SULLIVAN’S VIOLENT HISTORY:
11. SULLIVAN, DOB 07/18/1994, is a resident of Utah. Based on publicly available information and information provided by SULLIVAN in an interview on January 7, 2021, described further below, SULLIVAN is the leader of an organization called Insurgence USA through which he organizes protests. On July 13, 2020, SULLIVAN was charged with Rioting and Criminal Mischief by the local law enforcement authorities in Provo, Utah, based on his activities around a June 30, 2020, protest in which a civilian was shot and injured. The case is still pending.
12. The United States obtained a video of SULLIVAN, posted on YouTube, in which, while attending a protest in Washington, D.C., SULLIVAN can be seen telling a crowd, over a microphone, “we about to burn this shit down,” “we got to rip Trump out of office . . . fucking pull him out of that shit . . . we ain’t waiting until the next election . . . we about to go get that motherfucker.” SULLIVAN then can be seen leading the crowd in a chant of, “it’s time for a revolution.”
ON JANUARY 6 AT THE CAPITOL SULLIVAN’S OWN VIDEO SHOWS …
After the crowd broke through the last barricade, and as SULLIVAN and the others approach the Capitol Building, SULLIVAN can be heard in the video saying at various points: “There are so many people. Let’s go. This shit is ours! Fuck yeah,” “We accomplished this shit. We did this together. Fuck yeah! We are all a part of this history,” and “Let’s burn this shit down.”
d. At one point, SULLIVAN can be heard telling one of the individuals climbing the wall to give SULLIVAN his hand as individuals in the crowd are calling to help people up the wall.
e. The video records SULLIVAN’s entrance into the U.S. Capitol building through a broken window
f. SULLIVAN, once inside the Capitol Building, roamed the building with other individuals who unlawfully entered. During one of his interactions with others, SULLIVAN can be heard in the video saying, “We gotta get this shit burned.” At other times as he is walking through the Capitol, SULLIVAN can be heard saying, among other things, “it’s our house motherfuckers” and “we are getting this shit.”
g. In addition, several times during the video, SULLIVAN encounters law enforcement officers who are trying to prevent further advancement through the building by those who entered unlawfully. In at least two encounters, SULLIVAN can be heard on the video arguing with the officers, telling them to stand down so that they do not get hurt. Among other things, SULLIVAN can be heard telling officers, “you are putting yourself in harm’s way,” “the people have spoken,” and “there are too many people, you gotta stand down, the people out there that tried to do that shit, they got hurt, I saw it, I’m caring about you.”
At one point in the video, SULLIVAN enters an office within the U.S. Capitol, as seen in the screenshot below. Once inside the office, SULLIVAN approaches a window, also seen in the screenshot below, and states, “We did this shit. We took this shit.”
l. Further down the hall, SULLIVAN can be heard saying, “It would be fire if someone had revolutionary music and shit.”
m. In the video, once SULLIVAN reaches the Speaker’s Lobby, where Victim 1 was eventually shot, SULLIVAN can be heard telling one of the law enforcement officers guarding the doors, as seen in the screenshot below, “We want you to go home. I’m recording and there’s so many people and they’re going to push their way up here. Bro, I’ve seen people out there get hurt. I don’t want to see you get hurt.”
Eventually, the law enforcement officers begin to exit and individuals within the crowd move toward the doors. As this is happening, SULLIVAN can be heard yelling after the officers, “I want you to go home,” and then yelling, “Go! Go! Get 14 this shit!” SULLIVAN then films as others in the crowd try to break out the glass in the entryway door windows. Shortly thereafter, the video includes footage of Victim 1 getting shot as she tries to enter through the window opening.