johnearlesullivan/capitol · Datasets at Hugging Face

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confirmed secured. The proceedings resumed at approximately 8:00 pm after the building had been
secured. Vice President Pence remained in the United States Capitol from the time he was
evacuated from the Senate Chamber until the session resumed.
11. SULLIVAN, DOB 07/18/1994, is a resident of Uta h. 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 . . . fu cking pu ll
him out of that shit . . . we ain’t waiting until the next election . . . we about to go get that
mother fucker .” SULLIVAN then can be seen leading the crowd in a chant of, “ it’s time for a
revolution .”1
STATEMENT OF FACTS SUPPORTING PROBABLE CAUSE
13. On January 7 , 2021, SULLIVAN participated in a voluntary interview with a Federal
Bureau of Investigation Special Agent in Washington, D.C. SULLIVAN identified himself to the

1 Your affiant understands that SULLIVAN’s other conduct does not provide a basis for
finding probable cause he committed the offenses alleged in this affidavit. I provide this
information as background and as evidence of SULLIVAN’s intent and modus operan di as would
be admissible under Fed. R. Evid. 404(b). Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 5 of 186
agent and provided identifying information, including his date of birth, address, social media
identifiers, and phone numbers. In the interview, SULLIVAN stated that he was in Washington,
D.C. to attend and film the “Stop the Steal” March on January 6, 2021. SULLIVAN claimed to be
an activist and journalist that filmed protests and riots, but admitted that he did not have any press
credentials.
14. SULLIVAN also stated that he was at the U.S. Capitol on January 6, 2021, when
scores of individuals entered it. SULL IVAN stated he was wearing a ballistic vest and gas mask
while there. He showed the interviewing agent the ballistic vest. He further stated that he entered
the U.S. Capitol with others through a window that had been broken out. SULLIVAN stated he
follo wed the crowd as the crowd pushed past U.S. Capitol Police and followed the crowd into the
U.S. Capitol.
15. SULLIVAN further stated that he had been present at the shooting of a woman
within the U.S. Capitol by a U.S. Capitol Police officer and that he had fi lmed the incident. During
the interview, SULLIVAN showed the interviewing agent the footage he had taken, which
SULLIVAN stated he had uploaded to the Internet. The footage showed the area immediately
outside of the Speaker’s Lobby within the U.S. Capito l. I know from public source information
that the Speaker’s Lobby is the hallway from which one can enter directly into the chamber of the
U.S. House of Representatives. The Speaker’s Lobby is set off from the rest of the Capitol Building
by doors with g lass windows. The footage that SULLIVAN showed the interviewing agent
included footage of individuals breaking out the glass from the windows in the doors leading into
the Speaker’s Lobby, then a gun being discharged by a U.S. Capitol Police officer withi n the
Speaker’s Lobby, and a woman falling back into the crowd from a position of climbing through the
opening in one of the broken windows with a gunshot would . This woman was later identified as Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 6 of 187
Victim 1 .
16. SULLIVAN also voluntarily provided two phone num bers and multiple social media
account s and identifiers to special agents , including a YouTube account username , JaydenX.
17. At the conclusion of the interview, SULLIVAN stated that he was willing to
voluntarily provide a copy of all footage he recorded wit hin the U.S. Capitol to law enforcement
authorities.
18. On January 9, 2021, a task force officer with the FBI made contact with SULLIVAN
at one of the phone numbers SULLIVAN provided during his January 7 interview to follow up on
SULLIVAN’s offer to voluntari ly provide his footage . SULLIVAN told the task force officer that
the video he took within and around the U.S. Capitol on January 6, 2021, was in an iCloud account .
The same day, SULLIVAN sent a link to law enforcement from a Google Photos account under the
name “John Sullivan,” with an approximately 50 minute video. I have reviewed the video .2
19. The video footage records approaching, entering, and moving through the U.S.
Capitol on January 6, 2021. Although the video rarely shows SULLIVAN, at various points during
it, SULLIVAN narrates as he is moving and can be heard speaking to other individuals and law
enforcement officers. I recognize SULLIVAN’s voice in the video based on a January 11, 2021
voluntary interview I conducted wi th SULLIVAN at his residence, as described further below . In
addition, at one point the camera pans to an individual wearing a tactical vest and holding a gas
mask , as seen in the screenshots below, that match those SULLIVAN showed me during the
interview conducted on January 11 , 2021, also as further described in the paragraphs below :

2 A portion of the video with all of the clips discussed in this affidavit is also publicly
available on a YouTube channel attributed to “ JaydenX ” here:
https://www.youtube.com/watch?v=PfiS8MsfSF4&bpctr=1610480291 (last visited on January 13,
2021) . Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 7 of 188


20. Among other things, the video SULLIVAN recorded and provided to law
enforcement includes the following:
a. SULLIVAN filming at the front of a crowd as they push through police
Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 8 of 189
barriers on the west side of the U.S. Capitol. At the first moment the crowd breaks
through, SULLIVAN can be heard saying, “ they’re going in. ” The video follows
the crowd as they m ove toward the Capitol B uilding where SULLIVAN captured
additional sce nes of individuals b reaking through police barriers:

b. 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. ”
c. Later, SULLIVAN’s video includes footage of individuals climbing a wall
to reach a pl aza just outside the Capitol B uilding entrance, as seen in the screenshot
below. As individuals are climbing the wall, SULLIVAN can be heard saying, “You
guys are fucking savage. Let’s go!”
Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 9 of 1810

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:

Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 10 of 1811

confirmed secured. The proceedings resumed at approximately 8:00 pm after the building had been

secured. Vice President Pence remained in the United States Capitol from the time he was

evacuated from the Senate Chamber until the session resumed.

11. SULLIVAN, DOB 07/18/1994, is a resident of Uta h. 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 . . . fu cking pu ll

him out of that shit . . . we ain’t waiting until the next election . . . we about to go get that

mother fucker .” SULLIVAN then can be seen leading the crowd in a chant of, “ it’s time for a

revolution .”1

STATEMENT OF FACTS SUPPORTING PROBABLE CAUSE

13. On January 7 , 2021, SULLIVAN participated in a voluntary interview with a Federal

Bureau of Investigation Special Agent in Washington, D.C. SULLIVAN identified himself to the

1 Your affiant understands that SULLIVAN’s other conduct does not provide a basis for

finding probable cause he committed the offenses alleged in this affidavit. I provide this

information as background and as evidence of SULLIVAN’s intent and modus operan di as would

be admissible under Fed. R. Evid. 404(b). Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 5 of 186

agent and provided identifying information, including his date of birth, address, social media

identifiers, and phone numbers. In the interview, SULLIVAN stated that he was in Washington,

D.C. to attend and film the “Stop the Steal” March on January 6, 2021. SULLIVAN claimed to be

an activist and journalist that filmed protests and riots, but admitted that he did not have any press

credentials.

14. SULLIVAN also stated that he was at the U.S. Capitol on January 6, 2021, when

scores of individuals entered it. SULL IVAN stated he was wearing a ballistic vest and gas mask

while there. He showed the interviewing agent the ballistic vest. He further stated that he entered

the U.S. Capitol with others through a window that had been broken out. SULLIVAN stated he

follo wed the crowd as the crowd pushed past U.S. Capitol Police and followed the crowd into the

U.S. Capitol.

15. SULLIVAN further stated that he had been present at the shooting of a woman

within the U.S. Capitol by a U.S. Capitol Police officer and that he had fi lmed the incident. During

the interview, SULLIVAN showed the interviewing agent the footage he had taken, which

SULLIVAN stated he had uploaded to the Internet. The footage showed the area immediately

outside of the Speaker’s Lobby within the U.S. Capito l. I know from public source information

that the Speaker’s Lobby is the hallway from which one can enter directly into the chamber of the

U.S. House of Representatives. The Speaker’s Lobby is set off from the rest of the Capitol Building

by doors with g lass windows. The footage that SULLIVAN showed the interviewing agent

included footage of individuals breaking out the glass from the windows in the doors leading into

the Speaker’s Lobby, then a gun being discharged by a U.S. Capitol Police officer withi n the

Speaker’s Lobby, and a woman falling back into the crowd from a position of climbing through the

opening in one of the broken windows with a gunshot would . This woman was later identified as Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 6 of 187

Victim 1 .

16. SULLIVAN also voluntarily provided two phone num bers and multiple social media

account s and identifiers to special agents , including a YouTube account username , JaydenX.

17. At the conclusion of the interview, SULLIVAN stated that he was willing to

voluntarily provide a copy of all footage he recorded wit hin the U.S. Capitol to law enforcement

authorities.

18. On January 9, 2021, a task force officer with the FBI made contact with SULLIVAN

at one of the phone numbers SULLIVAN provided during his January 7 interview to follow up on

SULLIVAN’s offer to voluntari ly provide his footage . SULLIVAN told the task force officer that

the video he took within and around the U.S. Capitol on January 6, 2021, was in an iCloud account .

The same day, SULLIVAN sent a link to law enforcement from a Google Photos account under the

name “John Sullivan,” with an approximately 50 minute video. I have reviewed the video .2

19. The video footage records approaching, entering, and moving through the U.S.

Capitol on January 6, 2021. Although the video rarely shows SULLIVAN, at various points during

it, SULLIVAN narrates as he is moving and can be heard speaking to other individuals and law

enforcement officers. I recognize SULLIVAN’s voice in the video based on a January 11, 2021

voluntary interview I conducted wi th SULLIVAN at his residence, as described further below . In

addition, at one point the camera pans to an individual wearing a tactical vest and holding a gas

mask , as seen in the screenshots below, that match those SULLIVAN showed me during the

interview conducted on January 11 , 2021, also as further described in the paragraphs below :

2 A portion of the video with all of the clips discussed in this affidavit is also publicly

available on a YouTube channel attributed to “ JaydenX ” here:

https://www.youtube.com/watch?v=PfiS8MsfSF4&bpctr=1610480291 (last visited on January 13,

2021) . Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 7 of 188

20. Among other things, the video SULLIVAN recorded and provided to law

enforcement includes the following:

a. SULLIVAN filming at the front of a crowd as they push through police

Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 8 of 189

barriers on the west side of the U.S. Capitol. At the first moment the crowd breaks

through, SULLIVAN can be heard saying, “ they’re going in. ” The video follows

the crowd as they m ove toward the Capitol B uilding where SULLIVAN captured

additional sce nes of individuals b reaking through police barriers:

b. 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. ”

c. Later, SULLIVAN’s video includes footage of individuals climbing a wall

to reach a pl aza just outside the Capitol B uilding entrance, as seen in the screenshot

below. As individuals are climbing the wall, SULLIVAN can be heard saying, “You

guys are fucking savage. Let’s go!”

Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 9 of 1810

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:

Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 10 of 1811