johnearlesullivan/capitol · Datasets at Hugging Face

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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, SULLIV AN 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
officer s, “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.”
h. 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.” Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 11 of 1812

i. While at the window, a knocking noise is he ard off-screen . The camera then
pans to show more of the window and a broken pane can be seen that was not broken
on SULLIVAN’s approach to the window:

SULLIVAN can then be heard saying, “I broke it. My bad, my apologies. Well
they already broke a win dow, so, you know, I didn’t know I hit it that hard. No one
Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 12 of 1813
got that on camera.” SULLIVAN then exits the office.
j. At another point in the video, SULLIVAN joins a crowd trying to open doors
to another part of the U.S. Capitol which are guarded by law enfor cement officers ,
as seen in the screenshot below . SULLIVAN can be heard on the video telling other
individuals in the crowd, “there’s officers at the door.” Less than two minutes later,
while officers are still at the doors and as others yell to break th e glass windows in
them with various objects, SULLIVAN can be heard saying , “Hey guys, I have a
knife. I have a knife. Let me up.” SULLIVAN does not, however, ever make it to
the doors.

k. Eventually, individuals in the crowd outside the doors announce t hat the
officers are leaving and “giving us the building.” As the crowd begins to part so the
officers can leave, SULLIVAN can be heard saying, “Haul that motherfucker out
this bitch.”
l. At another time in the video, SULLIVAN is walking down a hallway in the
Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 13 of 1814
U.S. Capitol with a large group of people. SULLIVAN pans to a closed door and
can be heard saying, “Why don’t we go in there.” After someone hits against the
door, SULLIVAN can be heard saying, “That’s what I’m sayin’, break that shit.”
Further down t he 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 r ecording 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. ”

n. 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
Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 14 of 1815
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.
21. Subsequent to the events at the U.S. Capitol, SULLIVAN provided interviews to
various news outlets including CNN and ABC’s Good Morning America program. In the
interviews, SULLIVAN described the scene inside the Capitol Building on January 6, 2021.
22. On January 11, 2021, your affiant conducted a voluntary interview with SULLIVAN
at SULLIVAN’s residence. The interview was recorded. In the interview, SULLIVAN again
confirmed that he was in the U.S. Capitol, but denied having a knife. He also showed me the
ballistic vest and two gas masks he stated he had in Washing ton, D.C. Based on my review of the
video described above, the ballistic vest and one of the gas masks that SULLIVAN showed during
the interview on January 11, 2021, is the same seen in the video of SULLIVAN’s activities at the
U.S. Capitol on January 6, 2021.
23. At various times in his statements to law enforcement, to others inside the U.S.
Capitol that were recorded in his video, and to news outlets, SULLIVAN has claimed he was at the
U.S. Capitol only to document and report. I n addition, your affiant is aware that, at various times,
SULLIVAN has claimed to be a journalist. He has admitted, however, that he has no press
credentials and the investigation has not revealed any connection between SULLIVAN and any
journalistic organ izations.
CONCLUSIONS OF AFFIANT
24. Based on the foregoing, your affiant submits that there is probable cause to believe
that SULLIVAN violated:
a. 18 U.S.C. §§ 231(a)(3) & 2, which makes it a crime to commit or attempt to Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 15 of 1816
commit , any act to obstruct, impede, o r interfere with any fireman or law
enforcement officer lawfully engaged in the lawful performance of his official duties
incident to and during the commission of a civil disorder which in any way or degree
obstructs, delays, or adversely affects the perfo rmance of a ny federally protected
function;
b. 18 U.S.C. § 1752 (a), which makes it a crime to (1) knowingly enter or remain
in any restricted building or grounds without lawful authority to do; (2) knowingly,
and with intent to impede or disrupt the orderly c onduct of Government business or
official functions, engage in disorderly or disruptive conduct in, or within such
proximity to, any restricted building or grounds when, or so that, such conduct, in
fact, impedes or disrupts the orderly conduct of Governme nt business or official
functions; (3) knowingly, and with the intent to impede or disrupt the orderly
conduct of Government business or official functions, obstruct or impede ingress or
egress to or from any restricted building or grounds; or (4) knowingl y engage in any
act of physical violence against any person or property in any restricted building or
grounds; or attempts or conspires to do so. For purposes of Section 1752 of Title 18,
a restricted building includes a posted, cordoned off, or otherwise restricted area of
a building or grounds where the President or other person protected by the Secret
Service is or will be temporarily visiting; or any building or grounds so restricted in

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, SULLIV AN 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

officer s, “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.”

h. 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.” Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 11 of 1812

i. While at the window, a knocking noise is he ard off-screen . The camera then

pans to show more of the window and a broken pane can be seen that was not broken

on SULLIVAN’s approach to the window:

SULLIVAN can then be heard saying, “I broke it. My bad, my apologies. Well

they already broke a win dow, so, you know, I didn’t know I hit it that hard. No one

Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 12 of 1813

got that on camera.” SULLIVAN then exits the office.

j. At another point in the video, SULLIVAN joins a crowd trying to open doors

to another part of the U.S. Capitol which are guarded by law enfor cement officers ,

as seen in the screenshot below . SULLIVAN can be heard on the video telling other

individuals in the crowd, “there’s officers at the door.” Less than two minutes later,

while officers are still at the doors and as others yell to break th e glass windows in

them with various objects, SULLIVAN can be heard saying , “Hey guys, I have a

knife. I have a knife. Let me up.” SULLIVAN does not, however, ever make it to

the doors.

k. Eventually, individuals in the crowd outside the doors announce t hat the

officers are leaving and “giving us the building.” As the crowd begins to part so the

officers can leave, SULLIVAN can be heard saying, “Haul that motherfucker out

this bitch.”

l. At another time in the video, SULLIVAN is walking down a hallway in the

Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 13 of 1814

U.S. Capitol with a large group of people. SULLIVAN pans to a closed door and

can be heard saying, “Why don’t we go in there.” After someone hits against the

door, SULLIVAN can be heard saying, “That’s what I’m sayin’, break that shit.”

Further down t he 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 r ecording 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. ”

n. 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

Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 14 of 1815

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.

21. Subsequent to the events at the U.S. Capitol, SULLIVAN provided interviews to

various news outlets including CNN and ABC’s Good Morning America program. In the

interviews, SULLIVAN described the scene inside the Capitol Building on January 6, 2021.

22. On January 11, 2021, your affiant conducted a voluntary interview with SULLIVAN

at SULLIVAN’s residence. The interview was recorded. In the interview, SULLIVAN again

confirmed that he was in the U.S. Capitol, but denied having a knife. He also showed me the

ballistic vest and two gas masks he stated he had in Washing ton, D.C. Based on my review of the

video described above, the ballistic vest and one of the gas masks that SULLIVAN showed during

the interview on January 11, 2021, is the same seen in the video of SULLIVAN’s activities at the

U.S. Capitol on January 6, 2021.

23. At various times in his statements to law enforcement, to others inside the U.S.

Capitol that were recorded in his video, and to news outlets, SULLIVAN has claimed he was at the

U.S. Capitol only to document and report. I n addition, your affiant is aware that, at various times,

SULLIVAN has claimed to be a journalist. He has admitted, however, that he has no press

credentials and the investigation has not revealed any connection between SULLIVAN and any

journalistic organ izations.

CONCLUSIONS OF AFFIANT

24. Based on the foregoing, your affiant submits that there is probable cause to believe

that SULLIVAN violated:

a. 18 U.S.C. §§ 231(a)(3) & 2, which makes it a crime to commit or attempt to Case 1:21-cr-00078-EGS Document 1-1 Filed 01/13/21 Page 15 of 1816

commit , any act to obstruct, impede, o r interfere with any fireman or law

enforcement officer lawfully engaged in the lawful performance of his official duties

incident to and during the commission of a civil disorder which in any way or degree

obstructs, delays, or adversely affects the perfo rmance of a ny federally protected

function;

b. 18 U.S.C. § 1752 (a), which makes it a crime to (1) knowingly enter or remain

in any restricted building or grounds without lawful authority to do; (2) knowingly,

and with intent to impede or disrupt the orderly c onduct of Government business or

official functions, engage in disorderly or disruptive conduct in, or within such

proximity to, any restricted building or grounds when, or so that, such conduct, in

fact, impedes or disrupts the orderly conduct of Governme nt business or official

functions; (3) knowingly, and with the intent to impede or disrupt the orderly

conduct of Government business or official functions, obstruct or impede ingress or

egress to or from any restricted building or grounds; or (4) knowingl y engage in any

act of physical violence against any person or property in any restricted building or

grounds; or attempts or conspires to do so. For purposes of Section 1752 of Title 18,

a restricted building includes a posted, cordoned off, or otherwise restricted area of

a building or grounds where the President or other person protected by the Secret

Service is or will be temporarily visiting; or any building or grounds so restricted in