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EaRty | tn = | warcur Tem | Sze. MCRAE us Gace ‘March 23, 2023, chnacatthencm George Gascon, Esa Chief Michael R. Moore DISTRICT ATTORNEY L105 ANGELES POLICE DEPARTMENT LOS ANGELES COUNTY 100 West 1° treet 211 West Temple Street 0s Angeles, California 90012 Suite 1200 Los Angeles, California 90012 Re Criminal Investigation Into Garret Zegle’s legal Dox Kevin Morrie Dear Mr. Gascon and Chie! Moore: We write on behalf of our cient, P. Kevin Morris, Esq, resident ofthe city and county ‘of Los Angeles, to request thatthe Los Angeles County District Attorney's Office and the Los ‘Angeles Police Department investigate the actions of Mr. Garrett Ziegler i, among other actions, violating California Penal Code § 653.2 (Doxing) by posting Mr. Morris’ personal information, including his ‘ome addresses and cell phone number as wells pictures of Mr. ‘Morris family on the sociel media links connected with the website marcopolousa.cam (the Website"), operated by Nr. Ziegler withthe intent of causing Mr. Morris to be harassed and physically threatened by Nr. Ziegler’ extreme rightwing followers. Mr. Ziegler isa former White House staffer in the administration of President Donald Trump and i reportedly known for arranging a meeting atthe White House to convince then- President Trump to declar2 martial aw and use the military to seize vating machines and remain in power despite definitively losing the 2020 election. Since President Trump left office s reported by many news outlets, Mr. Ziegler has become a right-wing extremist and provocateur. Asan examfle of ths, as reported in the media, following his meeting with the January 6 Committe, Mr. Ziegler went on a profane and sexist rant on liveztream after hic testimony in which he attzcked committee members and two female former Trump staffers who have cooperated withthe January 6 Committee using misogynistic language. In that same rant, ithas been reported that Mr. Ziegler also accused the January 6 Committee of being “anti- 7 can com les/trump-ova-ofice-meeting-specalcounsel. smariatlawi 7 https www.cnn,com/2022/07/20/polites/garrett-iegler-rant/index.h Suu Wc Gate MCRAE LP | 620 Whe Bouvio | 1719 Fos | Ls AME, CANORA CONS Tu: (83) 301-4660 | Fs (323) 301-4576] woes cone Ean | sw tar RIGHT March 23, 2023 Fl Wricir Page 2 MCRAE ue white” and made such conments as "They're Bolsheviks. So they probably do have the ‘American founders and mast White people in general. This isa Bolshevstic ant White campatan.” Inaddition, we areinformed that Mr. Ziegler uses the intemet for harassment through the Website and its related social media channels where he engages in doxing activities, which 's posting personal contac: information for individuals inthe hopes that other right wing extremists will engage in Farassng and/ar violent behavior towards the individuals Mr. Ziegler targets? We are further informed that individuals targeted by Mr. Ziegler have been reporters, politicians, federal aw enforcement agents, and federal judges. Even mare concerning is that thas been reported that Mr. Ziegler has doxed Gina Haskel, the CIA director, and the FB! ‘agents who signed the search warrant for former President Trump's Mar-a-ago property in an effort to have extreme right-wing followers of former President Trump to harass the agents and their family members* if one ofthe highest ranking intelligence officals and federal aw enforcement agents can be doxed, then no one is safe from Mr. Ziegler’ legal conduet, Recently, Mr. 2eglr has been focused on exposing supposed information from what he claims came from a laptog belonging to Hunter Biden, the son of President Joe Biden, and \writing and eisseminatinga 600 page “report” on what he has titled Hunter Bidens aptop.® In “reporting” onthe supposed private information of Mr. Biden, it appears that Mr. Ziegler has no limits, respectablity or professionalism, even, as has been reported, going to far as to publish the private lary of Hunter Biden's sister in which she discussed her emotionally trauma from being a sex abuse vctim.® Mr. Ziegler uses harassment ofthe Biden family and Anyone connected with them as 2 money-making venture. We are informed and believe that (Mr. Ziegler has raised millons of dollars through his illegal activities. Further, we believe that thisis why Mr. Ziegler has targeted Mr. Morris for harassment. Mr. Moris is a friend of Hunter Biden ang, in May 2022, news articles reported that Mr. ‘Morris was providing financial assistance to Hunter Biden,” Immediately ater these articles appeared, Mr. Ziegler began a campaign of harassment against Mr. Morris. In r about May 2022, Mr. Ziegler contacted Mr. Morris impersonating a wel-known Democratic fundralser 3 oy ce marl st-got-doved-20220815 “ https ww thedsilybeast com/ex-trump-aide-sies-maga-lackeys-on-alleged-fb-agents families 5 http: /bidenlaptopreport marcopolousaort S nto frum iSm-arrettziegeran secrets thesstone him (last accessed Jan. 29,2023}, > https) /nvpost.com/202/05/12/meet-huntr-bidens-sugar-brotherlavoyer-kevin-mori EaRty | sun March 21, 2023 = | Wace Page 3 DBM | FiZee ue named John Cooper {*Mr. Cooper") in an effort to get Mortis to disclose information about Hunter Biden. Once Ziegler’s impersonation was expased, Mr. Morris hung up the phone ‘Thereafter, Mr. Ziegler continued to harass Mr. Mortis by pasting pictures of Mr. Morris and Me. Morris’ family onthe Mebsite's social media channels with derogatory comments. See Exhibit A attached hereto. Motivate by the attack on his family and by Mr. Zegler’s blatant invasion ofthe privacy of Ms. Ashley Biden, Mr. Morris engaged in a text exchange with Mir Zlegler in which Mr. Morris called out Mr. Ziegler for his legal conduct an threatened Mr “Ziegler with legal action uhile Mr. Ziegler just threatened Mi. Morris, Following this textexchange, Mr. Ziegler cherry picked portions ofthat text exchange and posted them on the Website in an effort to misconstrue the conversation as Mr. Morris ‘threatening Mr. Ziegler and asking for his followers help Because Mr. Morris was supposedly very rich and was threatening him. See Exhibit B attached hereto. Essentially, Mr. Ziegler was ring up his other extreme right-wing supporters to go after Mr. Morris, ‘Then Mr. Ziegler posted the address for Moris’ home in Malibu, Morrs' ell phone hhumber and Mortis’ home in Tennessee on the Website's sacal media channels without any reasonable justification or proper purpose for doing so. See Exhibit C attached hereto. ‘Thereafter, Ziegler engaged in conversations with followers of his Website who made commantesboutvilence of calling Moret’ cal phone, and of actualy driving past Mr. ‘Morris’ house in Tennessee. See Exhibit O attached hereto, Mr. Ziegler encouraged all such ‘conduct of harassment of Mr. Morris In addition, we areinformed and believe that Mr. Ziegler has harassed other indviduals associated with Mr. Morris. This includes doxing three fimmakers who work on documentary ‘lm projects with Mr. Mos. ‘Asa result of Mr. egler’s conduct, Mr. Morris has been continually harassed via phone «alls by numerous dfferert people and is informed and believe that people have been stalking him from time to time anc driving past his houses, all as adiect and proximate result of Mr. Ziegler’ outrageous conduct. Mr. Ziegler’s conduct as described hereinabove, and other actions, have clearly and Undeniably violated California Penal Code § 653.2, which provides: {a} Every person who, with intent to place another person In reasonable fear for his or her safety, or the safety of the other person's immediate family, by means ofan electronic ‘communication device, and without consent ofthe other person, ‘and for the purpose of imminently causing that other person EaRuy — SULLIVAN rast Um | G23, ‘unwanted physical contact, injury, oF harassment, bya third party, electronical distributes, publishes, e-mails, hyperlinks, or makes available for downloading, personal identifying information, including, but not imited to, aagital image of another person, oF an electrone message of a harassing nature about another person, which would be lke to incite or produce that unlawful action, is guilty ofa misdemeanor punishable by upto one year in 2 county jl, by fine of not more than one thousand dollars ($1,000), orby both that fine and imprisonment. (6) For purcases ofthis section, "electronic communication sevice” Incudes, buts not limited to, telephones, cell hones, computers, Internet Web pages or ites, Internet phones, hybrid cellular/internet/wireless devices, personal dighalasistants (PDA, video recorders, fax machines, or pagers, "Electronic ‘communieaton” has the same meaning asthe termis defined in Section 2510(12) of Tile 18 of the United States Code. (c) For purposes ofthis section, the following terms apply (1) Harassment” means 2 knowing and wilful course of conduct directed at a specific person that a reasonable perzon would contidar a rarioucly slarming, eeriously annoying, seriously tormenting or seriously terrorizing the person and that serves no legitimate purpose (2) OF aharassing nature” means ofa nature that a reasonable person would consider as seriously alarming, seriously annoying, seriously tormenting or seriously terrorizing ofthe person and that serves no legitimate purpose. ‘Moreover given Mr. Zegler’s history of rapid retaliation against people who angered or challenged him, we believe that Mr. Ziegler wil almost certainly increase the attacks on our client in a public manner ance the criminal investigation into Mr. Ziegler commences and place ‘our client in even more danger Accordingly, we request that an investigation will evea sufficient evidence of misconduct by Mr. Ziegler which wil lead toa convietion of Mr. Zigler for, among other actions, violating Penal Coie section 653.2, any = | satan March 21, 2023, => | wacur Pages em | Sze er MCRAE us Please acknowledge receipt of this letter, and do not hesitate to contact me should you, have any questions regarding this request. tiple Bryan M. 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