[Pete F.]

In November 2020, days after the election, Rhodes, the leader of the Oath Keepers,
began disseminating messages to other Oath Keepers members and affiliates
delegitimizing the results of the election and encouraging them to forcibly oppose the
lawful transfer of presidential power. See Indictment at ¶ 18(a) (telling those on the
“Leadership intel sharing secured” chat (hereafter “Leadership Intel Chat”), on November
5, that they “MUST refuse to accept Biden as a legitimate winner” and warning, “We aren’t
getting through this without a civil war. Too late for that. Prepare your mind, body,
spirit.”). Rhodes circulated and highlighted an eight-step plan, allegedly from a Serbian
contact to overthrow the government, which included: (i) peaceful protest, (ii) complete
civil disobedience, (iii) connecting with the police and organizing neighborhoods,
(iv) swarming the streets and confronting opponents, (v) gathering in the capitol and
discarding barricades, (vi) police joining with the protestors after initial violence,
(vii) storming parliament, and (viii) destroying the state media. Id.
Rhodes followed this plan in the months after the presidential election. At his
direction, certain members of his organization began preparing for operations inside of
Washington, D.C. Indictment at ¶ 21. He further organized deadly weapons to aid in the
conspiracy. Heavily armed QRF teams would be minutes away, just outside the Capitol,
ready to support those on the ground. Id. at ¶¶ 42-45. All contingency plans were
considered. The conspirators even sought to ferry lethal weapons from Virginia by boat
into the Capitol, if the bridges were closed. Id. at ¶ 52
In December 2020, Rhodes focused his co-conspirators on the Certification
proceeding of January 6, 2021. During a December 22 interview with a regional Oath
Keepers leader, Rhodes described January 6 as “a hard constitutional deadline” for
stopping the transfer of presidential power and warned that if President-Elect Biden were
to assume the presidency, “We will have to do a bloody, massively bloody revolution
against them.” Indictment at ¶ 30. On December 23, Rhodes published an open letter on the Oath Keepers website in which he noted that, on January 6, “tens of thousands of patriot
Americans, both veterans and non-veterans, will already be in Washington D.C., and many
of us will have our mission-critical gear stowed nearby just outside D.C.” Id. at ¶ 31.
Rhodes warned in the open letter that he and others may have to “take to arms in defense
of our God given liberty.” Id.
Rhodes and his co-conspirators created and administered Signal chats with titles
like “DC OP: Jan 6 21” and “OKFL Hangout” for coordinating their plans for January 6.
Indictment at ¶¶ 38-40. They utilized encrypted messaging applications for these planning
chats and stressed the need for operational security. See, e.g., id. at ¶ 27. The coconspirators discussed being prepared to use violence to stop the “usurpers” from taking
control and what weapons they would bring and plans for the QRF. Id. at ¶ 41-56, 58-60.
On December 25, Rhodes wrote to the OKFL Hangout Chat, “I think Congress will screw
him [President Trump] over. The only chance we/he has is if we scare the #^&#^&#^&#^& out of them
and convince them it will be torches and pitchforks time is they don’t do the right thing.
But I don’t think they will listen.” Id. at ¶ 34. Rhodes went on to say, “And he [President
Trump] needs to know that if he fails to act, then we will. He needs to understand that we
will have no choice.” On December 31, one week before the Capitol attack, Rhodes wrote
to the Leadership Intel Chat, “There is no standard political or legal way out of this.”
B. Vallejo and His Co-Conspirators Prepared an Armed QRF To Support the
Plot to Stop the Transfer of Power
Vallejo and his co-conspirators coordinated at least three regional QRF teams
stationed at a Comfort Inn in Arlington, Virginia, to support the co-conspirators’ plot and
the January 6 Capitol attack. Indictment at ¶¶ 45-49. The QRF teams guarded an arsenal
of firearms and related equipment and were prepared to speed those weapons into the hands
of co-conspirators on the ground in Washington, D.C., when directed by Rhodes or other
conspiracy leaders. Id. Vallejo served on one of those QRF teams.
On December 31, 2020, Vallejo’s Arizona QRF team member messaged Rhodes on
Signal that Vallejo and others were coming to Washington, D.C., and that “everyone has their own technical equipment and knows how to use it,” adding a “winky face” emoji.
Indictment at ¶ 44. Rhodes responded, “awesome!” Id. The Arizona QRF team member
also said that Vallejo and the group would have “rifles” and “man power.” Id.
On January 3, 2021, Rhodes informed a co-conspirator on Signal, “We WILL have
a QRF. this situation calls for it.” Indictment at ¶ 50. In the following days, coconspirators communicated and implemented plans to bring weapons to the Comfort Inn.
Id. at ¶¶ 58-59, 63-65, 68-69. Vallejo messaged co-conspirator and Florida team lead Kelly
Meggs, “Sir, Ed Vallejo of Arizona in Tenn. With cadre requesting coordinates to Allied
encampment outside DC boundaries to rendezvous. Please respond ASAP. For the
Republic.” On January 5, Vallejo messaged Meggs again, “Please text location so we will
know where to begin in the morning.” Meggs responded with the address of the Comfort
Inn Ballston, where the co-conspirators staged their multiple QRF teams.
The day before the attack on the Capitol, on January 5, Meggs and his Florida team
dropped off at least three luggage carts’ worth of gun boxes, rifle cases, and suitcases filled
with ammunition with their QRF team. A second QRF team from North Carolina consisted
of four men who kept their rifles ready to go in a vehicle parked in the hotel lot. Later,
Vallejo and other members of the Arizona QRF team wheeled in bags and large bins of
weapons, ammunition, and essential supplies to last 30 days—as seen in the QRF hotel
surveillance stills below, showing Vallejo on the left and his Arizona QRF team member
on the right: