U.S. Department of Justice
‘Matthew M. Graves
United States Attommey
District of Columbia
Patrick Henry Building
601 D Street N.W.
Washington, D.C. 20530
September 6, 2022
VIA Hand Delivery
Enclosed is a subpoena commanding your appearance as a witness before a federal Grand
Tury. The Grand Jury consists of sixteen to twenty-three persons from the District of Columbia
and is responsible for inquiring into federal crimes that may have been committed in this District.
Re: Grand Jury Subpoena #GI2022090694461
USAO #2022R00150
‘The Grand Jury is conducting an investigation of possible violations of federal criminal
laws. As a Grand Jury witness, you will be asked to testify. Upon receipt of this letter, please
contact this office to obtain instructions on the logistics of coming to court, reimbursement for
‘travel costs, and collecting a witness fee.
Only the members of the Grand Juty, attomeys for the United States, and a court reporter
are permitted in the Grand Jury room while you testify. You may refuse to answer any question
ifa truthful answer to that question would tend to incriminate you. Anything that you do or say
‘may be used against you by the Grand Jury or in another legal proceeding. You have the right to
speak to an attorney before appearing in front of the Grand Jury. If you cannot afford an
attorney, the Court may agree to appoint one for you free of charge. Your attomey cannot be in
‘the Grand Jury room with you, but the Grand Jury will permit you a reasonable opportunity to
step outside the Grand Jury room and confer with your attorney if you desire.
Ifyou need the United States Attorney's Office to arrange your travel and
accommodations, please call our Witness Coordinator, Tonya Jones, at (202) 252-7133. Please
call me immediately if there are any scheduling problems.Although you are not required to do so, you are requested not to disclose the existence of
this subpoena or the fact of your compliance. Any such disclosure could impede the investigation
‘being conducted and thereby interfere with the enforcement of the law.
We appreciate your cooperation in this matter. If you have any questions, please contact
this office at the number below.
By:
Sincerely,
Matthew M. Graves
United States Attomey
John D. Crabb, Jr.
J.P. Cooney
Capitol Siege Section
(s/Mary L. Dohrmann
‘Mary L. Dohrmann
Assistant United States Attomey
601 D Street N.W.
Room #5.723
Washington, DC 20530
202-252-7035
mary.dohrmann@usdoj. gov‘20 10 (ke. 0S) Subpoena Tesi foes Gna
UNITED STATES DISTRICT COURT
forthe
District of Columbia
Ts SUBPOENA TO TESTIFY BEFORE A GRAND JURY
YOU ARE COMMANDED to appear inthis United States district court atthe time, date, and place shown
below to testify before the court's grand jury. When you arrive, you must remain at the court until the judge ora court
officer allows you to leave,
Place: U.S. DISTRICT COURT FOR THE DISTRICT OF COLUMBIA | Date and Time
US. Courthouse, 3" Floor Grand Jury # 22-5 Friday, September 23, 2022 at 9:00 AM.
333 Constitution Avenue, N.W.
Washington, D.C. 20001
‘You must also bring with you the following documents, electronically stored information, or objects:
This federal grand jury subpoena requites you to produce the materials identified inthe attachment onthe return
date identified above. You may comply with the document production portion of this subpoena by promptly providing
the required materials to the agent identified in the attachment. This subpoena also requires your testimony before the
grand jury ata later date. Please contact, or have your attorney contact, the agent identified in the attachment or the
‘undersigned Assistant United States Artomey to schedule the date you will appear for testimony in the grand jury.
Date: September 6, 2022 CLERK OF COUR’ i %,
HY 4
Ss js Coe
wi
ignathre of Clrkor Depty Clerk
The name, address, telephone number and email of the Assistant United States Attomey, who requests this subpoena,
ae:
Mary L. Dohrmana, Assistant United States Attomey Subpoena ##672022090594461,
United States Attorney's Office forthe District of Columbia SAO #2022R00150
6601 D Sirect N.W. Room #5.723 Preparer: MRLEACH,
‘Washington, DC 20530
Phone: 202-252-7035 Fax:
Email: mary. dohrmann@usdo} gov(60 288 (Rev. 8/8) Subpoena to Testy Before Grand Jury
RETURN OF SERVICE
RECEIVED BY | XE PLAGE
‘SERVER
served | °F Pace
‘SERVED ON (PRINT NAME}
‘SERVED BY (PRINT HAE) THE
‘STATEMENT OF SERVICE FEES
TRAVEL “SERVICES TOTAL
DECLARATION OF SERVER a
T declare under penally f pezjury under the laws of the United States of America thatthe Toregoing Information|
contained in the Retum of Service and Statement of Service Fees is tue and correct.
Executed on
Bae
Sipnatre of Saver
Fes oT S599
"ADDITONAL INFORMATION
‘As o who may serve a subpoena and the manner of Is sonvce 609 Rule 17(), Federal Rules of Criminal Procedure, or Rule 45(),
Federal Ruts of Cv Proceaure
2x°Fees and mleage nepd nt be tendered to the witness upon srvce of 2 subpoena issued on behalf ofthe United States or an
cer or agency thereo (Rule 45(), Federal rules of Civ Procedure; Rule 17(6), Federal Rules of Criminal Procedure) ox on behalf of
‘lain indigent partes and criminal defendants whe are unable to pay such cost (28 USC 1826, Rule 47(b) Federal Rules of Criminal
Procedure)
Subpoena #G32022090694461nL.
SUBPOENA ATTACHMENT
INSTRUCTIONS
A
In complying with this subpoena, you are required to produce all responsive documents,
records, information, and communications that are in your possession, custody, or
control, whether held by you or your past or present agent, employee, or representative
acting on your behalf. You are also required to produce documents that you have a legal
right to obtain, that you have a right to copy, or to which you have access, as well as
documents that you have placed in the temporary possession, custody, or control of any
third party,
No documents called for by this request shall be destroyed, modified, removed,
transferred, or otherwise made inaccessible to the grand jury. If you have knowledge that
any subpoenaed document has been destroyed, discarded, or lost, identify the subpoenaed
document and provide an explanation of the destruction, discarding, loss, or disposal, and
the date at which the document was destroyed, discarded, or lost.
This subpoena is continuing in nature, Any document not produced because it has not
been located or discovered by the retum date shall be provided immediately upon
location or discovery subsequent thereto with an explanation of why it was not located or
discovered until the return date
If you believe any responsive documents are protected by a privilege, please provide a
privilege log which (1) identifies any and all responsive documents to which the privilege is
asserted, (2) sets forth the date, type, addressee(s), author(s), general subject matter, and
indicated or known circulation of the document, and (3) states the privilege asserted in
sufficient detail to ascertain the validity of the claim of privilege.
Production with respect to each document shall include all electronic versions and data
files from email applications, as well as from word processing, spreadsheet, database, or
other electronic data repositories applicable to any attachments, and shall be provided to
the grand jury where possible in its native file format and shall include all original
metadata for each electronic documents or data file,
DEFINITIONS
A.
“Document” means any written, recorded, or graphic material of any kind that is in your
possession, custody or control. The term includes, but is not limited to: contracts;
agreements; letters; telegrams; interoffice communications; memoranda; notes; reports;
analyses; worksheets; spreadsheets; notebooks; surveys; lists; outlines; schedules;
pamphlets; newsletters; flyers; charts; logbooks; tabulations; compilations; studies;
books; records; telephone books or messages; visitor books; calendar or diary entties;
desk or appointment calendars; drafts; business cards; ‘minutes or meetings or
conferences; notes or memos or other records of telephone or other conversations ot
communications; electronic transmissions (including emails, text messages, instant
messaging, chat rooms, electronic bulletin boards, and any communications using
applications such as WhatsApp, Telegram, or Signal); ledgers; financial statements; bank
statements; check images (front and back); bills or invoices; purchase orders; receipts;photographs; microfilm; microfiche; audio and video tape or disc recordings; computer
printouts; and communications. It also includes electronically stored data and electronic
files, stored on file servers, e-mail servers, hard drives, or other electronic storage media
within your control from which information can be obtained either directly or by
translation through detection devices or readers. Any such document is to be produced in
reasonably usable form, electronic and searchable, along with instructions for reading the
data, Any such electronically stored information must be preserved in its native format.
The term “document” includes the original (or a copy thereof if the original is not
available) and all copies that differ in any respect from the original or that bear any
notation, marking or information not on the original. “Document” shall also include all
documents, materials, transmissions, and information, including Electronically Stored
Information within the meaning of the Federal Rules of Civil Procedure,
“Electronically Stored Information” or “ESI” shall mean the complete original and any
non-identical copy (whether different from the original because of notations, different
metadata, or otherwise), regardless of origin or location, of any writings, drawings,
graphs, charts, photographs, sound recordings, images, and other data or data
compilations stored in any electronic medium from which information can be obtained
either directly or, if necessary, after translation by you into a reasonably usable form.
This includes, but is not limited to, electronic mail, instant messaging, videoconferencing,
and other electronic correspondence (whether active, archived, or in a deleted items
folder), word processing files, spreadsheets, databases, and video and sound recordings,
whether stored on: cards; magnetic or electronic tapes; disks; computer hard drives,
network shares or servers, or other drives; cloud-based platforms; cell phones, personal
digital assistants (“PDAs”), computer tablets, or other mobile devices; or other storage
media,
“Referring to” or “relating to” shall mean discussing, describing, reflecting, regarding,
containing, analyzing, studying, reporting, commenting on, evidencing, constituting,
setting forth, considering, recommending, concerning, or pertaining to, in whole or in
art,
The terms “including” and “includes” shall be construed broadly so that specification of
any particular type of document shall not be construed to exclude other types of
documents that are nevertheless responsive but not specifically identified,
“Communications” refers to exchanges kept in any form, whether written, electronic, e-
‘mail, Protonmail, text, instant message, WhatsApp message, Telegram message, Signal
‘message, telephone, or other, and is meant to be interpreted broadly in accordance with
federal law.
“Certification” shall mean any proceeding in the United States Congress on January 6,
2021, convened in order to count the electoral votes, resolve any objections, certify their
validity, and announce the result.
“Rally” shall mean any January 2021 rally or event in Washington, D.C., held with a
primary or partial purpose to advocate in favor of or in opposition to certification of the
results of the November 2020 Presidential election.H. Entities identified by name shall be construed broadly to include any subsidiary, affiliate,
successor-in-interest, or related corporate entity, as well as any employee, representative,
contractor, affiliate, or vendor.
I. REQUEST FOR DOCUMENTS
A. Forthe period October 1, 2020, through the present, all documents and communications:
1
Relating to the Certification,
Relating to or constituting any evidence (a) tending to show that there was
fraud of any kind in or relating to the 2020 Presidential Election, or (b)
used or relied upon to support any claim of fraud in relation to the 2020
Presidential Election.
Relating fo any information conveyed to you or to any other person
challenging, rebutting, undercutting, tending to show, or claiming that
there was not fraud in the 2020 Presidential Election, or claiming or
tending to show that any allegation of fraud was unfounded, baseless, or
incorrect in whole or in part.
‘Submitted to, received from, or involving any local, state, or federal public
official relating to (a) any claim of fraud in relation to the 2020
Presidential Election, including any presentation made to any such public
official regarding the 2020 Presidential Blection, or (6) any effort to
persuade any such public official to change or affect the results of the
2020 Presidential Election, or delay certification of the results of that
election,
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;
Relating to the signing, mailing, or delivery of any document purporting to
be a Certificate certifying electoral votes in favor of Donald J. Trump
and/ot Michael R. Pence.
Relating to any effort, plan, or attempt to have any person serve as an
Elector in favor of Donald J. Trump and/or Michael R. Pence.
Relating to any strategies or options for ensuring the certification of
Donald J. Trump as the victor of the 2020 Presidential Election,
Relating to any claim that the Vice President and/or the President of the
Senate had the authority to reject or choose not to count presidential
electors, to delay the certification of electors, to adjourn the Certification,
or to direct that a State or States reconsider ot re-evaluate its slate of
presidential electors.10.
To, from, with, or including any of the following, regardless of subject
matter:
. Arizona: Nancy Cottle, Loraine Pellegrino, Tyler Bowyer, Jake Hoffman,
Anthony Kem, James Lamon, Robert Montgomery, Samuel Moorhead,
Greg Safsten, Kelli Ward, Michael Ward, Karen Fann, or Thomas Lane:
. Georgia: Joseph Brannan, James “Ken” Carroll, Vikki Townsend
Consiglio, Carolyn Hall Fisher, Burt Jones, Gloria Kay Godwin, David G.
Hanna, Mark W. Hennessy, Mark Amick, John Downey, Cathleen Alston
Latham, Daryl Moody, Brad Carver, David Shafer, Shawn Still, C.B.
Yadav, John A. Isakson, Patrick Gartiand, CJ Pearson, Susan Holmes, or
Robert Sinners;
. Michigan: Kathleen Berden, Rose Rook, Mayra Rodriguez, Hank Choate,
Meshawn Maddock, Matt Maddock, Mari-Ann Henry, John Haggard,
Clifford Frost, Kent Vanderwood, Stanley Grot, Marian Sheridan,
‘Timothy King, James Renner, Michele Lundgren, Amy Facchinello, Ken
‘Thompson, Terry Lynn Land, Gerald Wall, or Shawn Flynn;
New Mexico: Jewll Powdrell, Deborah W. Maestas, Lupe Garcia, Rosie
Tripp, Anissa Ford-Tinnin, Harvey Yates, or Steve Pearce;
. Nevada: Michael J. McDonald, James DeGraffenreid, Durward James
Hindle IIL, Jesse Law, Shawn Mechan, or Eileen Rice;
Pennsylvania: Bill Bachenberg, Lou Barletta, Tom Carroll, Ted Christian,
Chuck Coccodrilli, Bernadette Comfort, Sam DeMarco III, Marcela Diaz~
Myers, Christie DiEsposti, Josephine Ferro, Charlie Gerow, Kevin Harley,
Leah Hoopes, Ash Khare, Andre McCoy, Lisa Patton, Pat Poprik, Andy
Reilly, Suk Smith, Calvin Tucker, Robert Asher, Robert Gleason, Thomas
Marino, Lance Stange, Lawrence Tabas, Christine Torretti, or Carolyn
Welsh;
; Wisconsin: Andrew Hitt, Kelly Ruh, Carol Brunner, Edward Scott
Grabins, Bill Fechan, Robert F. Spindell, Jr., Kathy Kieren, Darryl
Carlson, Pam Travis, Mary Buestrin, or Tom Schreibel;
B. For the period of October 1, 2020, through January 20, 2021, regardless of subject matter,
all documents and communications to, from, with, or including:
1
Any member, employee, or agent of the United States Department of
Justice (“DOJ”), or any component, branch, litigating unit, or office of
DOI.
Bernard Kerik
Mike Roman
James Troupis
Jenna Ellis
Joe DiGenovaiH.
Subpoenaed materials may be produced
a John Eastman
8 Kenneth Chesebro
9. Rudy Giuliani
10, Sidney Powell
11, Victoria Toensing
12, Cleta Mitchell
13, Bruce Marks
14, Boris Epshteyn
15. Justin Clark
16. Matt Morgan
17, Joshua Findlay
For the period of October 1, 2020, through January 20, 2021, all documents and
communications relating to any compensation, monetary or otherwise, provided to or
received from any individual listed in paragraph 1LB.2 through I11.B.17 of this
subpoena.
All documents and communications relating to the planning, coordination, funding of,
fundraising related to, compensation for participation in or attendance at, or intent of the
Rally and subsequent march to the U.S, Capitol
All documents and communications relating to any compensation received or provided,
monetary or otherwise, for or related to (1) efforts to contest the 2020 Presidential
Election; (2) the certification of the 2020 Presidential Election; and/or (3) the Rally.
All documents and communications relating to the Save America PAC, including, but not
limited to, documents related to the formation of the Save America PAC, the funding of
the Save America PAC, and/or the use of money received by the Save America PAC.
All documents and communications relating to any fundraising efforts premised, in part
or whole, upon (1) efforts to contest the 2020 election; (2) the certification of the January
2020 election; and/or (3) the Rally.
For the period October 1, 2020, through the present, documents sufficient to show any
email accounts, social media accounts, telephone numbers, messaging applications, or
other methods of electronic communication that you used.
Any and all documents or other materials produced to the House Select Committee to
Investigate the January 6th Attack on the United States Capitol, whether pursuant to
subpoena, voluntarily, or otherwise; and any documents responsive to any subpoena
served upon you or your agent by the Committee, regardless of whether previously
produced.
Daniel A. Mehochko
Special Agent
FBI Washington Field Office
damehochko@fbi.gov