DOJ Unimpressed by Mo Brooks’ Kickass Conspiracy Defense

Last night, DOJ refused to certify that Mo Brooks’ actions laid out in a lawsuit by Eric Swalwell were done in the course of his employment as a Congressman. To understand why, and why Brooks may have given DOJ an easy way to prosecute him in conjunction with January 6, you have to look at the sworn declaration Brooks submitted in support of a claim that his call on Trump rally attendees to “kick ass” was part of his duty as a Congressperson.

Broadly, the Swalwell lawsuit accuses Brooks of conspiring with Donald Trump, Donald Trump Jr, and Rudy Giuliani to violate his civil rights by trying to prevent him from performing his official duties. One of the descriptions of the conspiracy is:

169. As described more fully in this Complaint, the Defendants, by force, intimidation, or threat, agreed and conspired among themselves and with others to prevent members of Congress, including the Plaintiff, and Vice President Mike Pence from counting the Electoral College Votes and certifying President Biden and Vice President Harris as the winners of the 2020 presidential election.

It alleges Brooks committed a number of overt acts, which include a series of Tweets that mirror and in one case anticipate the public claims the other alleged co-conspirators made, as well as his speech at the January 6 Trump rally where he incited listeners to “kick ass” to save the Republic.

Mo Brooks addressed the large crowd at the January 6 rally. He said “America is at risk unlike it has been in decades, and perhaps centuries.” He told the crowd to start “kicking ass,” and he spoke with reverence, at a purportedly peaceful demonstration, of how “our ancestors sacrificed their blood, sweat, their tears, their fortunes, and sometimes their lives,” before shouting at the crowd “Are you willing to do the same?!” Brooks intended these words as a threat of violence or intimidation to block the certification vote from even occurring and/or to coerce members of Congress to disregard the results of the election.

In general, Brooks’ sworn declaration, submitted in support of a petition to certify that he was acting within the scope of his office as a Congressperson, claimed over and over that the actions he admits to (he claims all but one of the Tweets in question were sent by his staffers) were done,

pursuant to my duties and job as a United States Congressman concerning presidential election dispute resolution obligations imposed on Congress by the U.S. Constitution, Amendment 12 in particular, and the United States Code, 3 U.S.C. 15 in particular.

That includes, for example, when Brooks claims he,

drafted my January 6, 2021 Ellipse Speech in my office at the Rayburn House Office building on my Congressional Office computer. I also timed, reviewed and revised, and practiced my Ellipse Speech in my office at the Rayburn House Office Building.

Claiming such actions were part of his duties as a Congressperson is how Brooks responds to most of the allegations against him. One notable exception is when he claimed,

I only gave an Ellipse Speech because the White House asked me, in my capacity as a United States Congressman, to speak at the Ellipse Rally. But for the White House request, I would not have appeared at the Ellipse Rally.

The far more notable exception came when, presumably in an effort to disclaim intending to invite rally participants to “kick ass” on January 6, Brooks explains that the “kicking ass” was instead an effort to get Republicans to start focusing on the 2022 and 2024 elections.

Swalwell errs by splicing one sentence and omitting the preceding sentence in a two-sentence paragraph that emphasizes I am talking about “kicking ass” in the 2022 and 2024 ELECTIONSThe full paragraph states, in toto:

But lets be clear, regardless of today’s outcome, the 2022 and the 2024 elections are right around the corner, and America does not need and cannot stand, cannot tolerate any more weakling, cowering, wimpy Republican Congressmen and Senators who covet the power and the prestige the swamp has to offer, while groveling at the feet and the knees of the special interest group masters. As such, today is important in another way, today is the day American patriots start by taking down names and kicking ass.

My intent in uttering these words was to encourage Ellipse Rally attendees to put the 2020 elections behind them (and, in particular, the preceding day’s two GOP Senator losses in Georgia) and to start focusing on the 2022 and 2024 elections.

“As such” is the key phrase in the second sentence because it emphasizes that the paragraph’s second sentence is in the context of the paragraph’s first sentence’s 2022 and 2024 election cycles (that began November 4, 2020).

Consisted with this is the middle part of the paragraph’s second sentence, which states, “taking down names”. Whose names are to be “taken down”? The names of those Senators and Congressmen who do not vote for honest and accurate elections after the House and Senate floor debates later in that afternoon and evening. Once we get and “take down” their names, our task is to “kick their ass” in the 2022 and 2024 election cycles. [emphasis original]

This claim is inconsistent with many of the other claims that Brooks makes. And claiming that he means to replace Senators and Congresspeople who don’t vote against the legal outcome of the election only defers the threats against those who don’t participate in an election scam.

But the most important part, for the purposes of Brooks’ efforts to dodge this lawsuit, is that he has just confessed, in a sworn declaration, to have been campaigning when he delivered the speech that he wrote using official resources.

That’s one of the points that Zoe Lofgren made, in her role as Chair of the Committee on House Administration, when providing a response from Congress in lieu of one from the House General Counsel. After noting that Members of Congress cannot, as part of their official duties, commit a crime, she then notes that members are also prohibited from using official resources for campaign purposes.

Conduct that is campaign or political in nature is also outside the scope of official duties and not permissible official activity. For example, regulations of the Committee on House Administration provide that a Member may use their official funds only for “official and representational expenses,” and “may not pay for campaign expenses” or “campaign-related political party expenses with such funds.”5

Similarly, the Committee on Ethics notes that, “Official resources of the House must, as a general rule, be used for the performance of official business of the House, and hence those resources may not be used for campaign or political purposes.”6 For purposes of this rule, “official resources” includes not only official funds, but “goods and services purchased with those funds,” “House buildings, and House rooms and offices,” “congressional office equipment,” “office supplies,” and “congressional staff time.”7 The limitations on the authorized use of official time and space for campaign or political purposes extends to activities such as “the drafting of campaign speeches, statements, press releases, or literature.”8 Moreover, the scope of campaign or political activities that may not be conducted with official resources is not limited to the Member’s own reelection campaign. As the Committee on Ethics explains:

Members and staff should be aware that the general prohibition against campaign or political use of official resources applies not only to any Member campaign for re-election, but rather to any campaign or political undertaking. Thus the prohibition applies to, for example, campaigns for the presidency, the U.S. Senate, or a state or local office, and it applies to such campaigns whether the Member is a candidate or is merely seeking to support or assist (or oppose) a candidate in such a campaign.9

In his motion, Representative Brooks represents to the court that he intended his January 6, 2021, speech to incite action by the thousands of attendees with respect to election activity. Representative Brooks states that he sought “to encourage Ellipse Rally attendees to put the 2020 elections behind them (and, in particular, the preceding day’s two Georgia GOP Senate losses) and to inspire listeners to start focusing on the 2022 and 2024 elections, which had already begun.”10 For example, Representative Brooks affirms that in his speech, he said, “Today is a time of choosing, and tomorrow is a time for fighting.” 11 According to Representative Brooks, the first half of that statement, “Today is a time of choosing,” is not a “call for violence,” but is instead a reference to “[w]hich Senators and Congressmen to support, and oppose, in future elections.”12 Further, he explains that the second half of that statement, “tomorrow is a time for fighting,” is a reference to “fighting” “[t]hose who don’t vote like citizens prefer … in future elections, as is emphasized later in the speech.”13

Similarly, Representative Brooks also declares that in his speech, he said, that “the 2022 and 2024 elections are right around the corner” and that “As such, today is important in another way, today is the day American patriots start taking down names and kicking ass.” 14 As he said “the 2022 and 2024 elections are right around the corner,” Representative Brooks withdrew a red cap that stated “FIRE PELOSI” from his coat, donned the cap, and wore it for the remainder of his speech.15 Representative Brooks says that, “The phrase, ‘As such’ emphasizes that the second sentence is in the context of the first sentence’s ‘2022 and 2024 elections’ time frame … and the desire to beat offending Republicans in those elections!”16 He asks and answers his own question about the timing: “When do citizens kick those Republican asses? As stated in the first sentence, in the ‘2022 and 2024 elections that are right around the corner.’”17 He later affirms that, “My ‘kicking ass’ comment referred to what patriotic Republicans needed to do in the 2022 and 2024 elections and had zero to do with the Capitol riot.”18

For Lofgren’s purpose, the important part is that Brooks has sworn under oath that the specific language that seemed to invite violence was instead campaign activity outside the scope of his official duties.

Essentially, in deflecting the allegation that his speech was an incitement to violence, Representative Brooks has sworn under oath to the court that his conduct was instead in furtherance of political campaigns. As noted, standards of conduct that apply to Members and precedents of the House are clear that campaign activity is outside the scope of official duties and not a permissible use of official resources.

She doesn’t say it, but Brooks’ declaration, including his confession that he wrote the speech in his office, is also a sworn declaration that he violated campaign finance laws by using his office for campaign activities.

The DOJ response to Brooks’ request for certification cites Lofgren’s letter while adopting a similar approach to it, one that would extend beyond Brooks’ actions to Trump himself. The entire rally, they say, was a campaign rally, and therefore outside the scope of Brooks’ employment as a Congressperson — or the scope of employment of any elected official.

The record indicates that the January 6 rally was an electioneering or campaign activity that Brooks would ordinarily be presumed to have undertaken in an unofficial capacity. Activities specifically directed toward the success of a candidate for a partisan political office in a campaign context—electioneering or campaign activities—are not within the scope of the office or employment of a Member of the House of Representatives. Like other elected officials, Members run for reelection themselves and routinely campaign for other political candidates. But they do so in their private, rather than official, capacities.

This understanding that the scope of federal office excludes campaign activity is broadly reflected in numerous authorities. This Court, for example, emphasized “the basic principle that government funds should not be spent to help incumbents gain reelection” in holding that House or Senate mailings aimed at that purpose are “unofficial communication[s].” Common Cause v. Bolger, 574 F. Supp. 672, 683 (D.D.C. 1982) (upholding statute that provided franking privileges for official communications but not unofficial communications).

The current House Ethics Manual confirms that the official business of Members of the House does not include seeking election or reelection for themselves or others. House resources generally cannot be used for campaign purposes, and Members’ staff may engage in campaign work only “on their own time and outside the congressional office.” House Ethics Manual, Committee on Standards of Official Conduct, 110th Cong., 2d Sess., at 121 (2008). For instance, Representatives cannot conduct campaign activities from House buildings or offices or use official letterhead or insignia, and congressional staff on official time should terminate interviews that focus on campaign issues. See id. at 127–29, 133. Of direct relevance here, a Member of Congress also cannot use official resources to engage in presidential campaigns: “[T]he general prohibition against campaign or political use of official resources applies not only to any Member campaign for re-election, but rather to any campaign or political undertaking,” and this “prohibition applies to, for example, campaigns for the Presidency.” Id. at 124; see Lofgren Letter 2.

First, the record indicates that Brooks’s conduct was undertaken as part of a campaign-type rally, and campaign activity is not “of the kind he is employed to perform,” or “within the authorized time and space limits” for a Member of Congress. Restatement §§ 228(1)(a), (b). Second, the Complaint alleges that Brooks engaged in a conspiracy and incited the attack on the Capitol on January 6. That alleged conduct plainly would not qualify as within the scope of employment for an officer or employee of the United States, because attacking one’s employer is different in kind from any authorized conduct and not “actuated . . . by a purpose to serve” the employer. Id. § 228(1)(c). Brooks does not argue otherwise. Instead, he denies the Complaint’s allegations of conspiracy and incitement. The Department does not address that issue here because the campaign-related nature of the rally independently warrants denial of certification, and because the Department is engaged in ongoing investigations into the events of January 6 more generally. But if the Court were to reject our argument that the campaign nature of the January 6 rally resolves the certification question, the Court should not certify that Brooks was acting within the scope of his office or employment unless it concludes that Brooks did not engage in the sort of conduct alleged in the Complaint. [my emphasis]

Brooks might object to DOJ’s determination that the entire rally was a campaign event; he claims the other parts of his speech were part of his duty as a Congressperson. But if pressed on that point, the inconsistencies within his own sworn declaration would either support the view that Trump’s actions also weren’t part of his official duties, or that he himself meant the “kick ass” comment to refer to events of the day and therefore did incite violence. That is, the inconsistencies in Brooks’ sworn declaration may corner him into statements that go against Trump’s interests as well.

Importantly, DOJ’s filing treats the question of whether Brooks committed a crime as a separate issue entirely, asking Judge Amit Mehta not to rule in Brooks’ favor without first analyzing Brooks’ conduct to determine if the conduct alleged in the complaint — which happens to be but which DOJ doesn’t spell out — is a conspiracy to obstruct the vote count, the same charge used against three different militias charged in January 6.

Once again, DOJ emphasizes that this language applies to any Federal employee.

Instead, he denies the Complaint’s allegations of conspiracy and incitement. The Department does not address that issue here because the campaign-related nature of the rally independently warrants denial of certification, and because the Department is engaged in ongoing investigations into the events of January 6 more generally. But if the Court were to reject our argument that the campaign nature of the January 6 rally resolves the certification question, the Court should not certify that Brooks was acting within the scope of his office or employment unless it concludes that Brooks did not engage in the sort of conduct alleged in the Complaint.


Here, the Complaint alleges that Brooks conspired with the other Defendants and the “rioters who breached the Capitol on January 6” to prevent Congress from certifying the Electoral College votes. Compl. ¶ 12. To serve that end, the Complaint alleges that, among other things, the Defendants conspired amongst themselves and with others to “injure members of Congress . . . and Vice President Pence” in an effort to disrupt the peaceful transfer of power. Compl. ¶¶ 1, 12, 171, 179. Such a conspiracy would clearly be outside the scope of the office of a Member of Congress: Inciting or conspiring to foment a violent attack on the United States Congress is not within the scope of employment of a Representative—or any federal employee— and thus is not the sort of conduct for which the United States is properly substituted as a defendant under the Westfall Act.

Brooks does not argue otherwise. Instead, he denies the Complaint’s allegations that he conspired to incite the attack on the Capitol. See Brooks Aff. 17–18.5 The Department of Justice does not address that issue here. The campaign or electioneering nature of Brooks’s participation in the January 6 rally independently warrants denial of certification, and the Department is engaged in ongoing investigations into the events of January 6 more broadly.6 But if the Court were to reject our argument that the campaign nature of the January 6 rally resolves the certification question, the Court should not certify that Brooks was acting within the scope of his employment unless it concludes that Brooks did not engage in the sort of conduct alleged in the Complaint. Cf. Osborn v. Haley, 549 U.S. 225, 252 (2007) (recognizing that scope-of-employment questions may overlap substantially with the merits of a tort claim).

6 As this Court is aware, the U.S. Attorney’s Office for the District of Columbia and the Federal Bureau of Investigation have for several months continued their investigation and prosecution of those responsible for the attack. This investigation is ongoing. More than 535 defendants have been arrested across the country and at least 165 defendants have been charged on counts ranging from destruction of government property to conspiracy to obstruct a congressional proceeding. See Department of Justice Statement, [my emphasis]

Someone could write a book on how many important cases Judge Mehta has presided over in recent years. But he’s got a slew of January 6 defendants, including all the Oath Keeper conspirators. And so Mehta is not just aware that DOJ is conducting an ongoing investigation, he has also presided over four guilty pleas for conspiring to obstruct the vote count, close to (but charged under a different law) as the claim Swalwell made in his complaint.

So Mehta has already accepted that it is a crime to obstruct the vote count, four different times, with Jon Schaffer, Graydon Young, Mark Grods, and Caleb Berry. He’d have a hard time ruling that, if Swalwell’s allegations are true (as noted, Brooks contends that some of them are not, and they certainly don’t yet present enough proof to support a criminal prosecution), Brooks would be exempt from the same criminal conspiracy charges that the Oath Keepers are pleading guilty to.

DOJ’s declaration is not (just) an attempt to create space — by distinguishing campaign activities from official duties — between this and DOJ’s decision to substitute for Trump in the E. Jean Carroll lawsuit. It is an effort to preserve the principle that not just Congresspeople, but all Federal employees, may be charged and convicted of a conspiracy to obstruct the vote count, particularly for actions taken as part of campaign activities.

136 replies
  1. Fraud Guy says:

    So if only they had just discussed how to arrange support for the vote itself among members of Congress to stop/deny the count in Congress, as opposed to all of their efforts to create outside pressure and events, they would have been fine, if assholes.

    Of course, since it appears to be a conspiracy, those who worked with them to vote against the count in Congress become part of the external conspiracy by taking acts to further it?

  2. Peterr says:

    The incongruity of Brooks claiming that his speech was protected as part of his official duties (noting that he drafted it and practiced it in his House office) while at the same time repeatedly calling it a campaign event is truly stunning.

    No, strike that. It’s truly what we have come to expect from the Sedition Caucus.

      • John Paul Jones says:

        His Wikipedia page – which seems to derive largely from his official Congressional bio – indicates a purely local politician, able to rise to the “top” in Alabama but with no traction nationally, and always focussed on a political career rather than the legal career he supposedly trained for. He seems to have made a mistake in ’91 when he got himself appointed (local connections, I would guess, from his time as an Alabama state rep.) as a county DA when the incumbent went to Congress, and then lost the election for DA the next year. Having run out of immediate political options, he joined a law firm (Karl W. Leo) which his bio says has a national focus, but which when you look it up today, seems to have a mostly Huntsville focus. The Alabama Republican party came to his rescue a couple of years later and appointed him “state special assistant attorney general” under Jeff Sessions, a post he continued to occupy when Sessions moved to the US Senate and the Alabama AG post was won by Bill Prior. About the same time he got himself elected as a county Commissioner – I’m assuming the voters thought his status as an assistant AG would do the county no harm – a job he seems to have kept until he ran for Congress in 2010. In the interim (2006) he tried for Lieutenant Governor of Alabama and failed. He went to Congress in the first mid-terms of the Obama administration, the election which wiped out house Democrats. Not that Brooks needed that particular bit of momentum; his seat was rated as safe Republican. Even so, his margins have dipped down (except in 2020 when the Democrats didn’t run a candidate) so one would guess that his constituents, if the Party gave them a choice, would maybe plump for a different Congressman.

        In short a career not particularly noteworthy for zeal or ability, beyond the ability to mix and mingle with the boys in county and state politics. His Wikipedia bio doesn’t note any particular pieces of legislation his name is attached to, and his committee assignments look like they are important to his district via the Redstone Arsenal (which is just down the street from the Leo law firm, and is where his dad worked for most of his life). As for issues, Brooks seems to think that there is a “war on whites” being waged by both the Democrats and the Republicans. So yeah, I would endorse the statement: “not real bright.”

        • P J Evans says:

          Handwriting looks like grade school exercise stuff. Most of us, by the time we finish HS, have writing that’s more individual than that.

        • John Paul Jones says:

          Yeah, I was struck by that too, by the grade-three kind of look of it, rounded and cautious, as if he didn’t quite trust his mastery of the tool. A little odd for someone his age.

        • M Smith says:

          He signature reads ‘Morris Jackson “Mo” Brooks’, just liked the typed name underneath. Is he so strange as to sign everything this way, or is he so stupid he thought he had to sign it the same as it was printed?

        • Rayne says:

          Need to find a few more examples if possible of his signature. It almost looks like a woman’s, as if his wife or staffer had signed the document. He’s shallow (no real depth to his signature below the line, part floats above it), has ample ego (larger than average letters, signature consumes more than signature line provided), and acquisitive (handles on his Ms, of which he ensures there are two).

        • blueedredcounty says:

          Thank you! I also thought it looked more like a woman’s handwriting. And a young woman, at that.

        • Rayne says:

          LOL Trump’s signature is all shark’s teeth – anyone can analyze that, no training necessary.

          Also what the heck are you using for a device? Because I’m nowhere near margin busting with my link when viewed on my desktop!

        • posaune says:

          Rayne @ 6:49
          I’m almost guessing that he might be dysgraphic (frequently accompanying dyslexia), and that there could likely be some sort of cognitive disability. Could explain the lack of traction in life.

        • Rayne says:

          There’s not enough handwriting specimens to examine to make that guess, IMO. Need at least a paragraph each written under concentration and another written rapidly. (My own handwriting is frequently dysgraphic.)

        • Stephen Calhoun says:

          The assumption in graphology is that inferences about concrete elements of personality built from analysis of written marks are to some predictable degree accurate.

          Today I have spent time trying to figure out whether graphology is a science. My working assumption is that research models would likely be very straightforward and use the Big Five or HEXACO PI-R to establish the positive target. My method was to search for research in journals of psychology or journals of forensics. I also assumed I would run across technical manuals, textbooks, or guidebooks which would include in their bibliographies references to scientific research.

          The most interesting aspect I was hoping to inform myself about is what explains the somatic (or enactive,) element in the extension of personality into handwriting?

          (My own signature is, ummm, ‘abstract expressionist.’ My handwriting is not refined. This may be because I have been using a keyboard for 95% of my writing for over 45 years.)

        • Terry says:

          Graphology is certifiable hooey.

          [Welcome to emptywheel. Please use a more differentiated username when you comment next as we have several community members named ” Terry” or a variant. Thanks. /~Rayne]

        • Nord Dakota says:

          Oh my, I took a second look: “solemnly”?
          I tried to pronounce that but my tongue got twisted

        • Nord Dakota says:

          wait, I guess that is right
          it just looked wrong
          sigh. . .
          never look at a word too closely, they always look strange
          as for the handwriting, I thought the same as everyone else

        • Zirc says:

          I don’t have a lot of beefs with Obama, but getting installing Tim Kaine in the place of Howard Dean as head of the DNC in 2009 is a large one. 2010 may still have been a loss with Dean, but I am firmly convinced it wouldn’t have been the complete disaster it was under Kaine. We are still living with the results of that disaster in the form of gerrymandered districts, states where dems get the majority of the votes but the minority of the seats in state legislatures, and the ascendancy of the Tea Party which morphed into the MAGAts.


        • P J Evans says:

          Dean did a lot with the “50 state” idea. We’d be in a lot better shape if that had kept going.

    • Pete T says:

      This is – and has been – a pattern including the fg. They say what they man then claim the what they said is not what they meant.

      What would a regular ole “Jane or Joe” think hearing those words in that setting. Nuance about the 2022/2024 elections would not be the first thing that comes to mind.

    • Carolyn says:

      We all know what we saw and heard. This whole circus was intended to fire up the base to march on our Capitol and “Stop the Steal”!

      • Raven Eye says:

        Thoughts and prayers.

        At least you didn’t say he was your Member. ;-)

        But I know how you feel…The eastern edge of Nunes’ district is across the street from the house where I grew up.

        • P J Evans says:

          The area where I lived in west Texas elected a guy with no real qualifications, just that “R” after his name, and he’s been lying to them for 2.5 years (got re-elected). The one before him was barely better.
          I know they’re not stupid people, but they are brainwashed.

  3. Stacey says:

    How hard would it be to make the case that almost 100% of everything Trump did or said EVER was campaigning and not his official duties? Given that he literally turned absolutely everything he touched into ‘how does this benefit me politically?’ (or financially, but I guess that whole emoluments thing was never a real law or anything???). I mean his call to Ukraine’s president wasn’t even his official duty, it was him campaigning against Joe Biden, full stop!

    But then I’m still not clear how calling his rape accuser ‘not my type’ was in his official duties, either, so maybe some of this wasn’t too well thought out in DOJ??? Why didn’t Bill Clinton think of that? The blow job was IN THE OVAL OFFICE, that’s pretty ‘official’ right? With an ‘official’ intern. Trump would try that in a heart beat!

  4. Tom says:

    Elise Sycofanik on the Lincoln assassination: “The American people deserve to know the truth, that Abraham Lincoln bears responsibility for the tragic events at Ford’s Theatre on the evening of April 14, 1865. If only President Lincoln hadn’t given in to his desire to take in a play that evening, he might still be alive today.”

    • Tom says:

      And then there’s Chief Constable Jim “Jock-Sniffer” Jordan, called out to Snavely Manor to investigate why Colonel Plumtree was found face-down on the floor of the billiards room with an assegai in his back, who then declares that “the fundamental issue” is why the late Colonel didn’t have peanut shells scattered over the floor so that he could hear if anyone was sneaking up behind him.

      • Max404 says:

        I really wish jock-sniffing didn’t nowadays get such a bum rap. There were entire issues of St. Boyd McDonald’s immortal “Manhattan Review of Unnatural Acts” (aka “Straight to Hell”) dedicated to jock-sniffing. Gym Jordan has really debased the ancient practice.

    • Rayne says:

      Yes, why did Brooks know in advance there was a risk of violence necessitating personal protective gear, a risk for which the Capitol Police were not adequately prepared nor National Guard on standby?

      Why had Brooks not ensured the rest of his cohort in Congress were likewise prepared if as he claims he was performing his duty as a member of Congress on January 6?

      Which other members of Congress were wearing body armor that day?

      • P J Evans says:

        My guess is that he knew that the insurrectionists couldn’t tell him from any of the other white guys in Congress, and wanted to be sure he was “protected” against them.

        • Rugger9 says:

          Body armor doesn’t protect against head shots or bear spray, for example, and I would surmise that if he was captured and the rioters found body armor on him it would go much worse for Brooks. It’s sort of like have a radar detector visible when the cop pulls you over for speeding.

        • Rayne says:

          Which is likely why the yellow-and-black windbreaker. He’s also not Black, Asian, or other non-white as well as male, making him a less likely target.

      • bmaz says:

        Let’s ask him under oath.

        Now to be honest, DOJ is not the last word. Brooks, Rosen and any other prick can still affirmatively assert speech and debate privilege. So, this is not over, and will not be for a while. Go reread the William Jefferson litigation. He ultimately lost, but it took awhile.

        • emptywheel says:

          Yes, but they’ve got a sworn statement from him saying this is campaign activity, not speech and debate.

        • Peterr says:

          True, but I also have no sense that Brooks would feel bound by this, penalties for perjury/false statements notwithstanding.

          “I was coerced! . . . It was an FBI sting! . . . I’m being misinterpreted! . . . I didn’t understand the question! . . . “

        • Rugger9 says:

          How far out does S&D protection go? IIRC it was limited to the floors of Congress, but I’m pretty sure there is precedent taking it farther afield away from DC. However, as EW notes Brooks threw that defense away.

          Nonetheless, I think Brooks will still try it if for no other reason than to gum up the legal works.

        • timbo says:

          Hey, if you’re going to talk to a crowd full of gun nuts, after having spent months getting all of them riled up with worse than nonsensical ranting, it might be best to wear a bullet-proof vest, correct? I mean, what happens after they figure out that the Congressman is full of it?

      • BobCon says:

        Until the metal detectors went up, Rep. Andy Harris was regularly taking a gun into the House chambers.

        • Rayne says:

          Sure, sure, and yet Brooks wasn’t wearing his body-armor-hiding windbreaker during his Congressional speech-and-debate until January 6.

        • BobCon says:

          I suspect the ones who are plugged into the right wing extremist networks like Harris have been making use of vests and guns for a while as a hedge against the people they are allying with.

          The truly dumb ones like Gosar maybe think it’s protection against Antifa, but I think the more cynical operators like Harris know they are working with highly unstable people and what happened to Pence could happen to them too.

      • Leoghann says:

        His interviewer purports to have asked him that; thus far, he has refused to say who tipped him. As far as other members’ body armor, I guess we need to check photos to see who else was wearing a “nice little windbreaker” that day.

    • harpie says:

      Mo BROOKS [7/28/21]:

      I was warned on Monday [1/4/21] that there might be risks associated with the next few days.

      And as a consequence of those warnings, I did not go to my condo. Instead, I slept on the floor of my office. And when I gave my speech at the Ellipse, I was wearing body armor.

      That’s why I was wearing that nice little windbreaker, to cover up the body armor.

        • vicks says:

          I am missing the “why” in Mo telling a reporter he was wearing body armor?
          They say to look through the eyes of the ignorant in political messaging but in the case of people like Mo Brooks, does that mean looking through HIS eyes, or the eyes of those he is trying to manipulate?

      • harpie says:

        Six days earlier:

        12/29/20 Ali ALEXANDER claims he planned the upcoming Jan. 6 protest with Republican Reps. Paul GOSAR (R-AZ), Andy BIGGS (R-AZ), and Mo BROOKS (R-AL).

      • earlofhuntingdon says:

        What retirement-age congresscritter sleeps on the floor of his government office – close to his own home – in anticipation of the peaceful gathering of thousands of happy supporters he had helped to organize for the next day? Was he working on the gathering all night, and wanted to pretend it was all legislative business, covered by the speech and debate clause?

        Seems odd, given that the “risks” to peaceable assembly he should have heard about were coming from his side of the aisle. The rationale for the body armor seems equally dubious.

        • John Paul Jones says:

          I would take him at his word, but only in the sense that he was worried that shooting might start. If it did, doesn’t matter which side would have initiated the exchange of fire if you are unprotected. He might also have been flashing back to the baseball shooting at which he apparently was able to think clearly enough to help the wounded.

          But this might be also be telling us a couple of things. First, Slo Mo has people around him who can think and who likely told him the above (the thought being that it’s better to have something and not need it rather than need it and not have it), and second, that those thinkers are the same sort of people who would set up an armed QRF. It would be nice to know, in short, whether Mo was in contact with either the militia groups, or in contact with someone who was in contact with the militias.

        • timbo says:

          “I was wearing my bulletproof vest so that I could throw my body in front of the Vice President in case the Antifa mob got to him!” #waitingforit

        • earlofhuntingdon says:

          Those are possibilities, but are extrmely unlikely. The context is that Mo is a dedicated and an exaggerated Trumpy, who helped organize the events of January 6.

        • BobCon says:

          It’s a tough thing to untangle, and depends in part on how dumb Brooks is.

          During the 50s and 60s, there were a number of Southern politicians who collaborated with the Klan who also slept with a revolver or shotgun under the bed.

          The dumb ones were 100% sure it was protection against commie red Black nationalists. But there were also the more cynical, calculating types who realized they were running rhe risk of stirring up the Arthur Bremers, but decided to roll the dice anyway.

      • P J Evans says:

        I’d have thought he’d be much safer in his condo than in his office. So why *was* he sleeping in his office? Waiting for things to happen so he could go out and make another “campaign speech” to a crowd of non-constituents?

        • Rugger9 says:

          Boebert, MTG, Hawley of the fist pump, Tuberville, Gym Jordan, Gosar (off the top of my head) will all need to have their movements evaluated, maybe even Nunes as well given how far Devin went to keep DJT “informed” during earlier investigations. Once Bennie Thompson gets into the conspiracy I think there is a target-rich environment.

          FWIW, I personally do not think McCarthy was in on it, otherwise why would he call DJT as he did to get Individual-1 to call off the rioters? Let’s also remember how McC blabbed about the real reason for the interminable Benghazi hearings before Ryan shushed him, so I would suspect the orchestrators wanted McC kept in the dark to prevent him blurting out something.

    • Savage Librarian says:

      And he was wearing his bright yellow and black Proud Boy colors. No mistaking that.

      • Rayne says:

        Yikes — I hadn’t even noted that detail. Now I would like to know when and where he acquired that “nice little windbreaker.”

        • Rugger9 says:

          Not that Mo Brooks could ever be accused of being subtle or nuanced, but IIRC didn’t the PBs tell their minions to keep the colors off that day?

        • ceebee says:

          I believe they did specify civvies for the day.
          OTOH, PBs might think having sympathetic officials in cosplay garb on the scene is rather flattering if not encouraging.

  5. Tom says:

    As Marshall McLuhan once stated, “the medium is the message” and in the case of Mo Brooks on January 6th the medium was his speech and the manner in which he delivered it, not just the text on the printed page. Brooks may point to “As such” and claim it is “the key phrase” in the passage from his speech quoted above that truly explains and justifies his words and intentions that day, but “as such” it is the reddest of red herrings.

    “As such” is just a filler phrase; omitting it makes no difference to what Brooks meant to say and the goal he had in mind. For his real message was in the harsh, angry, rabble-rousing tone of voice he used, the expansive arm gestures and aggressive finger jabs that accompanied his call-to-arms. For Brooks to say otherwise is the same as imagining Shakespeare’s Mark Antony denying after his speech at Caesar’s funeral that he meant to incite the Roman mob against Brutus and his fellow conspirators. After all, did he not say they were “all honourable men”?

  6. Badger Robert says:

    OT: is former acting Attorney General Rosen going to be forced to speak to DoJ and Congressional investigators?

    • Rugger9 says:

      And focused, all in all as good an American as any except in MAGA world where her ancestry (Hmong, who lost lots of people supporting us in Laos during the Vietnam War) means she’s not really on their level (as they see it).

      It also pointed out just how talented the team is, and I’m still hoping Simone Biles gets things squared away before Sunday because she is just that awesome a talent.

      • Marinela says:

        Can’t imagine how hard must be for Simone Biles, and her determination to ensure the team succeeds is really awesome. Things would probably be different for Simone last year, but she is mature to know her goat legacy will remain intact after Tokyo, even if she is unable to compete.

        Seems like the Olympics, especially gymnastics, they always hype controversies, Simone Biles is telling us it doesn’t need to be this way.

      • P J Evans says:

        I read that she’s not allowed to have her prescription meds, because of Japan’s anti-drug laws. That can’t be helping any.

  7. harpie says:

    Trump Pressed Justice Dept. to Declare Election Results Corrupt, Notes Show
    “Leave the rest to me” and to congressional allies, the former president is said to have told top law enforcement officials. Katie Benner July 30, 2021 Updated 11:41 a.m.

    […] according to new documents provided to lawmakers and obtained by The New York Times. […] The exchange unfolded during a phone call on [Sunday] Dec. 27 in which Mr. Trump pressed the acting attorney general at the time, Jeffrey A. Rosen, and his deputy, Richard P. Donoghue, on voter fraud claims that the department had disproved. Mr. Donoghue warned that the department had no power to change the outcome of the election. Mr. Trump replied that he did not expect that, according to notes Mr. Donoghue took memorializing the conversation.

    “Just say that the election was corrupt + leave the rest to me” and to congressional allies, Mr. Donoghue wrote in summarizing Mr. Trump’s response. […]

    • harpie says:

      […] In a moment of foreshadowing, Mr. Trump said, “people tell me Jeff [Bossert] Clark is great, I should put him in,” referring to the acting head of the Justice Department’s civil division, who had also encouraged department officials to intervene in the election. “People want me to replace D.O.J. leadership.” […]

      So, that’s a prequel to the discussions we talked about here:

    • harpie says:

      Later that evening:

      12/27/20 STONE and TRUMP meet at Mara-lago:
      3:50 AM · Dec 28, 2020

      STONE: I thanked President Trump in person tonight for pardoning me.
      I also told the president exactly how he can appoint a special counsel with full subpoena power to ensure that those who are attempting to steal the 2020 election through voter fraud are charged and convicted and to ensure that Donald Trump continues as our president #StopTheSteal #rogerstonedidnothingwrong

      • harpie says:

        I mentioned this in relation to Brooks above, but it also fits here:

        Two days later: [#StoptheSteal]
        12/29/20 Ali ALEXANDER claims he planned the upcoming Jan. 6 protest with Republican Reps. Paul GOSAR (R-AZ), Andy BIGGS (R-AZ), and Mo BROOKS (R-AL).

        • bmaz says:

          “Republican Reps. Paul GOSAR (R-AZ), Andy BIGGS (R-AZ), and Mo BROOKS (R-AL).”

          Real men of genius.

        • Rugger9 says:

          There are reports from Bedminster where DJT and Meadows are talking about the “cabinet meetings” and “cabinet members” in interviews (on Newsmax IIRC). That would seem to point to a pretty organized conspiracy / shadow government, but IANAL.

          The GQP is daring the Ds to subpoena everyone from DJT on down. Let’s indulge them.

        • bmaz says:

          Sure, but the thing with Congressional subpoenas is that you have to enforce them. The Dems are simply pathetic at that.

    • harpie says:

      From the notes:
      1] 12/27/20 TRUMP: Once Jim Jordan-fighter-We’re like a third world country

      2] 1/11/21

      the same day an article of impeachment was filed in the House against Donald Trump for “incitement of insurrection”, Trump awarded [link] Jordan the Presidential Medal of Freedom in a closed ceremony at the White House.

      3] 7/29/21
      3:25 PM · Jul 29, 2021

      Jim Jordan tried to dodge a question about when he talked to Trump on January 6 and it did not go well [VIDEO]

      That second entry is from this:
      What did Jim Jordan know about the insurrection and when did he know it?
      I have some questions for the Republican congressman about events at the US Capitol on 6 January
      Sidney Blumenthal

      • harpie says:

        First words of President Donoghue wrote down:

        12/27/20 DAG call – on with POTUS + wants to conference me [RPD] [Donoghue] in

        P: Count[r]y is up in arms over the corruption

        • harpie says:

          Well, that didn’t come out the way I intended…lol!
          The first words Donoghue wrote down, quoted the President. [No quotation marks, though.]

    • harpie says:

      These are the totality of the notes from the 12/29/20 phone call with the WH [I could use help with initials and the “illegible” bits!]:

      p9] 12/29/20
      mtg w/: CofS, WH Counsel (PC +PP)[??], DAG, RPD [Donoghue] , SE

      Mark [???]
      John Eastman <<< P trusts [illegible] – they [illegible]
      # of votes cast.
      4) [Pointing at Eastman’s name] [illegible] – US. does not [underlined in original] have strength, DOJ should talk to the Olsens (atty who filed similar case)

      Arturo D’Elio – RPD to check his background w/ FBI+
      [This is about the ITALY conspiracy theory and I am NOT [underlined in original] transcribing it]

      • harpie says:

        Kurt OLSEN [from DONOGHUE’s point 4 ABOVE]:

        12/28/20 TRUMP “directs OLSEN to meet with AG Rosen on 12/29/20

        12/29/20 […] Eager to speak with Mr. Rosen about the draft Supreme Court lawsuit, a lawyer named Kurt Olsen, who had advised on Mr. Paxton’s effort, tried unsuccessfully to reach him multiple times, according to emails sent between 11 a.m. and 10 p.m. on Dec. 29 and obtained by the House Oversight Committee investigators.

        12/29/20 OLSEN to Solicitor General WALL:
        Last night the President directed me to meet with AG Rosen today to discuss a similar action to be brought by the United States […] I have not been able to reach him despite multiple calls/texts. This is an urgent matter. […]

        • harpie says:

          This thread shows Robert HYDE at the WILLARD with STONE and RUDY and EASTMAN:

          Capitol Hunters thread on
          Robert Patrick LEWIS and his group: 1st Amendment Praetorians

          8:01 AM · Jun 25, 2021

          #SeditionHunters – in ancient Rome, the elite Praetorian Guard kept overthrowing the emperors they were assigned to protect. In DC this January, seems the “1st Amendment Praetorians” had similar ambitions – intrigue is timeless. Here’s a 1st thread on 1AP & the Willard Hotel 1/ […]

        • harpie says:

          …from the Insta of CT lobbyist & Ukraine schemer Robert Hyde. Call it the Sore Loser room: it holds 3 failed Congressional candidates (Hyde, Eastman, Ramsland) + the son of a 4th (Daniel Bostic, dad is Curtis). Seems like a political / propaganda group, not military ops… 8/ [PHOTO]

    • harpie says:

      These are the Trump quotes [only the first does NOT use quotation marks]:

      1] P: County is up in arms over the corruption
      2] “You guys may not be following the internet the way I do”
      3] P: “Don’t expect you to do that, just say that the election was was corrupt + leave the rest to me and the R. Congressmen.”
      4] “We have an obligation to tell people that this was an illegal, corrupt election.”
      5] “Nobody trusts the FBI”
      6] “I’d like to request”

      • harpie says:

        3] just say that the election was was corrupt
        4] tell people that this was an illegal, corrupt election

        On 1/11/21 When TRUMP gave JORDAN the Medal of Freedom [link above] in that private ceremony, he said Jordan was being honored because he had

        worked to unmask the Russia hoax and take on deep state corruption – confronting senior justice department officials for obstructing Congress and exposing the fraudulent origins of the Russia collusion lie […] led the effort to confront the impeachment witch hunt.

        From that impeachment “Witch Hunt”:
        7:31 AM – 20 Nov 2019

        Key point from Sondland: Zelensky “had to announce the investigations, he didn’t actually have to do them, as I understood it.”

        In other words, whether or not Ukraine actually investigated Biden/Burisma/2016 was less important to Trump than their *saying* they were being investigated. It wasn’t about rooting out corruption, it was about publicizing information helpful to Trump.

        • harpie says:

          When I think of Impeachment #1, I think of
          Ambassador Marie Yovanovitch, and that reminded me just now that her stalker, Robert HYDE, was at the WILLARD Hotel with RUDY and EASTMAN and STONE et al on J6. [I’ll link that info above with RUDY]

        • Rayne says:

          I think this particular comment contains the singularly most powerful bits if we look at this through the lens of 18 U.S. Code § 610 – Coercion of political activity — the President issued an order when he instructed federal employees using the words “say” and “tell.” This was not a suggestion or exhortation but direction.

          It was electioneering, as your transcript at 1:19 pm noted; the instruction was relevant to political activity and not law enforcement.

        • harpie says:

          [quote] It is the three-pronged plan that elevates Trump and his top Republican allies from merely corrupt to outright seditionists. It was a plan intended to erase a U.S. presidential election. [end quote]

          I tend to agree with this…a seditious conspiracy.

        • harpie says:

          Thanks for that interesting observation, Rayne… Trump always acted as if the entire federal government was working for him…and his threat to replace them with Clark was practically the next thing D. wrote down.

          That electioneering comment seems to be someone [Donoghue?] writing his thoughts for the record. [not said out loud to Trump, I think.] Can you tell what the little squiggle before that comment is? Looks like it might be the initial “D”?

        • Rayne says:

          I don’t know, harpie, I’ve looked at this quite awhile now and with zoom and magnifying app – I don’t think it’s a D but a P because it looks like other Ps throughout the notes. I wonder if this wasn’t something Trump said but said to trump given the emphasis with the dots beneath the word “electioneering,” as if this was emphasized to him. This may need testimony to clarify.

          EDIT: Just dawned on me as I added this image and opened it yet again that perhaps that last word isn’t “period” but “fraud” with an F which doesn’t look like the other Fs in the document. Which means that’s a P and Trump told them this was “electioneering fraud” in spite of their objections to his lack of evidence.

          If this is what Trump said, it means someone explained to him what electioneering is and he therefore has an understanding which makes effort fully conscious and deliberate. This may explain the (unintentional) emphasis with the pen dot-dot below the word.

          It’s also possible it’s not “electioneering” but “election turning” with insufficient space or a dash between the two words. It may have given pause for some reason.

          Again, a statement is really needed for clarification.

        • harpie says:

          THANK YOU! I think you’re right:

          *-Pthis is election-turning fraud [no quotation marks in original]

          …and the next thing D. wrote down is Trump saying “we have an obligation to tell people […]”

  8. Rapier says:

    While Emptywheel is doing yeoman work keeping track of the Maga insurrectionists I’ve decided to start to organize the information about the Antifa members being swept up in the January 6 attack on the capital.

    Below is my initial summary.


    More to follow.

    • timbo says:

      Above appears to be the final summary. There weren’t any “antifa” folks at the Jan 6 riot and insurrection…unless you include the police and other folks protecting the Capitol from the insurrectionists. In fact, the bulk of the folks who “marched down there to ‘Stop The Steal!'” there seem to have been fascist and/or nutty yahoos.

  9. harpie says:

    Handwritten notes of Acting Deputy Attorney General Richard Donoghue of call with President Trump on Dec. 27, 2020 and call with White House on Dec. 29, 2020

    p1] 12/27/20
    DAG call – on with POTUS + wants to conference me [RPD] [Donoghue] in

    *P: Country is up in arms over the corruption [no quotation marks in original]
    *Scott Perry (PA) and Senator of PA – [Probably] Doug Mastriano Some of the [illegible] calling
    *205K votes – more than they have voters – PA
    *- flooded the market with ballots
    *- 600K votes added
    *- 570K – for Biden
    – few for me and lots of [blanks?]
    *0332 – flooded the market – all at
    – multiple states [illegible]
    *Jim Jordan – fighter – we’re like 3rd world country
    *Detroit – look at districts in MI
    – was nearly all but not Wayne City (Detroit)

    P2] Call dropped … ~ 3 mins [illegible]
    *- We have tremendous of people who went in to vote + were told you already voted by absentee ballot
    *- people are angry – blaming DOJ + [illegible]
    *- Statistically – election night it was a done deal
    – somehow, overnight the outcome changed bec all the ballots showed up
    *- AZ, GA, PA …
    *People won’t have confidence in the GA Senate races
    *GA/NV/AZ/MI – all corrupted elections
    *People are complaining to him constantly
    *Thousands of people call their USAOs + FBI

    p3] *DOJ failing to respond to legitimate complaints / reports of crimes
    *PA – 5M votes in the state
    – But 5.25M votes – clearly fraud
    >>>(Possibly true?)
    *GA – tape there shows fraud
    – Ruby Freeman – Huckster – closed the facility + then came back w/ hidden ballots, under table …
    *- networks unjustified the tape + saw them verify the transfer repeatedly
    *“You guys may not be following the internet the way I do” [quotation marks in original]
    *Detroit – throw the poll watchers out
    *Don’t even look at the illegal aliens
    [illegible] – don’t need to, it’s obvious
    *FBI will always say voting [nothing?] there – leaders there oppose me, SA’s [State Assemblies?] support me

    • harpie says:

      p4] *(TN) – that whole thing, clergy…
      – talked to the Gov. there
      – also upset
      *- I made some bad decisions on leadership there, but I was laboring under [illegible] illegal investigation – Special [illegible]. Should never have been [commenced?]
      *- You figure out what to do with H. Biden – people will criticize the DOJ if he’s not investigated [illegible]
      *- GA Leg. Is on our side – they want to bring a case but the Gov won’t let them
      *- Statistically impossible for me to lose
      – bookies had me at 100% on election night – dropped to 32% in 4 or 5 hours
      – never happened
      *>>>- DAG – will look at whether have more ballots in PA than registered voters – should be able to check on that quickly but understand that the DOJ can’t + won’t snap its fingers + change the outcome of the election, doesn’t work that way.
      *- ,strong>P: “Don’t expect you to do that, just say that the election was was corrupt + leave the rest to me and the R. Congressmen.” [quotation marks in original]

      p5] *>>>- RPD – Sir, we have done layers[?] of investing., hundreds of interviews major[?] allegations are not supported [underlined in original] by evidence [illegible]
      *- GA/PA/MI/NV
      *>>>- We are doing our job. Much of the info you’re getting is false [underlined in original]
      – g – MI – report says 68% error rate – but reality is it was .0063% error rate – less than 1 in 15K.
      *- ok, fine – but what about the others?
      *>>>- PA Twitch Drives [?] – we interviewed [?] on both ends – no ballots [illegible] Couldn’t even ID the envelopes
      *- ok, [illegible] I didn’t mention that one – what about the others?
      *>>>- GA – looked at the tape, interviewed the Ws, no suitcases (ok – but looked like that), cutters left, no multiple scanning of ballots

      • harpie says:

        two formatting errors here:
        1] P should be strong at Trump quote: “Don’t expect […]”
        2] last entry Trump quote parenthetical should be italicized.

    • harpie says:

      p6] *- Double voting, dead people, Indiv[iduals?] getting paid, lots of fraud.
      *- AZ – I [illegible] lost by 9K – clearly some fraud there too.
      *- Judges keep saying – where is the DOJ? Why are they not filing in these cases?
      *>>>- DAG/[illegible] bec. we are not in a position [illegible] on this evidence – we can only act on the actual evidence developed
      *>>>- Told him flat out that much of the info he is getting is false, +/or just not supported by the evidence – “we look at the allegations, but they do not pan out
      *>>>- [initials] – this is electioneering period
      *“We have an obligation to tell people that this was an illegal, corrupt election.” [quotation marks in original]
      *- People tell me Jeff Clark is great, I should put him in
      *- People want me to replace DOJ leadership
      *>>>RPD – fine, but won’t change the Depts’ position
      you should have the leadership you want

      p7] *- You, Rich, should go to Fulton Cty + do c signature verification and you’ll see how illegal it is. You’ll find tens of thousands.
      *- More votes than voters
      *>>>- I told him in WI they were copying the 2020 votes cast to 2016 verification #s – not a valid complaint
      *- “Nobody trusts the FBI” [quotation marks in original]
      – need steps[?] to [illegible] this
      *- “I’d like to request” [quotation marks in original]
      – Fulton Cty, GA
      – check signatures
      [illegible] years prior – not this year
      *>>>- DAG responds: we will take into account
      *- These people who saying that the election isn’t corrupt are corrupt
      *- Not much time left
      *>>>- Asked for cell # – provided (he had it anyway) – may have elected officials w/ relevant info call

      p8] *- Sen. Johnson has done great job getting to bottom of things
      – and that’s done in public, unlike DOJ investigation
      *NV – forensic accounting shows we won by 250K votes
      *Mark [Meadows?] – NC SC Justice – [illegible] stolen
      *“Ballot drops” changed the election

      • harpie says:

        *>>>- [initials] – this is electioneering period

        That SHOULD BE:
        *-Pthis is election-turning fraud [no quotation marks in original]

      • harpie says:

        [This makes much more sense in context]:

        *>>>- Told him flat out that much of the info he is getting is false, +/or just not supported by the evidence – “we look at the allegations, but they do not pan out
        *-Pthis is election-turning fraud [no quotation marks in original]
        *“We have an obligation to tell people that this was an illegal, corrupt election.” [quotation marks in original]
        *- People tell me Jeff Clark is great, I should put him in
        *- People want me to replace DOJ leadership

        [See RAYNE’s comment, here: ]

Comments are closed.