-3- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
religious denominations known for secrecy such as Scientology and Mormonism, which will be expanded upon further into this motion. In mid to late March 2020, defendant began to publicly express his disapproval for the Covid lock-downs and shelter-in-place orders, ultimately leading to defendant organizing protests against them. In organizing these protests and speaking out against what defendant believed to be the unconstitutional actions of the government, he was acting lawfully and his actions were protected under the 1
st
Amendment of the U.S. Constitution.
CHARACTERISTICS OF A COINTELPRO OPERATION
COINTELPRO began in 1956 as a program to deter and diminish communist activities within the United States. During the tumultuous 1960
’
s, the FBI began to focus this program on what they perceived to be the
“
dangerous radicals
”
of the Civil Rights Movement at that time led primarily by people of color such as Malcolm X, the Original Black Panther Party, and most notably Martin Luther King, Jr. COINTELPRO went on
“
officially
”
through 1971 until an activist group broke into FBI offices in Media, PA and stole thousands of pages of documents related to the program. The documents were distributed widely to numerous news media outlets, ultimately leading to a deeper investigation by a congressional committee called the Church Commission. The Church Commission identified much abuse of the constitutional rights of Americans targeted by this program and it was disbanded. Regardless of what the FBI might call such Counter Intelligence Operations Programs today, the program is very much alive and was used against defendant in this case.
Case 1:21-cr-00392-RCL Document 99 Filed 12/06/21 Page 3 of 82