'-"-"""'"' (Zastrow quoted) SENSITIVE INFORMATION: Do not disseminate without prior written consent NAl IONAL ABORTION FEDERATION 122 Eva Zastrow AKAs: DOB: Last Known Address: Previous Addresses: Phone Number: _ Website:­ Email: Social Media: Facebook: ­ Twitter: ­ lnstagram: Linkedln: YouTube: - SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 123 Eva Is one of Cal and IIII Zastrow's-children. Herllll siblings are - - and James Zastrow. The entire Zastrow family rs engaged in anti-choice activities and sometimes refer to themselves as the "Zastrow Holiness Revival Team." Several members of the Zastrow family, including Eva, have been arrested at reproductive health care facilities in the past. Zastrow is closely associated with Eva Edi, Coleman Boyd, Heather ldoni, Dennis Green, James Zastrow, and - Nationwide and International Operation Save America March 5, 2021: Zastrow was arrested for trespassing while participating in a blockade at Dennis Green, - in Mt. Juliet, TN, with Eva Edi, - (minor), Heather ldoni, Cal Zastrow, James Zastrow, and three other minors. August 27, 2020: Zastrow was a rrested for trespassing while participating in a blockade at in Sterling Heights, Ml, with Joel Curry, Eva Edi, Heather ldoni, Justin Phillips, and Cal Zastrow. Zastrow participates in OSA protests with the rest of the Zastrow family and Eva Edi. She also frequently travels as a missionary. December 2020-February 2021: Zastrow travelled to- to minister in a refugee camp. SENSITIVE INFOHMATION. Do not disseminate without pr1ur written consem NI\ I IONAL ABOHTION FEDEHAr!ON 124 October 221 2020: Zastrow participated in a Red Rose Rescue clinic invasion a t­ -but was not arrested. Zastrow travelled to - a missionary in 2018 and to SENSITIVE INFORMATION: Do not disseminate without prior written consent in 2019. NATIONAL ABORTION FEDERATION 125 James ''Jimmy" Zastrow AKAs:­ DOB: Last Known Address: Previous Addresses: Phone Number:._ Website: ­ Email:. Social Media: Facebook:. ­ Twitter:­ lnstagram: Linkedln: YouTube:.- 1111 Zastrow's- children. His 1111 siblings are -­ James is the one of Cal and and Eva Zastrow. The entire Zastrow family is engaged in anti-choice activities and sometimes refer to themselves as the "Zastrow Holiness Revival Team." Several members of the Zastrow family, including James, have been arrested at reproductive health care facilities in the past. SENSITIVE INFORMATION: Do not disseminate without prior written consent NATIONAL ABORTION FEDERATION 126 Zastrow is closely associated with Eva Edi, Dennis Green, 1111 Eva Zastrow, and - Nationwide Operation Save America March 5, 2021: Zastrow was arrested while participating in a blockade at - in Mt. Juliet, (minor), Heather TN with Eva Edi, Dennis Green, ldoni, Cal Zastrow, Eva Zastrow, and three other minors. Zastrow participates in OSA anti-abortion protests with the rest of the Zastrow family. - SENSITIVE INFORMA110N. Do not disseminate without prior written consent NAIIONALABORl lON FEDE.RAl lON 127 Vtolence and D1sruplion Stalist1cs Reports _,.. Statistics submitted to NAF 2D13-2019 (Export date: 06/15/2D21) 2015 0 0 2 20 3 0 2D14 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 8 0 0 0 48 0 600 156 (] 0 0 Type of Incident ML(rder Attempted Murder Bombing Arson Attempted Bombing/Arson Invasion Vandalism Trespassing Butyric Acid Attacks Anthrax/Bloterrorfsm Threats Assault & Battery Death Threats/Threats of Harm Kidnapping Burglary Stalking Hate Mail/Harassing Ca((s Hate Email/Internet Harassment Hoax Devices/Suspicious Packages 2013 0 0 0 0 0 0 0 157 0 Bomb Threats Picketing Obstruction Clinic Blockades �lNS111VE. INFUKMATION. {) 0 {) t)o nor d1ssen i1nate w11l1ou1 pr10, w11tten conser1 2017 2018 N/A N/A 2016 NIA NIA N/A N/A 2019 Totals 0 0 0 NIA 0 0 0 0 0 0 N/A 0 D 0 N/A N/A N(A NIA NIA NIA NIA NIA 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 157 0 0 N/A NIA N/A 0 0 0 NIA N/A 0 NIA NIA NIA NIA NIA NIA NIA N/A N/A N/A 0 0 0 0 0 N/A N/A NIA NIA N/A NIA NIA N/A NIA N/A N/A NIA NIA NIA NIA NIA NIA N/A NIA NIA NIA N/A NIA N/A N/A N/A NIA a a 0 0 2 79 3 0 0 D NIA N/A 0 48 0 104 NIA N/A 0 0 N/A N(A 0 0 0 800 156 0 N/A N/A 0 0 a a 51 NAIIONALABOK1ION FEDERATION 128 --Type of Incident Murder Attempted Murder Bombing Arson Attempted Bombing/Arson Invasion Vandalism Trespassing Butyric Acid Attacks Anthrax/Bioterrorism Threats Assault & Battery Death Threats/Threats of Harm Kidnapping Burglary Stalking Hate MaiVHarassing Calls Hate Email/Internet Harassment Hoax Devices/Suspicious Packages Bomb Threats Picketing Obstruction Clinic Blockades �E.N'illlVI: INFORM/\TION. 2013 201.4 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2015 NIA N/A 2016 NIA NIA N/A NIA NIA NIA NIA 2017 2018 2019 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 NIA N/A N/A NIA NIA 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 a 0 a a a NIA NIA NIA 0 0 0 0 11 0 0 16 2 2 0 0 N/A NIA NIA N/A N/A NIA N/A N/A N/A NIA NIA N/A N/A NIA NIA 0 N/A N/A 0 0 N/A 0 0 0 0 N/A NIA NIA NIA 0 0 0 0 0 0 0 0 0 0 a a 0 1 0 a 36 t)o noi ci1sse111111;;te w11l1uu1 prn.11 w11U1· 11 c.or,s�,, a a 0 0 169 1 N/A NIA NIA NIA 0 0 1 a 10 a 0 a a Totals 1 2 38 0 0 0 0 0 0 0 0 1 0 0 1 222 247 279 953 NA I IONAL ABOI� IION F-1-DH1A rlUN 129 -Type of Incident Murder Attempted Murder Bombing 1013 NIA N/A 2014 NIA N/A 1015 1016 2017 0 0 0 a 0 0 0 0 0 0 0 0 0 0 NIA N/A N/A N/A 0 2018 2019 Totals N/A N/A NIA N/A 0 0 0 NIA N/A N/A NIA NIA NIA NIA NIA NIA NIA 0 0 0 0 0 0 0 0 0 0 0 0 NIA N/A 0 0 0 0 0 0 0 0 NIA N/A NIA N/A 0. 0 0 0 0 0 0 0 0 N/A N/A Q Assault & Battery Death Threats/Threats of Harm Kidnapping Burglary N/A NIA NIA NIA N/A NIA N/A N/A 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 1 N/A N/A 0 0 Stalking Hate MaiVHarassing Calls Hate Email/Internet Harassment Hoax Devices/Suspicious Packages NIA N/A N/A N/A NIA N/A N/A NIA 0 0 0 0 0 0 1 20 NIA N/A 0 3 7 1 2 0 12 2 7 NIA N/A 0 0 1 Bomb Threats Pfeketing ObstructloH Clinic Blockades N/A N/A N/A NIA N/A 0 0 0 0 0 0 N/A 0 0 0 0 NIA NIA NIA NIA NIA NIA 0 0 0 0 0 0 0 0 Arson Attempted Bombing/ Arson Invasion Vandalism Trespassing Butyric Acid Attacks Anthrax/Bioterrorism Threats N/A N/A !>E.NS111Vt INFUIIMATION. Oo not d1�seo1milte wilhuu1 µr1u1 wrlt1rn tor,,t!nl 0 0 0 a 0 N!\1 IONAL A80RIION F-EDERATION 130 _.., Type of Incident Murder Attempted Murder Bombing Arson Attempted Bombing/Arson Invasion Vandalism Trespassing Butyrfc Acid Attacks Anthra>< Devices/Suspicious Packages Bomb Threats Picketing Obstruction Clinic Blockades 3 0 2014 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 8 0 0 2015 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 156 0 0 0 2013 0 0 0 0 0 0 0 157 0 0 0 0 0 0 2 21 244 SE.NSlllVI: INFURMATION. Oo not d1sseo11nate wtlliou, pr1u1 wduen cori•e111 1109 2016 0 0 0 0 0 0 0 5 0 0 0 0 0 2017 0 0 0 0 0 2 0 2018 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 s 1 0 0 0 0 0 0 0 0 1 67 23 0 1 0 0 0 0 0 0 0 4 0 0 983 0 0 58 3 64 111 827 0 1 152 2019 0 0 0 0 0 1 0 2 Totals 0 0 0 0 0 3 0 170 0 0 0 1 1 0 0 0 0 0 2 283 89 579 183 0 0 0 1 1266 4551 0 160 0 1 NAI IONAL ABOI{ IION FfDE:RA I Jt.JN 132 Appendix A Freedorn of Access to Clmic Entrances ( FACE) Act Summary: Section 248 of Title 18 protects the exercise of free choice in obtaining reproductive health services, and the exercise of First Amendment religious freedoms. Section 248 makes it u nlawful for a person to use force, threat of force, or physical obstruction to intentionally injure or intimidate a person because he/she is or has been obtaining or providing reproductive health services. Section 248 also makes it unlawful for a person to use force, threat of force, or physical obstruction to intentionally injure or intimidate a person because he/she is lawfully exercising the right of religious freedom at a place of worship. Finally, Section 248 makes it unlawful for a person to intentionally damage or destroy the property of a facility because it provides reproductive health services, or because it is a place of worship. Section 248 also prohibits anyone from attempting to commit any of the above. An offense under this statute is punishable by a range of fines and/or imprisonment up to a life term, depending upon the nature of the offense and whether or not it is a repeat conviction under this statute. TITLE 18, U.S.C., SECTION 248 (a) Prohibited activities. - Whoever(1) by force or threat of force or by physical obstruction, intentionally injures, intimidates or interferes with or attempts to injure, intimidate or interfere with any person because that person Is or has been, or in order to intimldate such person or any other person or any class of persons from, obtaining or providing reproductive health services; (2) by force or threat of force or by physical obstruction, intentionally injures, intimidates or interferes with or attempts to Injure, intimidate or interfere with any person lawfully exercising or seeking to exercise the Flrst Amendment right of religious freedom at a place of religious worship; or (3) intentionally damages or destroys the property of a facility, or attempts to do so, because such facility provides reproductive health services, or intentionally damages or destroys the property of a place of religious worship, shall be subject to the penalties provided in subsection (b) and the civil remedies provided in subsection (c), except that a parent o.r legal guardian of a minor shall not be subject to any penalties or civil remedies under this section for such activities insofar as they are directed exclusively at that minor. (b) Penalties. - Whoever violates this section shall(1) in the case of a first offense, be fined in accordance with this title, or imprisoned not more than one year, or both; and (2) in the case of a second or subsequent offense after a prior conviction under this section, be fined in accordance with this title, or imprisoned not more than 3 years, or both; except that for an offense involving exclusively a nonviolent physical obstruction, the fine shall be not more than $10,000 and the length of imprisonment shall be not more than six months, SE.NSITIVl 1NFDl To: "Patel San·a CRT" , "Cowan, Laura >,n"Smith.nKatelyn (CRT'' < Cc: Michelle Davidson �prochoice.org> Subject: NAF - Social Media Posts and OSA Info Date: Thu. 1 3 May 2021 17:32:35 -0400 Importance: Normal Attachments: 202 1 05 1 1-0NS .pdf lnline-lmages: image00 I jpg; image002.png; image003.png Hello DOJ Te� Please find the attaclied document with recently discovered anti-choice social media posts. Additionally, I'm including a Facebook nost from Cal Zastrow today that commemorates the fourth aru1ivei-sary of the blockade in Louisville at EMW in 2017, that reads, "Come join us for more." ln a conune11t on a rclaLe Share ;i,ar,;o a memory. ■ 4 Years Ago See lour Memones > M,y 13, 20l7 Id Gr<>ater love, h.ls no one \h,r, th,;, that sornrone lay oown tis li fe fu, Eimna Goldberg �prochoice.org> Subject: More RRR iofo Date: Thu, 20 Aug 2020 L0:42:37 -0400 I mportance: Normal Attachments: 201 905-RWW-RRR_Alt.pdf; � Handy-Statements.docx Hi Sanjay, Attached is more info on the Red Rose Rescue individuals and the group itself. Again, please pass these on to Aaron along with the previous email if you think it might be useful to his department. I hope you have a good weekend. -M 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch To our readers: Right Wing Watch, a project for People For the American Way, is run by a dedicated staff driven to shed light on the activities of right-wing political organizations. As a non-profit working hard every day to expose the Far-Right's extreme and intolerant agenda, our main source of support is donations from readers like you. If you use Right Wing Watch, please consider making a contribution to support this content. MENU $ Meet the Farm Team of the Radical Antiabortion Activist Movement By Robin Marty | May 15, 2019 5:15 pm Anti-abortion activist Lauren Handy photographs her handiwork on the facade of a Planned Parenthood clinic in Washington, D.C. Photo (c) 2019 Robin Marty https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsOm… 1/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch It was bitterly cold, even for January. A frigid wind cut through my cloth gloves MENU as the sun slowly dipped behind the white stone façade of Planned Parenthood’s Carol Whitehill Moses Center in Washington, D.C. The clinic, which offers abortions and other health-care services to patients in the nation’s capital, had already closed for the day. The guards were gone from the entrance; the clinic escorts–volunteers dressed in bright vests, who help patients navigate the continent of protesters who customarily greet them—had all gone for the day. Instead, a glance through the glass doors showed a lone security person inside, likely remaining on duty until all of the staff and patients left for the evening. Lauren Handy, a 25-year-old anti-abortion activist, waved at the man at the desk, calling out to him by name. He ignored her as if it were his job—which, for the most part, it was. As a graduate and current alumni organizer of the youth-oriented group, Survivors of the Abortion Holocaust, Handy is a familiar presence in the clinic’s neighborhood. The D.C. Planned Parenthood building is always the center of bustling activity during the days surrounding the March for Life, an annual gathering where tens of thousands of abortion opponents—many of them high school- and college-aged—are bused in from around the country. When the clinic moved locations three years ago , reopening across the street from a neighborhood elementary school, the activists moved with it, bringing with them their annual protest welcoming the out-of-towners, which they conduct the day before the march itself. As Handy wrestled with her skirts against the wind and the pile of equipment at her feet, two large coach-style buses pulled up in front of the clinic and young people poured out from the open doors. Bundled against the unaccustomed cold, roughly 50 high school students from Baton Rouge, Louisiana, lined the edges of the sidewalk directly across the street from the clinic—careful to https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsOm… 2/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch leave the sidewalk itself open for foot traffic—silently standing as a priest MENU offered a “Hail Mary” and “Our Father.” Just minutes later the students turned and left to re-board their buses, their vigil over as quickly as it had begun. Any one of those students could easily be the next Lauren Handy. Like them, she also made the trek to D.C. from Baton Rouge this year to attend the March for Life. But unlike the shivering students bounding from the buses in their matching white stocking caps and bright green scarves, Handy wasn’t in D.C. for camaraderie, or to merely celebrate the wins that the anti-abortion movement had seen in the two years that Republican President Donald Trump had been in office, or to simply cheer on the possibility that the United States may be just a year or two from overturning the Supreme Court decision, Roe v. Wade, which would send the right to a legal abortion back to each state to decide. No, Handy was in town to end abortion completely, through whatever means possible. Handy was in town to end abortion completely, through whatever means possible. The Survivors of the Abortion Holocaust could in many ways be thought of as the “farm team” of the radical anti-abortion activist movement. Officially launched in 1998 by Jeff White, a former Operation Rescue leader from California, Survivors quickly became the go-to place for young activists interested in learning how to hone their skills in abortion debate, protesting in public spaces and asserting their First Amendment rights while doing both. https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsOm… 3/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch Deeming anyone born after 1973—the year that the Supreme Court decided MENU Roe—to be a “survivor” because they were born after abortion was deemed a federally protected constitutional right, Survivors accepts anyone between the ages of 13 and 29 into the fold for camps and trainings. Many of those who attend these events are children of anti-abortion activists, or friends of children who already attended. Most new recruits come to Survivors via personal referrals. According to their website, in the roughly two decades that Survivors has been operating “hundreds” of Survivors have gone through the camp, with a number of them eventually moving on into leadership in other anti-abortion organizations, or even starting their own. For example, Keith Mason, a former Survivor, founded Personhood USA, the Colorado anti-abortion group best known for its repeated efforts to try to get the state voters to approve an amendment stating life begins at conception. Abortion-Free New Mexico, the southwestern organization dedicated to trying to shut down later abortions in Albuquerque, is led by Bud and Tara Shaver , both graduates of the Survivors. Stanton Healthcare , the growing network of antiabortion pregnancy and sexual health centers hoping to be the next “pro-life Planned Parenthood” (without offering any form of contraception) is the project of another Survivor, Idaho’s Brandi Swindell. Stand True, the national youth ministry arm of Priests for Life, was founded by Bryan Kemper, who not only was recruited by White while Operation Rescue was still in at its peak influence, but has continued to partner with White ever since, including assisting in Survivor trainings as a mentor. White’s founding of Survivors wasn’t the first attempt to recruit and weaponize younger activists for the abortion battle. For much of its history, Operation Rescue National included a youth ministry that continued even during its breakup and reorganization and eventual name-change to Operation Rescue/Operation Save America. https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsOm… 4/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch MENU Anti-abortion activists stage a “die-in” outside the U.S. Supreme Court in January 2019. Photo (c) 2019 Robin Marty Another youth-oriented anti-choice group was CALL (Collegian Activated to Liberate Life), an organization that was active in the 1990s, which encouraged students to dedicate one year of their education to living in a communal home and working to end abortion in their local areas. This quest involved everything from sidewalk chalking anti-abortion messages on sidewalks and holding “dieins”—a form of activism where students lay on the streets in the fetal position, draped in red cloth—to protesting pro-choice speakers or picketing at abortion clinics, or even “rescuing”—blocking clinic entrances or other avenues to ensure doctors and patients were unable to enter buildings to terminate a pregnancy. Rock for Life and Generation Life also worked to recruit students into the movement, all hoping to bring more younger activists to the cause that began as being historically dominated by the elderly. https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsOm… 5/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch “Back in those days [the 1970’s and 80’s], you know what we called a pro-life MENU rally with 50 year olds? A youth rally,” Reverend Pat Mahoney quipped to me as we waited for a “die in” to begin at the Supreme Court. Mahoney, a longtime activist and one of the founders of CALL, still continues to work as an organizer in the pro-life youth movement. In 1994 the Freedom of Access to Clinic Entrances (FACE) Act prevented the movement from conducting the “rescues” that had become synonymous with pro-life activism, and which by this point had evolved from crowds of protesters blocking clinics with their bodies to include smaller groups that chained themselves to doors, cement blocks, broken-down vehicles and, of course, each other, in order to make their removal from clinic sites all the more difficult. At the height of the “rescue” movement, clinics could be closed for hours or even days because of anti-abortion protesters sitting by the hundreds in doorways, surrounding the cars of providers so they couldn’t leave their homes to get to the clinics where they worked, or even rushing inside and breaking equipment like the suction machines commonly used in abortion procedures. Born after the FACE Act took effect with its new limitations on anti-abortion protesting, leaders of Survivors of the Abortion Holocaust had to decide where this new line was drawn between impeding clinic access and expressing a First Amendment right to protest. Once they established parameters, they would train future anti-abortion leaders to push that line as far as they possibly could. The die-ins popularized by CALL became a favorite Survivor tactic, and while abortion opponents could no longer directly block clinics, they could still protest in front of them on public sidewalks and easements. They also concentrated on protesting the homes of abortion providers themselves, a tool that lost popularity among other anti-abortion activist groups after a streak of violence against abortion providers in the mid-1990s. Meanwhile, the group also trained and unleashed the new Survivors in the streets in an effort to change the public’s mind on abortion one person at a time, using graphic signs and street displays to draw bystanders in, to be treated to the young activists’ newly learned talking points. https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsOm… 6/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch MENU Survivors quickly became known for their in-your-face confrontations. Survivors quickly became known for their in-your-face confrontations, tactics that sometimes badly hurt their movement. In 2013, when the city of Albuquerque, New Mexico, considered a ballot measure that would forbid abortion after 20 weeks of pregnancy, Survivors swarmed the city to rally support for the ban. One day they protested the home of a local doctor who was providing these later abortions, terrifying the practitioner’s wife , who called the police to disperse them. The Survivors activists—mostly teens—passed out postcards with the names and photos of doctors doing later abortions in the city, calling them the “Killers Among Us .” They even took their large graphic images of fetal remains to the local Holocaust Museum in an effort to engage voters and solicit media attention. They got the attention, but it didn’t translate into support at the polls. The ballot measure failed 55-44, with pundits pointing to “overzealous ” abortion opponents as a key factor in the loss. Then again, winning legislative victories isn’t a primary goal of Survivors, who believe that it takes direct action and agitation to ensure that America wakes up from its complacency about the existence of legal abortion. It’s for that reason that the group increasingly focuses on actions that don’t just make abortion supporters uncomfortable, but sometimes their own allies, too. https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsOm… 7/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch Graphic fetal images displayed outside of schools or in other public areas MENU where young children might see them is one topic of disagreement. Another is over giving the young people in their ranks—many of them minors—the autonomy to run their own protests and actions, even if they are toeing the line of legality under the FACE Act. When it comes to protesting clinics or other public actions, the Survivors trainees are in charge of the mission. That could mean having 13-year-old children not only participating in protests, but often serving as media spokespeople and police liaisons, too. Lauren Handy (center) of the anti-choice group Survivors of the Abortion Holocaust and colleagues display movement recruitment signs in Washington, D.C. Photo (c) 2019 Robin Marty The tactics used by Operation Rescue are based around the notion that fertilized eggs, embryos and fetuses are “babies” whose lives can be “rescued” if abortion clinics are unable to serve patients. Activists who deploy such tactics as clinic barricades are said to be conducting “rescues.” According to Handy, Survivors doesn’t train their campers to revive “rescue” tactics per se, but they do make sure they are aware of the rescue movement’s history. They https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsOm… 8/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch are now also adding in the newly launched Red Rose Rescues MENU , a more moderate, less blatantly FACE-violating form of “rescue,” where activists enter clinics carrying roses, urge patients to leave, and refuse to exit the clinic until police physically remove them from the building. As for whether that could be seen as encouraging a new generation of potential lawbreakers, well, that’s up to the recruits themselves. “Of course, because they’re kids, they like the war stories,” Handy tells me. “They get hyped up and everything like that. Red Rose Rescue, it’s really sparked the spirit of rescue again. That hope of doing a tangible, sacrificing witness—kids who are so passionate, they’re drawn to that. They need an outlet, a physical outlet, and there’s only so much protesting [in a legal manner] can do.” So does Handy believe in encouraging teens to violate the FACE Act? When I ask her, she pauses for a few seconds. “Oh gosh, you’re going to quote me on this,” she says, hesitating, then adds in a rush, “Whatever. I believe minors should rescue because at 18 the records get sealed.” Handy’s belief in letting minors take the lead on actions that could potentially lead to arrest isn’t uncommon in the movement. “Children’s Rescue” was a regular component of pre-FACE “rescues,” one that was particularly effective because of police officers’ discomfort with arresting and physically removing minors from a clinic. The fact that so few people are currently advocating for minors to undertake full-fledged “rescues” in order to test out the Trump administration’s stance on upholding FACE might be the biggest sign that abortion opponents believe they are on the verge of winning the battle to end legal abortion. After all, why poke an administration that is already so obviously in your favor? https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsOm… 9/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch Handy joined the Survivors herself when she was 19, already too late to avoid MENU the advantages of stretching the boundaries of the law as a minor. In 2015 she was arrested in Washington, D.C., with a handful of other activists for refusing to leave the entrance to the office of then-Speaker of the House John Boehner, after the Republican leader refused to hold a House vote on a bill which would have banned abortion throughout the nation after 20 weeks post-fertilization, with no exceptions for sexual assault or fetal anomalies. More recently, Handy was arrested for her part in a Red Rose “ rescue ” in Washington, D.C., another in Alexandria, Virginia , and then yet another D.C. “rescue” just this March . So far none of Handy’s arrests have resulted in jail time, but should that be her fate, she’s not daunted by the idea. “It would be a great time to start a prison ministry,” she said. Undaunted by the prospect of incarceration, Handy said, 'It would be a great time to start a prison ministry.' https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsO… 10/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch That’s not an unusual outcome for “rescuers” who land in jail. According to MENU Handy, White himself ran Operation Rescue National for six months out of a jail kitchen while serving one of the many sentences he racked up as a prominent anti-abortion organizer. And he very well may end up running Survivors from there, too. In October of 2018, White accepted a plea deal for defrauding the federal government of $27 million through illegal drug rehabilitation program enrollments, a scheme which allegedly netted White between $3,000-$7,500 per patient in kickbacks ; White is facing five years in prison for his actions. While he admits his guilt, both he and his supporters argue that his motivation was primarily to help homeless addicts get the help they needed—and to take advantage of a government program to foot the bill. “I believe it’s a form of rescue in itself,” Handy explained, saying that White’s actions are similar to a “Robin Hood” situation: Robbing the rich to help the poor. “He was using that money to… make sure people could get into rehab. Basically finding loopholes to ensure people can get quality healthcare. I always call him the Robin Hood, especially in this sense. Yeah, screw over the rich to help [poor people]. I have no problem with that, but some people think it looks like he tarnished the movement, and people have distanced themselves from us. I mean that’s their decision and that’s what people live with. But Survivors are survivors. I mean, would you expect anything less?” Although the prospect of going to jail doesn’t seem to frighten Survivors, the vast majority of their current agitation campaigns are more guerrilla tactic than FACE-challenging. Legal or not, they definitely draw attention—along with the ire of pedestrians, clinics and police. As Handy struggled with a projector she intended to use to splash text and images on the Planned Parenthood building, I watched her suddenly jump up to dash after one woman who emerged from the clinic doors. https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsO… 11/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch “You don’t have to work here!” Handy shouted. “I don’t work there, bitch!” the woman retorted, speed-walking down the sidewalk away from us. MENU “She works here,” Handy told me in a conspiratorial tone, settling back down with her projector. While I spent the evening in the cold with Handy and two other activists (who were not current or former Survivor members), it was evident that no one was happy with the projections she was trying to display on the Planned Parenthood clinic walls. Anti-abortion activist Lauren Handy wields her light-projector against the facade of a Planned Parenthood clinic in Washington, D.C. Photo (c) 2019 Robin Marty Once it became clear that Handy was too close to the building for the projections to be effective, she crossed the street to try again. Careful not to block the sidewalk, which she knew would be a violation, Handy moved her https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsO… 12/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch equipment into the edge of the street to position the projector. A young man MENU walking by who appeared to be in his 20s approached her and demanded that she move. “This is a bike lane. You can’t be here,” he told her. We hadn’t seen a bike come through in the hour we had been outside. “Thanks for letting us know,” one of Handy’s companions told him, turning back to the machine. The objector stepped even closer. “You have to move. This is a bike lane. You have to keep it clear for bikes.” The three activists thanked him again and continued to ignore him. After a few minutes of continuing to tell them to get out of the bike line, the man then jumped in front of Handy’s projector, blocking the image from the walls. A small, white-lit fetus now appeared on his red jacket as he jumped up and down in front of Handy’s machine. Hoping to defuse the confrontation, I asked the agitated passerby if he would come talk to me for a second, to which he reluctantly agreed. “I think I can get them to move, but I need you to leave or they won’t do it,” I told him, explaining that I wasn’t with the group but might be able to sway them regardless. He agreed, then threw a dirty look at Handy and left. She moved her equipment out of the lane once he was gone. “I just really don’t like people thinking they can tell me what to do, and be rude about it,” she said, smiling. https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsO… 13/19 8/19/2020 Meet the Farm Team of the Radical Anti-abortion Activist Movement | Right Wing Watch It was clear that this was the sort of reaction that Survivors are used to. Soon MENU after, another man who appeared to live in the neighborhood came to argue about abortion with the anti-abortion activists, who by this point had been joined by two Red Rose Rescuers, too. Voices grew louder on both sides as two men went in circles over the right to life and the obligation of a woman to remain pregnant if she conceives. Soon a police car pulled up next to us. “What’s going on here?” an officer asked as he stepped out of the vehicle. “We are just here expressing our First Amendment rights,” Handy responded, as her companions took out phones to record any possible confrontation. “And how long exactly do you plan to be doing this for?” he asked. “Probably another 30 minutes,” she answered. As the officer got back in his car, she leaned over and told me, “The clinic called them on us.” Handy claims that having the police called on her is a regular occurrence when she’s around a facility that provides abortion services. The clinic building was now awash in glowing images: “Planned Parenthood Is Evil,” “Planned Parenthood is Bad Business,” “Fetal Uprising” (with a picture of a skeletal fetus curled beside the text). After 30 minutes of projectormessaging, the group was ready to move on to a new location, this time far away from any abortion clinics. “Survivors are the Marines of the pro-life movement,” Handy told me. “First ones in, last ones out.” And at the Planned Parenthood, you can be certain staff, neighbors and police were all glad to see them finally go. https://www.rightwingwatch.org/post/meet-the-farm-team-of-the-radical-anti-abortion-activist-movement/?fbclid=IwAR0FQgv-tfL5oirr0dcnI3E0OxsO… 14/19 Date: August 14, 2020 ,. All I'm saying is imagine 1 00s of Prolifers peacefully blocking the doors of an abortion center to stop the abortionist from walking in 8 1 AM Aeg i.! 2020 from - Twiner for 1Phane 5 Retweets ano .:cmments 70 dlres 0 Catholic&-tndito � @repr;:aux Aug l.! RE:olying to ® To be nonest all I need ,s two other people with me and I'm good to go not waiting around fo, 10Os v 2 t.l 1 Date: July 19, 2020 CatholicBandito '}I - � I was trying to plan a Red Rose Rescue for next month but rny upcoming plans are so chaotic & I don't have the funds to make it happen So it will be put on ho)d for now '� I'm starting to feel stir-crazy b/c I haven't been able- to fully Rescue in a year instead just in patiial 1 14 .�M ,.lul 19 ?02(1 irom Date: June 15, 2020 Ca1holicBandito Jill @- "You have to break the law to fix tl1e law" -Elastigirl The lncredibles 2 Red RoseRescue.com #RRR #'lmGoingln f ' ' 2:43 PM -Jun 15 2020 from-• Tv. tter br Phom Date: May 29, 2020 CatholicBandito � �I- I wonder who is beyond @AbortionTrials ?? l accidentally got arrested twice outside his late tem, abortion facility so props to the local Prolife crew working to take him down. Such an evil and vile man. 1 .10 A'vl , May l.9 2020 , Tv.itter for 1Phon e Date: May 14, 2020 CatholicBandito @repreaux � Update: Third possible Rescue happening in DC right now. It's kinda funny that I was on the phone directing them where the back door is - prayers for JP (his 1 st Rescue) and J isn't a newbie but DC jails aren't a walk in the park (I know that intimately) l eatnolicBandrto JIii @reoreau)( ��av 14 Update; There is a Si:'l:011d Rescue ha ppening ri ght now ill Brigham ;; DC abortion center led by Father f1defis who 1s w,th the Franc,scan Fne� of the Renewal and Canon Lawyer ,winer.com/repreaux/siatu... 1:07 PM May 14 2020nirom Seton Rouge L<'\ Twct:ernfor Dhon:c 1 Retweet 10 L1ice, Date: May 13, 2020 Lauren Handy 1s • • feeling thoughtftJI. May 1 3 • 0 Beautiful write up by fellow Rescuer -about the Grand Rapids Red Rose Rescue this morning. I have this clenching feeling in my heart wanting so desperately lo join in the next Rescue. I miss my friends and co laborers Red Rose Rescu May 13 0 Today m Grand Rapids M1ch1gan, Red Rose Rescue held it' s first "e parlong lot rescue" mission For four hours the rescuers courageously brought roses. l(md words of support, and God's love to abortion-bound couples on both ttie s1dewallc and then in lhe parking lot of the killing facility A number of molhers and fathers accepted the gift of roses Date: December 13, 2019 CatholicBandito ®repreaux 11111 At the Pomona Planned Parenthood and I mushed myself under the fence to be able to better reach the abortion minded rnoms. I left resources inside the fence. I've never been here before but the security guard apparently knew me and was yelling, "You can't do that-!!" '-,t 0 1236 PM Dec 13 2019 ,w,ner foriPhcne 3 Retwttts ano CC>mmeots 20 l•l<.B Date: September 27, 2019 CaU,olicBandito �r�p,.,.,,ux ,. ./fP1olifeMemo11 lnBnPf Made a vow as a kid 1b never fall into the bystander effe.ct. Not gonna sit by while 3500+- humans are slaughtered each day through State sponsored violence. Parable of the Good Samarftan is my guiding factor w/ getting in the trenches to get shit done s�c2-: 2019 Iw&1,t to get aJUmp o, ths =Prolife -:etore the cops come. Passing oul while flowers and praying with n minded couples This was inspited by tile Rescues lead unde­ •oi Operation Rescue West in lhe late 80s Those who viish lo go inside lhe lobbies bu1 can·t risk arrest lhfs is a type of Rescue lhat might be good for you to do.... I have been participating in Window of Opportunity Rescues for the last 6 years during the Christmas season and when ev,er lhe "opportunlly' arises. Peace and Love. Servant to the Abandoned, Unloved and Rejected 38 Comm�nu 4 Sh.3rs Date: February 28, 2019 ••• Lauren Handy February 28, 2019 • 0 'Legality' is not synonymous with justice. In U1e Nuremberg trials, the defense of ·1 was just following the law' 'Nas rejected. #RRR #lmGoingln #WWJD READ: tinyurl.com/y8r8pt8e ,I ,I ,I LIFESITENEWS.COM Weep not for pro-life prisoner Mary Wagner but become more like her OO�nd 9 others Date: January 29, 2019 6 Shares Lauren Handy is with Ja111.Jarv 29 2019 •0 nd 2 others. ••• Charges dropped !! on to the next one! #RRR #l mGoingln S ,,nf, 728032 737186 737188 737187 584039 737200 ....._ ___ �:i.:,�_ .. __ 00 75 11 Comments 7 Shares Date: August 17, 2020 htt s·: www .facebook.com (02:05) "We continue to do Red Rose Rescues, we will continue to try to save babies' lives, we have. saved many many many babies' lives, through Red Rose Rescues" Date: May 2, 2020 (12:30) "Whether we enter the waltfng rooms of th�e stand alone abortion facilities, or whether we enter into these high rise buildings, which is what I do I go tnto these high rise burldings and after were asked to leave the waiting rooms we go in the hallway and we stay in the hallway risking arrest, I've been arrested 4 times as I .said, many many babies have been save'd because many many women have turned around and left over the course of these RRRs many other women cannot access their appointments. We know that when that happens there is a good possibility a high percentage that they will not reschedule the appointment thinking the same thing is goihg to happen again. My little mantra on social media is RRRs save lives and protect mom's from abortion ... " (13:45) "We're planning on re-initiating Red Rose Rescues. The hiatus had to do a little bit to do with COVID-19, but this is a way in which we have revisited the rescue movement that was so prevalent in the late 80s and early 90s where 70,000 people throughout the country did peaceful protests... 70,000 people got arrested, tens of thousands of people entered the movement. This is what Red Rose Rescues are, trying to save babies intervening to save a baby's life, and indeed being a witness, standing in witness for the babies. while the babies are dying we refuse to leave these facilities we stay in solidarity with the babies while thy are dytng even to the pint of risking arrest and event of the point of spending time in jail and many of these RRRs have spent time in jail. It's a significant movement, if you want more information you can go to RRR.com to get more Tnformcltion and to register and we'll be in touch with you" (20:00) "So we decided to do whatsidewc1lk advocates is not doing, instead of setting up on the sidewalk we've extending the sidewalk into the buildings and we've had tremendous success saving babies, twning moms around, brining attentions to these two very evil abortionists." EXHIBIT 048 'From: "Patel, Sanjay (CRT)" To: "Michelle Davidson" �procboice.org> Subject: RE: More RRR info Date: Thu, 20 Aug 2020 1 5:38:53 -0400 Importance: No11nal Thanks, Michelle. Besides Handy, can you send me the names of the other defendants whose cases are pending in DC? And, if you have any case info (like case number, etc) I'll take that too. It will make it easier for me to track down the assigned prosecutor. SP From: Michelle Davidson �prochoice.org> Sent: Thursday, August 20, 2020 10:43 AM To: Patel, Sanjay (CRT) Cc: Tara Gannon ; Emma Goldberg �prochoice.org> Subject: More RRR info Hi Sanjay, Attached is more Info on the Red Rose Rescue individuals and the group Itself. Again, please pass these on to Aaron along with the previous em.ail if you think it might be useful to his department. I hope you have a good weekend. -M EXHIBIT 049 From: Michelle Davidson �prochoice.org> To·:" Cc: Tara Gannon �roch0ice.org>, Emma Goldberg �prochoice.org> Subject: Red Rose Rescue Info Requested Date: Tue, 18 Aug 2020 19:39:57 -0400 Importance: Nonnal Attachments: 19951031-Moscinski_C-An.pdf; 19970t20-Moscinski_C-A11.pdf; 1997-Moscinskl_C­ Art.pdf; Red_Rose_Rescue-Cluonology.docx lnline-rmages:image002.gif Hi Sanjay, Feel free to share this with Aaron as well. He replied to my previous email wanting to know if any action from Handy occurs. It might be useful for him to have the timeline as well. I also attached some articles on Moscinski that go pretty far back. Let me know if you need anything else. I'll definitely keep you posted If we hear of any attempts at clinics right away. Case Numbers: File Date 3/20/19 File Date 8/18/2020 File Date 8/18/2020 File Date 8/12/2020 Flle Date 8/12/2020 Michelle Davidson Director, Security All pronouns are respectfully accepted (They/Them, He/Him, She/Hers) National Abortion Federation Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient, and may aontafn confidential and privileged information, Any unauthorized review, use, disdosure, or distribution is prohibited. If you have received this e-marl in error, please rmmediately notify the sender by e-mail at the address snown. Please delete it from your files if you are not the intended recipient. Thank you fqr your compliance. http://www.aclu.org/news/w012097b.html January 20a1 1997� Abortion Protesters Win 'Scary' Ruling NEW YORK --· In what the New York Times calls a "novel ruling that has startled both sides in the abortion debate," a federal judge has decided that two anti-abortion protesters committed no crime when they blocked access to a Westchester County clin�c because chey were motivated by •conscience­ driven religious belief." The protesters, a retired Roman Catholic auxiliary bishop and a Franciscan friar, could have been found in criminal contempt of an order by c.he judg.e, John Sprizzo of U.S. District Court in Manhattan. But the judge, invoking a 1970 Supreme Court decision in favor of a V�etnam War conscientious objector, said that the men had been acting 0n ' sincere, genuine, objectively based" religious convictions. AJ1d since he was sitting as jury as well as judge in the October bench trial, he acquitted Bishop George E. Lynch and Brother Christopher Moscinski under a rarely e,cercised privilege that permits jurors to vote in defiance of a law i= they believe it is wrong, the Times said, As word of the acquittal spread, abortion-righcs supporters reacted with alarm. ''It· s an off-the-wall, scary decision," Donna Lieberman, director of the Reproductive Rights Project of the New York Civil Liberties Union, told the Times. It• s so close to the A.c.lanta bombings and practically on the anniversary of the Brookline attacks,• she said, referring first to the bombing of a clinic last week, then to shootings on Dec. 30, 1994, at a Massachusetts clinic. 11 The case was the first effort by Mary Jo White, the U.S. attorney for the Southern District, to enforce the Freedom of Access to Clinic Entrances Act, known as FACE, which has been credited with the significant drop in violence at clinics. Although there have been several constitutional challenges to the law, federal appeals courts have upheld it. And the Supreme Court, the Times said, has so far declined to examine it, Red Rose Rescue Invasion Chronology The anti-choice group, Red Rose Rescue, conducts clinic invasions where affiliated individuals gain access to reproductive health care faciltties, attempt to intimfdate patients and staff with anti-choice rhetoric, and refuse to leave the property. The first invasions by this group were coordinated to take place on the morning of September 151 2017 and have continued through 2020. During the invasions, it is common for additional anti-choice individuals to remain outside to hold anti-choice signs, attempt to speak with patients entering the facility, and record any arrests that take place. Date: September 15, 2017 Location(s): Sterling Heights, Ml; Albuquerque, NM; Alexandria, VA Description: Three coordinated clinic invasions were planned at Alexandria in Sterling Heights, and University of New Mexico_ At these clinics, anti-choice individuals entered, or attempted to enter, the facilities, attempted to intimidate patients and staff with anti-choice rhetoric, and refused to leave the property. These individuals in two of the locations, VA and Ml, refused to leave and were subsequently arrested by local police. tn Alexandria, VA, Joan Andrew Bell, -Christopher "Fidelis" Moscinski, and were arrested during the invasion. Lauren Handy partTcipated but was not arrested. William Louis were arrested during the invasion. At Two unknown individuals entered the University of New Mexico Albuquerque, NM, but left when the police were called. No arrests were made. clinic in Date: December 2, 2017 Location(s): Washington, DC; West Bloomfield, Ml; Alexandria, VA Description: Three coordinated clinic invasions were planned at Alexandria Individuals at all three of the locations gained andaccess to the facilities, attempted to Intimidate patfents and staff with anti-choice rhetoric, refused to leave the property, and were arrested by police. and were not arrested. in Alexandria, VA, Lauren Handy, were arrested. and Jonathan Darnell participated but in Washington, DC, Joan Andrews Bell, and Christopher "Fidelis" Moscinski participated in the invasion. were arrested. Other arrests are unknown. William Louis Goodman, participated, but were not arrested. Date: May 26, 2018 Location(s): Washington, DC '), and Christopher "Fidelis" Moscinski facility, attempted to intimidate patients and staff with antientered the choice rhetoric. refused to leave the property, and were arrested and removed by law enforcement. (I Date: July 24, 2018 Location(s): Washington, DC Description: William Louis Goodman, '), Christopher "Fidelis" in Washington, DC, attempted to intimiqate Moscinski, and- entered patients and staff with anti-choice rhetoric, refused to leave the property, and were arrested and Lauren Handy, removed by law enforcement. Joan Andrews Bell, participated but were not -arrested. Date: September 29, 2018 Location(s): Montclair, NJ Description: - Will Goodman,_ -'), Christopher "Fidelis" Moscinski, and invaded in Montclair, NJ, attempted to intimidate patients and staff with anti-choice rhetoric, refused to leave, and were arrested and removed by law enforcement. - participated but was not arrested. Date: December 20, 2018 Location(s): Washington, DC; Trenton, NJ Description: Two coordinated clinic invasions were planned at and and_ At in Washlngton, DC, entered the facility, attempted to intimidate patients and staff with anti-choice rhetoric, refused to leave, and were arrested and removed by law enforcement. -- and articipated but were not arrested. William in Trenton, NJ, At the Goodman, Christopher "Fidelis" Moscinski, and entered the facility, attempted to intimidate patients with anti-choice rhetoric, refused to leave, and were arrested by police. Date: March 19, 2019 Location(s): Washington, DC Description: Two coordinated clinic invasions were planned at both in Washington, DC. and At five individuals attempted to enter the clinic inside a multi-office medical building but were denied entry. They refused to leave the hallway Ol..ltside the entrance to the clinic. were arrested and removed by law and Lauren Handy, enforcement. Joan Andrews Bell, Jonathan Darnell, and participated but were not arrested. William Goodman, Christopher "Fidelis'' Moscinski, and also known as' were arrested during the invasion. ', participated but left before she could be arrested. Date:April17,2019 Location(s): Vancouver, BC Description:-and also known as'_', entered_ in Vancouver, BC by following a patient into the waiting room. Both individuals refused to leave.-.ilwas walked out of the clinic by law enforcement but was not arrested- Date: June 7, 2019 Location(s): Flint, Ml Description: Seven anti-choice extremists entered in Flint, Ml at 8:30AM and posed as patients, while trying to counsel women by singing and handing out fliers. •-•, and another unknown individual left the clinic before the cops arrived and were not arrested. William Goodman, Lauren Handy, and arrested; removed from the clinic by law enforcement; and charged with The pre-trial hearing is scheduled for Monday, August 24, 2020. Date: July 13, 2019 location(s): Morristown, NJ Description: Will Goodman, - ', Christopher "Fidelis" attempted to intimidate patients Moscinski, and- entered the and staff with anti-choice rhetoric, refused to leave, and were arrested. - and participated but were not arrested. Date: September 5, 2019 Location(s): Houston, TX Description: Several anti-choice individuals who have previously been involved with clinic invasions in Houston, TX, attempted to intimidate patients and staff entered the with anti-choice rhetoric, and left the property before the police atdved. They called this a "Window of Opportunity Rescue". After they left, they attempted to enter another nearby facility, made a fake appointment to gain access to the facility; however, staff identifie�nd her mother, as anti-choice protesters and asked them to leave the clinic. No arrests were made. Jonathan Darnel, Will Goodman, Lauren Handy, and participated. Date: January 18, 2020 Location(s): Plainfield, NJ Description: Hve anti-choice individuals entered the in Plainfield, NJ, to intimidate patients and staff with anti-choice rhetoric, and refused to leave the property. attempted left an<:1 was not arrested. Police arrested Joan Andrews Bell, William Goodman, and Christopher "Fidelis" Moscinski and removed them from the building. Date: April 30, 2020 Location(s): Baton Rouge, LA in Baton entered the Rouge, LA, attempted to intimidate patients and staff with anti-choice rhetoric, refused to leave the property, ahd were arrested and removed by law enforcement. Description: William Goodman and Date: May 13, 2020 Location(s): Grand Rapids, Ml Description: Several individuals tried to gain access to the waiting room of in Grand Rapids, Ml, but were identified as anti-choice protesters and denied entrance by clfnicstaff. Date: May 14, 2020 Location(s): Washington, DC Description: Two coordinated clinic invasions were planned at and both in Washington, DC. At and entered the multi-unit building. They were unable to enter the waiting room of the clinic but stood in the hallway outside the door to the facility, attempted to intimidate patients and staff with anti-choice rhetoric, refused to leave, and were arrested. Jonathan Darnel, and entered the lobby of the building, but left before they could be arrested. At William Goodman, and Christopher "Fidelis" Moscinski attempted to enter the facility in the morning. In the afternoon, Jonathan Darnel entered the clinic's waiting room, attempted to intimidate patients and staff with anti-choice rhetoric, and refused to leave the property. http ://leaderu.com/ftissues/ft9706/mcconnell.html First Things · Breaki11g the Law, Bending the Law Michael W. McConnell Copyright (c) J 997 First Things 74 (June/July 1997): 13- 1 5 . Federal Judge John E. Sprizzo will never again be promoted or advanced, for he has committed an unpardonable act of courage in defense of conscience. On January 131 1997, in the U.S. Distdct Court in Manhattan, Judge Sprizzo acquitted an elderly bishop and a young priest of the crime of "quietly praying with rosary beads" in the driveway of an abortion clinic, in violation of a court injunc(ion and the Federal Access lo Clinic Entrances Act. His reasons? That these lwo offenders did not act with "bad purpose" and, even if they did, he would exercise a judicial version or jury nullification. Because their act was "purely passive"-meaning nonviolent-and "so minimally obstructive," iljustified "the exercise of the prerogative of leniency." Because the parties waived a jury trial. the judge's decision is equivalent to a jury verdict of acquittal, and cannot be appealed. As a matter of law Judge Sprizzo was probably wrong. There can be little doubt that the 1wo defendants, Bishop George E. Lynch and Brother Christopher Moscin.ski, violated the injunction aod the Clinic Access law "willfully." They knew exaclly what they were doing and why they were doing it. And there is no precedent in our law for a jlldge to exercise the prerogative of jury nullification. Juries can acquit for any reason or no reason at all, and can use that power to acquit guilty parties out of sympathy for lhe d�fendant or opposition to the law. A judge, by contrast, must act within the bounds of the law by which he holds office. Every decision a judge makes must be grounded in law. Th.is case has the unusual twist that Judge Sprizzo himself had issued the underlying injunction. Usually that makes a judge especially inclined Lo punish infractions, which are not just ''contempt of court" but contempt of his court. Lawyers for the defendants argued that a judge is entjtled to overlook violations or his own injunction. Maybe that is right. Rut the argument seems to suggest that contempt sanctions are imposed for the purpose of vindicating the personal authority of the judge. To m y mfod, that contradicts the very idea of injunctions as law. If t.be underlying injunction is lawful, the judge's duty to enforce it. should not be affected by the fact that he is the author. If this is so, Judge Sprizzo should not have acquitted the defendants. If he wished to exercise the prerogative of leniency (as, under the circumstances, he should), he should have entered a judgment of conviction and imposed a suspended sentence. Yet one cannot help admiring the judge's act. It will mark Judge Sprizzo for the rest of his career. He must have known that he would be excoriated by the newspapers and treated as a pariah by the "moderate" voices of his community for giving moral succor to "anti-abortion extremists." After reading Judge Sprizzo's opinion, I was driven to reread Dr. Martin Luther King, Jr.'s great Letter from the Birmingham Jail, addressed to the "moderate" clergy of his day. Dr. King, like Bishop Lynch and Brother Moscinski, had been enjoined by court order not to engage in a demonstration that, according to the authorities, would impede members of the public from access to lawful businesses and activities. King-like Lynch and Moscinski-believed that it was wrong to prevent citizens from engaging in nonviolent direct action to protest injustice, and King-like Lynch and Moscinski­ thought that the underlying law enforced by the injunction was unconstitutional. King was prosecuted by the state of Alabama and convicted for violating the injunction. He was sentenced to five days in jail. The United States government, prosecuting Lynch and Moscinski, sought a punishment of up to six months' imprisonment. Not even Bull Connor had asked for that. But in Lynch and Moscinski 's case, the judge refused to be a party to the effort to silence the protest. "Were a person to have violated a court order directing the return of a runaway slave when Dred Scott was the law," the judge asked, "would a genuinely held belief that a slave was a human person and not an article of property be a matter the court could not consider in deciding whether that person was guilty of a criminal contempt charge?" Perhaps most strikingly parallel was King's conviction- shared by Lynch and Moscinski-that there is a profound difference between peaceful, nonviolent protest and violence. In King's Letter, he contrasted his philosophy of nonviolence with the "force . . . of bitterness and hatred" of certain "black nationalist groups," which "comes perilously close to advocating violence." Of course, King's opponents did not see it that way. The lawyers for segregation who sought and obtained an injunction against King's Birmingham protests cited the danger of "mob violence" and the violation of "numerous ordinances and statutes of the city of Birmingham." It was they who blurred the distinction between violent and nonviolent protest, using the possibility of the former as an excuse for blocking the latter. Nor do Lynch and Moscinski's opponents see it that way. "It's an off-the-wall, scary decision," an abortion-rights lawyer told the New York Times. "It's so close to the Atlanta bombings and practically on the anniversary of the Brookline attacks," she said. "People will take il to the next level and then the next and they end up getting violent," another abortion-rights advocate said. If quietly praying the rosary in the driveway of an abortion clinic is "close" to bombings, then Dr. King's nonviolent march was no less close to "mob violence." The legislative history of the Federal Access to Clinic Entrances Act is filled with lurid examples of abortion-clinic violence, but there was no need for legislation against violence. Violence was already illegal. The innovation of the Clinic Access statute was to impose extreme sanctions- half a year in prison for a single offense- for peaceful, nonviolent acts of protest, without proof of injury to anyone, if they have the effect of "obstructing" access to the clinic. That can mean quietly praying on the steps. The New York Times article on Judge Sprizzo's decision slated thal the Clinic Access statute is "credited with the significant drop in violence at clinics." It does not point out that the statute is also credited with a significant drop in lawful, nonviolent protests. The penalties are so harsh, the terms so vague, and the coverage so sweeping that the statute frightens off lawful as well as unlawful protest. That presumably was its unstated purpose. Dr. King reportedly agonized over the decision to violate the Birmingham injunction. He was committed to the rule of law (after all, he was demanding that southern officials comply with court injunctions mandating desegregation) and he did not wish the civil rights movement to be tarred with the brush of illegality. But in two previous protests, compliance with injunctions had doomed the movement to failure. No doubt, newspapers credited those injunctions with a significant drop in violence, but they also brought about a significant drop in effective protest. In the most famous section of the Letter, Dr. King distinguished between "two types of laws: just and unjust. I would be the first to advocate obeying just laws. One has not only a legal but a moral responsibility to disobey unjust laws." He went on to explain: "An individual who breaks a law that conscience tells him is unjust, and who willingly accepts the penalty of imprisonment in order to arouse the conscience of the community over its injustice, is in reality expressing the highest respect for law." Perhaps that is what Judge Sprizzo meant when he held that Lynch and Moscinski lacked the "bad purpose" necessary to justify conviction for criminal contempt. In a sense, they-like King- were expressing the "highest respect" for the law: they assumed that the law is capable of reform. But King specified that the conscientious offender must be willing to accept the penalty. Acceptance of the penalty of imprisonment, King said, will "arouse the conscience of the community over its injustice." It seems unlikely that imprisonment of Bishop Lynch and Brother Moscinski would arouse the conscience of our community over roughly one and a half million abortions each year. Unlike King, Lynch and Moscinski face the hostility of most newspapers and elite institutions, and their cause is regarded by the Supreme Court of the United States as an affront to its authority. They would probably languish, unnoticed, in prison. But then, in 1963 Dr. King and his cause did not enjoy the support they have received in hindsighL While King was in lhe Birmingham jail, Time magazine and the New York Times editorialized against the demonstrations, and the Supreme Court's eventual decision upholding his imprisonment is told entirely from the point of view of the Birmingham authorities. If it had not been for Bull Connor's decision to turn water cannons and dogs loose on demonstrating children, it is possible that King's imprisonment, too, would have gone unnoticed. Judge Sprizzo spared Lynch and Moscinski the indignity of jail. Unlike King, Lynch and Moscinski will not have the chance to write a Letterfrom the Manhattan Jail, calling their fellow clergy to task for their silence, and worse, on the practice of abortion. I am not sure the judge's acquittal was wise, and I am quite sure it was not lawful. It cannot be true that individuals may violate court orders with impunity whenever they sincerely believe those orders are morally wrong. And it would be utterly unacceptable to allow such violations only, but whenever, the judge happened to agree with the violator. Over a decade ago, a federal judge released two "peace" prolestors who broke into a Honeywell defense plant, smashed the computer system, and poured blood over the wreckage of the computer. The judge called the vandals "friends of the people" and the victims "warmongers." Those who think that decision was wrong must also have their doubts about Judge Sprizzo's ruling. But there is one big difference between the cases. The perpetrators of the Honeywell break-in were prosecuted for their acts, not for their motives. The punishment sought by the prosecutor was no different from what it would have been if they had vandalized the Honeywell computers out of malicious mischief, or committed a similar act for different motives at a different kind of facility. It is utterly incredible that Lynch and Moscinski might be sent to prison for six months for praying in a driveway. If they had been in that driveway for some other reason (a labor dispute, for example), or if they had committed the same sort of protest at another kind of business (a fur store, for example, or a CIA recruiting office), they would have gotten off with a slap on the wrist, had they been punished at all. The Federal Access to Clinic Entrances Act singles out a particular kind of protest for penalties unheard-of in the history of American political protest movements. Lynch and Moscinski were not tried for the actual harm they caused. As Judge Sprizzo noted, the "obstructive" effect of their quiet protest was "minimal." The prosecutor who sought to imprison Lynch and Moscinski was not asking for impartial justice, but for repression of political dissent. Lynch and Moscinski should have been punished for the acts Lhey committed. They should not have been spared because their cause was just. But they also should not be punished more severely because their cause is unpopular. They should have been charged with trespassing on private property, and given the same punishment that is meted out to others who commit that offense in that jurisdiction with comparable damage. I'd guess a fifty-dollar fine would be about right. FACE Suit A suit was filed againsl two men, retired. Catholic Bishop George Brought Against Lynch and Chrisro12.her Moscinski. charging them with violating the Catholic Bishop Freedom of Ac.cess to Clinic Enlrances Act (FACE). In May, 1995, the two men were arrested for blockjng the driveway of lhe Women's Medical Pavilion in Dobbs Ferry, New York. The suit, filed by U.S. Attorney Mary Jo White, seeks $30 damages and a court order to prohibit both men from blocking the clinic entrance, According to a New York Times report, there have been over one thousand arrests at that clinic since 1988. October 30, 1995 http:/ /www.nyclu.org/ rrp_courts.html#Lynch United States v. Lynch and Moscinski (U.S. Court of Appeals, second Circuit, Docket No. 97-1092) (amicus) In February, 1996, the United States Attorney for the Southern District of New York sought and obtained an injur,ction pursuant to the Freedom of Clinic Entrances Act CFACe") prohibiting anti-choice protesters from Impeding or obstructing access to an abortion clinic in Dobbs Ferry, New York. Several months later, District Court Judge John Sprizzo, the judge who issued the injunction, held two anti-choice protesters, George Lynch and Christopher Moscinski, in civil contempt for violating the injunction. In a January 1997 decision, however, Judge Sprizzo dismissed the criminal contempt charges against the defendants. Judge Sprizzo reasoned that the defendants did not possess the willfulness necessary for criminal contempt because they acted on the basis of their sincerely held religious beliefs. In so holding, Judge Sprizzo analogized the anti-choice protesters' actions to those of conscientious objectors. T�1e Court also went on to hold that even if the defendants' actions indicated guilt, the court was entitled to exercise the prerogative of jury nullification, whereby a fact-finder can refuse to acquit even when the facts indicate guilt. Judge Sprino's decision directly contravenes the determination by both Congress and the United States Supreme Court that the grave threats to women's access to reproductive health care warrant extra protective measures. The reasoning of the decision is virtually unprecedented. The numerous federal and state courts to consider this issue have rejected the argument that a stncerely held religious belief can negate criminal willfulness. The sole exception, a cteclsion from a lower New York State court, is based upon a misapprehension of the abortion case law. In response to this decision, the United States Attorney is appealing the decision to the Second Circuit. In conjunction with the NOW Legal Defense and Education Fund, the NYCLU Reproductive Rights Project o rganized an amicus effort. Four organizations signed onto the NYCLU's brief: the Amerlcan Jewish Congress, Lambda Legal Defense and Education Fund, the Westchester Coalition for Legal Abortion, and the National Emergency Civil Liberties Committee. Tt,e brief argues first that principles of double jeopardy bar the appeal. It then states that if, however, the Court feels constrained to address the merits of the appeal, then Judge Sprizzo's decision should be reversed for the reasons discussed above. STATUS: An argument in the Second Circuit has not yet been set. (Yuehrru Chu; Donna Lieberman) Update: The U.S. Court of Appeals concurred with our analysis and denied the rehearing because of the principle of double jeopardy, while simultaneously striking down the lower court's reasoning. Donna Lieberman, RRP Director, said that "the message is clear to other judges and courts around the country that there is no religious exception in the case of abortion-related criminal cases." March, 2000 EXHIBIT 050 From: "Patel, Sat1jay (CRT)" To: "McNally, James (USADC)" Subject: RE: Red Rose Rescue Info Requested Date: Mon1 I 4 Sep 2020 I 0:53 ;24 -0400 Importance: Normal Attachments: 1 997-Moscin.ski_C-Art.pdf; 201 905-RWW-RRR_Art. pdf; 1 995 1 03 1 -Moscinski C-A1i.pdf; 1 99701 20-Moscinski_C-ArLpdf; Handy-Statements.docx.; Red_Rose_Rescue-Cbronology.docx J n line-Images: image00 l .gi f Hi,aJlma- Thanks again for taking t1me to chat about your pending cases, and sharing the related reports and body cam footage. Can you also look into getting the related reports from the closed/disposed-of cases? The applic;able statute I mentioned ies 18 USC 248(a}(l) {FACE Act). I believe that we would be considering the "physical obstruction" aspect of the statute. The 11th Cir. has a pattern instruction for this offense, but it does not capture the "attempt," where the defendants' conduct did not successfully prevent any person from providing or r-eceiving health care services (I'm sure we can craft something better). b.ttps://www.ca11.uscourts.gov/sites/default/files/coL1rtdocs/clk/FormCriminalPatternJurvlostruction.ruif In addition to this email string that provides the case info for your pending matters, I've attached the related documents received from NAF. Thanks. Sanjay From: McNally, James {USADC) Sent: Thursday, September 10, 2020 3:01 PM To: Patel, Sanjay {CRT) Subject: RE: Red Rose Rescue Info Requested SanJay - l'm free all day tomorrow and anytime next weel< WIii be OK. My number is Jim From: Patel, Sanjay (CRT) Sent: Thursday, September 10, 2020 2:57 PM To: McNally, James {USADC) � Cc: Cooney, Joseph (USADC) �; Willoughby Jr., Charles {USADC) Subject: RE: Red Rose Rescue Info Requested Thank you, Chip and J.P. Jim - it would probably be best if we have a call about your active cases. Do you have time for a call tomorrow or next week? Sanj.ay From: McNally, James (USADC) Sent: Thursday, September 10, 2020 2:24 PM To: Patel, Sanjay (CRT) Cc: Cooney, Joseph (USADC) �; Willoughby Jr., Charles (USADC) Subject: RE: Red Rose Rescue Info Requested Mr. Patel, I have the active Moscinski, an� cases. What do you need? Jim McNally From: Willoughby Jr., Charles (USADC) Sent: Thursday, September 10, 2020 2:18 PM To: Patel, Sanjay (CRT) Cc: Cooney, Joseph (USADC) �; McNally, James (USADC) � Subject: RE: Red Rose Rescue Info Requested Good afternoon Sanjay, Please forgive my delayed response. I told J.P. I would get this to the both of you last week and got a bit tied up. Per your inquiries, the following cases have been disposed of by conviction or dismissal and are likely among our closed case files, which we do not have access to at this time: were assigned to former SAUSA Kathryn Lauren Handy ( Schmidt. The cases were dismissed for want of prosecution on 7/23/19. as assigned to former SAUSA Sarah Harper. The defendant was sentencedChristopher Moscinski want of prosecution on 9/19/19. was assigned to former SAUSA Kathryn Schmidt. The case was dismissed for Christopher Moscinski ( for want of prosecution on 10/11/18. ) was assigned to former SAUSA Danielle Rosborough. The case was dismissed The following cases are still active and are currently assigned to SAUSA Jim McNally, who 'I ve copied here. Christopher Moscinski William Goodman Please let me know if you have any questions and/or need anything else from me. Thanks, Chip From: Cooney, Joseph (USADC) � Sent: Thursday, September 10, 2020 1:31 PM To: Patel, Sanjay (CRT) Cc: Willoughby Jr., Charles (USADC) Subject: RE: Red Rose Rescue Info Requested Thanks for the ping, Sanjay. Chip, circling back to this - can you help us get access to the underlying case flles/AUSAs? From: Patel, Sanjay (CRT) Sent: Thursday, September 10, 2020 12:19 PM To: Cooney, Joseph (USADC) � Subject: RE: Red Rose Rescue Info Requested Hi, J.P., Just following up on the potential DC FACE matters I had emailed you about. Assuming these defendants have active cases in superior court, can you have the assigned AUSA(s) reach out to me? Thanks. Sanjay From: Cooney, Joseph {USADC) Sent: Tuesday, September 1, 2020 1:41 PM To: Patel, Sanjay (CRT) Subject: RE: Red Rose Rescue Info Requ.ested Thanks for this, Sanjay. I'm reaching out to my counterpart in Superlor Court to find out where these are and will get you in touch. If we can take any of these federally under the FACE Act we're all in help out. From; Patel, Sanjay (CRT) Sent: Tuesday, September 1, 2020 12:01 PM To: Cooney, Joseph (USADC) � Subject: FW: Red Rose Rescue Info Requested Hi, J.P. Several pro-choice NGOs routinely reach out to me concerning possible FACE Act violations (18 USC 248{a)) that occur around the country. Recently, in DC, there were MPD arrests related to conduct that occurred at local reproductive health clinics. Below is case related information for some activists whom I've been monitoring over the past few years. I believe that these cases are active in superior court. If they are, can you connect me with the AUSA(s) handling these capers? (I'm not sure whether the numbers below are case numbers, report numbers, or something else?) File Date 3/20/19 File Date 8/18/2020 File Date 8/18/2020 File Date 8/12/2020 File Date 8/12/2020 I'd like to take a look at the related reports. I believe that at least two of these defendants have prior misdemeanor FACE Act convictions. If any of these DC cases are potential FACE Act violations, then we may be able to charge those as a felony (sect 248(!)) (2)). Thanks. Sanjay From: Michelle Davidson �@P-rochoice.org> Sent: Thursday, August 20, 2020 4:27 PM To: Patel, Sanjay (CRT) Cc:Tara Gannon �P-rochoice.org>; Emma Goldberg --@12rochoice.org> Subject: Re: Red Rose Rescue Info Requested Here they are, Sanjay. Sent this morning. From: Michelle Davidson Sent: Tuesday, August 18, 2020 7:39:57 PM To: Cc:Tara Gannon -@Rrochoice.org>; Emma Goldberg �P.rochoice.org> Subject: Red Rose Rescue Info Requested Hi Sanjay, Feel free to share this with Aaron as well, He replied to my previous email wanting to know if any action from Handy occurs. It might be useful for him to have the timeline as well. I also attached some articles on Moscinski that go pretty far back. Let me know if you need anything else. I'll definitely keep you posted if we hear of any attempts at clinics riglit away. Case Numbers: File Date 3/20/19 . File Date 8/18/2020 File Date 8/18/2020 File Date 8/12/2020 File Date 8/12/2020 Michelle Davidson Director, Security All prQnouns are respectfully accepted (They/Them, He/Him, She/Hers) National Abortion Federation Confidentfallty Notice: This e-mail message, Including anv attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, dfsc/osure, or distribution is prohibited. If you have received this e - mall fn error, please immediately notify the sender by e - mail at the address shown. Please delete it from your files If you are not the intended recipient. Thank you for your compliance. EXHIBIT 051 From: " (WF) (FBI)''t� , "Patel, san·a USADC " , "Laude�PD)" (WF)t(FBI)" � Subject: RE: [EXTERNAL EMAIL] - Latuen Handyt- FYI Date: Tue, 29 Dec 2020 14: S l : 52 -0500 Importance: Nonnal Inline-Images: image0O l .p11g Thank you sir! Appears to all be 1st Amendment protected activity, so Im being mindful of that, but figured it made sense to pass along the email. On Dec 29, 2020 14:48, ''Lauderdale. Jonathan (MPD)" No problem. wrote: I am about to leave for the day, on time for once but I checked our Cobalt database and so far I do not see any new arrest involving her. I can check later this evening from home to see if any new arrest for her show up. Jonathan Lauderdale Detective, Second District Criminal Investigations Division Metropolitan Police Departo1ent "We are here to help." From: (WF} (FBI)"� Sent: Tuesday, December 29, 2020 2:25 PM To: (WF) {FBI)--; Gaston, Molly (USADC) �; Patel, Sanjay (CRT}"�; Lauderdale, Jonathan (MPD) Subject: Fwd: [EXTERNAL EMAIL] - Lauren Handy"- FYI CAUTION: This email originated from outside of the DC Government. Do not click on links or open attachments unless you recognize the sender and know that the content is safe. If you believe that this email is suspicious, pfease forward to for additional analysis by OCTO Security Operations Center {SOC). FYSA - reaching out to Michelle this afternoon. Jonathant- can you keep an ear open in case Handy ends up in MPD custody again? 1111 Thanks ---------- Forwarded message --------(WF) (FBI)" � From: " Date: Dec 29, 2020 14; 1 7 Subject: Fwd: EXTERNAL EMAlL] - Lauren Hand (WF) (FBI)" To:T" Cc: ' . (WF) (FBI)" See below 011 one of your 286 subjects. - I believe Handy was arrested at aDother clinic outside our AOR a month or so ago as well. Would love to work with you guys on the case - any chance I could be added as• co? SA­ WFO:DT ---------- Forwarded message --------From: Michelle Davidson �procho1ce.org> Date: Dec 29, 2020 14; l J Subject: ·XTERNAL EMA1L] - Lauren Handyt- FYJ ' To: ' W F (FBI '1 (WF) (FB1)" Cc: Tara Gannon 112P.rochoice.org>,Emma Goldberg Good Afternoon All, Lauren Handy has posted on social media that she entered a clinic in VA this morning and that she was outside the PP in DC shortly after that. She may have plans to enter other facilities in the OMV and I wanted to give you a heads up. We are sending out a Member Alert shortly so providers i n the area are aware. Let me know if you have any questions or if I can help with anything. I hope you all had a restful holiday, -Michelle htt,Qs.//twiltercom https. /twitter.corn Michelle Davidson Director, Security All pronouns <1re respectfully accepted (They/Them1 He/Him, She/Hers) National Abortion Federation Confldentrallty Notice: This e-mall message� rncluding any attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution Is prohibited. If you have received this e-mail in error, please immediately notify the sender by e-mail at the address shown. Please delete it from your files Tf you are not the intended recipient. Thank you for your compliance, For the latest inf01mation on the District Governmem·s response lo COVID- 1 9 (Coronaviius)}.dplease visit coronavirus.de.gm.. EXHIBIT 052 Fro.m: "Patel, Sanjayi(CRT)" To: "Michelle Davidson" �prochoice.org> Subject: RE'. RRR - PA / OSA in MT Date: Thu. 09 Sep 202 l 16:3 l :20 -0400 Importance: Normal lnliue-Images: image003.jpg; image004.pog Hi, Michelle Do you have any info on Zastrow and Co's travel to Montana? From: Michelle Oavrdson-@prochoice.org> Sent: Tuesday, August 31, 2021 5:57 PM To: Cowall, Laura (CRT) ; Smith, Katelyn (CRT) (CRT) ; Patel, Sanjay (CRT) Subject: RRR - PA/ OSA in MT ; Fitzgerald, Paige Hi All, I wanted to make sure you were aware of the invasion that occurred on 8.27. I've attached our member alert as well as screenshots of FB posts. More fodder for fact that they plan to continue these. I recently got a call from_ Judicial Security Inspector with the Eastern District of Pennsylvania (USMS Philadelphia Office) and he wanted to get in touch wlth the FBI agent that would be assigned to this. Do you have a contact I can direct him to? Or you can certainly reach out. He said he got my alert forwarded to him and he wanted to make sure he was assisting as be.st he could. We also have word that Cal Zastrow and a few others known to blockade clinics are in Montana. I would bet they might try to block a clinic this week so I'm reaching out to clinics and my few local PD contacts to see if I could bring some awareness. Any other contacts you can connect me to would be very heipful as well. Since I'm the lone sallor on. this ship now, I can use all the help I can get! Hope you all a.re doing well. Stay safe, Michelle Davidson Director, Security All pronouns are respectfully accepted (They/Them, He/Hirn, She/Hers) Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this e-malf in error, ple,;1se immediately notify the sender by e-mail at the address shown. Please delete it from your files if you are not the intended recipient. Thank you for your compliance. EXHIBIT 053 From: "Pate.I, Sanjayt(CRT)'' To: '1 Gi lbert, Kathryn (CRT)" Subject: FW: FYSA- Handy. Lauren audio recording, and fake appointment script Date: Fri, 03 Feb 2023 08:28:27 -0500 Importance: Normal Attachments: Lauren_l-landy_ 1 1 t92023 _paau_planning__meeting.m4a; Re_Scripts_for_calls_email_ Redacted.pdf; Calling_Abortion_Bt1siness_.pdf lnline-Images: image002.j pg From: Eduardo Serrano �prochoice.org> Sent� Tuesday, January 31, 2023"10:35 AM To: Patel, San·a (CRT (CRT) ; Fitzgerald, Paige ; Cowall, laura (CRT) Cc: Michelle Davidson �@prochoice.org>; Robert Ledogarllllllllll@procholce.org>; security Subject: [EXTERNAL) FYSA- Handy, Lauren audio recording, and fake appointment script Hello DOJ team, Attached is an audio recording of Lauren Handy discussing how she planned three clfnic invasions that were attempted on 1/21/2023. We were able to p(event these invasions and PAAU was met with a heavy police presence. I have also attached the email that was sent to me by Handy containing the script that is being used to interfer,e with people receiving reproductive healthcare by making fake appointments. These fake appointments are also used as an access tool for invasions. The link is to a google drive and all access to the drive is set to anonymous by PAAU. For your OPSEC I have downloaded the script and attached it to this email, so you do not have to access their drive. Eduardo Serrano Intelligence Ana lyst pronouns (He/Him) Confidentiality Notice: This e -mail message., Including any attachments., is for the sole use of the intended recipient, and may contain confidential and privileged Information. Any unauthorized review, use, disclosure, or dfstribution ii; prohibited. If you have received . this e -mail in error, please lmmediately notify the sender by e -mart at the address shown. Please delete it from your files if you are not the intended recipient. Thank you For your compliance. EXHIBIT 054 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS (0 REQUEST FOR INFORMATION TO: Faiz Malek, Senior Director of Security and Equity FROM: Christina Longoria, Regional Intelligence Analyst Affiliate Regional Intelligence Program Global Safety and Security, Intelligence and Investigations SUBJECT: DATE: August 27, 2021 is an actieve anti-abortion member who is most well-known for his extensive participation in invasions of reproductive health care facilities. These invasions - coined "Red Rose Rescues" by the organizerse- involve no more than six people entering a health center and refusing to leave until they are forced to do so by law enforcement. These invasions effectively shut down health center operations. - has been an anti-abortion protester for at least ten years. During protests at was known to "bend the rules," such reproductive health centers in Minnesota, as using a ladder to peer over privacy fences. is a devout Catholic. He expressed his vows to the Franciscan Brotherhood of Peace in October 2010 and is known as Brother - - fbp1 . Over the years, it appears he has loosened his affil iation with the brotherhood, a s he has been observed less frequently in his robe during his opposition activities. - was arrested during the first documented "Red Rose Rescue" invasion in September 2017. He has since been documented for his involvement in 1 9 incidents at �health centers, including 14 attempted or successful "Red Rose Rescues." -- has participated in 40% of the documented 35 attempted/successful health center invasions. 1 http://www.brothersof eace.or /index. h /our-life/meet-the-brothers/40-franciscan -brothers-of-peace/our­ life/meet-the-brothers SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS REQUEST FOR INFORMATION Thus far, the majority of criminal penalties - has faced in connection with health center invasions have been limited to fines or communit service. GSS assesses - is a core member of the "Red Rose Rescue'' movement. He will continue to participate in invasions and non-violent actions unless faced with stiff legal penalties. - resides in with -· but frequently travels in connection with ''Red Rose Rescue." - ldentifying information rs as follows: Name(s): AKA: DOB: Address: Social: s://www.facebook.com s://www.facebook.com SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advise-d to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Pa,ticipation in ARIP is voluntary. EXHIBIT 055 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS TO: Affiliate Security Leaders FROM: PPFA Global Safety and Security, Intelligence and Investigations SUBJECT: Overview of Emerging Trend: "Red Rose Rescues" and blockade tactics DATE: July 14, 2019 Executive Summary: Global Safety and Security (GSS) assesses the "Red Rose Rescue" trespass-blockade tactics will expand as more opposition members see it as a viable and effective action against abortion providers. GSS further assesses the movement will likely grow and hold the potential to significantly disrupt Planned Parenthood operations unless significantjudicial consequences are brought against participants. Details: On May 1 3, 201 7 , opposition member of O eration Save Ameri'ca (OSA) and 1 o others, blocked the entrance of Clinic in -• Kentucky. - and followers were arrested, however, the blockade effectively shut down the clinic for the rest of the day. 1 While a constant and effective tactic in the 1980's and part of the 1 990's in closing health centers, these types of blockade/trespass tactics stopped upon the implementation of the 1 994 Freedom of Access to Clinic Entrances Act (FACE Act) by the United States Department of Justice (US DOJ). The FACE Act authorizes the Attorney General to seek injunctive relief, statutory or -Red Rose Rescue" are compensatory damage, and civil penalties against trespassing tactics used by individuals who engage in conduct that violates the act. 2 the anti-abortion movement The FACE Act creation brought severe criminal and civil penalties to opposition organizations and individuals bringihg a halt to the tactic that had been so effective in shutting down health centers. However, Global Safety and Security (GSS) assesses thee- incident sets a precedent where the blockade/trespass operations, have returned as an effective opposition tactic1 specifically, the "Red Rose Rescues." designed ta avoid federal FACE Act vlolatlons. Re&ctle psrttcipants enter a health center and refuse to teave eventually being arrested. Participants ere careful not to block entrances. or patients, thus avoiding FACE Act violatlo.t1& SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own Judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS While the - incident was not officially a "Red Rose Rescue" tactic, it likely influenced "Rescue" participants who have since conducted over a dozen such operations resulting in arrests. In previous "Red Rose Rescues", participants have entered health centers and refused to leave, resulting in a police response and eventual arrests of at least some of the participants who refused to leave. To date, none of the participants have engaged in aggressive behavior, damaged property or obstructed patients during the incidents, thus skirting the FACE Act violations. GSS assesses the participants likely grow bolder with each incident where federal FACE Act violations are not instituted. GSS has detected a "Red Rose Rescue" Facebook page where postings have asked for "volunteers" willing to be arrested.3 The page lists the following description: "A lifelong response to the abortion holocaust. We counter hate with love. We oppose violence with non-violence. We overcome death by personal solldarity.e"4 While a small core group are the leaders and organizers in the movement, GSS has noticed others joining the movement and assess they will likely recruit more individuals, thus expanding the use of the tactic. a I n June 2019, GSS noted that leading member of the "Rescues" obtained a camping trailer where he indicated he will be traveling across the country involved in anti-abortion activities. GSS assesses this to mean expanding the "Rescues" to other parts of History of Blockade Tactics During the 1980's. Operation Rescue organized massive .protests coordinated in several states resultii,g in the closing: 'Of numerous health centers from bJoctede tac11cs. The amount of trespassers. overwhelmed po&ce who would make an arrest only to tiave several other protesters take the place Qf those removed. Health centers would be shut down tordays as these tactics would be employed et a targeted health center for a week On October 29.. 1988, Operatlm, Rescue organl:zed the •National Day of Re�cue" where over 1,000 opf,>OSltlon members were arrested In 21 cities for blockades against abortion proV(ders In a coordinated "Rescue" nationwide. BIWIY by polite In Wichila'a �Summer of M&tr:y' blot;kadfU SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS the country. - is a New Mexico resident, however most of the "Rescues" have occurred an or near the East coast. - new mobility will likely result in radicalization and recruitment of like-minded opposition members to participate in incidents nationwide. Another participant in the 'Hescues" has been Joan Andrews Bell. Bell is a long-time activist who has been instrumental in the radical element of the o osition I n 1997, Bell employed as a volunteer at "Good Counsel Homes," a home for single mothers based in New Jersey that Bell founded with her husband Kopp considered Bell one of the eare leiest inspirations i n the movement. 6 5 Joan Alldf9lls Bfilllwffl •nNMd dlllfnO abarfian,,,.., ,n 1U90.s GSS assesses that the participants justify the risks of arrest based on light misdemeanor sentences that have been handed out in past. The fines and probation sentencing have done little to stop their enthusiasm for future direct action. Unless legal repercussions become more stringent, it is likely the movement will grow and expand nationwide. GSS further assesses that should this movement grow, it will have a direct impact on Planned Parenthood operations_ While violence at these incidents is unlikely, health centers will be closed down as the action is taking place. Intelligence Gaps in "Red Rose Rescue'' Planning and Operations Organizers of the "Rescues" do not divulge any information prior to the operations. Plans are made i n secret and participants do not discuss future plans online. GSS assesses that the opposition does conduct pre-operational surveillance at targeted health centers and viability a$sessments are made on the scene. Should a health center appear to be a difficult location, other health centers are picked, Due to this operational SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a servi'ce to Planned Parenthood Affiliates to supplement their own sewrity resources and programs. Planned Parenthood Affiliates are advised to rely on their own Judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS security, GSS cannot determine a future target and warn health center staff of potential "Rescue" operations without human intelligence (HUMINT). GSS assesses the core group of organizers and participants to be: William Goodman Fidelis Moscinski SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Recruitment a.nd Retention GSS assesses social media is used for recruitment purposes via Facebook page (htt s://www.facebook.com ). During the operation, a participant often a video on Facebook. The�e ta� ifically used for r�cruiting new live �treams . part1crpants. "Red Rose Rescue" organizer-- posted the following on the above Facebook page in May 2019: I Dear Supporters of Red Rose Rescue: -- Will you Participate in a Red Rose Rescue? I Is God calling you to reach out to mothers in the waiting rooms of th� killing centers-- to give them that last opportunffy to choose life and offer them the help they need to choose life�- and to stay with the babies should they still go off to their executions?! There are currently Red Rose Rescues being planned across the nation. Join this Life-Affirming, Woman Affirming effort --and peacefully defend the Unborn who have no one to stand up for them! We need to sacrifice ourselves to end abortion! The Lord of Love calls us to lay down our lives for our neighbor, the helpless, the unwanted, the outcast! Now's the time! I For information to heed the call to become a rescuerjust send an email tea . - one of the co-founders of Red Rose Rescue While the majority of the participants are repeat offenders, GSS notes new members ) appear at 11 Rescues" and are subjected to arrest. 11 Rescue ' members must recruit new members to participate 'in order to avoid stacked arrests that may result in harsher sentences for repeat offenders. "Rescue' activist must spread out their arrests in between court appearances and new operatives are the only way to avoid those sentences. Analys� a July 13, 201'9. Operation Save America meeting in Milwaukee, leader--- asked who in the audience has been arrested before for "Rescues" and encouraged 'the youth in attendance to learn from those previously SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service lo Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information recetved through the ARIP Participation in ARIP is voluntary. co PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS arrested. - added: "praying is not enough, and sacrifices must be made. ,,g While - is not official part of the Red Rose Rescue team, GSS assesses he strongly agrees with the tactic and will likely be a recruiter for future "Rescues". The following incidents represent recent organized trespass/blockades to include "Red Rose Rescues." Unless noted, all of the below participants were arrested. The organizers are in bold font. Eva Ed Eva Zastrow James Zastrow Dennis Green Unidentified juvenile William Goodman Fidelis Moscinski Joan Andrews Bell SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. co PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Analyst Note: The above events that took place on September 15th were coordinated nationwide. Will Goodman Lauren Handy Fidelis Moscinski Unknown individual SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Jul 24 2018: Fidelis Moscinski Will Goodman The following participated but were not arrested: Joan Andrews Bell Jane Doe (un identified female, likely Se tember 29 2018: Fidelis Moscinski Will Goodman Jane Doe (unidentified female) Analyst Note: It is not known who organized this event. The fol lowing participated but were not arrested: Jonathan Darnel SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS December 22 2018: Fidelis Moscinski Planned Parenthood The following participated but were not arrested: Joan Andrews Bell Will Goodman March 1 9 Fidelis Moscinski Will Goodman Analyst Note: The above events that took place on March 19th were coordinated nationwide. Will Goodman SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Lauren Handy The followin articipated but were not arrested: - Jul 1 3 2019: Jane Doe, (unidentified female, likely Will Goodman Fidelis Moscinski Analyst Note: Other members outside but not involved or identified. It Is not clear who organized this event. Conclusion: GSS assesses with high confidence that the "Red Rose Rescue" movement will expand as s�n members will join the group as publicity increases. Father- travel nationwide will likely recruit new members. Furthermore, the social media coverage of these "Rescues" including Facebook Live videos will likely influence future opposition members looking for a more aggressive tactic of protesting abortion. Ultimately, these actions will have a direct effect on Planned Parenthood operations should the "Rescue" movement target large number of Planned Parenthood health centers in the future. SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS END NOTES AP News, "US abortion clinics face surge of trespassing and blockades:" David Crary; dated May 7, 20 Freedom of Access to Cllnic Entrances Act (FACE), 1 8 U.S.C. § 248; https://www.justice.gov1crt-12; US DOJ online description of FACE Act. 3 https://www.facebook.com 4 Ibid 5 "Targets of Hatred," by Patricia Baird Windle; 2001; see pages 296-297. 6 Online Rewire article; https://rewire.news/article/201t8/03/01 /trespassing-trial-march -eaught-attention­ activTsts-sides-abortion-movement/; Sofia Resnick; dated March 1 , 2018. 7 Ibid. 8 Red Rose Rescue Facebo6k a e; dated Ma 24, 2019; osted l:> h�book.com 9 -- July 13, 2019 Facebook video b I https://www.facebook.com 1 2 This product was prepared by Global Saf�ity. Co --1 at , Director of Intelligence and Investigations, nd ueries can be addresse0 to Director or SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parentho0d Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. EXHIBIT 056 From: duVergne Gaines �fominist.org> Cc:- �feminist.org>,-femin.ist.org> Subject: [EXTERNAL] Meeting Request, FACE Act Memo, and Cover letter Date: Thu, 2 5 Aug 2022 2 1 :33:5 l -0400 Importance: Normal Attachments: FMF_Cover_Letter_re_FACE_Merno_08.25.2022_ (6)[J ].pdf; FACE_Act_Outline_Memorandum_08.25.2022.pdf Dear Ms. Cochran, Chief FeJte, Chief Rosenbaum, Principal Deputy Chief fjtzgerald, Deputy Chief Cowall, Mr. Patel, and Ms. Saxe; Attached please find a cover letter and accompanying legal memorandum urging the DOJ to pursue oationwjde injunctive relief to prevent ongoing and future violations of the Freedom ofAccess to Clinic Entrances ( FACE) Act. We welcome your assistance in ensuring these materials rnach Assistant Attorney General Clarke, Attorney GeneraJ Garland and Associate Attorney General Gupta. Together with our colleagues al the National Abortion Federation, we would like to request a meeting with you, Attorney General Garland, Associate Attorney General Gupta, and Assistant Attorney General Clarke to discuss this letter, the attached memorandum, and the escalation in threats. harassment, and violence against reproductive health care providers and patient communities since the Dobbs decision. We are grateful for your leadership and commitment to ensuring clinic, provider, and patient safety. Thank you for your time and attention to these materials and to our request. Best, Eleanor Smeal, President, Katherine Spillar, Executive Director, and duVergne Gaines, Director. National Clinic Access Project Feminist Ma'orit Foundation 0: E: The i.11.formatiou comained in tllis electronic message and any attached documents are privileged. confideotial and pro1ec1ed from disclosure. and 1be information m,ty not necessarily express the opinion of Feminist Majority Foundation. Ifyou are not the intended recipient, note that any review, disclosure, copying, or disscminatiou of this message or at1y attachments is stric-1ly prohibited. Jfyou th.ink tbat you have rec.eivecl this message in error, please destroy ir and notify the i,cnder. EXHIBIT 057 CONFIDENI'IAL TRBATMENT REQUESTED EXEMPT FROM FOIA FEMINIST MAJORITY FOUNDATION Working for Women's 'Equality August 25, 2022 t1eonor Smeal P�sldent Peg T'ork1n Cns11 of/lie Boa,u K,UJ1em1e $µIllar £t'3CIJ(i\lel 0J(eC./of Hon. Merrick Garland, Attorney General of the United States Hon. Vanita Gupta, Associate Attorney General of the United States Hon. Kristen Clarke, Assistant Attorney General, Civil Rights Division James Felte; Chief, Criminal Section, Civil Rights Division Steven Ro�enbaum,. Chief, Special Litigation Section, Civil Rights Division Laura Cowall, Deputy Chief, Special Litigation Section, Civil Rjgbts Division_ Paige Fitzgerald, Principal Deputy Chief, Criminal Section, Civil Rights Division Sanjay Patel, T1ial AttorueyJ Crhninal Section ., Civil Rights Division Elizabeth Saxe, Trial Attorney, Special Litigation Section, Civil Rights Division United States Department of Justice 950 Pennsylvania Ave,, N.W, Washin.gton 1 D.C. 20530-0001 Dear Attorney General Garland, AssociateAtt0rney General Gupta_, Assistant Attorney General Clarke, Chief Felte, Chief Rosenbaum, Principal Deputy ChiefFitzgerald, Deputy Chief Cowan, l\fr. Patel, and Ms. Saxe: We write today to urge the Department of Justice {DOJ) to use the full measure of its investigative and prosecutorial power to protect reproductive health care providers and the communities they serve from anti-abortion violence and threats of violence in the wake of the Supreme Court's decision in Dobbs v. Jackson Women's Health Organization overturning Roe v. Wade. Specifically, as set forth in the attached legal memorandum, we urge D0,J to purs·ue nationwide injunctive telief to prevent ongoing and future violations of the Freedom of Access to Clinic Entrances ("FACE'') Act. Clinics1 providers, and patie-nts are facing an onslaught of threats, intimidation, -and violence. As just one example, recent1y the Milwaukee-based anti-abortion extremist group Operation Save America (OSA) traveled to and targeted clinics in Nashville, Tennessee, as part of a week -long campaign to abolish abortion in that city, Over the. course of several days in late July, OSA leaders and adherents- many- of whom previously had targeted reproductive health clinics in other parts of the country­ conunitted acts of trespass, intimidation1 and clinic entrance obstruction; upon arrest, one individual - who attempted to enter two facilities that day- was carrying a concealed weapon. They have vowed to inLensify their efforts in tbe coniing weeks; Indeed, since the Dobbs ruUng, anti-abortion extremists have engaged tn seemingly relentless acts of violence, intimidation, and obstruction against cUnics and providers; 'tMem. of Law in Support of Emergency Mot. For TRO -at 1-2, Femhealth USA, Inc., d/b/a Cara/em v. Williams et al., No. 22-cv-00565 (M.D. Tn. July 29, 2022), ECF No. 3. 1 CONFIDENITAL TREATMENT REQUESTED EXEMPT FROM FOIA • On June 28, a bomb threat was called into a clinic in Victorville, California;2 • On ,July 7, three anti-abortion extremists invaded, disrupted and obstructed two clinics in Atlanta, Georgia and attempted to gain entry to a tliird while livestreaming the invasions;s • Also on July 7, a member of the Red Rose Rescue anti-abortion extremist group blockaded a clinic in Hempstead, New York using bike locks and his body;4 • On July 13 1 six individuals associated with OSA blockaded a clinic in Grand Rapids, Michigan while co-conspirators livestreamed the blockade;s • On July 1-4, three extremists invaded, disrupted and obstructed two additional clinics in Atlanta, Georgia;6 • On August 4, a man committed arson at a clinic in Kalamazoo, Michigan; 7 • On August 18, three extremists invaded, disrupted, and obstructed two clinics in Brooklyn,NY8 ; and • On August 23, a group of extremists involved in prior clinic blockades gathered in Michigan from across the country for three weeks to target - and possibly obstruct-­ clinics throughout the state.e1 movement in In addition, leaders affiliated with the California, Washington, Florida, and Arizona have stated that abortion providers should be put Planned Parenthood in Victorville Evacuated after Bomb Th,.eat, Victor Valley News Group (June 28, 2022), https://www.vvng.com/planned-pa.renthood-in-victonrille-evacuated-after- bomb-threa,t/. 2 s Social media posts by Kingdom Conservative Party member and OSAassociate Bevd1 Williams Bevelyn Williams, One Last Clinic, Hit 'Em Up!, Facebook (July 7, 2022), https://tbBevely:n Williams, By Faith we are Callin This Abortion Clinic Portal o Demons Down, Facebook (July 7, 2022), https;//www.facebook.com • Bevelyn Williams Another Clinic, Planned Parent-hood Will Fall!!, Facebook (July 7, 2022), https://tb.watch!lliiiiiilll 4 Pro-life Priest Arrestedfor Locking Planned Parenthood Entrance in Abortion 'Harbor' New York, Life Site (July 7, 2022), https://www.lifesitenews.com/news/pro-1ife-priest-arrested-for-locking-plauned­ parenthood-entrance-i n-abortion-hatbor-new-york/. "tMichael Oszust and Kyle Mitchell, 6Anti-Abortion Protesters Arrested at GR Reproductive Health Clinic, Wood TV (July 13, 2022), https://www.woodtv.com/news/grand- rapids/6-anti-ab011ion­ protesters-arrested-at-gr- reprodnctive-health-clini c/. Social media posts by Kingdom Conservative Party member and OSA associate Bevelyn Willlams, Bevelyn Wi11iams, Another Duy Another Abortion Clinic, That Must Come Down!!, Facebook (Ju1y 14, ' hat 2022), https://fb.watch/eGAk846_t Fd/; Bevelyn Williams, Another Day Another Abortion Clinic1 T Mttst Come Down!! PT 2, Facebook (July 141 2022), https://tb.watch/cGAkRBS2px/. 6 7 C. Ryan Barber, A Michigan Man Who Referred to Abortion as "Genocide" was Charged with Setting Fire to a Planned Parenthood, Business Insider (Aug. 4, 2022, 7:10 PM), bttps://www.businessinsider.com/planned-parenthood-fire-abortion-justice-de_partment-arsen-cbarge- 2022- 8 . s Reported by the National Abortion Federation and per social media posts by Kingdom Conservative Party member and OSA associate Bevel}'ll Williams. OSA associate and clinic blockader Dennis Green Au nd (August 1,0, 2022 2 CONFIDENTIAL TREATMENT REQUESTED EXEMPT FR.OM FOIA to death or subject to the death penalty for their "crimes. "w Individual members of the - Ill a violent network of anti-abortion extremists, have also openly celebrated violence on.line and of ered to share via Facebook newsletters describing how to bomb and burn clinics. u This escalating violence and harassment is generating tremendous fear among providers-especially i regarding known exh·emists who repeatedly target clinics and staff wth intimidating and disruptive invasions and flagrant blockades in city after city, state after state. We appreciate President Biden 's commitment to ensuring the safety and security of reproductive health care patients, providers , and third parties , as annou nced in the President's July 8, 202.2 Executive Order Protecting Access to Reproductive Health Care Serv:ices.i2 We also are grateful for Attorney General Garland's acknowledgment of the gravity of the threats abortion providers face in the wake of the Dobbs decision , 1 s and the commitment by Associate Atto rney General Gupta, Assistant Attorney General Clarke, and the DOJ National Task Force on Viol ence Against Reproductive Health Care Providers to keeping essential reproductive health care accessible and providers and patients safe. As part of DOJ's efforts to prevent abortion-re] ated violence, we encourage OOJ to seek n ationwide injunctive relief under the FACE Act against extremist Jeaders and adherents who conspire to obstruct access to reproductive health services and harass and inti midate providers and patients . Such broad enforcement under the FACE Act can help prevent repeated vio] ative behavior by these individu als and help keep clinics open and providers and patients safe-including those jn Nashville, who weathered repeated coordinated disruptions and threats just weeks ago. Furthermore, we urge DOJ to move quickly to pursue this relief. As the incidents described above demonstrate, the Dobbs ru ling has only emboldened anti-abortion extremists. 1 4 These • 0 In Wake ofSCOTUS Decision, New lFB Pastors Caltfor Government to Execute Abortion Doctors, ADL (July 1, 2022), https://www.adl .org/resources/blog/wake-scotus-decision-new-ifb-pastors.-call­ goverrunent-execute-abortion-doctors. u Social Media post- s by - membe�available upon request) . 12 E xecutive Order on Protecting Access to Reproductive Healthcare Services (July 8, 2022), https://www.whitehouse .gov/briefing-room/presidential-actions/ 2022/ 07/ 08/executive-order-on­ protecting-access-to- reproductive-healtl1care-services/. "l Press Release, U . S. Dep't of Justice, U.S. Attomey's Office, Attorney General Merrick B. Garland Statement on Supreme Court Ruling in Dobbs v. Jackson Women's Health Organization (June 24, 2022), bttps;//WWW.j LtStice.gov/opa/pr/attorney-general-me rrick-b-garland-statement-supreme-court-ruling­ dobbs-v-jackson-women-s. • 4 This is not to say that the months -p receding the Dobbs ruHng were devoid of jncidents. To the contrary, during that time : • a clinic in Kno;-.,ville, Tennessee was btlrned to the ground (Amanda Holpucb, Arson Destroyed Knoxville Pla nned Parenthood Clin ic, Officials Say, New York Tunes (Jan. 7, 2022), bttps ://www.nytimes.com/ 2022/ o 1/ 07 /us/knoxville-planned-parenthood-arson. html); • a clinic in Fort Myers, Florida was blockaded (Michael Brau n, 'Nasty and well-coordinated': An ti-abortion Protesters A rrested After Blocking En try to Fort Myers Planned Pa ren thood, • News Press (J an. 27, 2022), https ://www. news-press.com/story/news/crime/2022/01/27/fort­ myers-anti-.abottion-protestors-arrested-planned-parenthood/9242982002/) ; a clinic located within the San Francisco Genet·al Hospital in San Francisco, CaJifo111ia was invaded and vandalized and one of its physicians was staJked at her home (Gregory Yee, L.A. Antiabortion Actiui t Charged with Ha rassing San Francisco Doctor, Defacing Statue, LA Times 3 CONFIDENITAL TREATMENT .REQUESTED EXEMPT FROM FOIA individuals are aggressively organizing to target reproductive health clinics in states where abortion care will remain legal. 1s And in those states where abortion is banned, we understand that extremists are preparing to harass clinics that provide contraception, cancer screenings, transgender care, and other reproductive health care services. As clinics, providers, and patients confront an ever-changing legal landscape on reproductive health, they need robust enforcement of the protections that remain, including DOJ's enforcement of the right of access guaranteeo under the FACE Act Thank you for your time and consideration. We would like to request a meeting with you atyo11T earliest convenience to discuss this letter, the attached memorandum on the availability of nationwide injunctions under the FACE Act, and the escalation in threats, harassment, and violence since the Dobbs decision. We look forward to being in touch with you. Sincerely, Katherine Spillar duVergne Gaines Executive Director Director, National Clinic Access Project President Feminist Majority Foundation Feminist Majority Foundation Feminist Majority Foundation Eleanor Smeal (May 19, 2022), https://www.latimes.com/california/story/2022-05 -19/los-angeles­ antiabortion-activist-harassing�stalking-doctor); and • a soon-to- b e -opened clinic in Casper, Wyoming suffered an arson attack (Masked, hooded woman seen on uideo settingfire at what would be Wyoming's only abortion clinic, CBS News (June 6, 2022), https://www.cbsnews.com/news/wyoming-only- abo1tion-clinic-arson-video­ reward/). E.g., Priscilla Alvar·ez, DHS Warns of Potential Violent Extremist ActivitlJ in Response to Abortion Ruling, CNN (June 24, 2022, 4:57 PM), https://www.cnn.com/2022/o6/24/po1itics/dhs-warning� abortion-ruling/index.html (explaining that, per the Department of Homeland Security, reproductive and "family advocacy health care facilities" are likely targets of violence and criminal activity post Dobbs). '5 4 EXHIBIT 058 CONFIDENTIAL TREATMENT REQUESTED EXEMPT FROM FOIA August 25 1 2022 Memorandum To : Hon. Merrick Garlan d, Attorney General of the United States Hon. Vanita Gupta, Associate Attorney General of the United States Hon. Kristen Clarke , Assistant Attorney General of the United States James Felte, Chief, Criminal Section , Civil Rights Division Steven Rosenbaum, Chief, Special Litigation Section, Civil Rights Division Paige Fitzgerald , Principal Ch ief, Criminal Section, Civil Rights Division Laura Cowall 1 Deputy Chief, Special Litigation Section 1 Civil Rights Division Sanj ay Patel, Trial Attorney, Criminal Section, Civil Rights Division Elizabeth Saxe, Trial Attorney, S pecia] Litigation Section, Civil Rights Division From; Feminist Maj ority Fou ndation' Re : Nationwide Injunctions Under the FACE Act In the weeks leading up to and following the Supreme Court's decision in Dobbs u. Jackson Women's Health Organization -overturning Roe v. Wade and holding that there is no constitutionally protected right to an abortion-violence and harassment against reproductive health care providers and patients bas noticeably increased. Clinic invasions and organized obstt'l,lctions, as well as arson attacks, have occurred across the country with increasing regularity. And the anti-abortion eJi\.'tremists who are perpetrating this illegal conduct have pledged to escalate their efforts : in a recent suit brought by a Tennessee clinic under the Freedom of Access to Clinic Entrances Act ("FACE Act") , the clinic cited frequent instances of trespass, intimidation , and clinic entrance obstruction, as well as a threat from the defendants to intensify their assault on the cl inic. 2 Attorney General Garl and made cl ear in the wake of the Dobbs ruling that the U.S. Department of J ustice ("DOJ'') would not tolerate violence or threats of violence directed at f Feminist Maj ority Foundation ( "FMF" ) is a not-for-proit , national organization dedicated to ty advancing women's equali , non-vi olence 1 economic development , reproductive j ustice, and access to contraception, aborti on , and reproductive healthcare. FMF's National Clinic Access Proj ect, which began in 1989, leads eff01ts nationwide to reduce anti-abortion violence, keep abortion care personnel and patients safe , kee p clinics o p en , and brin g violent anti-ab01tion extremists to j ustice. Since 1 993 , FMF has periodicall y conducted a National Clinic Violence Survey . Femini st Maj ority Foundation , Femin ist Majo rity Foundation Clin ic Violence Su rvey, https : / /feminist .org/ our-work/ national-clinic-access-proj ect /monitoring-clinic-violence / ( containing links to all surveys conducted since 1 993) . The survey is one of the most com prehensive long itudinal studies of anti-abortion violence and harassment directed at clinics, p atients , health care workers , and volunteers in the United States. z Mem. of Law in Su pport of Emergency Mot. For T RO at 1-21 Femhealth USA, Inc. d/b/a Carafem v. Williams et al., No. 22-cv-00565 (M.D, Tn. July 2 9 , 2022), ECF No. 3 . 1 CONFIDENTIAL TREATMENT REQUESTED I .EXEMPT FROM FOA August 25 1 2022 Page'2 reproductive health providers and individuals seeking reproductive health services, and would use "every tool at [DOJ's] disposal to protect reproductive freedom. " 3 DOJ's pursuit of criminal charges for FACE Act violations is an important step in protecting reproductive health care rights. However1 it is critical that DOJ expand its efforts and pursue civil actions under the FACE Act as well. In particular, to help quell the well-docu mented and escalating violence and harassment targeting clinics, providers 1 and patients, DOJ should pursue nationwide inj unctions against individuals who violate the FACE Act. By pursuing this type of broad remedy, DOJ can help protect access to necessary reproductive care under a constantly shifting reproductive rights landscape. This memorandum outline ("memorandum ) first provides a general overview of today's violence and th reats facing tepi:oductive health service providers an d FM F's request that DOJ seek nationwide injunctions under the FACE Act. In suppoit of this request, the memorandum then addresses the availability and constitutionality of nationwide injunctive relief under the a FACE Act. Next, it explains why this remedy is critical to protecting clinics, providers, .nd patients, the breadth of rel ief that can be obtained via nationwide inj unctions, and the strategic benefits of DOJ pursuing and obtaining nationwide injunctions under the FACE Act. Finally, it expl ai n that nationwide inj unctions u nder the FACE Act remain available following the Dobbs decision-and indeed are now an even more important enforcement tool . I. Background and Overview of Request Congress passed the FACE' Act in 1994 in response to a marked increase in violent crimes against aborti on providers and trespassing and blockadi ng clinics. The violence and dangerous acts ranged from van dalism to arson and even to murder, and were often preceded by threats to property and life. Following its enactment, DOJ's robust enforcement of the FACE Act contributed to a significant reduction in cl inic violence and harassmen t. One of DOJ's most effective meth ods of enforcement was nationwide inj un ctions of conduct prohibited by the FACE Act. Indeed, DOJ obtained nationwide injunctions under the FACE Act in three separate cases during the 1990s. See United States v. Dinwiddie 76 F.3d 913 (8th Cir. 19 96) ; Un ited Sta tes v. McMillan, 946 F. Supp. 1254 (S.D. Miss. 1995); Un ited States u. Roach, 947 F. Supp. 872 (E. D . Pa. 1996). While civil and cri minal enforcement of the FACE Act by DOJ was the norm in past decades, civil enforcement efforts have tapered in recent years . · At the same time, abortion­ related violence, blockades, invasions, and threats have increased as anti-abortion individuals, networks, and organizati ons-emboldened by a lack of meaningful local , state, and federal law enforcement, and a grou ndswell of state legislation that seeks to curtail abortion access -have mounted campaigns to obstruct and disrupt access to reproductive health care and harass and intimidate providers .a nd patients . Press Release, U.S. Dep't of Justice, U.S. Attorney's Office, Attorney General Merrick B. Garland Statement 0 11 Supreme Court Ruling in Dobbs v. Jackson Women's Health Organization (June 24, 20 22), https://www.j ustice. gov/opa/pr/attorney-general-merrick-b­ garland-statement-supreme-court-ruling-dobbs-v-jackson -women-s. 3 CONFIDENTIAL TREATMENT REQUESTED I .EXEMPT FROM FOA August 25 1 2022 Page 3 Today's viol ence, obstruction 1 and intimidatio-n is often perpetrated by repeat players who partici p ated in or seek to em ulate the violence and harassment that spurred passage of the FACE Act. These i ndividualsJ many of whom are active participants in anti-abortion networks or organizations, repeatedly travel from city to city and state to state, across th e country, to obstruct and i nvade reproductive health care facilities and intimidate providers . Their coordinated campaigns deploy obstmctive tactics, threats, and even viol ence, that interfere with and deny individuals their statutory right to clinic access .4 According to a 2021 repmt by the National Abortion Federation ("NAF'') on violence and disrupti on against abortion providers, there bas been a significant i ncrease in such conduct compared to 2020, in cluding a 600% increase i n stal kin g 1 a 450% i ncrease in blockades, and a 163% increase in hoax devices and suspicious packages at clinics.s Tbis conduct terrorizes rep roductive health care providers into closi ng facilities and intimidates patients out of seeking essential reproductive health care. Social media, including far-right social merua platforms , is fueling the abili ty of groups and indiv iduals to remotely organize and incite violence and rusruption. The rise and increased use of social merua enables anti-abortion leaders to organize easily across multiple states. This results in anti-abortion leaders and their adherents frequently traveling across state lines to attempt to sbut down la cinics or othenvise prevent abortion access. It also allows these individuals to target clinic workers, providers, and th ose seeki ng care with h arassment or worse, regardless of location. In addition, soci al media enables anti-abortion €},,.'t:remists to broadcast their ac-tivity instantly: individuals increasingly use social media to livestream their threatening and obstructive tactics to recruit and facite other anti-abortion extremists to commit similar acts . These individuals also use soda] media to widely dissemin ate potential cl inic vulnerabilities, ex.posing the cli nics to even greater risk In short, the accessibility, conven ience, and speed of the internet all ows individuals to more easily and more quickly target cli nics and p roviders, placing them in greater jeopardy. FM F is encouraged that DOJ is pursuing criminal enforcement of the FACE Act against individuals who have made it their mission to block clinic acces . 5 This is an integral step 4 For example, FM F estimates that the same anti-abortion extremists have taken part in at least 37 anti-abortion events since 2017. s National Abortion Federation, 2021 Violence & Disruption Statistics, https : / /prochoice.org/ national -abortion-federation-releases-202 1-violence-disru ption-repo1t/ . 6 Press Release, U.S. Dep't of Justice, Office of Public Affairs , Columbus Man Pleads Gu il ty to Threatening Local Reproductive Health Services Facility (Feb. 15, 2022), https : // www.j ustice.gov / opa/pr/ coJ umbus-man-pleads-guil ty-th:reateni ng-local-reproductive­ h ealth-services-facility; Press Release, U.S. Dep't of Justice, Office of Public Affairs, Ohio Man Sentenced to Prison for Threaten i ng Reproductive Health Services Facility and an Individual Patient (June 19, 2022), https:// www.justice.gov/opa/pr/ohi o-man-sentenced-prison­ threatening-reproductive-bealth-services-facility-and-individua1. In early September, U.S. Attorney General Garl and i ssued a statement emphasizing DOJ's commitment to "provide (continued ... ) CONFIDENTIAL TREATMENT REQUESTED I EXEMPT FROM F0A August 25, 2022 Page 4 toward enforcing and protecting access to reproductive health services guaranteed under the FACE Act. And DOJ's novel u_se of the conspiracy again t righ ts statute in addition to the FACE Act i n a recent indictn1ent sends a strong message th at th e Department is committed to rigorous enforcement against individuals who obstruct access to abortion services)' As a complement to criminal enforcement, DOJ should seek civil inju nctive relief against individuals who are repeatedly intimidating, threatening, and/or obstructing access to abortion services, frequently crossing state li nes to do so, and organizing-even celebrating-these illegal acts through social media. Specifically, DOJ should vigorously pursue nationwide injunctions i under the FACE Act against these individuals. Nationwide injunctions are an effectve means to quelling violative conduct that can and has been replicated at multiple clinics with nation wide implications. Indeed, such injunctions are necessaty to provide complete relief to abortion providers, clinic workers, and people seeking abortion care, who, country-wide, are being intimidated out of providing or accessing reproductive health services -directly contrary to the FACE Act's guarantees . Civil injunctions also can sb·engthen local law enforcement's real-ti me response to incidents, allow for further repercussions against violators, including civil and contempt charges, and carry other strategic benefits . A combined appr.oach of criminal and civil enforce ment of the FACE Act will mean more robust protection of clin ics, providers, and patients. And it will also send a strong message : the federal government does not condone intimidation or interference with an individual's right to access reproductive health services. Such a stance is essential in light of the Supreme Court's ruling in Dobbs. II, Nationwide Injunctions are an Ava.Hable an d Constitutional Remedy Under the FACE Act A. The FACE Act prohibits, among other things: ''by force or threat of force or by physical obstruction , intentionally inj ur[ing] , intimidat[i ng] or interfer[ing] with or attempt[ing] to inj ure, intimidate or interfere with any person because that person is or has been , or in order to intimidate such person or any other person support from federal law enforcement when an abortion clinic or reproductive health cen ter is under attack," and reiterated that DOJ "wiU not tolerate violence against those. seeking t-o obtain or provide reproductive health services, physica1 obstruction or property damage in violation of the FACE Act." Press Release, U.S. Dep 't of Justice , Office of Public Affairs Statement from Attorney General Merrick B. Garland Regarding Texas SB8 (Sept. 6, 2021) , bttps : //www.j ustice .gov/ opa/pr/ statement-attorney-general -merdck-b-garland- regardi ng­ texas-s b8-o. Press Release, U.S. Dep't of Justice, Office of Public Affairs, Nine Defendants Indicted on Federal Civil Rights Conspiracy and Freedom of Access to Clinic Entrances Act (FACE Act) Offenses for Obstructing Patients and Providers of a Reproductive Health Services Facility (Mar . 30 i 2022), https: //www.j ustice.gov/ opa/pr/ nine-defendants-indicted-federal-civil-rights­ conspiracy-and-freedom-access-cl inic-en trances. 1 CONFIDENTIAL TREA.11\mNT REQUESTED I EXEMPT FROM FOA August 251 2022 Page's or any class of persons from, obtaining or providing reproductive health service&." 18 U.S.C. § 248 (a)(1) . B. Nationwide inj unctions under the FACE Act are an available and constitutional remedy. C. Courts have repeatedly upheld the constitutional ity of the FACE Act and injunctions issued under the FACE Act. 1. The FACR'Act itself has been upheld as a constitutional exerci se of Congress's power to regul ate activities substantially affecting interstate commerce. a) 2. Comts have repeatedly rejected challenges to the FACE Act o n First Amendment grounds . 8 a) 3. D. See, e. g ., United States v. Gregg , 226 F. 3d 253 1 26 2-63 (3d Cir. 2000) ; Dinwiddie, 76 F.3d at 920; Roach, 947 F. Supp. at 876; McMillan, 946 F. Supp. at 126 1 . See, e. g ., Dinwiddie, 76 F.3d at 921; Cheffer v. Reno, 55 F. 3d 1517, 1521-22 (11th Cir. 1995) ("The FACE Act is not content or viewpoint based, is not unconstitutionally vague or overbroad, and does not violate appell ants' First Amendment rights .") ; Am. L ife Lea g ue, Inc. v. Reno, 47 F.3d 642, 649 (4th Cir. 1995); Roach, 947 F. Supp. at 876 . Courts have also repeatedly held that injunctions limiting the ability to threaten cli nic providers and patients or to physically obstruct clinic access are constitutional under the First Amendment a) Dinwiddie, 76 F.3d at 92 8-29 ; Roach, 947 F. Supp. at 877,; McMillan, 946 F. Supp. at 1269 . b) By its own pJajn language, the FACE Act cannot be used "to prohibit any expressive conduct . . . protected . . . by the Fi rst Amendment to the Constitution." 18 U.S .C. § 248(d)( 1). The Supreme Court of the United States has recognized th e importance of injunctive relief in ensuring the right to a legal abortion, flow of free public 8 Courts have also rejected challenges to the FACE Act on equal protection grounds under the Fifth and Fomteenth Amendments. See, e. g ., Lucero v. Tr-osch, 904 F. Supp . 1336, 1343 (S. D. Ala . 1995) ; United States v. Dinwiddie, 88 5 F. Supp. 128.6, 1289 (W. D. Mo . 1995) . CONFIDENTIAL TREATMENT REQUESTED EXEMPT FROM FOIA August 25 1 2022 Page'6 traffic, medical privacy, an d publ ic safety. Madsen v. Women's Health Ctr., 5 1 2 U. S. 753, 767-68 ( 1994). E. In addition to upholding the constitutionality of the FACE Act and injunctions issued pursuant to the FACE Act, cou rts have upheld the nationwide scope of FACE Act injunctions. 1. IIT . See Dinwiddie, 76 F.3d at 929; see also Roach 1 947 F. Supp. at 878; McMillan, 946'F. Supp . at 1270. Nationwide Injunctions Under the FACE Act are a Necessary Remedy to Give Full Effect to the FACE Act's Protections A. Not only are nationwide injunctions an available an d constitutional remedy under the FACE. Act, but in light of the ease with which anti -abortion extremists can organize and commit abo1tion-related threats and violence across state lines, they are also a necessary and effective tool at the -government's disposal to provide complete rel ief to abortion providers , clinic staff, and individuals seeking reproductive health services . See Califano v. Yamasaki, 442 U.S. 682, 702 (1979) (explaining that "injunctive relief should be no more burdensome than necessary to the defendant to provide complet relief to the plaintiffs") . B. Nationwide injunctions will prevent eaj oined i ndivi duals from tal..'Ville Health Center (Jan . 26, 2022) , https : / /www.plannedparenthood.org/planned-_parenthood-tennessee-and-north­ mississippi /knoxville-arson. 34 3 s Press Release U .S. Dep't of Justice, U.S . Attorney's Office for District of Delaware , Middletown Man Pleads Guil ty In Fede,::al Cou rt to Use of Incendiacy Device at Newark Planned Parenthood (Feb.' 15, 2021) , https: //www.j ustice.gov/ usao-de / pr/ middletown-man-pleads­ guil ty -federal-court-use-incendiary-device-newark-planned . Vincent Del Giudice, Wyoming's Only Surgical Abortion Clinic Will Open Despite Arson, Bloomberg (May 27 202 2) , https : // www. . bloomberg.com / news / articles / 202 2- 05-27/ wyoming­ s-only-surg ical-abortion-clinic-to-open-despite-arson . 37 Social Media p osts by Kin g dom Conservative Party member Bevel yn Williams available u p on request. 36 CONFIDENTIAL TREATMENT REQUESTED I EXEMPT FROM F0A August 25 1 2022 Page 21 10. Also on July 7, 2022, a known an ti-abortion leader was arrested in New York for using bike locks to seal an entrance to a cl in ic and for lying down in the clinic's parking lot, temporarily preventing entrance to the cli n ic. 38 11. On July 29, 2022, a cli n ic. in Tennessee filed for a temporary restraining order- ("TRO'') against ten anti-abortion extremists and OSA for violating the FACE Act after several OSA adherents entered the clinic and made threats including that they would "take this whole building down, ''terrorize this whole building," and "do what needs to be done," and threatened to intensify their assaults on the clinic.39 The judge granted the TRO u ntil August 5 and subsequently extended it to Augus t 12, the maximum allowed length , at which point a hearing wil l be held to determine whether further action is necessary.4° 1 • 12. D. On August 4, 2022 1 a man from Michigan was charged with arson o f an organization receiving federal -funding for setting a Kalamazoo Planned Parenthood facility on fire, preventing it from opening the following .day.'11 An investigation uncovered that the accused had previously referred to abo1tion as genocide.42 Regardless of the Dobbs decision, DOJ must continue to enforce the FACE Act to prevent th reats and viol ence targeting reproductive health access, as Cougress intended. Indeed, robust enforcement of tbe FACE Act i all the more necessary in l ight of the like] ibood that the Dobbs outcome has or will embolden anti- Pro-life Priest Arrestedfor Locking Plan ned Pa renthood En trance in Abortion 'Harbor' New Yo rk, Life Site (Jul. 7, 2022), https://www.lifesitenews.com/news/pro-life-priest-arrested-for­ locking-planned-parenthood-entrance-in-abortion-harbor-n.ew-york/ . 38 Travis Loller, Restraining Order Against An ti-Abortion Activists Extended, AP News (Aug. 3 , 2022) , https : / / apnews .com/ article/ abortion-tennessee-naslwille5cd8odo50678c3857d8742ec245dao1c; Mem. of Law in Support of Emergency Mot. For TRO at l 1-2, Fem health USA, In c., d/b/a Carafem v. Williams et al., No . 22- v-0 0565 (M.D. Tn. Juy 29, 2022) , ECF No. 3. 39 40'Jd. 4 1 C. Ryan Barber A Mich igan Ma n Who Referred to Abortion as "Genocide" was Charged with Setting Fire to a Planned Pa ,·en thood, Business Insider (Aug. 4 1 2022, 7:10 PM), https : / /www.businessinsider. com/planned-parentb ood-ffre-abortion -j ustice-depa1tment­ arsen-charge-2022-8. 4 2 Id. CONFIDENTIAL TREATMENT REQUESTED I EXEMPT FROM FOA August 25 1 2022 Page 22 abortion extremi sts, perpetuating the -idea that th reats and violence can result in their desired outcome. VII. Conclusion A. Criminal FACE Act prosecutions are one pieoe of the robust enforcement necessary to reduce clin ic violence under the FACE Act 1 and FMF is encouraged by DOJ's novel strategy of protecting reproductive rights by pursuing both conspi racy against rights charges and FACE Act charges. But FMF urges DOJ to enforce the FACE Act using both criminal prosecution and civil remedies in order to prevent and/or take action before violence occurs. B. FACE Act inj u nctions applicable to nationwide conduct are imperative to meaningfully enfOTce the FACE Act and ensure its protections. Precedent establishes that nationwide injunctions under the FACE Act are permissible and necessary, 43 and the FACE Act injunctions urged in this memorandum are aimed at enforcing a long�standing federal law in an effective, constitutional, and targeted manner. Nationwide injunctions issued under the FACE Act will enable DOJ to prevent clinic obst ruction and violence on .a nationwide scale, . rather than one cH nic at a time. 43 See discussion of nationwide i njunction cases, supra Sections II, III, IV. EXHIBIT 059 From: "Fitzgerald, Paige (CRT)" , "Fette, James (CRT)" Subject: RE: [EXTERNAL] Meeting Request, FACE Act Memo. and Cover letter Date: Thu, 08 Sep 2022 l 7:48:05 �0400 Importance: Nonna! Just you two. I think this is totally in SPL's lane, and I'm not familiar with the civil FACE caselaw on injunctions. Fwi'w, assuming the memo cites the cases accurately, it seems that there is precedent for nationwide injunctions against specific repeat obstructionists (and we have a bunch of them) and that such injunctions would cover those who conspire with the injunctees, so it seems like a good idea to me. From: Moossy, Robert (CRT) Sent: Thursday, September 8, 2022 5:21 PM To: Felte, James (CRT)n�;. Rosenbaum, Steven (CRT) Paige (CRT) ; Patel, Sanjay (CRT)n� Subject: FW: [EXTERNAL] Meeting Request, FACE Act Memo, and Cover letter ; Fitigerald, Steve and FACE team: Thoughts on how to respond to this? From: Cochran, Shaylyn (CRT) Sent: Thursday, August 25, 2022 10;30 PM To: Clarke, Kristen (CRT) ; Moossy, Robert (CRT) (CRT) ; B0nd, Rebecca (CRT) Subject: Fwd: [EXTERNAL} Meeting Request, FACE Act Memo, and Cover letter ; Weiner, Robert FYSA. I'll circle back t o talk further about this meeting request. Shaylyn Sent from my iPhone Beg.in forwarded message: From: duVergne Gaihes �g:;:, Date: August 25, 2022 at 9:40:39 PM EDT To: "Cochran) Shaylyn (CRT)" "Fitzgerald, Paige (CRT)" , Sanjay (CRT)" , "Cowall, Laura (CRT)"n�n"Patel, ' �. "Saxe, Elizabeth (CRT)" , "Felte, James (CRT)" Cc: Ellie Smeal feminist.org>, Kathy Spillar <111111-@feminist.ot:E> Subject: [EXTERNAL,] Meeting Request, FACE Act Memo, and Cover letter Dear Ms. Cochran, Chief Felte, Cl7ief Rosenbaum, Principal Deputy Chief f itzgeral� Deputy Chief Cowall, Mr, Patel, and Ms. Saxe: Attached please find a cover Jetter and accompanying legal memorandum urging the DOJ to pursue nationwide injunctive relief to prevent ongoing and foture violations of the Freedom of Access to Clinic Entrances (FACE) Act. We welcome your assistance in enstlring these materials reach Assistant Attorney General Clarke, Attorney General Garland and Associate Attorney General Gupta. Together with our colleagues at the National Abortion Federation, we would like to request a meeting with you, Attorney General Garland, Associate Attorney General Gupta, and Assistant Attorney General Clarke to discuss this letter, the attached memorandum, and the escalation in threats, harassment. and violence against reproductive health care providers and patient communities since the Dobbs decision. We are grateful for your leadership and commitment to ensuring clinic, provider. and patient safety. Thank you for your time and attention to these materials and to our request. Best., Eleanor Smeal, President, Katherine Spillar. Executive Director. and duVergne Gaines, Director, National Clinic Access Project Feminist Ma·ori foundation 0: E: The information contained in this elecrronic message mid any attac11e;:c1 documents arc privileged, confid'entia'I and protected lro111 di'sclosure, and tile information may not necessarily express the opinion of Feminist Majority Foundation. Lf you arc not the intended recipient. note that any review, disclosure, copying, or dissemination of this message or any attachments b strictly prohibited. If you think that you have received this mQssagc in error, please destroy it and notify the sender. EXHIBIT 060 From: "Cowall, Laura (CRT)" To: "Patel, Sanjay (CRT)" Cc: "Klugman, Maura (CRT)'' Subject: RE: MosciJJski Date: Mon, 27 Feb 2023 15:36�03 -0500 Importance: Nonnal lnllne-lmages: image001 .jpg; jmage002.jpg; image003.jpg Good to know, we'll try to move things along on our end, thanks for the heads-up! Laura From: Patel, Sanjay (CRT)".-, Sent: Monday, February 27, 2023 3:09 PM To: Cowall, Laura (CRT)"� Cc: Klugman, Mal.Ira (CRT) Subject: RE: Mosdnski Hey, Laura I'll take care of that. Also, I had a few calls with duVergne last week, and I think she ,is getting ready to make some nofse about her letter/brief from last yeaT about the nationwide injunctive relief issue_ Putting it on your radar. SP From: Cowall, Laura (CRT)"� Sent: Monday, February 27, 2023 2:44 PM To: Patel, Sa.njay (CRT)"._, Cc: l Sent: Monday, February 27 1 2023 2:27 PM To: Cowall, Laura (CRT)"� Subject: [EXTERNAL) RE: Moscinski Thanks so much for sending! I'd love to get on this maiii ng list, if you know who the right person to contact about that. Hope you're doing wellSandra Ftom: Cowall, Laura (CRT)"� Sent: Monday, February 27, 2023 1:00 PM To: Balaban, Rachel {USANYE) ; Pullman, Sandra �g.ny�gQ.ll>; Levine, • Blain, Ellen ; Cha-Kim, Stephen (USANYS) • Danielle (USANYS) (USANYS) �; Klugman, Maura (CRT) Cc: Goldberger, Michael (USANYE) Subject: RE: Moscinski Also FYI on Moscinski: From: NAF Security Department �@12rochoice.org> Sent Monday, February 27, 2023 9:52 AM To: Patel, Sanja.y (CRT)� Subject: [EXTERNAL] Security Alert: Six Anti-Abortion Extremists Found Guilty by Michigan District Court NAF Member Security Alert: Six Anti-Abortion Extremists Found Gui lty by Michigan District Court February 27. 2023 Anti- a bortion extremists Christopher Moscinski, and- were found guilty of by a district court lasi Friday. - Moscinsl; Levine, Danielle (USANYS) ._.; Cha-Kim, Stephen (USANYS) �; Blain, Ellen (USANYS) �i Cowall, Laura (CRT) �; Klugman, Maura (CRT) Cc: Goldberger, Michael (USANYE) Subject: RE: Moscinski Hi - We would like to get a call set up to all speak further on Moscinski. Please let me know your availability for the week of March 6 and I will circulate a WebEx. Thanks and have a nice weekend. Rachel Rachel G. Balaban Deputy Chief of Appeals, Civil Division Assistant U.S. Attorney United States Attorney's Office Eastern District of New York IMPORTANT NOTICE: This e-mail, including any attachments, may be confidential, privileged or otherwise legally protected. It is intended only for the addressee. If you received this e-mail in error or from someone who was not authorized to send it to you, do not disseminate, copy or otherwise use this e-mail or its attachments. Please notify the sender immediately by reply e-mail and delete the e-mail from your system. EXHIBIT 061 Memorandum Subjt.-a: To: Request for Settlement Authority under the f-reedom of Access to Clinic Entrnnces Act, 18 U.S.C. 248 agains From: Kristen Clarke Assistant Attorney General Civil Rights Division Dace: Febmary 14, 2024 Steven H. Rosenbaum, Chief Laura L. CowalJ, Deputy Chief Maura M. Klugman, Deputy Chief Alyssa Wright, Trial Attorney Jated D. Hager, Trial Attorney Special Litigation Section uipy: U.S. Attomey's Office- I. RECOMMENDATION We recommend you authorize proposed consent decrees u.nder the Freedom of Access to Chnic Entrances ACE Act, 18 U.S.C. § 248, to resolve all claims agaihst and , two of seven i.ndjvidual Defendants LO the proposed lawsL1it you arcicipated in the cine 4, 2021 Red Rose Rescue (RRR) physical obstruction of the Center in participated in the of Planned Parenthood �RR �tion of the - in ......... ... \,"i/c developed evidence showing thatn- and 1111 used physical obstruction to jnce.ntionally interfere wjth people obt1in.i.ng or providing reproductive health sernces. Ill We sent letters to all defendants on December 20, 2023, seating our intent to file su.it in 30 days unless Defendants contacted us and were willing to enter into a court enforceable settlement. On January 16, 2024, 1111 counsel called our office to confirm rece.ipt of the letter and inquired about settling prior to litigation. Latex that s�e da)', counsel confirmed j� _o sertJement. On January 26, 2024, the Unned States Attorney's Office for tbe ---jod.icarin interest in settlement. The letter, which (USAO) received a letter from sent from the ■ 11111 The consent decrees wou.ld ensure bmh - and maintain clistance from clinics nationwide and are prohibited from violating FACE in tl1e future. The proposed resolution also avoids the risks posed by litigation anlate the FACE. Ace on June 5, 2021. found here: (last visited Jan. 24, 2024). - \'V'c)men's Center Home Page, tien- by SPL attorne)' Alyssa Wright; August 15, 2022: FBl interviews wit � • Office1-\rrest Reporr. "cId. � PBl lote,rvi<..--.v witl: -3not corning because they saw the police outside the building'' and that at least fiye consult appointments did not show up that day.7 B. � Defeodant - has a lnng b1story of sidewalk counseli ng and par� in Red Rose Rescue events. Si � arrested at least four times in � - and - for conduct in or i:iear reproductive bealthcare facilities. � ci ar es inchLde obstruct:iJlg the police, unlawfuJ entry, aod trespass. has also spoken publicly abouti participation in, a?d support· of, tbe Red Rose R�c�e invasi �os. As recently as Match 2023, gave a presentation about RRR to Corpus Ch1:1.so for Uruty and Peace, an orga�acion that defends ''courageousn defend the sanctity of life, liberty, _ priests �� p=le who _ ■ maraage, namtal law and our democratlc republic.n,,� - ex.plained that one of the Red Rose Rescue tactics is to tell clinic staff and police officers that "we aren't going to leave [inside of the clinicl until ■ ■ ■ this place s huts down."'' told the audjence thati participated in RRR invasions "four nr five times over the past four years," and worked witb Operation Rescue before then. H' has purportedly 11 part:Jcipatec.l in anti-abortion activism for over three decades. 10 Oo A .ril 24, 2021, Ill, aJong with co-defendant Moscin.ski, invadecacc, Red Rose Resc1✓e, Pmcti.i11g 011il Di.r(lbudiimte lo S11ec Bdbi,1J, YouTubc (March 12, 2023) ht s: ,;,;,�·w._,outuhe . com 1 Uni , and Pe ·,,g C'iril /JJ.mbediencc to Sal't' 13r1hie.r, YouTt1he " (3:10) Co1pus Ch • • 7 (March 12, 2023) "" ht-�......�--====.,. 1 1 Patty Knap, Red Roses Jvlean Love: Jury Couvict.s Priest and Two Others for- 'Red Rose Rescue', National Ca,hoLic Regisrer (Peb. 14. 2023), lurps://www.gcq:�ister.com/bh1dn,;d- mse-rtscne - feb-lO- verdict. i:: Bcrnadtttc Pt11c!, Thi: 1J 1it111,1.rs r!f R,•d R()1t1 Rnruers rr. Pil./dir Mn.l'Ciflski tmd- Tht: Cail 1nlic \'v'(lrld Rcpori O uly l, -�nps://www.e111hol 1cwrn:ldrc:.p< ,rt.com/2023/UrI� JI/t hc-wm1cs5-nf- rcd-rnsc-rc scucrs-fr- fiddi�- rnoscinski -�nd- -4- ■ June 202� Attorney General filed a civil suit against - for violations of the PACE Act and �Access Act forn conduct during this incident.I> Center in On A�l , . entered the - -- as part of another Red Rose Rescue. One individual hid in a bathroom and caused the clinic co evacuate all patients for safety concerns. - and at kasc one other Red Rose Rescue member also refused to leave the premises dut"ing this time. A S\VAT team was eventnally called to remove the protestor frorn the clinic bathroom, and the clinic was forced to cease operations for the rest o f the� The Special Litigation Section has. an open FACE investigation into this Red Rose Rescue and 111111 conduct during the invasion. We also received information from the Criminal Section that - was involved in a clinic obstruction in - on January 21, 2023. • used simiJar tactics to the - incident, including making an appointment under false pretenses to gain access ro d1c clinic, in order to invade the facility and shut down services. More information from the Criminal Section about 14 participation in tbe incident is forthcotning.n ■ While researching the RRRnincidenrs on March 3. 2023. Fi1st, 1111 also • articipated in two entered the and one ocher 1gnodng commands to leave by both a clinic staff and , j;1 member and a security gu�roceeded to hand out roses to patiems in the waiting room. While - left shortly after, - Stayed and laid down ih front of the clinic entryway'. 1'he clinic called 9 1 1 wbile rhe security guard attempted to bysicall, remove from the area. Later that same dav, and - also tried to enter the clinic. Both women were turned away b)' the about 20 minutes awav from the clinic entrance after refusing to provide identibcation and security officer at the "acting sw;piciously," according to documentation from the clinic's manager of secuxity and facilities. 15 The National Abortion Federation has tta.eked - and reports that in addition to the artici ated in incid�es: (1) October 14, 2020 incidents listed above, in 111111111111111 (2) November 27, 2021 at the 1 ' Comp!. at 17-18, ECF No. !, June 8, 2023. 14 On Januaty 29. 2024. the Ctirnioal Section informed us rbat they declined to pl'osecute this incident because of resource coostraints, lack of RRR planning documentatioo, and tbe iocidenrol nacure of the force used by - and bther participnnts. The (:r.i.mioal Section bas since referred the matter to our Scccioo. for pot-encia1 civtl enforcement. Manager of Security & Facilities at an- rBI, (,:\far. 3, 2023, 02:38 PJ\11). -5- in 1n • (4) May 26, 2022 'tit the and (5) December 2, 2022 a t The National Abortion Federation is creating an overview document for us that describes these addfrional incidents, inclu.dinglllll conduct dming each event. c. 1111 on une. S 2021 1..anren Handy,n_ and about 12 Around 8:50 �20;2' 1 , and others art-ived at the as part of an RRR event, Handy, � trespassed on clinjcptoperty and refused ro leave when asked by staff llllentered the facility with othet patients, sat down, but within seconds stood up and began proselytizing. Staff confronted leave the facility. Afcer engaging in :t physical altetcation with a patient inside • und demanded y left the cfuuc building, hut remained on private property� sitting in the center of the the facilitparking lot. W'ocried staff then ceased normal operations, 11-eecling co ensure. that everyone in the clinic was supposed to be there. While - sat in the middle of the parking lot, other RRR participants kneeled and prayed by tbe dinic's front doot, while others confronted patients and their companions at theit· cars. ■ II Staff called police around 8:50 a.m., a�et 1111 was discovered it1side the facility. Four of eight available units of the Police Department responded, including the K9 unit. About an hour after their atrival, police ordered RRR participartts ro v11cate or be artested. While ■ 1111 II did not comply, however, and were arrested against their non-violent resistance. ■ being 9uestioned �e, stated, 1']_ went inside because they're killing babies in there." After officers gathered - information, complied with their request to leave the parking lot. Handy and Around 1 0:05 a.rn., the on-scene commanding officer suggeste1:ee to the in j unctive relief provisions , co n d itioning payment o n viol ation o f tb e decree. Th j s strategy mirrors the negotiatio n and final consent d ecree j n U11ited Statu v. Comm: 1, Case o. 22-cv-05835 (D. .J. Oct. 4 , 2 22) which consi sted f i n j uncti ve relief and suspended pen alties. ■ A. ■ Scope of Injunctive Relief In j unctive relief is an appropriate temedy for a FACE violation i f it c'burdens no more s peech than neces ary to ·s erve a s igni ficant goyernment in terest. " Meir/sen v. 1-V'omen 's E-lealth Center, 5 1 2 U .S. 753 , 765 (1 994) . Such an i n j u nction rn ust be ' narrowly tailot·ed to the evidence presen ted." lliled States v. Mcl\ I/ illan , 946 F. Supp. 1 254 , 1 269 (S.D. Miss. 1 995) . Th Act speci fically p rovides that "th co urt ma) award appropriate relief, incl ud i ng temporary , preli mi nary r permanent in j unctive relief. ' ' 1 8 .S.C. § 248 (c) (2) (B) . One factor that courts e\ ahiate to determi ne whether a nationwide in j unction is warranted is the d efendant's. repeti tio u s violations of the F CE Act. I n United tales 1 . DiitJJ!iddie; the coutt granted a nationwide in j u nc tioo acrainst a d fendan t who had repeatedly protested at a cli nic , ft.ea vio lating the FACE Act by bst11Jcting, using physi cal force agai nst , and threatcnin t u se physical force against patien ts and sta ff 76 F.3d 9 1 3 , 9 1 7 , 928 (8 th Cir. 1 996) . Given the defe ndai1t'·s "co. n sistent, repetitious , and flagrant unwill ingntss r inabili ty to compl y ' with the FACE Act, the co urt detei-mined th at 'a geographical l y na1Tow i n j unction j was J i ns ufficien t" to p rotec t the righ ts o f patients and s taff at rep roducti e b ealth faci l i ties across the co untsy . Id. at 929 (intetnal g uotations omi tted) . The co urt en j oi ned the de fendant from vi olati ng tl1 e FACE ct and from being 'ip hysicall y located wi thin 500 feet o f th e entran ce o f any fac' Li ry . . . i n th e U nited States that pro ide [d l ,eprod uctive h eal th servic s." Id. at 9 1 8. Similarly, in United States v. Roach, a district co urt iss ued a p reliminary nationwide in j w, crion because , ' based on the his tory" of the defendant's actio ns , there was no as surance that th y wo uld not violate the ct i n the fu ture . 947 F. Supp. 872 , 8 7 (E.D. Pa. ] 996) . 1 \�Te clid n t incl ude sratutrJr y c!;imagc i n tbi • pn1po.� aJ because we are c, >nce:.rned rJ1at ·ceking statutory dam c� woul I i nvice discuss i'o n wirh0- nbour rhe overall n u m ber o f Out' aggrieved parties and their ide n t ities. M oreovet, ,ve wanr to minimize0 financial liability as an incentive to �ettle. 17 ■ -7- Followin�artment and case la\.v precedent, we seek to propose a nationw.ide injunction against - and - for their FACE Act violations. The consent decree would prevent them from coining within 15 feet of any entrance of any facility as defined by the Act unless for the sole purpose of seeking. medical care for themselves or accompanyjng a family member seeking care. Th.is injunctive prov:isioo is narrowly �ilored (0 protect First Amendment activity, sucl1 as sidewalk connselLng, while maintaining nationwide relief. \Y/e have secured this type of buffer zone relief in the past; in Din1JJiddie, for example, the injunction specified that th� defendant could not be \vithin 500 feet of any reproductive health facility in the United States unless she was pursLtlng legitimate personal acrh-,jfies. 76 F.3d at 928. More recently, we have secured a 25-foot buffer zone around a New Jersey reproductive health facility, United States v. Coumqy, No. 2:22-cv-05835 (D.N.J. Oct. 4, 2022), and a 1 5foot buffer zone around all reproductive health facilities in the Easter-n and Southern Districts o f New York, Na111 Yo,� l?J•James 11. RescNe, 2023 \X/L 8472727, at *23 (S.D.N.Y. Dec. 7, 2023). ln December 2023, tbe Southern Djsn-ict ofNew York granted a pai"cial preliminary injuoction against - ai1d other Red Rose Rescue defendants. New )'ork 0 James v. Rescue, 2023 \"VL 8472727 at *23. The court agreed that a 15-foot buffer zone was appropriate to deter dcfendsition to the preljminary injunction motion sheds light on - likely position dwing negotiations. - argues: Ill As co the first, Plaintiff adduce evidence that - trespassed at one clinic in over two years ago. Plaintiff also offered a newspaper · article indicating that been arrested for trespass in another state in April 2022. This �ory of past conduct is insufficient to establish a th.teat that the conduct will recur in --- Thi's is parcicularJy tme because the remedy Plaihtiff seeks is one that, t0ather than being narrowly tailored to prevent unlawful conduct, -instead iofrjnges on - First Amendment dghts on the public sicle\\ralks outside aborcion clinics. 18 Consequently, we antici� pusbback frotnn- to nationwide injunctive relief. But we have strong evidence demonstrating- has repeatedly participated. ir1 RRR events where invaders swarm clinics and refuse to leave until operations ate forced to shut clow� also continues to do notn so despite bein? repeate�rrested _ h �ve the _n and ��nvicr�d of tr�spas�ing. :X''h.ile -docs _n did pattJCJpate tn RRR mvas10ns 111 multiple states, iustifyLng a same lengthy rustory as nationwide inju0ction. We also believe that is motivated to settle and may agree to nationwide injunctive telief. has not participated in any invasjons after 2021 and thus may be amenable to a consent decree prohibiting activity that.no longer engages in. Therefore, we believe that pursuing nati.oowid�unccive relief is appropriate at this stage and that our _proposed injunctive relief still preserves ... and -ability co engage in protected First Amendment activity. ■ 18 ■ ■ Dd. - Opp'n (O .Mor. for Pre)jm _ [nj. at 12, £CF No. 36, Aug. 25, 2023. -8- IV. CONCLUSION For the�reason s, we recommend y . u authorize us to send p r pose � coosent d:cte _ to Defendan ts -- andr- to secure a co urt en fotceabl settl ement. H either decline t :_tiate, 0r i f we canno t reach a mL�tually atrrecab le s t d ment, we will file our comp laint tl:a� cov�1r-­ - and - conduct, along wlth the other seven de fendants, and eeks pe:nnancnt m1 u11et1ve re ljef, compensato ry damages for each aggrieved person and civil penalties to vindi care the pub Llc in rerest. Attach men ts Appro D LSapprove Comm n ts : EXHIBIT 062 From: NAF Security Departments�prochoice.org> To: Subject: 1nvasions at Two Washington, DC, Clinics Date: Thu, 22 Oct 2020 20:04:46 -0400 Importance: Nonna) .. �Membership I "-- Security Update NAF Member Security Alert: Invasions at Two Washington, DC, Clinics October 22, 2020 At 9 am this morning. a group of anti-abortion extremists invaded a NAF member clinic in Washingt·on, DC. When the extremists rushed the door, a staff member sustained minor injuries and was treated by medical professionals. Once inside the waitlng room, some of the invaders chained themselves together using blke locks and other mechanisms so they could not be easily removed by law enforcement. They used their bodies and furniture to block the internal door and refused to leave the facility. Approximately 10 individuals, including Joan Andrews BeJI and Lauren Handy, were arrested and removed from the facility. Lauren Handy is facing - charges for another invasion in An additional 20 protesters remained outside the building to record the incident and protest from the sidewalk. Lauren Handy referred to this morning's invasion as a "lock and block" incident. This tactic was used by anti-abortion extremists in the '80s and early '90s before FACE was enacted in 1994. We anticipate that "lock and block" incidents will become increasingly prevalent again. �Group photo • Group photo before the first invasion. i;:.;Extremists inside the clinic I Anti-abortion extremists chain themselves together inside the clinic. -- At 2:30 pm , Jonathan Darnel organized several participants from the earlier incident for a "Red Rose Rescue" invasion at a non-NAF member facility ln Washington, DC. During these types of invasions, extremists gain access to a facility and engage with patients by handing out roses, praying, singing, and refusing to leave the property. Approximately six individuals entered the clinic: however, only Jonathan Darnel was arresteq and carred in out of the building (below). Law enforcement is investigating both incidents. r� DaroeJ isT :Tcarr1ed out of fadlit, If you suspect anti-choice protesters have entered your facility, follow your invasion protocols and alert local police immediately, then contact NAF Security. For questions about invasions or other security protocols, please contact the NAF Securinty team at � [Jrochoice.org. Please report any suspicious activity to law enforcement and NAF Security immediately. The NAF Security team asks that you continue to submit your monthly violence and disruption reports on ou Please contact the team at �Rrochoice.org or the individuals below by phone with questions about this alert, submittin or any other security concerns. Tara G., Senior Director for Security: Michelle 0., Security Director: Emma G., Security Operations & Opposition Research Coordinator: Tara and Michelle are available by phone, 24 hours a day, to assist you with any security incidents, threats, or emergencies. Confidentiality Notice: This e -mail message, including any attachments, is for the sole use of the intended rec1p1ent, and may contain confidential and prlvieged lnformatfon. Any unauthorized revrew, use, disclosure, or distribution is prohib1ted. If li you have received this e-mail in error, please 1mmedialely notify the sender by e-mail at the address shown. Please delete it from your files if you are not the Intended recip1ent. Thank you for your compliance. Faoebook � Twitter YouTube Website Copyrig/11 © 2020 National Abortion Federation All nghts reserved. ■■■■@12 You are receiving these emails because you are either a NAF member or subscribed via our website. rochoice.org. You can update your emai l preferences at any time by contactng i EXHIBIT 063 To:" Cc: Emma Goldberg Subject: Blockade in TN Date: Fri, 05 Mar 2021 09:09:41 -0500 Jmportance: High lnlitne-lmages: image003 .png; image004.png Hi Everyone, hnP- • w There is an active blockade at- in Mt. Juliet, TN. We are monitoring and will download the live stream. Police are now on scene. Severa l patients have had to leave the building o1nd were not able to enter the clinic. Stay safe, Michelle Davidson Director, Security All pronovns are respectfully accepted (They/Them, He/Him, She/Hers) National Abortion Federation Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient, and may contain conffdentiaJ and privileged Information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this e-mail in error, please immediately notify the sender by e-mail at the address shown. Please delete it from your files rf you are not the intended recipient. Thank you for your compliance. EXHIBIT 064 From: "Fleisher, Aaron (CRT)" To: Michelle Davidson prochoice.org>, "Fitzgerald, Pai 0e , "Patel, Sanjay (CRT)'' t prochoice.org>, Emma Goldberg �prochoice.org> Cc: Tara Gannon Subject: RE: Blockade in Michigan Date: Thu, 27 Aug 2020 1 1 :33:27 -0400 Importance: Nonnal lnline-Images: image002.png Thanks for this heads-up, Michelle. I'm glad to hear that police are present and arrests are being made. I can't speak for Paige and Sanjay, but I can say from the Civil side that there's not much we can do in the moment, but any video/photos/witness statements you can provide would be helpful to us so that we can evaluate what action, if any, can be taken going forward. Aaron Fleisher Trial Attorney Special Litigation Section, Civil Rights Division U.S. Department of Justice Phone: Pronouns: he/him/his From: Michelle Davidson �@prochoice.org> Sent: Thursday, August 27, 2020 10:08 AM To: Fleisher, Aaron (CRT) ; Fitzgerald, Paige (CRT) Sanjay (CRT) Cc: Tara Gannon @prochoice.org>; Emma Goldberg �prochoice.org> Subject: Blockade in Michigan Importance: High ; Patel, There is an active blockade a t -and Chet Gallagher are among the protest�rs sitting in front of the doors. Local FBI has been notified and police are present. Patients and staff are not able to access the clinic. I was told by a staff member that arrests are being made. In the live video he also adm its to the blockade and are calling it a "re.scue". .facebook.com Michelle Davidson Director, Security All pronouns are respe ctfully accepted (They/Them, He/Him, She/Hers) National Abortion Federation Confidentiality NotTce� This e-maf/ message, including any attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this e-mail in error, please immediately notify the sender by e-mail at the address shown. Please delete It from your files if you are not the intended recipient. Thank you for your compliance. EXHIBIT 065 From: "Patel, Sanjay (CRT)" To: "Carlson Frances (USAMtE)" Subject: RE: Blockade in Saginaw Date: Fri, 1 6 Apr 2021 1 0:44:43 -0400 Importance: Normal lolioe-Images: image0OJ .jpg; image002.pog I was ashamed of myself for a hot second for not knowing. Would your unit chief feel differently about Sterling Heights if some of the subjects were involved ih other blockades, and that I'm hoping to indict one of them for FACE violations in DC? From: Carlson, Frances (USAMIE) Sent: Friday, April 16, 2021 10:41 AM To: Patel, Sanjay (CRT)n� Subject: RE: Blocl Sent: Friday, April 16, 2021"9:46 AM To: Cowall 1 Laura (CRT) ; Smith, Katelyn (CRT) (CRT) Cc: Emma Goldberg �Qrochoice.org> Subject: Blockade in Saginaw ; Patel, Sanjay Hi Sahjay, Laura, and Katelyn, There was a blockade a i n Saginaw, Ml this mornihg. This is the sister clinic t□- in Flint (RRR 6/7/2019). Two women chained themselves to the doors and two others sat down in front of other doors. We believe two of them were arrested. I'm working with the clinic to obtain the cctv footage, incident reports, ahd police report number. Can you contact local FBI- I can't seem to locate a contact in my files? httgs: www.facebook.com httgs: www.facebook.com From what we can tell- Eva Edi, - Heather ldoni, and one .other were involved. Stay safe, Michelle Davidson Director, Security All pronouns are respectfully accepted (TheyjThem, He/Him, She/Hers) ConfTdentic1lity Notice: This e-mc1il messc1ge, fncluding c1ny c1ttc1chments, is for the sole use of the intended recipient, c1nd may contain confidential and privileged Information. Any unauthOrized review, use, disclosure, or distribution is prohibited. If you have received this e-mail In error, please immediately notify the sender by e-mafl at the address shown. Please delete it from your files if you are not the Intended recipient. Thank you for your compliance. EXHIBIT 066 From: "Patel, Sa11jay (CRT)" " �. "Eve,tAnita To:" , "Gibson, Eric (USAPAE) 1' Subject: RE: : PPSP Security Incident Philadelpbia Date: Mon, 1 8 Oct 2021 08:25:40 -0400 Importance: Nonnal lnline- lmages: image00 1 .png Thanks, CJ. This looks like it has merit. We sho1.1ld set up a team call to discuss. My schedule is flexible this morning, and wide open tomorrow. Thanks, Sanjay From: � Sent: Saturday, October 16, 2021 5:50 PM To: Eve, Anita (USAPAE) �; Gibson, Eric (USAPAE) �i Patel, Sanjay (CRT) - Subject: : PPSP Security Incident Philadelphia Special Ag.ent Federc1I Bureau of Investigation Philadelphia Division From : - � Sent: Friday, October 15, 2021 2:46:51 PM To:Jackson, Christopher (PH) (FBI)n� Subject; (EXTERNAL EMAIL] - PPSP Security Incident Good afternoon, l am reaching out to see if you can provide Planned Parenthood with assistance with a recent security incident On I 0/ I3/202t1 , Volunteer Esco1i ushed down by protestor Mark Houck at PP located at Philadelphia (video attached). Please see below is following up with local police but was told he needs to file a private criminal complaint and no arrest was made on scene nor a warrant was initiated. this is for a private criminal complaint. injury suffered from incident: • A bleeding and scraped up arm, which should beal fine. • A problem with the palm of hand/thumb which will likely keept- from ce11ain physical activities for a number of weeks at least. • An ache in his rightthip. The objective of this would be to obtain an injunction similar to the following case law. Thank you in advance for your assistance. Thank you, - M.S.C.J, LPC Senior Director of Security (r3 Parenthood· Planned He/Him/His Care. No mrut« what On Wed, Oct 1 3, 202e1 ate5:26ePMe- wrote: HI First of all, ., as you asked in your other note, I will be going back downtown to press charges. Attached are ph otos of the injury to my arm, as well as the complaint number info given to me by Civil Affairs officerllllll, who took my statement. Also note that I have a bruise and swelling on the palm of my hand from this incident. Also note that when I finally left about 2:45, Civil Affairs was across - talking to the assai lant, Mark Houck. My statement: BTW, in all this, Mark was accompanied by his young son. Mark Houck (known provocateur) was fol lowing two women down the street and across -· followed to let them know they could ask him to leave them alone if they wanted to. Mark told me to get out of the way (I wasn't in the way) and pushed my arm around. No injury from that. And that would have been out of camera range. a bit, and went back to near the I came back to the gate, talked to -• where Mark was. I'm guessing I was maybe 8 feet away from h im. I go there because at the corner he attempts to confuse women who are looking to come into the clinic, and he tries to get them to go to their "clinic'' across the street, thinking they are going to Planned Parenthood. He told me he didn't want me that close to him and his son. I told him it was a public street. He threatened to push me i nto the street. I asked him "is that a threat?", and he said "yes". I turned my back from h im, and perhaps was walking a little back to towards the gate, I'm not sure. He then pushed me hard i n the back and I fell to the ground, badly scraping my right arm below the elbow, which was bleedin g. Also later realized th at my palm was bruised and somewhat swollen, as I had braced myself with the han d I guess. 1111. This was witnessed by two passers by for whom we have their info. Went in, and asked the guard to call Civil Affairs, which he did , and he also callede-· Civil Affairs told me that we needed to call 911i. Not sure if that happened, but eventually Civil Affairs came out. One of the officers was - I believe. He took some info, but said it was a matter for the regular police and he would have them come out. Civil Affairs then went back to their car. Over the next maybe half hour I went back to their car a couple times to ask when the uniforms might come. They didn't know. A bit after the second time, Civil Affairs Officer �am to me and said she could take the info, which she did. She was very helpful. She told me I would need to go to the District - tomorrow when they'd have the info she took, if I wanted to file, and gave me the piece of paper With the DC# (photo attached). Before this, by the way, the guard asked me to look at the footage on video with him, while he was on the phone with a tech person. Eventually we located the incident at 1 2 :51 PM, showing very clearly Mark pushing me down. The guard had difficulty saving the footage, but I assume that eventually happened. That's about it. If there's anything else you need please let me know. And Once I've done the complaint of Thursday, I'll be in touch again. EXHIBIT 067 From: "Patel, Sanjay (CRT)" To: "Kennedy, David (USANYS)" Subject: FW: Grand Rapids, Moscinski, Atlanta, California Bomb Threat Date: Thu, 14 Jul 2022 08:09:59 -0400 Importance: Nonnal IoJi11e-lmages: imageO 14.png; imageO 1 5.png; imageO 16.png; imageOl 7.png; image0 1 8.png; imageOI 9.png; image020.png; image021 .jpg; image022.jpg; image023.jpg; image024.jpg; image025.jpg; image026.jpg; image027.png; image028.png; image003.png; image004.png Good morning, David. See below update re: Moscinski. Looks like he blockaded a Hempstead clinic last week. ls that EDNY? Putting this on your radar. I'm planning to look into it. Best, SP From: Michelle Davidson Sent: Wednesday, July 13, 2022 9:06 PM To: Patel, Sanjay (CRT)n� Subject: [EXTERNAL) Grand Rapids, Moscinski, Atlanta, California Bomb Threat httP-s: www.facebook.com Confirmed Arrested: Cal Zastrow Derek Anderson Potentially 3 more htq�s:Uwww.woodtv.com/news/grand-raP.ids/6-anti-abortion-protesters-arrested-at-gr-reP.roductrve-health-clinic/amP.f. Doesn't sound like the cops know about FACE... per usual. Secu rity r...... .. ....... .. ....... . ··- ··...... .. ·..... . · ·· ..... .. ................. ...... .... ·...... ·-·...... ............... .. ··· ·· .... · ..... . ..... . . . .... ............ ...........· .... ............ .. .................... ..·· .... · ....7 L__ �NAFMe�·b;;s�� .ty Alert: ci�'ct'iaei'n'G";-��-,.,,....,.,.._ Rapids, Ml, and Clinic Invaders found Guilty i 1• .n n. ......, """.._,,,,.n·,.n., _:uln 13,n20�i : . ,:,JM.@J, Sent: Thursday, July 14, 2022 11:22 AM To: Patel, Sanjay (CRT) - Subject: [EXTERNAL] FW: Grand Rapids, Moscinski, Atlanta, California Bomb Threat - Bevelyn and Co and currently attempting to invade clinics i n Atlanta again. They got in to For Grand Rapids: These others listed could be the others arrested. I believe-was also present/blocking. We are trying to ID everyone. and are now at t§ � • . 08% 20:59 � Search ... Joel Curry 1 hour ago · 0 It's time to rescue those being taken away to death. 1 save and 6 arrests in Grand Rapids! "Jesus is King, Cesar is not" In the back of the co car "You want to sing 11 some songs? "All hail the power of Jesus name" Cal Zastrow "Ifs a l l for Him-Jesus" Justin Phillips "I've heard an old old story about a Savior came from glory" To an officer arresting a peaceful Christian "Examine ourself to see if you are in the faith" "You are di sobeying God's Law by rewarding the evil doer and unishing those who do good" "What makes you different than a Nazi just following orders?" Me-Amen -r• 'l( .,"· ,..,,.. � - • ..-..... - '· i._ __ JI ..,•• r -Michelle From: Michelle Davidson Sent: Wednesday, July 13, 2022 9:06 PM To: Subject: Grand Rapids, Moscinski, Atlanta, California Bomb Threat httP.s: www.facebook.com Confirmed Arrested: Cal Zastrow Potentially 3 more httr:2s://www.woodtv.com/news/grand-ra12ids/6-anti-abortion-12rotesters-arrested-at-gr-re12roductive-health-clinic/amp.L Doesn't sound like the cops know about FACE ... per usual. '....... _ .. .............. -......... i l , l I Secu rity ·rt�·�cii��-��"•G·;:;�" riiv�Are ;SecuClinic =-Me·;Ml,a;;and ftJlrpids, Invaders found Guilty i.. , .................. ,,,. !!Grand Rapids, M l Blockade i " ' .r I! r�• 1 ..�.,, ... •-·�, _, Ju!Y 13, 2022T . ... i E:e :i �..,.....�........... _ . ��it�����'tt;���iH�tt( ' �iJX:� :«f."XQ��,.,���•�� "P� � �..��� 1'(���� .���Mi�.J:•i®" • , m ! ! I jwith photos of the provider along with the provider's personal information. Staff notified local police I !who came to the clinrc. According to reports from the staff and local news coverage, six individuals ! ave been detained for trespassing and disobeying lawful orders. i I jThis morning at approx mately 7:00 am, a group of about 30 anti-abortion extremists participated in aj !blockade at a NAF member facility in Grand Rapids Ml. According to a livestream of the incident, r,embers of the group blocked the driveway and employee entrances to the facility while other !members of the group harassed staff as they arrived at the clinic. Protesters also distributed flyers - rn i flease be aware that acts of disruption and obstruction are expected to continue across the U.S. !indefinitely. Mitigation of violence and disruption is enhanced through immediate reporting of )suspicious activity, continuous communication amongst staff regarding anti-abortion activity, and preparedness training. !n l I ! t j I 1 • fit anti-abortion extremists enter or attempt to enter your facility, follow your invasion protocols, alert f aw enforcement immediately, and contact NAF Security. iRed Rose Invaders Found Guilty by Alexandria, VA Jury t'Known anti-abortion extremists Joan Andrews Bell, Terrisa Bukovinac, Lauren Handy, and Jonathan Darnel were ·ailed after pleading no contest to trespassing charges in! � teiation to a November 1 6, 2021 , Red Rose invasion. Lauren Handy and Joan Andrews Bell were i entenced to 30 days while lhe others involved were sentenced to four days. rn ! �andy, Darnell, and Bell, along with six others, are also facing federal charges for FACE Act and Civil! JRights violations stemming from an invasion they participated in in October 2020. �auren Handy was also found guin lnty by a jury on June 28, in relation to a Red Rose invasion at a INAF member facility in Flint, Ml, in 2019. The charges include resisting arrest (felony), trespassing, Jand disturbing the peace. Handy is scheduled for sentencing in September and could face up to two iyears in prison. 1For questions about these incidents or any other security related matters, please contact the NAF Security team. !n """""'""""'"""' I -i� r;�:;;:rn n · :::n·=.==� I about thls alert, submitting incident reports, or any other security concerns: , t Michelle Davidson, Security Director: grochoice.org; Robert Ledogar, Southeast Security Manager: llllllll@P.rochoice.org; Michelle and Robert are available by phone, 24 hours a day, to assist you with any security incidents, threats, or emergencies. �-!ii:6•&JJ1i"tn�W�/JJlMWrft,��offe������ ,• -•r ff jConfidenti ality Notice: This e- mail message, including ii any att.;ichments, is for the sole use of the intended recipient, and may review, use, dii closure, or distribution 1s prohibited. you i fcontain confiden�ial and _privileged inform�tion. Any unaut�orzed ii fhave received this e-mail 1n error, please 1mmed1ately notify the sender by e- matl�iat the address shown. Please delete rt from! ,t::'.� �' n '.�,�:�,=���:i �.�� rei ii i t Th . �·,�:�,i00 :::::�.:�.�::::::_._�----�-•--J. lr---i-<¥�•w-rr•lf•����-rT� ll �i"'-rri·r-�� ! l .. ... - ! -i [�- ..;,.t.EFacebooki f ilnstagram, [ � ITw1ttefc � i NouTubeJ r @ M/ebst� 1 � .:· . .·�·:·... ·.·"t••t.... �":··:�·-·"J.�L . .. ....:Ll....... .... ....,.. . L. ._.L.........�- ~-. ;. �.. �,�. L: � ' -- .. M... = f. ... . . .,. . . . . . . . ... . . . . . . .. . . .. . c;;;;g;:;i·@.2022"N;t;��;,·Ab�rl1��· F�d;;;·ii";;:A·it;;g;;1;·;;;-;;;:;:; �·t· ··..,.. . .. . . ... . ..... .... . . . .... . .....] L'.. -=- .• =-=·· I _J! You are receiving these emails because you are either a NAF rnember or subscribed via our websiLe.i .• _,,_ You can update your e mail prefere nce s a! any tim e by contacting · � • �-- -��----,.,,,-----.,�....... ---.-,y,.,,,-,-;_,....,.,,.,.,,,......,..,.,.,,._,� _• ;:;; ,,:,,;, ;;:; . 0 ·-··-·- · · -··· -··- ·- · ·-············--·· ·······-···••·-••·······...·····-···..·······-····- · ···· - "•·· · - · ·- ·· · · ·-······--··• ····· - · ··· - · 1i I i j t l I !!; Il Secu rity ��$$Ht .•. a:>���::: r 1• ::• . :: •. :.:. · rs . +..-W:S: :::.� WAt. j i � � ·r:· . .� r �NAF Member Security Alert: Clinic Blockade in � ,. � .• . • • 022T t:=� �::��l_J���T · Blockade in Hempstead, NY j Jon July 7 at approximately 10:00 am, antT i -abortion extremist Friar Christopher "Fidelis" lMoscinski carried out a clinic blockade at a non-NAF member facility in Hempstead, NY. JMoscinski used six bike locks to obstruct access at the facility entrance, shutting down fervices for approximately two hours. Hempstead Police were notified and Moscinski was j8rrested. He was later released from the Nassau County jail with an order to appear in !court on July 18 for charges of disorderly conduct by ''obstructing vehicular traffic." ! l � ! I � � I 1 � ! E � � ! � I � � � i I I! � � � � � � � � � � I I I E � � � � � ! I � !Moscinski has been arrested over a dozen times for his participation in clinic invasions, !clinic blockades, and resisting arrest, and was recently convicted for misdemeanor ! �respassing stemming from a 2021 invasion at a NAF member facility in White Plains, INY. He is an active anti-abortion extremist with close tn i es to several anti-abortion groups. ; i !Please be aware that acts of disruption and obstruction are expected to continue across �he U.S. indefinitely. Mitigation of violence and disruption is enhanced through immediate reporting of suspicious activity, continuous communication amongst staff regarding ant1fhoice activity, and preparedness training. � !Clinic Invasions In Atlanta, GA �lso on July 7 , known anti-abortion extremists Bevelyn (Beatty) Williams, Edmee !Chavennes, and Rickey Williams invaded the waiting rooms of two member facilities �n Atlanta, GA. They began yelling at staff, speaking in tongues, and gesturing wildly �hile moving throughout the waiting room. Staff immediately went into lockdown and however, a staff member !called 911. The three individuals left before the police arrved; in !was grabbed during one of the incidents and filed assault charges with the responding bffn i cer. ! ' _____ jPrior to entering these facilities, the extremists attempted an invasion at a non-member I racility and were unsuccessful due to mask requirements enforced by a staff person at the I i lfront door. , Bevelyn Williams !Rickey Williams ! Edmee Chavennes (If anti-choice extremists enter or attempt to enter your facility, follow your invasion protocols, alert law enforcement immediately, and contact NAF Security. !For questions about these incidents or any other security related matters, please contact ; fhe NAF Security team. . f . . . . . .,. . . . . ... . ."'"'ti . ,�-�--�--==---�--=11mi-------��-��--=��.. .... .. .i.i r . .i. ! j ffiRrochoice.org; Robert Ledogar, Southeast Security Manager: ; ! i I i f questions about this alert, submitting incident reRorts, or any other security concerns: Michelle Davidson, Security Director: l ! Ii l Please contact �Rrochoice.org or members of the Security Team directly with ' ! �grochoice.org; I • Michelle and Robert are available by phone, 24 hours a day, to assist you with any security incidents, threats, or emergencies. t--···-tm.1rJWMfJi/�WlM#Wf�&MfUJJ1iiJfi&P.WWJlifiJJW!Wi%/}/JM!i1PtmmJlifJJ!J'ffJWJld/i.WiJff{JM�&'IMl,l\i1m.ll��---mH!ii� ! ,confidentiality Notice: Th iis e-mail messagei including any attachments. is for the sole use of the intended . review. use, disclosure, or . {recipient. and may contain confidential and privileged information. Any unauthorzed ii istribution is prohibited. If you have recei ved this e-mail in error, please immediatel y notify the sender by e-mad Ei if you are not the intended recipient. Thank you for your the address shown. Please delete it from your files ii ji e ompliance . l_,..... *' 1 O a')a '+ 'ro o , ..., C .Q'ro:,.,... , .,o )o � o • i I : oj � :(,o,a!C o� ,.,__ • • � r . n . 1 J ..... r -�""'-�"¥/l�Y/fl\Yl'l(f(«(ff1\JYf � . .. _,·----�--,---. , . ·t 1 L July 1 , 2022 1 111111111111111111111 111111>111111IIIIIIIMIIIIIIIIIIIPIIII IIIlllllllllllll 1111111111111·1111111'11111111111111111111111111111111111 1111·"''1111IIIIHIWIIIIPUUIIIIJIDlllllll�a\'1)'ey'� 1· f'Red Rose" Invaders Found Guilty by Michigan Jury ,.,..,,..,.,.,,,.,uu,, ,.,., ., .,,,.,.,.,,u.,,uu,1 ,. ....... .,, .. ...... . ....1",uu,w,,,..... ....... ... .... .... ,.,.,. ._,... .... .,.,,o;_T,,..1,.. ....... ... ,,_..,,.__.,,.,un,,0<,wu,,.,no .,..,.,,............ ..., ,...,,•.,.....�..,..,.,,,,. ,t.. .,.,,., jKnown anti-choice extremists William Goodman, Lauren Handy, and were found guilty by a jury on June 28, in relation to a _ t'Red Rose" invasion at a NAF member facility in Flint, Michigan, in 2019. The charges ) _ l j i �ncluded resisting arrest (felony), trespassing, and disturbing the peace. Handy, Goodman,! - and are scheduled for sentencing in September and could tace up to two years in prison. Lawyers for the group stated that they plan to appeal the pedsion. Goodman and Handy, along with seven others, are also facing federal charges lfor FACE Act and Civil Rights violations stemming from an October 2020 invasion. ! fBomb Threat at California Facility ; !A bomb threat was called in at a non-NAF member facility in Victorville, (California. According to news reports, the threat was called in June 28 just before 4:00 f i ! ! m and the facility was evacuated and police were notified. After the police arrived on t5cene, a search was conducted and nothing dangerous was identified. The ihvestigatt iton isj Jongoing. I i I For information on how to prepare staff for this kind of obstruction or any other act of iolence and disruption, refer to the NAF Security Resource Manual or contact a member of the NAF Security Team at �Qrochoice. org. l l - �-;:,�11111 II1I _,.�-l, '. 'AIINI Iii 11 17llll'# l, ontact �Rrochoice.org or members of the Security Team directly with 't I �t . ::::�t questions about this alert, submitting incident reP-orts, or any other security concerns: Michelle Davidson, Security Director: P.rochoice.org; Robert Ledogar, Southeast Security Manager: llllllll@wochoice.org; Michelle and Robert are available by phone, 24 hours a daYJ to assist you with any security ;ncidents, threats, or emergencies. . . . J . mww1w;m1f��� ' - -· · - l��t.�o1,:1J...to1M·tw1111M1/:llil:w1.m111,ir16sm 1 I l !confidentiality Notice: Th iis e-mail message, including any attachments, is for the sole use of the intended �eciipient, and may contain confidential and privileged information. Any unauthorized review. use. disclosure. or j !d istribution is prohibited. If you have received this e-mail in error. please immediateiy ii y the sender by e-maili l notif l (at the address shown. Please delete it from your files if you are not the Intended recipient Thank you for your ' . L-�· ::=:.•�=�:=::· �: :: : :�:· · .. .. ..�......:· :�·:�.�: �:� .. -���- .. . t�=:t �,:::..___,____ _________.. .,.,,. . ' lia r·T�,.,..,,1m1r'(1't(i'f',,ru" t\Wl'r.-,r•1!'irfri�·r.r,mro!,1'i'MY1\fmfT"'(1'M'ft'l'1i'(l,fffl11'Mr•1,(, � l 1! ' I t � ;Faceboo� � � p-w1tte� � � ;vouTube; � 'l"IX)��r-...,_._i ,w,���Ai\ r�•iri 1 pnstagramf � !Nebs,t8; ! C�pyright © 2021 National Aborlion Federation, All ,/;his res�rved. -Michelle � • You are receMng these emails because you are either a NAF member or subscribed via our website. You can update your email preferences at any time by contacting l �� �"'H'IN',-,,,.,.,,,."�._.,.""¥'Hi� o♦ • �w,,y,_I f 1111,WW,��� i ,_ l -�_J..____ !? ' EXHIBIT 069 .From:a' To::" Cc:t' FBl)''t� Subject: Fw: Thank You Date: Tue, 23 Mar 2021 10:24:25 -0400 Importance: Nom1al lnline-Jmages: Hi Team, It appears thar Herb Geraghty is the to his FB provided by Michelle below. ndividual that appears in the security videos. Link .. Thanks; From: Mfchelle Davidson �@prochoice.org> Sent: Monday, January 4, 2021"1:35 PM To Cc: FBI)"� (FBI)"�; Emma Goldberg �@prochoice.org>; Tara Gannon Subject: [EXTERNAL EMAIL] -RE: Thank Yo� Hi- Below are the names and social media links for the individuals that we were able to identify. We are still working on"# 5 and #6. I have CC1d Tara Gannon, Senior Director for Security and Emma Goldberg, Security Operations and Opposition Research Coordinator for introductions. We are the NAF Security Team and here to help with anything you need. Looking forward to hearing how the interviews go if you are able to share, of course. "'-'L!!..!...====== Protester 1· Protester 2. _ Protester 3: Herb Geraghty"(_ ���=� Protester 4: (httgs: ww . . Happy New Year and stay safe, Michelle Michelle Davidson Director, Security All pronouns are respectfully accepted (They/Them, He/Him, She/Hers) National Abortion Federation Confidentiality Notice: This e-mail message, Jnc/udTng any ;;Jttachments1 i.s for the sole use of the fntended recipient, and may contain confidential and privileged information. Any unautho,ized review, use, disclosure, or dfstributlon is prohibited. If you have received this e-mail in error, please immediately notify the sender by e -mail at the address shown. Please delete it from your files if you are not the intended recipient. Thank you for your compliance. From: (FBI)n� Sent� Wednesday, December 30, 2020 4:08 PM To: Michelle Davidson-@prochoice.org> Cc: Subject: Thank You Hi Michelle, (FBl)-- Thank you so much for taking the time to connect today! I really appreciate you sharing your insight:s and information with me. Attached, please find six photos of unidentified individuals we'd be interested in speaking with. If you recognize any of them, could you please provide their name and any other identifiers you may have? Thanks again for your help and please don't hesitate to rec1ch out to me if' I can ever be of any assistance in the future. - Happy New Year! FBlnj­ c­ o- EXHIBIT 070 From: Michelle Davidson To: , security • Cc: Subject: lexre:KNAL] RE: Identification A�sistance Date: Tue, I 8 Oct 2022 12:34:30 -0400 IJnportance; Normal Attachm�nts:IIIIIIIIIDo�ssicr.docx Jnlinc-fmagcs: imageOOLpng; im.age002.png; iruage003.png; image004.png Hi Mike, The woman in the "tpro-life" shirt is The masked woman is 'II Wuju�tfD'd �prochoice.org>. •-gJusdoj.gov" < so ,ve doll'! lwvetoo muclt 011 heryet. o .. ... ...........�., ....-""' .... :.' � ...:....__ .... � . ....�°:�:":w�• ...-. _..,,.,,,__...� m ■ �.,.....ll•h:,,\� .... . ;, ,,... ■ !!1!.--0 -.I!.. ■ .. ��•"!Nd"1W7'9e.'ftl� .......... .....,iJ$.U11\AI� tttJ�.,,.,... Sent: Monday, October 17, "2022 11 :30 AM From'. To: Michelle Davtdson i Cc:···· security Subject: RE: ldentilicat,on Assistance @prochoite.org>; Thanks- so much Michelle! From: Michelle Davidson Sent: Monday, October 17, 2022i11:28 AM To: (WF) (FBI) Cc: (WF) {FBI) ; Aloi, Eli2abeth (USADC) Subject: !EXTERNAL EMAIL] -Re: Identificati on Assistance We'll get 011 1111s for you, S1·a ysafe. Michelle David,on Director. Security Art prano.uns are respectfully accepted (They/Them, He/Him, She/lie,-,;) ...... .,.simage ; security �grocboice.org>; Patel, SanJay (CRT) iyusdoJt.gov> COnMe11r:/al/ty NotJ CCflf/de11cia/ a/Id prl'(ller;ecJ inrorr1atlQJ1, My unau_t110,,,ed rewew, 1·1se, (J/sdrJsure, QI dlstrlbut/011/5proJ11blt'etJ, Jf you M�e received c/1/s e·11• a// 111 error, p/eilSe tmmer1/ace/y 110urv the send; Hi Michelle, Hope th·s i· email finds you and your team staying heallhy and $t'lle. I was hop\ng you might Ile able ro provide some assistance Identifying the rwo indi11id11als In lhe_ photos below. In the second photo, we were in1erested fn l'he masked individual ln the bedazt!ed "Cherish Ute" shirt, Thanks so much for your r.elp l 61/st, SA FBI I WFO I CR-10 C 0 EXHIBIT 071 From: "Patel, Sat1jay (CRT)" To: "McNally, James (USADC)" Subject: RE: Red Rose Rescue Info Requested Date: Mon1 I 4 Sep 2020 I 0:53 ;24 -0400 Importance: Normal Attachments: 1 997-Moscin.ski_C-Art.pdf; 201 905-RWW-RRR_Art.pdf; 1 995 1 03 1 -Moscinski C-A1i.pdf; 1 9970120-Moscinski_C-ArLpdf; Handy-Statements.docx.; Red_Rose_Rescue-Cbronology.docx J n line-Images: image00 l .gi f Hi,"Jlm"- Thanks again for taking t1me to chat about your pending cases, and sharing the related reports and body cam footage. Can you also look into getting the related reports from the closed/disposed-of cases? The applic;able statute I mentioned ies 18 USC 248(a}(l) {FACE Act). I believe that we would be considering the "physical obstruction" aspect of the statute. The 11th Cir. has a pattern instruction for this offense, but it does not capture the "attempt," where the defendants' conduct did not successfully prevent any person from providing or r-eceiving health care services (I'm sure we can craft something better). b.ttps://www.ca11.uscourts. gov/sites/default/files/coL1rtdocs/clk/FormCriminalPatternJurvlostruction.ruif In addition to this email string that provides the case info for your pending matters, I've attached the related documents received from NAF. Thanks. Sanjay From: McNally, James {USADC) Sent: Thursday, September 10, 2020 3:01 PM To: Patel, Sanjay {CRT) Subject: RE: Red Rose Rescue Info Requested SanJay - l'm free all day tomorrow and anytime next weel< WIii be OK. My number is Jim From: Patel, Sanjay (CRT) Sent: Thursday, September 10, 2020 2:57 PM To: McNally, James {USADC) � Cc: Cooney, Joseph (USADC) �; Willoughby Jr.", Charles {USADC) Subject: RE: Red Rose Rescue Info Requested Thank you, Chip and J.P. Jim - it would probably be best if we have a call about your active cases. Do you have time for a call tomorrow or next week? Sanj.ay From: McNally, James (USADC) Sent: Thursday, September 10, 2020 2:24 PM To: Patel, Sanjay (CRT) Cc: Cooney, Joseph (USADC) �; Willoughby Jr., Charles (USADC) Subject: RE: Red Rose Rescue Info Requested Mr. Patel, I have the active Moscinski, an� cases. What do you need? Jim McNally From: Willoughby Jr., Charles (USADC) Sent: Thursday, September 10, 2020 2:18 PM To: Patel, Sanjay (CRT) Cc: Cooney, Joseph (USADC) �; McNally, James (USADC) � Subject: RE: Red Rose Rescue Info Requested Good afternoon Sanjay, Please forgive my delayed response. I told J.P. I would get this to the both of you last week and got a bit tied up. Per your inquiries, the following cases have been disposed of by conviction or dismissal and are likely among our closed case files, which we do not have access to at this time: were assigned to former SAUSA Kathryn Lauren Handy ( Schmidt. The cases were dismissed for want of prosecution on 7/23/19. as assigned to former SAUSA Sarah Harper. The defendant was sentencedChristopher Moscinski want of prosecution on 9/19/19. was assigned to former SAUSA Kathryn Schmidt. The case was dismissed for Christopher Moscinski ( for want of prosecution on 10/11/18. ) was assigned to former SAUSA Danielle Rosborough. The case was dismissed The following cases are still active and are currently assigned to SAUSA Jim McNally, who 'I ve copied here. Christopher Moscinski William Goodman Please let me know if you have any questions and/or need anything else from me. Thanks, Chip From: Cooney, Joseph (USADC) � Sent: Thursday, September 10, 2020 1:31 PM To: Patel, Sanjay (CRT) Cc: Willoughby Jr., Charles (USADC) Subject: RE: Red Rose Rescue Info Requested Thanks for the ping, Sanjay. Chip, circling back to this - can you help us get access to the underlying case flles/AUSAs? From: Patel, Sanjay (CRT) Sent: Thursday, September 10, 2020 12:19 PM To: Cooney, Joseph (USADC) � Subject: RE: Red Rose Rescue Info Requested Hi, J.P., Just following up on the potential DC FACE matters I had emailed you about. Assuming these defendants have active cases in superior court, can you have the assigned AUSA(s) reach out to me? Thanks. Sanjay From: Cooney, Joseph {USADC) Sent: Tuesday, September 1, 2020 1:41 PM To: Patel, Sanjay (CRT) Subject: RE: Red Rose Rescue Info Requ.ested Thanks for this, Sanjay. I'm reaching out to my counterpart in Superlor Court to find out where these are and will get you in touch. If we can take any of these federally under the FACE Act we're all in help out. From, Patel, Sanjay (CRT) Sent: Tuesday, September 1, 2020 12:01 PM To: Cooney, Joseph (USADC) � Subject: FW: Red Rose Rescue Info Requested Hi, J.P. Several pro-choice NGOs routinely reach out to me concerning possible FACE Act violations (18 USC 248{a)) that occur around the country. Recently, in DC, there were MPD arrests related to conduct that occurred at local reproductive health clinics. Below is case related information for some activists whom I've been monitoring over the past few years. I believe that these cases are active in superior court. If they are, can you connect me with the AUSA(s) handling these capers? (I'm not sure whether the numbers below are case numbers, report numbers, or something else?) File Date 3/20/19 File Date 8/18/2020 File Date 8/18/2020 File Date 8/12/2020 File Date 8/12/2020 I'd like to take a look at the related reports. I believe that at least two of these defendants have prior misdemeanor FACE Act convictions. If any of these DC cases are potential FACE Act violations, then we may be able to charge those as a felony (sect 248(!)) (2)). Thanks. Sanjay From: Michelle Davidson �@P-rochoice.org> sent: Thursday, August 20, 2020 4:27 PM To: Patel, Sanjay (CRT) Cc: Tara Gannon �P-rochoice.org>; Emma Goldberg --@1;1rochoice.org> Subject: Re: Red Rose Rescue Info Requested Here they are, Sanjay. Sent this morning. From: Michelle Davidson Sent: Tuesday, August 18, 2020 7:39:57 PM To: Cc: Tara Gannon -@Rrochoice.org>; Emma Goldberg �P.rochoice.org> Subject: Red Rose Rescue Info Requested Hi Sanjay, Feel free to share this with Aaron as well, He replied to my previous email wanting to know if any action from Handy occurs. It might be useful for him to have the timeline as well. I also attached some articles on Moscinski that go pretty far back. Let me know if you need anything else. I'll definitely keep you posted if we hear of any attempts at clinics riglit away. Case Numbers: File Date 3/20/19 . File Date 8/18/2020 File Date 8/18/2020 File Date 8/12/2020 File Date 8/12/2020 Michelle Davidson Director, Security All prQnouns are respectfully accepted (They/Them, He/Him, She/Hers) National Abortion Federation Confidentfallty Notice: This e-mail message, Including anv attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, dfsc/osure, or distribution is prohibited. If you have received this e - mall fn error, please immediately notify the sender by e - mail at the address shown. Please delete it from your files If you are not the intended recipient. Thank you for your compfiam:e. EXHIBIT 072 prochoice.org" ppfa.org> Cc: "Channapati, Anita (CRT)" Subject: [EXTERNAL] Re: TENNESSEE WOMAN SENTENCED TO 4 1 MONTHS IN PRISON FOR VlOLATlNG THE FREEDOM OF ACCESS TO CLJ.NlC ENTRANCES ACT Date: Wed, 24 Jul 2024 14:51t:33 -0400 Importance: Nonna] Thank you, Sanjay. This is excellent news. Grateful for the update and l1ard work behind the case. duVergne duVergne Gaines, JD Director, National Clinic Access Project Feminist Ma'oti Foundation O; C: E; The information contained tu this electronic message and any attached documents are privileged, confidential and prolccted from disclosure, and the infom1ai-ion may not necessarily express the opinion ofFeminist Majority Foundation. If you are nl)t the intended recipient, nole that any review, disclosure, copying, or dissemination ofthis message or any attachments is strictly prohibited. If you think that you have .t:eceiycd this message i n error, please destroy it and notify the. sender. From: Patel, Sanjay (CRT)n� Sent: Wednesday, July 24, 2024n11:43 AM To-@prochoice.org; duVergne Gaines; Chiko Scozzafava Cc: Channapati,nAnita (CRT) Subject: FW: TENNESSEE WOMAN SENTENCED TO 41 MONTHS IN PRISON FOR VIOLATING THE FREEDOM OF ACCESS TO CLINIC ENTRANCESnACT Chiko/Miche.lle/duVergne I hope this email finds you well. Please see below press release concerning FACE Act defendant Bevelyn Williams. Thank you, SP From: USANYS-PressOffice Seht: Wednesday, July 24, 2024 12:28 PM Subject: TENNESSEE WOMAN SENTENCED TO 41 MONTHS IN PRISON FOR VIOLATING THE FREEDOM OF ACCESS TO CLINIC ENTRANCES ACT R Head r FOR I M ME D rATE RELEASE Wednesday, J u ly 24, 2024 ht!;p://www.j ustice .gov/usao/oys CONTACT: U .S. ATTORNEY'S OFF [CE N icholas B i ase. Lauren Scarff, ord � TENNE SS EE WOMAN SENTENCE D TO 4 1 MONT HS IN PRISON FOR VI OL AT I NG THE FR E E DO M O F ACC E SS TO C L I N I C E NTRAN C E S ACT Damian Wil liam s, the U nited States Attorney for the Sou thern District of New York, announced today that BEVELYN B EATTY W I L L I A M S was entenced to 4 1 month s in prison for v i olati ng the Freedom of Access to C linic Entrances Act (the ''FACE Act'' ) in J une 2020 in connecti on with her interference, including by threats and force, w ith indivjduals seeking to obtai n and pro vide lawful reproducti ve health services al a reproductive health cenler in Manhattan . On February 22 , 2024, WILL IAMS was convicted after a nine-day j ury trial of one co unt of violati ng the FACE Act befme U . S . Distric t Judge Jennifer L . Roc hon, who imposed today 's sentence. U . S . Attorney Damian W i ,l harns sai d : " Bevelyn Beatty Wil liams repeated l y i ntim idated and i nterfe red w i tb i ndjvi dua l s seeki ng and prov idi ng cri tical reproductive heal th serv ices. She d i.d so by physical ly bloc king access to c l i n ics, th reatening staff, and by force. Th i Office and our law enforcem ent partners are committed to ensuring t hat pat i ents exerci s i ng thei r lega l right to obtain reproducti ve health services and heal thcare fac i l it ies and the ir sta ff provi d i ng those serv ices, can do so without unlawful i nterference or fear of threats or violence ." According to ev idence admitted at trial and other public fi l ings and statements made in Court: On June 1 9, 2020 and J une 20, 2020, WILLIA M S tlu·eatened a,nd used force agajnst patients and taff members at a reproducti ve health center located in lower M anhattan (the " Health Center") and b locked patients and staff members from accessi ng the Health Center. In one i nstance, and as captured on video, WILLIAMS pressed her body against the door of the H eal th Center s pati e nt entrance and refused to move, preventi ng a Health Center volunteer from entering the Hea lth Center. As a Health Cen ter staff member i ( "VictmI ") attempted to open the door for the volunteer WILL IA M S pmposeful l y leaned agaj nst the door crushing Victim- 1 's band. Vict i m- I yel l ed " She's crushfog my hand,'' but WILL 1 AM S remained against the door, trapping Victim- 1 's hand and i nj uring it. At various tjmes on J une 1 9 and 20, 2020, WI LLl AMS stood directly in front of the Health Center entrances . W l LUAMS i ll' i tially bloc ked the main entrance used by pat ients caus ing the Health Center to h ave to divert patients to enter through the staff entrance . W I L L LAMS responded by movi ng to block the staff en trance an.d direct ing others to do the same. WI L L I A M S L i ve streamed some of ber con duct on June 1 9 aad 20, 2020, o n a soc ial media account. On the li vestream on June 1 9 ., 2020, WILLCAMS stood with in inches of the H ealth Center 's chief administrative officer and threatened to "tenorize this place" and warned that "we ' re gonna terrorize you so good, your b u si nes is gonna be over mama ." Simi larly, WILL IAMS stood w ithin incbes of a H ealth Center secw-ity officer and threatened "war. " WILLIAMS al so stated that she would act by "any means necessaiy. '-' ln additjon to W l L L fAMS 's conduct i n Manhattan on multipl e other occasjons from at least 20 1 9 to 2022, W I L L I AM S and others intimidated and inte·1 fered with i ndividua ls seek i ng to obtain or provi de reproducti ve heal th serv ices at other hea lth cli nics across the countiy, i ncluding in Fl orida, Tennessee , G eorgia, and Brookl yn, New York . For example, i n January 2022, W I L LIAMS ttave11ed to a health center i n Fort Myer , Florida, where she d i rected other indiv iduals to b l ock hea l th center entrances. As a result of the blockade, medical staff wa delayed in treating at least a dozen patients, three of whom were scheduled for tin1e- sensitive procedures that could have resulted in bleeding, infection, or sign i ficant pai n without ti mely treatment . l n addition , in July 2022, Wl LL LAMS invaded a bea ltl1 center in Atlanta, Georgi a, where she screamed through the door at patients attempting to enter the faci lity until they were forced to leave. Among other th ings, W I LLJ AMS shouted that she'd go to jai l before letting patients enter the faci lity for an abortion and that he was "not a fraid to get arrested_'' * * * I n addition to the prison tenn, WILL IAMS, 3 3 , of 0oltewab, Tennessee was sentenced to two years of superv ised release . Mr. Wi l l iams prai sed the outstanding work of the Federal B w·eau of lnvestigation . The prosec ution of this case is being handled by the Office's Civi l Rights Unit in the C1i m i nal Division. Assi stant U.S. Attorneys Emily A . Johnson, Mitzi S tei ner, and Jamie Bagliebter, with the assi stance of Paral egal Spec ialist [ sabel Loftus, are i n charge of the prosecution. 24-255 ### You have ,,:i:c 1v,.:J tlw, • mu l l b1:c.iw,e )' l l U hnH· n� k ·J rn Ill' nut 1 Ci ed or · h.m g 1.:!> tu the U . S . Attomex' Offi ce for the Southern f Disbi t of ew York's wch� 11 c , l,ov Dcl i vcr , , p l'II 1d1 ng. t h 1 , l! I vrc (111 hch a l r o l I I 1� I .x cn1t1 v c l f it: fi 1r L n , tet.l . I ates )I 11 ,mi:-y I c-parrn1�11 1 ,l J u,,tt1.·1. . tJ;'i() l c:nn ,j- I ·-:tn iu ;\, e , I'-\A, Wn-;h mg 1 ,n D 20S. 0 �02 -'; J -l -2000 .i n d n, ,,) ll\1 L w,c y!'ur ,, iii i.:nr11 m 1 1 1 fi.in n u r in11 lor Jll)' uthcr p11rp1 �c, !\,Ian, g�y,,w· . uh11 n pt m n, Ol!pnrl me t o f .l w,t ict f>n <.11.Y, Pc1 l u.:y_ 10110 · l 1 v · r-y rn\l,llY� Follow us on Facebook Fol low us OD Tw itter Follow us on Li nked J n , SDNY Website EXHIBIT 073 From: Michelle Davidson �prochoice.org> To: " WF) (FBI)" Cc; Tara Gannon �pmchoice.org>, Emma Goldberg �prochoice.org> Subject: US Capitol-Anti-Abortion Extremists Intel Date: Fri, 08 Jan 202 t 13:05:09 -0500 Jmportaoce: Nonnal Inline-lmages: image003.png Good Afternoon Everyone, I'm sure you are all extremely busy. I wante.d to let you know that we are gathering and compiling a lot of video and intel from Wednesday's events at the Capitol. The Abortion Access Front is a partner organization that we work with often and they have also gathered a large amount of video that we would like to share with you. The March for Life is scheduled for January 29th and we are very concerned that the individuals that participated in the invasion at the Capitol will continue similar actions at this event. I'm not sure what can be done without rights to gather coming into play but because of the severity of the events, and the growing concerns that these types of extremists now pose an even greater threat to Homeland Security than HO's, we wanted to hear your thoughts and provide as much information to you as possible. This is something that we deal with in our field regularly and the escalation is not surprising. Clinics are express1ng concern and are on high alert -and we continue to field calls and support them. We will create a drop box link to the information we have so far and will continue to upload items as both our organizations find them. Let me know if there is one of you fn particular that I can direct these to or if you all are interested. The downloads will take some time but we will send them as soon as they are ready. Stay safe all, Mic:helle Michelle Davidson Director, Security All pronouns are respectfully accepted (Tney/Them, He/Him, She/Hers) National Abortion Federation Conftdentja/ity Notice: This e - mail mess,age, including any attachments, 1$ for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution Is prohibited. Jf you have received this e-mail in error, pleast;= immediately notify the sender by e-mail at the i:lddress shown. Please delete it from your files if you are not the intended recipient. Thank you for your compliance. EXHIBIT 074 From: Tara Gannon �prochoice.org> To: (WF) (FBIt" oice.org> ' ( FBf)'' , " Patel, Sanjay (CRT)" Cc: Emma Goldberg �procboioe.org> Subject: RE: VS Capitol-At1ti-Aborhon Extremists Intel Date: Ttte, 12 Jan 2021 14:59: l 8 -0500 Importance: Nonnal Attach ments: Anti_Abortion_Insurrectionists_at_US_Capitol_ Overview.docx lnline-Jmages: image002.jpg; image004.png Thank you, SA- We have uploaded severaf videos to the link you provided, however; some were not able to upload. We received error messages, In the attached word document, we have added the names of our well known antis present last Wednesday. Under ea-ch name, we provided social media links showing some of them climbing the wall. We also provided statements made throughout the Videos with the time mark stamp. Some of these indiVlduals have been arrested several times for abortion related violence and disruption to include stalking, assault, blocking a clinic entrance1 etc- the-who resigned last week, regularly protests at a member clinic­ confessed to setting fire to an abortion clinic and plotting to later bomb the clinic. He served time in federal prison. The majority of these folks plan to return to DC on Jan 20th and again on Jan 2·9th for t he annual March for Life event. Thank you all so much for your continued support. Tara Gannon Senior Director, Security National Abortion Federation (T) ­ (E) Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have .received this e-mail Jn error, please immediately notify the sender by e-mail at the address shown. Please delete ft from your files if you. are not the intended recipient. Thank you for your compliance. From: (WF)"(FBI ) � Sent: Friday, January 8, 2021"1;11 PM (WF) {FBI) �;To: Michelle Davidson �@prochoice.org>; (WF) (FBI)"�; Patel, Sanjay (CRT) (W�) (FBI)"._; � Cc: Tara Gannon ...@prochoice.org->; Emma Goldberg �prochoice.org> Subject: Re: US Capitol-Anti-Abortion Extremists Intel Michelle, Thank you very much for your continued support. In an effort to streamline a l l the tips we've been getting, we are asking everyone to report information such as this to the tip line. You can continue sending these to us, but let 1.1s know that the information has also been reported to the tip line: httg://www.fbi,gov/USCaP.itol. Individuals may also call l-800-CALL- FBI ( 1 - 800-225-5324) to verbally report tips and/or information related to this investfgation. I cannot thank you enough for your continued assistance and partnership. Sincerely, SA Washington Field Office SA n Field Office � From: Michelle Davidson-@P.rochoice.org> Sent Fridi;ly, January 8, 2021"1:05 PM (WF) To: (WF)"(FBl) �; - (WF)(FBI)� (WF) (FBl)"._,r"Patel,"Sanjay (CRT)"� (FBI)�; Cc: Tara Gannon --@.P.rochoice.org>; Emma Goldberg"._@P.rochoice.org> Subject: [EXTERNAL EMAIL] - US Capitol-Anti-Abortion Extremists Intel Good Afternoon Everyone, I'm sure you are all extremely busy. 1 wanted to let you know that we are gathering and compiling a lot of video and intel from Wednesday's events at the Capitol. The Abortion Access Front is a partner organization that we Work with often and they have also gathered a large amount of video that we would like to share with you. The March for Life is scheduled for January 29th and we are very concerned that the individuals that participated in the invasion at the Capitol will continue similar actions at this event. I'm not sure what can be done without rights to gather coming into play but because of the severity of the events, and the growing concerns that these types of extremists now pose an even greater threat to Homeland Security than FTO's, we wanted to hear your thoughts and provide as much information to you as possible. This is something that we deal with in our field regularly c1nd the escalation is not surprising. Clinics are expressing concern and are on high alert and we continue to field calls and support them. We Will create a drop box link to the information w e have so far and will continue to upload items as both our organizations find them. let me know if there is one of you in particular that I can direct these to or if you all are interested. The downloads will take some time but we will send them as soon as they are ready. Stay safe all, Michelle Michelle Davidson Director, Security All pronouns are respectfully accepted (They/Them, He/Him, She/Hers) National Abortion Federation Confidentiality Notice: This e -mail message, including any attachments, is for the sole use of the intended recipient, and may contain confident/al and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this e-mail in error, please immediately notify the sender by e -mail at the address shown. Please delete it from your files if you are not' the Intended recipient. Thank you for your compliance. EXHIBIT 075 People of Interest on site during the storming of the Capitol Building: • o o training camp in Ohio Video of h m Video of him ··0 o o o o • • • • ., Founde Salt and Light Brigade, OSA Extensive coverage of Recorded many videos on site at Capitol with , also runs a survivalist n Ohio ·- on camera with - and On video at Capitol, 2:40 saying ''You have two weeks to get ready . . . then its on. We are not coming back to normal" Bevelyn Beatty o At the Well Ministties, Love Life o Several previous incidents with police at clinics around the country, including painting over the BLM mural at Trump Tower o Video of her recap after the Capitol attack, saying we are headed for civil war at 2:50 ■ 4:20 talking about •- who lives in the back woods who's been training all his life" and how patriots are pissed and it's not Antifa ■ 4:55 "Civil War is definitely a promfnent thing that is coming to pass" Jason Storms o Asst. Director of Operation Save America, Founder of o o 0 - FounderTo Video of him next to the woman who was shot in the Capitol , associated with Army of God, Operation Save America, Missionaries to the Preborn/Defy Tyrants o Vfdeo of him ·- works with Operation Save America 0 Founder of a -nersonal Capitol Video 0 � 0 0 o • � � Recap Video ■ Promises to post more from inside on - page by Friday • • • • o -.State Senator, associate of Operation Save America o Video of him, claiming to be with several other senators, in front of the Capitol o Associate of Missionaries to the Preborn/Defy Tyrants, Operation Save America o He posted a video showing him going In there. but then took it down - per NYT People of Interest on site for the Trump Rally prior to the storming of the Capitol: I o Regular Speaker at the March for Life ·­ o OSA Associate • Offsite people of interest who were supporting the storming of the Capitol Building • • of Operation Save AmerT iTca o -.,,issionaries to the Preborn/Defy Tyrants, Associate of Operation Save America o EXTENSIVE comment thread advocating for a civil war o Author o Offsite people of interest who were supporting the Trump rally pfior to the Storming of the Capitol: ·0 o • o o Founder o regular speaker at the March For Life Several posts supporting the raid, refusing to acknowledge Biden as president, saying we have started a civil war Founder of regular participant in the March for Life Initial posts supported the police, later posts denounced the violence ·c Video of her interviewing during the capitol storming EXHIBIT 076 From: "Mody, Saeed (CRT • , "Fitzgerald, Paige (CRT)" Subject: RE: US Capitol-Anti-Abortion Extremists lntel Date: Fri, 08 Jan 2021 J 6:36:39 -0500 Importance: Nonnal lnline-lmages: image00l.png Let me check with J.P. to see who in FBI he's coordinating with. I don't think it's the civil rights foll�- From: Patel, Sanjay (CRT) Sent: Friday, January 8, 2021 4:33 PM To: Fftzgerald, Paige (CRT) Subject: FW: US Capi tol-Anti-Abortion Extremists Intel ; Mody, Saeed (CRT) Just a heads up that NAF is the process of collecting .videos from their sources concerning Wednesday. They will share them wlth DOJ (CRTand FBI) once they have completed collecting the videos, Much of it involves individuals they have been following who are involved With the upcoming March For Life protest/rally scheduled for Jan 29 in DC. Many of them were apparently 1nvolved in Wednesday's events. Saeed - d o you want me t o pass this along to Randy at FBI-HQ? SP From: Michelle 0avidson �grochoice.org> Sent: Friday, January 8, l021n1:05 PM To: (WF)n(FBI)n� (WF) (FBI)n.._,; Patel, Sanjay (CRT) ._,; Cc:nTara Gannon �grocholce.org>; Emma Goldberga-.il@Rrochoice.org> Subject: US Capitol-Anti-Ab ortion Extremists Intel Good Afternoon Everyone, I'm sure you are all extremely btisy. I wanted to let you know that w e are gathering and compiling a lot of Video and intel from Wednesday's events at the Capitol. The Abortion Access Front is a partner organization that we work with often and they have also gathered a large amount o f video that we would like to share with you. The March for Life Is scheduled for January 29th and we are very concerned that the indivfduals that participated in the invasion at the Capitol will continue similar actions at this event. I'm not sure what can be done without rights t o gather coming into play but because of the severity of the events, and the growing concerns that these types of extremists now pose an even greater threat to Homeland Security than FTO's, we wanted to hear your thoughts and provide as much information to you as possible. This is something that we deal with in our field regularly and the escalation is not surprising. Clinics are expressing concern and are on high alert and we continue to field calls and support them. We will create a drop box link to the information w e have s o far and will continue to upload items as both our organizations find them. Let rne know if there is one of you i n particular that I can direct these to or if you all are interested. The downloads will take some time but we will send them as soon as they are ready. Stay safe all, Michelle Michelle Davidson Director, Security All pronovns are respectfully accepted (They/Them, He/Him, She/Hers) National Abortion Federation Confidentiality Notice: This e-mail message, Including any attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unavthorlzed review, use, disclosure, or distribution is prohibited. If you have received this e-mail in error, please immediately notify the sender by e-mail at the address shown. Please delete it from your files if you are not the intended recipient. Thank you for your compliance. EXHIBIT 077 From: "F1tzgeral.d, Paige (CRT)" To: "Patel , Sanjay (CRT)" Cc: "Mody, Saeed (CRT)'' Subject; GJ_memo_DC_FACE_Draft chopped Date: Fri, 08 Jan 2021 1 7:36:40 -0500 Importance: Normal Attachments: GJ_memo_DC_FACE_Draft_chopped.docx Hi, Sanjay"This is a great case to be bringing now - the FACE Act was enacted i n part to deal with these kinds of obstructions, and has been effective in essentially wiping them out, so we should make sure that the extremists know that we still have this tool and will use it. The memo is very well done, but it is way longer than necessary for a GJ auth memo. Your intro is fantastic - I was essentially ready to approve after reading that. After that, it re.ads much more like an indictment memo, especially the legal analysis part. I whittled it down a bit in places, and would like you to revisit the legal analysis part to shorten it considerably. You can keep all of this for the indictment memo, but I try to keep our GJ memos for Robert to around 5-7 pages unless there is a particularly complicated issue. Let's at least get this down to no more than 10. That said, you already have almost everything you need for the eventual indictment memo, and your analysis is right on point. Looks like a really strong case, and one we can bring quickly. Thanks! • Paige EXHIBIT 078 From: Subject: FW: **Exempt** INTEL - FT Myers PP Date: Fri, 28 Jan 2022 1 3:48:49 -0500 Importance: Nonnal Attach ments: GSS_InteU igenc�J!i:i�!l!i!lLOSAlllll,df; GSS_Advisory----organizing_s for_healtb_center_invasions_l .2022.pdf; 20220122_G SS_Adviso1y_PP_lnvasion_in_Ft_M yers_FL.pdf; screencapture­ protestchi ldkill ing-campaign-to-end-childkilling-in-florida-2022-01-28-09_47_1s8.png Please see attached and bel"ow. We are getting the surveillance video from the Planned Parenthood facility. We should have it on Monday, From: ._@sheriffleefl.org> Sent: Friday, January 28, 2022 12:48 PM To: (TP) (FBI)"� Subject: [EXTERNAL EMAIL] - FW: **Exempt** INTEL - FT Myers PP Fvi They left for the day in these vehicles. tagn­ tag ­ Tara.11111 Sergeant Desk:­ Narcotics Lee County Sheriffls Office www.sheriffleefl.org I From:"�@sherlffleefl.org> Sent: Friday, January 28, 2022 12:20 PM To: �g> Subject: FW: **Exempt "'* INTEL - FT Myers PP This might have some good info for you! Desk: I Cell: I Criminal Invest. Assistant Real nme Intel Center Analyst Lee county Sheriff's Office �g I www.sheriffleefl.org From: Sent: Friday, January 28, 2022"10:53 AM To: sheriffleefl.or > """ Subject: FW: **Exempt INTEL- FT Myers PP - Can you please revie'i" the attachments regarding future Planned Parenthood protests and add it to the RFI. Please create an Bulletin for forward to the possibly affected areas. IMPORTANT MESSAr;;f· * This messagie is intended for the use or the person or \/ntlly to whom IL ts addressed and mav cont�ln 1mormation lhat Is pnvIIegec1 and tonfident1al, the rj Iscl os,..re of Which r,s goveri,ed by appi,cahle l,w1. If rhe reaoer 01 this emai l Is n1>t the 1t1lencled rectp1ent or ttie ;,n,ploye.- or agert respons,bl!l co dehver ,r ro tl1e Intended rec,p,ent, you are hereby 11ot1fieo thot any c1,ssemInaL1011, rhstrlb11t1ori cir CC1py,ng of this ,nformatIon ts STRICTLY PROHIBlTED If '{Ol.l �ave received this email by errJr, please notify us l1T1inecrIateiv a11d oestroy Lhe related message. nus foot11o(e also conflrri,s trial this ernatl messaqe t,as been swept for the r,resenr..e of computer vln,ses worms, hostile senpt� and other email-borne net;vork tltreats. PUASE NOTE. rlorid,, hns il Vr:ry l.7road put,llt rP.cord� la't'I, Most written com111unicatom, to 01 !rum oovemment offic.laIs are 111Jbhc reeot ds available to the publlc. and ml'!dIa upon reque!>L You1 I em,;11 communications may be subJed to i:,ubht dfsdosu1e p�r Sec l19 F.S. Desk: I Sergeant Intelligence lee County Sheriff's Office �g I www.sherifAeefl.org From: Davis., Alicia �-RRfa.org> Sent: Friday, January 28, 2022 10:02 AM To: �sheriffleefn ln.org>-�g> Cc: Krumwiede, Steven< 1rnswcf.norg>; Clark, Chris �RRSWcf.org>, �ppsenfl.org> Subject: **Exempt** INTEL- FT Myers PP CAUTION: This email originated from outside of the Lee County Sheriff's Office. Do not click links or open attachments unless you recognize tile sender and know the content is safe. Good morning Sgt. - and Detective ... Thank you again for all of your support yesterday. 1 apologize this email is a day late, but as you all know, om' management was seeking an advisory on my end, so I had to push tbis out. This is the second PP this month that .has been ta1·geted by protesters conducting a blockade in my region, so I bave been slammed. As I protnised you Sgt., yesterday's group is associated with Operation Save America (OSA), a well-known a11ti­ abortion extremist group. A majority of the protesters today are out-of-state and came to this health center specifically to conduct this blockade. Tbe minors iovolved are all children of these longtime extretnists. This is the second blockade thal we have seen that has involved their .kids. OSArecently cbanged leaders, cw-rently under Jason Storms, so we are watching closely to see where he takes this group. I have attached the advisory that I pushed out to my side of the house for yesterday, along with an OSA Intel briefing to give you some background on OSA. I will be sending a second email with the profile�ects anested as tbis isn't their first arrest, and it won't be their last. Cal Zastrnw, Chet Gallagher, ..... and Eva Zastrow have been arrested nmnerous times for conducting blockades since we started our unit in 2017. The elders, lik� have bad previously FACE Act charges, but for some reason, the authorities have been dropped. WJ�at ca11 we do to pu �h FACE Act cl� arge�; aga�n for those involved with i11�itlent _ �ure illcidents? This was a well-organized blockade, likely orgaiuzcd by and his Wlf� as they are the local OSA connection. Secondly, as you know, we recently had another extremist, move to Holly Hill, FL, and he has warned that he will be conducting an invasion in FL and is recruiting opposition to get involved. 1 have attached that advisory o- warning. He will be at P P Ft Myers tonight at 6 pm and tomon-ow morning. We have seen in recruiting FL antis to get involved with the anti-abortion movement. Thank you. Stand by for a second email. - **J,itellige,u:e"'* Sensitive lrrformatio11. Do Not Disseminate Information Jntelligence Analyst - Region TII Affiliate Regional Intelligence Program Global Safety and Security Planned Parenthood Federation of America ions Center: --This e-mail ts for the sole use of the Intended recipient(s) and contains information which is confidential and/or legally privileged. lf you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or taking of any action in reltance on the contents of this e-mail information is strfctly prohibited. If yov have received this e-mail in error, please immediately notify the sender by reply e-mail and destroy a// copies of the orrginal message. EXHIBIT 079 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS TO: Affiliate Security Leaders FROM: Global Safety and Security, Intelligence and Investigations SUBJECT: Operation Save America Intelligence Briefing DATE: March 22, 2021 THIS INFORMATION IS SENSITIVE 00 NOT DISSEMINATE WITHOUT PRIOR APPROVAL Executive Summary: Operation Save America (OSA) is one ofthe most prominent opposition groups currently active in the United States. While its budget, social media reach, and number of active volunteers are small compared with more "mainstream" national organizations, OSA 's hardline protest tactics-including graphic signs, megaphones, inflammatory rhetoric, and in some cases civil disobedience-substantially increase the group's ability to disrupt operations and threaten the security of patients and staff. This is especially true when OSA gathers large numbers of followers for national and regional conferences. SENSITIVE INFORMATION/IFOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) Is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. 1 (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Contents Executive Summary 1 History 3 Current Structure and Philosophies 4 Current Tactics and Strategies Leadership Events and Conferences Legislative Lobbying Civil Disobedience 4 5 6 7 Current Leadership President - Reverend Assistant Director - Jason Storms Administrative Director and Police Liaison - Chet Gallagher Other Notable Leaders/Members 8 Chapters and Factions 9 Affiliated Groups 10 Organizational Forecast Media Campaigns Against Patients and Supporters Strategic Abortion Provider Targeting 10 11 11 Endnotes 12 8 8 8 9 SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. 2 (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS History Operation Save Arnerica (OSA) is a national organization that began as Operation Rescue (OR) in 1 986. Founded by Randall Terry, Operation Rescue became infamous for using large groups of people to conduct blockades of the entrances of abortion providers. Between 1 987 and 1 990, thousands of activists were arrested for taking part in these demonstrations ( i ) _ Some blockades lasted for days, often shutting down health seNices in those locations. OR also created •·wanted" posters featuring the photos, names, and addresses of abortion provider Mounting legal problems ultrmately forced Terry to shut down Operation Rescue, though much of the organization's membership and operations continued under the name Operation Rescue National (ORN), led by . At this time, a number of regional splinter groups existed as well, including Operation Rescue West (ORW). I n 1999, ORN fought- and lost-a legal battle with ORW over rights to the "Operation subsequently rebranded the Rescue" name. ORN's then-director group as Operation Save America. ORW took over the Operation Rescue name and contienues to operate as a separate group headed by I n 2014, to succeed him as OSA's leader. r n appointed January 202 1 , it was announced Jason Storms would be replacing - as the leader of OSA in June 2021e. SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional lntelfigence Program (ARIP) is offered as a service lo Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. 3 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Current Structure and Philosophies Operation Save America remains a loose coalition of evangelicals and non­ denominational Christians. Although the organization is registered in Florida, its leader home is in - TX and serves as its de facto base of operations <3l. The number of official members is unknown, but OSA's Facebook account has over 21 thousand followers. While the group often refers to individuals as regional leaders, these titles may often be honorary: exact regions or responsibilities appear to be rather nebulous. There are also several local chapters that are run semi-independently under the OSA theosophical umbrella. OSA affiliates and supporters are often also involved with other anti-abortion groups. OSA's primary focus is on ending abortion. It asserts that human life begins at fertilization, and its leaders advocate for making abortion legally the same as murder (4 )_ The group is also anti-LGBTQ and anti-Muslim. - and others have claimed that all the social, political, and environmental problems facing the United States are God's judgement (punishment) for allowing "the sin of abortion." OSA asserts that there are three levels of government: family, church, and civil. One of its core doctrines is that God's law surpasses civil law, and OSA members therefore feel a duty to obey God's law-as they see it- over any law passed by humans (see Doctrine of the Lesser Magistrates under Legislative Advocacy). Cu rrent Tactics and Strategies Operation Save America is known for its antagonistic approach-loud protests, inflammatory rhetoric, and large, graphic signs are typical features of an OSA demonstration. Aside from abortion providers, the group often targets schools, shopping centers, city squares, LGBTQ events, and religious congregations. From a secular SENSfTIVE rNFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. 4 0 PPFA GLOBAL SAFETY A N D S EC U R I TY I NTE LLI G E N CE AN D I N VEST I GAT IO NS pe rspective , s u ch tactics have the advantag e (for OSA) of g en erating g reate r p u b lic attention and potentia l ly i nti m idating those it h as targeted for h arassm ent. H oweve r, GSS assesses that OSA members view the i r efforts fi rst and foremost as fig hti ng a s pi ritual wa r between God and the dev i l . They bel ieve that Plan ned Pa re nthood and other abortion provid ers are contro l led by demo n ic fo rces , a nd they often refe r to health ce nte r protests as "stormi ng the Gates of He l l . " Th ey bel ieve it is thei r God-g iven duty to fight abortion pri marily by 1 ) preach i n g the Gospel to non­ believers ,a 2) d issuad i ng potentia l abortion patients , and 3 ) fervent pra yer. T hey believe God will end abortion only when a criti cal mass of peo ple has adopted O SA's theology and a p p roach . Becau se OSA members consider the i r anti-aborti on d emonstrations an act of obed i ence to God , GSS assesses that worldl y concern s l i ke media attenti on are secondary to the g ro u p's tactical decision-ma king . W h i l e they have some concern fo r lega l co nsequences i nsofar as they m i g ht i m pinge on the i r capacity fo r conti n u ed activ is m , members have period i ca l ly been wi l l i ng to ri sk a rrest when it su ited thei r p u rposes. I n rece nt years, OSA's efforts have been pri m ari ly di rected toward p rotests-ofte n carried out d u ring its national and reg iona l conferences-and lob bying for leg islation that wo u l d ba n a l l abortion without exceptio n . Leadership Events and Conferences O SA hosts several reg iona l and nati onal eve nts each year. The i r larg est event is the national co nferen ce, wh ich occu rs in a different city each s um mer. Th is eve nt attra cts betwee n 1 00-250 partici pa nts. Protests at abortion p roviders are a stap le of the event. Pa rticipa nts usual l y break u p i nto teams to target seve ra l faci l ities at once. OSA wi ll hold the 202 1 nationa l eve nt i n Phoenix. Arizona . a I ncluding any self-professing Christia ns who are not actively campa i g n ing aga i nst abortion . S E N S IT IVE I N FORMAT I ON//FOR I NTERNAL U S E ONLY DO N OT D I SSEM I NATE WITHOUT P R I O R WRITTEN P E RM I S S I O N The Affiliate Regional Intelligence Program (ARIP) is offered a s a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the A RIP. Participation in ARIP is voluntary. 5 (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Legislative Lobbying Many anti-abortion organizations have pushed for laws restricting abortion, both for their immediate effect and in hopes of setting up a legal challenge that would overturn Roe. However, OSA is firmly opposed to that approach for two reasons. First, it argues that laws merely restricting abortion imply that the procedure is acceptable under certain circumstances. Second, the idea that Roe must be overturned undermines OSA's assertion that Roe was an illegitimate ruling to begin with. OSA is a proponent of the so-called "Doctrine of the Lesser Magistrates," which asserts that local and state government officials have a duty to disobey laws-and Supreme Court rulings-they regard as antithetical to the laws of God. As a result, OSA often lobbies local and state authorities to "ignore Roe" and act as though abortion were legally the same as murder. The group also lobbies for new state laws that would ban abortion without exception. - Wish is one of OSA's most advertised legislative campaigns. The campaign is named for - -, one of sons. - was diagnosed with cancer at the age of16. His dying wish was to abolish abortion in Texas. This wish spread through social media and resulted in - having a personal phone call with Texas Governor Greg Abbott. During that call, Governor Abbott tolde- his wish was granted, as the Republican Party would pursue legislation outlawing abortion during the 201 9 Texas legislative session. - passed away prior to the legislative session and the session ultimately did not end with abortion becoming illegal. As a result, - Wish remains an active campaign to make Governor Abbott "keep his promise". The campaign features emotional videos and photographs of-as his health deteriorated and calls for people to make - short life meaningful by signing a petition to Governor Abbott. When people sign the petition, they are also signing up to receive emails on additional action they can take to outlaw abortion (5l_ Recently, OSA has supported the "Sanctuary City for the Unborn" movement in which small towns pass laws that criminalize abortion. Of note is the city of Waskom, Texas, SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. 6 (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS which passed an ordinance in June 2019, that not only completely outlawed abortion procedures, but also any material support lent in support of abortions. The ordinance declared Planned Parenthood and several other organizations that perform or facilitate abortions to be criminal organizations. Two days prior to the city council vote, OSA's and - delivered sermons at a church in Waskom as a way to garner support for the ordinance. - went on to speak at the city council meeting and told his social media followers, "Please pray as we work with both church and state leaders to build a sanctuary city for the preborn. May our Lord be pleased to establish a precedent that other cities, counties, and states can follow. Time to ignore Roe, establish justice, and abolish abortion now in Jesus' name!" (Bl_ is currently acting as the head of this movement in the State of Texas and surrounding areas. Civil Disobedience In May 2017, OSA organized a blockade of the in Louisville, Kentucky. and ten others were 7 ultimately arrested ( )_ During the most recent OSA national event, - praised those who have been arrested for conducting "rescues'' in the past and encouraged young people to follow .in their footsteps (8). In what appears to be an attempt to revisit the organization's roots, - has been pushing a message that personal sacrifices must be made in the fight against abortion. In August 2020, OSA leader Cal Zastrow organized a blockade a in Sterling Heights, Michigan. The blockade was publicly applauded by .. although it is unknown if he was involved with the planning of the event. This SENSITIVE INFORMATION/!FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. 7 (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS blockade marked the beginning of a reemergence of OSA sanctioned blockades, all of which have been led by Zastrow and Coleman Boyd. In 202 1 , blockades occurred at in Little Rock, Arkansas, and in Mt. Juliet, Tennessee. Cu rrent Leadership President- , of- became the president of OSA in July 2014. Prior to his affiliation with OSA, he was an evangelical preacher who ra�, which is still active and generated $1e65,805 in revenue in 2018 <9J_ He studied acting in college, and his sermons tend to be boisterous, theatrical, and militant. , He has 1 3 children, many of whom are also involved with OSA. Assistant Director - Jason Storms , became Assistant Director in February Jason Storms, of 2018. Storms will become the OSA president in June 2021. He is married to , the daughter of of Missionaries to the Preborn. Storms does not believe that violence as a tactic is inherently wrong but feels it would be counterproductive to the anti- abortion movement. Administrative Director and Police Liaison - Chet Gallagher Police Officer who was He has bee� SENSITIVE fNFORMATfON//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own Judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. 8 co PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS for anti-abortion protest activities and has participated in recent blockades. • • • • • • • • Other Notable Leaders/Members • - Arkansas - Wisconsin - Nort.h Carolina - Texas - Oklahoma • Coleman Boyd • Mississippi • Derin Stidd - Indiana • Indiana • - Indiana • Cal Zastrow - Michigan • - Louisiana • - Florida • - Indiana - North Carolina GSS notes that although OSA's official position is that men should be the leaders in the home, church, and state and women should be helpers, nurturers, child-bearers, and homemakersi(4l, the group does have many women who take on subservient roles during campaigns but are leaders behind the scenes. For example, , does not hold a formal leadership title within OSA, but is the wife of often responsible for behind the scenes operations. Chapters and Factions Several people associated with Operation Save America have created local chapters to organize their efforts on a smaller scale. Some of the known chapters are: • Operation Save Chicago • Operation Save Phoenix • Operation Save Waco • Operation Save Kansas City SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. 9 (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS • • • • Operation Save Pakistan Operation Save Charlotte Operation Save Ashville Operation Save Spokane • • • • Operation Save Central Florida Operation Save Jacksonville Operation Save Little Rock Operation Save Mexico Affiliated Groups Operation Save America is known to work with and/or support the following organizations: • Abolish Human Abortion • Apologia Church (and Apologia Studios) • Missionaries to the Preborn GSS notes that membership in these organizations is informal, and OSA is so closely associated with both Abolish Human Abortion and Missionaries to the Preborn (MttP) that there is almost no significant difference beyond who is ostensibly leading the action. Superficial differences include distinctly branded clothing and accessories, distinctly branded propaganda, and separate-but often connecting-websites. OSA is older than AHA, and most of its core members have either historical or family connections to the group. Apologia Church has a much shorter history of working with OSA, but their level of collaboration appears to be growing. Apologia Church is hosting the 2021 OSA national conference. Organizational Forecast OSA has never been able to muster anywhere near the number of activists who once participated in the blockades organized by Operation Rescue under the leadership of Randall Terry. Part of this is due to the proliferation of anti-abortion organizations that SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. 10 (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS have emerged since the late 1 990's. Activists now have several options to choose from and may align themselves primarily with local groups, but participate with national organizations, such as OSA, when there is a local event. Even with the decline in active members, OSA remains one of the most prominent opposition groups in the United States. OSA still has the ability to amass large crowds that can disrupt health services and threaten the security of both abortion providers and patients. Furthermore, the group's virtual merger with AHA means that its leaders__, Storms, Gallagher, and others-will continue to have influence over a growing number of hardline activists, whether those activists consider themselves to be OSA, AHA, or another ideologically aligned group. Media Campaigns Against Patients and Supporters Operation Save America states on its website that "we are working on a Kingdom Warehouse website called #notavictim for the abolition movement to dispel the myth of the 'second victim' narrative promoted by the pro-life movement." The goal of this campaign is to challenge the narrative often promoted by other anti-abortion groups that a woman having an abortion is a "second victim" along with the aborted embryo or fetus. To that end, OSA is soliciting "testimonies" from women who will describe themselves not as victims but repentant murderers redeemed by Jesus Christ Ol_ (legal name of- TX, is provided as the point of contact for women volunteering their testimonies. OSA also uses the #notavictim hashtag on social media to share content that they feel advances the narrative that women who have abortions are murderers, not victims. Ultimately, the group hopes this campaign will lead to the criminalization of all abortion, with legal penalties both for the people who have abortions and those who provide them. Strategic Abortion Provider Targeting In 201 2 , OSA launched the "States of Refuge" campaign to target physicians and clinics in states with only one abortion provider, including Mississippi, South Dakota, North SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. 11 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Dakota, Arkansas, Missouri, and Wyoming. During this campaign, OSA leaders organized to have a continual presence at abortion providers immediately following the 40 Days for Life Campaign, followed by "truth tours·· and regional events ( 1 1). The goal was to target the abortion industry at their '1weakest and most vulnerable points" (121 ) to establish at least one abortion free state. Although OSA has not published plans to conduct a campaign of similar nature, some of its messaging suggests this could be a future strategy. During the group 1s July 2019 national event in Wisconsin, OSA leaders repeatedly emphasized that Wiscohsin only had three remaining abortion providers, and they called on young people to "complete the work." As new legislation restricts abortion access to fewer and fewer providers in many states, GSS assesses OSA may find new opportunities to single out specific providers for harassment. This product was prepared by , Regional Intelligence Analyst and , Intelligence Research Specialist. Comments and queries. can be fa.or o at addressed to Directo SENSITIVE rNFORMATION//FOR fNTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional lntelfigehce Program (ARIP) is offered as a seNlce to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own Judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. 12 (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Endnotes 1 . [Online] https://www.upi.com/Archive 2. [Online] Feminist Majority Foundation. https://www.feminist.org 3. Report, 2019 Florida Not For Profit Corporation Annual. Florida Division of Corporations. sunbiz.org. [Online] [Cited: 08 20, 2019.] http://search.sunbiz.or 4. Operation Save America About Us. Operation Save America. [Online] [Cited: 08 20, 2019.] http://www.operationsaveamerica.org/about_us/. 5. https:/�ish.org. [Online] 6. Facebook. [Online] 7. [Online] Feminist Majority Foundation. https://feminist.org 8. Facebook. [Online] https://www.facebook.com 9. [Online] IRS.gov. 10. [Online] http://www.operationsaveamerica.or 1 1 . Schedule of Events. www.statesofrefuge.org. [Online] [Cited: 08 22, 2019.] 12. http:�in.com [Online] SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. 13 EXHIBIT 080 (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS TO: , Director of Facilities and Security Planned Parenthood of South, East, and North Florida Senior Director of Facilities and Security Planned Parenthood of Southwest and Central Florida FROM: Global Safety and Security; Intelligence and Investigations SUBJECT: Anti-abortion extremist health center invasion in Florida DATE: threatens to conduct a Januarye7, 2022 Executive Summary: Anti-abortion extremist, organize and conduct a health center invasion i n Florida in 2022. states he will Details: On January 5, 2022, Global Safety and Security (GSS uncovered a Facebook video of an interview with well-known anti-abortion extremist . The of Catholic (AKA ) an interviewr hosted by with what the opotion chooses to call involvement Drivetime, discussed 1£11 "Red Rose Rescue" and the pro-life movement. During the 21-minute video interview, - promotes his agenda and mission. He encourages listeners to become more involved in protesting abortion by supporting non-violent direct action. He states that opposition members can become more involved by participating in a health center invasion or protesting outside a health center. 111 1 Catholic Drivetime. Facebook video osted on December 16, 2021. Retrieved from Facebook on January 4, 2022 from :..:.. htt ==c...u..u====� SENSITIVE INFORMATION//FOR INTERNAL USE ONLY 00 NOT DISSEMINATE WITHOUT PRIOR WRJTTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affffiates to supplement their own security resources and programs. Planned Parenthood Affifiates are advised 10 rely on their own judgment as to the accuracy or significance of information received through the AR/P. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS - continuously expressed his distaste that Florida has 58 abortion health centers. By the end of the interview, - admits several times that he will conduct at least one health center invasion in Florida in 2022. Analyst Notes: GSS assesses- will follow through with his threat. He will plan, organize and facilitate a health center invasion within the upcoming months. GSS previously assessed that- recent move to Florida would result in him t'rying to organize anti-abortion opposition. In Mey 202.0, - made several social media posts hintin�ing his ministry to Florida. By September 2021, moved to - Since his move. he has been aggressively attacking anti-aborUon advocates online, pointing out their lack of organizing anti-abortion protests and their inability to shut down the 58 health centers in the state. GSS queried internal databases, sub�atabases, and open-source databases for the most up-to-date information on - Below is a combination of that data. Name: AKA: Father Date of Birth: Address: Possible Phone Numbers: Vehicles: -· license plat Opposition Association: Life Ministry US; Red Rose Rescue; On The Road for Life Arrest History; Social Media: • Facebook:.!.Z w...?.: w!..!.w:.:.f!.!=a����:!::::: www.efaceboo SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplemf'Jnf their own security re-sources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance ofinformation received thr(wgh the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS ��J.WJLLU�== • Twitter: • Website: GSS has documented several supporters for - located in Florida. Many of his supporters have been involved in anti-abortion protests. Some have participated in health center invasions, have conducted a similar versfon of a RRR, or have expressed of a desire to articipate in ahealth center invasion. Those rotesters are • In 2021, - traveled to Washington, DCJ St;Jveral times to participate in RRR. • On May 16, 2020, protesters did not invade the roses. . but did verbally harass patients and pass out red • On January 23, 2020, - posted a Facebook video admitting • and attempted to enter a non-Planned Parenthood health protester center in Washington, DC. 2£21 The protesters went into the building where the health center was located and walked up the front door. The protesters were going to enter the lobby, but instea� left religious pamphlets and anti-abortion material on the front door. - commented several times that • was surprised by the lack of sec1.1rity at the health center and how easy it was for them to gain access to the health center. 2 r21 - Facebook video posted on Janua 23, 2020. Retrieved from Facebook on January 5, 2022 from htl . w fa b k. SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affilfate Regional Intelligence Program (ARIP) is offered as a seNlce to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on /heir own judgment as to !fie accuracy or significance. of information received through the ARIP Participation in A.RIP is voluntary, (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS • In May 2020, ex ressed his desire to participate what he called a "Red Rose Rescue" with - has been working with - in organizing anti-abortion protests, The Men's March throughout the country. GSS assesses - will continue encouraging his followers and supporters to participate inhealth center invasions. Florida does not have a very organized anti-abortion network. �the anti-abortion organizations are small and very fragmented. GSS notes - does have the social media influence and outreach to potentially create a more organized network within the state. Conclusion: - will conduct at least one health center invasion in Florida in the upcoming months. GSS cannot identify a date, time, or location due to limited and his associates. GSS will monitor other information but will closely monitor key associates Lauren Handy, and ) to document any traveling to the state. GSS assesses that local opposition may conduct counter-surveillance and undercover surveillance to collect data for potential targets. Previous opposition counter-surveillace tactics include protesters posing as patients seeking abortion health care, posing as patient partners seeking abortion information, and posing as transgender patients seeking health services. GSS recommends Affiliate Security Leaders (ASL) familiarize themselves with what the opposition has chosen to call "Red Rose Rescues" and their tactics, -· and the local opposition that - associates with. ASLs should report any suspicious activity to GSS for further follow-up investigation. SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP Participation in ARIP is voluntary. (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Photos SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS ■ license plate - Florida RRR Supporters SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of Information received through the ARIP. Participation in ARIP is voluntary. (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS - SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP Participation in ARIP is voluntary. (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS and Conducting Similar RRR at Non-Planned Parenthood in - ■ SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS ■ .., R•dnR....,nflttlwtn, ' ��" '""'""""l'� YVOOOE(fu, - SlITI ine t1.a•1w;,y o• Ille -w,,were """"-,d t1)' 11,e, v W1Con• ot tr,e $t.;/fp.11.-uie rlo.,e • , a:ncs 'SA'lrflte llletouure oiifld �n s;,,11r1 net c:-KIOf 3 wx,g ,n,e in snie ,nen w•rll c:,;,<:1< mto Illa ""'· lllll qul-,,,iy -=11. Sile"""°° anc5"'4-wa, 1 ea,,119 1n �IIQ�'ell �11;: Vlt! tttett C'l)ll..ut.rV:c:m::d 8 � !\:.I\W� vetOdi.n 1d'. tte­ 4 e..c.11 otn l V ,1,1)1,b,ye Wlttn ln ln w-.s tr,!rtg IQ�·�� a,,d -- w.>$ \J""9 J10 fll1"1$0 00 $>ni't>y ..rn, .._, iao1 11 .vu�9l a:,� tt• ..,,J...w,,nr, llf aQ�•ll', l ""' M1t1ti.,tj Df1 l�1't.,,_...,• 1 l !• ! 0 I 1'11'Tffl l •� ::; SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and progrc�ms. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Intelligence Analyst, Global Safety and This product was written by Security, Intelligence and Investigations. Comments and queries can be addressed to or at ENDNOTES SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP Participation in ARIP is voluntary. EXHIBIT 081 (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS TO: Affiliate Security Leaders FROM: Global Safety and Security, Intelligence and Investigations SUBJECT: �ion opposition carry out a blockade at a Planned Parenthood in -.eFlorida DATE: January 27, 2022 Executive Summary: On January 27 ists formed a blockade· at the • individuals were arrested. n S�ca (OSA) in - Florida . Details: On January 27, 2022, at 8:1 �� I • t ..I t gather in front ofe-­ tt • • . Protesters began to trespass onto the health center's property, • n and staff as they arrived. Planned Parenthood of started to hares notified the Lee County Sheriff's Office (LCSO) to At 8:49 a.m .. six anti-abortion protesters trespassed onto the property of the health center and approached the front door, where they attempted to enter the lobby. The group was unsuccessful in enter1ng the health center due to the locked doors in the vestibule. The protesters left the building and went back to the street. The group of protesters was led by Operation Save America (OSA) associates Cal Zastrow and Chet Gallagher. l11 t21 t 11 Coleman Boyd Facebook. January 27. 2022. Retrieved on January 27, 2022 from https.//www.facebook.com1 L2l Coleman Boyd Face book. January 27, 2022. Retrieved on January 27, 2022 from https://www .facebook.com/ SENSITIVE IN FORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affifiate Regional lmelllgence Program (ARIP) Is ottered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of Information received through the ARIP. Participation in ARIP fs voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS By 8:55 a.m., LCSO arrived on the scene to witness this same group of protesters trespassed onto the health center's property again, where protesters proceeded to sit down and block the front doors. Officers immediately begin to remove the protesters from the area and placed the under arrest During this incident occurring in the front of the �our protesters walked to the rear doors of the health center. OSA associate - and Chet Gallagher blocked the rear doorway, resulting in their arrest. LCSO Deputies arreste�rotesters. GSS identified the arrestees as: igan - �ofeTennesse ---- (minor) Ev Z GSS has identified protesters that were standing by the street as: yd - Bevelyn Beatty Edmee Chavaness SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or slgnificanoe of Information reoelved through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Analyst Notes: - recognition of unusual anti-abortion protesting activity and � I •••I I to� alleviate the impact the invasion would have had on the operation. GSS previously notified Florida Affiliate Security Leaders that Boyd and hi n · the northern part of Florida after protesting at a non-Planned Parenthood in- GSS had no information or intelligence that Boyd was planning on an invasion or would protest at any Planned Parenthood health center but to be aware of any unusual activity. GSS notes this the first reported health center invasion in Florida. I GSS assesses this invasion was a well-organized event that included a wide range of OSA and Abolish Human Abortion (AHA) protesters fro� Mich· M' • • pi, North Carolina, and Tennessee. GSS further assesses - and re likely responsible for organizing . Leading up to this invas have aggressively targeted this by organizing protests to include riveway access, and enc ers to harassing patients and staff I Ii viously charged h. but the charges were ultimately droppeq•.J.��.JJpted to that they would be p�fferent charges against- due to his previous arrests. GSS and- will be working with LCSO's intelligence unit to provide information to assist on possible FACE Act charges against this group. Conclusion: Blockades conducted by OSA opposition and Red Rose Rescues are tactics used to cause, a disruption that shut down health care facilities. The tactics are often in violation of the Freedom of Access to Clinic Entrances (FACE) Act. SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or slgnificanoe of Information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Photos rovided b First Blockade Attempt Second Blockade SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Second Blockade Second Blockade SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS - .�.' ..- Eva Zastrow's Arrest _.....,..--:-,,:..,,...,..--..... SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Cal Zastrow's Arrest SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Bevelyn Beatty and Edmee Chaveness harassing SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Opposition photos provided by - and- Chet Gallagher, Cal Zastrow, and Dennis Green SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Opposition photos provided by - SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional lntel/igence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. (0 PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Opposition Identified Cal Zastrow Coleman Boyd SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS Opposition Identified SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS This product was written by Security, lnte�we - at Intelligence Analyst, Global Safety and d � addressed to or-. SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional lntellfgence Program (ARIP) Is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own Judgmen/ as to lhe accuracy or significance of information received through the ARIP. Participation in ARIP is voluntary. PPFA GLOBAL SAFETY AND SECURITY INTELLIGENCE AND INVESTIGATIONS SENSITIVE INFORMATION//FOR INTERNAL USE ONLY DO NOT DISSEMINATE WITHOUT PRIOR WRITTEN PERMISSION The Affiliate Regional Intelligence Program (ARIP) is offered as a service to Planned Parenthood Affiliates to supplement their own security resources and programs. Planned Parenthood Affiliates are advised to rely on their own judgment as to the accuracy or significance of Information received through the ARIP. Participation in ARIP is voluntary. EXHIBIT 082 From: Michelle Davidson �proohoice.org> To: � Cc: Robert Ledogar �prochoice.or > EduaJ·do Serrano "Taskforce, Clinicviolence CRT " (CRT)" a prochoice.org>, , "Cowall, Laura ,, usdoj.gov> Subject: [EXTERNAL] Incidents int - Bevelyn Beatty & Co/Contact info for Georgia Clinics Date: Thu, 07 Jul 2022 1 8:34:51 -0400 Jmportance: Nonnal Att.achments: Beatty-Bevelyn-Dos.docx: 20220707-Wiltiams_Bevelyn-­ PD_Report_Num.jpeg AgentBevelv.n WIiiiams, Edmee Chavennes, and Rickey Williams entered 3 facilities this morning and caused lock downs at at least 2 of them. -alerted me while they were still ihslde and I could hear them screaming in the background. Staff reported that they were afraid and very shaken by the incident. The 3 extremists (who are known to us) left before police arrived. theadmin at- reported that she was grabbed by one of the individuals and has filed assault charges. Attached is the police report number for that incident as well as a dossier on Bevelyn Williams (aka­ Bevelyn Beatty). Let me know if you need more information or if I can clarify anything. NAF Member Facilities - -Medical Associates - Executive Director Primary contact - - Administrator Incident FB live video: htt� Incident FB Uve video: httP-= S :.u....,.=== Center,a_ Center, _ Primary Contact for both facilitiese- Clinic _,_ - - Front Office Supervisor - Chief Clinical Administrator -- 1st contact �P of Abort1on Access/Security - coo 1st contact -- Security Director - Gynecology, - Medical Clinic, _ GYN, _ - CEO/Owner/Physician -- Office Manager Non NAF Clinics *I can't be certain of the accuracy of the info below but this is what we have on record- *They didn't get in to this facility due to mask requirements but the comments above the post are concerning but not unusual for Beatty-Williams considering her history. Incident Videot- httP-s: fb.watch "Another clinic, Planned Parenthood will fall ! I Truly I say to you, whoever says to this mountain, 'Be taken u p and c;ast into the sea,' and does not doubt in his heart, but believes that what he says is going to happen, it will be granted him, Therefore I say to·you, all things for which you pray and ask, believe that you have received them, and they will be granted you." Mark 11:23-24 NASB1995 "From the days of John the Baptist until now the kingdom of heaven suffers violence, and violent men take it by force. Matthew 11:12 NASB1995" ..... VP Patient Services -Center -Center -Center Sent: Friday, July 1, 2022 2:39 PM To: Michelle Davidson �@prochoice.org> Subject: contact info. From : - � Special Agent­ CellDesk-- And please provide contact for- Medical Associates EXHIBIT 083 Bevelyn Will iams Rickey Williams & Bevel yn Williams Bevelyn Williams bei ng arrested fordefacing a Black Lives Matter mural in NYC AKAs: Bevelyn Zaki a Beatty, Bevlin, One of the "Ounamis sisters" DOB: Last Known Address: Previous Addresses: Phone Number Website: At the Well M inistries Social Media: Face bookTwitter: lnstagram: linkedln: Unknown YouTube: Wflliams married Rickey WIiiiams i�and has an infant She is close associates with • She is often accompanied by her husband and Edmee Chavannes when engaging in obstructive activities at clinics. Williams travels nationwide and globally with At the Well Ministries At the Well Ministries Operation Save America Williams writes blogposts about evangelizing and protesting abortion on The Well Diary. July 7th, 2022: Bevelyn and Rickey Williams along with Edme Chavennes entered three abortion facilities in Atlanta, GA consecutively, screaming at staff and causing the clinics to lock down. They live streamed the invasions and grabbed one staff member during one incident. They left each of the clinics before police arrived. Starting in January 2021, Bevelyn Williams, Rickey Williams, and Edme Chavennes traveled to different cities across the country as part of a n At the Well Min istries "Iron Sharpens Iton" tour. January 6th, 2021: Attended the U.S. Capital insurrection with February 9, 2021: New York Attorney General Letitia James brought a lawsuit against Williams and Chavannes to prevent them from entering a buffer zone around Center. Beatty allegedly made the following statement at the time of her arrest - "We are going to terrorize you so good that your business will be over, Mama. We are violently pursuing the kingdom of God. Violently pursuing.'1 January 29-30, 2021: Williams was a featured speaker at the Lubbock, TX March for Life. July 13 - 20, 2019: Williams went to OSA's 2019 national event in Milwaukee, WI and participated in protests downtown and outside of clinics. Williams unsuccessfully ran as a Republican for House District 97 in Maine in 2018. She withdrew her candidacy after Downtown M ilwaukee, Street Preaching withe: Bevefyn Beatty-. and marry others Two (Awesome) Black Gals Get -Charged with a Crime Eye on Augusta· Candidate for Belfast House Seat FacingAssault Charge "I want people to know I am not your typical innocent candidate. I have been arrested before, I have been homeless before, I was shot in the leg at 14 in North Carolina and also stabbed in my back literally at 16 years old by a group of girls that bullied me growing up in North Carolina. I come from a hard knock life and hard background. My mother was a single woman on drugs and diagnosed bipolar and my father was absent at times due to his life of crime and discord with my mother, and this subjected her to taking care of 5 children alone." - Beatty, quoted in Free Press article EXHIBIT 084 From: "Taskforce, Clinicviolence (CRT)" To:s" Subject: RE: Anti-Abortion Extremists On a Spree Date: Wed, 20 Jul 2022 16:00:20 -0400 lmportance: Normal Hi,-- Apologies for the delay responding. Let's have a call to discuss. I am available tomorrow morning at 10 am, and pretty flexible on Friday. Thanks, Sanjay humedco.com> From: Sent: Thursday, July 14, 2022 1:58 PM ; Michelle Davidson To: Taskforce, Cllnicviolence (CRT) �prochoice.org>;-@procholce.org;"-@procholce.org; Scozzafava, Chiko ._@ppfa.org>; Noah, Krista -@ppfa.org>; Peha, Richard �@ppfa.org>; · duVergne Gaines �@feminist.org>; -@northlandfamllyplanning.eom; -@northlandfamilyplanning.com; -@yahoo.com�awomanschoiceinc.com;-@awomanschoiceinc.com; -carafem.org-@outlook.com;"-@redriverwomensclinic.com;-@gmail.com; a.l@apwhc.com; -@wholewomanshealth.com;..-il@gmail.com; �affmedical.com; -@yahoo.com;"-@yahoo.com;-@yahoo.com; -@yahoo.com; @gmail.com; -@feministcenter.org; -@abortioncarenetwork.org; @thewomenscenters.com> Cc: Fitzgerald, Paige (CRT) (CRT) Hello, I am writing this email t o the broad group as I am deeply concerned about serial and nation-wide actions being conducted by ahti-abortion extremists. I cannot speak for all abortion providers on this list, but I do believe my concern will be echoed by many and I invite them to share. Last Thursday on 7/7/22, 3 separate abortion-providing offices i n Atlanta were aggressively invaded by 3 individuals: Bevelyn Beatty Williams, her husband Rickey Williams and Edmee Chavannes. Today they were buzzed into our security vestibule at 11111). Upon entry they were recognized and our office (which was caring for patients) had to go on lock-down. The invaders spent over 10 minutes yelling, threatening and telling patients approaching our front door that they would need to get thru them in order to get inside our center, they threatened to only leave under arrest. The Atlanta Police did not respond in time to take direct action and did not take a report. We called our district police and they came to our center but refosed to make a report because we "invited" the invaders in by buzzing the door and the invaders left on their on will. Allow me to note- we buzzed them into our security vestibule which was uniquely designed to protect our staff and patients from aggressive invaders. After leaving our center, Bevelyn, Rickey and Edmee went on to invade another abortion providing office In Atlanta with no police intervention. Since they were broadcasting their actions live on Facebook, we notified the Atlanta Police that the invaders were going to other offices. We falsely assumed they would cut them off- they did not. I contacted an excellent and pro-active Georgia based Special Agent of the FBI and received an appropriate response- a visit in person. I am dismayed it took our FBI to make this case a recorded experience for our traumatized staff and patients. In the wake of the "Roe leak" and the final opinion release on 6/24/22, abortion providers have experienced blockades (Michigan, New York), invasions (Georgia, Washington DC,) as well as daily protests. Of course some of us have also been subjected to the presence of the Proud Boys at rallies in Philadelphia and Boston. At previous protests of our center we endured hours of verbal abuse by Bevelyn and Edmee- they are infamous for hate speech and criminal activtties. 011 the evening of January st \ they publicly socialized with the Proud Boys in Washington DC and publicly bragged about their ability to bring the Proud Boys to our clinic for their security. We are scared. Can you help to stop these three habitually criminal extremists from coming on our properties? Can you tell me they are on your watch list as domesticterrorists? I need to continue to provide abortion .services in any state where we have offices for as long as we can and I will not submit to Bevelyn, Rickey or Edmee- but they seem very dedicated to doing whatever they like to disrupt our duty to care for patients who are already under intense pressure to find a safe and legal abortton. I intend on pursuing charges against these bad actors and 1 have compiled evidence of their FACE violations and brazen trespasses. --- Thank you in advance for your serious consideration of this message and for being available to me via the Task force. Sincerely, Vfce President for Abortion Access P'ronou1m she/hi::r/hc:rs �mail: CONFIDENTIALITY: Thfs email and any attachments may be confidential and/or privileged and are therefore protected against copy1ng, use, disclosure or distribution. If you are not !he Intended recipient, please notify us lmmedlately bv replylng to the sender and dollble delellng this copy arid the reply from yo11r sysrem. Than�s. EXHIBIT 085 From:s" To: Subject: Re: [EXTERNAL] WOHOOOOOO Date: Wed, 30 Aug 2023 09:06:28 -0400 Importance: Normal Thanks-! Sent from my iPhone On Aug 29, 2023, at 15:38, Thank you! Vice President for Abortion Access Pronouns: she/her wrote: EXHIBIT 086 From: "Morr is, Catherine (PAO)" To: "Gibson, Rose lCRT)" Subject: RE: DC FACE Trial Date: Tue, 29 Aug 2023 15 :3 l :20 -0400 Importance: Normal Attachments: 8.29.23_DC_FACE_Case_3.30_PM.docx Sounds good. Here's the latest draft, and we'll get this out shortly. Catherine Morris Special Assistant to the Director, Office of Public Affairs U,S. Department of J1.1stice (m)n- From: Gibson, Rose (CRT)n� Sent: Tuesday, August 29, 2023 3:31 PM To: Mortis, Catherine (PAO) Cc: Felte, James (CRT)n._,; Weiner, Robert (CRT) ; Bradford, Aryele (PAO) (CRT) �;nPatel,nSanjayn(CRT)n� Subject: Re: DC FACE Trial ; Moossy, Robert ; Hartnett, Julia (PAO) - I don't have a sentencing date. I'd just leave that blank for now. Rose Gibson On Aug 29, 2023, at 3:28 PM, Morris, Catherine (PAO) wrote: Thanks, Jim! I was just drafting an email about this one! Has a sentencing date been set? Catherine Morris Special Assistant to the Director, Office -0f Public Affairs U.S. Department of Justice (m) From: Felte, James (CRT)n._, Sent: Tuesday, August 29, 2023 3:28 PM To: Weiner, Robert (CRT) Cc: Bradford, Atyele (PAO) Hartnett, Julia (PAO) .; Moossy, Robert (CRT) ; Morris, Cathetlne (PAO) ; Gibson, Rose (CRT)n�; Patel, Sanjay (CRT) Subject: DC FACE Trial Team, The jury found all defendants guilty on all counts. Additlonally, the jury made the finding that ALL 5 defendants used force and physical obstruction and ALL 5 defendants were taken into custody. Well done, Sanjay! Jim EXHIBIT 087 From: MjcheUe Davidson �prochoice.org> To: "Patel, Sanjay (CRT)" Subject: [EXTERNAL] RE: Super Quick Question Date: Mon, 1 5 May 2023 1 0:57:43 -0400 Importance: Nonnal Thank you!! Thanks, Michelle From: Patel, Sanjay (CRT)"� Sent: Monda.y, May 15, 2023 10:56 AM To: Michelle Davidson �@prochoice.org> Subject: RE: Super Quick Question Sure ...thls should b e a complete list of all active/pending FACE cases: 1, US v, Handy et al (DC) 22-cr-96 2. US v. Gallagher et aJ (MDTN) 22-cr-327 3. US v, Zastrow et al (EDMI) 23-cr-20100 4. US v. Freestone et al (MDFL) 23-cr-25 *(CPt) 5. US v. Chamberlain (COCA) 22.-cr-36 6. US v. Vandebona (COCA) 23-cr-148 7. US V/, Barron (NDIL) 22-cr-500 8. US v. Green (DWY) (I don't have the case number) 9, US v. Dear (DCO) 19-cr-506 10. US v. Moscinski (EDNY) 22-cr-485 11, US v, Williams et al (SONY) 22-cr-684 From: Michelle Davidson �Qrochoke.org> Sent; Monday, May 15, 2023 10:34 AM To: Patel, Sanjay (.CRT)"� Subject: lEXTERNAL) Super Quick Question Hey Sanjay- do you have a list of acttve FACE charges (all"- including CPC's and churches)? Time sensitive! Thanks, Michelle EXHIBIT 088 From: "Patel, Sanjay (CRT)" To: "Michelle Davidson" �prochoice.org> Cc: "security'' �prochoice.org> Subject: RE: Terms of Release Date: Mon, 3 l Oct 2022 L4:5 J :06 -0400 Importance: Nonnal Attachments: E_Zastrow_conditions. pdf; Edl_conditions.pelf; Greeni _:-_modified_conditions.pdt; J_Zastrow_conditions.pdf; Place_conditions.pd[; C_Zastrow_-_modified_conditions.pdf fnli ne-Jmages: image005.png; image006.png; image007.png; image008.png Hey, Michelle Here's what I have. I'm hoping to connect with Amanda tomorrow. I'll see if she has the rest of them. Hope you're well, SP From: Michelle Davidson �@prochoice.org> Sent: Monday, October 31, 2022 2:21 PM To: Patel, Sanjay (CRT)._. Cc:- Subject: [EXTERNAL) Terms of Release Hey Sanjay ! Just following up to see if you could pass on the Terms of Release for the other OSA extremists (Gallagher, Cal, James, and Eva Zastrow, Edi, and Place) as well as the DC (PAAU) crew Terms of Release. 10/27/22 - Michigan Cal Zastrow is with 1t � Moms are arriving now to commit murder We are are here to offer hope and help, We are here to proclaim Jesus! Cal Zastrow 1d � It's a kill day here at the Saginaw surgical abortuary. As I offer help, preach the Gospel of Jesus Chdst, and intercede , would you please pray for saved souls and lives? 10/30/2022- ' Reformcon 2022" Mesa, AZ 1 ... X Reformcon 2022 was such an encouragement. Such a refreshing time to gather with saints in the battle from all over the country and rest in the Word, worship, and prayer. I took almost no pictures 1 but these pictures taken by my friends really captured a moment that will be very precious to me for a long time. Thanks be to God for the encouragement and communion of the body of Christ. Thanks be to God for brothers and sisters willing and faithful to labor to further the Kingdom of Heaven. Worthy is the Lamb! 10/31/2022 < Progressive Anti-Abortion Upri ... Last night, days before the Michigan election1 PAAU activists dropped a large banner that read "NO PROP 3• during tne 1nfamous football game between the Universrry of Michigan and Michigan State University at Michigan Stadium. This action was in response to the extreme and dangerous nature of the consti1utional amendment that Michigan will b� voting on next Tuesday. If passed, this amendment would alter the Michigan state constitution to expand abottion to all 9 months of pregnancy, allow non-doctors to perform abortions, remove parental consent laws, and remo¥e 25 healrh and safety standards from abortion businesses, forever -Michelle EXHIBIT 089 From: "Klopf, Amanda (USATNM)" � To: du Vergne Gaines �feminist.erg> Cc: Michelle Davidson aprochoice.org>, "Ramnane , Nikhil , "Patel. Sanjay (CRT)" Subject: RE: Indictment copy Date: Tue. 1 1 Oct 2022 1 7 :43:22 -0400 Importance: Nom1al Attachments: Vaughn_conditions.pdf; Davis_condjtions.pdf� Boyd_conditions.pdf; ldoni_conditions.pdf; Green_conditions.pd f IoJine-lmages: image0Ol .png Please see the attached. When Zastrow and Gallagher's are entered, I'll circulate them From: duVergne Gaines �feminist,org> Sent: Monday, October 10, 2022 7:52 PM To: Klopf, Amanda (USATNM) � Cc: Michelle Davidson �@prochoice.org> Subject: [EXTERNAL) Re: Indictment copy Dear Amanda We would greatly appreciate it if you are able to share publicly filed Terms of Pre-trial Release for all indicted defendants re. Case No. 3:22-00327. Many thanks. duVergne. du Vergne Gaines, JD Director, National Clinic Access Project Feminist Ma·o1i Foundation 0: C: 8: Tbc information cootninc,d ill trus olectroolc mcssnge and nuy attached Jocumca1s are privileged, canlidcntial aod protected from disclosure, and tlic informal-ion may not neceSsarily eiu11d::ttion, I f you are not the intended recipie1it. 11ote that any review. di�dosure, copying_. or dissemination ef this message or-0ny attachments is strictly prohibited. I f you think th-.ll you have rect'ii{ed this message in �rror, please destroy it And notify the sender. From: Klopf, Amanda (USATNM) Sent: Wednesday, October S, 2022 4:58 PM To: duVergne Gaihes; Michelle Davidson Cc: Patel, Sanjay (CRT); Ramnaney, Nikhil (CRT) Subject: I ndictment copy duVergne and Michelle, FYI, attached is a copy of tbe indictment that was Lmsealed today in US v. Gallagher. If you bave any questions, please let us know. Amanda Amanda J. Klopf Assistant United States Attorney Civil Rights Cvm•dinatcn· Computer lTacking and fntellectu<,l Pl·operly Allorney Middle District ofTennessee U.S. Attorney's Office I T: eMa.il1 EXHIBIT 090 From: "NAF Security Department" To: usdoj.gov Subject: [EXTERNAL] Security Alert: Terms of Release for Antis in TN, MJ, GA, VA, DC, MS Date: Thu, 13 Oct 2022 09:02:01 -0400 Importance: Normal PMembership ·-· Security U pdate NAF Member Security Alert: Anti-Abortion Extremists Indicted by Tennessee Grand Jury Update: Terms of Release October 13, 2022 Last week, we shared information about recent investigations and charges against 1 1 anti­ abortion extremists for violating the Freedo m ofAccess to Clinic Entrances(FACE) Act. Those individuals were detained and most of them were released this week subject to the conditions below. If convicted, the 1 1 individuals (Chester "Chet" Gallagher, Heather ldoni, Calvin Zastrow, Coleman Boyd, Caroline Davis, Paul Vaughn, Dennis Green, Eva Edi, Eva Zastrow, James Zastrow, and Paul Place) could each face up to 10 years in prison and significant fines for violating the FACE Act. Many federal conspiracy charges carry a five- to 20-year minimum sentencen. These defendants must not violate federal, state, or local laws while on release. Violating any of the conditions of release may result in the Immediate issuance of a warrant for arrest, revocation of release, an order of detention, forfeiture of any bond, and a prosecution for contempt of court and could result In imprisonment, a fine, or both. Chester ''Chet" Gallagher remains in custody at this time. The following individuals were released from detention with the following terms: Paul Vaughn • Prohibited from traveling outside the Middle District of Tennessee unless approved in PaulV advance by pretrial services, except for work and notification in advance is required. • Vaughn must avoid all contact. directly or indi�ectly, with any person who is or may be a victim or witness in the investigation or prosecution. • Prohibited from entering any building or the curtilage of any building in which a reproductive hean lnth services facility is located or be within 20 feet of such a building without Heather ldoni, Heather prior approval of pretrial services. • Prohibited from traveling outs'lde the Middle District of Tennessee, Eastern District of Michigan , and the District of Columbia solely for the purposes of court hearings unless approved in advance by pretrial services. • Must avoid all contact. directly or indirectly, with any person who is or may be a victim or witness in the investigation or prosecut[on as well as c0defendants. • Prohibited from entering any building that contains a facility that provioes reproductive health services, the curtilage of such a building, or being within 20 feet of such a building unless she is seeking her own personal medical needs and without prior approval of the pretrial services department. • Not possess a firearm, destructive device, or o1her dangerous weapons ahd remove all Caroline Davis l.,j CarolineD described Intems from residence. • Prohibited from traveling outside the Middle District of Tennessee and Michigan solely for court hearings and for attorney-client Defendant Is also restricted to the Northern District of Georgia unless the supervising meetings regarding pending criminal cases. officer has approved travel in advance. Defendant must provide advance notice to ·n her pretrial services officer before traveling to Michigan or Tennessee. • Must avoid all contact, directly or indirectly, with any person who 1s or may be a victim or witness in the investigation or prosecution as well as codefendants. • Defendant is directed to stay at least 100 feet from any cllnic providing family planning services. .unless she has permission from her pretrial services officer. • Not purchase, possess, or acquire a firearm, destructive device, or other dangerous weapon. Dennis Green DennisG Coleman Boyd � ColemanB • Remain in the Western District of Virginia and not travel outside of the Western District of Virginia except for meeting with his attorney or court appearances approved in the Middle District of Tennessee and as approved by ptetrial services. • Green is prohibited from entering any building that contains a facility that provides reproductive health services, the curtilage of such a bullding, or being within 50 feet of such a butlding. • Boyd must remain in the state of Mississippi at all times during the pendency of these proceedings unless special permission is obtained from the Court and to travel to Nashville, TN to attend Court proceedings. • Boyd is prohibited from entering any building that contains a facility that provides reproductive health services, the curtilage of such a building, or being within 20 feet of such a building. We will provide details on the Conditions of Release for Chester "Chet' Gallagher, Calvin �cal" Zastrow. Eva Zastrow. James Zastrow, Eva Edi. and Paul Place as soon as they are available. If you see any of these individuals outside your facility or witness any violations of the terms of release listed above, contact law enforcement and any member of the NAF Security Team immediately. Please report any suspicious activity to law enforcement and NAF Security immediately. Please contact�grochoice.org members of the Security Team directly with questions about this alert. submitting incidentrep�, or any other security concerns: Michelle Davidson, Security Director: �prochoice.org; Robert Ledogar, Southeast Security Manager: �prochoice.org; Eduardo Serrano, Intelligence Analyst: �prochoice.org; Michelle and Robert are available by phone, 24 hours a day, to assist you with any security incidents, threats, or emergencies. Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, disclosure. or distribution is prohibited. If you have received this e-mail 1n error, pe l ease immediately notify the sender by e-mail at the address shown. Please delete it from your files if you are not the intended recipient. Thank you for your compliance. !;� Facebook � YouTube � ■■■■ Copyright© 2022 Nat,onal Abottion federation, All rights reserved You are receiving these emails because you are either a NAF member or subscribed v,a our website You can update your email preferences at any time by contacting ID.P.rochoice.org. EXHIBIT 091 From: "Sanja�" To: Laura-Kate Bernstein Subject: Fwd: [EXTERNAL] Eva Zastrow - Potential Sentencing Violation Date: Thu, 29 Aug 2024 1 7 : 1 9:49 -0400 Importance: Nonnal Attachments: 1 69 1 5865986.pdf; image.pug lnUne-Images: Outlook-eexxJ f5c.png Sent from my iPhone Begin forwarded message: From: Michelle Davidson �prochoice.org> Date: Au ust 29, 2024 at 15: 1 3 :50 EDT ME) (FBI)"t<_....., "Klopf, Amanda USATNM)'' To: '' Cc: securi.ty prochoice.org>, "Patel, Sanjay (CRT)" Subject: I EXTERNAL] Eva Zastrow - Potential Sentencing Violation Hi Amanda and Mark, We received intel that Eva and Cal Zastrow were protesting outside a NAF member facility in Flint, Ml today. Would this be a violation of her house arrest? Let me know if there is anyone else I should send this i·nfo to. Would you be able to provide details on when Cal will report for his 6 month sentence? Thanks for any assistance you can provide. Please don't hesitate to reach out if you need anything at all. I hope you both are doing well! -Michelle Michelle Davidson Director, Security Pronouns: Any (no preference) l\l' fost Michdle 1111, 111H' ,1 ,,,,, ,l1"'1i1, , to, '(''' 111\•1.1"�' " , "Don't' ever let them steal your joy" - Brandi Car/fie I respect that your working hours may be differentfrom mine and I support your healthy work/life boundaries. Only respond when you have the time and capacity. Confidentiality Notice: This e-mail message, including any altachmcnls, is for the sole use of the intended recipient, and may contain confidential and privileged infom1ation. Any unau1horized review, use, disclosure, or distribution is prohibited. If you have received this e-mail in enor, please immediate.Jy notify ihe sender by e-mail at tJ1e address shown. Please delete it from your files ifyou are nol the intended recipient. Thank you for your compliance. T 0 A I S O R T O N F E D E RAT I O N EXHIBIT 092 From: "Patel, Sanjay (CRT)"s� To: "Christopher Keefe" (USADC)" Subject: RE: Possible Violation of Release Terms, Lauren Handy Date: Fri, 12 May 2023 16:58:35 -0400 Importance: Normal Inline-lmages: image0O 1.jpg (WF) (FBI)" �. "Aloi, Elizabeth Thanks-and­ Adding- to this thread. We should discuss the Handy event. Is everyone available Monday for a team call? SP From: Christopher Keefe Sent: Friday, May 12, 2023 3:24 PM To: (WF) (FBI) ■■■■■■ ; Aloi, Elizabeth (USAOC) �; Patel, Sanjay (CRT) Subject: Re: Possible Violatiion of Release Terms, Lauren Handy Also following up on trial subpoenas, was located and served today. She was nervous about her role at trial but willing to cooperate about Molly Gaston but I'm sure we can make her feel as comfortable as possible through the trials. which bodes well. She was asking ii More to follow for travel and prep but at least we know where she is and have a good contact for her as we move forward. Talk soon, C From: (WF) (FBI) Sent: Friday, May 12, 2023 3:18:53 PM To: Aloi, Eli zabeth (USA0C) > ; Patel, Sanjay (CRT)i�; Subject: Re: Possible Violation of Release Terms, Lauren Handy (WF) (FBI) Hi Liz & Sanjay, Apologies for the brevity of my previous email, as I forwarded it from a marathon sentencing hearing. - Just wanted to get your thoughts on this and whether o r not it would constitute a violation of Handy's probation. Thanks! SA FBI I WFO I CR-10 (DC Public Corruption & Civil Rights) C: 0: From: (WF) (FBI) Sent: Thursday, May 11, 2023 2:53:26 PM To: Aloi, Elizabeth (USA0C) �; Patel, Sanjay (CRT)i �; Subject: Fwd: Possible Violation of Release Terms, Lauren Handy FYSA SA FBI I WFO I CR-10 (DC Public Corruption & Civil Rights) C: 0 From: (CID) (FBI)i� Sent: Thursday, May 11, 2023 2:50:08 PM (WF) (FBI) To: ■■■■■■ (WF) (FBI) Cc: _____ (WF)(FBI).-. Subject: Fwd: Possible Violation of Release Terms, Lauren Handy Forwardi.ngfor awareness in case this rnay be a violation of Handy's releas.e conditions as alleged below. Hope you all are settled into the new space in SW! Supervisory Special Agent FBIHQ- Civil l\ights Unit via mobile device From: Eduardo Serran o • @grochoice,org> Sent: Thursday, Ma.y 11, 2023, 1:57 PM To: Patel, Sanjay (CRT) ; Fitzgerald, Paige (CRT)i< Cc: s.ecurity • @.i:rochoice.org> i Subject: [EXTERNAL EMAIL] - Possible Violatron of Release Terms, Lauren Handy Hello all, i Attached is a post made by Lauren Handy, Director of acti vism for the Progressive Anti- Abort on Uprlsing (PAALl), announcing that she wfll be leading a training on anti-abortion activity. The event is virtual and is scheduled to take place May 18 from 7-9prn ET. Here is some language created by PAAU about the event. "Are you nervous to go sidewalk counseling inyour city? Do you feel like you oren't making a difference, ar you don't know what to say? PAAU is paving the way with a new approach to sidewalk counseling that is changing the narrative an what it means to defend your community from the Violence of the abortion [ndustry YOU need to defend the people around you from this violence, and we are ready to give you the tools to do so. Come and /earn.how you can defend your community through sidewalk counseling, You'll learn practical tactics, important theory, and hear stories from PAAU stafffrom the sidewalk. You will also have the chance to ask questions and get live answers from act£vists at PAAU who have saved hundreds of babies outside abortion businesses. This is the first edition of our new series "Progressive Prolife 101 ". Join us at 7pm EST an Thursday, May 18th on YouTube Live!! Link in bio: We wanted to make sure you are all aware of this if it is indeed a violation of her terms of release. From what we have seen historlcally these seminars/trainings will typically include talks about future direct actions. I will continue to monitonhe event and provide any relevant updates, 1hank you all for your work and contii"lued efforts, Respectfully, Eduardo Serrano Intelligence Analyst pronouns (He/Him) .... ConfitJenUallty Notice: This 1;1-malf message, including any att<1chments, is for the sole use ofthe tntended recipient, and may contain confidential and pn'vlleged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this e-mail in error, please immed{ate/y notffy the sender by e-mail at the address shown. Please delete It from your fifes If you are not the intended recipient. Thank you for your compliance. EXHIBIT 093 'From: "Patel, Sanjay (CRT)" To: "Moossy, Robert (CRD" Subject: RE: National Abortion Federation Conference Date: Fti, 12 May 2023 18: LO: l 7 -0400 Jmportance: Norma] Correct - it was not copied or distributed. From: Moossy, Robert (CRT) Sent: Friday, May 12, 2023 5:37 PM To: Patel, Sanjay (CRT)"� Cc: Felte, James (CRT)".-,; Weiner, Robert (CRT) Subject: RE: National Abortion Federation Conference Thanks, and this was just shown, not copied and distributed, right? From: Patel, Sanjay (CRT)"� Sent: Friday, May 12, 2023 5:16 PM To: Moossy, Robert (CRT) Cc: Felte, James (CRT)".-,; Weiner, Robert (CRT) Subject: RE: National Abortion Federation Conference Sorry -forgot to attach it. From: Moossy, Robert (CRT) Seht: Friday, May 12, 2023 5:14 PM To: Patel, Sanjay (CRT)"� Cc: Felte, James (CRT)".-,; Weiner, Robert (CRT) Subject: RE: National Abortion Federation Conference Thank, do you have a powerpoint or other visuals you used for your remarks to the group? From: Patel, Sanjay (CRT)"� Sent: Friday, May 12, 2023 5:12 PM To: Moossy, Robert (CRT) Cc: Felte, James (CRT)".-,; Weiner, Robert (CRT) Subject: RE: National Abortion Federation Conference Robert Below is some related information (including a link to NAF stats) concerning the uptick of targeted attacks against clinics, and a short blurb related to last week's NAF conference . Happy to jump on a call if you have any questions. SP Abortion clinics saw an increase in violence and th reats in 2022, report says By Janue Gumbrecht, CNN Published 9:12 AM EDT, Thu May 11, 2023 CNN looks at the latest polling on hbW Americ.a ns see abortion rights O'I ·', 1 So11 , i; CNN CNNnA new report says there was a "sharp increase" in violence at abortion clinics i n 2022, the year when Roe v. Wade was overturned, ending the federal right to an abortion. A disproportionate increase occurred i n states that protect abortion rights, according to the National Abortion Federation, a professional association for abortion providers. In Its annual reRort on violence, the federation says there were tnore major incidents at abortion clinics, including arson, burglaries, death threats and invasions last year than in 202 1 . There were decreases in trespassing and assault and battery, which the federation attributes to clinic closures. There were 32,000 fewer legal abortions in the lJS in the si>c months after the Dobbs decision, new analysis suggests There were four cases of arson in 2022 - in Bakersfield, California, in March; Casger, .JYy,oming, i n May; Kalamazoo, Michigan, in July; and Las Vegas in December - an increase from two in 2021. Tile report says there were 2 1 8 reports of deaths threats or threats of harm, an i ncrease from 1 82 i n 2021 and 57 i n 2018. In 2022, reports of stalking providers and patients grew to 92 from 28 in 202 1 , and reported burglari�s grew to 43 from 1 3. For the first time since 201 1 , facilities reported receiving suspicious letters containing a white powdery substance. The 'federation says it has tracked violence and disruption at reproductive health facilities since 1977. It collects monthly reports from facilities - 80% reported data for the new report - and follows up to coHect complete reports. Some closed clinics weren't able to report data in 2022 and others reported for only part of the year. The 2022 report includes data from the US, Canada and Colombia, while 2021 data also includes Mexico City. The federation says it does not include incidents ihat can't be validated, "which suggests that actual incidents are higher than reported." httgs://www.cnn.com/2023/0S/11/health/abort1on-d1n1c-violence-regort/index.html Link to annual report: hll�Lwocho1ce.or NAF CONFERENCE: NAF held its annual conference in Denver May 1-5. I was invited to speak about our FACE enforcement efforts. The conference had 1000+ registered attendees. Our FACE segment was well attended...we had over 150 providers in the audience. NAF budgeted 1.5 hours for the presentation, but we could have easily filled 2+ hours with the audience participation/questions. The presentation was well received. I was thanked for our FACE work by a long line of folks after the presentation. The big takeaway - many providers are scared with the Doobs annivetsary fast approaching; and they are fr1;1strated that we are using FACE to protect "fake clinics." There were many other providers who fired back during some cross-audience debating, recognizing that if we don't enforce the statute even-handedly, we will likely lose it. Overall, our participation and my experience was positive. From: Moossy, Robert (CRT) Sent: Friday, May 12, 2023 4:43 PM To: Patel, Sanjay (CRT)o� Cc: Felte, James (CRT)�; Weiner, Robert (CRT). Subject: FW: National Abortion Federation Conference Sanjay, Have anything? They are preparing remarks for Vanita, so were wondering what you had for the NAF conference. No need to create anything. From: Sooknanan, Sparkle (OASG) Sent: Friday, May 12, 2.023o11:18 AM To: Moossy, Robert (CRT) Subject: National Abortfon Federation Conference Are there any materials that Sanjay used for his presentation that you can share? Also fyi: ReP-ort: "Sharpincrease'' ln crimes against abortion clinics gost-Roe (axios.com) EXHIBIT 094 From: "Patel, Sanjay (CRT)" To: "Michelle Davidson" �prochoice;org> Subject: RE: Status Hearing Rescheduled"- Investigative Case Case 23-CR-20 l 00 Date: Wed. ] 9 Apr 2023 l l :5 J : ] 5 -0400 Importance: Normal - Court Hey, I'm pretty sure the. continuance was to accommodate the attorheys' schedules, and to provide sufficient time before trial to litigate pretrial issues the defendants may raise. The part regarding pleas might be standardized language in all letters. I'll check with the prosecutors about that. From: Michelle Davidson �@prochoice.org> Sent Wednesday, April 19, 2023"11:38 AM To: Patel, Sanjay (CRT)"� Subject: [EXTERNAL) -Status Hearing Rescheduled - Investigative Case 20100 - Court Cas·e 23-CR- Hey Sanjay, duVergne has probably asked you about this but just in case she hasn't and the chance that you may have sotne insight that you can share as to why, just thought I'd ask. - as you know, does not like ominous situations and reached out for my help/insight which I don't have much currently. It seems like they may plead? If I know- she Will not want to accept one but also listens for advice. Below is the letter she. received yesterday. -MD From: U.S. Department of Justice� VNS � Date: Tue, Apr 18, 2023 at 12:14 PM Subject: U.S. Department of Justice - VNS - Investigative Case To: DO NOT REPLY TO THIS EMAIL. l Jlogo - Court Case 23-CR-20100 - U.S. Department of Justice Eastern District of Michigan April 18, 2023 Re: United States v. Defendant(s) Chester Gallagher, Eva Edi, Justin Phillips, Joel curry, Eva Zastrow, Calvin Zastrow Case Number - and Court Docket Number 23-CR-20100 The enclosed rnformatlon is provided by the Untted States Departmen1 of Justice Victim Notification system (VNS), As a vfctim witness professional, my role is to assist you With informatfon and services during the prosecution of this case. I am contacting you because you were identified by law enforcement as a victim or potential victim during the investigation of the above criminal case. The status hearing previously scheduled for defendant(s) Eva Edi, - Chester Gallagher, Calvin Zastrow, Eva Zastrow, Joel Curry, Justin Phillips on May 16, 2023, 02:00 PM at Cou.rtroom 207, 231 West Lafayette Blvd., Detroit, Ml 48226 has been rescheduled by the court. VNS will continue to provide you with updated case scheduling and event Information. A status hearing is scheduled before Judge Matthew Leitman for July 17, 2023, 02:00 PM at Courtroom 207, 231 West Lafayette Blvd., Detroit, Ml 48226 for defendant(s) Eva Edi, - Chester Gallagher, Calvih Zastrow, Eva Zastrow, Joel Curry, Justin Phillips. The purpose of this hearing is to determine if there are issues that the Court needs to address and to schedule any necessary future court dates. The trial previously scheduled for defendant(s) Eva Edi, - Chester Galfagher, Calvlh Zastrow, Eva Zastrow, Joel curry, Justin Phlllips on May 30, 2023, 09:00 AM at Courtroom 207, 231 West Lafayette Blvd., Detroit, Ml 48226 has been rescheduled by the court. VNS will continue to provide you with updated case scheduling ahd event Information. A trial is scheduled before Judge Matthew Leitman on August 1,. 2023, 09:00 AM at Courtroom 207, 231 West Lafayette Blvd., Detroit, Ml 48226 for the case which involves defendant(s) Eva Edi,_ Chester Gallagher, Calvin Zastrow, Eva Zastrow, Joel Curry, Justin Phillips. Please be aware that many criminal cases are resolved by a plea agreement between the United States Attorney's Office and the defendant. You should also know that it is not unusual for a defendant to seek to negotiate a plea agreement shortly before a trial is scheduled to begin. Plea agreements can be made at any time and as late as the moming of trial, leaving little or no opportunity to provide notice to you of the date and time of the plea hearing. If the court schedules a plea hearing in this case, we will use our best efforts to notify you of available information as soon as practicable. If you want to inform the prosecutor of your views regarding potential plea agreements1 or any other aspect of the case, please contact the prosecutor assigned to this. case or me. Unless you have received a subpoena to attend as a wi"tness in this matter, your attendahce is not required. Becc1use of the Court's schedule, hearing dates could change on very short notice. If you plan on attending, you may want to call the VNS Call Center or check the web site to confirm the date and time. Because of the Court's schedule, hearing dates could change on very short notice. If you plan on attending, you may want Please note, there is a 24-hour delay in to call the VNS Call Center or check the website to confirm the date and t"me. i information transfer to the website, Through the Victim Notification System (VNS) we will continue to provide you with updated scheduling and event information as the case proceeds through the criminal Justice system. You may obtain current Information about this case on the VNS website at.!}!j;Qs://www,noti[Y..usdoJ,gov or from the VNS Call Center <1t ( (TDD/TTY: (International: . In addition, you rnay use ttre Calf Center or Internet to update your contact information and/or change your decision about participation in the notification program . You will use your Victim Identification- Number (VIN) - and Personal Identification Number (PIN) - anytime you contact the Call Center and the first time you log into VNS on the website. If you are receiving notifications with multiple victim ID/PIN codes please contact the VNS Call Center. In addition, the first time you access the YNS website, you will be prompted to enter your last name (or business name) as currently contained in VNS. The name you sh0uld enter is Remember, VNS is an automated system arid cannot answer questions. If you have other questions which involve this matter, please contact this office at the nu,nber listed above. Slncerely, Sherri Holloway Victim Witness Specialist If you do not want to receive email notifications from the Victim Notification System (VNS) please log into the VNS Web site at httP-s://www.notifv..usdoj,gov, select "My Information 11, remove your email address and click the " update" button. If you remove your email address, you will continue to receive letters from VNS except in those case which have large numbers of victims. To change your email address, select ''My Information", provide a new address and click the "update" button. If you do not want to receive any notifications in your case, select "Stop Receiving Notifications" and follow the instructions on the screen. If you believe you have received this email in error; please contact the office listed at top of the email message. Please note, if this is the first notification you have received from VNS you will need to wait 4�8 hours from receipt of this email before you cao login to the VNS Internet site (httRs://www.notify.usdoj,gov). In addition, it will also be 4-8 hours before any documents which may have been uploaded to VNS as part of this notification are available under the "Downloads/Links" section on the Web page. Please call the Victim Notification System (VNS) Help Desk at phone number for assistance and questions. EXHIBIT 095 From: Michelle Davidson To: "Patel, Sanjay (CRD" Subject: [EX.TERN AL] RE: questions for TF Date: Mon, 29 Nov 2021 1 7:25;49 -0500 Importance: Normal I know-from Is going to ask about the blockade at her clinic in 2020 as well as_ and his AR-15, standing on a laddet, yelling ''you deserve to die" outside her clinic at staff and patients­ scaring them. She may also ask about how protesters will surround a car pulling into the driveway of the clinics forcing the driver to stop. There may be questions on the injunction against Bevelyn Beatty in NY getting overturned. !'II let you know If I come across any others between now and then. Thanks for adding-to the attendee fist. - Exec Director, (Detroit, Atlanta) From: Patel, Sanjay (CRT)"� Sent: Monday, November 29, 2021 1:43 PM To: Michelle Davidson Subject: questions forTF Hey, Michelle Thanks for the call today. I'm putting together a list of q's to discuss with Paige that I can expect to receive at the meeting. Here's what I got from our call today: l, Can DOJ bring FACE charges (crim or civ) related to RRR clinic invasions where the subjects do not actively block entrances and exits, but still force the clinic to shut down be of the disturbance caused? (i.e. charge 011 a theory of "constructive phys obstruction"?) 2. If FACE language does not allow #1 (above), then can you do something to change or amend the language of the statute to deal with RRR styled conduct? 3. Can DOJ support or advocate for amendments to the proposed Peace Act to include funding to support seQ.lrity for reproductive health care clinics? See httP-s:l/www.congress.gov/b1ll/117th-congress/senate -bill/2682/text? r=-62&s=l Did I frame the questions correctly? Are there anv other questions you're aware of? EXHIBIT 096 'From: Michelle Davidson �ptochoice.org> To: "Patel, Sanjay (CRT)" Subject: [EXTERNAL] RE: looking for a resource Date: Tue, 09 Nov 2021 1 8:54:57 -0500 Importance: N01mal Okay, getting a list together for you. Is it okay If I connect you via email intro so they aren't confused? Do you have a quick description of the goal of the meeting I can use then you can follow up with your big Invite? Here's my list so far: Providers that have experienced significant incidents of targeted anti-choice harassment/FACE violations: - Blockades, Bomb Threats, Saginaw, M l and Flint, Ml - Blockades, Invasions Funders/Donors: The Lisa and Douglas Goldman Fund is the main funder of our Security work. We could invite our Program Officer. There is a large anonymous foundation who is the largest funder in our movement and we could invite a Program Officer from there. I'm assuming your inviting PPFA (Krista, Chiko, and Rich) as well as duVergne at FMF, right? I'm still wracking my brain but this should be a very talkative group. I'll be there for sure. Let me know what you think of the list and I'll get it rolling! From: Patel, Sanjay (CRT)"� Sent: Tuesday, November 9, 2021"1:46 PM To: Michelle Davidson -.illll@prochoice.org> Subject: RE: looking for a resource I'd like to include the larger organizations that cover most of the clinics nationwide, and those who specifically serve the clinics that have been targeted over the past year. Particularfy those who have somethihg they want to share/ask/address with the task force (and AAG). As for the funding organizations, yes, the larger ones that provide the majority offunding nationwide. I'm trying to keep the group a manageable size so that everyone will have time to speak and share thoughts / concerns. Sorry for the confusion. SP From: Michelle Davidson �wochoice.org> Sent: Tuesday, November 9, 2021e1:34 PM To: Patel, Sanjay (CRT)e� Subj�ct: [EXTERNAL] RE: looking for a resource Hey Sanjay, Can you help me narrow it down a little? Are we talking about key providers that have experienced incidents recently? There are a lot of orgs across the country that provide funding - almost every state has one. Are you looking for large orgs that provide funding like we do? From: Patel, Sanjay (CRT)e� Sent: Tuesday, November 9, 2021e12:27 PM To: Michelle Davidson �P-rochoice.org> Subject: RE: looking for a resource Hey, Michelle Following up on this request. Any chance you might have a list of folks for me this week? Also, can you include in that list organizations that provide access funding? Should I reach out to duVergne as well? From: Michelle Davidson �P-rochoice.org> Sent: Wednesday, October 27, 2021 5:02 PM To: Patel, Sanjay (CRT)e� Subject: [EXTERNAL] RE: looking for a resource Hey Sanjay, I'm not sure who all was on the call with the AAG since I had to miss it. Do you have a list you can share and then I can add to it? If not, it might take me until Monday to get something to you. Sorry fpr the delay! From: Patel, Sanjay (CRT)e� Sent: Friday, October 22, 2021e11:51 AM To: Michelle Davidson �P-rochoice.org> Subject: looking for a resource Happy Friday, Michelle I'm planning the joint Task Force/stakeholders meeting. And, I need to figure out the universe of attendees to invite. Do you have a list of organizations that provide some service to patients/providers whom I should Tndude? I know that there were several organizations like Afiya that particfpated In the last meeting with the AAG. If you have a resource (a list) of the big ticket organizations and suggestions as to whom I should invite to the meeting, can you share? Thanks! SP EXHIBIT 097 From: "Patel, Sanjay (CRT)" < To: "Fitzgerald, Paige (CRT)" < Subject: draft agenda for 12-1 TF meeting with NGOs Date: Fri, 26 Nov 2021 11:35:00 -0500 Importance: Normal Attachments: Agenda_12-1-21_meeting_w-NGOs.docx > > Hi, Paige – Hope you had a great Turkey Day with your family. Attached is a draft agenda for next week’s meeting. After you have reviewed it, I’d like to circulate the agenda to the TF by Monday. FBI wants a quick call before the meeting to discuss the agenda, and how to handle questions. And, heads-up that Mississippi v. Jackson Women’s Health is set for SCt oral argument on 12-1. Thanks, SP EXHIBIT 098 Task Force on Violence Against Reproductive Health Care Providers Agenda for first meeting *Mississippi v. Jackson’s Women’s Health is set for oral argument before SCt today (Dec 1). Issue is whether MS 15-month prohibition on abortions is unconstitutional Anticipated NGO participant list: • • • • • • • • • • • • National Abortion Federation Planned Parenthood Feminist Majority Foundation clinic (Detroit area clinics) Center (Saginaw and Flint (Michigan) clinics) Center (east coast clinics, including NJ (Cherry Hill) and Philadelphia) (North Carolina and Florida clinics) (clinics in Atlanta, Chicago, Nashville, and DC) Center (Fargo) Center (Cleveland) Center (Charlotte and Georgia area clinics) Whole Women’s Health ( – plaintiff from TX SB8 civil suit pending with SCt) Introductions: • Sanjay to introduce the member agencies. Each agency designee provides quick selfintro as well as others from their agency in meeting o CRT – Sanjay o NSD – o FBI – o ATF – o USMS – o USPIS – o Missing member agencies – Sanjay Agenda: • Welcome and purpose behind inclusive meeting with NGOs • TF mission: o Coordinate national investigation and pros efforts into all matters involving acts of violence and other unlawful conduct directed against health care providers, patients and facilities that provide reproductive health care services, especially those implicating FACE • Quick take on FACE: o Two provisions of primary concerns: ▪ 248(a)(1) - incidents of force/threat/phys obstr ▪ 248(a)(3) – intentional damage or destruction of facility ppty • • • • • • • • TF, in consultation with local U.S. Attorneys, will assess matters in an effort to make early and coordinated decisions regarding whether to proceed federally (crim or civ) on an incident Difference bw crim and civ o SPL – Laura to discuss briefly the difference bw civil and crim; and available remedies. Quick-take on U.S. v. Rusty Thomas, et al (WDKY)? Efforts to reach all incidents presents challenges Outreach important o Manner – use your contacts (NGOs have direct line to TF; FBI – we are coordinating outreach efforts) o Timing – investigative importance o Reaction – follow protocols encouraged by your security consultants to record, document, and notify ▪ Take moment to praise NAF and PPFA security TF has been and will continue to provide law enforcement training aimed at appropriate local response One-offs v. organized efforts – unaffiliated actors v. planned and organized. The coordinated actors are savvy and well know how to skirt federal laws like FACE Although we cannot discuss on-going investigations and prosecutions, we hope that improved communication and coordination will result in more cases being prosecuted (crim and civ), which will have a deterrent effect Security assessment requests – USMS Questions: • • • Open floor for NGO/provider questions-talking points o Any ideas to improve flow of information? o We cannot speak for local LEO response but will conduct outreach and training to help shape the response o Many USAOs have dedicated prosecutors to handle clinic violence incidents. It all starts with notifying TF Things providers can do to: o Document – Δs statements with specificity o Capture or save digital evidence (i.e. emails, recorded telephone calls/VMs, mail/letters – minimize the number of hands) o Additional tips from FBI, USPIS? Sanjay will handle all questions related to on-going / active matters EXHIBIT 099 From: "Patel, Sanjay (CRT)" To: "duVergne Gaines" Cc: '�prochoice.org" �prochoice.org> Subject: RE: Question re. Mt. Juliet Local Cou.rt Case Date:Thu, 03 Feb 2022 20:43:46 -0500 Jmportance: No1mal That's an excellent point. I'll relay the thought. Thanks, and be safe. SP From: duVergne Gaineso� Sent: Thursday, February 3, 2022 7:12 PM To: Patel, Sanjay (CRT)o� Cc-@prochoice.org Subject: (EXTERNAL] Re: Question re. Mt. Juliet Local Court Case Sanjayt. Thanks so much for the effort, Sanjay. It's good to know the judge is trying to mitigate the circus for all. Let's hope the mies do indeed apply to all. I'm attaching some updated OSA materials for you. Bobby and 1 were talking today, and Bobby made the tenific point that the local DA should really ask for a stay and/or they plead guilty or are found away order to be entered against the Defendants if their case is conttnued i guilty given a) their arrests last week for another blockade in ft. Meyers, and b) their return this week to intimidate and target Carafem with protests. Any chance this request might be made to the DA's office via the AUSA? Thanks so much again. duVergne duVergne Gait1es, JD Director, National CljtJic Access Project Feminist Ma·ori. Foundation 0: C: E: The infonnacion contained in this electronic message and any attached documenlS are privileged, confidential and protected from disclosnte, and the infonnation may not riece�sarily express the opinion of Feintni.st Mitjority Foundation. lf you are not U1e i.ntended recipient, note that any review, disclosure, copying, or dissemination of this message or any attachments is strictly prohibited. Jfyou think tllar you have received this message lo enor, please destroy it arid notify the sender. Sent: Thursday, February 3, 2022 6:53 PM To: duVergne Gaines Subject: RE: Question re. Mt. Juliet Local Court Case From; Patel, Sahjay (CRT)n._, Hi duVergne and BobbytMy AUSA partner in Nasbville reached out to the DA's office. Unfortunately, the judge ordered the courtroom closed in anticipation of large crowds and potential protest. He won't be able to accommodate the request to allow Bobby (or anyone else) to attend. Only defendants and counsel will be admitted. Sorry. We'U stay in touch with the DA and share what we can with you. SP From: duVergne Gaines Sent: Wednesdayi Februa 2, 2022 1 1 :54 PM To: Patel, Sanjay (CRT) Subject: [EXTERNAL] Question re. Mt. Juliet Local Cowi Case Sanjay, The Wilson County Sheriffs office has advjsed us - or rathe.t Bobby Ledogar -- that Friday's court hearing for the Mt. Juliet blockaders is closed and only defendants and lawyers wiJl be allowed in court room. C-arafern would like to have Bobby Ledogar, NAF's South East Sec11Tity Director, attend as their representative or witness to tbe proceedings. We'd like to get in touch with the local prosecutor and see if1hey would allow Bobby to serve as a courtroom presences/witness on behalf of the victim in the case: Carafem. Do you have the local prosecutor's name and contact info so thar we may discuss this with them? Many thanks for any and all of your help trying to reach the local DA. Best, duVergne duVergne Gaines, JD Director, National Clinic Access Project Feminist Ma'orit Foundation 0: C: E: The infonnatlon contained i n this electronic message and any attached documents are privileged, confidential and prorccted from disclosure, and 'lhe information may not necessarily express t11e opinion of Feminist Majority Fou11dation. If you are not the intended recipient, note that any review, disclotiure, copying, or dissemination of this message or any attachments is strictly proltibite(,L If you Lhi11k thnl you have r,eceived this message in error, please destroy it and notify the sender. EXHIBIT 100 Operation Save America Leaders, Key Members, & Recent Blockade Arrestees Diiii .Jason Storms Director Nashville OSA Leader Assistant Director DerinStidd Assistant Director Chester "Chet" Gallagher Police Liaison , Cal Zastrow Blockade Leader Arrested Blockaders Affiliated with OSA James ("Jimmy") Zastrow Minors: Blockade Participants Collliiiiiiifd Live Streams blockades, deploys his children to blockade. 5/13/17 - Blockade of 8/27/20 - Blockade of 1/15/21 - Blockade of 3/5/20e- Blockade of 4/16/20 - Blockade of 1/27/20 - Blockade of Live Streamer ouisville, KY. g Heights, Ml. Rock, AR. Ft. Meyers, FL. EXHIBIT 101 From: "Patel, Sa11jay (CRT)" To: "Klopf, Amanda (USATNM)" � Subject: RE: Tomorrow's heating Date: Tue, l0 May 2022 1 1 :39:20 -0400 Importance: Normal lnlioe-Images: image0OJ .png Awesome. Thanks, Amanda! SP From: Klopf, Amanda (USATNM) � Sent: Monday, May 9, 2022 4:59 PM To: Patel, Sanjay (CRT)�; Ramnaney, Nikhil (CRT) Cc:-(ME)"(FBI)"� Subject: RE: Tomorrow's hearing I was holding off turning edits until I heard back from -but hopefully I can get him on the phone tomorrow to run our questions to ground, and turn something around the same day. From: Patel, Sanjay (CRT)"� Sent: Sunday, May 8, 2022 12:43 PM To: Klopf, Amanda (USATNM ) �; Ramnaney, Nikhil (CRT} Cc:-(ME)"(FBI)"� Subject: RE: Tomorrow's hearing Hey, Amanda,. Happy Mother's Day! Hope your family has made today special for you. Thanks for the update. Not sure if you spoke with - but I'm wondering wh� and James Z were dismissed. And, when do you think you can turn the memo around to us so that we send it up our chain 7 June is jam packed for me, and I'd like to get the memo moving so that we can figure out what our likely target indictment date i-s. Thanks! SP From: Klopf, Amanda (USATNM) � Sent: Friday, May 6, 2022 5:09 PM To: Patel, Sanjay (CRT)�; Ramnaney, Nikhil (CRT) Cc:-(ME)"(FBI)"� Subject: FW: Tomorrow's hearing Hot off the presses, here are the updates on the various players From: �tndagc.org> Sent: Friday, May 6, 2022 4:06 PM To: Klopf, Amanda (USATNM ) � Subject: [EXTERNAL] HE: Tomorrow's hearing Sorry it has takeh me so long to get back with you. Here is the status of the defendahts charged: - Juvenile Defendants: Adult Defendants: Dennis Green Bound Over and Set for Jury Trial: Eva Edi Chester Gallaher Heather ldoni Paul Place Calvin Zastrow Eva Zastrow Thankyou From: Klopf, Amanda (USATNM) Sent: Friday, Apr" i l 22, 2022 3:11 PM To: �tndagc.org> Subject: RE: Tomorrow's hearing - Of all of these defendants, who was the one who ended up with Diversion? Vaughn's PH is very heJpful. On the recording, the ADA says something along the lines of "this is the last one/1 Did ahyone else call witnesses for themselves or make argument like Vaughn did? Thank you! Amanda �gLlllg> From: Sent: Monday, March 14, 2022 1:54 PM To: Klopf, Amanda (USATNM) � Subject: (EXTERNAL) Re: Tomorrow's hearing It went fihe. All of the defendants are represented by an attorney named who is not a particularly strong lawyer. They asked for trial dates and were set for trial in November, with a pre·trial motion date set in September. - Keep me posted Get Outlook for iOS From: Klopf, Amanda (USATNM) - Sent: Monday, March 14, 2022 1:50:50 PM To: Subject: RE: Tomorrow's hearing How did last week's hearing go? we are still assessi�g where we are, but hopefully will have an answer soon. Thank you! Amanda From: Sent: Friday, February 4, 2022"11:13 AM To: Klopf, Amanda (USATNM) � Subject: [EXTERNAL] Re: Tomorrow's hearing Amanda, Today did go smoothly. They protested on the sidewalk but did not cause a disruption. The cases were continued to March 7, for a discussion date . I am curious- is there any decision yet on your end about whether a federal charge is going to be so1.Jght? Any idea on that timeline? Keep me posted please. Thank you Get Outlook for iOS From: Klopf, Amanda (USATNM) Sent: Friday, February 4, 2022 9:26:53 AM �gc.org> To: Subject: RE: Tomorrow's hearing I completely understand. I've shared your concerns with my team to be relayed. I hope today goes as smoothly as possible. Thank you Amanda From: �gLlHg> Sent: Thursday, February 3, 2022 5:08 PM To: Klopf, Amanda (USATNM) � Subject: [EXTERNAL) Re; Tomorrow's hearing Amanda, I believe that the judge is expecting these defendants t o be part of a protest tomorrow, which may be in the parking l ot, may be in the lobby, and may be in the courtroom. Given those concerns, I believe that the court will only be permitting defendants in the courtroom. While the gentleman that you are referring to may come and be in the lobby, I anticipate that he may not get into the courtroom given the judge's limitation. Likewise, given the potential of protest, it may be a difficult crowd to be around. I would recommend that he not attend under these circumstances as I do not wish to escalate the situation however it js a public court house and I cannot prevent his entry but cannot assure that he will be permitted entry into the courtroom. I hope this helps. Get Outlook for iOS From: Klopf, Amanda (USATNM) Sent: Thursday, February 3, 2022 4:36:44 PM 1111 To: �tndagc.norg> Subject: Tomorrow's hearing I know that the- tr�rs have an arraignment tomorrow, and that the cow1:r.oom attendance may be limited. I understand that .... would like to have Bobby Lcdogar, NAF's South East Sccu1ity Director, anend as their representative · or witness to the proceedings. Would that be sometbitlg that cou_ld be arranged? Tf you have any questions, please let me know. Thank you! Amanda Amanda J. Klopf Assistant United States Altom�)' MiddJe District ofTenne,ssee U.S. Attorne\1.S Office I T:� �,rv� LEGAL CONFIDENTIAL; The information in this e-mail and in any attachment may contain informati on that is privileged either legally or otherwise. It is intended only for the attention and use of the named recipient. If you are not the intended recipient, you are not authorized to retain, disclose, copy or distribute the message and/or any of its attachments. If you received this e-mail in error, please notify me and delete this message. EXHIBIT 102 From: Michelle Davidson �prochoice.org> To: "Patel, Sanjay (CRT)'' Subject: [EXTERNAL] Re: Check in? Date: Wed, 09 Feb 2022 08:56:50 -0500 Importance: Normal Yes to all of that! Talk to you Jater. Stay safe, Michelle Davidson Director, Security All pronouns are respectfully accepted (They/Them, He/Him, She/Hers) )mage Dlrect line:"_ '�image Confidentiality Notice: This e - mail message, Including any attachments, is for the sole use of the intended recipient, and may contaio confidential and privileged Information. Any unauthorized review, use, disclosure, or distribution fs prohibited. If you nave received this e -mail in error, please immediately notify the sender by e - mail at the address shown. Please delete it from your files if you are not the intended recipient. Thank you for your compliance. From: Patel, Sanjay (CRT)"� Sent: Wednesday, February 9, 2022 8:27,35 AM To: Michelle Davidson -@prochoice.org> Subject: RE: Check in? tli, Michelle Welcome back! A tan must mean good times were had! Looking fwd to hearing about the honeymoon, I heard that Zastrow and gangwer�in Little Rock. But you probably have better information than I do. Does today at 4:30pm work for a call? From; Michelle Davidson --@prochoice.org> Sent: Tuesday, February 8, 2022 8:18 PM To: Patel, Sanjay (CRT)� Subject: [EXTERNAL) Check in? Hi Sanjay, I'm back with a tan and a very full inbox. Hoping we can talk this week if you have a few minutes. I have some folks at Everv.town for Gun Violence asking about FACE strategies that I want to get yowr opinion on, the Little Rock Blockade utcome, and an update on the TN briefing t o name a few. I know your inbox is like mine s o anywhere you can squeeze me in, you always get priority o n m y calendar. Hope your week is going well. -M!chelle EXHIBIT 103 From: Michelle Davidson �prochoice.org> To: Cc: "Cowall, � RTi)" .i securlty �prochoice.org> Subject: (EXTERNAL] RE: Facts for TRO Date: Fri, 29 Jul 2022 1 2:58:31 -0400 Importance: Normal Hi Everyone, Just to update you - carafem has teamed up with Bass, Berry, and Simms along with the ACLU and we just completed the affidavits for the TRO. You can find drafts of both mine and ..ittatement in the Dropbox link. Let me know that it wmks for you. This is exciting - I hope it happens. Fingers crossed. *incident reports from staff and one patient are also in the Dropbox. I believe that the ACLU will be reaching out to Saniay and Laura for input or at least keeping you updated. Let me know how we can help more. We currently have eyes on those named in hopes of making serving easier today as quite a few of them are leaving town tomorrow. Hope you all are doing well"- I'm exhausted but got sotne energy/hope from this potential help. Go team. -Michelle From; Michelle Davidson Sent: Thursday, July 28, 2022 9:52 PM To Cc: Cowall, Laura (CRT) �; duVergne Subject; FW: Facts for TRO Forwarding for awareness and hopefully for good use. ·Michelle From: Michelle Davidson Sent: Thursday, July 28, 2022 9:55 PM To: 'Stella Yarbrough' �aclu-tn.org>; Robert Ledogar-J;lrochoice.org>; Melissa Grant �g>; Kat"Boyd"�g> Cc: Brigitte Amiri �g>; Ryan Mendias"�aclu.org>; securl"ty �Rrocholce.org> Subject: RE: Facts for"TRO Hi Everyone, The attached document has links to this DroQbox account. Please let me know if you have trouble oper:iing it or any of the links. -Michelle From: Stella Yarbrough �aclu-tn.org> Sent: Thursday, July 28, 2022 6:01 PM To: Robert ledogar �Rrochoice.org>; Melissa Grant �carafem.org>; Kat Boyd �@carafem.org> Cc: Michelle Davidson --P-rochoice.org>; Brigitte Amiri �aclu.org>; Ryan Mendias �g> Subject: Facts for TRO Hi Robert and Michelle (and Melissa and Kat), I was wondering if you all could help start typing out a narrative of what happened today so we can use that to develop your filings. We have local counsel to file but it looks like ACLU might be the one who is drafting. Specifically, I need • a narrative about OSA being present at the clinic (who, what when where); OSA people entering the building this week and today; MJPD not making arrests; and carafem clients being blocked from entering. • the names of who from carafem could attest to the above and the names of people who you know to be active in OSA and who you want stopped by the court. • any statements and their source (video, social media, in-person witness) about intent to come back, intent to "terrorize" the building, intent to escalate, etc. Brigitte, Ryan, any other facts we may need? From: Robert Ledogar -prochoice.org> Sent: Thursday, July 28, 2022 12:08 PM To: Stella Yarbrough �aclu-tn.org> Subject: Carafes - Invasion/Blockade Stella, I was just informed that 3 adults made entry into the building to the 2nd floor into the hallway of the entrance door of Carafem. They did not make entry into Carafem. My Juliet Police are on scene. FBI agent notified. M/TN AUSA notified, Bobby Get Outlook for iOS EXHIBIT 104 From: "Patel , Sanjay (CRT)" To: "Dean, Keny K (CRT)" Subject: RE: Nashville Date: Mon. 01 Aug 2022 1 8:38:50 -0400 Importance: Normal Hi, Kerry"Sorry for the late response The weekend was surprisingly quiet. No incidents at either clinic. I understand and agree with your thoughts. Perhaps we'll find out more at the call tomorrow. SP From: Dean, Kerry K (CRT)"� Sent: Monday, August 1, 2022 4:38 PM To: Patel, Sanjay (CRT)"� Subject: RE: Nashville Hi Sanjay, It doesn't look like anyhing materialized over the weekend in terms of obstruction, is that right? I didn't find anythihg in mv general news searches. We drafted an SOI, but aren't exactly sure ·how to proceed given the posture - it would have been easier if the judge hadn't granted the TRO so quickly, but I'm certainly glad she did. They didn't raise the March 2021 blm:kade in their pleadings or very specific statements about OSA wanted to escalate and continue obstruction after the rally and up until Aug. 25, and we generally don't add facts in an SOI. Civil FACE doesn't give us any remedies that they cannot get, so I'm not sure filing our own suit makes sense. I would love to file an SOI to show our support, but we're just trying to work it through. Thanks, Kerry Sent: Monday, August 1, 2022 2:49 PM From: Brigitte Amiri illlllll@aclu.org> To: Dean, Kerry K {CRT)"�; Ryan Mendias"._@aclo.org>; Patel, Sanjay {CRT) ��v..com; �ry.com; lllll@bassber01,.com; Stella Yarbrough"�g> Subject: [EXTERNAL] Re: Nashville Thanks, everyone. As you see in the order, there will be a hearing on Aug. 5 at 9 a.m. We u nderstand that at least some of the defendants will be present. We assume but are confirming that the judge will want live witnesses. If you are able to file a statement of interest, are you able to do so before the hearing? Or send a n AUSA to make that statement on the record? We also hope you are also considering joining the suit, and we also want to raise that this issue will continue to come u p with OSA and these individuals - we'll send you the social media posts, but we understand that they will be targeting clinics in NM, MA, and IL, etc. Also, if there are live witnesses, we are c oncerned a b ou t the safety of our clients, and will be reaching out t o the court to discuss options for security to enter the courthouse. If the defendants violate the order, and are found in contempt, will the Marshals be able to enforce the contempt? Thank you, Brigitte From: Dean, Kerry K (CRT)n._ Sent; Friday, July 29, 2022 9:44 PM To: Brigitte Amiri ....@aclu.org>; Ryan Mendias �@aclu.org>; Patel, Sanja,y (CRT)n�; -@bassberry.ecom ; -bassberr-;..com -@bassberry.com �; Stella Yarbrough �@adu- tn.org> Subject: RE: Nashville Wow. Congratulations! We will be in touch about what we can do. From: Brigitte Amiri ....@aclu.org> Sent: Friday, July 29, 2022 7:10 PM To: Dean, Kerry K {CRT)n._; Ryan Mendias �@aclu.org>; Patel, Sanjay (CRT) �-@bassberr-t.com; -@bassberry.com; -@bassberry_.com; Stella Yarbrough �@aclu-tn.org> Subject; [EXTERNAL] Re: Nashville Thanks all. The judge called the attorneys at Bass Berry late afternoon, and just issued the attached order. if there is. anything you are able to do to be supportive, we'd appreciate it. From: Dean, Kerry K (CRT)n._ Sent: Friday, July 29, 2022 3:39 PM To: Brigitte Amiri �g>; Ryan Mendias �g>; Patel, Sanjay {CRT)n�; �y.com �ry.com �v..com �; StellaYarbroughn�g> Subject: RE: Nashville Hi Brigitte, Thahks so much for keeping us in the loop. Definitely let 1.1s know when a hearing will be and we will try to have someone attend. I do not think anyone would participate yet as we are still assessing what we can do. Thanks, Kerry From: Brigitte Amiri �g> Sent: Friday, July 29, 2022 3:30 PM To: Ryan Mendias �g>; Patel1 Sanjay (CRT) �; Dean, Kerry K (CRT) --;e�v..com:e�v.-com; �y.com; Stella Yarbrough �g> Subject: [EXTERNAL] Re: Nashville Thanks all. Sanjay & Kerry - we will let you know when we have a case number and when a hearing is scheduled. Please let us know if an AUSA will be able to come and/or whether you'll be able to file a statement of interest. From: Ryan Mendias �@aclu.org> Sent: Friday, July 29, 2022 2:57 PM To: Brigitte Amiri <111111@aclu.org>; Patel, Sanjay (CRT)"�; Dean, Kerry K (CRT) �-@bassberty.com · -@bassberty_.com >; �; Stella Yarbrough"� r �bassberrv..m. �bassber v..mrn tn.org> Subject: RE: Nashville Hello all, Attached are the pleadings that are being filed today in carafem's FACE Act action. Best, Ryan From: Brigitte Amiri �g> Sent: Friday, July 29, 2022 1:27 PM To: Patel, Sanjay (CRT)�; Dean, Kerry I< (CRT)"�; Ryan Mendias �@aclu.org>; -@bassberry.com; -@ bassberry."com; -@bassberry.com; Stella Yarbrough �@aclu-tn.org'> Subject: Re: Nashville - And here is a Dropbox of video and pictures: Brigitte On Jul 29, 2022, at 11:53 AM, Brigitte Amiri wrote, Thank you, San jay. I'm also adding Ryan from my office, Stella from the ACLU of TN, and Angie, Allison, and Sarah from Bass Berry, who are bringing the case. We'll send drafts of the pleadings as soon as we can. We are trying to get a hearing today - rf it gets set, could an AUSA be present? Thank you, Brigitte From: Patel, Sanjay (CRT)"� Sent: Friday, July 29, 2022 10:32 AM To: Brigitte Amiri �g>; Dean, Kerry K (CRT)"� Subject: RE: Nashville Connecting Kerry on this thread so she has Brigitte's cell. From: Brigitte Amiri �g> Sent: Friday, July 29, 2022 9:54 AM To: Patel, Sanjay (CRT)"� Subject: [EXTERNAL) Re: Nashville Yes, thank you. Feel free to call my cell phone - From: Patel, Sanjay (CRT)e� Sent: Friday, July 29, 2022 9:53 AM To: Brigitte Amiri �g> Subject: Nashville Good morning, Brigitte I'm following up with you about the events In Nashville, and potential civil action by the ACLU. Do you have time for a call today? Sanjay Sanjay Patel Director National Task Force on Violence Against Reproductive Health Care Providers Criminal Section Civil Rights Division U.S. De ai·tment of Justice EXHIBIT 105 From: "Fitzgerald, Paige (CRT)" To: "Patel, Sanjay (CRT)" Subject: RE� Reference Request Date: Wed, 30 Dec 2020 14: 1 7:36 -0500 Importance: Nonnal JnJine-lmages: image0OJ .jpg Hi, Sanjay"Sorry for the delayed response, and hope you are having a happy holiday season. Re: the request for a reference, do you know what you would be asked to opine on? I don't know what we would be able to say. Once you know what you would be asked about, we should probably ask our ethics person, John Bu(:hko, what we are a llowed to do/say re: ah NGO with whom we interact. Thanks, Paige From: Patel, Sanjay (CRT) Sent: Wednesday, December 23, 2020 11:05 AM To: Rtzgerald, Paige (CRT) Subject: FW: Reference Request Hi, Paige. Just following �p on rny below email. Unless you disagree, I'll have NAF use me as their reference for their grant application. Thanks. SP From: Patel, Sanjay (CRT) Sent: Friday, December 18, 2020 11:25 AM To: FTtzgerald, Paige (CRT) Subject: FW: Reference Request Hi, PaigeNAF has asked if they could list you as a reference for a fund proposal (that supports, among other things, their training and threat monitoring servi�es). It looks like they may be able to list me in your place. Do you have a preference either way? I would suggest using me. Thanks. SP From: Tara Gannon �Rrochoice.org> Sent: Thursday, December 17, 2020 3:19 PM To: Patel, Sanjay (CRT) Subject: R�ference Request Hi Sanjay, The NAF Security team is working with a funder, the Lisa and Douglas Goldman Fund, to help cover the cost of security activities within our department. This includes, but is not limited to, travel costs to provide member training - active shooter, bomb threats, domestic violence i n a reproductive health settihg, etc. It also includes the annual fee we pay MSA fortheir onllne thre:at monitoring services. We need to provide five references to the Lisa and Douglas Goldman Fund for our proposal. We previously listed JUiie Abbate when she was·at DOJ. Can you ask Paige if she would be ok being a reference for us? I'm not 100% sure the Foundation will contact her since they know us, butthey might. It would be confidential-the only place her name would be listed would be in the proposal we send them. It would not be published. They are c1 very pro-choice, friendly foundation. If you think it makes more sense to list you as a reference, we can do that as well. Melissa Fowler {our VP) reached out to me and specifically asked about Paige"- b.ut I will defer to you on that. Thanks and I hope you are well, Tara Gannon Senior Director, Security National Abortion Federation (T­ (E-.il@Qrochoic.e.org ConfidentialltY. Notice: This e-mail message, Tncluding any attachments, is tor the sole use of the intended recipient; and may contain confidential and privileged information. Any unauthorized review1 use, disclosure, or distribution is prohibited. Ifyou have received this e-mail in error, pleaS"e immediately notify the sender by e-mail at the address shown. Please delete it from your files if you are not the intended recipient. Thank you for your compliance. EXHIBIT 106 From: "Patel, Sanjay (CRT)'' To: "Tara Gannon" �prochoice. org> Subject: RE: Reference Request Date; Wed, 23 Dec 2020 1 1 :06: 1 1 -0500 Importance: Nonnal lnline-Images: image0OJ .jpg Hi, Tara I'm so sorry for the delayed response. Feel free to use me as a reference. If you all would rather use Paige, let me know so that I can get her approval. Thanks, and Happy Holidays! SP From: Tara Gannon Confidentiality Notice: This e-mail message, including ant attachments, is for thf! sole use of the intended reciplenc, and may contafn confidential and PFl\11/eged Information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this e-mail In error, please immediately notify the sender by e- mail at the address shown. Please delete it from .your files if you are not the• intended recipient. Thank you for your comp/lance. Sent from my T-Mobile SG Device Get Outlook for Android From: Patel, Sanjay (CRT)"._, Sent: Wednesday, October 25, 2023 5:53:02 AM To: Michelle Davidson Subject: RE: Request GM Mfchelle! Can we chat a bit more about this after my trial is over. We're in the middle of trial for the final DC defendant (Harlow). And, I wo1;1ld have to get permission from Paige to write a statement for yot.1 (which you �now I am otherwise happy to do for you). Should be done with trial on Thurs or Fri. SP From: Michelle Davidson Sent: Tuesday, October 24, 2023 5:37 PM To: Patel, Sanjay (CRT)"._, Subject: [EXTERNAL) Request ltnportance: High Hey Sanjay, I have a request that I hope you could squeeze into your very busy schedule. We have the opportunity to submit a proposal for grant funds that would support the already existing security work I do in the DMV for providers. I'm hoping you could write a short impact statement, on DOJ letterhead, and in your own words, on the importance of the NAF Security Departments work and the itnpact on provider safety in the OMV. You could also talk about how we work together and some of the outcomes of our efforts if you feel inclined. I know you have a lot going on but a statement from you would have a big impact on the proposal. It's due next Tuesday so of course, like with everything else these days, a big rush, I also completely understand if it's not possible so don't worry or stress -just let me know. H0pe your good - looking forward to ahy updates on the nert trial you may have. Let's chat soon l -M Michelle Davidson Director, Se�urity Pronouns. Any (no prefer.ence) orjust Michelle NAF Security Annapolis Junction, MD 20701-0416 *This line is not reliable for text message 11se "Don't ever let them steal yourjoy" - Brandi Carlile I respect that your working hours may be differentfrom mine and I support your healthy work/life boundaries. Only respond when you have the time and capoc/ty. Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, discl osure, or distribution is prohibited. If you have received this e-mail in error, please immediately notify the sender by e­ mail at the address shown. Please delete it from your files if you are not the intended recipient. Thank you for your compliance. EXHIBIT 108 To: "Jodie Bell Cc: • , "KJoµf,Amanda (USATNM)" Subject: RE: US v. Gallagher Date: Wed, 22 Feb 2023 I 8:29 : J 3 -0500 Jmportance: Nonna] Hi,JodieThanks again for reaching out ,md following u p on your earlier request for information related to your expected motion. As the national clinic violence coordinator, I do not keep the kind of records you have requested and, as a result, I do not believe that we will provide them to you, However, I expect that much of what you seek is publicly available. For example, there are press releases on the DOJ's public website that address FACE Act prosecutions. With those press releases, you would be able to obtain additional materials through the courts' online databases. Thanks, Sanjay Patel From: Jodie Bell Sent: Tuesday, February 21, 2023 3:52 PM To: Patel, Sanjay (CRT)"� Cc: Patel, Sanjay (CRT)�; Ramnaney, Nikhil (CRT) (USATNM)"� Subject: [EXTERNAL) Re: US v. Gallagher ; Klopf, Amanda Mr. Patel and Ms. Ramnaney"- I am reaching out because I am hearing that Mr. Gallagher may have another federal indictment in Michigan. If this is the case, will you please let me know and he will promptly turh himself in on that indictment. I checked PACER to see if ahything was filed, but I could not see anything. If the indictment is sealed, I guess that would explain why. If there are any indictments in any districts, simply let me know and Mr. Gallagher will turn himse"l"f in. He is committed to appearing in Court and complying with any rules of pretrial release. Also, I am still wait.ing to hear back on the request for the number of FACE Act criminal prosecutions following the Dobbs decision, as well as the number of any prosecutions for vandalisms df pregnancy centers. I need this information for the pretrial motion filing deadline next week. Thanks, Jodie Bell Joelie Ann Bell Attorney �t Law I ,EGAL CONFIDR1 TlAL: The information in this e � rnail and in any attacl1mem may contain information tba,t jg privileged ejther legally or otherwise, lt is intended only for the attention and use of the named recipient. Lf �ron are not the intended recipient1 you are not authorized to retain, disclose, copy, or distribute the message and/ or any of its attachments. If you received this e-mail in error, please notify me and delete this message. From: Klopf, Amanda (USATNM) Date: Sunday, February 19, 2023 at 12:24 PM To: Jodie Bell Cc: Patel, Sanjay (CRT) Subject: RE: US v. Gallagher , Ramnaney, Nikhil (CRT) Jodie, I am unexpectedly tied up in what looks to be a S week long trial. I've cc'ed my counterparts on here Thanks Amanda From: Jodie Bell Sent: Sunday, February 19, 2023 11:51 AM To: Klopf, Amanda (USATNM) � Subject: [EXTERNAL) Re: US v. Gallagher Amanda - Just circlihg back around on the below email to see if you or the DOJ attorneys can answer the first question about FACE act prosecutions and prosecutions of pregnancy centers. Our initial pretrial motion filing is approaching. Thanks, Jodie Jodie Ann Bell Attorne\' at Law LEGAL CONFIDENTIAL: The information in trus e-mail and in any attachment may contain information that is priv,ileged either legally or otherwise. Lt is intended only for tbe attention and use of the named recipient. Lf you are not the intended recipient, you are nor authorized to retain, disclose, cop)� or distribute the message and/ or any of its attachments. l f you received this e-mail in error, please notify me and delete this message. From: Klopf, Amanda (USATNM) Date: Friday, February 3, 2023 at 4:09 PM To: Jodie Bell Subject: RE: US v. Gallagher Jodie, I'm sorry for the delay in getting back to you. I'm going to have to get back to you on your first question. On your second question, this is an interesting quirk of this discovery-the recordings are embedded in the PDF. If you go to the PDF that references the recordings, which I believe should be stamped 000942, and hover your mouse over the green triangles, it acts as a "play" button. Let me know if you have issues with it. Thank you Amanda From: Jodie Bell Sent: Friday, January 27, 2023 12:47 PM To: Klopf, Amanda (USATNM) � Subject: [EXTERNAL] US v. Gallagher Hi Amanda - I am currently looking into some of pretrial motions in the Gallagher case and was hoping you and your co­ counsel can help me out. I am curious about how many FACE act criminal prosecutions there have been in the last ten years, including both reproductive right clinics, churches etc. As for pregnancy crisis clinics (the pro-life clinics), how many federal prosecutions have there been for any crimes have related to bombings and vandalisms of these places. It is no secret that we will likely make a selective prosecution type argument and I anticipate Judge Trauger will ask this question. I would think the DOJ would keep track of th1s. Please let me know what you or your co-counsel know about this. Also, I opened a file in the discovery on the and the file seems to make reference to a recording that is not there. I would think since my client was convicted and then appealed that there would be a recording of the initial trial, did you pull it? Is it in discovery and I'm missing it? Thanks much, Jodie Bell Jodie Ann Bell LEGAL CONFIDEN'rIAL: TI1e ihfotmation in this e-ma.il and in any artacl1rnent tnay contain information thar is privileged either legally or otherwise. Ir is intended only for the attention and use of rhe named recipient. If you are not the intended recipient, you ate not authorized to retain, disclose, copy, or distribute the message imd/ or ahy of its attachments. If you received this e-mail in error, please notify me and delete rbjs message. EXHIBIT 109 From: "Miller1 Angela (CRT)" To: "Patel, Sanjay (CRT)" Cc: "Gamondi, Cristina (CRT)" Subject: 248.Consolidated.October 2022.xJsx Date: Wed, 19 Octt2022 L0:1t8:55 -0400 I mportance: Normal Attachments:248.Consolidated.October 2022.xlsx Sanjay- Before I' share to the one drive, is this what yol.l are looking for (granted, it may have some additional inforrnation, too)? The orange highlights at the top are things thqt Remy can fill out, provided he. can find the information. Would this work? Angela Case Name Defendants' names CHESTER GALLAGHER; HEATHER IDONI; CALVIN ZASTROW; COLEMAN BOYD; CAROLINE DAVIS; PAUL VAUGHN; DENNIS GREEN; EVA EDL; EVA US v. CHESTER GALLAGHER, ZASTROW; JAMES ZASTROW; PAUL PLACE ET AL US v. CHRISTOPHER MOSCINSKI # of defendants District Docket Number 11 MDTN 3 22CR327 Year Filed Offense Date 2.10.2021 to 3.5.2021; 2022 3.5.2021 Charging Date Charges 10.3.2022 Status 241(248(c)); 248(a)(1) Outcome Sentence Filings PENDING 10.3.2022 (Indictment) 1 EDNY 22CR1052 2022 7.7.2022 9.28.2022 248(a)(1) PENDING 9.28.2022 (Complaint) 1 EDPA 2 22CR323 2022 10.13.2021 9.22.2022 248(a)(1), (b)(1), (b)(2) PENDING 9.22.2022 (Indictment) 10 DDC 1 22CR96 10.7.2020 to 3.24.2022; 2022 10.22.2020 10.22.2020 10.14.2022 241(248(c)); 248(a)(1) PENDING 3.24.2022 (Indictment) US v. RICHARD CHAMBERLIN 1 CDCA 2 22CR36 3.30.2021; 5.7.2021; 6.20202 to 5.7.2021; 2022 5.7.2021 1.28.2022 248(a)(1) 922(g) PENDING (trial 2.7.2023) 2.11.2022 (Indictment) US v. DEVIN KRUSE 1 DOR 1 22CR64 2022 11.23.2021 11.26.2021 2.24.2022 248(a)(3) 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 DNJ SDOH MDFL DDE MDFL DCO EDMO WDMO WDTX CDIL NDIL DAK DMD DMD WDMO DMN SDIN EDVA EDWI NDFL EDWI EDCA DMA MDNC 2 21MJ15452 2 21CR171 2.21CR40 1 21CR1 3 19CR186 1 10CR506 4 19CR2799 2 19CR4031 3 18MJ5256 2 18CR20014 1 18CR88 3 16CR130 1 16CR520 1 16CR490 3 13CR5054 0 16MJ81 1 14CR98 1 12MJ645 1 12CR77 3 12CR18 3 12CR43 1 11CR308 1 11CR10072 1 10CR358 2021 10.16.2021 10.30.2021 12.2.2021 2021 2021 2020 2019 2019 2019 2019 2018 2018 2018 2016 2016 2016 248(a)(1) 248(a)(1) 875 844 248(a)(3) PLEA 9.19.2022 248 DISMISSED; AGREEMENT 10.3.2022 PLEA 248 & 875 PLEA 248 2.24.2022 (Info) US v. DANIEL COURNEY US v. CARLOS BRIME US v. EVERETT LITTLE US V. JAMES GULICK US v. RODNEY ALLEN US v. ROBERT DEAR US v. MARIA TERRY US v. WESLEY KASTER US v. PHILLIP MILLS US v. EMILY HARI US v. LUKE WIERSMA US v. ROBERT KLIMA US v. CHARLES MILLER US v. TRAVIS REYNOLDS US v. STOUT US v. MICHAEL HARRIS US v. DAVID CURRELL US v. CHRISTIAN US v. FRANCIS GRADY US v. BOBBY ROGERS US v. LANG US v. DONNY MOWER US v. HOLMANDER US v. JUSTIN MOOSE US v. THEODORE PUCKETT, ET AL. US v. ERLYNDON LO US v. FREEMAN US v. HERTZ US v. ALEXIS KEISER 12 months, 1 day 8 months 248(a)(1); 844 PLEA; 1001 & 248 24 months 248(a)(3) 844 PLEA 248 & 844 120 months 1 1 1 1 SDNY NDTX DOR DCO WDMO 1 10CR6 3 10CR110 6 09CR60148 1 09CR384 2 08CR4035 2010 2010 2009 2009 2008 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 DNM WDTX DKS MDFL DMD SDIA DNE NDAL NDOH SDFL NDTX EDNC SDTX WDNC EDPA EDAR 1 08CR144 1 07CR98 2 07CR20014 3 06CR362 8 06CR279 2 06CR576 8 06CR165 7 06CR186 3 05MJ7116 0 03CR60259 4 03CR1878 4 03MJ23 4 03CR163 1 03CR14 2 02CR582 4 02CR109 2008 2007 2007 2006 2006 2006 2006 2006 2005 2004 2003 2003 2003 2003 2002 2002 248(a)(3) PLEA 248 48 months prob. DNJ WDNY WDNY EDCA NDMS DUT NDFL DNM DSD DND MDPA DKS DSC EDAR WDOK SDMS EDCA EDVA DMT EDCA WDNY EDWI DMA WDMO EDVA SDMS EDCA WDKY EDWI WDWI DMT NDNY EDWA SDTX DKS DOR SDFL DNM NDAL EDWI EDWI NDFL 1 01CR158 1 01CR60 1 00CR189 2 00CR139 1 00CR119 2l99CR557 1 99CR58 1 99CR566 4 99CR40061 3 99CR10 1 98CR302 2 98CR20069 2 98CR577 4 98CR132 5 98CR40 3 97CR87 2 97CR288 1 97CR219 2 97CR3 1 97CR5084 6 96MJ629 2 96CR189 4 96CR40019 95-0010-CV 4 96CR18 3 95CV633 2 95CR542 4 95CR17 2 95CR168 3 95CR55 6 95CR16 5 95CR144 2 95CR85 4 95CR71 6 95CR10036 6 95CR60035 9 95CR8025 1 95MJ01103 5 95CR16 2 94CR140 2 94CR86 3 94CR3118 2001 2001 2000 2000 2000 1999 1999 1999/2001 1999 1999 1998 1998 1998 1998 1998 1997 1997 1997 1997 1997 1997 1996 1996 1996 1996 1995 1995 1995 1995 1995 1995 1995 1995 1995 1995 1995 1995 1995 1995 1994 1994 1994 US v. MARK HOUCK US v. LAUREN HANDY, ET AL US v. SERGIO BACA, ET AL. US v. EVANS US v. BURKE US v. RICHARD REESE US v. WEILER US v. McMENEY US v. WESLIN US v. SKINNER US v. PATINO US v. JORDI US v. FERGUSON US v. LOCASCIO US v. BIRD US v. PHILLIPOS US v. WAAGNER US v. MACDONALD US v. NICHOLAS MORENCY US v. MARRA, ET AL. US v. KOPP US v. WILLIAMS, ET AL. US v. REECE US v. EMMETT US v. KELLY US v. McDONALD US v. UPHOFF US v. HANSON US v. MAHADY US v. BURKE US v. WALTZ, ET AL. US v. HART US v. CABANISS US v. CHANDLER US v. ANDREWS US v. MITCHELL US v. YANKOWSKI US v. HOWARD US v. WESLIN, ET AL. US v. WILSON, ET AL. US v. MCMANUS US v. DINWIDDIE US v. SPERLE, ET AL. US v. McMILLAN US v. SHANNON US v. EMBRY US v. ROBERT COOK US v. VINCENT WHITAKER US v. BLACKBURN US v. ARENA, ET AL. US v. MATHISON US v. BIRD US v. LUCERO, ET AL. US v. PRIESTLEY US v. OLSON, ET AL. US v. McDONALD US v. LANG US v. WILSON, ET AL. US v. BROCK, ET AL. US v. PAUL HILL LAUREN HANDY; JONATHAN DARNEL; JAY SMITH (AKA JUANITO PICHARDO); PAULA "PAULETTE" HARLOW; JEAN MARSHALL; HOHN HINSHAW; HEATHER IDONI; WILLIAM GOODMAN; JOAN BELL; HERB GERAGHTY 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 2016 2014 2012 2012 2012 2011 2011 2011 2010 2.11.2022 12 2 2021 (Info) Filings 248 PLEA Oregon Man Pleads Guilty for Planned Parenthood Property Destruction | OPA | Department of Justice Bergen County Man Arrested for Interfering with Reproductive Health Services | USAO-NJ | Department of Justice US Trial Brief 156 F.3d 292 (2d 1998) US Brief (Bird II) 124 F.3d 667 (5th 1997) 212 F.3d 1067 (8th 2000) 371 248(a)(1) CIVIL / Prelim. Inj. 76 F.3d 913 (8th 1996) CIVIL / Prelim. Inj. 946 F. Supp. 1254 (SDMS 1995) 248(a)(1) 248(a)(1) 248(a)(1) 924 Bench trial 30 dy - 6 months Life US Op cert Press Releases Nine Defendants Indicted on Federal Civil Rights Conspiracy and Freedom of Access to Clinic Entrances Act (FACE Act) Offenses for Obstructing Patients and Providers of a Reproductive Health Services Facility | OPA | Department of Justice Grand Jury Indicts Convicted Felon Who Allegedly Fired BB Guns at Planned Parenthood in Pasadena with Violating FACE Act | USAO-CDCA | Department of Justice 10.14.2022 (SS Indictment) 30 months US Brief Decisions Add'l Press Releases Eleven Defendants Indicted for Obstructing a Reproductive Health Services Facility in Tennessee | OPA | Department of Justice Defendant Charged with Blocking Access to Planned Parenthood Health Center on Long Island | USAO-EDNY | Department of Justice Bucks County Man Indicted on Federal Charges for Assaulting a Reproductive Healthcare Clinic Escort | USAO-EDPA | Department of Justice US Brief US Brief (Bird I) Decisions 73 F.3d 675 (7th 1995) 82 F.3d 1370 (7th 1996) 401 F.3d 633 (5th 2005) Pennsylvania Man Indicted on Freedom of Access to Clinic Entrances Act and Conspiracy Against Rights Offenses for Obstruction at Reproductive Health Services Facility | OPA | Department of Justice Justice Department Secures Agreement to Protect Access to Reproductive Health Services | OPA | Department of Justice EXHIBIT 110 From: " Cc: " Subject: RE: FACE Act cases with Pro-L, Pro-C breakdown Date: Fri, 3 1 May 2024 09:13:55 -0400 Importance: No1mal Attachments: FACE_Act_Case_Tracker_FY_ 1 7_-present.5.29 .2024.xlsx Good morning, Please see attached spreadsheet for FACE ACT Fis, Pis, and Assessments, the b i - weekly data pull was completed Wednesday. Moving forth, I will send the reports monthly per the email below. Thank you, MAPA Crimin nvestlgatwe 1V1Sion PCCRS/Civil Rights Unit (Desk) I (Cell) From: Patel, Sanjay {CRT Se To: > {CID) {FBI) >; Channapati, Ani Hi .. Whatever is more convenient. If no difference, monthly works. Thanks! SP From:Sent: Tuesday, May 7, 2024 3:11 PM To: (CID) (FBI) Anit (CR ) > >; Patel, Sanjay {CRT) >; Channapati, Good afternoon all, Sanjay and Anita, we previously provided an updated list of FACE Act investigations. - updates the list bi-weekly and wanted to know if you wanted the bi-weekly updates or monthly updates moving forward? We rather not inundate your emails but wanted to know your preference moving forward. Respectfully, From: (CID) (FBI) < > Sent: Friday, April 5, 2024 1:04 PM To: Patel, Sanjay (CRT) < >; Channapati, Anita (CRT) < Cc: (CID) (FBI) < >; (CID) (FBI) < Subject: FACE Act cases with Pro-L, Pro-C breakdown > > Good afternoon, Please see attached spreadsheet (Read-Only). The FACE Act Tracker is updated bi-weekly for Full & Preliminary Investigations and Assessments. The last data pull was Wednesday, 4/3 for updates through Tuesday, 4/2. Thank you, MAPA Criminal Investigative Division PCCRS/Civil Rights Unit (Desk) | (Cell) From: (CID) (FBI) < > Sent: Thursday, April 4, 2024 2:28 PM To: Patel, Sanjay (CRT) < >; (CID) (FBI) < (CID) (FBI) < >; Channapati, Anita (CRT) < Subject: RE: FACE Act cases with Pro-L, Pro-C breakdown >; > Good Afternoon All, I apologize for the oversight. Thank you for bringing it to my attention. I misspelled out an update tomorrow. From: (CID) (FBI) Sent: Thursday, April 4, 2024 1:38 PM To: Patel, Sanjay (CRT) < >; (CID) (FBI) < > Cc: Channapati, Anita (CRT) < > Subject: RE: FACE Act cases with Pro-L, Pro-C breakdown ’s name. (CID) (FBI) < will send >; Sanjay, Thanks for reaching out. I believe just updated our spreadsheet. I cc’d her on this email. Respectfully, From: Patel, Sanjay (CRT) < Sent: Thursday, April 4, 2024 12:15 PM To: (CID) (FBI) < > >; (CID) (FBI) < > > Cc: Channapati, Anita (CRT) < Subject: [EXTERNAL EMAIL] - FW: FACE Act cases with Pro-L, Pro-C breakdown Hi, and – Thanks for sharing at today’s meeting. 11 1 Wondering if we can get an updated matter tracking list? Attached is the latest one I have from last Aug. As new investigations are added to the list (open or assess), can you pass them along to me and Anita please? Thanks! SP From: < > Sent: Monday, August 14, 2023 1:00 PM To: Patel, Sanjay (CRT) < > Subject: FACE Act cases with Pro-L, Pro-C breakdown Hi SanjayAttached is a list of all our Civil Rights FACE Act cases as of 8/4/2023 with an additional column to identify if the victim is Pro-life or Pro-choice. Of the 60 total cases, there are 22 where the victim(s) are Pro-life, and 38 where the victim(s) are Pro-Choice. Following Dobbs, the percentage was reversed from what it is now. Please let me know if there are questions. Thanks! ~ SSA Civil Rights Unit FBI Desk Cell EXHIBIT 111 'From: "Patel, Sanjay (CRT)" To: "Felte, James (CRT)" , "Miller, Angela (CRT)" Subject: RE: question, AG hea,ing prep Date: Tue, 28 May 2024 1 2:03:49 -0400 Importance: Normal - correct US v. Durant. 23-mj-08003 (NDOH). Angela - I'm sorry I forgot to mention that one. It was charged last ye.a r and D was sentenced this year. From: Fette, James (CRT)e� Sent: Tuesday; May 28, 2024 11:56 AM To: Miller, Angela (CRT) ; Patel, Sanjay (CRT)e� Subject: RE: question, AG hearing prep A question re FACE: In addition to the four Freestone et al. defendants, didn't a USAO (in Ohio) also charge a defendant with a non-FACE statute (arson?) for an attack on a pregnancy resource center? From: Miller, Angela (CRT) Sent: Tuesday, May 28, 2024 9:56 AM To: Felte, James (CRT)�; Patel, Sanjay {CRT)e� Subject: RE: question, AG hearing prep Hi, Jim Sanjay and I have discussed the FACE numbers. - our best attempt, given that some defendants have been charged multiple times and some defendants have been charged for targeting a reproductive health clinic but have NOT been charged with FACE. We've tried to break it down as best we can. The n umbers in the first paragraph are exact (meaning, I counted 5.0 individual/distinct defendants - with some being charged more than once; i n 25 cases). This assumes we know the universe of non-FACE Act cases (we may not). But using the "more than" phrasing for the total cases puts us at the same phrasing for exclusive FACE Act cases: more than 45 defendants in over 20 cases. SO...to provide some room for error, it MAY make sense to just include ALL cases together (FACE and non-FACE) and use the "more than" language. It would then look like Option 1. Breaking them out looks like Option 2. If you have a preference, I can put it in a word document if that would be helpful. (FYI, the four defendants targeting a pregnancy resource center were charged together in one case.) • Angela Option 1 (lumping FACE and non-FACE defenda nts/cases together: Since January 2021, the Department has charged more than 45 defendants in over 20 cases for their actions related to interfering with those providing, or those seeking to obtain, reproductive health services; some of these defendants have been charged in multiple cases. This includes charges brought exclusively under the FACE Act, as well as other criminal charges specific to the alleged criminal conduct (e.g., damaging or destroying, by means of fire or a n explosive, a building used in interstate commerce). Among these defendants, four were charged for their actions targeting a pregnancy resource center. Option 2 (breaking out FACE and non-FACE defendants/cases): Since January 2021, the Department has charged 50 defendants- in 25 cases for their actions related to interfering with those providing, or those seeking to obtain, reproductive health services; some of these defendants have been charged in multiple cases. This includes charges brought exclusively under the FACE Act, as well as other criminal charges specific to the alleged criminal conduct (e.g., damaging or destroying, by means of fire or an explosive, a building used in i nterstate commerce). Among these defendants, four were charged for their actions targeting a pregnancy resource center. When limited to just those charges brought under the FACE Act, the Department has charged more than 45 defendants i n over 20 cases for their actions related to i nterfering with those providing, or those seeking to obtain, reproductive health services; some of these defendants have been charged in multiple cases. Among these defendants, four were charged for their actions targeting a pregnancy resource center. In any event, here are the defendants / cases we identified: FACE Act cases: US v. James Gulick US v. Everett Little US v. Carlos Brume US v. Daniel Courney US v. Devin Kruse US v. Richard Chamberlin US v. Lauren Handy, et al. (Lauren Handy, Jonathan Darnel, - Paula Harlow, Jean Marshall, John Hinshaw, Heather ldoni, William Goodman, Joan Bell, Herb Geraghty) US v. Mark Houck US v. Christopher Moscinski US v. Chester Gallagher, et al. ( Paul Vaughn, Dennis Green, ester a a he , Heather ldoni, Calvin Zastro� Coleman Boyd, , Eva Zastrow, James Zastrow, Paul Place) US v. Michael Barron US v. Bevelyn Williams, et al. (Bevelyn Williams, Edmee Cavannes) US v. Caleb Freestone, et al. (Caleb Freestone, Amber Marie Smith-Stewart, Annarella Rivera, Gabriella Oropesa) US v. Calvin Zastrow, et al. (Calvin Zastroyt, Chester Ga la Phillips, , Eva Zastrow) eJ, Heather ldoni, Joel Curry, Justin US v. Steven Lefemine US v. Nisith Vandebona US v. Chance Brannon, et al. • US v. Ernez Tomas Ausun US v. Whitney Durant US v. Mohamed Woes US v. Joshua Brereton Non-FACE Act cases: US v. Tyler Massengill US v. Lorna Green US v. Hrindindu Raychowdhury US v. Phillip Buyno From: Felte, James (CRT)e� Sent: Friday, May 24, 2024 5:39 PM To: Miller, Angela (CRT) Subject: FW: question, AG hearing prep ; Patel, Sanjay (CRT)e� Angela & Sanjay- See below regarding a stat request from the AG's office for the AG's upcoming congressional testimony. Please do not work over the weekend, but do you think you can get these stats to me by Wednesday morning? Angela- for the HOW request, we can talk on Tuesday about the parameters. 247 cases are fairly easy to identify, but 875 and other statutes that don't require certification may be difficult to identify. Thanks, Jim From: Felte, James (CRT) Sent: Friday, May 24, 2024 5:31 PM To: Sooknanan, Sparkle (CRT) Cc: Moossy, Robert (CRT) Subject: RE: question, AG hearing prep Sparkle, We don't currently have these numbers. We should be able to get the FACE Act numbers fairly easily on Tuesday. Regarding the second request for HOWs, while we keep a running total of our general hate crimes stats (x # cases, against y # defendants, and z # defendants convicted since January 2021), we don't have them broken out by specific categories such as HOWs. That means we'll need to do a hand count for that specific category which will take some time. I'll see we can get those on Tuesday. Jim From: Sooknanan, Sparkle (CRT) Sent: Friday, May 24, 2024 5:23 PM To: Felte, James (CRT)e� Cc: Moossy, Robert (CRT) Subject: FW: question, AG hearing prep Jim-Do we already have these numbers? If not, I'll ask Shaylyn for more time so it doesn't require work over the weekend. Thank you! From: Cochran, Shaylyn (OAG) Sent: Friday, May 24, 2024 4:41 PM To: Moossy, Robert (CRT) Cc: Trepel, Samantha (OASG) Subject: question, AG hearing prep ; Sooknanan,eSpar�ee(CRT) • Bruck, Andrew (ODAG) Hi Robert and Sparkle, With huge apologies for sending this request before the long weekend, am looking to pin down the followrng informatfon: • The total number of FACE Act prosecutions brought since January 2021 (and, if possible, the breakdown re: cases involving pregnancy resource centers and facilities offering comprehensive reproductive health services). • The total number of prosecutions involving attacks on or unlawful threats against houses of worship since January 2021. For this one, I recommend focusing on cases brought under 18 U.S.C. § 247 or threats cases under 18 U.S.C. § 875 involving houses of worship, but I defer to CRT on whether the;!re are prosecutions under other statutes (that CRT enforces) that are likely to fall under this description, We need this information compiled by no later than Tuesday at noon. However, if meeting that deadline would require folks to work on this over the holiday weekend, then please let me know asap so we can huddle. Shaylyn EXHIBIT 112 From: "Patel, Sanjay (CRT , "Ramnaney, Nikhil (CRT)" Subject: RE: Gallagher Date: Thu, 02 Feb 2023 17:34:33 -0500 Importance: Nonnal Attachments: OCaMTD.pdf _a lnline-Images: image001a.png Thanks for lead.Ing the discussion with Henry. Nikhil and I spoke with Forrest about Jody's request, and we agreed that we should not provide her with anything. To make a claim of selective pros, she bears a significant burden to show both discriminatory effect and purpose. She will have to, at a minimum, point to a similarly situated pro-choice individual who was not prosecuted for a 248(a)(1) violation. Our pros stats won't help her achieve that goal. She'll need more than raw data to make her case. Moreover, she may use our compliance as a discovery vehicle to dig iflto our investigation and pros decisions. Providing her with the requested information may open gates we will struggle to close later. I attached the Philly court's written opinion denying D's MTD for selective pros (among other grounds). Our facts are different, but the legal issue is the same. Happy to chat more a�out this. From: Klopf, Am;inda (USATNM) � Sent: Thursday, February 2, 2023 5:12 PM To: Patel, S11njay (CRT)"�; Ramnaney1 Nikhil (CRT) Subject: Gallagher Thank you both (and Forest) for joining that call. I spoke to Tom (our FAUSA) afterwards about Jody's records request, and his inclination is to just hand over the data. After you have a chance to talk it over with Forest1 will you let, me know your feelings on it? Thank you Amanda Amanda J. Klopf /\ssistant United Stales Attorney Civi( Rig/its CQordinator Com11uter flacking and Intellectual PropertyAttorney Mi.tldle District ofTennessee LI.S. Alluroev' s Clftlce I 'I':· � t't,,� EXHIBIT 113 From: "Patel, Sanjay (CRT)" To: "Bernstein, Bobbi (CRT)" Cc: "Fitzgerald, Paige (CRT)" Subject: FW: Blockade Update Date: Fri, 28 Aug 2020 l 0:35 :26 -0400 Importance: Normal loline-Images: image002 .png; image00l .jpg Hi, Bobbi. Below are links to a bunch of videos that were posted on-line (some live-streamed on facebook) from a clinic blockade that occurred yesterday in Sterling Heights, Ml. According to Michelle Davidson (NAF), the blockade lasted nearly an hour, and several women seeking medical services were not able to enter the building and obtain services. Some of these videos appear to document this. I'm expecting clinic staff incident reports to be fwd'd to me when they're ready. The clinic has been jn touch with FBI (S�. I have not reached out to Francis. I'm happy to jump on this if you'd like. Let me know. Thanks. SP From: Tara Gannon �@prochoice.org> Sent: Friday, August 28, 2020 9:31 AM To: Michelle Davidson �@prochoice.org>; Fleisher, Aaron (CRT) Paige (CRT) ; Patel, Sanjay (CRT) Cc: Emma Goldberg �@prochoice.org> Subject: RE: Blockade Update Good Morning, The following dropbox links are the videos from the incident yesterday. httQs://www.droP-box.co https://www.rlfoJ;!box. co httgs://www.dmRbox.com httQS7//www.droRbox.co htt gs://www.droRbox.com https'.//www.droRhox.com httgs://www.droP-box.co httgs://www.droRbox.co hllP-s://www.droP-box.co ; Fitzgerald, httgs://www.droP-box.co Thank you, Tara Gannon Senior Director, Security National Abortion Federation m (E) ConfidentialitY. Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this e-mail fn error, please Immediately notify the sender by e-mail at the address shown. Please delete It from your files if you are not the intended recipient. Thank you for your complfance. From: Michelle Davidson �P.rocho1ce.org> Sent: Thursday, August 27, 2020 6:20 PM To: Aciron fleisher Cc: Tara Gannon -@.1::1rochoice.org>; Emma Goldberg �l:)rochoice.org> Subject: Blockade Update Good Evening All, We are still working on the downloads (they are taking forever) so as soon as we have them in a dropbox, Tara will forward them on. We will also be sending you incident reports and video footage from the clinic- hopefully tomorrow. Looks like we are about to be reliving the pre FACE late 80 1s/early 90's. The clinic is grateful for the support and ·as always, so are we. Thank you all for all you do. -Michelle Michelle Davidson Director, Security All pronouns are respectfully accepted (TheV/Them, He/Him, She/Hers) National Abortion Federation Confidentiality Notice: This e-mail message,. includin(J any attachments, is for the sole use of the intended recipient, and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you have received this e-mail in error, please immediately notify the sender by e-mail at the address shown. Please delete ft from your files if you are not the intended recipient. Th;;mk you for yovr comP,fiance. EXHIBIT 114 From: "Patel, Sanjayt(CRT)" To: "Carlson, Frances (USAMIE)" Subject: FW: Sterling Heights, M l FACE violations and more, 08.27.2020 Date: TlLe, 0 I Sep 2020 1 1 :06:48 -0400 Importance: Normal Frances, The below email was fwd to me by the NAF security director. It's from- and related to the incident from last week (the one with video links 1 sent you}. l thfnk we have a good misdemeanor 248(a)(l) for each protester who blocked the entrances. I know that you've got a busy week, but can we set up a call with the F'BI? Or, I can reach out to" and get things mov'ing with collecting arrest reports for protestors, and statements from clinic staff/patients that have already been written up (per -Then we can regroup once we have time to digest these materials? Let me know Whi:lt wor�s pest for you. Thanks. SP ■ From: Michelle Davldson-@prochoice.org> Sent: Monday, August 31, 2020 5:56 PM To: Patel, Sanjay (CR1) Cc: Tara Gannon".:allll@prochoice.org>; Emma Goldberg Subject: Sterling Heights, Ml FACE violations and more, 08.27.2020 From: ­ Sent: Monday, August 31, 2020 5:47 PM DE) (FBI. ) Subject: Sterling Heights, Ml FACE violations and more, 08.27.2020 Dear Agents We are copying on this email our attorneys, as well as Michelle Davidson from the National Abortion Federation and duVergne Gaines from the Feminist Majority Foundation, both of who we believe you work with on these FACE issues. a be�ter description of the events that transpired at ou,_ � u� to � ive you . .........ilChnlc In Sterling Heights last week. The events that happened on Thursday were distressing, illegal and we are not happy with the way it was handled. I am going to summarize below ( 1 ) what happened generally (2) how we were treated by the S H Police - the disrespect and how they did NOT do their job to protect us or the patients and (3) the probable FACE violations and how to move forward with prosecution. Sterling Heights, Ml-. As staff began to ( 1 ) The following events h appened at arrive at the clinic for work around 8:30am, there were already a large number of protesters present. As more staff members and patients began to arrive for opening at 9am, approximately 1 0-15 of the protesters trespassed into the parking lot. There .are multiple signs visibly posted all over the property stating "No Trespassing- patients and guests only" and it lists the Sterling Heights ordinance number for trespassing. They approached patient's cars and immediately began trying to open patient's car doors in the parking lot, block clinic entrances and harass anyone present in the parking lot. This was approximately at 8:50am. Many staff members were already inside the building but some were not and patients were arriving for 9am appts. The police were called as soon as this was discovered. The police arrived shortly after 9 am (we are checking the exact times). Our security guard gave the trespassers a verbal warning to leave the premises and the police did not arrest anyone for trespassing. There were a number of protesters filming/live-streaming from the sidelines of our property (also trespassing but not blocking entrances). The doors to enter/exit the building were blocked for approximately 1 . 5 hours. Prior to her arrival at the clinic, the owner called 2 more security guards to come to the clinic to help with the situation. When the owner arrived on the scene around 9:30am, the police asked the owner to AGAIN verbally tell those blocking the main clinic entrances to leave. The owner refused to and asked the police if they knew the trespassers names and information because they were breaking a federal law and if they get up and leave after blockading clinic entrances, they wouldn't be able to charge them with violating the FACE federal law. At that time, the owner called FBI Agent - and asked for help because the police were uncooperative and this was clearly a FACE violation. Agent - advised the owner that the Sterling Heights FBI office would contact the Sterling Heights police department to explain FACE. Police stated to the owner that they had to wait for more police and cars to arrive before they could begin arresting. At this time there were a few officers on the scene and at least 3 police cars. At some point between 9:30-1 0am, the clinic owner tried to take a staff member and a patient around the building to another entrance facin . Some of the trespassers blocking the main doors facing the parking lot left and ran around the building in order to block them from entering at 2 different doors on that side of the building. Some of those same trespassers that were blocking the doors were the same protesters that were going up to cars and harassing patients trying to open car doors. The police could have arrested them at any time they were walking around and they had enough cars to put at least one person in a car each and allowed them to return to the main doors and continue to block it. The police were rude and dismissive to the owner and staff. The police advised the owner and staff that the trespassers had a r.i ght to be there. The owner explained that they had a right to protest on the public sidewalk in front of the building and they did not have a right to trespass into the parking lot, which is against the city ordinance and they did not have a right to block our entrances and keep our business from operating as that is breaking a federal law. A female Sargent arrived close to 1 0am. The owner had the same discussion with her and officers began asking the people blocking the door for their identification. The owner gave a verbal request to leave the premises and was answered by one person blocking the door that she could not comply. A paddywagon type vehicle arrived and they started arresting around 1 0am. They took their time doing that and kept our business from opening for medical care for over 1 .5 hours. These protesters expressed their surprise on their live-streaming videos about how long they could engage the police officers in chit chat conversation to enable their fellow people to leave the door to harass the patients in the parking lot- or so-call "minister" to them. The arrests were slow and our parking lot continued to be blocked with police cars and protesters preventing patients with later appointments from entering our parking lot and being subjected to the harassment on the street. 2. When the police arrived on the scene they NEVER once asked or checked on the safety of the staff inside. They didn't show any concern for their well-being. They also did not try to talk to any staff in the parking ·lot or check on the well�being of the patients being harassed and terrorized in the parking lot. They did not try to enter the building or try to speak to any of the staff inside. They did not check to see if anyone was injured on the inside or, in fact, if any of the trespassers had succeeded in entering the building. The staff could have been in danger, held at gunpoint, etc. and the police would not have known as they did not even inquire about their welfare. After the police were there for some time, one supervisor tried to beckon a police officer inside by slightly opening the door and asking him to speak to her in the vestibule and he was rude and dismissive. The officers who arrived first on the scene immediately began engaging with the trespassers in conversation about random things while they were blocking the clinic entrances. They did not check for weapons nor did they take the personal property of the trespassers after they were arrested. In fact, one male who blockaded the clinic entrance actually had his phone recording for 1 h r 26 min. This recording included his time blocking the clinic entrance. conversations with law enforcement, the as well as recording from audio for his whole ride to the jail and his conversation with Officer within the jail until the owner of the clinic called the police to advise them they were recording live from within the jail. The police allowed the private property of our clinic to be a circus of harassment c1nd terror for approximately 1 .5 hours. They not only sympathized with those breaking the law but allowed them to continue breaking the law for as long as they could. They ignored the rights of the business owner, the staff and the patients waiting to be seen for medical care. There are public groups calling for the firing of these officers involved due to their actions in this situation. We are looking into filing formal complaints about the actions of the officers involved with the Department. During this whole ordeal, there were about 40 other protesters out on the sidewalks adding to the mayhem. '1111' 3. We are disappointed in the communications we had with the FBI as this was happening. Our I left Agent - a voicemail at 1 0:52am that day to communications were with Agen ask about witness statements for a FACE case and what needed to be collected. I did not receive a phone call back u ntil the following day, which was not helpful as all witnesses were obviously no longer present. She stated the next day that she would have advised me to call NAF about that. As far as I am aware, the Dept of Justice who is the "boss" of the FBI would be the prosecutor of any federal cases. Not NAF. So why wouldn't the FBI be the ones to advise us on what information would be important to obtain in a federal FACE case? We didn't hear from any FBI agents for the rest of the day. In fact, we have still not heard from any agents regarding what happened. We understand that in Detroit was dealing with a suspicious package situation and 2 agents attended to that situation. We are glad for that and are also wondering why when we were experiencing a severe FACE violation, not one FBI agent checked in with us for not only the rest of the day, but for the rest of the week. Agenti- advised me on our call Friday that what we were clinic didn't rise to the level of requiring FBI involvement at that time. We are very experiencing at for the suspicious package incident but still do not under� our glad the FBI was at experience did not reach the same level of FBI support. We were told that - from -­ spoke with Agent- on Friday and told him about our experience, the recording of the protesters, how long they were in our parking lot and how long our business was shut down and according to her., he wasn't aware of the situation and that it sounded like a clear FACE violation. If that is correct, why did we not hear from someone at the FBI? These same terrorists that were arrested in Sterling Heights on Thursday also went to our location on Friday. They did not attempt to blockade the clinic but were present and intimidating and could have tried to do the same thing. There were a total of 1 0 arrested on Thursday in Sterling Heights. We have identified them all. We have identified the 3 police officers. that we believe did not do their job and whose actions were most egregious. We have collected witness statements from those willing to give them (patients and their support persons) as well as statements from all the staff members. We have gathered video footage and photos of the FACE violations and from the whole incident from all Facebook videos, security footage, and staff phones. We want to move forward with a FACE prosecution and are sending all this information over to the Department of Justice. "Ill' I am adding a link here of a video that was taken by 1 per.son arrested, Chet Gallagher, who is in some sort of leadership position with Operation Save America. This video is the most egregious in show,ing the behavior of the police officers involved, including conversations between the FACE violators and the police, the interactions between them, the conversation with Officer and Chet on the way to jail (that included opinions about Black Lives Matter, people burning cities and other personal viewpoints. and the recording from inside the jail. I have this video downloaded, as well as many others that were captured from anti-abortion terrorists that were recording, our staff members that recorded and show explicit blockadin of all clinic entrances both atient and employee). htt12s://www.y:outube.co We are going to be sending a separate email to you regarding a separate incident, concern and location as to not confuse the two. It is regarding an occurrence at our �ity location on Saturday, August 29, 2020 with protesters with assault weapons and the police situation there. Thank you, and (owner of - JD (she/her/hers) Director of Advocacy & Development Centers, Michigan Did you know you can support our non-profit Reclaim with every Amazon purchase? SHOP NOW CONFIDENTIALITY NOTICE: This email transmission from Centers and any documents, files or previous email messages attached to it may contain confidential information that is privileged. If you are not the intended recipient, you are. hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is strictly prohibited. If you have received this ema11 in error, please irnmedjately notify the sender and delete the message and its attachments. EXHIBIT 115 From: "Patel, Sanjay (CRT)" To: "Michelle Davidson" �procboice.org> Cc: "Tara Gannon'' �prochoice.org>, "Emma Go1dberg11 �prochoi.ce.org> Subject: RE; Sterling Heights, MI PACE yjolations and more, 08.27.2020 Date:Tue, 01 Sep 2020 11 : 1 2� 1 9 -0400 Importance: Normal Hey, Michelle. I've reached out to the USAO in D�troit. In the meanwhile, can you help coordinate getting these for me? We have collected witness statements from those willing to give them (patients and their support persons) as well as statements from an the staff members. We have gathered video footage and photos of the FACE violations and from the whole incident from all Facebook videos, security footage, and staff phones. We want to move forward with .a FACE prosecution and are sending all this information over to the Department of Justice. Thank you! SP From: Michelle Davidson.-il@prochoke.org> Sent= Monday, Augllst 31, 2020 5'.56 PM To: Patel, Sanjay (CRT) Cc:Tara Gannon �prochoice.org>; Emma Goldberg �pr-ochoice.org> Subject: Sterling Heights, Ml FACE violations and more, 08.27.2020 From:­ Sent: Monday, August 31, 2020 5:47 PM (DE·) (FBI}< Subject: Sterling Heights, Ml FACE violations ar1d mor:e, 08.27.2020 Dear Agents _, - an d _ We are copying on this email our attorneys, as well a s Michelle Davidson from the National Abortion Federation and duVergne Gaines from the Feminist Majority Foundation, both of who we believe you work with on these FACE issues. a be�er description of the events that transpired at our­ � u� �o � ive you ·e. ---- Clinic In Sterling Heights last week. The events that happened on Thursday were distressing, i.llegal and we are not happy With the way it was handled. I am going to summarize below ( 1 ) what happened generally (2) how we were treated by the SH Police - the disrespect, and how they did NOT do their job to protect us or the patients and (3) the probable FACE violations and how to move forward with prosecution. ( 1 ) The following events happened at Sterling Heights, Ml - As staff began to arrive at the clinic for work around 8:30am, there were already a large number of protesters present. As more staff members and patients began to arrive for opening at 9am, approximately 1 0-1i5 of the protesters trespassed into the parking lot. There are multiple signs visibly posted all over the property stating "No Trespassing- patients and guests only" and it lists the Sterling Heights ordinance number for trespassing. They approached patient's cars and immediately began trying to open patient's car doors in the parking lot, block clinic entrances and harass anyone present in the parking lot. This was approximately at 8:50am. Many staff members were already inside the building but some were not and patients were arriving for 9am appts. The police were called as soon as this was discovered. The police arrived shortly after 9 am (we are checking the exact times). Our security guard gave the trespassers a verbal warning to leave the premises and the police did not arrest anyone for trespassing. There were a number of protesters filming/live-streaming from the sidelines of our property (also trespassing but not blocking entrances). The doors to enter/exit the building were blocked for approximately 1 .5 hours. Prior to her arrival at the clinic, the owner called 2 more security guards to come to the clinic to help with the situation. When the owner arrived on the scene around 9:30am, the police asked the owner to AGAIN verbally tell those blocking the main clinic entrances to leave. The owner refused to and asked the police if they knew the trespassers names and information because they were breaking a federal law and if they get up and leave after blockading clinic entrances, they wouldn't be able to charge them with violating the FACE federal law. At that time, the owner called FBI Agenti- and asked for help because the police were uncooperative and this was clearly a FACE violation. Agent - advised the owner that the Sterling Heights FBI office would contact the Sterling Heights police department to explain FACE. Police stated to the owner that they had to wait for more police and cars to arrive before they could begin arresting. At this time there were a few officers on the scene and at least 3 police cars. At some point between 9:30-1 0am, the clinic owner tried to take a staff member and a patient around the building to another entrance facin . Some of the trespassers blocking the main doors facing the parking lot left and ran around the building in order to block them from entering at 2 different doors on that side of the building. Some of those same trespassers that were blocking the doors were the same protesters that were going up to cars and harassing patients trying to open car doors. The police could have arrested them at any time they were walking around and they had enough cars to put at least one person in a car each and allowed them to return to the main doors and continue to block it. The police were rude and dismissive to the owner and staff. The police advised the owner and staff that the trespassers had a r.ight to be there. The owner explained that they had a right to protest on the public sidewalk in front of the building and they did not have a right to trespass into the parking lot, which is against the city ordinance and they did not have a right to block our entrances and keep our business from operating as that is breaking a federal law. A female Sargent arrived close to 1 0am. The owner had the same. discussion with her and officers began asking the people blocking the door for their identification. The owner gave a verbal request to leave the premises and was answered by one person blocking the door that she could not comply. A paddywagon type vehicle arrived and they started arresting around 10am. They took their time doing that and kept our business from opening for medical care for over 1 .5 hours. These protesters expressed their surprise on their live-streaming videos about how long they could engage the police officers in chit chat conversation to enable their fellow people to leave the door to harass the patients in the parking lot- or so-call "minister" to them. The arrests were slow and our parking lot continued to be blocked with police cars and protesters preventing patients with later appointments from entering our parking lot and being subjected to the harassment on the street. 2. When the police arrived on the scene they NEVER once asked or checked on the safety of the staff inside. They didn't show any concern for their well-being. They also did not try to talk to any staff in the parking lot or check on the well-being of the patients being harassed and terrorized in the parking lot. They did not try to enter the building or try to speak to any of the staff inside. They did not check to see if anyone was injured on the inside or, in fact, if any of the trespassers had succeeded in entering the building. The staff could have been in danger, held at gunpoint, etc. and the police would not have known as they did not even inquire about their welfare. After the police were there for some time, one supeNisor tried to beckon a police officer inside by slightly opening the door and asking him to speak to her in the vestibule and he was rude and dismissive. The officers who arrived first on the scene immediately began engaging with the trespassers in conversation about random things while they were blocking the clinic entrances. They did not check for weapons nor did they take the personal property of the trespassers after they were arrested. In fact, one male who blockaded the clinic entrance actually had his phone recording for 1 hr 26 min. This recording included his time blocking the clinic entrance, conversations with law enforcement, the audio for his whole ride to the jail and his conversation with Officer •�• as well as recording from within the jail until the owner of the clinic called the police to advise them they were recording live from within the jail. The police allowed the private property of our clinic to be a circus of harassment and terror for approximately 1 .5 hours. They not only sympathized with those breaking the law but allowed them to continue breaking the law for as long as they could. They ignored the rights of the business owner, the staff and the patients waiting to be seen for medical care. There are public groups calling for the firing of these officers involved due to their actions in this situation. We are looking into filing formal complaints about the actions of the officers involved with the Department. During this whole ordeal, there were about 40 other protesters out on the sidewalks adding to the mayhem. 3. We are disappointed in the communications we had with the FBI as this was happening. Our communications were with Agenti-- I left Agenti- a voicemail at 1 0:52am that day to ask about witness statements for a FACE case and what needed to be collected. I did not receive a phone call back until the following day, which was not helpful as all witnesses were obviously no longer present She stated the next day that she would have advised me to call NAF about that. As far as I am aware, the Dept of Justice who is the "boss" of the FBI would be the prosecutor of any federal cases. Not NAF. So why wouldn't the FBI be the ones to advise us on what information would be important to obtain in a federal FACE case? We didn't hear from any FBI agents for the rest of the day. In fact, we have still not heard from any agents regarding what happened. We understand that - Clinic in Detroit was dealing with a suspicious package situation and 2 agents attended to that situation. We are glad for that and are also wondering why when we were experiencing a severe FACE violation, not one FBI agent checked in with us for not only the rest of the day, but for the rest of the week. Agent - advised me on our call Friday that what we were ex_periencing at NFP clinic didn't rise to the level of requiring FBI involvement at that time. We are very glad the FBI was at - for the suspicious package incident but still do not under� our experience did not reach the same level of FBI support. We were told thati-ram __ spoke with Agent- on Friday and told him about our experience, the recording of the protesters, how long they were in our parking lot and how long our business was shut down and according to her, he wasn't aware of the situation and that it sounded like a clear FACE violation. If that is correct, why did we not hear from someone at the FBI? These same terrorists that were arrested in Sterling Heights on Thursday also went to our location on Friday. They did not attempt to blockade the clinic but were present and intimidating and could have tried to do the same thing. There were a total of 1 0 arrested on Thursday in Sterling Heights. We have identified them all. We have identified the 3 police officers that we believe did not do their job and whose actions were most egregious. We have collected witness statements from those willing to give them (patients and their support persons) as well as statements from all the staff members. We have gathered video footage and photos of the FACE violations and from the whole incident from all Facebook videos, security footage., and staff phones. We want to move forward with a FACE prosecution and are sending all this information over to the Department of Justice. I am adding a link here of a video that was taken by 1 person arrested, Chet Gallagher, who is in some sort of leadership position with Operation Save America. This video is the most egregious in showing the behavior of the police officers involved, including conversations between the FACE violators and the police, the interactions betw.een them. the conversation with Officer .... and Chet on the way to jail (that included opinions about Black Lives Matter, people burning cities and other personal viewpoints. and the recording from inside the jail. I have this video downloaded, as well as many others that were captured from anti-abortion terrorists that were recording, our staff members that recorded and show explicit blockadin of all clinfc entrances both atient and employee ). https://www. outube.com We are going to be sending a separate email to you regarding a separate incident, concern and location as to not confuse the two. It is regarding a n occurrence at our- city location on Saturday, August 29, 2020 with protesters with assault weapons and the police situation there. Thank you, and (owner of - JD (she/her/hers) Director of Advocacy & Development Centers, Michigan Did you know you can support our non-profit Reclaim with every Amazon purchase? SHOP NOW CONFIDENTIALITY NOTICE: This email transmission from Centers and any documents, files or previous email messages attached to it may contain confidential fnformation that is privileged. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or: use of any of the information contained in or attached to this tr:ansmission is strictly prohibited. If you have received this email in error, please immediately notify the sender and delete the message and its attachments. EXHIBIT 116 From: "Fleisher, Aaron (CRT)" To: "Patel, Sanjay (CRT)" Subject: FW: Blockade Date: Mon, 14 Sep 2020 1 3:54:55 -0400 Importance: Nonnal Attachments: police__:report.pdf Sanjay: I'm assuming you all are still looking into this. When you decide if you're moving forward, will you let me know? Thanks, Aaron Aaron Fleisher Trial Attorney Special Litigation Section, Civil Rights Division U.S. Department of Justice Phone: Pronouns: he/him/his Ftom: Michelle Davidson --@prochoice.org> Sent: Monday, September 14, 2020o1:37 PM To: Fleisher, Aaron (CRT) ; Fitzgerald, Paige (CRT) Sanjay (CRT) Cc:Tara Gannon ; Emtna Goldberg �prochoice.org> Police Report Subject: Blocl Cc:­ Subject� police report - HI Michelle Here is the police report from she/her/hers in Sterling Heights fromo8/27/20. Manager Centers and any documents, files or CONFIDENTIALITY NOTICE: This email transmission from previous email messages attached to it may contain confidential information that is privileged. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is strictly prohibited. If you have received this email in error, please immediately notify the sender and delete the message and its attachments. EXHIBIT 117 From: To: Subject: Date: Gardey, David (USAMIE) Carlson, Frances (USAMIE) RE: FACE Act prosecutions Tuesday, January 4, 2022 2:16:29 PM Are there any instances of violence by any of the possible targets at any of the other locations like Tennessee or Kentucky? It seems if they used violence at other locations during the course of their protests that it may support doing a prosecution even if the protests in our district were non-violent. From: Carlson, Frances (USAMIE) < AM To: Gardey, David (USAMIE) < Subject: RE: FACE Act prosecutions > ay Sent: Tuesday, January 4, 2022 11:47 > Circling back again. Sanjay/Bobbi have gone ahead to get agents assigned to each incident. (The amount of work to be done is minimal.) We also just had a call with the prosecutor who is handling the 2020 trespass case in Sterling Heights. His case is pending an interlocutory appeal by the prosecution regarding a defense jury instruction that the district court judge granted. However the appeal turns out, they will proceed with the trespass trial but it is a 30 day misdemeanor. He expects they would get 1 year non-reporting probation. If there was a federal prosecution (which he was excited about), he would not proceed with his case. Sanjay and Bobbi would like to know if our office will do the prosecution with them. I think we should. Either way, the Civil Rights Div will proceed with the prosecution. Let me know if you would like to discuss, or whether we should discuss this with Mark again? Frances From: Carlson, Frances (USAMIE) Sent: Wednesday, December 15, 2021 12:25 PM To: Gardey, David (USAMIE) < Subject: RE: FACE Act prosecutions > Re: your question #2, Sanjay is not aware of any FACE Act prosecutions involving non-violent violations yet. But, the posture of the administration and his particular office has changed so expects that there will be. His office definitely plans on moving forward with this and would prefer to do it with us. In addition to the information I provided you before re: the repeated behavior of some of the individuals, here are some additional reasons why the Civil Rights Division wants to pursue this: The clinic in Sterling Heights has been targeted by the organization to which the repeat offenders belong, but not necessarily targeted on a repeated basis by these particular individuals. Given that the repeat offenders travel from clinic to clinic and state to state, a civil enforcement action in EDMI likely will have little effect since any injunction would only prohibit them from engaging in this activity within EDMI. At this point, they would like to know where we stand. I believe they are in the process of getting agents assigned to each incident. Sanjay said he is sure that Bobbi would be happy to discuss this with you if you think it would be helpful. From: Carlson, Frances (USAMIE) Sent: Monday, December 13, 2021 11:44 AM To: Gardey, David (USAMIE) < Subject: RE: FACE Act prosecutions > I’ll find out re: question #1. As to question #2, I am pretty sure “recent events” refers to the Texas law restricting abortion. I believe that was enacted on 9/1/2021. From: Gardey, David (USAMIE) < Sent: Monday, December 13, 2021 11:18 AM To: Carlson, Frances (USAMIE) < Subject: RE: FACE Act prosecutions > > Is Civil Rights aware of any non-violent FACE Act prosecutions that have been done around the country by USAOs, either in response to the DAAG memo or otherwise? Also, do you know what the DAAG memo is referring to when it twice references “recent events”? From: Carlson, Frances (USAMIE) < Sent: Monday, December 13, 2021 10:12 AM To: Gardey, David (USAMIE) < Subject: RE: FACE Act prosecutions > > I have video from three BWCs from Saginaw PD that shows those two women. Our Pros Guidelines don’t directly address repeat non-violent offenders that block entrances as multiple clinics vs. a sustained campaign over an extended period of time. I think prosecution should be considered for individuals who clinic hop and repeat their illegal activity over and over again. From: Gardey, David (USAMIE) < Sent: Monday, December 13, 2021 9:49 AM To: Carlson, Frances (USAMIE) < Subject: RE: FACE Act prosecutions > > Here are some photos of the Saginaw incident. https://www.lifesitenews.com/news/soviet-concentration-camp-survivor-pro-lifer-arrested-forblocking-entrance-to-abortion-center/ From: Carlson, Frances (USAMIE) < Sent: Monday, December 13, 2021 9:41 AM To: Gardey, David (USAMIE) < Subject: RE: FACE Act prosecutions > > I’m in the office today if you want to chat about this. From: Gardey, David (USAMIE) < Sent: Thursday, December 9, 2021 10:40 AM To: Carlson, Frances (USAMIE) < Subject: RE: FACE Act prosecutions > > Hey---as we delve into this issue, attached are the most recent pros guidelines for PCU, which include the updated FACE guidelines on the last page. From: Carlson, Frances (USAMIE) < Sent: Thursday, December 9, 2021 9:41 AM To: Gardey, David (USAMIE) < Subject: FACE Act prosecutions > > Hi DaveSanjay Patel from the Civil Rights Division reached out to me a few weeks ago about that case from Sterling Heights where the individuals blocked the clinic entrance. His management is very eager to pursue the prosecution now given some events that have occurred since then. If you recall, the Sterling Heights blocked happened in August 2020 and resulted in 10 individuals receiving trespassing tickets. I’m in the midst of finding out what happened with those cases but from what I can see, I’m not sure anything did. 2 out of 10 of the individuals had previously been arrested in May 2017 in Kentucky for a blockade (Eva Zastrow and Eva Edl). This resulted in a civil enforcement action by the DOJ. In March 2021, 6 of the 10 individuals that were involved in the Sterling Heights incident were arrested in Tennessee (including the Eva Zastro and Eva Edl who were also involved in Kentucky). In April 2021, Eva Edl and Heather Idoni (who was also involved in Tennessee and Sterling Heights) were arrested in Saginaw for blocking the entrance to a clinic. The Civil Rights Division is interested in pursuing the Sterling Heights and Saginaw incidents for prosecution. The videos are very clear as to what the individuals were doing. As a reminder, once an individual has a misdemeanor FACE Act conviction, a second offense would be a felony. Given the recent directive from the DAG of the Civil Rights Division (see attached), I agree with opening these. I know you had strong opinions back when the Sterling Heights incident happened since there was no violence or damage to the clinic so wanted to run it by you. ThanksFrances Frances Lee Carlson Assistant U.S. Attorney Deputy Chief, Public Corruption Unit Criminal Civil Rights Coordinator Eastern District of Michigan | EXHIBIT 118 'From: "Patel, Sanjay (CRT)" To: "Bernstein, Bobbi (CRT)" Subject: RE: Order dismissing Date: Frj, 06 May 2022 12:35:02 -0400 Importance: No11nal Confirmed that USAO wants to indict, so we should have a combined gj memo to you soon, with charging memos to follow. From: Bernsteih, Bobbi (CRT) Sent: Friday, May 6, 2022 12:34 PM To: Patel, Sanjay (CRT)"._ Subject: RE: Order dismissing Thanks. On a separate note, what's the status of the FACE cases? those mernos looked pretty ready-to-go when I read them. From: Patel, Sanjay (CRT)"._ Sent: Friday, May 6, 2022 12:29 PM To: Bernstein, Bobbi (CRT) Subject: FW: Order dismissing Hi, Bobbi Attached ls the dismissal order for -· Thanks, SP From: Whelan, Traci {USAID)"� Sent: Friday, May 6, 2022 10:58 AM To: Patel, Sanjay (CRT)"._ Subject: Order dismissing Sanjay, Here is the order dismissing the case. Take care, tjw - Traci J. Whelan AUSA/Branch Manager District of Idaho Coeur d'Alene Office EXHIBIT 119 From: "Bernstein, Bobbi (CRT)" To: "Fitzgerald, Paige (CRT)" Subject: FW: detroit FACE Date: Thu, 19 May 2022 1 9;35:58 -0400 Importance: Normal From: Patel, Sanjay (CRT) Sent; Thursday, May 191 2022 6:15 PM To: Bernstein Bobbi CRJ ; Bernstein, Laura-Kate (CRT)"� Subject: RE: detroit FACE I'm persuaded to add the 241. I'll connect with LK about it, and we'll try to get you something asap. We'll also connect with Frances to get herthollghts. From: Bernstein, Bobbi (CRT)"< Sent: Thursday, May 19, 2022 4:52 PM To: Patel, Sanjay (CRT) Subject: FW: detroit FACE ; Bernstein, Laura-Kate (CRT) Fyi. let me know if/when you guys want to chat. and/or if you want to set up a conversation with paige. Fron1: Fitzgerald, Paige (CRT) Sent: Thursday, May 19, 2022 3:20 PM To: Bernstein, Bobbi (CRT) Subject: RE: detroit FACE I've spoken with Jim and Robert (Robert just to get his thoughts, not as a decision-maker). Jim and I both think we should charge the conspiracies in both of the Detroit clinic obstructions and the TN obstruction to come, and Robert is fully supportive. We already charged 241 in the DC matteri which involved one of the Detroit targets (ldoni). Six of the' targets are involved in 2 or more incidents; 1 of those 6 is involved 3 incidents; 1 (ldoni) is involved in all 4 incidents. They knew they were violating FACE and flaunted it despite being given ample opportunity to comply with the law. If we lay down felony markets now, we may dissuade larger,. potentially more dangerous obstructions later, when presumably there will be fewer clinics in operation and thus a smaller number of targets that the extremists can more easily descend upon. And Detroit seems like it would have a jury pool that would be more accepting of the FACE Act than TN (and as mentioned before, we can't assume victory will come i n any of these). Happy to discuss (and to Include Sanjay) If you'd like. From: Fitzgerald, Paige (CRT)"<> Sent: Thursday, May 19, 2022 10:29 AM To: Bernstein, Bobbi (CRT) Subject: RE: detroit FACE I'm talking with Jim and Robert at 11. Also, fwiw,the 86-year old is also in the TN case, along with five others, for a total of 6. And that case isn't charged yet and we can't assume convictions in this world right now, esp. in a place like TN. From: Bernstein, Bobbi (CRT) Sent: Thursday, May 19, 2022 10:21 AM To: Fitzgerald, Paige (CRT) Subject: FW: detroit FACE FYI. Here are Sanjay's thoughts on the 241. Once you read over this, please let us know if you want to set up a time to talk. Thanks! From: Patel, Sanjay (CRT)e� Sent: Thursday, May 19, 2022 8:33 AM To: Bernstein, Bobbi (CRT) Cc: Bernstein, Laura-Kate (CRT) Subject: Re: detroit FACE I still believe that a 248 only is the best play. Be it's a petty offense, we can get a quick trial date before a mag judge. The fast 248 conviction will be more useful than a dragged out felony indictment that may not get to trial for over a year. These subjects are very active, Plus, we have the Nashville 241 memo that will be going to PF soon, so the objective will be served as to five of the subjects (the "leaders"). Ls this worth discussing any further, or shld we just add the 241. (assuming Frances agrees)? On May 19, 2022, at 00:21, Bernstein, Bobbi (CRT) wrote: Talked with paige today. she is very much inclined to charge the 241 s, so that the Ds will have felonies and will be baITed from possessing fireanns. l badn't thought of that angle. Given the gun violence associated with hotly disputed social issues, f think she has a good point. Can you add a 241 to the indictment memo and see if it seems convincing? If so, we can add it to the 'indictment. (do you think the USAO will go along with this?). Thanks, bobbi Bobbi Bernstein Deputy Chief, Criminal Section Civil Rights Division U.S. Department of Justice EXHIBIT 120 From: To: Subject: Date: Gardey, David (USAMIE) Carlson, Frances (USAMIE) RE: FACE Act - charging Thursday, June 2, 2022 3:33:39 PM Got it. I will bring it up with Dawn and Dan at my meeting with them tomorrow and see how Dawn wants to proceed. -----Original Message----From: Carlson, Frances (USAMIE) < Sent: Thursday, June 2, 2022 3:04 PM To: Gardey, David (USAMIE) < Subject: FACE Act - charging > > DaveI had a call with the trial attorneys from the Civil Rights Division. Their bosses feel strongly about the felony charges. If we feel differently, they plan to go forward on their own with the prosecution. Of course, they would prefer to do the case with us so if it would be helpful, they would like to have a call with you and our “front office.” On another note, we interviewed the patient from the Sterling Heights incident today. Probably one of the most compelling interviews I’ve ever had. Her story really highlights the importance of taking these cases seriously. would have charged them $25k to induce her and terminate her pregnancy. Not being able to afford that, they found the clinic in Sterling Heights. When she arrived for her 9am appointment, she was met by the subjects who called her a murderer and worse. Her appointment was delayed by several hours due to the subjects blocking the door. What she went through on the worst day of her life is something no one should have to endure. Like I mentioned yesterday, we are at the point where I think our office needs to make a decision on what we want to do so please let me know what the next steps should be. ThanksFrances Frances Lee Carlson | Assistant U.S. Attorney EXHIBIT 121 From: "Patel, Sanjay (CRT)" To: "Carlson, Frances (USAMIE)" Cc: "Bernstein, Laura-Kate (CRT)" Subject: RE: FACE Act GL ranges Date: Mon, 13 Jun 2022 2 1 :53:31 -0400 Importance: Normal That's great news, Frances! I think that Nashville was on par with these incidents. DC was more egregious be they entered the clinic, injured a nurse, chained themselves together, and forced a very pregnant woman to climb through a receptionist window be of the blockade. From: Carlson, Frances (USAMIE) � Sent: Monday, June 13, 2022 8:12 PM To: Patel, Sanjay (CRT)"� Cc: Bernstein, Laura-Kate (CRT) Subject: Re: FACE Act G L ranges Ah, good to know. Anyway, looks like my USA is on board for the felony. The one question that came Up is whether the condLJct was more egregious in Nashville and DC? I recall that the subjects entered the clink in those cases so perhaps the answer is yes? Fral'lces lee Carlson I Assistant U.S. Attorney On Jun 13, 2022, at 6:00 PM, Patel, Sanjay (CRT)"� wrote: Hey, Sorry for chiming in late. You are both correct! They also get +2 under 301.4 be 241 and 248 do not group. So, 18 for the organizers and 14 for the remainder. From: Carlson, Frances (USAMIE) � Sent: Monday, June 13, 2022 3:02 PM To: Bernstein, Laura-Kate (CRT) Subject: RE: FACE Act GL ranges ; Patel, S-anjay (CRT)"� That's what I catne up with too :: From: Bernstein, Laura-Kate (CRT) Sent: Monday, June 13, 2022 3:01 PM To: Carlson, Frances (USAMIE) �; Patel, Sanjay (CRT)"� Subject: RE: FACE Act GL ranges I think they are both 12s, right? 2Hl.1 is the guideline for both 248 and 241. 2Hl,l(a)(2) starts us at 12 for offenses involving 2+ participants. The organizers will get up to +4 for their role. I don't think vulnerable victim applies. But either way, I think the guidelines are the same. (But I'm new and could totally be missing something!) From: Carlson, Frances (USAMIE) � Sent: Monday, June 13, 2022 2:28 PM To: Patel, Sanjay (CRT)e�; Bernstein, Laura-Kate (CRT) Subject: FACE Act GL ranges Do you happen to know the GL ranges for a misdemeanor vs. felony FACE Act conviction? I'm meeting with my USA today about our case and charging decisions ... Frances Lee Carlson Assistant U.S. Attorney Deputy Chief, Public Corruption & Civil Rights Unit Criminal Civil Rights Coordinator Office I E.D. of Michl an lllillliiiilf EXHIBIT 122 From: ''Bernstein, Lai1ra-Kate (CRT)" To: "Carlson, Frances (USAMCE)" Subject: RE: Memo (EDMI FACE Act case) Date: Tue, 1 8 Oct 2022 1 0:35:27 -0400 Importance: Normal Attachments: EDMI_Indictment_Memo for FACE_violations_-_DRAFT'.docx Hi Frances -here is the draft draft draft memo - Sanjay is hoping to take a look today, but so far this is entirely unreviewed by anyone besides me :) From: Carlson, Frances (USAMIE) � Sent: Monday, October 17, 2022 5:11 PM To: Bernstein, Laura-Kate (CRT) Subject: RE: Memo (EDMI FACE Act case) H i Laura-Kate! It was so n ice to meet you last week! I loved meeting so many people from the Criminal Section and put fa ces to names/voices. Has Sanjay had a cha nce to look at your memo yet? I'm curious if it is very different from the initial GJ Authorization Memo? I'm asking because my USA, who is on the AG's sub-committee for Civil Rights, has requested a memo on the status of this case. Selfishly, it would be so helpful to me to have yours to guide me. Thanks! From: Carlson, Frances (USAMIE) Sent: Thursday, October 6, 2022 9:18 AM To: Bernstein, Laura-Kate (CRT) Subject: Memo (EDMI FACE Act case) H i Laura-Kate: If you don't mind, I'd love to see your charging memo when you are done with it. Thanks! Frances Frances Lee Carlson Assistant U.S. Attorney Deputy Chief, Public Corruption & Civil Rights Unit Criminal Civil Rights Coordinato.r -•� Office E.D. ofiMichi 'an EXHIBIT 123 Memorandum Subject: Proposed Petite Policy Waiver for FederaJ Prosecution of Heather ldoni and Eva Edl (EDMI) Date: DRAFT DJ No. To: K1isten Clarke Assistant Attorney General Civil Rights Division 1. Subjects: 2. Victim: From: James Felte Chief Criminal Section Heather ldoni Eva Edi Saginaw, Micl1igan 3. Date of lncident: April 16, 2021 4. Statute of Limitations: 5 years (April 16, 2026) 5. Venue: Eastern District of Michigan 6. Statute: 1 8 U.S.C. §248(a)( I ) l. Factual and Procedural History The Criminal Section of the Civil Rights Division and the United States Attorney's Office for the Eastern District of Michigan seek authorization to proceed with the prosecution of Heather Idoni and Eva Edl for allegedly blockading an abortion clinic in Saginaw, Michigan. Clinic On April 16, 202 1 , Saginaw pol ice officers were smnmoned to the (herein "Clinic") after they 1· eceived a call of two women blockading their doors. Upon tbeir arrival, officers observed the su·bjects using their bocties to block the Clinic's two entrances. Both subjects admitted to responding police officers that the purpose for the blockade was to preven1 patients from receiving, and cljniciaos from providing, abortion serv.ices. 1 1 The subjects, along witl-11111 others. participated in a blockade at another abortion clinic in the Eastern D-istrict of Michigan, on August 27. 2020. We are consjdering charging federal civil rights conspiracy and FACE Act offenses in that matter. Additionally, subjects ldooi and Edi were indicted (along with - other co-defendants) on October 3, 2022, for the similar offenses committed in the Middle District ofTennessee; and subject ldoni was charged with -2Responding pol ice recorded the subjects blockade o n body worn camera ( B WC ), during which the subj ects made i ncriminating statements . Idoni bad chained herself to a doorframe with a bicycle lock around her neck blocking access, and Edi stood in front of another door that interfered with patients entering and exiting the Cl inic. Both admitted to police officers that it was their intent to prevent women fro m obtai n- i ng abortion s. State authorities m Saginaw C oWJty, M ichigan, charged ldoni and Ed i w ith a state misdem eanor trespass offense. On June J 0, 2022, the subjects were found gu· i l ty after a jury trial . The trespa s conviction cani ed a maxim um sentence of 30 days imprisonment and a fine up to $250 . Each subj ect was ordered to merely pay a $225 fine . The state court disposition left federal interests demonstrably unvindicated. As cli cussed be low , a federa l FACE Act prosecution w i l l vindi ·cate sub tantial federal interests . A conviction wi l l have a significant ·deterren t and p unitive impact because it will make any s ubsequent FACE Act violation by these subj ects a felony. Moreover, the Clinic ' s and its pat i ents ' i nterests wi ll be vindi cated because a FAC E Act prosecut ion wi l l address the spec i fi c hann caused by t b e subjects ' conduct - interference with a federally protected r ight to reproductive health care . I n hght of the prior state court proceedings, the Crim inal Section and the Un ited States A ttorney ' s Office, pursuant to the J ustice Department' s Petite Pol icy. tnust obtain authorization from A s sistant Attorney Genera l Kri sten C larke before it may seek to charge ldoru and Edl. With this· authorization the Cri minal Section and the United States Attorney ' s Office will be prepared to mov forward with fil ing au i ndictment chargi ng the subjects with a v iolation of the FACE Act 1 TI. Applicatio n o f the Petite Policy The Department ' s Petite pol icy , set fmth in Section 9-2 . 03 1 of tbe U.S. Attorney 's Manual , mandates that tlu-ee requirements must be satis fied before a successive federal prosecuti on may beg in or continue : ( I ) the matter must involve a substantial federal interest ; (2) the pri or prosec ution must have left that interest demonstrably unvi ndicated; and (3) the govem roent must bel ieve that the defendant violated a federal stah1te and that the admissible evidence probably wi l l be suffi cient to s us tain and maintain a conv iction by an unbiased ttier of fact. All tlu-ee requiTements are m et here . L Su bstantial Federal [n terest The determinat ion of whether there is a substantial federal interest is made on a case- by­ case basis, applying the princ iples of federal prosec utions found in USAM 9- 27.230. USAM 92.03 1 (D) . USAM 9-2 7.23 0 provides the fol lowing l ist of factors to be considered: e lbe c i v il rights conspiracy and FACE Acl offenses (along with - other co-defndants) i n a supersed ing ind�chnent on October 2 1 , 2022. in the Dist rict of olumbia . Ill 2 W e also anticipate i odicti.11g the subjects and other co-defendants with violat i on s of L 8 U .S.C. § • 24 1 and 248(a )( l ) for t heir participation in an un related abortion clinic blockade in Sterli.ng Heights, M ichigan. -3- A. Federal Len Enforcement Priorities This factor supports federal prosecution . F01111a l d partment po licy has declared c iv i l rights prosecuti ons a high pri ority for federal law en forcement. See FB I Website, at www . tbi .gov/hq. htm (identifying civi l rights prosecut ion as one of nine maj or iovestigat i v primi tie ) . 8. The Nature and Seriousness of the Offen e We bel ieve that this factor, on balance , .supports federal prosec ution. Although the crime with which we propose to charge the subj ects is a misdemeanor, the conduct in wh.ich Idoni and Edi engaged was quite serious and inte ,fered with numerous individual s who work at , or are patients of. the c linic. Department policy places primary importance on "the act ual or potential impact of the offense on the commun ity and on the vict im,'' U SAM 9-2 7.230 ( 8 )( 2 ) , and acknow ledge that the effect can be measured � among other ways "in terms of erosion of the inhabitants' peace of m ind and sense of secmity .'' Id. Additionally, federal prosecution of this case serves an important federa l interest that stems from the unusual strncture of the FACE Act. The statute specifie that a first-time offense that does not result in inj ury or death is a misdemeanor. However , the statute also p rovides that a subsequent conviction for the same conduct const itutes a fe1oli .y . H ere, neither ldoni nor Bdl have a pri or FACE Act conv jction. Although the y have pen d in g FAC E Act p rosecuti ons in other di stricts , we have no guarantee that the y will be convicted in the cu,rnnt post-Dobbs3 cl imate where many states have prohibited ab011ion care , or seek to do so . We antici p ate facin g hosti lity i n these other district where we are p ursuill g FACE Act prosecutions a ga·i nst ldon i and Ed i , both from the j udiciary and the venire . Thus, it i s imp ortant to p rosecute the e subj ects federal ly in the Eastern Distri ct of Mich i gan for their conduct, so that the federal g overnment can seek a con v i ction thal will a l low for an app ro priate res ponse. if and when the SlLbj ects strike ag ain. C. Deterrent F;/fect of Prosecution Th is facto r su pp ort federal p rosecution . Federal _'p rosecution in this case would have a deterrent e ffect b y sending a messag e to the s ubj ects and others who share their desire to obstruct access to rep roductive hea lth services. A lso, as noted above, p rosec ution for th is misdemeanor i s a necessary prere quisite for any felony prosecution for si m i lar m i sconduct i n the future. Additi ona l l y , since the Eastern District of M ichi gan is home to seve ral rep roducti ve hea lth serv ice facil ities. the deterrent effect of a successful prosecution of these subj ects would be a signi ficant one. D. The Subjec1s • Culpability in Connection with the Offense ', Dobbs v. Jackson Women,'s Heaflh Org. , J 42 S .Ct. 2228, 2 2 79 {2022 ) ( holding that t l1e Constitution does not confer a right to abortion and overruling Roe v. Wade). -4l doll i and Edl ' s c ulpabi l ity i s eas ily provable based upon the BWC footage from the i ncident. Both subj ects princ i pa l ly b l ockaded the C l i nic 's doors and te-fused to move. rdon i used chains and locks to b ind herself StLCh that respondi ng pol ice were forced to use bolt cutters to remove the restrai nts. The subj ects admitted to intentional ly blockading the c l inic to interfere w ith the Clini c ' and i t s patients ' because they were exerc i s i n g thei r reproductive hea l th care r ights . The subj ects were eq ual participants in this obstruct i ve conduct, and their ev ident motivation was criminal. E. The Subjects ' Personal Circumstances The ubject are well known to federa l author ities for their involvement with anti-abortion activi ties nat ionw ide. l.n addition to their participati on i n b lockades that are current ly pendi n g F A C E Act prosecutions in o ther di stricts, Edl w a s a defendant in a c ivil F A C E Act s uit filed by the Spec ial Litigation Section in 20 1 7 .'4 In th at case, Edi was found to have viol ated tbe FAC E Act. 5 l doni has trave led aroun d the country to partic i pate in si m i l a r bl ockades involving chai n s and locks . [ n some cases, l doni w a s a n organ izer a nd l eader of the blockade. H ere video footage from responding pol ice officers ·· BWC show the s ubj ec ts actively blockading the Clinic's doors . As those o fficers engaged with the subjects , they re fused to l eave, and i nstead repeated l y exp l ai ned t hat they wou l d con tinue bl ocking the doors and wou1d rather be arrested than leave vol untari l y . The s ubjects' harbor strong anti-abortion bel iefs and are knowo to be associated witb extrem j st groups, which sugge sts that they are l ikely to commit si m i l ar conduct in the future. In l ight of the subj ects ' backgrou nds, this factor weighs in favor of prosecution by federal authorities . F. The Victims'' interests The Cli nic and their corresponding national Non-Govemmental Organ izations (NGO) stakeholders are very committed to pursuing a federa l prosecution. The Clinic has i nfonned the FBI that they are rout i nely targeted by anti-a bort i on protes ters, and that the subj ects ' conduct · i n this ca e was an egregi ous example of activity that ha a profound psychological impact on the Clini c ' s staff and its patients. For example, BWC footage from the blockade captured the statement of the Cl inic ' s manager, admorr ishing respondi ng po lice officers for negotiati ng with the subj ects prior to arrests. who is B lack, tated "If tbi was me laying out here, 1 'd have six s hots i n my back right now . " S i m i l a rl y , NG Os, including the N ational Abortion Federation and Fem inist M ajority Fo u ndation , have on several occasions contacted federal authorities and expressed their and the Cl inic · s stTong interest in the Department of J usti ce ptµ·su ing a federal FAC E A ct prosecuti on here . G. The Probable Sentence 4 See U. S. v. Tho111t1s, et al, l 7-cv-43 2 (WDKY). 5 A prior c i vil FACE Act vio lation does not e1ve as a prerequisite for ubseque111 felony charges. The prjor conviction must be a criminal offen se. -5This factor also weighs in favor of federal prosecution. The subjects were sentenced in state coll11 to s·imply pay a fine of $225 each. A FACE Act conviction wil.l provide a conviction U1at will serve as a prerequisite for a future felony charge for similar conduct. The subjects have demonstrated, and all but admitted, that they will continue to engage in obstructive conduct that interferes wit11 the provision of abortion care because of their strongly held ideologies. Through this prosecutjon, we may be able to bring future felony charges against the subjects. I n summary, consideration of the factors listed in USAM 9-27.230 demonstrates that there is a substantial federal interest in this case. 2. Substantial Federal lnterest Demonstrably Unvindicated The second requirement for obtaining a Petite policy waiver is that the prior prosecution must have left a substantial federal interest demonstrably unv.indicated. USAM 9-2.031 (D). Although lhe Petite policy generally presumes that a prior state prosecution vindicates federal interests, this presumption is rebuttable. In this case, the presumption should not apply because the federal interest in the subjects' obstruction of the community's freedom of access to climes was not addressed by the state trespass conviction. Additionally, a successful federal prosecution 1s necessary to v:indjcate th.is interest because the instant federal prosecution of a misdemeanor offense will allow federal authorities to bring felony charges ag�inst the subjects in the case of a subsequent offense. The misdemeanor FACE Act conviction coupled with the prospect of future felony charges for similar conduct vindicates the substantial federal interest. 3. Likelihood of Conviction of a Federal Offense Finally, for a waiver of the Department's Petjte policy to be appropriate, the government must believe that the subject's conduct constituted a federal offense, and that the adrnissible evidence probably will be sufficient to obtain and sustain a conviction by an unbiased trier of fact. USAM 9-2.031 (D). In this case, the subject were video recorded blockading the Clinic's entrances. 1n that same recording, the subjects admitted that it was their intent to prevent the Clinic from providing, and its patients from obtaining, abortion care. Coupled with witness testimony, we believe that the admissible video evidence will easily prove a FACE Act violation beyond a reasonable doubt UI. Conclusion This case wa1i-ants federal prosecution because the state prosecution alone will not have the same deterrent effect as a federal conviction. The subjects have both demonstrated and admitted that they will continue to engage in obstructive conduct that targets ab011ion providers and patients. With a misdemeanor FACE Act conviction here, the subjects can be charged with a future federal felony. Federal prosecution in this case will also vindicate a strong fedetal interest. We therefore seek approval from Assistant Attorney General Kristen Clarke to prosecute Heather ldoni and Eva Edl fot• a violation of 1 8 U.S.C. § 248(a)(I ). EXHIBIT 124 Memorandum ·SP:LKB:pg Proposed Petite Policy Waiver for Federal Prosecution of H d • va Edl Clinic (EDMJ) Subject: Kristen Clarke Assistant Attorney General Civil Rights Division 1'o: Through: _From: Robert J. Moossy, Jr. Deputy Assistant Attorney General Civil Rights Division Date: November 30, 2022 JamesdFelte Chief Criminal Section Paige Fitzgerald Principal Deputy Chief Bobbi Bernstein Deputy Chief Sattjay Patel Laura-Kate Bernstein Trial Attorneys 1 . Subjects: Heather Idoni EvadEdl 2. Victim: Clinic Saginaw, Michigan 3. Date of Incident: April 16, 2021 4. Statute of Limitations: 5 years (April 16, 2026) 5. Venue; Eastern District of Michigan 6. Statute� 18 U.S.C. §248(a}(l) I. Introduction The Criminal Section of the Civil Rights Division and the United States Attorney's Office for tne Eastern District of Micbigan seek authorization to pursue prosecution of Heather ldoni and Eva Edi, for a misdemeanor violation of the FACE Act, despite a previous prosecution by the state, wbich resulted in a $225 fine, related to one of two incidents currently subject to federal charges. In light of the prior state court proceedings, the Criminal Section and the United States Attorney's Office, pursuant to the Justice Department's Petite Policy, must obtain authorization from Assistant. Attorney General Kristen Clarke before it may seek to charge Idoni and Edl for the -2- charge related to the same incident for which she was prosecuted by the state. If authorization is granted, the Criminal Section and the United States Attorney' s Office will be prepared to move forward with filing an indictment charging the subjects with a violation of the FACE Act. 1 II. Factual and Procedural History Clinic On April 16, 2021, Saginaw police officers were summoned to the (herein "the Clinic") after they received a call oftwo women blockading their doors (while dozens ofprotesters demonstrated on the adjacent sidewalk). Upon arrival, officers observed the subjects using their bodies to block the Clinic's two entrances, while the sidewalk protesters video recorded the incident. Both subjects admitted to responding police officers that the purpose for the blockade was to prevent patients from receiving, and clinicians from providing, abortion services. Additionally, responding police Tecorded the subjects' blockade on body worn cameras (BWC), during which the subjects were recorded committing the offense and making incriminating statements. Idoni had chained herselfto a doorframe with a bicycle lock around her neck blocking access, and Edt stood in front of another door that interfered with patients entering and exiting the Clinic. State authorities in Saginaw County, Michigan, charged ldon1 and E-dl with a state misdemeanor trespass offense. On June 10, 2022, the subjects were found guilty after a jury trial. The trespass conviction carried a maximum sentence of 30 days imprisonment, and a fine up to $250. Each subject was ordered merely to pay a $225 fine. This state court disposition left federal interests demonstrab.ly unvindicated. As discussed below, a federal FACE Act prosecution will vindicate substantial federal interests. A conviction will have a significant deterrent and punitive impact because it will make any subsequent FACE Act violation by these subjects a felony. Moreover, the Clinic's and its patients' interests will be vindicated because a FACE Act prosecution will address the specific harro caused by the subjects' conduct- that being the psychological impact caused by the subjects' interference with a federally protected right to access and provide reproductive health care. Specifically, the Clinic's staff has complained about the fear and intimidation the subjects and their associates caused when the protesters filmed staff and patients accessing the Clinic during the instant blockade. The deterrent effect of a FACE Act prosecution would help assuage these concerns. TTI. Application of the Petite Policy The Department's Petite policy, set forth in Section 9-2.031 of the Justice Manual, mandates that three requirements must be satisfied before a successive federal prosecution may begin or continue after resolution of a state prosecution: (1) the matter must involve a substantial 1 We also anticipate indicting the subjects and ..other co•defendants with violations of 1 8 U.S.C. §§ 241 and 248(aXI) for their participation in an unrelated abortion clinic blockade in Sterling Heights, Michigan. Additionally, subjects Idoni and Edi were indicted (along with nine other co-defendants) on October 3, 2022, for the similar offenses committed in the Middle District ofTenncs�ce; and subject Idoni was charged with civil rights conspiracy and FACE Act offenses (along with nine other co-defendants) in a superseding indictn,ent on October 2 l, 2022, in the Distrtctof Columbia. These charges do not implicate the Petite policy. -3federal interest ; (2 ) the p rior prosecution must have left that interest demonstrably unvindicated; and (3 ) the government must believe that the defendant violated a federal statute and that the admissible evjdence p robabl y will be sufficient to sustain and maintain a conviction by an unbiased trier of fact. All three re q uirements are met here. 1. Substantial Federal Interest The determination of whether there is a substantial federal interest is made on a case-b y ­ case basis, appl yin g the princi p les of federal prosecutions found in JM 9-27 .230. JM 9-2 7.230 provides the following list of factors to be considered : A. Federal Law Enforcement Priorities This factor supports federal p rosecution . Fonnal department policy has declared ci vil ri g hts prosecutions a hi gh priority for federal law enforcement. See FBI Website at hU s:// ww. fbi. J v/aho ut/rn is ·i n/ lbi- ·trut , ( identi fy ing civil ri ghts as one of ei ght mission priorities ) . In fact , fol lowin g the Sup reme Court' s decision in Dobbs v. Jackson Women '.s Healh 2 , Attorney General Garland announced that, 'The Justice Department will work tirelessly to protect and advance rep roductive freedom , " and that "the Department wi ll continue [to use the PACE Act] r to p rotect healthcare p roviders and individuals seeking re productive health sevices." See Attorney o urt • u l i ng i n D bbs . Ja k n Wom1:n · • n r I Merrick B. Garl nd . 't temcnl • n l lcalt ll nI P I B. The Nature and Seriousness of the O.Qense We believe that this factor on bal ance also su pports federal p rosecution. Although the specific federal crime that gives rise to invocation of the Petite Polic y is a misdemeanor, the conduct in which ldoni and Edl eng aged was q uite serious and interfered with numerous individual s who work at, or are patients of, the CliJ1ic. De partment p olicy p laces p rimary importance on ''the actual or potential im p act o f the offense on the community and on the victim , " JM 9-27.230 and acknowled g e that the effect can be measured , amon g other ways ,' ' in tenns of erosion of the inhabitants 1 p eace of mind and sense of security." !d. Additionally, federal prosecution ofthis case serves an important federal interest that stems from the unusual structure of the FACE Act. 'Phe statute speci fies that a first-time offense that does not result in injury or death is a misdemeanor. However, the statute also provides that a subsequent conviction for the same conduct constitutes a felony. Here, neither ldoni nor Edl has a prior FACE Act conviction. Although nei ther defendant has been convicted of a prior FACE Act violation both have committed (and been charged with) other violations. As repeat offenders, they are more culpable than other one-time violators. Additionally, they have made statements indicating that they intend offend again when given the opportunity . The likelihood of reci cliv ism Dobbs v. Jackson Women 's Health Org. , 1 42 S.Ct. 222 8, 2279 (2022) (ho lding that the Constitution does not confer a right to abortion and overruling Roe v. Wade). 2 -4- makes it important for the government to pursue a misdemeanor FACE conviction now, so that any future offense will be a felony. 3 It is important to prosecute these subjects in the Eastern District of M i chigan for their conduct, so that the federal government can seek a conviction that wil l al l ow for an appropriate response i f and when the subj ects engage in further criminal activity . C. f Deterrent Effec/ o'Prosecution This factor supports federal prose cution . Federal prosecuti on i n this case would have a deterrent effect by sending a message to the subjects and others who share their desire to obstruct access to reproductive health services. Also, as noted above prosecution for this misdemeanor i s a necessary prerequisite for any fel ony prosecution fo r sim i l ar misconduct in the future . Add itionally, s i nce the Eastern District o f M ichigan i s home to several reproduc tive health service faci l ities, the deterrent e ffe ct o f a succ essful prosec ution of these subj ects would be a sign ificant one. D. T he Subjects'' Culpability in 'onnection with the Offense I doni and Edi ' s culpability i s easily provable based upon the B WC footage fro m the incident . Both subj ects principaJ ly bl ockaded the C l i n ic ' s doors and refused to move . ldoni used chains and locks to bind hcrsel f such that her arrest was del ayed because respond i ng po lic,e had to acq uire bolt cutters to remove the restraints. The subj ects admi tted to intentionally b lock adi ng the C l i ni c to in terfere with i t s prov iders and patients because they were exercising their reproducti ve health care ri gh ts . The su bj ects were eq ual participants in thi s obstruc tive conduct, and their e v i dent moti vation was criminal. E. The Su bjects ' Personal Circ umstances The s u bj ects are well known to federal autho ri ties for their involv ement i n ac t iv ities nati on w ide t hat v i olate the FACE A ct. I n additi on to the ir parti cip ati on in bl ockades that are c ur ently pendin g FA C E Act pro secution s i n o ther d istri c ts , Edl was a d efendant in a ci vil FACE Act suit Jil ed by the Special L itigat ion Sectio n in 2 0 1 7 . 4 In that case Edl was found to have v i o l ated t he FACE Act. 5 Idon i has traveled around the co untry to partic ipate in sim i lar blockades in vol v i ng chai ns and l ocks . In some case , ldon i was an organizer and l eader o f the blockade . Although an y FACE Act con v iction-incl uding one that might result from the pending M DTN prosecution, or from the FA CE Act charge that wi l l be included in the current indictment but wh ich is not sub ject to Petile analysis-would also serve to make any future violation a feloniy, the mere poss ib ility of a conviction for another v iolation does not lessen the federal interest in pursu ing a FACE Act violation in this instance. Despite the stren gth of the evidence in those other cases, there are j ury nullification risks in these m atters and there is no guarantee that any of those charges wi ll result in convictions , Thus, it is important to pursue charges for all of the defendantsi' multiple vio lations, in order to ensure that future violations can be charged as felonies. 3 4 See U. S. v. Thomas, et al, 1 7-cv-43 2 (WDKY) . A -pr ior civ i l FACE Act v iolation does not serve as a prerequ isite for .subsequent felony charges. The prior convict ion must be a criminal offense. 3 Here, video footage from responding police officers' B WC show the subjects actively blockading the Clinic ' s doors. As those officers engaged with the subjects, they refused to leave, and jnstead repeatedly explained that they wouJd continue blocking the doors and would rather be an·ested than leave voluntarily. Edi and Idoni have close affiliations with the extremi st organization Operation Save America (OSA), which has over the years, sponsored mul tiple blockades of abortion clinics nationwide. In 20 1 7 1 OSA advertised and promoted a blockade in Louisville, Kentucky, that Edl participated in and was prosecuted for civilly by the Special Litigation Section; and in JuJy 2022, OSA sponsored blockades of clinics in Nashville, Tennessee that are the subj ect of a ci vil FACE Act suit brought by the providers . The subjects' adherence to the extremist positions of this group make recidivism almost inevitable. In light of the subjects' backgrounds and history, this factor wei ghs in favor of federal prosecution. F The Victims ' Interests The victims at the Clinic are very committed to pursuing a federal prosecution . These vi ctims have informed the FBI that they are routi nely targeted by anti -abortion protesters, and that the subj ects' conduct in this case was an egregious example of activity that causes extreme fear on the part of the Cl inic ' s staff and its patients. Representatives from national Non-Governmental Organizati ons (NGOs) have also expressed fear for their stakeholders in other places. Footage from th i s incident showed a large group of regular protesters, including a subj ect well known to federal authorities (Cal vin Zastrow), who is a known leader and organizer of blockades nationwide. Zastrow, who is al so the subject of the related FACE Act investigation in Sterling l [eights, Michigan, and a defendant in the pending FACE Act prosecution in the Middle District of Tennessee, has close ties with ldoni and Edl. The Clinic's NGO representatives, who are very familiar with Zastrow, l doni and Edl from blockades that have targeted their other member-clinics nationwide, have expressed their concern about these subjects targeting other cl inics-frightening and endangering other victims-if the subjects &1·e not prosecuted here. G. The Probable Sentence This factor also weighs in favor of federal prosecuti on. The subjects were sentenced in state court to simply pay a fine of $225 each. A FACE Act con viction will provide a misdemeanor conviction that will serve as a prerequisite for a future felony charge for similar conduct. The subj ecl<, have demonstrated, and all but admitted, that they will continue to engage in obstructive conduct that interferes with the provision of abortion care because of their strongly held ideologies. Thro ugh this prosecution, we may be able to bring future felony charges against the subjects that would hopefully act as a deterrent, if not to them, then to others. In summary, consideration of the factors listed in JM 9-27 .230 demonstrates that there is a substantial federal interest in thi s case. 2. The second requirement for obtaining a Petite policy waiver is that the prior prosecution must have left a substantial federal interest demonstrably unvindi cated. JM 9-2.03 1 . Although the Petite pol icy generally presumes that a prior state prosecution vindicates federal interests, this presumption is rebuttable. In this case, the presumption is overcome because the federal interest -6. in the subjects' obstruction of the community's freedom of access to clinics was uot addressed by the state trespass oonvictiou. The Clinic and their NGO representatives have repeatedly requested that federal authorities investigate the incident and bring a FACE Act prosecution to deter the subjects from victimizing other clinics in the future, and becaw�e of the psychological impact of this incident specificaUy, and anti-abortion activity at the Clinic generally, on the staffand patients. Both groups have reported experiencing fear and anxiety after the subjects blockaded the Clinic as dozens of protesters encouraged their criminal conduct and antagonized patients in the Clinic's parkjng lot. Adclitio_nally, a successful federal prosectitiot1 is necessary to vindicate this interest because the instant federal prosecution of a misdemeanor offense will allow federal authorities to bring felony charges against the subjects in the case of a subsequent offense. A misdemeanor FACE Act conviction coupled with the prospect of future felony charges for similar conduct will serve as a deteITeut for future criminal acts and vindicate the substantfal federal interest. 3. Likelihood of Conviction of a Federal Offense Finally, fol" a waiver of the Deparlment's Petite policy to be appropriate, the government must believe that the subject's conduct constituted a federal offense, and that the admissible evidence probably will be sufficient to obtain and sustain a conviction by an unbiased trier of fact. JM 9-2.03 1 . 1n this case, the subjects were video recorded blockading lhe Clinic's. entrances. h1 that same recotding, lhe subjects admitted that i t was their intent to prevent the Clinic from 13roviding, and its patients from obtaining, abortion care. Coupled with witness testimony, we believe that the admissible video evidence is sufiicient to establish a FACE Act violation beyond a reasonable doubt to a fair and impartial jury. IV. Conclusion This case warrants federal prosecution because the state prosecution alone did not vindicate the victims' interests, and does not have the same det�rent effect as a federal conviction. The subjects have both detnonstrated and admitted that they will continue to engage in obstructive condtlCt that targets abortion providers and patients. With a misdemeanor FACE Act conviction here, the subjects can be charged with a future federal felony. Federal prosecution in this case will also vindicate a strong federal interest We therefore seek approval from Assistant Attorney General Kristen Clarke to prosecute Heather Idoni and Eva Edl for a violation of 1 8 U.S.C. § 248(a)(l ). 0Not Approved Kristen Clarke EXHIBIT 125 From: "Patel, Sanjay (CRT)' To:t" , "Bernstein, Laura-Kate (CRT)" Subject: RE: recap of arraignment dates Date: Fri, 1 0 Mar 2023 08:50:31 -0S00 Importance: Normal Inline-Images: image0O l .png Ugh...always a veritable circus with these cases. Thanks for the update! From: Carlson, Frances (USAMIE) � Sent: Friday, March 10, 2023 8:46 AM To: Patel, Sanjay (CRT)n-; Bernstein, Laura-Kate (CRT) Subject: RE: recap of arraignment dates There were about 20-30 people that protested outside the courthouse. Fortunately, not the side that we use! Then, I'd say about 15-20 of them came into duty court to watch the arraignments, which were LONG. U nfortunately, we ended up with a very Catholic magistrate on duty this week and he was very particular about the bond conditions and not infringing on their first amendment rights. At the end, we ended u p with overly lawyered bond conditions that would be difficult to enforce! From: Patel, Sanjay (CRT)n� Sent: Friday, March 10, 2023 8:19 AM To: Bernstein, Laura-Kate (CRT) Subject: RE: recap of arraignment dates >; Carlson, Frances (USAMIE) < Happy Friday, LK and Frances Any update on how this week's appearances went? Any grandstanding outside the courthouse? Thanks, SP From: Bernstein, Laura-Kate (CRT) Sent: Monday, February 27, 2023 4:18 PM To: Patel, Sanjay (CRT)n_ Subject: FW: recap of arraignment dates FYI From: Carlson, Frances (USAMIE) Sent: Monday, February 27, 2023 3:59 PM To: Michael Miedona ; Doddamani, Sunita (USAMIE) Subject: recap of arraignment dates Def number DEF 1 2 3 4 5 Arraignment Date Calvin Zastrow Chester Gallagher Heather tdoni Joel Curry 6 Justin Phlllips: 7 8 Eva Edi Eva Zastrow 3/7/2023 - --+-- - 3/7/2023 3/6/2023 3/14/2023 3/16/2023 3/6/2023 3/14/2023 3/7/2023 Frances Lee Carlson Assistant U.S. Attorney Deputy Chief, Public Corruption & Civil Rights Unit Criminal Civil Rights Coordinator U.S. Attorney's Office I E.D. Michigan - ! EXHIBIT 126 '< From: To: "Bernstein, Laura-Kate (CRT)"t< Subject: Re: FACE voir dire (LK) (w bb edits) Date; Stm, 1 7 Mar 2024 2 1 :0 1 :0 l -0400 Importance: N01mal Or just add a few places like NPR and whatever tl1e local liberal stations are. Happy to chat thru the other concern i f you wanl I might be more conservative than most on this, but to me there's a difference btw the court saying something on its own & US proposing it, and also a difference difference between asking the court to say something injury instructions versus asking the court to say it injury selection. Say hi hi to frances for me! Sent from my iPhone On Mar 17, 2024, al 7:52 PM. Bemstein, Laura-Kate (CRT) wrote: Thanks! I will definitely run these by Frances. The abortion question is I think verbatim from DC, but I get that DC and EDMI may be two very different places. For the list of news sources -those are all of the places that Steve Crampton (on of the defense attorneys} has been on his press rampage claiming that the gov is persecuting Christians for praying for mothers. I can leave it at the more general "have you heard about this case in the news'' though. From: Bernstein, Bobbi (CRT)"< Sent: Saturday, March 16, 2024 7: 8 To: Bernstein, Laura-Kate (CRT) < Subject: FACE voir dire (LK) (w bb edits} LK: see my comments/questioos. l think l might have a different view on some of these than the folks who have gone before. I've mostly tried cases in front of southern, conservative judges, and it's easy for me to see some of tbem being upset by some of these proposals (the questions that seem very one-sided). I love what you're trying to do, but I worry that it might backfire, That said, I would defer heavily to frances, who will know the judge. Please just nm some of my concerns by her and see what she thinks. Happy to chat, anytime. bobbi EXHIBIT 127 . "Doddamani, Sunita (USAMdlE)" Subject: proposed voir dire lmportance: Nom1al Attachments: U.S ._v._Zastrow_et_al_gov _proposed_volt_dire_S. 1 d5.docx I deaned up our previous list and took out the questions already covered by the questionnaire. Here1s what's left. I'm frankly less concerned about proposed voir dire now that we've got the questionnaire - I feel like following up on the answers to the questionnaire will be what we need. Itook out the one about religion, because I think we'd decided it would never fly, but if ybu remember differently oi- have another way to ask the question we can add to this! Sita, I know you'd talked about asking specifically about religion, how often people go to services, etc..Ym just struggling to think of an anodyne way to ask the question. Laura•Kate Bernstein Trial Attorney Criminal Section Civil Rights Division U.S. De artment of Justice EXHIBIT 128 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MlCHlGAN SOUTHERN DNlSION UNITED STATES OF AMERICA, Case No, 23-cr-20100 HON. MATTHEW F. LEITMAN V. D-1 CALVIN ZASTROW, D-2 CHESTER GALLAGHER, D - 3 HEATHER IDONI. D-5 JOEL CURRY, D-6 JUSTIN PHlLLIPS. D-7 EYAoEDL, artd D-8 EVA ZASTROW, __ _ _ _ _ _ _ Defendants. _t _ ! GOVERNMENT'S PROPOSED V0IR DJRE QUESTIONS The Government hereby submits the following voir dire questions for the Court's co11sideration. Respectfully Submitted_ DAWN N. [SON United States Attomey Frances Lee Carlson Sunita Doddam.tni Assistant United States Attorne s Detroit, Michigan 48226-32o1o1 -., �ltv(!r-'-=­ La-ura-K.ate Bernstein Trial Attorney Civil Rights Division, Criminal Section U.S. Dep1:1rtrnent of Justice 950 Pen11sylvania Ave. NW Washin on, DC 20530 2 UNITED STATES OlSTRlCT COURT EASTERN DJSTRICT OF M1CHJGAN SOUTHERN DJVJSION UNITED STATES OF AMER[CA, Case No. 23-cr-20100 HON. MATTHEW F, LEITMAN V. D-L CALVTN ZASTROW, 0-2 CHESTER GALLAGHER, D�J HEATHERo.IDONI, 0-5 JOEL CURRY, D-6 JUSTIN l>H[LLIPS, D-7 EVA EDL,oand D-8 EVA ZASTROW, _ _ _ _ _ _ _ Defendants. _a _a _a _ ! GOVERNMENT'S PROPOSED VOlR DIRE QUESTIONS I . Are you familiar with the facts ofth.is case from any source? Clinic is localed a 2. The Sterli11g Heights, Ml Do any ofyou work or live in the area of -in Sterling Heights? 3. The Clinic is located at MI. Do any of you workor live in the area of Saginaw? 4. The government is represented by Assistant United States Attorneys Frances Carlson and Sunita Doddamani from the United States Attorney's Office for the Eastern Distiict ofMicbjgan and Tro i .al Attorney Laura-Kate Bernstein from the OeparhJ1ent ofJustice's Civil Rights Division, and they will be assisted by paralegal Maria Koch. a. Do any of you know these individuals? b. Have you ever worked for or otbetwise dealt with the United States Attomey's Office or the Department of Justice's Civil Rights Division? 5. The defendants in this case are Calvin Zastrow, Chester Gallagher, Heather Idoni. Joel Curry, Justin PbjJlips, Eva EdL and Eva Zastrow. Do any of you know: a. Calvin (also knowu ;1:, ''Cal"} ZastTOw? b. Chester (abo known as ··Chet") Gallagher? c. Heather fdoni? d. Joel Curry? e. Justin Phillips? f. Eva Edi? g. Eva Zastrow? 6. Other thau Defendant� Heather ldoni and Ch�ster Gallagher, who haves elected to represent hen;elf themselves in tllis case, tbe defendants are each represented by defense counsel. Do any of you know: a. Arthur Weiss? b. Bradley Friedman? e. BrenAaA TylerHroe-k-5-'.? LStephen Crampton? d. Pmtl Stablein'? e. (Counsel for Defendant Cunvj� f. David Peters? g. Lisa Dwyer? h. PameJla Szydlak? 7. Are any of you familiar with the Thomas More Society? 8. Are any of you familiar witb the Pacific Justice institute? 9. Does any member of the panel know any other member of the panel, for example from work, school, socially, prior jury service, or one's neigbborhood? JO. 2 1 1 . /\re any ofyou famiffar with [defense witncsscs)'?[Defendants· ·...-itne..,,,n] 12. In this case, you may hear testimony from federal and local law enforcement officers. Would any of you be inclined to give greater or lesser weight to a law enforcement officer's testimony than that of other witnesses, simply because of their status as a law enforcement officer? l3.During this trial, ymunay learn that the government has entered into a cooperation agreement or cou1t-approved plea agreement with a witness. You may hear that. as part of an agreement tbe witness has agreed to testify in the hopes of receiving more lenient treatment by law enforcement in rehlm for truthful cooperation with the government. Agreements such as these are lawful and the government is permitted to enter into them. a. Do you have any opinion - whetber positive or oegative - about witnesses who testify for the prosecution under such agreements? l<1. Haye you ever sep1ed onagrandjury? a.. if;·e3, proYide tile details. i1rnlucling wlmt couf4; 15. Ha,.,e you · ,t fr-_l➔__Althougb this case w i ll mention abortion, I want to be clear that thi s case is not about whether abortion is right or wrong, morally justified o r u nj ustified . or is it about whether abortion should or should not b e legal . �ne of those tl=tiAgs are re(e,;ant to this case. This case is about two laws that pennit reproducti ve health c linics - i ncluding clinics that provide abortion serv ices - to do so without physical obstruction . Having said that, T will ask whether you have any persona l, political, moral, or religious opi nions or bel iefs rega rding the i ssue of reproductive health care inc luding abottion.- that are so deeply held that they coul d interfere with your abi l ity to be fair and impartial in this case? �o yo1:1, a family membaF;-efii cl-Ose friend belong lo auy gro1:1p or organization or contribute Lo any group or organizalioo that advocates for or 4 "eheat1eaiemch:1dmg, II ... • but Flotlin1ited to. against aay aspectof reprodU£tiv abOltion. 15. !--lave you,afamily rnen3ber, oraclose friende " • •et• p01.•t1•e1pated IA any protest, march, or rally, or peft' 110ncdor contacted •�o·•crnirent . representatt\·es, Fegardin-g-reproduotive health ca-r� � • fnend eve�· observed any • 26.Have you,afamilyme beJ'• OIaclose reproductive health car�protests, marches, or rallies on either side ofthe � 27.Although this case will mention r 1•o s elt�fs,Iwant to be_ clearthat this � ::! ;oats1:are: case is not about wlletber you sh 1 agree_ordisagree, with .,.IiC}tplam dCI.a , fullyto 1i e�aw •h,chJwl any particular religious beljef· Ull .,,_-, w t . . f �)'ata theen d oftrial• i e ue ief, howe¥e-F ud 1. 1 th oneeom1mtsaer1m _a H er • e . . smcere, thathisor her conducta,,, s reli o,�_slyor_mornlly re�ui:red, that is no �; ;�11 a,tAg said that,Iwill ask wheaior defense to aie commissioA ofaa . t ofthe _law; that is, would you have anyhesitation regardi:e: o::·. aspc? .· :agl:ult�•' anybody have any difficulty rendc1m HerdieEag�msta·� - 11·gto . us ormoral beltef? whose crime was committed outof1e T!,e.:following questions €t-pp/y on(�·to)'Ou. l to �o, every.1uror rnustagree 28.To reachaverdict, asjurors will takeano . aH .aI d1·b • ns u to the•;erdict. That is, any"erdi tmustb � c eunammolls .a : nae• erat1o , yo . , f t . p i.l e final fellowJ. u ro r s. In must consider the opiB1ons and o �1 so )Oura t .a Would sonall),satisfied with any verdict• n analysis, however, you must beP _ae:a w optA "e aAv you hav Jd1'ff 1e1:1Jt,y expressmg yourO'"H • I•OASand thoughts aao=at this case to fellowjurors? • TIM6Eetry, tmtilarm:tnd D� 29.Iexpcet thi-s case to takeaPPr _ao •mately ;; \"le will nothold trial on"a 1tpnla-:J or 14 Does aayeeeha e any pressing • . .a _a? "itf•nooontisJu �'a commitmelltt"1at would make� R ryahardship 30. Does anyone,due to health problem , meEHcati•on, or the Like, feel that they l:S cannotsit on thisjury?a • • tliatwould make il 31. Does anyone EHlYC a11y El'ffc i �I� ,seeiagor_heanng 7 .a �a Am • this • case or djfficult forJ vou to �ollo"'. .rorIece1ve tue e"1dence prcsenteu ,,' u "' fer which you Ould eedaaa aecommodatrna? 5 32. Do )'OU have BAJ' religious or n:iorol beliefs, soe+a+;--f)olitical, or pl-:.ilosopeical, or any other beliefs that would interfere with being a member ofth is jury and retuming a .fair and impartial verdlet solely OA the e¥idenee?33. Do you have a0y religious or moral beliefs, social, political. or philosophical, or any other beliefsthat would interfere. with yo�ir ability w sit in judgment of the defendants in this case? �+..Ll.,__WouJd you for any reason hesi tate to enforce the laws invo l ved in thi case? 1 6 . W i ll you follow the in trnctions of the law that the Court wi l l give you, regardless of whether or not yo u agree wi th those instructions? _ ..!.1.,__Does anyone have any strong feel i ngs, for or against, the FBI or the U . S . Department of J ustice? Ifyes. please e"plujn_ J+:_IB:___ ls there anyone who be lieves the PBJ o r Depart ment of J ustice pursues cri minal investiga tions and/or prosecutions for reasons other than the impartial pursuit of j ustice? �12.:__Tbere have been numerous crim inal i nddents throughout the country that have targeted reproducti ve health care cl inics and pregnancy crisis and cou nseling centers . Have you seen any of the media reports on any of these other i ncidents? Have you formed any impressions regarding those incidents? ��Q,__Have you heard about or seen any med ia coverage about this case or about the e defendants? 40 . 1 Do t'.ny ofyou read or watch lhe following news sources: a. The Epoch Times b. Tl�e Mike W1:1ekabee show? c. The Man Walsh Show? El.. The Daily Wire? e. Or:,e America Ne,,.,rs Nefwork? f. CBN News. aJso knowa as Christias BroadcastiRg News? g. fo:x Nevis? h. Hte Ingraham Angle? 1. R�ud Lion? 6 j. America Military �:ews? k. Nation.al Catholic: Register? -1-h�ls there any reason that you can think of, whether or not it bas been covered by a previ ous question, why you could not sit fairly, attentively and impartial ly in this case? 7 Commented [ LB l I : remove Bernstein Laura-Kate (C RT) 2024-05- 1 4 1 7 :25 : 00 EXHIBIT 129 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION UNITED STATES OF AMERICA, Case No. 23-cr-20100 HON. MATTHEW F. LEITMAN v. D-1 D-2 D-3 D-5 D-6 D-7 D-8 CALVIN ZASTROW, CHESTER GALLAGHER, HEATHER IDONI, JOEL CURRY, JUSTIN PHILLIPS, EVA EDL, and EVA ZASTROW, Defendants. / JUROR QUESTIONNAIRE INSTRUCTIONS Dear Prospective Juror: You are on the jury panel for the case listed above. This questionnaire is designed to obtain information about you, to use in deciding your qualifications to serve as a juror in this case. The purpose of these questions is to determine whether prospective jurors can impartially decide this case based upon the evidence presented at trial and the instructions on the law given by the presiding judge. The questions are not intended to unnecessarily inquire into personal matters; all information obtained will be kept confidential. You are sworn to give true and complete answers. Your answers will be available only to the court and the attorneys for the parties. The questionnaires belong to the court and all copies will be returned to the court. You are instructed not to discuss this case or the questionnaire with anyone, including your family, fellow jurors, or anyone else. Although some of the questions may appear to be of a personal nature , please understand that the Court and the attorneys for the parties must learn enough information about each juror's background and experiences to select a fair and impartial jury. ¥°--ea:r-ee6�tt-t��rtMtee:--Please answer each question as fully and completely as possible. Your complete candor and honesty are necessary so that both the prosecution and the defense will have a meaningful opportunity to select a fair and impartial jury. You must answer all the questions to the best of your ability. If you do not know the answer to a question then write, "I don't know." If the question does not apply to you, write "N/ A." Please fill out the entire Questionnaire. DO NOT LEAVE ANY QUESTION BLANK. It is important that the answers be yours alone. Unless the question states other:wise, the fa-et that a pMtiettla:f quest.ion: is asked does not imply that the !ftlbjeet ma:tter: of the quest.ion i� ll:tl issue .in this ell:!!e. A:. j'Otl .tn1d the quest.ions, y,ott .tte not to Ma."1' aey infe.tenees abotlt theissues whieh mttst: be decided .in this ea:,e. ,, . ht!' In, ____ f____ : ._ ,_,_ ,l th,Uati:la:C-Meano •ang= �a Of ,. Wft>ttg ll:tlSl.'llefS, 0ttlf m eompkt:e ll:tld.ineomplete att!!'\'l!et:s. Complete =wer::i llff moi-e helpful tha.tt meompl:ete ll:tlswu:s :io plea:se Ans wet all rhe quot.io1u 1:o the bcit of y,ottt ahility . Citi!ilens ott:t eofflfttttfl..ity h.1t..,,c; d:iffecent riew11 a:tld perc£ Idem 11ad Evil Edl.Qf the even de tendants re chara ge d with a second count of (3 ) F£eedem te Aeeess Gliftie EnEftlcneesClinic Access Obstruction. In Count (1), the indictment alleges that all defendants conspired. or agreed to block acce s s to the entrance of a clinic that provides womefl: reproductive health €efttei=-sei:vices in Stei:ling Heights, Michia . The indictment all�es they did this to gan Commented (CF(l): I know these preliminary instructions a re from Castro, but I think they are too long ... Carlson, Frances (USAMIE) 2024--04-26 08: 17:00 Commented (BLK(ZJ: I'd take out thei r na mes Bernstein, laura-Kate (CRJ) 2024-04-25 20:34:00 Commented (CF(3R2) : The reason to name them is in case a nyone ln the venire knows them? Carlson, Frances (USAMIE) 2024-04-26 08:a16:00 oppress or intimidate patients of the clinic from obt.'1.iniug seeliiag reproductive health se.i:vices or employees from providing those services. Obtaining andSeelaag e£ providing reproductive health services is a right guaranteed under the laws of the United States. In Count (2), the indictment alleges that all defendants intentionally interfered with patients and employees of the d:i:n.iea clinic that provides reoproductive health services in Sterling Heights. Michi:g_an by using their bodies to physically obstruct the entrance to the clinic and that they did so because patients and employees we.re obtaining or providing reproductive health services. Count (3) of the indictment only applies to twoof the seven dc-teoda.11� Helttha---Id�Edl and _alleges they intentionallyinterfered with patients and employees of a clinic that provides reproductive bealth services in� Saginaw, Michiigan by using their bodies to physically obsti:uct the entrance to the clinic, and that they did so because patients and employees were obtaining or p.coviding .reproductive health services.:- The charges are not any evidence of guilt; there is a presumption of innocence applicable to the-each defendant on each charge. The defendant� haveti entered a Commented (DS(4): Please review. Doddamani, Sunita (USAMIE) 2024-04-2S 12:18:00 plea.2 of not guilty to all of the charges against him-them. The jury in this case will be asked to listen to the evidence presented in court and make their decision based ONLY on the evidence they hear in court, without outside influence. As a member of this jury panel, you are instructed that you MUST NOT do any research of any kind in relation to this case and must not talk to anyone else about it. You are NOT allowed to: - Read or research anything related to this case. - - Listen to any discussion related to this case. Talk to anyone about this case, includingyo1.11'. spouse/partner and other Jury selection is scheduled to start on or about jA.ugust 6, 2024, rnnning _ a.m. to _ Commented (DS(S): Fill in. family members. i_p.m. and is expected to last approximately _ i_ i_ i_ i_ ..i_ resentation of evidence will begin once a jury is selected and will last two to three weeks. At the end of the questionnaire, you will be required to siign a true declaration stating pnder penalty of perjury at the answers ou have rovided on the questionnaire are tme. correct, and complete a,ael thftt ne eae has assis�ed yoain _i Doddamani, Sunita (USAMIE) 2024-04-25 1�:25:00 Commented (8U((6): Techn i cally, thi s is not what the signature block states Bernstein, Laura-Kate (CRT) 2024-04-2S 21:02:00 Commented (CF(7R6): True. Added the penalty of perjury language to the declaration. Carlson, Frances (USAMIE) 2024-04-26 08:33:00 providing information and/or respondingto the best of your knowledge. You must answer truthfully and honestly and will be asked to affirm that you did so at the end of the questionnaire under penalty of perjury. Please use a black or blue ink pen. DO NOT write on the back of the page. There is extra space at the end of this questionnaire if you run out of space for any question. Please write your juror number on the top right corner of each page where indicated. PLEASE PRINT OR WRITE LEGIBLY. After you have completed, signed, and turned in the questionnaire, you may leave. You will be notified by the Clerk’s Office when to report for jury duty. Do not discuss the questionnaire or your answers with any member of your household, family, friends, co-workers, fellow jurors, court personnel, or anyone else. Do not conduct your own research, including using the internet or any other electronic media, and from this point forward, do not read or watch any news reports about this case. You must not gather, or attempt to gather, any information or otherwise investigate this case or any issues related to it. Thank you for your cooperation, Hon. Matthew F. Leitman United States District Judge JURORRUESTIONNA1__1•'---- _ •_ •_ ___,.,... • •_ •_ _ _ _ Personal Background 1. Juror Number_ i_ i_ _i i_Name_ i_ _ _ _ _ _ _ _ _ _ _ _ _ 2. Which of the following reflects your current relationship status? □ Single o Married D Living with someone o Widowed o Sieparated 3. City or community you currently live in: _ a . How long have you lived there: _ i_i i_ _ i_i i_ i_ _ i_ i_ i_ i_ i_ i_i _ _ i_ i_ _ i_ i_ i_i _ but I'llworry aboutspacing between each question once we finalizethat we like the overall formatand content. Doddamani, Sunita (USAMIE) 2024-04-2S 12:30:00 Commented [CF{9R8): Yesfor sure. it does look smushed. Carlson, Frances (USAMIE) D Divorced _ Commented (DS(S): This mayall feel a bitsmushed, 2024-04-26 08:34:00 i_i _ _ b. If you have lived at your current address less than 5 years, please list where else you have lived in the last 10 years (without providing your exact address): �i Do you have children? If so, how many and what are their agef.'t:tigc3�: _ - i_ _ i_ i_ _ l ,.,,-/' Commented (DS(lO): Added this. l-/' Doddamani, Sunita (USAMIE) 5. What is your current or most recent job? (Please indicate ifyou are retired, do not 2024-04-25i11:S5:00 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ i_ i_ _ _ _ _ _ i_ i_ _ _i work outside the home, unemployed, disabled, or a student) a. Employer: _ i_ i_ _i b. Job Title: _ i_ i_ i_ i_ i_ i_ i_ i_ i_ i_ _i i_ i_ i_ i_ i_ i_ i_ _ i_ _i i_ _ i_ i_ c. How longhave you had (or did you have) this job: _ d. Job duties: _ i_ i_ i_ i_ i_ i_ i_ i_ i_ _i i_ i_ i_ i_ i_ i_ _i i_ i_ i_ i_ i_ 6. Please briefly describe the types of jobs you have held in the last 10 years: i_ 7. What is your highest level of education? D less than high school D high school graduate D Technical/trade school D some college D college graduate D graduate school Major/degree: _i _i _i _i _i _i _ i_ i_School attended: _ _i _i _i _i _i _i _ _i _ i_ -- - - - - - - - - - - - - - - - 8. If married, or sharing a household with another adult, please describe that person’s job. (Please indicate if they are retired, do not work outside the home, unemployed, disabled, or a student) a. Employer: _____________________________ b. Job Title: ______________________________ c. How long have you had (or did you have) this job: __________________ d. Job duties: _________________________________________________ 9. Other than a spouse/partner or children, who else lives in your household? a. Relationship to you: _________________________________ b. Age: ____________ c. Occupation (if any): _________________________________ 10. What is your spouse/partner’s highest level of education or degree? _________________________________________________________________ 11. Have you ever served in any branch of the armed forces of the United States (including the military reserves, National Guard, or ROTC)? □ Yes □ No If yes, please list what branch of service, the approximate years of service, highest rank attained, and places where you were stationed: ____________________________________________________________ ____________________________________________________________ If yes, did you ever participate in a court martial? □ Yes □ No If yes, please describe your role and the charges: ______________________ ____________________________________________________________ 12. What do you like to do in your spare time? What are your interests or hobbies? __________________________________________________________________ 13. What is your main source of news? □ Radio □ TV □ Newspaper D Internet/Social Media D Family/friends D Washington Post □lUSA Today D I don't follow the news 14: What ace your soucces of news? (f:heck all that apply),L]----------- �,,,,.,.,..,,-i Commented (BU((11]: I think we should delete -atiaboutsornething like: There wasn'tanything voluntary or helpful in this ii blockade. said st,e didn't see one meaningful conversation ii take p!ace between any member of the holiness revival team and any woman al the cllnic. She said it best, when Chet Gallagher Wa$ questioning ii her. a conversation t;ikes two people. We all heard Mr. Gallagher tell her that these oonversatiom "aren't about ttie women," and tie was i right. These weren't conversat ons. This Was a group of peoplewho weren't interested in what any ofthe women in ttie parking lot had to say. Thev were sure n o one couid interested in one th1ng: makng i li make the choice to obtain RHS. Bernstein, Laura-Kate (CRT) 2024-08-18 10:23:00 Commented [DS(ZO]: Does this make sense? I'm trying to marrytwo ide�s here • that-testifed ii that they WERE trying to persuade women and our idea that they were just turning peopie li away. Joel Curry in exhibit 4C says "we' re trying to help you." Doddamani, Sunita (USAMIE) 2024-08-17 18:()6:00 Commented [BLK(21R20]: I tfiink this makes sense, but mavbe break. it down a littlie more? What about something lll To: "Fitzgerald, Paige (CRT)" < > Subject: RE: GJ_memo_FACE_Philadelphia_assault_SB_SP (002)(2) Date: Fri, 19 Nov 2021 18:09:46 -0500 Importance: Normal Thanks, Paige. Have a great weekend. From: Fitzgerald, Paige (CRT) Sent: Friday, November 19, 2021 6:02 PM To: Patel, Sanjay (CRT) < >; Beer, Sheldon (CRT) < Subject: RE: GJ_memo_FACE_Philadelphia_assault_SB_SP (002)(2) > Thanks, Sanjay. This is approved to be put in final for Robert. From: Patel, Sanjay (CRT) Sent: Friday, November 19, 2021 7:50 AM To: Fitzgerald, Paige (CRT) < >; Beer, Sheldon (CRT) < Subject: RE: GJ_memo_FACE_Philadelphia_assault_SB_SP (002)(2) > Revised memo with PF edits From: Fitzgerald, Paige (CRT) Sent: Thursday, November 18, 2021 4:12 PM To: Patel, Sanjay (CRT) < >; Beer, Sheldon (CRT) < Subject: RE: GJ_memo_FACE_Philadelphia_assault_SB_SP (002)(2) > Thanks, Sanjay. That’s a good clear shove and doesn’t look mutually aggressive at all – I’m comfortable proceeding. From: Patel, Sanjay (CRT) Sent: Thursday, November 18, 2021 4:05 PM To: Fitzgerald, Paige (CRT) < >; Beer, Sheldon (CRT) < Subject: RE: GJ_memo_FACE_Philadelphia_assault_SB_SP (002)(2) Thanks, Paige. I’ll work on breaking those habits. Appreciate the micro-edits. Attached is the video. From: Fitzgerald, Paige (CRT) Sent: Thursday, November 18, 2021 2:20 PM To: Beer, Sheldon (CRT) < > Cc: Patel, Sanjay (CRT) < > Subject: RE: GJ_memo_FACE_Philadelphia_assault_SB_SP (002)(2) Hi, Shelly and Sanjay – > Attached are my edits and comments. On substance, my concern is about what the video actually shows re: the victim's actions immediately preceding the assault and whether a reasonable person might conclude that the two men were both becoming physically aggressive as the victim stepped toward the subject. I'd like to see the video. Second, even if the video is clear on that point, we need to candidly acknowledge that the victim significantly underplayed his own conduct immediately preceding the assault, and we will have to deal with that if this gets indicted and goes to trial. It may be perfectly understandable - he may have been rattled and was simply confused, but he will need to be able to explain why his account is so different from the video. My intent here rs not to nit - pick, but to help you elevate your written work, which will serve you across the board, including in court filings. Thanks, Pa ige From: Beer, Sheldon (CRT) Sent: Monday, November 15, 2021o10:08 PM > To: Fitzgerald, Paige (CRT) Cc: Patel, Sanjay (CRT) Subject: GJ_memo_FACE_Philadelphia_assault_SB_SP (002)(2) Hi Paige, Attached you will find a short GJ memo for a matter involving a FACE Act violation in EDPA. Please let us know if you have any questions. Thank you, Shelly EXHIBIT 132 From: "Patel, Sa11jay (CRT)" To: "Beer, Sheldon (CRT)" Subject: FW: : PPSP Secmity Incident Philadelplua Date: Mon, 18 Oct 2021 08:29:04 -0400 Importance: Normal Attachments: 1MG_202 I 1 0 1 3_ 1 3081 2533.jpg; JMG_202 I 10 13_1 30807386.jpg Inline-lmages: image001 .png ShellyLooks like a good felony FACE matter. I'm going to open it and assign it to myself for now. SP From� Sent: Saturday, October 16, 2021 5:50 PM To: Eve, Anita (USAPAE) �; Gibson, Eric (USAPAE) �; Patel, Sanjay (CRT) - Subject: ; PPSP Security lncident Philadelphia Special Agent Federal Bureau of Investigation Philadelphia Division From:-� Sent; Friday, October 15, 2021 2:46:51 PM To: Jackson, Christopher (PH) (FBI)e� Subject: [EXTERNAL EMAIL] - PPSP Security Incident Good afternoon, I am reaching out to see i f you can provide Planned Parenthood with assistance with a recent security incident. us11ed down by protestor Mark Houck at PP Philadelpl1ia (video attached). Please see below located at is folJowing up with local poLice but was told he needs to file a private crimina] statement from him. complaint and no arrest was made on scene nor a warrant was initiated. this . is for a private criminal complaint. fnjury suffered from incident: • A bleeding and scraped up a1111, which should heal fine. • A problem with the palm of hand/thw11b which will likely keep - from certain physical activities for a number of weeks at least. • An ache in his r:ight hip. The objective of this would be to obtain an injunction similar to the following case law. Thank you in advance for your assistance. Thank you, - M.S.CJ, LPC Senior Director of Security He/Him/His Planned ra Parenthood· Care.Nomatterwtlat On Wed, Oct 1 3, 2021 at 5:26 PMe- wrote: HI First of all, -• as you asked in your other note, I will be going back downtown to press charges. Attached are photos of the injury to m y arm, as well as the complai nt number info given to me by Civil Affairs officer ., who took my statement. Also note that I have a bruise and swelling on the palm of my hand from this incident. Also note that when I finally left about 2:45, Civil Affairs was across - talking to the assailan t, Mark Houck. My statement: BTW, in all this, Mark was accompan ied by his you ng son . Mark Houck (known provocateur) was fol lowing two women down the street and across -· followed to let them know they could ask him to leave them alone if they wanted to. Mark told me to get out of the way (I wasn't in the way) and pushed my arm around. No injury from that. And that would have been out of camera range. I came back to the gate, talked to a bit, and went back to near th where Mark was . I'm guessing I was maybe 8 feet away from him. I go there because at the corner he attempts to confuse women who are looking to come into the clinic, and he tries to get them to go to their ''clinic" across the street, th inking they are going to Planned Parenthood. He tolcf me he didn't want me that close to him and hi s son. I told him it was a publ ic street. He threatened to push me into the street. I asked him "is that a threat?", and he said "yes''. I turned my back from him, and perhaps was walking a l ittle back to towards the gate, I'm not sure. He then pushed me hard in the back and I fell to the ground, badly scraping my right arm below the elbow, whi ch was bleeding. Also later realized th at m y palm was bruised and somewhat swollen, as I had braced myself with the hand I guess. This was witnessed by 1111, two passers by for whom we have their info. Went in, and asked the guard to call Civil Affairs, which he did, and he also callede- Civil Affairs told me that we needed to call 911i. Not sure if that happened, but eventually Civil Affairs came out. One of the officers was - I believe. He took some info, but said it was a matter for the regular police and he would have them come out. Civil Affairs then went back to their car. Over the next maybe half hour I went back to their car a couple times to ask when the uniforms might come. They didn't know. A bit after the second time, Civil Affairs Officer - cam to me and said she could take the info, which she did. She was very helpful. She told me I would need to go to the District - tomorrow when they'd have the info she took, if I wanted to file, and gave me the piece of paper With the DC# (photo attached). Before this, by the way, the guard asked me to look at the footage on video with him, while he was on the phone with a tech person . Eventually we located the incident at 1 2: 51 PM, showing very clearly Mark pushing me down. The guard had difficulty saving the footage, but I assume that eventually happened. That's about it. If there's anything else you need please let me know. And Once I've done the complaint of Thursday, I'll be in touch again. EXHIBIT 133 From: " Fitzgerald, Paige (CRT)" To: "Beer, Sheldon (CRT)" Cc: "Patel, Sanjay (CRT)'' Subject: RE: GJ_memo_FACE_Philadelphia_assault_SB_8P (002)(2) Date: Thu, 18 Nov 2021 14: 19:57 -0500 Importance: Normal Attachments: GJ_memo_FACE_Philactelphia_assault_SB_SP_i (0Q2)(2)i _pf.docx Hi, Shelly and Sanjay Attached are my edits and comments. On supstance, my concern is about what the video actually shows re: the victim's actions immediately prececling the assault Sent: Thursday, June 9, 2022 12:15 PM To: Eve, Anita (USAPAE) � Cc: jpw0077@gmail.com Subject: [EXTERNAL) Target letter sent to Mr. Mark Houck AUSA Eve: As you know from my telephone messages lo you on May 2 1 and June 7. L am one of tbe atlomeys representing Mark J lot1ck, together with Pennsylvaoia attorney John Williamson. 1 llnderstaud you have just returned from being out of the office for l 0 days and are probably very busy. ( l used Lo be in charge of one of the criminaJ divisions of the Phoenix USAO. and J remember The madness a�er rernming from any break.) On the other hand, since you sent my client a 'target letter, 1 think it is necessary for me to make contact with you. I assume you arc contemplating a FACE action. You probably are familiar with the Sulpizio case from your district cou1t, but it is possible it has not yet come to your attention. Just 2 ½ years ago, your district considered nearly identical facts 10 those of the Houci; Visser, Tim (OAG) < ; Weiner, Robert (CRT) H i team, several have asked me what we know about the FBl's arrest of Houck in this FACE case. Below are some bullets prepared by CrimSec on the matter, and attached is the FBI 302 of the arrest. Talkers: Letters to AG re: EDPA FACE indicbnent(fl Mark Houck). • ll Houck was charged with two counts of violating the FACE Act (not one) o D. committed two assaults against the victim on 10/13/2 1 . The assaults were separated by a short amount of time. !!:. initially pushed the victim to the ground as he attempted to escort two clinic patients. A short time later, /). forcefully shoved the victim to the ground as the two men stood close to one another near the cl.inic's entrance. o Count 1 charges A with a misdemeapor FACE Act offense for the initial push, which did not result in bodily iajmy. o Count 2 charges D. with a felony violation for the subsequent assault, which resulted in bodily injury • ll Houck was charged by private criminal complaint filed by the victim after local police failed to chargee!!:. for assaulting the victim. The private criminal complaint case was dismissed without prejudice by local authorities in lieu ofthe then on-going federal investigation, Federal and local authorities were in regular contact (up until yesterday 9/26/22 ) about the status of the federal pi-osecution. • The indictment was filed under se-al, and a j:udge issued an arrest warrant for !!:. H011ck that was executed by the FBI on 9/23/22. • The FBI did not execute a search warrant, and did not enter ll's residence. • According to the FBl, who developed and impleme11ted the arrest plan on its own, approximately 16 law enforcement officers executed the anest wattant (not 20-25). Officers knocked on D. Houck's residence door, and arrested llim aft.er be complied with orders to step outside of bis residence. Officers did not enter !!:.'s. home, and allowed him to dress appropriately (change his clothing and shoes) before transporting him to the FBI field office. At no time were firearms pointed at ti 1 s wife or bis children. The anest was a11Jicable, altl104gh 6's wife demanded to see the warrant (which was shown to her although not immediately). 11 apologized to the officers for the actions of his wife thanked and exp1:essed his appreciation for them not enteting his home or frightening his family and for providing him the courtesy of allowing him to exit the residence. EXHIBIT 144 From: "Patel, Sanjay (CRT)" To:a" '' �- "Eve, Anita (USAPAE)" � Subject: RE: HOUCK in custody Date: Fri, 23 Sep 2022 07:34: 1 9 -0400 Importance: Nonnal ■ Excellent. Thanks for the update" From: � Sent: Friday, September 23, 2022 7:21 AM To: Eve, Anita (USAPAE) �; Patel, Sanjay (CRT) � Subject: HOUCK in custody - Houck is in custody and we are headed to FBI space Special Agent Federal Bureau of Investigation Philadelphia Division EXHIBIT 145 From: "Patel, Sanjayt(CRT)" To: "feJte, James (CRT)" Cc: "Fitzgerald, Paige (CRT)" Subject: RE; FACE Meetings Date: Mon, J 7 Oct 2022 L l : 18:24 -0400 Importance: Normal Hi,"Jim"I responded to each question below. Happy to provide more details if needed. SP From: Felte, James (CRT)"� Sent: Mohday, October 17, 2022 11:06 AM To: Patel,"Sanjay"(CRT)� Cc: Fitzgerald, Paige (CRT) Subject; FACE Meetings Sanjay, Robert will be meeting with the DAG to dlscuss numerous topics this a�ernoon. One of the topics will be FACE. A few cjuestions: 1) Ar.e you aware of any other allegations {other than Houck) of the Department or FBI being overbearing? Yes re: MDTN FACE - allegations are that FBI raided the homes of two defendants (of 11), and that FBI pulled guns on one of them. Tucker Carlson had a couple of segments on this. Here's one of them: Pro-lffe father details jarring arrest in front of ch11dren - YouTube 2 ) I know you met with the USCCB last week, have we had any more follow-up communications 0r are there anv other meetings or calls scheduled? No follow-up meetings scheduled. FBI is waiting for us to approve/edit their message that USCCB will broadcast to affiliated pregnancy centers. I fwd'd that to you and Paige last week. USCCB will also remain in contact with FBI to share/assist with outreach. 3 ) Have you received any allegations of criminal conc.luct involving abortioh alternative facilities since the meetings with the umbrella groups with the past couple of weeks? No new reports. But glad to report that we are actively working with NSO and MDFL USAO on three separate Jane's incidents involving a common subject. We're getting warrants and shoring up some evide.nce in hopes of bringing charges soon. 4 ) Wheh would be a reasonable time by which we can make our anticlpated changes to the resource booklet knowing that we need to both make the chaoges and to message these changes with appropriate groups? I'm going to work on the booklet this week and send to Paige for review by Friday. Once it's approved, I will .send along for 508 compliance, which could take a couple of weeks. CareNet has shared their .suggestions/ inclusions with me. Thanks, Jim EXHIBIT 146 From: "Patel, Sanjay (CRT)"i< To: "Felte, James (CRT)"i-> Cc: "Siscaretti, Christine CRT)" >, "Fitzgerald, Paige (CRT)" < Subject: RE: DOJ response to Sen Grassley's letrer FBl/USAO Response needed Date: Tue, 1 8 Oct 2022 17:45:14 -0400 Jmportance: Normal The Roy-Lee letter mostly asks for stats and policy/practice stuff in addition to the q's about FACE applying to houses of worship, so I didn't respond to those qs. Here are my responses to the questions raised in the Grassley letter. Grassley: 1. Why did the Justice Department wait 11 months after the October 2021 incident to indict Mr. Houck? Our investigation commenced two days after the incident. The investigation was on-going throughout that time up to the day defendant was indicted. 2.. Please provide a list of Justice Department and FBI officials who approved the decision to open a grand jury investigation into Mr. Houck after the state criminal complaint had already been dismissed. The FBI investigation began two days after the incident (I have an email from the clinic to FBI dated 10-15-21). Moossy signed my grand jury auth letter on 11-23-21. During the federal investigation, we were in regular contact with local prosecutors who dismissed the state case in lieu of the on-going federal investigation. The state case against defendant Houck was dismissed sometime bw April 18-29, 2022, which was during the grand jury investigation. 3. Please provide a list of Justice Department and FBI officials w h o approved the execution of the arrest warrant for Mr. Houck. This was FBI after we (CRT and USAO) urged FBI to allow defendant to self-surrender. 4. How many law enforcement personnel did the FBI use in executing the arrest warrant? 16 according to the arrest 302. 5. In light of Mr. Houck's alleged cooperation with federaln · authorities, what factors led to the Justice Department and FBI executing an arrest warrant 9gainst him instead of using less aggressive tactics, including a summons to appear? Please explain how the executi on of the search warrant complied with Attorney General Garland's use of force memorandum? Defense counsel claims that he twice called and left AUSA Eve messages, and did not receive a return call. He also sent an email indicating defendant would voluntarily appear., and that AUSA Eve did not respond. AUSA Eve did report to me that she had conversations with an attorney representing defendant, and received emails from another. Defense counsel's initial calls were while AUSA Eve was on leave. She did subsequently return the call and have a conversation with him, which was during the on-going grand jury invertigation. I believe this occurred in June 2021. I was not cc'd on any emails. As to the factors supporting the arrest warrant - standard USAO practice to get a warrant when an indictment is filed under seal. FBI standard practice to arrest in this and similar cases where defendant charged with a felony. let me know if you'd like m ore details. SP From: Felte, James (CRT)n.Sent: Tuesday, October 18, 2022 5:33 PM To: Patel, Sanjay (CRT) >; Beer, Sheldon (CRT) .-; Cc: Siscaretti , Christine (C T < Fitzgerald, Paige (CRT) Subject: Re: OOJ response to Sen Grassley's letter FBI/USAO Response needed Sanjay, Hold off on preparing the draft. It looks like OOAG and OASG are going to do it and we'll review. Go ahead and get answers for ODAG to the questions on the other emall chain though. Thanks, Jim On Oct 18, 2022, at 5:14 PM, Felte, James (CRT)e.-, wrote: Correct. On Oct 18, 2022, at 5:13 PM, Patel, Sanjay (CRT) - wrote: Will do. I'm assuming our letter was the one you circulated yesterday, and the most recent one you sent ls the FBl's? From: Felte, James (CRT) Sent: Tuesday, October 1 To: Patel, Sanjay (CRT) Cc: Siscaretti, Christine (CRT) ; Beer, Sheldon (CRT) -; Fitzgerald, Paige (CRT) Subject: Re: DOJ response to Sen Grassley's letter FBI/USAO Response needed Thanks Sanjay. Can you take a stab at merging our letter with the FBl's? Jim On Oct 18, 2022, at 4:46 PM, Patel, Sanjay (CRT) wrote: FYSA From: Cake, Christina M. (OLA) Sent: Tuesday; October 18, 2022 4:11 PM To: Patel, Sanjay (CRT) Cc: Weiner, R ; Bond, Rebecca (CRT) Sora.ya (OLA) Subject: FW: OOJ response to Sen Grassley's letter FBI/USAO Response needed ; Haddad, Hi Sanjay, I don't believe we've met. I am a DAAG in OLA and have been handling the response on this one. I think there might have been some crossed wires here. FBI drafted an initial response, which I edited and then sent to Rob Weiner & Rebecca Bond, cc'ing OASG, yesterday. We had a call yesterday afternoon and laid out next steps. We are looking for input from you and Rob Moosey, but were hoping to have it incorporated into the placeholder section in the attached draft. OLA is separately reaching out to EOUSA to run down some additional info. I'm happy to jump on a call to discuss furtherThanks, Christina From: � Sent: Tuesday, October 18, 2022 3:40 PM To: Calce, Christina M. (OLA) Cc: (OCA) (FBI) > Haddad, Soraya (OLA) Subject: FW: DOJ response to Sen Grassley's letter FBI/USAO Response needed Hello Christina, The Philadelphia FO was contacted about adding language (see chain below) to the attached draft response to Grassley re: Houck. However, the draft doesn't include any language from the proposed response I sent on Friday (also attached). Has CRT been provided with the FBI language? Please let me know if you do need anything from FBI/Philadelphia. Thanks, Claire Legislative Affairs Specialist FBI I Office of Con ressional Affairs Desk: I Mobile: From: (PH) (FBI)e� Sent: Tuesday, October 18, 2022 12:43 PM To: (OCA) (FBI)e._, Subject: FW: DOJ response to Sen Grassley's letter FBI/USAO Response needed Hi Claire - please see the chain below and the DOJ doc attached. Can you shed any light on the back and forth with DOJ since that 9/29 draft response you'd sent me? Seems weird that none of the FBI statement language from that draft is included here, and DOJ is now asking for PH input. Thanks! Public Affairs Officer FBI Philadelphia desk cell @FBIPhiladeli;1hia From: (PH) (FBI) Sent: Tuesday, October 18, 2022 11:46 AM To: (PH) {FBI) > {PH) (FBI)n� Cc: Subject: RE: DOJ response to Sen Grassley's letter FBI/USAO Response needed It's odd that they're asking for us to add anything now. Late last month, FBI OCA sent me a draft Grassley response that OCA/OGC put together, which included a lot of the language from our statement about the arrest. OCA asked for PH's input; we said we were fine with it. CID was also reviewing. It was my understanding that OCA/OGC would then be provid.ing that draft to the DOJ folks for use in crafting the final reply, However, this version of the letter has all the PH statement language stripped out. I'm going to touch base with OCA and try to get some clarlty on this. (tl;dr - previous FBI input on the response letter has been stripped out and now they're asking for FBI input again. What gives?) Public Affairs Offn i cer FBI Philadelphia desk­ cell @.FBIPhiladelghia From: (PH) (FBI)n� Sent: Tuesday, October 18, 2022 11:22 AM (PHJ (FBI) To;, > Cc: (PH) (FBI) Subject: DOJ response to Sen Grassley's letter FBI/USAO Response needed Hey Carrie, Attached is the DOJ response to the congressional letter inquiry into the HOUCK arrest. DOJ would like us to draft a response to add to it before submitting. Let me know what you need from me. Thanks, hope all is well. ■Speciaf Agent Federal Bureau of Investigation Philadelphia Division From: Pate l , Sa njay (CRT}: _ Sent: Tuesday, October 18, 2022, 9 ,43 AM To : ( P H ) ( F BI ) �; Eve, An1ta ( USA PAE} -Subject : [EXTE RNAL E M AI L] - DOJ resf)onse to Sen G rassley ' s letter ■- A nita: ! Attach ed a re a co ngress ional letter received b y DOJ, and a d raft res ponse that is bei n g prepared b y O LA. Ca n you h ave yo u r shop review and add to the res ponse, and send back to m e for my shop's review? Than ks, SP EXHIBIT 147 From: "Felte, James (CRT To: . "Fitzgerald, Paige (CRT)" Cc: ''Christian, Fon-est (CRT)" Subject: RE: NashvilleArrest PJan Date: Tue, 04 Oct 2022 1 3 : 17 :59 -0400 Jmportance: Normal Got it! From: Patel, Sanjay (CRT)"._, Sent: Tuesday, October 4, 2022 1:17 PM To: Fitzgerald, Paige (CRT) Cc: Christian, Forrest (CRT) Subject: RE: Nashville Arrest Plan ; Felte, James (CRT}"._, Main reason is in hope of seizing phones for SWs (so that no one wipes them once they find out they were charged). I thrnk the unspoken reason is be the FBI really likes to make arrests. From: Fitzgerald, Paige (CRT) Sent: Tuesday, October 4, 2022 1:09 PM To; Patel, Sahjay (CRT)"._,; Felte, James (CRT)"._, Cc: Christian, Forrest (CRT) Subject: RE: Nashville Arrest Plan Why are they arresting rather than allowing self surrender? From: Patel, Sanjay (CRT)"._, Sent: Tuesday, October 4, 2022 1:01 PM To: Felte, James (CRT)"._, Cc: Christian, Forrest (CRT) Subject: RE: Nashville Arrest Plan ; Fitzgerald, Paige (CRT) Yes, we discussed it ye.sterday with USAO and FBI. And I mentioned to them what happened· in Philly. Of the 11 defendants indicted, two are local to TN and four to ML The others are scattered in various other states. FBI stated their plan was to arrest the locals in TN, and leave it up to the other FBI FOs as to arrests v. self surrender. If they cannot execute simultaneous arrests, then those not arrested will be told to turn themselves in. The plan was still being formulated as of last night. I'll connect with the team later today to see what the final plans are. From: Felte, James (CRT)"._, Sent; Tuesday, October 4, 2022 12:45 PM To: Patel, San jay (CRT)._, Cc: Christian, Forrest (CRT) Subject: Nashville Arrest Plan Sanjay, ; Fitzgerald, Paige (CRT) Good synopsis and lessons learned summary about the Houck case this morning. In that regard, what is the arrrest/non­ arrest plan for Nashville? As an aside, ODAG reached out to FBI Leadership to make sure that the FBI is aware of the Houck case with regards to Nashville, and ODAG asked that we do the same on the line level. To be sure, ODAG stressed that the arrest plans are determined by the FBI, but ODAG wants to make sure that the FBJ Ts considering all relevant factors regarding arrest/non-arrest. Thanks, Jim EXHIBIT 148 From: "Ev�. Anita (USAPAE)" � PH) (FBI)"i�. "Patel, Sanjay (CRT)'' To:t' Subject: RE: [EXTERNAL] Good to see doj thuggery deployed towards pro fife people Date: Mon, 26 Sep 2022 07:52: 1 3 -0400 Importance: Nonnal I received the one ernall that I forwarded earlier. Fortunately or maybe not, I've misplaced my cell phone and have only seen emails from members of rny office checking in on me. I'm good. The tragedy is that Mrs. Houck is attempting to taint the public's view of the arrest and prosecution. I think I calle9 each of you on Friday, so I think my phone is lost under the pile of paperwork that I was attending to this weekend. I'll be clearing things out today and retracing my movements to uncover my phone. Meanwhile, I will keep you <'lll posted as to the r:iext court da.te and share comments that I receive from my office. I will be going Into the office tomorrow and get started with the discovery. So, I'll be reaching out to you regarding all that is considered the discovery and to get the paralegal started on redc!cting PII so that we can produce the disc0very ln short order. Today, I am also going to notify Judge Pappert's chambers of the circus that we expect in this case. Anita From: ._.. Sent; Sunday, September 25, 2022 9.:01 PM To: Patel, San jay (CRT)"�; Eve, Anita (USAPAE) ._.. Subject: Re: [EXTERNAL) Good to see doj thuggery deployed towards pro life people Have you been receiving multiple emails from the public? ■ ■- Special Agent Federal Bureau of Investigation Philadelphia Division From: Patel, Sanjay (CRT)"� Sent: Sunday, September 25, 2022 7:09:30 PM To: Eve, Anita (USAPAE) ._.; (PH) (FBI)"._.. Subject: fEXTERNAL EMAIL] - Fwd: [EXTERNAL] Good to see doj thuggery deployed towards pro life people Here's another one Sent from my iPhone Begin forwarded message: �gmail.com> From: Date: September 24, 2022 at 11:58:20 AM EDT To: 11 Eve1 Anita (USAPAE)" �, 11 Patel, Sanjay (CRT)''"� Subject: [EXTERNAL] Good to see doj thuggery deployed towards pro life people Funny how you left out the "victfm" was harassing his kid Sent from my iPhone EXHIBIT 149 From:a' Subject: Re: Houck Trial in EDPA Date: Mon, 30 Jan 2023 15:47:07 -0500 Importance: Nonnal Thanks Jim. a tough pill to swallow. Sent from my iPhone On Jan 30, 2023, at 3 :04 PM, Felte, James (CRT) wrote: Hey Cathy. The jury just returned not guilty verdicts oh both counts, so no need for the PR. Sanjay- really great effort on a very difficult case. The USAO has been very complimentary of your work and the job you did. Jim From: Morris, Catherine (PAO) Sent: Monday, January 30, 2023 1:47 PM To: Fette, James (CRT)".-,; Dulaney, Emma (PAO) Cc: Moossy, Robert (CRT) ; Weiner, Robert (CRT) Sheldon (CRT)"._; Patel, Sanjay (CRT)"._. Subject: RE: Houck Trial in EDPA ; Beer, Hi all, See attached with OPA's edits to the release. Best, Catherine Catherine Morris Special Assistant to the Director, Office of Public Affairs U.S. Department of Justice (m)- From: Morris, Catherine {PAO) Sent: Friday, January 27, 2023 5:35 PM To: Felte, James (CRT)".-,; Dulaney, Emma (PAO) Cc: Moossy, Robert (CRT) ; Weiner, Robert (CRT) Sheldon (CRT)"._; Patel, Sanjay (CRT)"� Subject: RE: Houck Trial in EDPA ; Beer, Thanks Jim. Best, Catherine Catherine Morris Special Assistant to the Director, Office of Public Affairs U.S. Department of Justice (m) From: Fette, James (CRT)e� Sent: Friday, January 27, 2023 3:27 PM To: Morris, Catherine (PAO) Cc: Bradford, Aryele (PAO) Robert (CRT) ._ ; Dulaney, Emma (PAO) . ; Moossy, Robert (CRT) ; Beer, Sheldon (CRT) ; Weiner, ; Patel, Sanjay (CRT) Subject: Houck Trial in EDPA Cathy & Emma, We just got word that the Houck case is now wfth the jury. The trlal began on Tuesday. 'I ve attached a bare bones press release which we can supplement with additional facts from trial. Thanks, Jim Jim Felte Chief, Criminal Section Civil Rights Division U.S. Department of Justice EXHIBIT 150 From: "Moossy, Robert (CRT To: Cc: "Weiner, Robert (CRT)'' Subject: Houck NOT guilty both counts Date: Mon, 30 Jan 2023 1 5 :02:29 -0500 Importance: Normal Robert J. Moossy, Jr. Deputy Assistant Attorney General Civil Rights Division United States Department of Justice EXHIBIT 151 'From: "Patel, Sanjay (CRT)" To: "Bernstein, Laura-Kate (CRT)" Subject: RE: stats on crimes involving reproductive health? Date; Tue, 03 Sep 2024 1 7: 1 3:24 -0400 Importance: No11nal Yes! First 241 pleas, From: Bernstein, Laura-Kate (CRT) Sent: Tuesday, September 3, 2024 4:12 PM To: Patel, Sanjay (CRT)"� Subject: RE: stats on crimes involving reproductive health? Is it correct to say that the three Freestone defendants who pied will be the first defendants to be sentenced for a 241 plea involving FACE Act rights? From: Patel, Sanjay (CRT)"� Sent: Tuesday, September 3, 2024 3:55 PM To: Bernstein, Laura-Kate (CRT) Subject: RE: stats on crimes involving reproductive health? Not super easy, I'll share what I have here that I think is relevant from some recent FACE blockade cases. Kyle or Wil can share the sentences for each of their Nashville Os: 1 . US v Handy (DOC) 22-cr-96 (all prison sentences) a. Lauren Handy (lead 0)T- 57 months b. Jonathan Darnel (co-lead D) - 34 months c. Jean Marshall - 24 months d. Joan Bell - 27 months e. John Hinshaw - 21 months f. William Goodman - 27 months g . Heather ldoni - 24 months h. Herb Geraghty- 27 months i. Paulette HarT l ow - 24 months 2. US v. Williams (SONY) 22-cr-684 (371 conspiracy and felony FACE for force resulting in Bl (and phys obstr) a. Bevelyn Williams - 41 months imprisonment 3. US v. Moscinski (EDNY) 22-cr-1052 (misd FACE only for supergluing locks and blocking parking lot) a, Christopher Moscinski - 1 2 months imprisonment Hope this helps! SP From: Bernstein, Laura-Kate (CRT) Sent: Tuesday, September 3, 2024 3:32 PM To: Patel, Sanjay (CRT)�; Channapati, Anita (CRT) Subject: RE: stats on crimes involving reproductive health? Got it. Do we have easily accessible info about sentences? I'd like to make an informed statement about avoiding sentencing disparities. From: Patel, Sanjay (CRT)e� Sent: Tuesday, September 3, 2024 2:41 PM To: Bernstein, Laura-Kate (CRT} ; Channapati, Anita (CRT) Subject: RE: stats on crimes involving reproductive health? Unfortunately not. The NGOs, particularly NAF who tracks these stats, won't admit clinic criminal activity is trending down (even though it actually is). From: Bernstein, Laura-Kate (CRT) Sent: Tuesday, September 3, 2024 2:17 PM To: Patel, Sanjay (CRT)e�; Channapati, Anita (CRT) Subject: stats on crimes involving reproductive health? Do we have any statistics on whether criminal activity targeting reproductive health providers is up, down, static, etc? Something I could cite in a sentencing memo? Thanks, LK Laura-Kate Bernstein Trial Altomey Criminal Section Civil Rights Division U.S. De artment of Justice EXHIBIT 152 From: "Patel, Sanja (CRT ' To:t" , "Fitzgerald, Paige (CRT)" Cc: "Gibson, Rose (CRT)" Subject: FW: TENNESSEE WOMAN SENTENCED TO 4 1 MONTHS IN PRISON FOR VIOLATING THE FREEDOM OF ACCESS TO CLJNIC ENTRANCES ACT Date: Wed, 24 Jul 2024 14:40:04 -0400 bttportance: Normal BossesnSharing the below email I just sent Sheln l y. I believe he's on leave this week. SP From: Patel, Sanjay (CRT) Sent: Wednesday, July 24, 2024 2:39 PM To: Beer, Sheldon (CRT) Cc: Channapati, Anita {CRT) Subject: FW: TENNESSEE WOMAN SENTENCED TO 41 MONTHS I N PRISON FOR VIOLATING T H E FREEDOM OF ACCESS TO CLINIC ENTRANCES ACT Shelly FACE defendant Bevelyn Williams was sentenced today . . . 41 months imprisonment. An outstanding result. Blurb below: United States v. Chavan11es, et al. (SDNY)(Sanjay Patel Consulting) On July 24� 2024, the court sentenced Defendant Bevelyn Williams to 4 1 months imprisonment following her conviction from February 22; of felony FACE Act and conspiracy offenses in the Southern District of New York. Specifically, on June 1 9 and 20, 2019, Defendant Williams and a co-defendant, Edmee Chavannes. who was acquitted at trial. targeted the patients and providers at a Manhattan area Planned Parenthood clinic. Williams physically blocked the clinic's entrance, threated clinic staff, and used force against clinic employees. Specifically, on both dates, Willaims blocked the diruc's entrance, and thteated to assault clinic staff. Ou June 201 she used force by making physical contact with one clinic escort, and forcefully closing the clinjc door on another e.sco1i's hand that resulted in bodily injury. The court ordered tbe 4 1-month imprisonment sentence to be followed by two years of supervised release. SP From: Kelly, Jacqueline (USANYS) 2 Sent: Wednesday, July 24, 2.024 2:16 PM To: Patel, Sannjay (CRT) __ Cc: Bagliebter, Jamie {USANYS) � Subje!=t: FW: TENNESSEE WOMAN SENTENCED TO 41 MONTHS IN PRISON, FOR VIOLATING THE FREEDOM OF ACCESS TO CLINIC ENTRANCES ACT Hi Sanjay, Williams was sentenced today to the top of the G L - 41 months. We are very pleased with the outcome. Thanks for all your assistance along the way. Jackie From: USANYS-PressOffice Sent: Wednesday, July 24, 2024n12:28 PM Subject: TENNESSEE WOMAN SENTENCED TO 41 MONTHS IN PRISON FOR VIOLATING THE FREEDOM OF ACCESS TO CLINIC ENTRANCES ACT ]PR Header FOR IMMEDIATE RELEASE Wednesday, July 24, 2024 htlp://www.justicc.gov/usao/ny� CONTACT: U.S. ATTORNEY'S OFFrCE Nicholas Biase, Lauren Scarff, -ord TENNESSEE WOMAN SENTENCED TO 41 MONTHS IN PRJSON FOR VIOLATING THE FREEDOM OF ACCESS TO CLINIC ENTRANCES ACT Damian WiUiams, the United States Anorney for the Sot11bem District of New York, announced today that BEVELYN BEATTY WILLIAMS was sentenced lo 4 1 months in prisOLl for violating the Freedom of Access to Clinic Entrances Act (the "FACE Act'') in June 2020 in connection with her int·erference, including by threaL'> and force, with individuals seeking to obtain and provide lawful reproductive health services at a reproductive liealth center i1, Manhattan. 011 February 22, 2024, WILLIAMS was convicted after a nine-day jury trial of one co\mt of violating llie FACE Act before U.S. District Judge Jennifer L. Rochon, who imposed today's sentence. U.S. Attorney Damian Williams said: "Bevelyn Beatty Williams repeatedly i.ntimidated and interfered with individuals seeking and providing critical reproductive health services. She did so by physicaUy blocking access to clinics, threatening stafl': and by force. This Office and Ollf law enforcement partners are- committed to ensuring that patients exercising t·heir legal right to obtain reproductive health services, and healthcare facilities and their staff providing lhose services, can do s o without unlawf-ul interference or fear of threats or violence." According to evidence admitted at trial and other public tilings and statements made in Court: On June l9, 2020, and June 20, 2020. WlLLlAMS tlll·eatened and used force against patients and staff members at a reproductive health center located in tower Manhattan (the "Health Center") and blocked patients and staff members from accessing the Health Center. lo one instance, and as captured on video, WILLIAMS pressed he.r body against the door of the Health Center's patient entrance and refused to move, preventing a Health Center volunteer from entering the Health Center. As a Health Center staff member ('"Victim-I'') attempted to open the door for the volunteer. WlLLlAMS purposefiiUy leaned against the door, crrusbing VicHm-1 's hand, Victim- I yelled, "She's crushing my band." but WI LL IAMS remained against the door, trapping Victim-1 's band and injuring it. At various time.s ob June 19 and 20, 2020, WLLUAMS stood directly in front of the Health Center entrances. WILLIAMS in:itfally blocked t-he main entrance used by patients, causing the Health Center i-o have to djvert patients to enter through U1e staff entrance. WI LL!AMS responded by moving to hlock the staff entrance and directing others to do the same. W lLLIA MS livestreamed some of her conduct on June 1 9 and 20, 2020, on a social media accou nt On the livestream on J une 1 9, 2020, W J L L IAM S stood within inche< i of the Heal.th Center 's ch i e f administrative officer and threatened to "terrorize thi s place" and wamed that "we're gonna ierrorize you so good, your business is gonna be over mama." Si miJarly, WI LLIAMS stood within i nches of a H ealth Center security officer and threatened "wa r.' WI L L IA MS a l so stated that she would act by "any mean s necessary," Jn addjtion to WI LLIAMS ·s cond uct in Manhattan, on mu ltiple other occasions from at least 20 1 9 to 2022, W I L L I AMS and others i nti midated and interfered with individuals seeking to obtain or provide reproductive health services at other hea lth cl inics aeross the country, including in F lorida, Tennessee, Georgia, and Brooklyn, N ew York. For example, in January 2022, W I LLIAMS t ravelled to a health center i:n Fort Myers, F l orida, where she directed other i:ndividuals to block health center entrances. As a result of the blockade, medical staff was delayed in treating at least a dozen pa1ients, three of wbom were sched u led for time­ sensiti ve proced ures that could have result ed m bl eeding, i nfection, or signi ficant pain without timely treatment. 1n add ition, in J u ly 2022, W I LL IAMS invaded a heallh center in Atlanta Georgia, where she screamed through the door at patient attempt ing to enter the fac i lity unti l they were forced to leave. Among other things, WILLIAMS shouted that she ' d go to j ai l before letting patients enter the facility for an abo1tion and that she was "not a fraid to get arrested.' * * * In addition to the prison term, W I LL JAMS, 33. of OoJ tewah, Tennessee, was sentenced to two years of supervised release. Mr. Wi l l iams pra ised the outstanding work of the Federal Bl1Jeau of Investigation . The prosecution of this case is being bandied by the Office's Civil Rights U nit in tbe Criminal Divi s ion. Assistant U . S . Attomeys Emily A . Johnson, Mitzi Stei ner, and Jami e Bagliebter, with t he assistance of Paralega l Specialist Isabel Loftus, are in charge of the prosecution. 24-255 ### Y0u hil v� 1 't:<.' L ed tlu r-m,1 1 1 h •i.;,1 u:..� y 1u hu 1 1. ti . kcd l l' be 1 n t 1 lkd u l ch nge� rri 1h� U . S . AllorneY.'s Offi ce for the South rn District of N ew York'. wchs 1 1 1:. l H v Di I i w, is p r •n 1 d ing I hi:,, �0n !CL un h..:ha J f o l thl: I ,er 1 1 1 1 v t:. l J ft1tl.' f o r t 1 1 1 teJ S I .i ll: r\!lom •y � �pll n m � n l l1 f Ju. Ii c. 1./'il l I' ll!lS\• l v am 1w c . . W Wn:.h 111 g1 u11 I ) :!l h m :!02. - l J-2000 o ri J m:1_' no, , usl' yc, u r u h. c r 1 pt 1 f111 i n fi: 1 r m n ! l \ l l l lnr ,1 11 nthcr purpu. C!-.. l\.'l;.1 11:.1g£.your 't,liscnr.1 1 m. Depurt mc1 tl uf .l u:-;t 1Lc 1-'n vacY. Pnl tc _ _ ,pvOc l 1 w ry 1-'macy Pu l te_ _ Fol low us on Faccbook Fol low us_ on w i tter Follow us 011 Linkcd J11 SON Y Website EXHIBIT 153 From: "Patel, Sa1,jay (CRT)" To: "Kelly, Jacqueline (USANYS) 2" Cc: "Bagli ebter, Jamie (USANYS)" I Subject: RE; TENNESSEE WOMAN SENTENCED TO 4 1 MONTHS 1N PR SON FOR VIOLATING THE FREEDOM OF ACCESS TO CLINIC ENTRANCES ACT Date: Wed, 24 Jul 2024 14:26: 1 7 -0400 .Importance: NormaJ Wow! Congratulations, such an incredible result. Thank you for sharing the great news. SP From: Kelly, Jacqueline (USANYS) 2 � Sent: Wednesday, July 24, 2024 2:16 PM To: Patel, Sanjay (CRT)"� Cc; Bagliebter, Jamie (USANYS) � Subject: FW: TENNESSEE WOMAN SENTENCED TO 41 MONTHS IN PRISON FOR VIOLATING THE FREEDOM OF ACCESS TO CLINIC ENTRANCES ACT Hi Sanjay, Williams was sentenced today to the top of the GL-41 months. We are very pleased with the outcome. Thanks for all your assistance along the way. Jackie From: USANYS-PressOffice Sent: Wednesday, July 24, 2024 12:28 PM Subject:TENNESSEE WOMAN SENTENCED TO 41 MONTHS IN PRISON FOR VIOLATING THE FREEDOM OF ACCESS TO CLINIC ENTRANCES ACT '�""PR Header FOR lMMEDJATE RELEASE \Vednesday, July 24. 2024 httn://www.justice.gov/usao/n� CONTACT: U.S. ATTORNEY'SOFFICE Nicholas Biase, Lauren Scarff, --ord TENNESSEE WOMAN SENTENCED TO 41 MONTHS IN PRISON FOR VIOLATING THE FREEDOM OF ACCESS TO CLINIC ENTRANCES ACT Damian Williams, the United States Attorney for the. Southern Disttict of New York, announced today that BEVELYN BEATTY WILLIAMS was sentenced to 41 months in prison for violating the Freedom of Access to Clinic Entt·ances Act (the "FACE Act") in June 2020 in connection with her interference, including by threats and force, with individuals seeking to obtain and provide lawful reproductive health services at a reproduct1ve health center in Manhattan. On February 22, 2024, WILLIAMS was convicted after a nine-day jmy trial of one count of violating the FACE Act before U.S. District Judge Jennifer L. Rochon, who iwposed today's sentence. U.S. Attorney Damian Williams said: «Bevelyn Beatty Williams repeatedly intimidated and interfered wjth individuals seeking and providing critical reproductive health services. She did so by physically blocking access to clinics, threatening staff, and by force. This Office. and our Jaw enforcement partners are committed to ensuring that patients exercising their legal right to obtain reproductive health services, and healthcare facilities and their staff providing those services, can do so without un]i;twful interference or fear of threats or violence." According to evidence admitted at trial and other public filings and statements made in Court: On June 1. 9, 2020, and June 20, 2020, WILUAMS threatened and used force against patients and staff members at a reproductive health center located in lower Manhattan (the ''Health Center") and blocked patients and staff members from accessing the Health Center. In one instance, and as captured on video, WILLLAMS pressed her body against the door of the Health Center's patient entrance and refused to move, preventing a Health Center volunteer from entering the Health Center. As a Health Center staff member 1'Victim� J ") attempted to open the door for the volunteer, WTLLIAMS purposefuHy leaned against the door, crushing Victim-1 's hand. Victim-I yelled, ''She's crushing my hand," but WTLLIAMS remained against the door, trapping Victim- I 's hand and injuring it. At various times on June 1 9 and 20, 2020, WI LLlAMS stood directly in front of the Health Center entrances. WILLIAMS initially blocked the main entrance used by patients, causing the Health Center to have to dive11 patients to enter through the staff entrance. WILLIAMS responded by moving to block the staff entrance and directing others to do the same. WILLIAMS livestreamed some of her conduct on June 1 9 and 20, 2020, on a social media account. On the livestream on June 1 9, 2020, ·w1LLJAMS stood within inches of the Health Center's chief administrative officer and threatened to "terrorize this place" and warned that "we·'re gonna terrorize you so good, your business is gonna be over mama." Similarly, WILLIAMS stood witlun 'inches of a Health Center security officer and threatened "war." WILLIAMS also stated that she would act by "any means necessary." In addition to WILLIAMS 's conduct in Manhattan, on multiple other occasions from at least 20 1 9 to 2022, WILLIAMS and others intimidated and inte1fered with individuals seeking to obtain or provide reproductive health services at other health clinics across the country, including in Florida, Tennessee, Georgia, and Brooklyn, New York. For example, iJ1 January 2022, WILLIAMS travelled to a health center in Fort Myers, Florida, where she di.rected other individuals to block health center entrances. As a result of the blockade, medical staff was delayed in treating at least a dozen patients, three of whom were scheduled for time­ sensitive procedures that could have resulted in bleeding. infection, or significant pain without rimely treatment. ln addition, in July 2022, WlLLlAMS invaded a health center in Atlanta, Georgia, where she screamed through the door at patients attempting to enter the facility until they were forced to Leave. Among other things, WILLIAMS shouted that she'd go to jail before letting patients enter the facility for an abortion and that she was "not afraid to get aiTested." * * * I n addition to the prison term, WI LLIAMS, 33, of Ooltewab, Tennessee, was sentenced to two years o f supervised re lease . M r. Wi l l iams prai sed the outstandi ng work of the Federal B ureau of Tnves tigation. The prosecut ion of th is case i being hand.J ed by the Office's Civ i 1 Rights U nit in the Cri m inal Di v i si on . Assistant U .S . Attorneys Emi l y A . Johnson, M itzi Steiner, and Jam ie Bagl ie bter, w ith the assistance o f Paralegal Specialist Isabel Lo ftus are in charge of the prosecution . 24-255 ### 'v u u hu\'t: rccc1 vcJ t h i s l.' - ma i l hl.'cause _ ou h:t\C 3:,, kc