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I was disappointed, in the way we here in the peanut gallery sometimes are, that Tish James had to specifically rebut the silly things that Lindsey Halligan’s loaner AUSA, Roger Keller, claimed to try to excuse Lindsey’s stalking of Anna Bower.

Attorney General James’ original request asked Judge Jamal Walker to order the government to do three things:

1. Abstain from further extrajudicial statements like Lindsey’s Signal stalking of Bower
2. Follow rules and laws requiring prosecutors (and Federal employees generally) to retain their communications
3. Create and maintain a log of all contact between any government attorney or agent on this case and any member of the news media

As Lawfare’s excellent trial dispatch from Molly Roberts described, when initially presented with this question, loaner AUSA Keller — “a civil litigation lawyer by training,” Roberts helpfully noted — got hung up on a contact log tracking not just with the reporters Lindsey the Insurance Lawyer spoke to, but also with whom others (this is implicit, but let me make it more obvious) like Eagle Ed Martin did.

Keller responded to this request, that prosecutors follow the rules, by demanding that the defense follow the same rules … which is not how it works, both Abbe Lowell and Judge Walker reportedly responded.

The next motion invites a bit more controversy, or at least confusion. James also filed a motion prior to the arraignment asking the court to order the government to follow rules preventing disclosure of investigative and case materials, as well as to refrain from extrajudicial statements concerning the case to the press and public. This motion was prompted in part by an Oct. 20 article published inLawfare by my colleague, Senior Editor Anna Bower, detailing texts sent to her by Halligan in which Halligan criticizes Bower’s tweets about New York Times coverage of grand jury testimony in the case.

This violated, the filing says, Rule 6(e) of the Federal Rules of Criminal Procedure. It argues that the exchange with Bower and the other instances of apparent disclosure it describes—including pre-indictment reports that prosecutors intended to bring charges—also violate various rules, regulations, and ethical obligations. The motion doesn’t ask for a finding to that effect, only for an order to prevent such conduct in the future.

The judge, mentioning only “a journalist” and “an article published,” notes these oddities of the filing. Anyone hoping for a television-ready showdown in which the defense demands the prosecution be held in contempt is quickly disappointed: Judge Walker has interpreted the filing correctly, confirms Lowell.

The judge determines that leaves the prosecution three options: oppose the motion in its entirety; don’t oppose it at all; or oppose the proposed relief. The Eastern District prosecutors would have to preserve all documents relevant to the trial (a litigation hold) as well as create a log of all contact between its attorneys or agents and the media. The litigation hold doesn’t bother Keller. But he expresses reservations about the log, mentioning that “the defendant is also active on the Internet.” Specifically, he takes issue with her tweeting that she is innocent.

The judge, understandably, appears perplexed. He remarks that it’s unclear what Keller is asking. And it is: A public tweet from James in which she says “I am not fearful, I am fearless” has little to do with contact between her attorneys and the media. The misunderstanding only becomes greater when Keller elaborates that any log requirement for the government should also be a requirement for the defendant, and should cover “statements of innocence before the press.”

Does he mean that James should have to keep a record of any proclamations of her intention to fight the charges against her? Or does he mean she shouldn’t be allowed to make them at all?

Keller seems to be suggesting that the restrictions on the defendant’s public speech should mirror those placed on the prosecution. But this is not how these things work. Prosecutors have unique obligations not placed on defendants, who have First Amendment rights to protest their innocence.

Judge Walker delicately instructs Keller—a civil litigation lawyer by training, as it turns out—to take some time to think about the matter and get back to him. Lowell, for his part, declares that the rules to which government lawyers are held aren’t the same ones that apply to a defendant.

“The court certainly understands the requirements,” responds the judge. It is a little less certain that the prosecutor does. [my emphasis]

Now, when I first read Roberts’ dispatch, I honestly thought Keller’s confusion stemmed from that detail, “a civil litigation lawyer by training.” He just doesn’t know what he’s doing.

But when I started writing an abandoned post on his response, I came to believe he — like Lindsey the Insurance Lawyer — is mostly performing for a one man audience. To understand why I think that, check out how loaner AUSA Keller spends a 17¶¶ response:

1. Lindsey the Insurance Lawyer and loaner AUSA Keller ask that Walker not impose unilateral requirements to preserve all communications and keep a log [my emphasis]
2. Background: a grand jury indicted the Defendant
3. Walker should not impose unilateral requirements to preserve all communications and keep a log and also, US v. Trump! (citing the DC Circuit opinion partly upholding the gag on Trump), because Lindsey the Insurance Lawyer had to protect her client [my emphasis]
4. Here’s a citation that’s totally inapt but which will allow me to argue Tish James has to shut her yap
5. If the government has to “preserve all communications with any media person” and also keep a log of those contacts, “the unstated threat that she – at some future point in time – may engage in a ‘gotcha’ game where she brings a sanctions motion” may “chill all Government/media interaction” [my bold, italics original]
6. “There is no Court-imposed requirement that the Government preserves the records,” but can you imagine if a log of all communications means “all communications”?
7. If we have to follow the rules, Tish James has to follow rules for prosecutors too (citing US v Trump again)
8. “Defendant’s right to a fair trial does not give [her] the right to insist upon the opposite of that right – that is a trial prejudiced in [her] favor,” citing US v. Trump again
9. Because she’s a lawyer, Attorney General James has to adhere to NY rules of professional conduct even if Lindsey the Insurance Lawyer refuses to adhere to any rules of professional conduct
10. After her arraignment, James said she “will not bow” and there have to be rules against that!
11. Lindsey the Insurance Lawyer covertly bullying a journalist on disappearing messages is nowhere near as bad as Tish James saying “I will not bow” on a telly that Donald Trump can see!
12. Lindsey the Insurance Lawyer was just protecting her client — which client I will decline to name — “from substantial undue prejudice”
13. Grand jury secrecy is no big deal
14. Lindsey the Insurance Lawyer didn’t explicitly reveal what went on in the grand jury
15. Lindsey the Insurance Lawyer was merely — and heroically — “protect[ing] her client from unfair prejudice resulting from reporting half-truths”
16. I’m going to distract from the way Bower caught Lindsey the Insurance Lawyer pretending “thousand(s)” of dollars was not just two thousand
17. You should tell Tish to shut her yap!

I admit, the first time I read this filing, I read in terms of obvious bullshit to rebut, like I imagine lawyers do.

But when you lay it out like this, paragraph by paragraph, the pressing question becomes whether these people — not just Lindsey the Insurance Lawyer, Donald Trump’s defense attorney, but also loaner AUSA Keller — think Donald Trump, and not the US of A, are their client, a client demanding that his minions ensure that Tish James doesn’t become a rock star because of this prosecution.

Because otherwise, why demand that Tish James bow down? Why cite US v. Trump so prominently?

James addressed both these questions. She asked, Who exactly do these people think their client is?

Third, the government’s assertion that Ms. Halligan was only trying to protect “her client” raises the question of who she believes “her client” to be. Her “client” is neither the President, nor the Attorney General, nor the Administration, nor even her Office. It is the United States, as the case caption makes clear, and “[t]he United States wins its point whenever justice is done its citizens in the courts.”2 The point remains true regardless of whether the outcome is the one that the government favors. “Justice is done” when its “citizens in the courts” receive a fair trial. And in any event, a defendant’s fair trial rights decidedly trump any so-called “unfair prejudice” to the government’s case from public reporting. Courts have held that extrajudicial statements and comments by attorneys may be restricted to protect a defendant’s fair trial rights and the integrity of judicial proceedings—which override any desire by government prosecutors to “attempt to protect [Ms. Halligan’s] client from unfair prejudice.” Opp. at 6. See, e.g., Sheppard v. Maxwell, 384 U.S. 333, 361 (1966); Gentile v. State Bar of Nevada, 501 U.S. 1030, 1066 (1991).

2 DOJ, Remarks as Delivered by Attorney General Merrick B. Garland, https://www.justice.gov/archives/opa/speech/attorney-general-merrick-b-garland-deliversremarks-office-access-justices-gideon (Mar. 17, 2023).

The insistence that “fair trial rights decidedly trump any so-called ‘unfair prejudice’” is, I hope, an intentional double entendre.

James’ citation for the quote, “[t]he United States wins its point whenever justice is done its citizens in the courts,” is more subtle. The footnote cites this speech by Merrick Garland, a tribute to public defenders and defense attorneys generally, in which he emphasized the import of rule of law.

It reaffirmed that the law protects all of us – the poor as well as the rich, the powerless as well as the powerful.

In so doing, it reaffirmed this country’s commitment to the Rule of Law.

And trust in the Rule of Law is what holds American democracy together.

But the words, “[t]he United States wins its point whenever justice is done its citizens in the courts,” are not Garland’s words (though that was not the only speech where he used them). They were spoken by Willliam Taft’s Solicitor General, Frederick Lehmann, and they are inscribed on the building at DOJ. Judge Walker (a former AUSA) will presumably recognize that; Keller the loaner AUSA should: but Lindsey the Insurance Lawyer may see only a citation to Garland and worry about her boss — her client — again.

Then there’s James’s treatment of Keller the loaner AUSA’s inapt reliance on US v. Trump. She uses that to recall Trump’s misconduct as a defendant, something she knows well.

The government’s reliance on United States v. Trump, 88 F.4th 990 (D.C. Cir. 2023)—a case affirming a limited gag order placed on then-defendant Donald Trump in response to his public statements threatening witnesses, participants, and the judiciary during litigation—to defend Ms. Halligan’s interactions with the reporter is entirely misguided. Opp. at 3–4. Trump is relevant only to the extent that it proves the relative strength of a criminal defendant’s First Amendment rights and the extraordinary circumstances required to justify any burden on such rights. See id. (“[A] criminal defendant—who is presumed to be innocent—may very well have a greater constitutional claim than other trial participants to criticize and speak out against the prosecution and the criminal trial process that seek to take away his liberty.”). The Trump court set out facts justifying the order in vigorous detail, including a timeline of President Trump’s extensive attacks on witnesses, court officials, judges, law clerks, and other government personnel. See id. at 1010. It also catalogued the violent and threatening responses resulting from President Trump’s statements. See id. at 1011.

Even under those extraordinary circumstances, the court still found that “Mr. Trump [was] free to make statements criticizing the current administration, the Department of Justice, and the Special Counsel, as well as statements that this prosecution is politically motivated or that he [was] innocent of the charges against him.” Id. at 1028. Attorney General James’ speech, including following her initial appearance, cannot be reasonably compared to the statements that led to the United States v. Trump gag order, and regardless, would have been outside of its reach.

And James invoked Trump’s “almost weekly … disparaging comments against her” to suggest the government won’t win a war of the lesser wrong.

The comparison that the government now offers is to a public statement by a defendant who has faced almost weekly assertions by the President, or those carrying out his bidding, calling for her prosecution and conviction or making other disparaging comments against her. The government’s argument appears to be that “two wrongs don’t make a right.” But the defendant has not contravened the cited rules; the government has. The relief requested in the Motion is intended only to ensure that does not happen again and that, if it does, the government does not delete the evidence of its wrongdoing. That relief should be unobjectionable to the government.

The James prosecution is not functionally necessary for Donald Trump’s witch hunt — it is discrete punishment for someone who humiliated Donald Trump by treating him as a garden variety fraudster. That may be why Lindsey the Insurance Lawyer only got one loaner AUSA for this case, as compared to two overt ones for the Comey case (plus at least one more guy writing the filings), which is one part of the larger project. So maybe this is all about the posturing, an attempt to ensure that nothing about this prosecution backfires on the “client.”

But the focus on Trump — the need to respond to the totally inapt reliance on US v. Tump — distracted from something potentially more important.

Go back to bullet 5 again. Here’s that full quote:

Essentially, Defendant attempts to chill all Government/media interaction with the unstated threat that she – at some future point in time – may engage in a “gotcha” game where she brings a sanctions motion because the Government inadvertently failed to maintain a document or include a contact in its log.

This is an astonishing statement, one James addresses this way:

The opposition’s hyperbolic claim that the Motion seeks something like a gag order, Opp. at 3, fares no better. Government counsel and their agents have an ongoing obligation to refrain from certain types of extrajudicial statements and disclosures that may jeopardize a fair trial in this case. James Mot. at Sec. I. The defense is not asking the Court to “chill” all the government’s interaction with the media; it concedes that many statements that “a reasonable person would expect to be further disseminated by any means of public communications” are permissible.1 James Mot. at 9 (quoting Loc. Crim. R. 57.1(C)). Rather, the defense is seeking the Court’s assistance in assuring that the government adheres to the rules it has set for itself.

1 Another red herring, based on nothing in the Motion, is the government’s suggestion that Attorney General James is “attempt[ing] to chill all Government/media interaction” to later play “a ‘gotcha’ game” over the government’s failure to maintain a document or include a contact in its log. Opp. at 3. Following long-standing rules on extrajudicial statements is not “gotcha,” it is basic to the government’s obligation to protect fair trials.

These are prosecutors, wailing about being asked to retain documents! The government complains about being asked to preserve documents five times, plus the requirement that it maintain documents in its chill comment. And loaner AUSA Keller makes those complaints after having agreed to a litigation hold at the arraignment, something James notes in the first paragraph.

[A]s government counsel acknowledged at the October 24, 2025, initial appearance and arraignment, the government agreed to comply with the litigation hold request made in the Motion to prevent any further deletions and to preserve any other extrajudicial communications that may have been made.

Loaner AUSA Keller outright states that it would “chill” … something if prosecutors are asked to retain all their documents, something that normal prosecutors do as a matter of course, at least until a matter is concluded. This is like Trump demanding that he get to wipe every phone involved in this prosecution on a daily basis, after spending years misrepresenting what happened after Mueller team members left that team.

It’s not a “gotcha” if, as a prosecutor, you start deleting documents willy nilly. It is a real violation. It should be. Especially in a case like this one where the President accidentally issues orders on his social media site intended to be private. Is there a whole stash of Truth Social DMs about this case that have been deleted?

So I get the point of replying to the issues loaner AUSA Keller raised, including the inapt nod to the indignities that Donald Trump suffered after he got indicted and then threatened to kill witnesses (including the witness he almost got killed on January 6).

But that repeated complaint about merely retaining all your communications, particularly coming after already orally agreeing to do so, has me wondering if something much bigger than Lindsey the Insurance Lawyer’s stalking problem is going on.

I think the dispute between Lindsey Halligan’s loaner AUSAs and Jim Comey is a fight that has ramifications for Trump’s larger attempt to use DOJ to punish his enemies.

According to court filings, investigators from the case got access to Comey’s attorney-client information, possibly on September 25, the day Halligan obtained the indictment. Before they had given Comey a shred of discovery, they sent him a draft filter protocol on October 10. Then on October 13 — still before they had handed over discovery, which appears to have revealed they got no new warrant to access this old material — the loaner AUSAs asked Judge Nachmanoff to approve a filter protocol that would give the government the first chance to make privilege determinations. Abiding by local rules, Comey didn’t respond right away, leading prosecutors (on October 20) to ask the judge to hasten his consideration of the matter, even while accusing Patrick Fitzgerald of being part of a “leak” behind sharing unclassified information under Dan Richman’s name. Which is one of the things Comey patiently explained that same day: the loaner AUSAs were defaming Fitzgerald. After Nachmanoff denied the prosecutors’ bid to rush the issue, Comey laid out all the problems with this bid to get access to his privileged communications on Monday (which I wrote about here).

Among other things, he noted that prosecutors don’t appear to have gotten a warrant to review this material for this alleged crime — they’re still relying on warrants obtained in 2020 to investigate a leak of classified information.

Comey requested that, before he had to suppress this material, Judge Nachmanoff first require prosecutors to answer a bunch of questions, such as who already accessed the material and under what authority.

Nachmanoff didn’t do that.

Instead, he ordered Magistrate Judge William Fitzpatrick to deal with it; Fitzpatrick, in turn, set a hearing for next Friday.

At one level, that looks like a punt.

But in effect, it makes it exceedingly unlikely that prosecutors will get their filter protocol.

Nachmanoff cited a relevant precedent for this, in which lawyers (including Roger Stone prosecutor, Aaron Zelinsky and Joe Biden Special Counsel Robert Hur, because this year of my life necessarily requires revisiting every fucking case I’ve ever covered before) tried to do the filter review for a law firm, only to have the Fourth Circuit remand it for a magistrate judge do it.

This Court assesses the appropriate contours of a privilege filter protocol according to the guidelines set forth in In re Search Warrant Issued June 13, 2019, 942 F.3d 159 (4th Cir. 2019), as amended (Oct. 31, 2019). In In re Search Warrant, a Baltimore law firm challenged the government’s use of a Department of Justice filter team to inspect attorney-client privileged materials seized from that firm. Id. at 164. The Fourth Circuit reversed the district court’s denial of the law firm’s motion to enjoin the filter team’s review of the seized material. Relevant to this case, the Fourth Circuit held that “a court is not entitled to delegate its judicial power and related functions to the executive branch, especially when the executive branch is an interested party in the pending dispute.” Id. at 176. The Fourth Circuit observed that, “[i]n addition to the separation of powers issues” that might arise, allowing members of the executive to conduct the filter, even if those members were trained lawyers, raised the possibility that “errors in privilege determinations” would result in “transmitting seized material to an investigation or prosecution team.” Id. at 177. It thus determined that the filter protocol “improperly delegated judicial functions to the Filter Team,” and that instead, “the magistrate judge (or an appointed special master) — rather than the Filter Team — must perform the privilege review of the seized materials[.]” Id. at 178, 181 (collecting cases).

Prosecutors had argued (in what might be their only reference to this, a directly relevant precedent) that informing Comey at the start mitigated the risk at the heart of the earlier case.

Further, the Proposed Protocol creates a process by which the putative privilege holders remain engaged and may assert a privilege over PPM, with any remaining disputes to be resolved by the Court. Indeed, the Proposed Protocol requires authorization from the potential privilege holder(s) or the Court before the Filter Team may disclose PPM to the Prosecution Team. Thus, this Protocol does not authorize the Government to adjudge whether specific material is privileged. Instead, the Protocol leaves adjudication of any unresolved privilege claims to the Court. See Fed. R. Evid. 501. Accordingly, unlike the concerns raised by In re Search Warrant, the Government has engaged the putative privilege holders from the onset and will continue to engage them and the Court, if necessary, as prescribed by the Protocol before disclosing any PPM. Cf. In re Search Warrant Issued June 13, 2019, 942 F.3d 159, 176-178 (4th Cir. 2019), as amended (Oct. 31, 2019) (discussing concerns of delegating judicial functions to the executive branch where the magistrate judge authorized an ex parte filter review of a search warrant return of a law firm).

Without even mentioning this (specious) claim from the loaner AUSAs, Nachmanoff treated the entire privilege review as one the In re Search Warrant opinion defines as a judicial function. That, plus the Fourth’s citation to the 2018 treatment of Michael Cohen’s communications (when I said every fucking case I’ve ever covered, I meant all of them) signals Nachmanoff will surely insist Fitzpatrick or someone Fitzpatrick appoints conduct any review.

But Nachmanoff went further in his seeming punt. He also suggested that, even before Fitzpatrick conduct a review, he should first answer a number of questions — questions that largely track those Comey raised, including the questions (cited at page 12 here) he raised.

The Fourth Circuit further concluded that adversarial proceedings before the magistrate judge were needed prior to the authorization of a filter team and protocol. Id. at 179.

Similarly here, briefing on the government’s proposed filter protocol raises several legal questions that must be resolved before any protocol is authorized. These questions include, but are not limited to, whether the original warrants authorizing the seizure of the materials at issue are stale, whether those warrants authorize the seizure and review of these materials for the crimes at issue in this case, whether the lead case agents or prosecution team in this case have been exposed to privileged materials, and what the proper procedures are, if any, for review of the materials at issue. See ECF 71 at 1, 5, 6, 8–10, 12.

Which is to say, this is a punt, but a punt saying, “binding Fourth Circuit precedent says Comey is right.”

Update: Comey has submitted three additional pretrial motions. He asked to:

• Access grand jury proceedings.
• Get a Bill of Particulars.
• Throw out the indictment because Ted Cruz’ questioning sucked and also Comey told the truth (and also to submit the actual video showing the questioning).

In support of his efforts to Twitter Files the January 6 investigation, Chuck Grassley just released 179 subpoenas and a summary of them sent out between September 2022 and June 2023.

The release is definitely serving his purposes. One after another far right wing propagandist is screaming, Worse than Watergate!!!

But the may also be an absolute gold mine for people trying to reconstruct what Trump did in 2020, to say nothing of political oppo researchers and foreign hackers. The subpoenas provide a map of all the political organizations that were close to Trump in 2020 to 2021, organized by person; not all of these are public and certainly not in such a readily usable form. They list where people — including some people who are exceedingly important in Trump’s current administration — banked during the 2020 election (and if China hacks DOJ servers, it provides them a roadmap to find the actual bank account numbers).

Yet much of the general thrust of the subpoenas are not new. Indeed, many of them were reported in real time and laid out in an appendix of the J6C Report, which I wrote about here.

False advertising

As J6C laid out, Trump’s team decided to keep fundraising after he lost the election, purportedly in the guise of a recount and/or election integrity.

The claims made in the fundraising materials made knowably false claims — so much so that the RNC stopped running them. J6C did a number of interviews and served a number of subpoenas to find out more.

But they hit roadblocks. For example, the RNC succeeded in fighting a Salesforce-related subpoena to learn more about what a whistleblower told them about concerns raised internally.

The Trump Campaign knew that emails that the Approvals Group had blessed were being rejected by Iterable. However, the RNC continued to send millions of Trump Campaign emails through Salesforce, TMAGAC’s original email service provider, up until January 6th. Evidence uncovered bythe Select Committee shows that there were internal concerns at Salesforceregarding the content of the TMAGAC emails.

The Select Committee interviewed an individual (“J. Doe”) who worked at Salesforce during the post-election period during which TMAGAC was sending out the fundraising emails concerning false election fraud claims.147 Doe worked for Salesforce’s privacy and abuse management team, colloquially known as the abuse desk.148 An abuse desk is responsible for preventing fraud and abuse emanating from the provider’s user or subscriber network.

Doe indicated to the Select Committee that, as soon as early 2020, they recalled issues arising with the RNC’s use of Salesforce’s services and that a“deluge of abuse would’ve started in June-ish.”149 Doe noted that Salesforce received a high number of complaints regarding the RNC’s actions, which would have been primarily the fundraising efforts of TMAGAC.150 In the latter half of 2020, Doe noticed that the emails coming from the RNC’s account included more and more violent and inflammatory rhetoric in violation of Salesforce’s Master Service Agreement (“MSA”) with the RNC, which prohibited the use of violent content.151 Doe stated that, near the time of the election, they contacted senior individuals at Salesforce to highlight the “increasingly concerning” emails coming from the RNC’s account.152 Doe explained that senior individuals at Salesforce effectively ignored their emails about TMAGAC’s inflammatory emails 153 and Salesforce ignored the terms of the MSA and permitted the RNC to continue touse its account in this problematic manner.154 Doe said, “Salesforce very obviously didn’t care about anti-abuse.”155

There’s no evidence the RNC and Salesforce had the same success with this December 2022 subpoena.

That led to a series of even more interesting subpoenas sent in March 2023 to individuals who worked this side of things at the RNC.

The subpoenas asked for materials pertaining to fundraising in the name of election integrity after the election, and named some of the people involved.

B. Regardless of time period, all documents related to the “Election Defense Fund” or “Official Election Defense Fund” referenced in the fundraising emails sent out between November 3, 2020 and January 20, 2021.

C. For the time period of November 3, 2020 through January 20, 2021, all communications between or among or referencing you and one or more of the following individuals or entities:

1. Benjamin Angle;

2. Rudy Giuliani;

3. Jason Miller;

4. Andrew Surabian;

5. Donald Trump, Jr.;

6. Eric Trump;

7. Lara Trump;

The subpoenas asked, among other things, for details of advertising targeting Mike Pence.

D. For the time period of November 3, 2020 through January 20, 2021, all documents related to:

1. The use of Michael R. Pence’s name in fundraising, including but not limited to whether his name could or would continue to be used in fundraising;

2. Any individual indicating that they do not want to be, or no longer would be, a surrogate in fundraising emails; and/or

3. All joint fundraising efforts involving the RNC, all documents related to any changes as to what entities would participate in any fundraising campaign and/or how the funds raised would be divided among participating entities.

And asked for evidence that the RNC knew Trump was lying.

K. For the time period of November 3, 2020 through January 20, 2021, all documents related to any disagreement, whether as to tone or substance or anything else, the RNC or any of its employees, agents, or contractors had with any statement made by or on behalf of Donald J. Trump, anyone affiliated with the Trump Campaign, anyone affiliated (formally or informally) with the White House, including, but not limited to statements made by Donald J. Trump, Eric Trump, Donald J. Trump, Jr., Lara Trump, Rudy Giuliani, Sidney Powell, and/or Jenna Ellis. L. All documents related to or referencing January 6, 2021, the Rally, and/or the subsequent march to and breach of the United States Capitol.

There may even be newly disclosed domains that people can track in this material.

Payoffs

J6C focused on another aspect of this fundraising, too: how Trump spent the money raised by lying to his rubes, partly by paying off those who had been loyal to him.

The Trump Campaign spent the money on President Trump, giving donations to his associates, and keeping it for himself in Save America. Hundreds of millions of dollars that were raised to go towards “election defense” and “fighting voter fraud” were not spent that way at all. To thecontrary, most of the funds remain unspent, and millions have been paid tocompanies that are known affiliates of President Trump, or payments to entities associated with former Trump administration officials. Since the election, former Trump officials who are still working for President Trump’s PACs, and are publicly receiving salaries as FEC-reported “payroll,” are also associated with these companies.

For example, from July 2021 to the present, Save America has been paying approximately $9,700 per month to Dan Scavino,171 a political adviser who served in the Trump administration as White House Deputy Chief of Staff.172 Save America was also paying $20,000 per month to an entity called Hudson Digital LLC. Hudson Digital LLC was registered in Delawaretwenty days after the attack on the Capitol, on January 26, 2021,173 and began receiving payments from Save America on the day it was registered.174 Hudson Digital LLC has received payments totaling over $420,000, all described as “Digital consulting.”175 No website or any other information or mention of Hudson Digital LLC could be found online.176 ThoughHudson Digital LLC is registered as a Delaware company, the FEC ScheduleB listing traces back to an address belonging to Dan and Catherine Scavino.177

Nick Luna, President Trump’s former personal assistant and “body man,” was being paid from April 2021 to December 2021 approximately $12,000 per month by Save America for “payroll.”178 The Make America Great Again PAC (MAGA PAC)—formerly the authorized committee of President Trump’s reelection campaign, Donald J. Trump for President—paid $20,000 per month to a limited liability corporation called Red State Partners LLC from April 2021 through October 2021, and Save America paidRed State Partners LLC $20,000 in February 2022.179 The company was registered in Delaware on March 11, 2021 180 and has received a total of $170,000.181 Though it is registered in Delaware, disclosures filed with the Federal Election Committee (FEC) list Red State Partners at an address inMiami, Florida, that is an address for Nick Luna and his wife, Cassidy Dumbauld.182

Further, Vince Haley, Taylor Swindle, and Ross Worthington are corporate officers of a company known as Pericles LLC.183 Haley is a former policy advisor to President Trump,184 Swindle is the Chief Financial Officer for Gingrich 360,185 and Ross Worthington is the former White House speechwriter 186 who wrote the speech President Trump delivered on the Ellipse on January 6th.187 Pericles LLC was registered on January 27, 2021,188 the day after Scavino’s Hudson Digital LLC, and, since then, has received payments from Save America totaling at least $352,700.189

There are corresponding subpoenas for much of this activity (indeed, it explains a great deal of the subpoenas).

But it could have been worse! Jack Smith appears not to have subpoenaed a suspect payment to Melania’s designer, “Herve Pierre Braillard,” one of the odd payments made out of this money.

Brad Parscale

There’s over a dozen subpoenas, dating to the period immediately following Jack Smith’s appointment, for information pertaining to Brad Parscale, which may address some of the financial shenanigans he was engaged in that became public in real time.

I’m not sure all of these were public before. They’re now all mapped out.

Closely (potentially directly) related to that series is a January 2023 subpoena asking for Know Your Customer information (that is, money laundering) from Paychex and ADP. The subpoena includes America First Legal Foundation which, AFLF people keep squealing about on Xitter, wasn’t founded until after January 6.

The theory behind some of this, as laid out by J6C, is that money was raised under one theory and shared with others. These two were the sole subpoenas pertaining to AFLF; there’s no evidence they did anything wrong. But now they’ve given cause to look more closely.

Joint Defense Agreements paid by political PACs

Particularly in the stolen documents case, we learned that Susie Wiles vetted people for their loyalty before paying for their defense.

Prosecutors sent out a series of subpoenas in March 2023 to Trump’s PACs asking for details (and retainer agreements) of law firms paid by political organizations that purported to serve Trump’s election.

A number of those law firms were public. But here’s the full list:

1. Abel Bean Law P.A.

2. Akin Gump Strauss Hauer & Feld

3. Bedell, Dittmar, DeVault, Pillans

4. Brand Woodward Law

5. Cadwalader, Wickersham & Taft

6. Clark Hill PLC

7. Compass Legal Group

8. Compass Legal Services, Inc

9. Dhillon Law Group Inc

10. Earth & Water Law LLC

11. Elections, LLC

12. Greenberg Traurig

13. Jones Day

14. JPRowley Law PLLC

15. Kasowitz, Benson, Torress LLP

16. Marino, Tortorella & Boyle, P.C.

17. McGuireWoods LLP

18. Mintz Levin Cohn Ferris Glovsk

19. Neal & Harwell, PLC

20. Nelson Mullins Riley & Scarborough

21. Parlatore Law Group, LLP

22. Squire Patton Boggs (US) LLP

23. Statecraft PLLC

24. The Binnall Law Group

25. The Garber Group LLC

Some of these — like the law firm Stanley Brand shared with Stan Woodward — have long been central to the Trump investigation narrative. Others, though, are newly disclosed thanks to Chuck Grassley.

Previously unknown people

Right wingers are busy on Xitter pointing to individual subpoenas that, in the process, identify people not previously known to have had any role in January 6. For example, SJC Republicans pointed to this December 16, 2022 subpoena for Robert Gasaway, which appears to be the only one that asks for his contacts with DOJ, with Congress, or with the campaign. It is also one of just six that asked for any communications, “To, from, with, or involving any member of law enforcement relating to any allegation of fraud or lack of fraud in the 2020 Presidential Election,” which is another interesting request.

All of which is to say, there’s a whole lot of screaming over on Xitter about this.

But the people whose potential involvement in Trump’s attempt to cheat his donors is newly disclosed should be screaming at Chuck Grassley rather than what he disclosed. Because he really exposed a great deal of new information useful for researchers.

If it weren’t for a recent shift in DOJ’s prosecutorial focus, Jeanine Pirro’s wildly corrupt effort to suppress the larger criminal context of Tayler Taranto’s stalking of Barack Obama in 2023 would be no more than a garden variety authoritarian effort to rewrite history.

As ABC and Politico have written, two AUSAs who’ve been prosecuting Taranto, Carlos Valdivia and Samuel White, submitted a sentencing memo documenting how the Navy veteran with long-standing mental health issues first participated in January 6 and then, years later, drove his van containing guns and ammunition to stalk Kalorama, looking for Obama while ranting, “Gotta get the shot, stop at nothing to get the shot. This is where other people come to get the shot;”

The language in the memo about the January 6 attack and Taranto’s role in it attracted some press attention.

On January 6, 2021, thousands of people comprising a mob of rioters attacked the U.S. Capitol while a joint session of Congress met to certify the results of the 2020 presidential election. Taranto was accused of participating in the riot in Washington, D.C., by entering the U.S. Capitol Building. After the riot, Taranto returned to his home in the State of Washington, where he promoted conspiracy theories about the events of January 6, 2021.

And so Pirro (or someone at DOJ) did what all corrupt sycophants would do: put the two attorneys on leave for speaking the truth about Pirro’s liege.

Then, two of the AUSAs who bolloxed the Sydney Reid case, Jonathan Hornok and Travis Wolf, filed notices of appearance and submitted a new sentencing memo, asking for the same sentence. The description of January 6 as a riot, above, was removed (but not a quote of Taranto mentioning it).

More scandalously, the revised sentencing memo excised the description of how Taranto came to be stalking the former President, the passage in red, below: Because Donald Trump, as a private citizen, first doxed Obama.

The next day, on June 29, 2023, then-former President Donald Trump published on a social media platform the purported address of former President Barack Obama. Taranto re-posted the address on the same platform and thereafter started livestreaming from his van on his YouTube channel. Taranto broadcast footage of himself as he drove through the Kalorama neighborhood in Washington, D.C., claiming he was searching for “tunnels” he believed would provide him access to the private residences of certain high-profile individuals, including former President Obama. He parked his van, walked away from it, and approached a restricted area protected by the United States Secret Service. He walked through the nearby woods and stated, “Gotta get the shot, stop at nothing to get the shot.” [my emphasis]

As I said, if it weren’t for a recent shifted prosecutorial focus, criminalizing doxing partly as a way to criminalize otherwise peaceful protest against ICE and CBP, this kind of memory hole would be merely another instance of gross corruption and the human waste of professional careers destroyed because the aspiring dictator refuses to take accountability for his own actions.

But DOJ has recently arrested a number of people for doxing under 18 USC 119, a law that specifically protects law enforcement officers: first Gregory Curcio (who not only posted the address of an ICE lawyer, but invited others to swat her; his indictment included a domestic violence claim). Then Cynthia Raygoza, Ashleigh Brown, and Sandra Carmona Samane, who livestreamed from the house of an ICE officer they followed home.

Here’s how Bill Essayli, who regularly made shit up even before getting exposed for playing dress-up as a US Attorney the other day, said about the latter.

“Our brave federal agents put their lives on the line every day to keep our nation safe,” said Acting United States Attorney Bill Essayli. “The conduct of these defendants are deeply offensive to law enforcement officers and their families. If you threaten, dox, or harm in any manner one of our agents or employees, you will face prosecution and prison time.”

According to the indictment, on August 28, 2025, the defendants followed the victim – an ICE agent – from the Civic Center in downtown Los Angeles to his personal residence. The defendants livestreamed on their Instagram accounts their pursuit of the victim and provided directions as they followed the victim home, encouraging their viewers to share the livestream. Their Instagram accounts used to livestream the event were “ice_out_of_la,” “defendmesoamericanculture,” and “corn_maiden_design.”

Upon arriving at the victim’s personal residence, the defendants shouted to bystanders while livestreaming on Instagram that their “neighbor is ICE,” “la migra lives here,” and “ICE lives on your street and you should know.”

The defendants publicly disclosed on Instagram the victim’s home address and told viewers, “Come on down.”

Ashleigh Brown is the woman whose charges for being assaulted by an FPS officer were dismissed this week after defense attorneys discovered his criminal record. Unlike the Taranto case, there’s no claim the women did or would have been armed.

Mostly, they told this guy’s neighbors he was la migra, one of the men who kidnap workers from outside Home Depot.

Donald Trump’s doxing of Barack Obama was more consequential than what these three women did. Taranto was armed and, not least because of his mental health problems, dangerous.

Donald Trump’s own DOJ says the kind of doxing Donald Trump did should hold a five year sentencing in prison.

And DOJ just took ham-handed steps to pretend Trump didn’t do just that.

The loaner AUSA in the Tish James case, Roger Keller, has responded to Attorney General James’ request that they be ordered to follow the rules (he even authored his own document, unlike the Comey loaner AUSAs). I’ll come back to it but it is … inadequate to the task, though it cites liberally and faithlessly from the DC Circuit opinion upholding part of the gag on criminal defendant Donald Trump.

In any case, that may be far less important a development than the order that Judge Cameron McGowen Currie gave in both the James and Comey cases.

As happened with the other challenges to Trump’s unlawfully appointed US Attorneys, Currie (a senior judge from another District within the same Circuit) was appointed by Fourth Circuit Chief Judge Albert Diaz to preside over the challenge to Lindsey Halligan’s appointment. While Comey included Halligan’s appointment paperwork in his challenge, James (who filed hers before she got any discovery) did not.

In any case, Currie wants more. She ordered DOJ to file, “all documents relating to the indictment signer’s participation in the grand jury proceedings, along with complete grand jury transcripts.”

The undersigned has been appointed to hear this motion and finds it necessary to determine the extent of the indictment signer’s involvement in the grand jury proceedings. Accordingly, the Government is directed to submit, no later than Monday, November 3, 2025, at 5:00 pm, for in camera review, all documents relating to the indictment signer’s participation in the grand jury proceedings, along with complete grand jury transcripts. In camera review is appropriate given the secrecy requirements applicable to grand jury proceedings. Fed. R. Crim. P. 6(e)(2).

Currie may need these simply to understand what the remedy would be if she ruled for Comey and James. As far as we know (and as news reports cited in both motions claim), unlike other challenges to Trump’s unlawful US Attorney appointments, Halligan was the only one present for the presentment, meaning if her appointment is unlawful, the indictments have to go away. Both Comey and James are arguing for dismissal with prejudice, though the argument is less compelling in James’ case (because unlike Comey, the statute of limitations did not expire). So Currie needs to understand how much of the case relies on Halligan’s presence.

Whatever Currie’s goal, reviewing these transcripts will likely to be exceedingly damning for Halligan, whom Currie refers to not as the “interim US Attorney” or even (as James referred to her) as the “purported interim US Attorney,” but as the “indictment signer.”

After all, they will show that Dan Richman gave testimony that debunked the very premise of the indictment against Comey; such a review may show that Halligan simply neglected to share that transcript with grand jurors. More damning still, it’ll reveal the testimony of James’ great-niece, Nakia Thompson, describing that she has paid almost nothing in rent since she lived in the home James bought for her in 2020, undercutting the entire claim that Attorney General James was intending to use the house as an investment property. It’ll reveal that Halligan got an Alexandria grand jury to indict James, bypassing those grand jurors in Norfolk who had heard Thompson’s testimony.

But Judge Currie may find something else Comey argued compelling: that because Halligan was not lawfully authorized to be US Attorney, Halligan’s mere presence in the grand jury was a violation of grand jury secrecy.

Here, Ms. Halligan’s unlawful appointment tainted the structural integrity of the grand jury process. Absent Ms. Halligan’s unlawful title, she would not have been able to enter the grand jury room, let alone present and sign an indictment. Indeed, the Federal Rules of Criminal Procedure allow only “attorneys for the government” to be “present while the grand jury is in session,” Fed. R. Crim. P. 6(d)(1), and define such attorneys to include only “attorney[s] authorized by law to conduct” grand jury proceedings, Fed. R. Crim. P. 1(b)(1)(D) (emphasis added). Those rules implement the longstanding principle “that the proper functioning of our grand jury system depends upon the secrecy of the grand jury proceedings”—a principle that “is ‘as important for the protection of the innocent as for the pursuit of the guilty.’” United States v. Sells Eng’g, Inc., 463 U.S. 418, 424 (1983) (citations omitted). By limiting participation to government attorneys “authorized by law,” Rules 1 and 6 maintain the secrecy of the grand jury proceeding and reinforce that an unlawfully appointed attorney’s presentation to the grand jury undermines the structure of that proceeding. The fundamental error here thus allows a presumption that Mr. Comey was prejudiced, “and any inquiry into harmless error would [require] unguided speculation.” Bank of Nova Scotia, 487 U.S. at 257.

Judge Currie may have very modest reasons for requesting these transcripts. But they will, almost inevitably, raise larger questions about both Halligan’s conduct, and that of the people who appointed her.

When the government first asked, on October 13, to use a filter review to access content seized from Dan Richman five years ago, it described that Jim Comey, “prefers to challenge the underlying search warrant first before any review takes place.”

But in his response yesterday, Comey didn’t do that.

Rather, after a heavily-redacted discussion of the problems with DOJ’s past and prospective access to the content, he proposed that Judge Michael Nachmanoff should deny the government’s filter request without prejudice, allowing DOJ to reconsider its bid for a filter protocol after they’ve first answered a set of questions.

For the foregoing reasons, the Court should deny the government’s motion to implement its proposed filter protocol without prejudice, and direct the government to disclose the following information to allow both the Court and the defense to assess the appropriateness of the protocol:

1. The legal authority for the contemplated review.

2. Whether any quarantined materials have been accessed by, shared with, or provided to the case team (and, if so, which materials were reviewed by which personnel on which day), and whether any such materials have been produced in discovery.

3. The protocol used during the prior filter review, including search parameters, segregation measures, privilege determinations, and associated logs or correspondence.

4. Whether the government intends to search raw returns or only the set already filtered in the prior review. See In re Search Warrant Issued June 13, 2019, 942 F.3d 159, 181 (4th Cir. 2019), as amended (Oct. 31, 2019) (holding that “the magistrate judge erred” by approving a filter protocol “without first ascertaining” the materials to be reviewed).

5. Whether non-lawyers will conduct any portion of the Filter Review. See ECF No. 38-1 ¶ 2 n.2 (“The Filter Team is comprised of Two Assistant United States Attorneys, and their support staff”) (emphasis added); see In re Search Warrant Issued June 13, 2019, 942 F.3d at 177 (criticizing the use of non-lawyers to designate documents as nonprivileged).

One might explain the reason why he’s doing this in one or two ways.

The first is a procedural reason. The warrants and original filter protocol themselves were probably reasonably sound for the purpose to which they were put: investigating whether Richman leaked classified information. The heavily redacted bit describes four different warrants and the loaner AUSAs’ original filing described content seized from “an image of a computer hard drive, an iCloud download, the backup of an iPhone, and the backup of an iPad.” There are five sealed exhibits to the filing (none cited in unredacted form), of which four are presumably the warrants and one may pertain to the original protocol, though there is something identified in footnote 4 that “was not produced,” not even after Comey’s team asked about it on October 23. While the seized material included a great deal of material, including material pertaining to Richman’s clients other than Comey and “sensitive and private materials belonging to his students,” the original filter protocol withheld, “private materials related to his students, as well as privileged materials, [from] the case team.”

But, contrary to the approach used with (for example) Michael Cohen as well as what we’ve been able to publicly review of warrants implicating Rudy Giuliani, in which prosecutors obtained new warrants every time the scope or target of an investigation changed, the government appears not to have obtained new warrants to search this material for a different crime, the alleged lie Comey told in 2020.

[I]t appears that the government has not obtained any search warrants in connection with the instant matter, including any warrant authorizing a search of the Arctic Haze materials for evidence of the two offenses with which Mr. Comey is charged.

Comey cites several precedents, one in the Fourth Circuit, that would require a new warrant.

He points to other reasons, too, why the government would need to obtain new warrants: because these warrants are not only stale, but they predate the alleged crime here, testimony from October 2020.

The government now proposes to use those warrants to search for evidence of different crimes that arose from a proceeding that occurred after USAO-DDC obtained the Arctic Haze warrants.

Comey also objects because some part of this was sealed by another court, which by date and location would probably have been an order from Beryl Howell when she was Chief Judge in DC.

The government has no lawful basis to review materials obtained more than five years ago, in a closed investigation that ended without any charges, pursuant to stale warrants for separate offenses, including materials that remain under seal by another court. [my emphasis]

Comey maintains that he can challenge the use of these warrants here.

The Fourth Amendment plainly prohibits the government from doing exactly what it seeks to do here: the Arctic Haze warrants were obtained more than five years ago in a separate and now-closed criminal investigation and authorized the seizure of evidence of separate offenses. Yet the government seeks to turn those warrants into general warrants to continue to rummage through materials belonging to Mr. Comey’s lawyer in an effort to seize evidence of separate alleged crimes. The Court should not authorize the government to conduct an unlawful review.

[snip]

Mr. Comey reserves his right to move to suppress these warrants, to the extent the government continues to use them in this manner. See, e.g., United States v. Place, 462 U.S. 696, 709–10 (1983) (a seizure lawful at its inception can nevertheless violate the Fourth Amendment based on agents’ subsequent conduct); DeMassa v. Nunez, 770 F.2d 1505, 1508 (9th Cir. 1985) (“an attorney’s clients have a legitimate expectation of privacy in their client files”). Until the government answers the questions the defense has previously raised about these warrants, which to date have remained unanswered and which are detailed at the end of this submission, the defense will not be in a position to file an appropriately targeted suppression motion.

But even the language here notes at one problem: Normally you challenge a Fourth Amendment violation by suppressing evidence for use at trial. Here, Comey is trying to do more. He’s trying to prevent investigators from even accessing it. And so, instead, he’s asking the judge to force prosecutors to answer some basic questions in the guise of allowing him to suppress the warrants.

Until the government answers the questions the defense has previously raised about these warrants, which to date have remained unanswered and which are detailed at the end of this submission, the defense will not be in a position to file an appropriately targeted suppression motion.

Which brings us to the second possible reason for responding this way: question 2. Who already accessed privileged material, when did they do so, and has the government turned over that material in discovery? The answer to that question, especially, would force investigators to confess if they’ve already snuck a peek into what is in the privileged communication.

The “spill” that Comey suspects happened may have happened recently: on the day Lindsey Halligan obtained the indictment.

That footnote, marked in pink, cites the Criminal Case Cover Sheet, which, in spite of being labeled as “REDACTED,” is not, and so among other things, reveals the name of one of two FBI agents on the case, Miles Starr (the other being Jack Eckenrode, who investigated Scooter Libby but then left the team, and who joined John Durham in chasing Russian disinformation for four years).

I’ve redacted Starr’s phone number. You’re welcome, Miles.

But the Sheet also includes an error: it lists three counts, including the one, pertaining to Comey’s answer to Lindsey Graham’s question about a CIA referral (one that FBI may never have received) that Kash Patel and John Ratcliffe ret-conned into a “Clinton Plan” on which to hang the Durham investigation. That’s the one the grand jury no-billed.

While none of that explains when and how Starr and Eckenrode snuck a peek of privileged information, it might explain why.

Kash and Eckenrode are still chasing the theory behind the dropped charge, that Jim Comey purportedly knew Hillary Clinton had a plan (one fabricated by Russia and then embellished by Eckenrode and Durham to claim Hillary wanted to frame Trump) to emphasize Donald Trump’s ties with Russia. That’s the logic of the larger conspiracy theory that Eckenrode has been hired to chase. It was and remains Russian disinformation, but that didn’t stop Eckenrode the last time he tried this.

Indeed, because DC USAO obtained warrants in 2019 and 2020, there may be communications between Comey and his attorneys about the John Durham investigation, about Eckenrode’s past witch hunt, which would explain why Comey is so interested in the scope of proposed review, which the loaner AUSAs still haven’t told Comey.

Because Kash and Eckenrode are chasing that conspiracy theory, this is a much bigger issue than just the case before Nachmanoff. As I laid out in my post predicting that John Durham’s investigation was a preview of coming attractions (even before I knew that Kash had brought Eckenrode back!), Durham already played games to access attorney-client privileged material.

In response, Sussmann accused Durham of abusing the same grand jury process he abused with Benardo (abuse, ironically, that debunked Durham’s conspiracy theory).

First, the Special Counsel’s Motion is untimely. Despite knowing for months, and in some cases for at least a year, that the non-parties were withholding material as privileged, he chose to file this Motion barely a month before trial—long after the grand jury returned an Indictment and after Court-ordered discovery deadlines had come and gone.

Second, the Special Counsel’s Motion should have been brought before the Chief Judge of the District Court during the pendency of the grand jury investigation, as the rules of this District and precedent make clear.

Third, the Special Counsel has seemingly abused the grand jury in order to obtain the documents redacted for privilege that he now challenges. He has admitted to using grand jury subpoenas to obtain these documents for use at Mr. Sussmann’s trial, even though Mr. Sussmann had been indicted at the time he issued the grand jury subpoenas and even though the law flatly forbids prosecutors from using grand jury subpoenas to obtain trial discovery. The proper remedy for such abuse of the grand jury is suppression of the documents.

Fourth, the Special Counsel seeks documents that are irrelevant on their face. Such documents do not bear on the narrow charge in this case, and vitiating privilege for the purpose of admitting these irrelevant documents would materially impair Mr. Sussmann’s ability to prepare for his trial.

He also revealed that some of those privilege claims went back to August — that is, the weeks after Durham should have closed up shop.

Email from Andrew DeFilippis, Dep’t of Just., to Patrick Stokes, Gibson, Dunn & Crutcher LLP, et al. (Aug. 9, 2021) (requesting a call to discuss privilege issues with a hope “to avoid filing motions with the Court”); Email from Andrew DeFilippis, Dep’t of Just., to Patrick Stokes, Gibson, Dunn & Crutcher LLP, et al. (Aug. 14, 2021) (stating that the Special Counsel “wanted to give all parties involved the opportunity to weigh in before we . . . pursue particular legal process, or seek relief from the Court”). And since January— before the deadline to produce unclassified discovery had passed—the Special Counsel suggested that such a filing was imminent, telling the DNC, for example, that he was “contemplating a public court filing in the near term.” Email from Andrew DeFilippis, Dep’t of Just., to Shawn Crowley, Kaplan Hecker & Fink LLP (Jan. 17, 2022). [my emphasis]

In a hearing on May 4, right before trial, Joffe’s lawyer revealed they had demanded Durham press a legal claim much earlier, in May 2021.

MR. TYRRELL: So if they wanted to challenge our assertion of privilege as to this limited universe of documents — again, which is separate from the other larger piece with regard to HFA — they should have done so months ago. I don’t know why they waited until now, Your Honor, but I want to be clear. I want to say without hesitation that it’s not because there was ever any discussion with us about resolving this issue without court intervention.

THE COURT: That was my question. Were you adamant a year ago?

MR. TYRRELL: Pardon me?

THE COURT: Were you adamant a year ago that —

MR. TYRRELL: Yes. We’ve been throughout. We were not willing to entertain resolution of this without court intervention.

THE COURT: Very well.

Ultimately, Cooper did bow to Durham’s demand, but prohibited them from using those documents at trial.

That didn’t prevent DeFilippis from attempting to use the privileged documents to perjury trap his one Fusion witness, the kind of perjury trap that might have provided a way to continue the madness indefinitely.

There must have been nothing interesting there: most of the Fusion documents were utterly irrelevant to the Sussmann charges, but could implicate the Danchenko ones, but Durham didn’t use them there, nor did he explain their content in his final report.

That effort involved, among other things, abusing the prosecutorial process to bypass rulings (such as the sealing order mentioned above) that Beryl Howell had already made, and using one criminal case, against Michael Sussmann, to obtain attorney-client privileged materials that would only be relevant in another criminal case, the Igor Danchenko case (or a larger conspiracy).

Particularly given the reticence of the loaner AUSAs to tell Comey what happened, whether they have warrants, who read what, this feels like an attempt to retroactively bless access that investigators already got. And the stakes are bigger than this one case. As Durham (and Eckenrode) did in 2022, this likely would primarily serve to feed their bigger conspiracy theory.

Plus, if Eckenrode is sneaking peeks at Comey’s privileged communications still in FBI custody, there’s nothing that would prevent him from doing the same with all the other people whose privileged communications have been seized during this years-long witch hunt.

And that’s why you ask these questions.

The high profile politicized prosecutions — of Jim Comey, Tish James, and John Bolton (and of LaMonica McIver if the press weren’t broken) — are really important tests of Trump’s attempt to turn DOJ into a weapon.

But the relatively anonymous cases — as often as not, defended by Federal Public Defenders — are just important a vindication of rule of law.

Today’s important victory goes to Ashleigh Brown. She was charged in conjunction with a confrontation with Federal Protective Services (not, NOT ICE or CBP) outside Roybal Federal Building in Los Angeles on August 2.

c. Approximately three [Federal Protective Services] Officers, including FPS Officer Z.C., walked out to remove REDONDO-ROSALES from the path of the government car. As the group of FPS officers approached REDONDO-ROSALES, he moved backwards away from the FPS officers in an apparent attempt to avoid being apprehended. Then, FPS Officer Z.C. approached REDONDO-ROSALES in an effort to detain him, and REDONDO-ROSALES intentionally struck Officer Z.C. in the face with his left hand (at the time, REDONDO-ROSALES had a tan, wide-brimmed hat in his left hand).

d. After FPS officers were able to detain REDONDORO-SALES, Officer Z.C. and approximately four other FPS officers began to escort REDONDO-ROSALES towards the Alameda Street Entrance.

e. As Officer Z.C. walked a few feet in front of the two FPS officers who were escorting REDONDO-ROSALES toward the Alameda Street Entrance, BROWN approached Officer Z.C. and stepped into Officer Z.C.’s path. Officer Z.C. continued past BROWN toward the Alameda Street Entrance, but as he did so, BROWN intentionally hit Officer Z.C. in his left side with her right arm.

The felony charge against Brown was reportedly no-billed by a jury. For whatever reason, Bill Essayli charged her with misdemeanor interference instead, only to succeed in getting her detained after she allegedly violated bail by following an ICE officer home, for which she and two others were charged with conspiracy to dox him.

Though in Brown’s response to a 404(b) notice attempting to present the doxing case to the “assault” jury, her lawyers claimed that, “R.H. got into his personal vehicle and drove to where Ms. Brown was parked. He stopped his vehicle in the driveway, blocking Ms. Brown’s vehicle from leaving.” That is, even on the case that did get indicted, the cop in question arguably instigated the confrontation.

There were a number of things that would have been interesting if this had gone to trial, including Brown’s sealed filings about why she had a claim of self defense, as well as her success, after submitting them, in getting an order to share DHS’ Use of Force guidelines.

But things got interesting today when Brown submitted a motion to disqualify the victim in this case, ZC, from testifying based on DOJ’s failure to tell the defense that he had a (misdemeanor) criminal record, most notably a conviction in a harassment involving physical contact charge just four years ago.

C. Defense Discovers Z.C.’s Criminal History

On October 23, 2025, while preparing for trial in this matter, defense counsel learned that Z.C. has criminal history that includes at least:

• Harassment – subjecting a person to physical contact, in violation of Pennsylvania Statute § 18.2709(a)(1), convicted on June 17, 2021;
• Disorderly conduct, in violation of Florida Statute § 509.143, arrested on August 31, 2014; and
• Driving under the influence, in violation of Florida Statute § 316193(1), convicted on November 4, 2013.

Exhibits H, I, filed under seal.

These records were obtained through independent defense investigation. Of note, the defense does not have access to law enforcement databases and thus cannot confirm whether this is Z.C.’s complete criminal history or whether there is additional relevant information about these or any other arrests or convictions.

D. Defense Contacts the USAO With Its Findings. The USAO States It Was Not Aware of Z.C.’s Assault History.

On October 26, 2025, after further research and internal discussion, defense counsel contacted government counsel regarding its findings. Government counsel requested a few hours to investigate and respond. Later that evening, the parties conferred by telephone. Government counsel indicated that it was not previously aware of Z.C.’s 2021 conviction for assault. The government had asked Z.C. about his prior convictions in interviews. The government was only aware of Z.C.’s 2014 arrest for disorderly conduct and his 2013 conviction for driving under the influence. In addition, government counsel stated that it had not conducted an independent Henthorn review of Z.C., but had relied on the word and responsiveness of another agency (FPS) to conduct a Henthorn review of Z.C.’s personnel file.

The judge in the case, Obama appointee Fernando Olguin, was not only interested in learning more about DOJ’s failure to disclose this detail, but also who, if anyone, knew about ZC’s criminal history, and if so, why they didn’t disclose it.

Having reviewed and considered all the briefing filed with respect to defendant’s Motion to Compel Production of Complete Personnel Files and Motion in Limine to Exclude Testimony of Z.C., (Dkt. 83, “Motion”), the court concludes that it would benefit from full briefing on the issues presented in the Motion. Accordingly, IT IS ORDERED THAT:

1. The government shall file its papers in opposition to the Motion by no later than Tuesday, October 28, 2025 at 5:00 p.m.

2. Together with its opposition, the government must submit a declaration signed by counsel for the government that sets forth the names and titles of the individuals who conducted the Henthorn and/or Brady reviews of the relevant personnel file materials, and the dates on which such reviews were conducted. Counsel for the government is cautioned that failure to provide such a declaration may lead to the imposition of sanctions, including but not limited to the exclusion of evidence and/or witnesses.

Normally, when DOJ has decided they have to abandon false assault charges, they attempt to dismiss without prejudice.

Not so here. They’re filing to dismiss with prejudice.

The United States moves to dismiss its information with prejudice against defendant in the interests of justice under Federal Criminal Rule 48(a), and therefore respectfully requests that the Court grant its motion. Defendant does not oppose dismissal and the parties agree all pending motions should be denied as moot.

Brown’s legal troubles are not done. The doxing case is a felony, and as a conspiracy case, DOJ has broader leeway for introducing evidence against Brown. She remains detained (based on her prior violation of bail) in that case.

But DOJ has been attempting to link these two cases, presumably as a way to salvage the initial assault case.

And even that tactic could now backfire.

US v Brown (assault) docket

US v. Raygoza (conspiracy to dox) docket

It started with the willful destruction of USAID.

I start what is sure to be a kaleidoscopic (or some might call disorganized) reflection on the undercurrents of power as Trump attempts to build a new America based on illusion by reminding that the first assault was on USAID. USAID was targeted, among other reasons, because it supported the kind of pro-democracy NGOs that have haunted Viktor Orbán for years, and also because the realities of aid in the field look funny to those pickled in the provincialism of culture war.

But it’s a useful reminder, because the destruction of USAID was both the first great strike against Congress’ power of the purse (because Marco Rubio was refusing to spend on programs Congress had appropriated, including programs with bipartisan support, like PEPFAR), and also the consensual destruction of a great deal of soft power the United States built up going back to the Cold War. Then, during the Cold War, USAID was recognized as a low-cost way to contest another great power and, along the way, to do something good and maybe even create a few new reliable markets for farmers in the heartland. Now, it had become a symbol of a past hegemony that conspiracy theorists, starting with the richest man in the world, had made suspect.

This reflection will focus on how Stephen Miller’s two-faced war on America’s immigrant diversity and Latin America exists in tension with Trump’s attempt to subjugate both the Democrats and China. I’m attempting to capture these intertwined threads to get to a point I’ve raised before. We know what the decline from democracy to authoritarianism looks like. Trump is overtly following Orbán’s path to competitive authoritarianism. But far too few have considered what it means that Trump is pursuing that model while committing hegemonic suicide.

The willful destruction of USAID laid an important foundation for two “negotiations” that are bedeviling Trump’s effort to consolidate power: the trade war Trump picked with China, and a funding fight with Democrats over whether Congress will be Congress anymore.

Art of the Deal guy is conducting a bunch of “negotiations” right now. Many of them involve levying threats, whether threatening to withdraw government funding, launching frivolous lawsuits, imposing draconian tariffs, or even charging people with fabricated crimes, and in response, extorting bribes, like the free work some white shoe law firms decided to give away or payment for the ballroom that will scar the edifice where the East Wing used to be. For most negotiating partners, such threats leave two choices: suing in an attempt to deem the entire extortion attempt unlawful, or attempting to minimize the extracted tribute through flattery.

But for China and the Democrats it is different. The government of China doesn’t do flattery — not of foreigners, anyway. Plus, China has been preparing for this moment since the last time Trump tried it, in his first term, in part by increasing its own capacity, in part by replacing American suppliers with countries China has been wooing with soft power for years.

And while Democrats have been suing and suing and suing, Trump’s ultimate goal for the minority — whose party currently leads most of the net donor states in the US — is nothing less than subjugation. Trump was happier to negotiate with Hamas than negotiate with Chuck Schumer and Hakeem Jeffries. Trump intends to make them, all Democrats, give him the adulation they refuse him.

And so Trump’s negotiating “tactics” for both are similar: a serial ratcheting up of demands, based on the belief that the desired end — subjugation — is the means to win the negotiation. In both cases, this obstinance has instead created vulnerabilities. By pushing China to impose an export control regime not dissimilar to those the US uses, Trump gave China leverage over the Rest of World countries with which China will continue to trade even as Trump shrivels inside his manufactured walls, the countries Trump once wished to peel off from China.

And every time Russ Vought commits another unprecedented Antideficiency Act crime, it proves the Democrats’ point that there can be no negotiations unless that lawlessness ceases.

But when Trump decided that he had to pay military servicemembers, he directly violated congressional statute. It is “by far the most illegal budgetary action he’s taken as POTUS, potentially setting the stage to break everything,” writes Bobby Kogan, the senior director of federal budget policy at the Center for American Progress. “The mechanism through which Trump is paying the troops is the most blatant large Antideficiency Act (ADA) violation in US history.”

Trump is taking money from an account specifically earmarked for research, development, testing, and evaluation, and spending it on military pay, which is forbidden by both the Constitution and law (the Antideficiency Act carries a jail sentence of up to two years), and something administration officials publicly promised Congress they would not do. Dave Jamieson reports at HuffPost that Trump is planning a similar process to keep paying ICE and CBP law enforcement.

Even in three votes on paying essential workers, Democrats refused to budge for a bill that ceded any more power to Vought (the end vote was the same as cloture for the continuing resolution has been, but two different Democrats — Jon Ossoff and Raphael Warnock — voting with Republicans instead of Catherine Cortez Masto and Angus King).

Vought becomes a greater liability as he gleefully cuts things cherished by Republicans, too, like the promise of an easier commute into NYC.

Having failed thus far, Trump is going to withhold emergency funding for SNAP starting this week. Either he believes that Democrats have empathy (or courage) that Republicans don’t, or he forgets that poor people across the country rely on government aid. But he believes that starving families will force Democrats to bow.

Donald Trump is destroying not just the village but broad swaths of the country in his bid to humiliate his two adversaries. He is seeking capitulation to his person rather than any benefits for the United States.

Even as the country remains shut down, Marco Rubio and Stephen Miller have become NeoNeoCons.

Trump has reverted to Cold War means, launching a larger covert war based on dubious legal claims, what his buddies call the “Donroe Doctrine,” a name as stupid as the concept.

Mr. Trump’s new directive appears to envision a different approach, focused on U.S. forces directly capturing or killing people involved in the drug trade.

Labeling the cartels as terrorist groups allows the United States “to use other elements of American power, intelligence agencies, the Department of Defense, whatever, to target these groups if we have an opportunity to do it,” Marco Rubio, the secretary of state and national security adviser, said on Thursday in an interview with the Catholic news outlet EWTN. “We have to start treating them as armed terrorist organizations, not simply drug dealing organizations.”

The use of Special Forces against alleged drug cartels in other countries rests on the same kind of legal chicanery and nested fabrications that went into Stephen Miller’s unlawful deportation of mostly innocent Venezuelans to Bukele’s concentration camp. And even though the B-1 bombers flying off the coast of Venezuela were readily tracked on commercial apps, Trump explicitly denied them. They’re not hiding, though, that they’re sending the ships that have for decades projected power in the Middle East to take out a two-bit dictator in Venezuela.

But that’s not the only bullshit Trump is selling. For example, Trump’s latest cartel designation — of Cartel de los Soles — is of a cartel that (unlike TdA) may not even exist.

While some of US President Donald Trump’s right-wing led allies in South America — Argentina, Ecuador and Paraguay — have echoed his designation of “Soles” as a terrorist organization, many have doubts such a group even exists.

Venezuela itself, and neighbor Colombia, insist there is no such thing as “Cartel de los Soles.”

Some experts agree, saying there is no evidence of the existence of an organized group with a defined hierarchy that goes by that name.

[snip]

“There is no such thing, so Maduro can hardly be its boss,” Phil Gunson, an analyst at the International Crisis Group think tank, told AFP of the so-called “Cartel de los Soles.”

[snip]

According to the InSight Crime think tank, the name was ironically coined by Venezuelan media in 1993 after two generals were nabbed for drug trafficking. The sun is a symbol on the military uniform epaulettes of generals in the South American country.

“Rather than a hierarchical organization with Maduro directing drug trafficking strategies, the Cartel of the Suns is more accurately described as a system of corruption wherein military and political officials profit by working with drug traffickers,” InSight Crime said on its website.

Yet that is the sketchy basis on which Stephen Miller has authorized the murder of one after another boat full of unidentified, first in the Caribbean and now in the Pacific.

The Administration’s thinking — starting from Stephen Miller’s goal of using dead Latinos as a propaganda stunt– is insanely childish.

Then there are the senior officials who see Venezuela as a means to project a tough-guy, defender-of-the-homeland image. Stephen Miller views the air strikes as an opportunity to paint immigrants as a dangerous menace, according to one of the White House officials. Vice President J. D. Vance, though often inclined toward isolationism, has pushed the necessity of defending U.S. borders. And Hegseth, who prefers to be known as the war secretary, is seeking a means of projecting military strength in a region where Defense Department planners hope to reassert American primacy. Finally, there’s Trump himself, who wants to score a foreign-policy victory amid frustrations over his inability to end the war in Ukraine. One close ally of the president’s told us that he was also drawn to the chance to take decisive action, as he did with June’s Iran bombings. “He can give the order and watch it explode. It’s clear-cut and simple, and no American gets hurt,” that ally told us.

This is not the Dulles brothers playing chess. It’s a bunch of insecure boys overturning the checkers board because the rules assign the same number of pieces to both sides. But they’re toppling the board while wielding very big weapons and sketchy — or no — targeting data.

Indeed, they look like they’re playing, from the failure to destroy a submersible in open water, leaving two very inconvenient survivors, to the shrapnel strike on the Vice President’s security, to the new propaganda corps made up of Russian useful idiots.

Such buffoonery extends to Miller’s war on Blue cities. For all the untold human damage it has and is causing,  it nevertheless continues to shine in its Butt Cracks and Beer Belly squalor, including in its training dropouts who can’t pass an open book test on the Fourth Amendment.

Like the invasion of Latin America, it feigns root in intelligence, as viewed by the invasion of an entire apartment building on Chicago’s South Shore Drive predicated on the alleged presence of one or at most two Tren de Aragua members, looking just like an apartment invasion John Yoo dreamt up 24 years ago.

[I]n execution, a number of aspects of the raid looks just like what the raid Yoo envisioned two decades ago.

The raid took place in the middle of the night; a warranted search would mandate permissible hours — usually after dawn — when the search could be conducted.

The entire raid was predicated on the presence of (initially) two and in retrospect just a single Tren de Aragua member. But virtually every one was detained while law enforcement searched for active warrants, and 37 people were arrested. With the exception of a few apartments, the entire building was searched, and left in a mess.

[snip]

In other words, this raid looks just like what we would expect if Stephen Miller were applying already-dodgy John Yoo opinions targeting terrorists who really did launch a military style attack on the US, and applied it, instead, against a gang that Miller has lied persistently to turn into something greater than it is.

But mostly, like the make-believe cartel just added to the terrorist list, the predicate for invading Blue cities remains make-believe.

Stephen Miller’s justifications for invading Blue cities is no more based in reality than the latest cartel he invaded on which to hang murderboats and Special Operations invasions.

Miller has fed Trump manufactured propaganda about Oregon. And those on the ground have manufactured false claims. Or, in Oregon, the state informed the Ninth Circuit that a key claim a panel used to overturn Trump appointee Karin Immergut’s injunction on Guard deployment — that much of the Federal Protective Services had had to deploy to Portland, was false: “defendants admitted that 115 FPS officers have never been redeployed to Portland.”

Or in Chicago, the explanation that Greg Bovino contemptuously violated a retraining more with claims of “commercial artillery shell fireworks.” “The statement is a lie,” lawyers for Illinois stated plainly about the claimed use of commercial artillery shell fireworks.

It’s still very much in question whether appellate courts and SCOTUS will permit Trump to invade Blue cities based entirely on propaganda, as Susan Graber asked in her dissent to her colleagues’ decision to allow Trump to invade Oregon (a dissent that noted the vagueness of the now-debunked FPS claim).

We have come to expect a dose of political theater in the political branches, drama designed to rally the base or to rile or intimidate political opponents. We also may expect there a measure of bending—sometimes breaking—the truth. By design of the Founders, the judicial branch stands apart. We rule on facts, not on supposition or conjecture, and certainly not on fabrication or propaganda. I urge my colleagues on this court to act swiftly to vacate the majority’s order before the illegal deployment of troops under false pretenses can occur. Above all, I ask those who are watching this case unfold to retain faith in our judicial system for just a little longer.

Steve Vladeck lays out the play of all three Blue states — California, Oregon, and Illinois — challenging Trump’s invasion. Joyce Vance has a great update on the Ninth. And Chris Geidner catalogs all the innocent Americans whose rights are being trampled along the way, with three attempts to get Justice Kavanaugh to answer for the Kavanaugh stops he blessed.

Trump is engaging in a kind of magical realism in both Latin America and the United States, inventing the most transparent, outlandish bullshit to justify military invasions by incompetent dolts of both other countries and Blue states.

And for all his dickwagging about power, both of those campaigns make the United States far weaker.

But all that’s happening against the background of Trump’s intransigence — his demand that, while he conducts these invasions, both China and the Democrats (and more recently, Canada) simply bow before him.

This is one reason I’m especially fascinated by Trump’s treatment of Argentina, an attempt to support their peso long enough to stave off a debacle for Javier Milei in this weekend’s legislative elections. That part succeeded: Milei’s party won more than enough seats to sustain his veto power.

President Javier Milei scored a decisive political win Sunday, strengthening his position in Argentina’s Congress and securing a lifeline for his audacious free-market revolution backed by President Trump.

With nearly 92% of votes counted, Milei’s Freedom Advances party won almost 41% of the national vote, putting it on track to more than double its representation in Congress. That means his party and allies should secure at least one-third of the seats in both chambers—the critical threshold that allows Milei to preserve his veto power and defend his sweeping decrees.

The result, stronger than most polls had predicted, gives Milei fresh political momentum after months of unrest over deep spending cuts and a grinding recession last year. It also shores up his standing with Washington and the International Monetary Fund, which have tied future financial support to the survival of his austerity experiment. Market analysts expect Argentine bonds and the peso to rally when trading opens Monday, reflecting relief that Milei still has political traction.

But at what expense?

The only conceivable way to spin this bailout as a benefit for the US — other than for Scott Bessent’s hedge fund buddies and a right wing populist, like Trump, tainted by corruption problems — is to imagine that this bailout, the cost of which soon may rise to $40 billion, helps shore up US allies on a continent increasingly cultivated by China.

That is, in the same year Trump willfully destroyed USAID (yearly budget, $30 billion for the entire world), the best explanation for spending up to $40 billion bailing out a failed economic ideology is that same purpose: soft power.

For just one country.

In a nice touch, the folks in Treasury who’ve implemented Bessent’s bailout of his hedgie buddies have been instructed not to take and disseminate pictures of the wreck Trump has made of the East Wing.

“As construction proceeds on the White House grounds, employees should refrain from taking and sharing photographs of the grounds, to include the East Wing, without prior approval from the Office of Public Affairs,” a Treasury official wrote on Monday evening in an email to department employees viewed by The Wall Street Journal.

A Treasury Department spokesman said the email was sent to employees because photos could “potentially reveal sensitive items, including security features or confidential structural details.”

But the tone deaf bailout wasn’t enough. Nor was Argentina’s poaching of US soybean markets in China, the final death blow for the US soybean market this year. But in the last week, Trump has signaled he will turn to Argentine beef imports in an attempt to bring sky-high beef prices down.

In an interview with Fox Business on Thursday, Agriculture Secretary Brooke Rollins said: “Currently, Americans consume 12 million metric tons of beef. 10 million, we produce in this country. 2 million, we import. Out of 12 million, [the Argentine quota] would be 20,000 every quarter. This is not a massive influx in the millions of tons I think that some have thought of beef from Argentina.”

But Christian Lovell, an Illinois cattle farmer and the senior director of programs at Farm Action, a nonpartisan farm organization, said: “If Trump goes through with what he outlined, I do believe it’s a betrayal of the American rancher. It’s a feeling that you’re selling us out to a foreign competitor.”

On Wednesday, Trump reacted to the backlash from cattle ranchers.

“The Cattle Ranchers, who I love, don’t understand that the only reason they are doing so well, for the first time in decades, is because I put Tariffs on cattle coming into the United States, including a 50% Tariff on Brazil,” Trump wrote on social media.

“It would be nice if they would understand that, but they also have to get their prices down, because the consumer is a very big factor in my thinking, also!” he added.

In a statement, Colin Woodall, CEO of the National Cattlemen’s Beef Association, a trade association for beef producers, said the organization and its members “cannot stand behind the President while he undercuts the future of family farmers and ranchers by importing Argentinian beef in an attempt to influence prices.”

Trump got what he wanted in Argentina, propping up his chainsaw puppet for the next little while.

But in doing so, he made the US far weaker, making China’s leverage over the US even greater.

Trump’s attempts to extend his power by force — to replace American hegemony with personalized coercion — are and will continue to backfire, diluting the power of that coercion.

No one knows what happens after that.

[NB: check the byline, thanks. /~Rayne]

Hello, I’m Rayne, and I’m a lapsed Catholic. I fell away from the Church over a period of time, beginning roughly with the Reagan years and the uptick in Christian fundamentalism’s influence on politics.

It didn’t happen all at once but I finally had enough when the Church became little more than a crypto-fascist mouthpiece for right-wing ideology, focusing almost exclusively on anti-abortion efforts instead of what I was taught were Christ’s teachings.

And yet more than 10 years of Catholic catechism shaped my values and morals, underpinning my Democratic identity. In hindsight I don’t think I left the Church so much as it left me.

Perhaps I should have nailed a thesis to the the Church’s doors in protest but when the entire Church has been subsumed by a political movement, it didn’t occur to me as an effective option.

Now we may need to figuratively nail a thesis on fellow American Christian citizens who’ve lost their way. They have forgotten altogether what Christ taught while forcing on us their corrupt vision of a white Christian nation.

If a nation is truly Christian, it’s not identified as white; the supremacy of whiteness is not what Christ taught. It’s certainly not what I was taught.

From Matthew 22:35-39, the New Testament, King James Version:

35 Then one of them, which was a lawyer, asked him a question, tempting him, and saying,
36 Master, which is the great commandment in the law?
37 Jesus said unto him, Thou shalt love the Lord thy God with all thy heart, and with all thy soul, and with all thy mind.
38 This is the first and great commandment.
39 And the second is like unto it, Thou shalt love thy neighbour as thyself.

During catechism, instructors elaborated on how we must love ourselves as we are the Creator’s handiwork; to love God as commanded means loving His works as well.

And loving His works meant to love our fellow humans because they too, were God’s handiworks.

You can see where I’m going, of course. What the Trump administration does is a rejection of what I’ve understood to be God’s commandments.

Not just the top two commandments, but so many other teachings from both the Old and New Testament representing the core of Christianity:

Old Testament

Exodus 12:49
The same law applies both to the native-born and to the foreigner residing among you.

Exodus 22:21
You shall not wrong a stranger or oppress him, for you were strangers in the land of Egypt.

Exodus 23:9
Do not oppress a foreigner; you yourselves know how it feels to be foreigners, because you were foreigners in Egypt.

Leviticus 23:22
When you reap the harvest of your land, do not reap to the very edges of your field or gather the gleanings of your harvest. Leave them for the poor and for the foreigner residing among you. I am the LORD your God.

Leviticus 24:22
You are to have the same law for the foreigner and the native-born. I am the LORD your God.

Leviticus 25:35
Now in case a countryman of yours becomes poor and his means with regard to you falter, then you are to sustain him, like a stranger or a sojourner, that he may live with you.

Deuteronomy 10:18
He defends the cause of the fatherless and the widow, and loves the foreigner residing among you, giving them food and clothing.

Deuteronomy 10:19
And you are to love those who are foreigners, for you yourselves were foreigners in Egypt.

Deuteronomy 15:7-11
“If there is a poor man with you, one of your brothers, in any of your towns in your land which the Lord your God is giving you, you shall not harden your heart, nor close your hand from your poor brother;

Deuteronomy 24:14
Do not take advantage of a hired worker who is poor and needy, whether that worker is a fellow Israelite or a foreigner residing in one of your towns.

Deuteronomy 27:19
Cursed is anyone who withholds justice from the foreigner, the fatherless or the widow. Then all the people shall say, “Amen!”

Zechariah 7:10
and do not oppress the widow or the orphan, the stranger or the poor; and do not devise evil in your hearts against one another.

New Testament

Matthew 25:35-46
For I was hungry, and you gave Me something to eat; I was thirsty, and you gave Me something to drink; I was a stranger, and you invited Me in; naked, and you clothed Me; I was sick, and you visited Me; I was in prison, and you came to Me.’ Then the righteous will answer Him, ‘Lord, when did we see You hungry, and feed You, or thirsty, and give You something to drink?

3 John 1:5
Beloved, you are acting faithfully in whatever you accomplish for the brethren, and especially when they are strangers;

James 1:27
Religion that God our Father accepts as pure and faultless is this: to look after orphans and widows in their distress and to keep oneself from being polluted by the world.

Galatians 3:28
There is neither Jew nor Gentile, neither slave nor free, nor is there male and female, for you are all one in Christ Jesus.

Hebrews 13:2
Do not neglect to show hospitality to strangers, for by this some have entertained angels without knowing it.

I don’t know how any Christian can have learned these tenets and not objected strenuously to Trump’s anti-immigrant policies and the funding of ICE as his personal anti-immigration militia.

Immigrants are strangers, travelers from foreign lands, asylum seekers looking for aid and justice. Christians haven’t been told to segregate the legal from illegal when it comes to treatment of immigrants; they have been told repeatedly to treat immigrants with kindness and generousity because all humans are ultimately the descendents of immigrants.

I thought of that last verse from Hebrews in particular after learning ICE shot a pastor in the face at the ICE detention facility in Broadview, IL.

(link to video if embedded link above does not play: https://www.youtube.com/watch?v=DVKXujeagO0)

I thought of Hebrews 13:2 again when ICE turned away interfaith clerics who came to administer communion to the faithful in detention two weeks ago.

And ICE has been harassing Catholic faithful by menacing them outside Chicago-area churches.

(link to video if embedded link above does not play: https://www.youtube.com/watch?v=YFDgzIWvpQA)

It doesn’t matter if Christian clerics representing the faith have appeared to protest ICE’s abuses and Trump’s immigration policies, let alone administer to the faithful. How much closer to an obvious an angel does one have to be for Trump and ICE to halt the perversion of Christ’s teachings these so-called white Christian nationalists are forcing on fellow humans?

It’s obvious Trump would have no compunction about shooting an angel in the face on Fifth Avenue given his administration’s policies and actions.

Even a lapsed Catholic like me finds the Trump adminstration’s behaviors decidedly un-Christian. It makes me think of yet another lesson I learned during catechism:

James 2:14-26
What good is it, my brothers, if someone says he has faith but does not have works? Can that faith save him? If a brother or sister is poorly clothed and lacking in daily food, and one of you says to them, “Go in peace, be warmed and filled,” without giving them the things needed for the body, what good is that? So also faith by itself, if it does not have works, is dead. But someone will say, “You have faith and I have works.” Show me your faith apart from your works, and I will show you my faith by my works. …

Deeds not words. Attacking immigrants is far from demonstrating Christian faith.