johnearlesullivan/capitol · Datasets at Hugging Face

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father and employer John J. Sullivan . Mr. Sullivan reiterates that he is his
son's employer and that his son is paid on a commission basis.
Unfortunately, due to COVID-19 and other factors Mr. Sullivan's business
in 2021 has not been particularly lucrative. Accordingly, his son, defendantv
1Case 1:21-cr-00078-EGS Document 61 Filed 12/17/21 Page 1 of 17John Sua ivan,has only received cornrnission in calendar year 2021 in the
amount of$6B 700.00
2.Attached hereto as Exhibit#2 is a Notice of Eviction for defendant
at his apattmentiocated at 567 Annaston Piace,#2,Murray Utah.The
eviction notice shows defendant was in arrears of his rnonthiy rental
obligation in the amount of$495,23.The arrearage has been satisfied
through funds borrowed fronl defendant's parents.The total monthly rentis
$1,944,32 and Exhibit#2 evidences that defendantis having difficuity
paying his rento E)efendant had to sea some of his personal camera
equipmentto pay his rent.Defendant's parents give hirn$1,000.00a!Y onth
to assistin rent payments.However,they cannot continue to provide this
amount of rental assistance for rnuch ionger.
3.Attached hereto as Exhibit#3 is a credit repott frorn Experiano The
repott documents that on June 20,2020 defendant had a credit score of
770BHowever,as of December 7,2021,defendant's credit score has
dropped to 559.The reason forthe drop in defendant's credit score is
primarily due to delinquent payments on his revoiving credit card accounts
Defendant's credit score has gone fronl good to poor since June,2020B
4.Attached hereto as Exhibit#4 are defendant's credit card
StaterYlentS for December,2021.The statements re÷ ectthat defendant has
2Case 1:21-cr-00078-EGS Document 61 Filed 12/17/21 Page 2 of 17outstanding revolving credit card debtin the approxirnate amount of
$20,925B 17
5,Attached hereto as Exhibit#5 is a deciaration frorn defendantthat
he has a-229.93 negative balance in his bank account with Chase Bank
Defendant has a checking account with American First Credit Union with a
current balance of$236B 98 remaining.These are his onty bank accountsB
Defendantfutther declares that he has to borrow money fronl his parents in
orderto rnake his rnonthiy living expenses.He has no other sources of
income.The seized assets are needed fbr defendantto rYlake his upcorning
and on]going rnonthly expenses,(Defendant notes there are some rninor
ditterences bemeen his initialfinancial deciaration and the attached
financial deciaration.These rninor direrences are due to his changing
financial obligations over the past six rYlonthsr
6.VVith respect to his vehicles,defendant owns a 2007 motorcycle
with an approxirnate value of$3,000.00 and a 2014 Mercedes Benz CLA
250 with an approxirnate value of$10,000.00.Defendant has not used his
motorcycte since June,2021 due to an inability to pay insurance costs.
Defendant's insurance has not been paid on the car since October,2021
and he expects that his insurance wili soon be cancea ed.in addition,
defendant has not been able to pay registration fees on the vehicleB
3Case 1:21-cr-00078-EGS Document 61 Filed 12/17/21 Page 3 of 177.Defendantforrneriy had health insurance through BIue Cross/BIue
Shield.Thatinsurance has been terrninated.He cannot afFord to purchase
any other health insurance.E)efendant has a pending application with
Medicaid for health insurance subrYlitted on December 5,2021 and he
applied forfood stamps on December 5,2021.
8BE)efendant has had to borrow money fronl his parents to pay his
electric ba Ist gas bilis and water bilis.Defendant takes prescription
medications.He has to borrow funds fronl his parents to pay forthese
medications.Defendant's rYlOnthly telephone bia is approxirYlately S278B 00B
The telephone bia also has to be paid for with borrowed funds
9.There has been a vast amount of discovery generated to date by
the United States.itis anticipated that the United States wili produce
significant amounts of additional discovery.Aa of these rnaterials rYlust
reviewed,outlined and organized.in addition,defendant wia be ttling
multiple additional pretriai motions that vG arequire resolution by the Cou .
The United States House of Representatives is conducting an extensive
inquiry into the facts surrounding the events that forrn the basis ofthe
indictrnent.The inquiry rnay produce relevant and exculpatory evidence
pertaining to the very signi,cant charges in the indictrYlent and rYlay
produce evidence retevant to attirrYlatiVe defenses available to defendant,
4Case 1:21-cr-00078-EGS Document 61 Filed 12/17/21 Page 4 of 177.E)efendant emphasizes the factors detailed in Paragraph 9 as itis
defendant's expectation that trial of this rnatter vvili not cornrnence for a
signi,cant period of tiw vle and not before the 1louse of Representatives
completes its investigation.Aå ordingiy.defendant wia need a portion of his
seized assets in orderto pay ordinary and necessary household expenses
for an extended pettod oftime.
WHEREFORE,the foregoing consideredE defendant prays this
Honorable Court for reconsideration of his Motion to Retease Seizure
Order.
Respectfua y subnlitted,
s
Steven R.Kiersh« 323329
5335 VVisconsin Avenue,N.VV.
Suite 440
Washington,D.C.20015
(202)347] 0200
CERTIFiCATE OF SERViCE
5Case 1:21-cr-00078-EGS Document 61 Filed 12/17/21 Page 5 of 17I HEREBY CERTIFY that a true and accurate copy ofthe foregoing
was seW edEvia the Cours eled_ nic ming systemE upon Assistant UoS.
Attomey Candioe Wong on thisthe 17n day Of Decembeä 2021.
Steven R.Kiersh
6Case 1:21-cr-00078-EGS Document 61 Filed 12/17/21 Page 6 of 17UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
V 21]cr]73(EGS)
JOHN SULLiVAN
MOT10N FOR RECONSIDERAT]ON OF DECEMBER 6,2021
DENIAL OF MOT10N TO RELEASE SEIZURE ORDER AND
SUPPLEMENT TO MOT]ON TO RELEASE SEIZURE ORDER
EXHIBIT LiST
Notice of eMction
Credit score reports
4. Credit card statement
5. Deciaration of defendant1. Amdavh Of JOhn Jo Sullivan
Q
@

father and employer John J. Sullivan . Mr. Sullivan reiterates that he is his

son's employer and that his son is paid on a commission basis.

Unfortunately, due to COVID-19 and other factors Mr. Sullivan's business

in 2021 has not been particularly lucrative. Accordingly, his son, defendantv

1Case 1:21-cr-00078-EGS Document 61 Filed 12/17/21 Page 1 of 17John Sua ivan,has only received cornrnission in calendar year 2021 in the

amount of$6B 700.00

2.Attached hereto as Exhibit#2 is a Notice of Eviction for defendant

at his apattmentiocated at 567 Annaston Piace,#2,Murray Utah.The

eviction notice shows defendant was in arrears of his rnonthiy rental

obligation in the amount of$495,23.The arrearage has been satisfied

through funds borrowed fronl defendant's parents.The total monthly rentis

$1,944,32 and Exhibit#2 evidences that defendantis having difficuity

paying his rento E)efendant had to sea some of his personal camera

equipmentto pay his rent.Defendant's parents give hirn$1,000.00a!Y onth

to assistin rent payments.However,they cannot continue to provide this

amount of rental assistance for rnuch ionger.

3.Attached hereto as Exhibit#3 is a credit repott frorn Experiano The

repott documents that on June 20,2020 defendant had a credit score of

770BHowever,as of December 7,2021,defendant's credit score has

dropped to 559.The reason forthe drop in defendant's credit score is

primarily due to delinquent payments on his revoiving credit card accounts

Defendant's credit score has gone fronl good to poor since June,2020B

4.Attached hereto as Exhibit#4 are defendant's credit card

StaterYlentS for December,2021.The statements re÷ ectthat defendant has

2Case 1:21-cr-00078-EGS Document 61 Filed 12/17/21 Page 2 of 17outstanding revolving credit card debtin the approxirnate amount of

$20,925B 17

5,Attached hereto as Exhibit#5 is a deciaration frorn defendantthat

he has a-229.93 negative balance in his bank account with Chase Bank

Defendant has a checking account with American First Credit Union with a

current balance of$236B 98 remaining.These are his onty bank accountsB

Defendantfutther declares that he has to borrow money fronl his parents in

orderto rnake his rnonthiy living expenses.He has no other sources of

income.The seized assets are needed fbr defendantto rYlake his upcorning

and on]going rnonthly expenses,(Defendant notes there are some rninor

ditterences bemeen his initialfinancial deciaration and the attached

financial deciaration.These rninor direrences are due to his changing

financial obligations over the past six rYlonthsr

6.VVith respect to his vehicles,defendant owns a 2007 motorcycle

with an approxirnate value of$3,000.00 and a 2014 Mercedes Benz CLA

250 with an approxirnate value of$10,000.00.Defendant has not used his

motorcycte since June,2021 due to an inability to pay insurance costs.

Defendant's insurance has not been paid on the car since October,2021

and he expects that his insurance wili soon be cancea ed.in addition,

defendant has not been able to pay registration fees on the vehicleB

3Case 1:21-cr-00078-EGS Document 61 Filed 12/17/21 Page 3 of 177.Defendantforrneriy had health insurance through BIue Cross/BIue

Shield.Thatinsurance has been terrninated.He cannot afFord to purchase

any other health insurance.E)efendant has a pending application with

Medicaid for health insurance subrYlitted on December 5,2021 and he

applied forfood stamps on December 5,2021.

8BE)efendant has had to borrow money fronl his parents to pay his

electric ba Ist gas bilis and water bilis.Defendant takes prescription

medications.He has to borrow funds fronl his parents to pay forthese

medications.Defendant's rYlOnthly telephone bia is approxirYlately S278B 00B

The telephone bia also has to be paid for with borrowed funds

9.There has been a vast amount of discovery generated to date by

the United States.itis anticipated that the United States wili produce

significant amounts of additional discovery.Aa of these rnaterials rYlust

reviewed,outlined and organized.in addition,defendant wia be ttling

multiple additional pretriai motions that vG arequire resolution by the Cou .

The United States House of Representatives is conducting an extensive

inquiry into the facts surrounding the events that forrn the basis ofthe

indictrnent.The inquiry rnay produce relevant and exculpatory evidence

pertaining to the very signi,cant charges in the indictrYlent and rYlay

produce evidence retevant to attirrYlatiVe defenses available to defendant,

4Case 1:21-cr-00078-EGS Document 61 Filed 12/17/21 Page 4 of 177.E)efendant emphasizes the factors detailed in Paragraph 9 as itis

defendant's expectation that trial of this rnatter vvili not cornrnence for a

signi,cant period of tiw vle and not before the 1louse of Representatives

completes its investigation.Aå ordingiy.defendant wia need a portion of his

seized assets in orderto pay ordinary and necessary household expenses

for an extended pettod oftime.

WHEREFORE,the foregoing consideredE defendant prays this

Honorable Court for reconsideration of his Motion to Retease Seizure

Order.

Respectfua y subnlitted,

s

Steven R.Kiersh« 323329

5335 VVisconsin Avenue,N.VV.

Suite 440

Washington,D.C.20015

(202)347] 0200

CERTIFiCATE OF SERViCE

5Case 1:21-cr-00078-EGS Document 61 Filed 12/17/21 Page 5 of 17I HEREBY CERTIFY that a true and accurate copy ofthe foregoing

was seW edEvia the Cours eled_ nic ming systemE upon Assistant UoS.

Attomey Candioe Wong on thisthe 17n day Of Decembeä 2021.

Steven R.Kiersh

6Case 1:21-cr-00078-EGS Document 61 Filed 12/17/21 Page 6 of 17UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

V 21]cr]73(EGS)

JOHN SULLiVAN

MOT10N FOR RECONSIDERAT]ON OF DECEMBER 6,2021

DENIAL OF MOT10N TO RELEASE SEIZURE ORDER AND

SUPPLEMENT TO MOT]ON TO RELEASE SEIZURE ORDER

EXHIBIT LiST

Notice of eMction

Credit score reports

4. Credit card statement

5. Deciaration of defendant1. Amdavh Of JOhn Jo Sullivan

Q

@