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The contents of a recently discovered email reveals that key figures in the Casey Anthony murder trial, and HaLeigh Cummings kidnapping case, were secretly coordinating to fund the illegal activities of William (Cobra) Staubs, a Florida private investigator and bail bondsman that planned and directed the fake kidnapping of HaLeigh Cummings.

In the e-mail, Staubs refers to the HaLeigh Cummings case as a “gig” that he got from Rev. Richard Grund, a witness in the Casey Anthony murder case.

'Cobra' Staubs was arrested by the Putnam County Sheriff's Office in May of 2009 for felony false imprisonment after he arrested a 'patsy' while the group's camera-man filmed it for You Tube - in a ploy to convince the American public they had gotten the pedophile that kidnapped and murdered the two little girls.

The never before seen e-mail thread, which exposes several members of the secret group discussing the finances of the group, was thought to have been destroyed after the East Grand Forks Police Department seized, secretly searched, and permanently disabled the hard-drive of HaLeigh Cummings book author Timothy Charles Holmseth during a violent raid by armed officer wearing bullet proof vests.

On November 21, 2014, Timothy Holmseth, the Plaintiff in Timothy Charles Holmseth v. City of East Grand Forks et al. Case Number: 14-CV-2970 (DWF/LIB), United States District Court, District of Minnesota, filed a Motion for Continuance, asking for time to review more files.

Holmseth’s Motion is based upon the existence of the explosive e-mail, which was discovered by pure chance in November, 2014, and shows motive for the Defendant's actions against him.

The e-mail is directly linked to the City of EGF through its own Witness List.

Holmseth is requesting the Honorable Leo I. Brisbois accept the existence of the incriminating e-mail, which now sits on a disabled hard-drive, as evidence that the City of East Grand Forks conspired with criminal elements in the State of Florida to destroy evidence involving the murder of Caylee Anthony, and kidnapping of HaLeigh Cummings.

Officials with the City of EGF, including multiple defendants in Holmseth’s lawsuit, are presently at the center of a bank loan/money-laundering scandal known as ‘Boardwalk Enterprises’ – the scheme was exposed by an audit after Timothy Holmseth reported the activities of the City of EGF to the Minnesota State Auditor.

Minnesota Governor Mark Dayton is said to be monitoring the situation.

The Motion for Continuance has been served by e-mail to all Parties.

VIEW MOTION

VIEW SUPPLEMNETAL AFFIDAVIT

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IN THE UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

PLAINTIFF TIMOTHY CHARLES HOLMSETH’S
MOTION FOR CONTINUANCE

* * * * *

COMES NOW Plaintiff, Timothy Charles Holmseth, and respectfully moves the Court for a continuance of the pre-trial hearing, which is set for December 17, 2014.

Plaintiff’s has acquired new information and evidence that dramatically affects the entire case.

Plaintiff requests all Motions to Dismiss be continued until Plaintiff has ample time to review new evidence.

As grounds for this Motion, counsel submits the following Memorandum in Support:

* * * * *

MEMORANDUM IN SUPPORT

1. Plaintiff is a reporter, journalist, author, and publisher.

2. In July, 2014, Plaintiff filed this Deprivation of Rights action against law enforcement officers and public officials that targeted Plaintiff’s Constitutional rights.

3. Plaintiff became the target of Defendant(s) beginning in 2009, after Plaintiff began conducting interviews regarding the national profile cases of the kidnapped child HaLeigh Ann-Marie Cummings, and slain toddler Caylee Marie Anthony.

4. In December, 2012, Defendant City seized Plaintiff’s hard-drive, which contained his entire work product on the aforementioned cases; took the hard-drive to an unknown location; secretly searched it without an applicable warrant; and then permanently disabled the hard-drive before returning it.

5. Defendant John Doe also damaged Plaintiff’s computer processor whereby he/she un-hooked wires and caused internal plastic clips to snap. 

6. The malicious and illegal actions taken against Plaintiff by Defendants, which afforded them access to Plaintiff’s computer and hard-drive, were executed under the pretext of a fraudulent divorce court scheme that Plaintiff was a perpetrator of ‘domestic violence’ against an REDACTED from Florida named REDACTED REDACTED (whom he had never met).

NEW INFORMATION AND EVIDENCE OF A CRIME

7. In November, 2014, Plaintiff discovered new information contained in audio interviews Plaintiff conducted with kidnapping suspects between 2009 and 2012. The audio interviews were the same interviews contained on the hard-drive seized by Defendants.

8. Plaintiff located the interviews in November of 2014 by using an old computer processor that was given to Plaintiff by his parents. Plaintiff obtained the old computer processor while visiting Southern Minnesota for a wedding in September, 2014, and brought the old processor back to Northern Minnesota.

9. The acquisition of the old processor was not planned, rather, a spontaneous offer by Plaintiff’s father.

10. After returning to Northern Minnesota, Plaintiff searched two old hard-drives but did not locate the sought files. On November 16, 2014, while again sifting through files on a hard-drive, Plaintiff happened upon the ‘mother’ file of his HaLeigh Cummings/Caylee Anthony project, which was buried deep in the drive.

11. Plaintiff then began reviewing hours of audio interviews. 

12. Plaintiff needs several months to effectively review all the audio interviews that may potentially have a bearing on this case. 

13. As is set forth in Plaintiff’s First Amended Complaint, Plaintiff conducted hundreds of hours of recorded interviews with key figures in the national profile cases, which included family members, suspects, persons of interest, law enforcement officers, attorneys, advocates, and witnesses.

14. Plaintiff also obtained highly sensitive information in the form of emails and other recordings. Some of the recordings were mailed to Plaintiff that captured various suspects committing felonies (including REDACTED REDACTED).

15. Plaintiff obtained information regarding a (1) murder (2) kidnapping (3) drug trafficking, (4) child pornography (5) international human trafficking operation (6) fraud (7) money laundering (8) public corruption (9) police corruption.

16. REDACTED REDACTED, an REDACTED from REDACTED, Florida, was involved in all of the aforementioned criminal activity.

17. REDACTED REDACTED admitted to Plaintiff during an interview that REDACTED and a staff member were suspects of law enforcement in transporting the missing child HaLeigh Cummings across state lines.

18. In November, 2014, Plaintiff discovered information, that demonstrates Plaintiff’s hard-drive, which was seized, searched, and destroyed by Defendants, contains e-mail evidence that implicates REDACTED REDACTED for REDACTED criminal involvement regarding the:

• Kidnapping of HaLeigh Ann-Marie Cummings
• Cover-up of the murder of Caylee Marie Anthony
• Felony false imprisonment of Daniel Everett Snodgrass
• REDACTED Misconduct

19. On November 16, 2014, Plaintiff listened to an interview conducted in 2010 with Wayanne Kruger. During the interview, Wayanne Kruger and Plaintiff discussed the contents of an e-mail thread dated March 23, 2009 that Kruger had forwarded to Plaintiff. Both Kruger and Plaintiff have the e-mail up in front of them on their computer monitors as they discuss the contents.

20. The contents of the e-mail, in sum and substance, is the smoking gun that REDACTED REDACTED sought to keep hidden.

THE SECRET TRUTH ABOUT REDACTED REDACTED
EVIDENCE OF CRIMINAL ACTIVITY DESTROYED BY DEFENDANT CITY

21. The newly discovered evidence of an e-mail reveals the previously unknown fact that in March of 2009, REDACTED REDACTED was the REDACTED for William Eugene Staubs, Case Closed Inc.

22. William Staubs (a.k.a. Cobra) is a bail bondsman and licensed private investigator from Broward County, Florida. In 2009, William (Cobra) Staubs interjected himself into the HaLeigh Cummings kidnapping investigation and performed a high-media ‘search’ for the missing child.

23. In sum and substance, REDACTED REDACTED, a REDACTED, was using REDACTED REDACTED license and status as an REDACTED, to act as an ‘agent’ and/or ‘operative’ in a criminal operation involving the kidnapping of one child, to cover-up the murder of another child.

24. William Staubs originally claimed he was the private investigator working for Crystal Sheffield, HaLeigh’s Cummings’ mother.

25. In March of 2009, REDACTED REDACTED became the REDACTED REDACTED REDACTED REDACTED Crystal Sheffield. REDACTED appeared on national television in this capacity. REDACTED claimed to have a team of investigators working for REDACTED.

26. REDACTED REDACTED was strategically brought into the HaLeigh Cummings case by William Staubs (to officially REDACTED Staubs’ PI client Crystal Sheffield).

27. William Staubs told Plaintiff he brought REDACTED REDACTED into the case so he would have REDACTED subpoena power over any witness he wanted to lean on.

28. REDACTED REDACTED told Plaintiff REDACTED was privy to sensitive investigative information regarding the kidnapped child because REDACTED was the REDACTED for the missing child’s mother. REDACTED told Plaintiff REDACTED was “coordinating leads” with “Captain Dominic Piscitello” and “Detective Peggy Cone” at the Putnam County Sheriff’s Office.

29. The newly discovered proof of an email reveals REDACTED REDACTED was REDACTED BOTH William Staubs and Crystal Sheffield at the same time (but keeping the William Staubs REDACTED/REDACTED relationship secret).

30. The newly discovered proof of an email reveals that while REDACTED REDACTED was openly, publicly, and officially acting as the REDACTED for Crystal Sheffield, REDACTED (REDACTED REDACTED) was receiving REDACTED instruction and directives from REDACTED CLIENT/CO-CONSPIRATOR William Staubs.

31. In May of 2009 William Staubs was arrested by the Putnam County Sheriff’s Office on charges of felony false imprisonment stemming from illegal actions he took.

32. The newly discovered information shows William Staubs acted under REDACTED direction and criminal conspiracy with REDACTED REDACTED REDACTED.

CONSPIRACY TO CREATE REASONABLE DOUBT
THE TRUTH ABOUT THE DEATH OF CAYLEE MARIE ANTHONY AND THE STAGED KIDNAPPING OF HALEIGH ANN-MARIE CUMMINGS

INTRODUCTION

• Caylee Marie Anthony, Orlando, Florida, was reported missing on July 15, 2008, by her grandmother who had not seen the child for a month. Caylee’s skeletal remains were found on December 11, 2008, in a wooded area near the family home.

• HaLeigh Ann-Marie Cummings, 5, was reported missing from her Satsuma, Florida home on February 10, 2009. An Amber Alert was issued for HaLeigh and she has never been found. 

• Crystal Sheffield is the mother of the missing child HaLeigh Ann-Marie Cummings.

• William Staubs, Case Closed Inc., Weston, Florida, was the licensed private investigator working for Crystal Sheffield in regards to the case of her missing daughter. Staubs is also a licensed bail bondsman for a company called Lighting Strike Force.

• REDACTED REDACTED REDACTED, REDACTED REDACTED Office, REDACTED, Florida, was the REDACTED working REDACTED Crystal Sheffield.

• REDACTED REDACTED, convicted felon/bankrupt/fraudster, REDACTED, Florida, is the REDACTED of REDACTED REDACTED.

• Wayanne Kruger, author/sex victims advocate, Avondale, Arizona, was the official advocate and media coach for Crystal Sheffield. 

• Rev. Richard Grund, Supernatural Response Team, Windermere, Florida, was on the tentative Witness list in the Casey Anthony murder trial, and subsequently interjected himself into the HaLeigh Cummings kidnapping case through his relationship with William Staubs and Wayanne Kruger.

• Art Harris, tabloid blogger, is a former CNN correspondent and reporter for the Nancy Grace Show.

• Jeremiah Regan, drifter, interjected himself into the HaLeigh Cummings kidnapping case to set up a money-making facility called the HaLeigh Bug Center.

• John Regan, father of Jeremiah Regan, is a clergy impersonator, sexual predator/pedophile that interjected himself into the HaLeigh Cummings case and claimed to be an agent of the FBI and CIA.

CRIMINAL CONSPIRACY TO CONCEAL TRUE FACTS AND CIRCUMSTANCES SURROUNDING THE MURDER OF CAYLEE MARIE ANTHONY

• Plaintiff’s journalistic investigation and interviews resulted in Plaintiff assimilating statements, admissions, confessions, dates, times, and circumstances into a fact-pattern that revealed the true facts and circumstances surrounding the unsolved death/murder of Caylee Marie Anthony, and unsolved kidnapping of HaLeigh Ann-Marie Cummings.

• Prima Facie evidence exists that shows multiple actors including REDACTED REDACTED REDACTED, REDACTED REDACTED, William Staubs, Rev. Richard Grund, Wayanne Kruger, John Regan, Jeremiah Regan, and Art Harris conspired to:

• Create reasonable doubt regarding the identity of the person(s) responsible for the death/murder of Caylee Marie Anthony, 2, Orlando, Florida, by way of;

• Staging the kidnapping of HaLeigh Ann-Marie Cummings, 5, Satsuma, Florida, and creating the false appearance the child was abducted and murdered by a local child molester roving the area.

FACT PATTERN

• Caylee Marie Anthony’s remains were discovered on December 11, 2008.

• HaLeigh Ann-Marie Cummings was reported missing from her home in Satsuma, Florida on February 10, 2009.

• During interviews between Plaintiff and REDACTED REDACTED REDACTED, conducted in May of 2009, REDACTED REDACTED discussed a meeting between himself, REDACTED REDACTED REDACTED (REDACTED wife), and William Staubs, which revealed the following: 

• The aforementioned meeting occurred on a date that fell AFTER William Staubs had returned from Satsuma, Florida, but Staubs was ‘going back up there’

• REDACTED REDACTED REDACTED would now be assisting William Staubs in his ventures involving the missing child HaLeigh Cummings

• William Staubs would provide REDACTED REDACTED rough numbers of how much money he would need REDACTED REDACTED to secure to fund the venture

CHILI’S RESTAURANT MEETING
CONSPIRACY TO CREATE REASONABLE DOUBT
HALEIGH ‘MIRRORS’ CAYLEE

• On a date before March 20, 2009 (believed to be March 19, 2009) William Staubs, REDACTED REDACTED, Art Harris, Donald Knop, Crystal Sheffield, Jeremiah Regan, Matthew Staubs, Donna Wagoner, and Jerri Greene met at the Chili’s restaurant in Palatka, Florida.

• See Exhibitive Photo A

• At the Chili’s meeting, the group discussed their illegal plan for William Staubs (a licensed bail bondsman) to travel to the home of Daniel Everett Snodgrass, Satsuma, Florida, an accused child molester that was free on bond, and revoke his bond.

• REDACTED REDACTED REDACTED discussed the Chili’s meeting with Plaintiff during recorded journalistic interviews. REDACTED openly stated that during the Chili’s meeting REDACTED provided William Staubs legal advice and information regarding the tentative bond revocation of Daniel Snodgrass.

• REDACTED REDACTED told Plaintiff REDACTED met with William Staubs immediately after the bond revocation of Daniel Snodgrass. REDACTED gleefully stated she sat in William Staubs’ vehicle with him and viewed footage of the violent event on a lap-top computer and congratulated him.

• Plaintiff has in his possession, multiple documents regarding Daniel Snodgrass, which were originally faxed to William Staubs by the REDACTED REDACTED of REDACTED REDACTED.

THE FIRST COAST NEWS INTERVIEW

• On a date between March 11, 2009, and March 20, 2009, William Staubs was interviewed by news reporter Jessica Clark, First Coast News, Florida. William Staubs was wearing a ‘wire’ during his conversations with Jessica Clark. William Staubs subsequently sent copies of the recordings to Plaintiff. During William Staubs’ interview with Jessica Clark the following was said/established:

• William Staubs told Jessica Clark he had been sent to Satsuma, Florida, to search for HaLeigh Cummings at the request of a pastor from Orlando named Richard Grund.

• William Staubs told Jessica Clark his bills were being paid by a reformed drug dealer from Miami.

• William Staubs asserted he was:

• Sent into the case by Rev. Richard Grund
• To act as the PI for Crystal Sheffield
• While being financed by a drug dealer from Miami

RICHARD GRUND

• Rev. Richard Grund is the father of Jesse Grund. Jesse Grund is the former fiancé of Casey Anthony. In March, 2009, Casey Anthony was in the custody of the State of Florida facing first degree murder charges of her two year-old daughter, Caylee Marie Anthony.

• Plaintiff interviewed and communicated with Richard Grund multiple times beginning in 2009. Richard Grund told Plaintiff:

• There was a plot to frame his son Jesse Grund for the murder of Caylee Anthony

• Casey Anthony unsuccessfully attempted to lure his son Jesse Grund into a shower to obtain pubic hair and/or semen to plant on the dead body of Caylee Anthony

• Casey Anthony attempted to lure his son Jesse Grund to the location of her vehicle and trick him into touching the trunk (where the lifeless body of Caylee Anthony is believed to have been for a period of time)

• The Anthony family hacked Richard Grund’s computer and stole photographs, etc.

• There was an ongoing conspiracy and multiple continued attempts being made to obtain DNA to plant on Caylee Anthony’s body that would implicate Grund

• Caylee Anthony was the biological child of Casey Anthony’s brother, Lee Anthony

• Richard Grund operates a paranormal service called the Supernatural Response Team, which specializes in casting out demons through exorcisms, etc.

• The Anthony family home was possessed by demons

• On one occasion, when Richard Grund was in the home of the Anthony’s, items began to fly off the shelf on their own. He said the demons were letting him know the power they had in that house

• Richard Grund was once a worshipper of Satan

• Richard Grund once had an encounter with a fallen Watcher 

• Casey Anthony’s body was possessed by an ancient god called “Moloch” that demanded the sacrifice of babies

• Casey Anthony’s body was/is taking on the physical form of “Moloch” (literally he said)

• Cindy Anthony was the most evil person Richard Grund ever met

• Casey Anthony was deadly afraid that Caylee Anthony would become like Casey’s mother, Cindy Anthony

• Caylee Anthony, 2, was overtly sexual (according to Richard Grund) because she ‘flirted’ with men (had five pair of sunglasses and was ‘becoming’ Casey Anthony and Cindy Anthony)

• During the First Coast News interview William Staubs told Jessica Clark:

• Daniel Snodgrass was a person of interest in HaLeigh Cummings’ kidnapping because he was charged with sexual battery against a child under twelve

• Daniel Snodgrass’ ankle bracelet monitor didn’t always work; so the fact that he had been cleared by law enforcement couldn’t be trusted

• Daniel Snodgrass was believed to have been crossing the county line [emphasis added]

• William Staubs was investigating Daniel Snodgrass

FELONY FALSE IMPRISONMENT
THE BOND REVOCATION OF DANIEL EVERETT SNODGRASS

‘MIRRORING’ THE CAYLEE ANTHONY DISAPPEARANCE WITH A STAGED KIDNAPPING OF HALEIGH CUMMINGS

• On March 20, 2009, William Staubs revoked the bond of Daniel Snodgrass in Satsuma, Florida. In doing so, he violently slammed the handcuffed man down onto the ground face first. Art Harris, tabloid blogger (formerly of CNN) accompanied Staubs and filmed the entire event. Harris subsequently published it on You Tube.

• Information obtained during Plaintiff’s journalistic investigation shows the Daniel Snodgrass bond revocation was a strategically planned media event intended to create the false appearance for the American public that Daniel Snodgrass was the pedophile/murderer that kidnapped HaLeigh Ann-Marie Cummings.

• The expanded intent of the Daniel Snodgrass bond revocation media stunt hoax was to create the false appearance that Daniel Snodgrass might have also murdered Caylee Marie Anthony, whose body had been discovered in December of 2008, 75 miles south in Orlando.

• The staged kidnapping of HaLeigh Cummings was carefully planned and executed to create  REASONABLE DOUBT for any possible criminal charges that may be brought against those responsible (e.g. Rev. Richard Grund) for the death of Caylee Anthony – 75 miles south in Orlando. 

• Evidence shows Caylee Marie Anthony likely died during an exorcism and/or satanic ritual based upon: 

• The expressed suspicions of Cindy Anthony contained in the files of the Orange County Prosecutor’s Office, as reported by the National Enquirer in 2009

• Statements by Wayanne Kruger to Plaintiff that Rev. Richard Grund told her HaLeigh Cummings was born “without a soul” because she has Turner’s syndrome and no reproductive ability

• Statements by Wayanne Kruger to Plaintiff that she feared Rev. Grund may have killed HaLeigh Cummings in one of his “frickin exorcisms”

• Rev. Grund’s consistent expressions of fear that his family’s DNA (pubic hair, semen) was going to be ‘planted’ on Caylee Anthony’s body

• Rev. Grund’s assertion the slain child’s mother was physically taking on the form of the ancient satanic god “Moloch” which demanded the sacrifice of babies

• After the bond revocation and physical assault on Daniel Snodgrass by William Staubs, Snodgrass went to the Putnam County Sheriff’s Office and demanded criminal charges be filed against Staubs

• On dates following William Staubs’ arrest, REDACTED REDACTED REDACTED made a flurry of telephone calls to authorities on behalf of Staubs, including telephone calls to State’s Attorney Joseph Boatwright, officers at the Putnam County Sheriff’s Office, and newspapers

• The newly discovered information by Plaintiff now shows that REDACTED REDACTED made these calls as William Staubs’ REDACTED

• REDACTED REDACTED advised William Staubs that REDACTED had spoken to authorities, and that if he left Putnam County he would not be arrested

• William Staubs refused to leave Putnam County and remained active in the HaLeigh Cummings case

• On May 20, 2009, William Staubs was arrested by the Putnam County Sheriff’s Office and charged with felony false imprisonment based upon his actions regarding Daniel Snodgrass on March 20, 2009

THE NEWLY DISCOVERED EVIDENCE OF AN E-MAIL IN THE POSSESSION OF
TIMOTHY CHARLES HOLMSETH

• In November, 2014, Plaintiff discovered back-up files he saved on a hard-drive. While reviewing audio interviews, Plaintiff discovered key information about REDACTED REDACTED, William Staubs, Richard Grund, and Wayanne Kruger that had been lost in the malicious illegal destruction of Plaintiff’s hard-drive by Defendant City.

THE E-MAIL

• On March 20, 2009, William Staubs executed the Daniel Snodgrass bond revocation media hoax after the Chili’s meeting with REDACTED REDACTED, Art Harris, and others.

• On March 23, 2009, Richard Grund emailed REDACTED REDACTED REDACTED and told REDACTED he had a following of supporters on the Web because of his family’s involvement with the Casey Anthony murder case. He told REDACTED REDACTED he believed he could encourage donations from his followers to help support William Staubs and keep him going.

• In his email, Richard Grund told REDACTED REDACTED he had been threatened by the Anthony family and it would not be a good idea to accept donations directly through his ministry. He asked REDACTED REDACTED if REDACTED could set up a “client account” [emphasis added] for the funds. He asked REDACTED to think about it and advised he would call REDACTED the next day to discuss it.

• After receiving the aforementioned email from Richard Grund, REDACTED REDACTED then forwarded the email to William Staubs and said, “Bill, is this your guy? Give me authority to talk to him and tell me what you want me to do with him”.

• William Staubs replied to REDACTED REDACTED and said, “Yes he is REDACTED – he got us this gig”.

• The fact that REDACTED REDACTED asked William Staubs to give REDACTED “authority” to speak to Richard Grund regarding a “client account” demonstrates REDACTED REDACTED was Williams Staubs’ REDACTED.

• REDACTED REDACTED is a REDACTED REDACTED and only licensed to practice REDACTED REDACTED. REDACTED REDACTED REDACTED Kathy Staubs, the ex-wife of William Staubs during the Staubs’ REDACTED, which creates further conflict of interest issues.

• The fact pattern and timeline shows that REDACTED REDACTED was the REDACTED for BOTH William Staubs and Crystal Sheffield at the same time.

• The e-mail shows that in March, 2009, REDACTED REDACTED was receiving instructions and directives from William Staubs.

• REDACTED REDACTED was William Staubs’ REDACTED BEFORE REDACTED was Crystal Sheffield’s REDACTED, and strategically proceeded covertly as an agent of William Staubs, amidst William Staubs’ felonious activity, for which he was arrested, while presenting REDACTED to the American public as the REDACTED for the mother of a missing child. 

• Defendant City attempted to destroy this evidence.

Respectfully submitted,

PARTIES CONTACT INFO:

Attorney(s) for City of East Grand Forks
Jon K. Iverson
Iverson Reuvers Condon
9321 Ensign Avenue South
Bloomington, MN 55438
T: 952.548.7204
F: 952.548.7210
jon@irc-law.com

Nathan Midolo
Iverson Reuvers Condon
9321 Ensign Avenue South
Bloomington, MN 55438
T: 952.548.7200
F: 952.548.7210
nathan@irc-law.com

Attorney(s)s for Polk County, Minnesota
Tom Carlson
Carlson & Associates Ltd.
1052 Centerville Circle
Vadnais Heights, MN 55127
T: 651-287-8640
F: 651-287-8659
www.carlsonassoc.com

Nigel H. Mendez
Carlson & Associates Ltd.
1052 Centerville Circle
Vadnais Heights, MN 55127
T: 651-287-8640
F: 651-287-8659
nmendez@carlsonassoc.com

Attorney for Ronald I. Galstad
Daniel J. Dunn
Maring Williams Law Office PC
1220 Main Avenue STE 105
Fargo, ND 58103
T: 701-241-4141
F: 701-235-2268
ddunn@maringlaw.com

Attorney for Michael LaCoursiere
Alethea M. Huyser
Minnesota Attorney's General's Office
445 Minnesota Street, #1100
St. Paul, MN 55101-2128
T: 651-757-1243
F: 651-282-5832
alethea.huyser@ag.state.mn.us

Attorney for Jeannette Ringuette
Craig R. Baune
United States Attorney's Office
300 S 4th Street STE 600
Mineapolis, MN 66415
T: 612-644-5600
F: 618-644-5788
craig.baune@usdoj.gov

IN THE UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

1. On November 22, 2014, I, Timothy Charles Holmseth (hereby referred to as Plaintiff) submitted a Motion for Continuance. The Motion contained newly discovered evidence that Plaintiff’s disabled hard-drive, which was tampered with by Defendant City, contained e-mails authored by REDACTED REDACTED that incriminated REDACTED REDACTED.

2. The aforementioned e-mail evidence exposes multiple relationships that REDACTED REDACTED sought to conceal in REDACTED effort to avoid REDACTED discipline and/or criminal prosecution.  

3. The significance of the now exposed relationships is profound; nearly beyond comprehension; because it involves evidence of REDACTED REDACTED’s involvement in the planning of felonious activity. The felonious activity is connected to a murder and kidnapping in Florida.

4. The significance of the newly discovered evidence is compounded by the fact that the information Plaintiff possesses, remained unknown to the public in these two national profile cases, and never came come out for five and a half years; all the while Plaintiff has been a target for rights violations that included death threats, extortion, and blackmail.

5. The new information changes the entire dynamic of Plaintiff’s First Amended Complaint. It provides a clear motive for Defendant City’s unconstitutional search, and subsequent malicious destruction of Plaintiff’s hard-drive.

6. Defendant City’s entire campaign against Plaintiff; and alleged justification for the malicious acts against Plaintiff; was based upon Defendant City’s involvement with a fraudulent domestic violence order fabricated in the state of Florida in the divorce court division by REDACTED REDACTED.

7. Plaintiff will present herein, prima facie evidence, derived primarily from recorded journalistic interviews Plaintiff conducted with REDACTED REDACTED and REDACTED REDACTED on May 23 and May 26, 2009; as well as their colleagues William Staubs and Wayanne Kruger, which shows Plaintiff possesses critical information regarding the aforementioned serious crimes. 

8. Plaintiff began conducting interviews with REDACTED REDACTED, REDACTED REDACTED, and William Staubs in May of 2009. At that time the aforementioned individuals were all very nervous and paranoid of each other.

9. REDACTED REDACTED admitted to Plaintiff REDACTED had been questioned by law enforcement per their suspicion REDACTED had transported the missing child HaLeigh Cummings across state lines in a vehicle, along with a REDACTED named Jeremiah Regan.  

10. There is a Putnam County Sheriff’s Office report that reveals Lindsey Croslin reported to the Sheriff’s Office that she heard William (Cobra) Staubs tell her husband, Hank Croslin Jr. that they had HaLeigh Cummings hidden in Georgia.

11. REDACTED REDACTED and William Staubs were under investigation by the Putnam County Sheriff’s Office and State’s Attorney for planning the felony false imprisonment of a man named Daniel Snodgrass.

12. At the time Plaintiff was interviewing the aforementioned persons, they were extremely paranoid of each other because law enforcement was closing in on them.

13. At the time Plaintiff was interviewing the aforementioned persons, REDACTED REDACTED was in contact with State’s Attorney Joseph Boatwright – discussing the tentative legal actions of law enforcement regarding the felony false imprisonment of Daniel Snodgrass.

14. REDACTED REDACTED and REDACTED REDACTED, REDACTED and REDACTED, have known William Staubs for many years.

15. William Staubs told Plaintiff that REDACTED REDACTED, a REDACTED REDACTED REDACTED, was the REDACTED REDACTED his ex-wife, Cathy Staubs, during his divorce from Cathy Staubs.

16. Cathy Staubs and REDACTED REDACTED had an REDACTED-REDACTED relationship that was REDACTED to the benefit of Cathy Staubs. 

17. William Staubs’ girl friend in 2009 was Paula Andrews. Paula Andrews told Plaintiff that REDACTED REDACTED was her REDACTED.

18. This fact pattern shows REDACTED REDACTED is the REDACTED of many individuals that are married, intimately involved with each other, and/or involved in business dealings together.

19. REDACTED REDACTED is a convicted felon. REDACTED REDACTED, REDACTED REDACTED REDACTED, was aware of REDACTED REDACTED’s federal fraud conviction when REDACTED REDACTED him.

20. Upon documents, information, and belief, Plaintiff believes Florida Power and Lights presently has a legal claim/action/lien against REDACTED and REDACTED REDACTED, REDACTED REDACTED REDACTED REDACTED, REDACTED REDACTED, Florida, in an amount exceeding $20,000 for unpaid electricity.

21. William Staubs told Plaintiff during an interview that REDACTED REDACTED hooked up REDACTED power to the neighbor’s electricity and stole power from the neighbor.

22. REDACTED REDACTED told Plaintiff that William Staubs assisted him with an issue that involved electricity.

23. “I’m not going to say anything disparaging about Bill. I mean, I called the guy up and go hey I got an electrical problem over here - hey man let me come over there we’ll get it done. He comes over, I mean, he’s dug in the yard, climbed under the house with me and everything else, you know.” -REDACTED REDACTED / May 23, 2009 / interview with Timothy Charles Holmseth

24. Plaintiff believes REDACTED REDACTED was sending a message to William Staubs, via Plaintiff, that if he (William Staubs) told law enforcement about the stolen electricity, REDACTED (REDACTED REDACTED) would implicate William Staubs in the felony theft by claiming William Staubs helped him do it.

25. Plaintiff interviewed Wayanne Kruger.

26. Wayanne Kruger told Plaintiff that infants were being sold through the United States Embassy via an operation involving REDACTED REDACTED and REDACTED REDACTED.

27. Wayanne Kruger told Plaintiff the operation used a dossier through the church and fake pastor - pedophile priest named John Regan.

28. Wayanne Kruger told Plaintiff how the trafficking of infants was accomplished. She explained that young parents were coerced and threatened into giving their baby up for adoption. The process involved diabolical deception, false medical paperwork to move children younger than the age of two through the United States Embassy, un-certified home studies, as well as strong-arm tactics and threats of rape allegations and prison time to force the biological father into capitulation and giving up their parental rights.

29. Wayanne Kruger said REDACTED REDACTED was able to access targets for REDACTED human trafficking endeavors because REDACTED  “worked for the social service department doing volunteer work – REDACTED was working for the social service department in the home study field.”

30. Caylee Marie Anthony, 2, and HaLeigh Ann-Marie Cummings, 5, both disappeared mysteriously in the State of Florida.

31. The e-mail evidence submitted to the Court by Plaintiff on November 22, 2014, contained content and substance that undeniably tied the two child cases together through:

• REDACTED REDACTED, REDACTED
• William Staubs, private investigator/bail bondsman
• Rev. Richard Grund, online minister/demon hunter/exorcism specialist
• Wayanne Kruger, author/child sex victim’s advocate

32. The following is a timeline regarding the two cases.

• June 16, 2008 - Caylee Marie Anthony, 2, Orlando, Florida, was last seen alive

• July 15, 2008 – Caylee is reported missing by her grandmother, Cindy Anthony

• September 5, 2008 – Rev. Richard Grund tells detectives in Florida there is a sinister plot to frame his son for the murder of Caylee Anthony using planted DNA evidence such as semen and pubic hair that will be planted on the child’s body

• December 11, 2009 – Caylee’s skeletal remains are found in a wooded area not far from the Anthony home

• February 10, 2009 - Nationally televised memorial held in Orlando for Caylee Marie Anthony

• February 10, 2009 – Smaller memorial for Caylee Anthony held at a park by Rev. Richard Grund. In attendance are William Staubs and Wayanne Kruger.

• February 10, 2009 – HaLeigh Ann-Marie Cummings, 5, Satsuma, Florida, is reported missing - law enforcement officially state HaLeigh’s disappearance was “domestically involved” and “no stranger abduction”

• February 15, 2009, Fox News reports Chad Eugene Reynolds, 25, is missing. Chad Reynolds, a convicted sex offender, was last seen on February 1, 2009. He was reported missing February 4, 2009. Reynolds was originally sentenced in Putnam County (the same county HaLeigh Cummings disappeared from) for burglary and molestation of a child under the age of 12

• AFFIANT’S NOTE: In June, 2014, your Affiant published “In Re: Caylee Anthony (the shocking truth explained)” wherein your Affiant sets forth evidence that indicates Chad Eugene Reynolds may have been murdered in the trailer home of Ronald Cummings and was the original patsy for the staged abduction of HaLeigh Cummings, which was done to mirror the disappearance of Caylee Anthony and create reasonable doubt for those responsible for Caylee Anthony’s death

33. On May 23, 2009, Plaintiff interviewed REDACTED REDACTED and REDACTED REDACTED. The following excerpts are from those interviews.

“My REDACTED wanted him to go back up there and help I sat on the back porch with my REDACTED and Paula and Bill formed a game plan – REDACTED said this is what I need – you want to help me Bill? I need your help. He said I’ll go up there. You give me a list and I’ll get it done for you. REDACTED gave him a list. I said ‘Bill before you leave you need to stop by my office because I need to put in my mind here what its going to cost for you to be up there – I know you can’t live for free – I said but I need you to go home tonight and put on a piece of paper what it costs for you to maintain and existence at least that way I know this what you got to have every week’ – and he came to my office broke out a pad of paper and wrote it down this is what it takes to maintain an existence and if you can throw me anything else obviously – I’m doing – you know I need to make some money – I can’t just maintain an existence – I said maybe one week we’ll just maintain an existence maybe the next week they’ll be some extra money for me to throw at you – no problem – that’s how it went – I got the paper that he sat down and wrote in his handwriting on my desk – right now – so then he turned around and I’m not working for you you son-of-a-bitch and all this and I’m saying to myself what’s wrong?”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

"We were doing this - all of this - for him and for all of us to work on this case together - we're friends...”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

“Him and Mr. Grund were talking about doing a movie. And my REDACTED even heard Bill and Mr. Grund talking about that on speaker phone when Bill was sitting in my REDACTED office. Not a big secret. And so if he doesn’t have any food for a movie or food for reporters he goes away. And just comes back to Ft. Lauderdale and mows his lawn with all of us.”
     -REDACTED REDACTED / May 26, 2009 / Interview with Timothy Charles Holmseth

34. The following quote is consistent with the new evidence Plaintiff submitted to the United States District Court on November 22, 2014. The e-mail evidence that has emerged reveals that Rev. Richard Grund, REDACTED REDACTED, and William Staubs were attempting to raise funds to keep William Staubs going in what William Staubs called a “gig”.

“Him and Mr. Grund were talking about doing a movie. And my REDACTED even heard Bill and Mr. Grund talking about that on speaker phone when Bill was sitting in my REDACTED office. Not a big secret. And so if he doesn’t have any food for a movie or food for reporters he goes away. And just comes back to Ft. Lauderdale and mow his lawn with all of us.”
     -REDACTED REDACTED / May 26, 2009 / Interview with Timothy Charles Holmseth

35. The following quote is consistent with the new evidence that shows REDACTED REDACTED was William Staubs’ REDACTED in March of 2009. In the quote, REDACTED states REDACTED obtained permission from REDACTED REDACTED’S (plural), to have everything filmed. REDACTED REDACTED’S were Crystal Sheffield and William Staubs.  

“Art Harris was down in Satsuma and was filming a lot of us a lot of these things - and he wanted to you know, write - I don't know if he was going to be doing a story on this or what, but he was in Satsuma riding around with Bill - he would share meals with us - sit at the dinner table - occasionally we went out to dinner or lunch and - or he would film - even our conversations some times - I approved that with my REDACTED’S (plural) [emphasis added] and that was fine.”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

1. PRE-REVOCATION MEETING AND PLANNING

“I was sitting there on Art Harris' camera - we were all at like a Chili's - we discussed it multiple times…”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

“Art Harris was down in Satsuma and was filming a lot of us a lot of these things - and he wanted to you know, write - I don't know if he was going to be doing a story on this or what, but he was in Satsuma riding around with Bill - he would share meals with us - sit at the dinner table - occasionally we went out to dinner or lunch and - or he would film - even our conversations some times - I approved that with my REDACTED’S and that was fine, and we were sitting at Chili's one night - I remember the long table with all of us - I have a picture with all of us sitting there - like fifteen of us and we’re all sitting there at Chili's and Bill was hot to trot and he - I remember one seat needed to be on the end - Bill was without a chair - the host or whatever was going to put a chair - he didn't even - he couldn't even sit down - he was so - he told 'I don't even want a chair' - what are you going to stand up and eat - I'm not eating - he was drinking those caffeine things that you get at like a 7-11 - that's all he did - wouldn't eat - he was going bonkers and this was prior to him having that breakdown on the set - on the CNN set in front of everybody - even in front of the CNN - I'm glad they had the discretion enough not to put the camera on him because it was a horrible incident for him - personal incident actually - and so he was all hot to trot that night and this -  and I've got him - and I've got the bond papers - he was all excited - the papers from - and he claimed that he had the authorization and this and I'm like - I'm a REDACTED REDACTED, I don't know what authorization he needs, I've never read bail bondsman statutes or anything and I said well Bill hang on be careful I said you know because everything we do in this case is high media so you need to make sure that you're doing this right - I said how do you know that you’re allowed to go violate this guy or revoke his bond or whatever, and because, I'm forget the term he had an ‘appointment’ or some shit like that it was some you know word - and I said well give me the papers and he said I got the papers right here and he shoved the papers down to all of us and I said well Bill it doesn't sound right to me that you're allowed to go and just pick someone up for no reason - well you can then you would have to return the bond and that would be seven thousand dollars so otherwise you would have to do something that would constitute a revocation and I said well [Daniel Snodgrass] hung around the center with the kids and he goes you could testify to that and I said well I wasn't there but yah that's what my people told me I said but that gives you the right to revoke his bond? Yeah because he's on all these terms of release that he's not allowed to be around children and so I said well as all I'm saying Bill is you make sure you're right because you, I remember that case where you had gotten sued before for something like this - a false imprisonment thing - and I reminded him of that - and I knew the opposing REDACTED and everything - and you know he was being - I said you don't want to get into any trouble I said don't get sued or some shit - I said and remember that who was it Dog or someone on TV had gotten in trouble for revoking someone or something improper - doing something - I said you make sure you know what you're doing - he was putting me down - Art was sitting there - we were having this big argument - you don't know anything you're a REDACTED REDACTED - you don't know the statute I went to classes its chapter dih dih dih dih - you know Bill - and I said okay - and then my REDACTED piped up, I remember I was mad at her and I she said 'no REDACTED I think he's right and I used to be involved with a PI firm or something and I know that you can revoke on - I looked at my REDACTED I was mad at her I said unless you Jerri have called the Florida legislature...”

"And Art is sitting there typing everything we’re saying on his lap-top...”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

1. POST-REVOCATION MEETING AND DISCUSSION BETWEEN REDACTED REDACTED AND WILLIAM STAUBS

"I remember Bill calling me going 'look to your left mama' - you know that sort of thing - and I looked and he said you're sitting at the light and you're next to a blue car - something like that you know funny like I'm spying on you type thing -  and he said look to your left and actually he was sitting in a parking lot so I got in the other lane and he goes ‘come here I got something to show you’ and so I pulled over and got in the parking lot and he showed me the video and I said 'oh my God oh my God' you got that guy oh my God' tell me how it won't down he said no they made me release him - I said what? Why? And he said and even before it went down I was sitting there on Art Harris' camara we were all at like a Chili's - we discussed it multiple times he wanted Snodgrass bad because of the charges he had pending and because of this - that Snodgrass guy's ex-wife had told him all of these horrible horrible stories - well when I went in to tell DCF or law enforcement...”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

“I drove upon him during the day at that parking lot and he told me about it and I was like 'oh my God' wow you know -  I'm excited that he's taken down the bad guy type of thing and I said ‘oh wow’ and he said ‘I even did it in front of the cops all legit’ and I said 'well that's good Bill you've taken this guy off the streets - good for you - you did this town a service - good for you Bill - and you want to see the tape? Sure. So he showed me the whole tape. It was great. The cops - I could see the cops standing right there on the tape. And then that was that. But then he was like ‘but they made me let him go’ and I was like ‘what that is bull-shit’ - what is going on? Yep they got cold feet they told me let him go…”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

“I said ‘what the heck are you doing making him - this guy has come by our center been around little kids…”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

"I called the police that day when [Daniel Snodgrass] rode by...”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

“I got on the phone – stopped my REDACTED – and got on the phone and called every police officer I could get in touch with - and the filing attorney at the State attorney’s office saying woah woah woah I thought Bill had permission - and he thought he had permission - and this was you know not something improperly done that he yah know- and let him yah know - can you just yah know - stop this its ridiculous - and consider that you're talking to a sexual predator from the bond company. I did that - then later on when there was issues when the cops were mad at him - all throughout - I would call all of them, including Major Bowling, including the Department of Licensing saying 'please please please he's trying to do things right'”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

"[Law enforcement] believed Bill was committing crimes. That's what they believed. They had gotten multiple citizen complaints. At one point the police called me and said they were getting more complaints about Bill - but they call him Cobra - then, then they were getting tips on HaLeigh. It became a problem and I had to consistently talk to Bill about cooling it down. Don't do this. Don't do that. Things with you know with serious stuff to the police. And I was consistently trying to keep him you know doing the right thing. Because he could get in trouble for this. For things that they knew he was doing. And not that I want to say what they are and I won't. I hope that one day he's playing with my kids again that's why."
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

“Yep they got cold feet they told me let him go and I said - you can even call the insurance agent and I want you to and I said ‘I will - I'll call right now’ he gave me the number - looked it up on the lap-top in his car - said Continental and said look Continental is on my list of insurance companies that I'm allowed to deal with or something like that I don't know and so I was allowed so here the guy's number call the guy - I said ‘what the heck are you doing making him - this guy has come by our center been around little kids’ he said ‘REDACTED REDACTED do you know the difference between an appearance bond and a performance bond?’ I said ‘no’ - well this man was on an appearance bond do you have the paperwork in front of you he was on an appearance bond that means the only way a bail bondsman can revoke him is pursuant to the terms of the bail bondsman contract...”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

Timothy Holmseth: Did you have a contract with Mr. Staubs?

REDACTED REDACTED: A contract? Not - no. It was like between Crystal (Sheffield) and her mom (Marie Griffis). You know we had a meeting. And he kept on asking me to try to get him funds and of course I wanted to, and it spared him to be paid. But my REDACTED was paying for his hotel rooms. I was paying for any meals - ya know - usually we'd meet together for meals - and share notes this that and the other.

“And I went in and I said listen - I want to meet with the entire Task Force with my REDACTED, and I did that. And I got information that they can only tell to a parent to a missing child case - they can't tell to an average citizen going up…”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

"I'd love to tell you the exact scenario that he created. It is inappropriate. I think it is a disparaging story to him. I don't care to do that. I want to go on and do my REDACTED for this REDACTED”
     -REDACTED REDACTED / May 23, 2009 / Interview with Timothy Charles Holmseth

Further More Your Affiant Sayeth Not

Timothy Charles Holmseth

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