10 ul 2 3B 14 45 16 v 18 1s 20 24 SELECT COMMITTEE TO INVESTIGATE THE JANUARY 6TH ATTACK ON THE U.S. CAPITOL, U.S, HOUSE OF REPRESENTATIVES, WASHINGTON, D.C. DEPOSITION OF: DAVID SCOTT KUNTZ Monday, April 11, 2022 Washington, D.C. The deposition in the above matter was held via Webex, commencing at 10:00 am,10 ul 2 3B 14 45 16 Appearances: For the SELECT COMMITTEE TO INVESTIGATE THE JANUARY 6TH ATTACK ON THE U.S. CAPITOL: TR st associate NVEsTIGaTIve couNseL TR CHF CLERK (| vesticative counseL For THE WITNESS: CHRIS WIEST10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 WR We are on the record at 10:10 a.m. Good morning. This is a deposition of David Scott Kuntz conducted by the House Select Committee to Investigate the January 6th Attack on the United States Capitol pursuant to House Resolution 503. Mr. Kuntz, please state your full name and spell your last name for the record. The Witness. David Scott Kuntz, K-u-n-t-. HE thankyou very much. Would you please raise your right hand so that the court reporter can swear you in. The Reporter. Do you solemnly declare and affirm under the penalty of perjury that the testimony you are about to give will be the truth, the whole truth, and nothing but the truth? The Witness. Ido. HE Thank you very much This will be a staff-led deposition and members, of course, may choose to also ask questions, although | don't see any with us at the time. My name is ME. I'm an investigative counsel with the select committee. And on Webex with me isIE also an investigative counsel. He is also remote. So if you see his nice-looking face pop up on the screen, he might have a question and I'll recognize him. And for this deposition, we will follow the House deposition rules that we provided to your counsel previously. Under the House deposition rules, you are permitted to have an attorney present. Mr. Kuntz, at this time, I'm going to ask your counsel to please state his name for the record,10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 Mr. Wiest. Chris Wiest, representing Mr. Kuntz in this matter. HR Thank you, mr. wiest. Under the House deposition rules, neither committee members nor staff may discuss the substance of testimony you provide today unless the committee approves release. You and your attorney will have an opportunity to review the transcript. But before we begin, I'd like to describe a few ground rules. There is an official reporter transcribing the record of this deposition. The reporter also is joining us by Webex. So please wait until each question is completed before you begin your response, and we will try to wait until your response is complete before we ask our next question. It's just really hard over virtual for the reporters to hear two — or to understand two voices talking at the same time, So I'lldo my best and please do your best as well. Thank you. And the reporter cannot record nonverbal responses such as shaking your head, so it is important that you answer each question with an audible verbal response. And for the benefit of the reporter and the record, there may be times where I spell a name or a word that we are using, of | ask that you do the same. ‘And we ask that you provide complete answers, based on your best recollection. If the question is not clear, which certainly might happen, just please ask me for clarification. And if you don't know the answer, please simply say so. And just in terms of logistics, if you need a break for comfort or to talk to Mr. Beast about anything, just let us know. We'll go, you know, off camera. We'll go mute so that you can have whatever time that you need, And today, we're going to be showing you some exhibits as we move along, and those will be displayed on the screen in front of you. And when we refer you toa document, you can take some time to familiarize yourself with it before we discuss it.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 ‘And just to test out the system here, I'm going to bring up exhibit 1. All right. Do you recognize exhibit 1, Mr. Kuntz? The Witness. Yes. HEE |'*'s the subpoena and the accompanying documents that the select committee issued to you. ‘The Witness. Yes, sir. TR) Thank you. So during this deposition, you may only refuse to answer a question ~ sorry. | am also doing the exhibits, so there might be a little bit of a pause as | bring them up and take them down. But during this deposition, you may only refuse to answer a question to preserve a privilege recognized by the select committee. If you refuse to answer a question based on a privilege, staff may either proceed with the deposition or seek a ruling from the chairman on the objection. If the chairman overrules such an objection, you are required to answer the question, And at this time, | would ask Mr. Wiest to please place on the record any objections or to make any opening remarks he may have. Mr. Wiest. | suspect we may get into objections and privilege issues, you know, either — hopefully not anything attorney-client, but possibly Fifth Amendment. We'll deal with those as those come up. We do not intend to raise a general objection. ME | 2ppreciate it. Thank you. So want to remind you, Mr. Kuntz, as we do with all witnesses, that it is unlawful to deliberately provide false information to Congress. Since this deposition is under oath, providing false information could result in criminal penalties, to include for perjury and/or providing false statements. Do you understand?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 The Witness. Yes, sir. HE Thank you very much. Q Mr. Kuntz? A > 2 >. Q EXAMINATION —_ So we'll just start off with some background questions. How old are you, Fifty-one ‘And where do you currently live? In Jeffersonville, Indiana. How long have you lived there? Twenty years, maybe. So not your hometown, but sort of your hometown now? Yeah. Okay. Thank you. ‘And what is your current occupation? A Qa > ( ) I'm not working at this time. What did you do before you were not working? | was a welder in a shipyard Were you ever a law enforcement official? Yes, sir. What type? Sheriff's deputy. Was that also in Indiana? Yes, sir. The same town?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 A No. Itwasin Harrison County. Q Did you say Carrison, C-a-r-r? A No, Harrison, H-a. Yes, sir. Q Thank you, Were you ever in the military? A No, sir. Q Appreciate it. Thank you. Are you aware of a group known as the Three Percenters? A Yes, sir Q How did you become aware of them? A Afew friends. Q_— Through some friends. Do you consider yourself a member of any Three Percenter group? A Yes. QQ Which one? A Grey Ghost Partisan. Just that one or others? No. We're affiliated with Central Kentucky. Qa A Q What is Central Kentucky? A They're a Three Percenter group, too. Q Okay. So the group name is Central Kentucky Three Percenters? A Yes,sir. Sorry about that. Q Oh, no, that's okay. | was just making sure | didn't miss something, Okay. So what drew you to want to be part of the Three Percenters? A Just—-I don't know. It's been so long since I've done it. | mean, it's — we get together, you know, good hangouts in the mountains. You know, we do some10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 shooting, you know, target pra , camping, you know, do a little rappelling, stuff like that. | mean, it's, you know -- it's general stuff and it's just ~ I've been stuck with it ever since. You know, good people. You know, it's just a fun time, You know, we all get, together and just have a good time. Q__Soit sounds like a bit of - there's some social aspect to it, but what is the ideology or the idea of the group? Like, what brings everybody together to be a Three Percenter? A Everybody has their own -- their own opinion about it, of what it’s for, | guess. So what does it mean to you, Mr. Kuntz? Is it what now? DED) Sorry. What does a Three Percenter mean to you? A Asa, | guess, defender of people's rights and the Constitution. Q And how does a Three Percenter do that? A Protect people's rights whenever there's ~ like if a ~ like a store or something wants us to come down and protect it during riots or something like that, we go down there and we protect that store, that property. _Just people in general, that during the riots that people aren't like beat up or, you know, or serious injuries or anything like that. Q And how do you provide —I'm sorry. Go ahead. A No, that'sit. Q Okay. And how do you provide that protection? A We just show up to make sure everybody's, you know, protected, that nothing bad is happening to anybody.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 When you say you just show up, do you show up in a group? A Yes. Q Okay. And do you bring anything with you? A Itjust depends on the situation that's ~ that's at hand. If there's a lot of ~ if — like if the rioters have weapons or something like that, then yes, we bring our gear with us. Q And when you say gear, can you describe that for me? A Like our ~-bring our plate carriers, sidearm, our rifles. Just, | guess, normal gear, you know, for different situations. Sorry. HR that's okay. MIMI, do you have a follow-up? WM sYess, | have a couple of follow-ups. Thank you, Il —_ Q So INNNNNNNNE mentioned if the rioters have weapons you would bring your gear as well. How do you know if the rioters are going to have weapons before you attend an event? A Well, we see them like on TV or social media and stuff first before ~ before we appear. You know, we want to see how -- what they have and how they're acting. QQ Sowhat inc tions would tell you it was necessary to bring equipment, including sidearms, as you mentioned? A Like BLM or something like downtown Louisville or something like is the only way | can describe it is we know that they have security details with them fully armed as well. So we already know this. So we show up for self-defense, but do not engage them in any hostile manners or anything. a Q Can ask where you get your intel from?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 10 A Like, social media type stuff. Friends will post it or they'll call and say, Hey, you know, this is going on right now, let's go. We're going to go down there fora little ~ you know, and bring your gear. It's just-- it's -- |don't know. It's just --I don't know. It's really kind of hard to describe. You just see it or somebody calls you or something like that. It's -- because they don't -- mean, they don't hide it. They show it. a Q Sol know you just mentioned going down for self-defense, but obviously, you're going down to where the armed groups might be, so you're actively seeking out those situations that you mentioned to protect others. But to me, that seems like something that law enforcement would be tasked with. Why do Three Percenter groups or the Three Percenter group you were involved with want to do that when law enforcement, at least in the traditional view, would be doing that? A Weare ~ we don't go down there to engage them in any ~ we are down ~we stand more-- okay. Like, for instance, a year and a half, last summer maybe, we protected a gas station. You know, we protected the property of a gas station, a pawn shop, a couple pawn shops, really, and some hotels in a general area, just to make sure that they wasn't burned down, destroyed or any of that type stuff. We don't really engage these people, you know, at any point. We have ~ we did one time downtown Louisville, just ~ you know, just, | don’t know, shake them up a little bit or something, let them know, Hey, you know, there are other people here. Q — Sowhen you say "shake them up," what do you mean by that? A Just to show them that there's other, like, groups that don't want the violence and don't want buildings or property destroyed and all that. So we marched in10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 1 with them to make sure that there was no trouble. And there was no trouble. | mean, there was some words or stuff like that, but | think it was a good thing. Nothing happened in Louisville after that, you know. A lot of ~it mainly has been peaceful-type stuff and it's great. That's what we like to see. Q Certainly. So before these kind of events where you'd go down to protect a gas station or a shop, would you communicate your intentions to law enforcement or have any other kind of coordination with law enforcement? A They knew we were there, yes. Q And how would they typically know that? A don't know all the details of it, but | know that somebody was in contact with one of the higher-ups down there, letting them know every time that we were there. And every time that we were done and we left, we would -- that person would inform them, Now, what they talked about or anything, | don't know. Q Was that something that had been done for many events or was it more specifically centered around the summer of 2020, the law enforcement liaison? A You're talking about like other things going on? Q Yes. A Yeah. We would generally inform any of the, like, sheriff's departments or city police that we were -- we were going to be there in the events. And they okayed and they were with it, never gave us any trouble. We never gave them any trouble. So they were okay with it. Always informed when we went in. Q And if there was a perceived need to bring weapons or other equipment, would you tell the law enforcement that as well? A Yes, sir. They were well aware. Q As faras you knew, there was never any objections lodged by law10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 2 enforcement to those activities? A No, sir, never. Q And during the events themselves, did you ever interact with law enforcement? A Yes. Q How so? A In like your ~ not general like -- like your ~ like the big city, like Louisville, we didn't interact with them. They kind of stayed to theirself, we stayed to ourself, but they knew where we was at all times. The smaller towns, some of the officers, you know, would come in, you know, and say, Hey, how you all doing or something like that. It wasn't nothing like a coordinated thing or something, like, | guess. Q Sure. That makes sense. A Itwas just a Hi, Hey, how you guys doing, you know. That's basically it. Q_ Thatis helpful. One more question. It's alittle broader ~ before I turn it back to [IS- How did you view the Three Percenters' relationship with law enforcement, or your role compared to law enforcement as you attended these events? Mr. Wiest, He asked how did you view your role vis-a-vis law enforcement? Like, how did you interact with them? What was your role versus theirs? The Witness. Oh, you talking about like ~ like | said, you know, the crowds, you know, just to make sure that people kept between both sides. If — like if somebody was attacked and, | don't know, if law enforcement wasn't close enough to react, we could maybe step in and help, like separate the parties, you know, just to keep the peace between —- between everybody. Because everybody has their own, you know, views of everything. So we don't10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 13 judge on their view or our views or anything like that. We just want to make sure that everything is peaceful and everybody go about their day. That's what it's all about. HE Got it. Thankyou. I'llturn it back to [NE but looking forward to more questions hay = _! Q _ Soyou keep mentioning the "we," which | find interesting, How is the group organized? So how ~ let's start with the Grey Ghost Three Percenters. Was there a formal organization? ‘A What do you mean a formal organization? Just like ~ it's ust a group of guys that --in a group that hang out. Q How did you join the group? A [think I met - don't quote me on this. I'm not really exactly positive, but | think it was during an event downtown Louisville that | met with the ~ | guess he's the CO, | guess. Idon't call him CO. | just call hima friend. Q_— Sothere is a leader of this group, someone who calls ~ does he represent himself as the CO? A Yes. Q And what is his name? A It's Mike Cole. Q — Canyou spell that? A It's Mike, M-i-k-e, C-o-le. Q Thank you. So was there any formal application that you had to do to join the group after you met with Mr. Cole? A No, sir.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 14 Q — Nodues? A No. No, there was nothing like that. Q Did you have a weekly meeting or was it just whenever you all wanted to get together? A It's whenever everybody wants to get together, but we try to do it like once ‘a month, just, you know, get together and camp out in the woods or, you know, just normal guy stuff, I guess. Q_ Did you ever do any trainings together? A Yeah. We shot and -- you know, shoot and stuff like that. We got targets and, you know, stuff like that. We don't do any type of, | don't know, aggressive-type training. | mean, we might set up some, you know, thing to walk through or something like that, but it's not no aggressive-type stuff. Q__Sol'm going to show you my lack of law enforcement experience. Can you explain the difference between the trainings that you did and what you were saying were more serious? A Normal law enforcement. | was more a Reserve than ~ | didn't go to the Academy, okay. Iwas more of a Reserve. It was your basic kind of like stuff we do now. It's just your normal -- your target practice with your right hand and switch to your, left. It's like move to this to shoot and then move to this area to shoot and then switch up type stuff, some hand-to-hand stuff, baton-training, pepper spray-training and taser-training stuff. Q Understood. So were you training in military formations at all? A On-- through law enforcement? Q_ Sorry. With the Grey Ghost group. A I don't know if you'd call it military. | mean, like if we was going to go down10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 15, the street or something like that we would — you know, we'd walk, | don't know, kind of, staggered. | don't know if you call that military stuff or not, We just staggered up on each side of the road. Q But in your words and as | take it, you weren't doing sort of advanced, more tactical training when you met up. It was more target practice, some hand-to-hand stuff, basic walking? A Notinourgroup. You know, we don't do any of that hand-to-hand type stuff. That was just law enforcement side. Q Gotit. A With, you know, the self-defense class, I think, is what they referred it to. But on our side, no, we don't do stuff like that. We just ~ Q Okay, A We get together and camp out in the woods and some target practice, or go. rappel or something like that. That's - that's about it Q Appreciate it. And how did you communicate about these, you know, getting together? Did you use messaging apps? A Like Telegram or something, they got like a little site. Q Yes. A Get together on ~- our training on the first of the month or, Hey, we're going to do some rappelling this weekend, you all want to come down. Just like that. Q__Sol'm going to pull up exhibit 3, which is something you provided to us. Give me one second, Okay. So this ~ can you all see exhibit 3? A Yes, sir. Q__ It looks like a chat labeled Kentucky Horses and Asses with 75 members.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 16 This was a screenshot that you provided to us. Is this the Telegram chat that you used with the Grey Ghost group? A Yes, sir Q_— Great. So'm just going to ~- I'll pause here and take a little sidetrack for a second, and we do this with all witnesses, but we just have to check for the record to make ~ you know, ask you some questions about document production. Did you search through your personal email for any responsive documents to the subpoena? A Yes. Thank you. And you provided the screenshot of the chat. Did you try to log back into chat messages? A What does he mean? Q_ Sorry. Did you try to access your chat messages for messages that are responsive? A Yeah. For this? Q Yeah. Just in general, for all your documents. A Yes. Q Okay. So in terms of this particular screenshot then, was this just something you had on your phone, the screenshot, and you could not access the full chat? ‘A No, sir. I went back through the phone all the way back. It took me like ~ like 2 hours to get to that point. And that's as far as back as it will let me go. Q Okay. Soll the messages before that were deleted? Mr. Wiest, Do you know the answer to that? —10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 7 Q You could not access the messages before this? A No. Itwon't go back any further, That's it. That's as far as back as it would let me go. Q Understood. Did you try to log onto Telegram on a computer, like a personal computer? A No, just —just my phone. | just used my phone. Q Okay. Gs. Wiest, we might talk after this about whether that's possible. | know it can be sometimes. I'm not sure in this case it is possible. I'm not representing that you were not responsive to the subpoena, but we can talk after if you'd like, Is that okay? Mr. Wiest. I think we can. | think he has undertaken an exhaustive effort to produce documents in part of my instruction, and | don't think there's anything further that can be accessed, but we can have a further conversation if you'd like. MEE Yes. And !'d like to reiterate, | am not suggesting that you did not do an exhaustive search and that you produced what you had found, but technology can be sometimes complicated, so we'll touch base after, But thank you very much, Mr. Kuntz. The Witness. Yes, sir. a Q Besides Telegram, did you use any other chat apps with the Grey Ghost group? ‘A With Grey Ghost? No, | don't think so. Q No Signal? No. No, I don't think so.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 18 Q Parler? A I don't think so. Q Okay. Zello? A Zello? Mr. Wiest. No, I think he said that you know of. I don't -- can you repeat that question? _ Q Yes. Did you use, or do you know if you used any other chat-messaging apps like with other members of the Grey Ghost group? ‘A Honestly, Idon't think so. I don't really remember, but I don't think so. Q —Lappreciate it. Did you have a social — was there like a social media page for the Grey Ghost group? A No, just that, what's up there. | mean, wasn't no -- you talking about like our own site type thing or — Q Yeah. A No. Q__ Like a Facebook page or whatever. No. 1~no. Q Okay. Thankyou. You mentioned a Mr. Cole before. Can you tell mea little bit more about him. Does he live in Indiana? A No, sir. He lives in Kentucky. Q And do you know what he does for a living? A I think he's retired. Q__Didhe ever, like, explain to you how he started the Grey Ghost group? A I'mnot ~ I'm not really -- I'm not really sure 100 percent how he come up10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 19 with that name or whatever, you know, because we were all together, and then I think it was just a name that he come up with for us, you know, because we were always hanging together. Q Oh, so when you mentioned him being the CO, the name Grey Ghost hadn't been established yet when you joined? A No, | don't think so. Q_— Sowhy did you call Mike the CO then? A {didn't call him — Q Not you, sorry. Why did he call himself the CO before there was the name of the Grey Ghost? A Hewas the creator of the Grey Ghost. So, | mean, it's - we ~I mean, we look at it as, you know, he's the creator of it, so he would be the CO. That's the best | can describe it. Q_—Sowhen you met Mr. Cole, did he call himself the CO of, like, a Three Percenter group or did that come later? A Later. Q_ Sothat came later? | think that came much later. Q —Doyou remember when that was, about when? A No, sir, | do not, Q Totallyfine. Thank you. Does the Grey Ghost group ~ | know you mentioned the Central Kentucky Three Percenters, but does Grey Ghost ever associate with Oath Keepers? A We--canItakeasec? Imean— Q Yes. Do you want a couple minutes to talk to Mr. Wiest?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 20 A Hangon. Yes, sir. Ws et's go for a quick recess at 10:40, You should mute and turn off your video, though. [Recess.] He'll go back on the record, 10:42. a Q__ I think | had asked you before whether the Grey Ghost Patriot Rangers had associated with the Oath Keepers? A Yes,sir. Sorry about that. | didn't really understand that. But no, we are not affiliated or associated with them in any way. Q_— lappreciate it. Just let me know if you don't understand a question. I'll rephrase, Did the Grey Ghost Patriot Rangers ever work with the Oath Keepers? A Yes, we have one time. Q When was that? ‘A Itwas during an event downtown Louisville when like the gas station, the pawn shop, taking care of those properties. We were asked to help with manpower to protect those properties. And other than that, that's the only time we've ever dealt with them. That's the only ~ Q How did the Oath Keepers ask you? A That I'm not aware of, on how they communicate or anything. | was just asked to come down. Q Who asked you? A [really don't remember. Q But do you remember whether an Oath Keeper asked you directly or an Oath10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 21 Keeper asked Mr. Cole to ask the whole group? A They didn't ask me directly, no. Q_ So they asked Mr. Cole? A {don't know if it was ~ if it was Cole or not. I don't know, | really don't. Q That's okay. In terms of what happened at Louisville, do you remember the Cath Keepers sort of -I don't know a better way to put it ~ like, kicking out certain groups who were trying to provide defense? _ Like, the Oath Keepers, did they ever try to tell certain groups to leave who had come to provide defense? A I don't think so. Q So you didn't see them telling other groups like yourself, other Three Percenters or other people who had come to help defend buildings, to get out of Louisville? A No, sir. Q_ Thank you, A Yes, sir. Q__ And do you personally affiliate with the Oath Keepers? A Dol personally? Q Yes. A No, sir, Ido not, Q How about the Proud Boys? A No, sir, don't. Have you heard of a group called the First Amendment Praetorian? =) No, I don't think so. Q Okay. Do you associate with other militias or groups? Sorry, let's just say other groups.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 2 A Like talk to them or whatever? Q Do you consider yourself to be, you know, a member in other groups? A No, not member. I mean, we have conversations, you know, with other groups on social media type stuff. It ain't — we're not like a combined, you know, like group. It's not nothing like that. Which groups do you have conversations with? Just -- let's see, Like the Central Kentucky AF. DO What does AAF stand for? A American Action Force | think is how they put it. Those are basically the only people | really talk to unless they're like on a -- like a chat or something. | mean, it ~- | don't know how ~ I really don't know how to explain it, It's not it's Just on a social plat - you know, where everybody talks. I don't really know the names of, you know, if they have groups or, you know, because a lot of people, | guess, represent themselves as Three Percenters and, you know, and then not be affiliated with the group, | guess the best way to ~ to describe it. So that's the best way | know how to describe it, man. | don't know any other way to say it. Q understand, In terms of your interactions with the American Action Force, do you know where they're located? A Theyare Indiana. Indiana -- And -- oh, go ahead. A No, it's just Indiana, Kentucky, | think is how they do it. Q And they are also a Three Percenter group? A Yes, sir QI forgot to ask this, but Central Kentucky is also a Three Percenter, correct? A Yes, sir10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 23 Q_ Sothe three, those three groups, when you say you talk to them mostly on social media or most often on social media, do you all share like a specific chat or is it just general conversation? A Like they'll have ~I don't know. _| guess like Kentucky Horses and Asses, they ~ they have their own little like talk thing for their group or something, and then — but Central, they're just ~ they use our platforms, | guess, that Telegram Kentucky Horses and Asses. Q__ Have you heard of something called Sons of Liberty Reaper Crew? A I've heard of Sons of Liberty. Now, as far as who they are or what they're with or nothing, no, | do not know them personally, Q So do you know who Ellen Hanon is? A No,Idonot. Not that | am aware of I don't - the name doesn't recall me. Q_—That'sfine. I'll pull up exhibit 2 on page 4. | think Mr. Wiest represented to me that you lost access to social media, so we have some of your old posts here and a Ms. Hanon on November 10th responded to your post where you say, "Everyone will know my name one day, | am the reaper," with what looks to be a Meme called Sons of Liberty established 1765, Reaper Crew. What is -- A That's just like a sticker that somebody made up. You know how you can go in and bring up different type things. It'snot a --it's nota group. It's just a ~ how do you say this? You can go in and there will be, like, different types of reapers in there and different sayings and stuff like that. Q_ it'saMeme? A Yeah. It's not a ~ it's not a group or nothing like that. That's not what that is.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 24 Q_—Sowhat is the significance of the reaper? A It's just think it’s cool, | mean. Q oa lot of people talk together about the reaper? So it seems like Ms. Hanon said "Reaper Crew." | mean, is there like a group of people online who all associate around the reaper that you know of? A No, not that | know of. Q. Great. Just one more question, then I'm going to give it over tA Would you consider Grey Ghost Kentucky Patriot Rangers to be a militia? A Yeah. Q And why would you say that they are a militia? A That's what my CO calls it. That's the only way I can describe it. So what does a militia mean to you? >. Just ~- just like people who guard the Constitution and believe in people's rights. Q Does being a militia have anything to do with the training that you do? A Idon't ~I don't really know. Like | said, we just get together and, you know, just have fun together and just do different things. | mean, that's the way I look atit, I don't look at it as as a militia or whatever. | just see a bunch of guys get together and just have fun on the weekends. Q Right. Buta lot of guys get together a lot of times, and | would hope that most Americans want to defend constitutional rights and protect people, but not every group of people hanging out would call themselves a militia. So I'm wondering why you would call the Gray Ghost a militia A don't call them that. Now, my CO says he's militia, | don't ~-I've never heard him say we're militia, not that I'm aware of. | mean, he always says he's militia.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 25, So, I mean, | don't know. We --I don't —I really don't know why he callsit that. But that's just him, I'm not saying I've never said it, you know, kidding around or something like that, but — you know, to appease him or whatever, but | just don't ~I just don't look at it like that, | really don't. Q Do you think it has to do with, you know, target practice and the other small shooting trainings that you all do? A Dowe consider that? We just d whenever we show up, just something todo, You know, if the wives are there or if kids come, you know, we let them shoot at targets and, you know, just —~ Q Right, but do you think Mr. Cole uses the term "militia," in part, because of those types of trainings? A don't ~ I don't believe so, but I know he's been in other groups. So maybe that's how ~ why he does — says that, but I really don't know. Q appreciate it. I'm sorry, one second. A You're okay. QI lost my voice over the weekend. That was fun. Do the Gray Ghost Patriot Rangers, do they -- | know | asked about the Oath Keepers. Have they ever worked with Proud Boys? A don't think so. I never, I mean, really have worked with them. I mean, no, not as far as ~ are you talking about helping them or — Q The same way you described working together with the Oath Keepers on something, so ~ A No. I mean, we've been in the same areas that they've been in. We've never actually worked together or anything like that.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 26 Q__ You didn't communicate ahead of time when you were in the same area as them, did you? A Whats it? Q__ Did you communicate with the Proud Boys ahead of time before you were in the same area as them? A No. Q —Andaside from -- I never did. Q _I'msorry, what? A I never have. Q That's ll you can answer for. Thank you. And in terms of other militias, you talked about the socialization with Central Kentucky and the AAF. Did the Grey Ghost militia work with them on anything? A Just I mean, we were together like downtown. | think they might have had one or two guys there, you know, just to help out, but that was only for like a night. But it's not nothing --| mean, if we ask them for help, Hey, can you come help us with this rally or something or, you know, but other than that, no, it's nothing. so. Q Understood. Thank you. Any other militias that Grey Ghost Patriot Rangers have worked with? A Not that I'm aware of, other than them. | really don't know. I don't think Q Okay. Thank you very much. — eS o<, —_10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 7 Q__thad a couple of questions to follow up on those points. And | noticed when III asked you if you were affiliated with the Oath Keepers and the Proud Boys, you gave a pretty quick response both times. | wonder is there a reason why you aren't associated with the Oath Keepers? ‘A Just | have no desire, you know, to be affiliated with them. | mean, I'm happy with the guys that I'm around, you know. _ It's ~ it's I have no desire to be with Oath Keepers, never have. Q What do you see as the difference between your organization and the Oath Keepers? ‘A From what | understand, the Oath Keepers get paid to do events or to protect, like, buildings and stuff like that. They get paid for that stuff. We don't. We just ~ | look at us as just a bunch of guys that hang out to have fun on the weekend, one weekend a month. Q_— Gott. And what about the Proud Boys? A I mean, | know they're -- honestly, | don't know much about them other than | know they show up to a lot of protests and whatever, just stufflsee. | don't know any personally. Q Do you see any ideological differences between your Three Percenter group and the Oath Keepers and the Proud Boys? ‘A From what I seen is the PBs are totally different than what we are. They go in, | guess, to fight or whatever. The Oath Keepers are for guarding and protecting buildings and stuff like that, events that they're paid, ‘And we're just, you know, if we're asked to help type. You know, we'll -~ we'll go down and help them, you know, if they ask or somebody asks us to come down, you know, but that's the difference I see, is just help, just to help.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 28 Q And when you are involved in similar events with these other groups, did you see any shared mission or shared vision that you all had as to why you were there? A No, | don't think so. It's just ~ the only thing | can think of is that we're there just to keep the peace. Other than that, | mean, that's about the only thing | can say. You know, we I don't know. That's about the best I could say is just to make sure the peace was kept and that's it. | mean, isa good thing. So everybody wants peace. Q That'shelpful. Thank you BE 82k too), HE Thank you, a Q__ Sol'm going to move us to talking about specific events, starting in November 2020 and moving on through January 2021. For now, we're going to be in November of 2020. Did you believe that the 2020 election was stolen? Mr. Wiest. I'm sorry. Did you ask whether he believes that today or whether he believed it ~ HH tthe time. at the time. The Witness. At that time, | really don't know what | thought, you know, about that. | really still don't to this day, | mean, really. ' Q Did you start participating in any rallies about stopping the steal or supporting President Trump after the election? A No. Are you talking about being at a rally? Q Yes.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 29 AI mean, we was ~ we was there for the rallies in D.C. Yeah, we were there. Q _Sowhy did you attend those -- we'll start with the November 14th rally, Why did you attend that rally? A TohearTrump speak. And then, | think there was some other speakers there or something that day. I'm not really 100 percent with who was all there, who spoke or any of that. Q And we're talking about the November 14, 2020, rally. | don't believe President Trump —- well, actually, | can represent to you President Trump did not speak at that rally. Was it your expectation that he would have spoken? A I would say probably yes. I mean, I'm not 100 percent sure, but | think | thought that he was supposed to speak then. Q Do you remember where you learned about the event? A On social media, | think, is where we - where I seen it at. Q Do you remember if it was a group called Women for America First? A Idon't remember. Q_— That's okay. If you don’t remember, you don't remember. Does the name Ali Alexander ring a bell? A {don't think so. Q — Doyou remember seeing anything that Alex Jones posted about November. lath? A No, | don't remember that. Q Do you have any sort of recollection about what you were seeing on social media that told you about November 14th? A Honestly, no, | don't, Q Okay.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 30 A {really don't. Q That's completely fine. And you mentioned that "we" went. So did you go with other people to the November 14th rally? A Yeah, | went with a friend. Q_Isthis friend part of the ~ sorry, go ahead, A Sorry. He drove. 2 Was he a member of the Grey Ghost Patriot militia? > Yes. Q And what is his name? A Dan Wire. Q_ Dan Wire. Anyone else go with you guys? A don't think so in November. Was it November? I can't remember if it was November or December. My--afriend went with me. She'sagirl. She went with us. Chrissie | think is her name, | think. Q_ So Chrissie either went with you in November or December, you just can't remember? A Yeah. Q_— That's okay. Did you coordinate with anyone else besides Dan Wire about going to D.C. in November? A No. Q Did you meet up with anybody there? A No. No,!don't think so, I don't think, I'm not sure what all happened on that date. It's been so long. | don't want to say yes, no, this is what or really ~ honestly, | do not know. Q_— That's okay. So the questions are to the best of your recollection. And if10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 31 you can't remember, you can't remember. That's okay. A apologize. Q Thank you. Did you expect any sort of violence to occur in November 2020 at the rally? A No, sir. Q__I'mgoing to share exhibit 2, page 5, if Ido this correctly. So this page has two Facebook posts by you. The first is November 10th, and the second is also on November 10th So it looks like you were posting from Florida with someone named Angry Viking Can you all see that? A Yeah. Q Okay. And somebody named Deep Talker replies to your post, saying: “Let me know when you need some real pipe hitting boys." And youreply: "Deep Talker, Hell yeah, it's about time to act, buddy." What were you referring to there? A Honestly, Idon't know. It was probably just making fun of him or something. It's -~I mean, there wasn't nothing, you know ~- on my side, there was nothing meant to be bad about it. | was probably making fun of him or just getting him to leave me alone-type post. Q Well, you're talking -- your post is about -- well, Mr. Wire says: "D.C. this weekend, you in?" You say, "Dan Wire, you driving?" So it seems Deep Talker might be referring to the weekend in Washington, D.C. Did you at all expect there to be violence that weekend? A No. Q — Sodo you remember what you did in November in D.C.?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 32 A I mean, the only thing | can think of would be in the crowds, you know, just seeing everything. | can't remember if they had a stage or something, a stage set up or something or | don't know. I really don't know. Just in the crowd with everybody just walking around Q But you weren't there to provide security or anything, right? A No, | don't think so. Q__ Did you talk to any other members of Three Percenter groups while you were in D.C? A don't ~ honestly, | don't know who we talked to or who was there. It was Just chaos, | guess, around with all the people, and I can't remember that kind of stuff. Q_— That's okay. | want to show you exhibit 18, which is a screenshot that you provided to us. It looks like someone took a picture of you and then posted, A Antifa did. Q_ Soit'santifa, That's them? A Yeah. Q_—"Chucklefuck on the right in picture 1 had the pliers and flashed the sign after Federal police told them to F off." Do you know what this person is talking about? A Ihave no idea, I guess he's -- what -- me, I guess, is that what he's calling Chucklefuck? Mr. Wiest. Do you know? The Witness. No, | don't know. I don't know who he's talking about, a Q__ Did you bring pliers to D.C.? A Did | bring what?10 ul 2 3B 14 45 16 v 33 Q__ The person's post mentions pliers. It's not clear if he's talking about you or another person in the photo. So did you bring pliers to Washington, D.C.? A No. No, I didn't have anything on me at all. Just a jacket and a shirt right there, my glasses. Q Okay. Did that that person, Angry Viking, who you mentioned in the previous post, go to Washington, D.C., on November 14th? A No. You're talking about in D.C.? Q Yeah, in D.C. A No. To my knowledge, he wasn't there that | know of. Q Okay. And who is Angry Viking? Just a nobody guy, maybe. | mean, he's not ~I mean, he's nothing, really. He just got a bunch of people together, that was it, for a march down in Louisville, and one in Florida. And after that, he's just ~ I don’t know what he does. Q Understood. So now we're going to talk about that December 12, 2020, rally that you remembered earlier. Do you remember how you learned about that event in Washington, D.C.? A Social media, | do believe.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 34 [11:12 a.m.) a Q Okay. But you can't remember a specific poster, things like that? A No. Q__I'mgoing to show you exhibit 2, page 2. ‘Am |sharing it? Nope. Sorry about that. So you'll see ~ can you see this, Mr. Kuntz? A Yes. Q Great. And so this is a Facebook post from you sharing what looks to be a flyer for the march for Trump on December 12, 2020. And you say, "This is Reaper. We are going." Who is the "we"? A Probably me and Dan. Q__ Did you go with anyone else from Grey Ghost? A No. | think it was just ~ it was just me and him that drove together, if that's what you're asking. Q Yeah. Did you meet — A Just me and-- Q~ Goshead. A Yeah, it was just me and him. Q Did you meet up with anybody in D.C. that day? A Idon't think so. don't I don't really know. Let's put it that way. | really don't know. There was so many people there, Q Okay. Do you remember why you decided to go to D.C. for this march?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 35, A Just to go. That's the best way to describe it. Just to go to see it. Q What was the purpose of seeing it? A Well, hopefully the -- I guess, see Trump and all the people and --I never 1 mean, these are the only two times at that point that | had ever been to D.C, and | was more amazed with it than | was with anything else. Q So this flyer, it says, "#StopTheSteal," "#AuditTheVote," "#ElectionintegrityNOW." A Ub-huh, Q Were those issues on your mind when you decided to go to Washington, D.C? A don't think so. | mean, | don't ~I can't be 100 percent, but I don't think 50. Q So, in this post, a Jason Cumle replies to you, and | can summarize that - maybe it's a flippant comment, but saying something like "Trump did not do everything he said he would do." And you reply, "I understand but we half to stand together to fight this bull shit that is going on buddy." So what were you fighting against? A Tobe honest with you, |don't know. I don't know. | don't even remember writing that. Q You don't remember wanting to stand up against the, you know, 2020 election results and try to get President Trump another term in office? A No. No, I don't Q Was supporting Mr. Trump's efforts to get a second term on your mind at the time? A Honestly, | don't know what | was thinking, other than ~ | mean, |10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 36 remember, you know, D.C,, being just amazed with it, because I'd never been there. You know, I'd been there in November, but then we was going back again, and | wanted to see more of it. | think that was more on my mind than anything. Q Okay. Well, 'm going to show you page 9 of exhibit 2. This is your post from November 24th, And you say, "This is Reaper. You all need to join my telegram page with other patriots i understand how some feel but if my fb goes down we must stay in contact at any cost.” Do you remember writing this post? A No. I don't remember writing it. Q Did you start a Telegram page? A I don't personally have a Telegram page. | don't - yeah, don't think so, | don't have one. Q Well, if we scroll down, it looks like people are sending you messages. "Message sent." Mss. Hanon says, "Absolutely." ‘A What them are ~I couldn't tell you what - what that was about that. But | don't think personally | ever had a Telegram page, unless it was a site, maybe an old site or something | had been on for ~ people could join or something. | really don't know. Q Okay. Well, a couple of days before that, on November 22nd, you posted, "This is Reaper i need all to message me so i can get you to telegram site so you can talk about patriot stuff with other patriots pls and thank you." What did you ~ A I mean, that could be. What did you mean by "patriot stuff with other patriots"?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 37 A Patriot-type people, | guess that's I don't know. People who wanted to talk on social media with other people about what ~- | guess the events that have happened or whatever. Q Well, what do you take the term "patriot" to mean? A American people. Q__ Isthere a specific kind of American person that would be a patriot? A No. American people in this country. American people are patriots. Everybody's a patriot, in my eyes. Me, you, everybody. a ME Thank you. a Q_— Mr. Kuntz, | just had a couple followups on those points. Do you think there are Americans who aren't patriots? A | don't know personally. | mean, I don't know any personally, but | guess. | mean, that's their right, | guess. But | don't look at anybody other than a patriot in this country, QM showed you some messages that involved antifa earlier. Do you believe that individuals involved with antifa are patriots? A Yes. Everybody in this country, to me, is a patriot, They havea right -- they have the same rights as | do, you do, or anybody. Q So, when you were going to protect buildings over the summer, over the summer of 2020, were you protecting them against individuals who you believed to be patriots? A Individuals ~ anybody that was there to destroy that property. Not ~ my is all Americans are true patriots in this country. It doesn't matter what, I guess,10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 38 their beliefs or my beliefs or whatever, but they're still - they're still Americans. They're patriot Americans. Q Understood. You spoke earlier about, sometimes we need to bring weaponry to defend against other armed groups who had weapons. So I'm curious about what you think the purpose of those groups were if they were also patriots, ‘A When you know that, like, another group has weapons, and if you ~ and you come in with yours, it's a big deterrent for no violence. They got weapons, we got weapons. And it~ I've never seen any trouble whatsoever, you know, at either side. Q__ Soare there groups that you view as threats to the constitutional order or to the United States in general? A Me personally — Qs Yes. A -no. Because I don't -- I just - I don't know if | look at things different than a lot of people do or whatever, but their side, my side, whoever's side, they're still ‘American people, patriots, They have a right to do the things they're doing until they start, like, burning down buildings, | guess, or beating people up or something like that, | guess. QI guess I'ma little confused, because you have described the Three Percenters as standing for the Constitution and wanting to protect individuals. So-- A Protect people's rights. Q_— Right. Right. And so the armed groups who are trying to destroy other individuals’ properties or potentially harm people, what do you think their purpose is? ‘A don't know what their purpose is. | know what my purpose is or what our group's are. Okay? If 'm there to protect property, I'm going to defend that property. Okay?10 ul 2 3B 14 45 16 v 18 1s 20 39 But anything other than that, than what we are asked to do, the police have to handle the other side. We are not police officers. Q Uh-huh, A We're there to protect the people's stuff, if we are asked Q Right. And, just to be clear, you didn't expect any individuals who were trying to damage other folks' property ~ you didn't expect them to be in D.C. in the December event you're talking about now with [EP A No, not that ~ not that I'm aware of. Q Allright, thank you. That was helpful. Sorry for the interruption, —_i Hb solutely fine. We've been going for about an hour and 20 minutes or so. Do you need a break, Mr. Kuntz? ‘The Witness. Can | go to the bathroom real quick? TER Sere. Why don't we just take a 10-minute recess, and we'll come back at 11:30 or so, Does that work, Mr. Wiest? Mr. Wiest. Yep, that works. Ws Great. Thank you. And we'll go off the record. [Recess.]10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 40 HR) We can go back on the record at 11:34 a.m. ry Q So, Mr. Kuntz, before the break, we had been chatting about some Facebook posts from November 2020 where you asked people to join a Telegram page. I'm going to bring those back up. And they're exhibit 2. Right now it would be page 9. Part of what you post is that "if my fb goes down we must stay in contact at any cost." Was it safe to say that you were afraid Facebook would take down your profile? AI mean, by that post, maybe. Q Was it something that you were afraid of quite often in November 2020? A don't know. I really don't know. Q Was it your common practice to invite people to a Telegram page? A Yeah, | mean, | invite people to them all the time. Q So here, specifically, you say "join my telegram page." So you -- what Telegram pages were you inviting people to all the time? A Oh. |--I don't know. Q Well, just describe a little bit of the process. If you weren't inviting people to your Telegram page, what were you inviting them to do? A | guess to join Telegram. Q Just to join Telegram? Or to talk to specific people on Telegram? A ~- [really don't know. I really don't. Q Well, if we go to page 11 on exhibit 2, you'll see as | start scrolling that there are a lot of people who seem to be responding to you. For example, Jeffrey Johnson says, "I would like in."10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 a Ted Jagen, J-a-g-e-n, says, "Hell yea." Rick Adgate: "I'm in Patriot!" David Hughes: "I'm in hands down. But if we keep talking like this we will eventually be looked at and maybe looked for." Scott Pease says he sent you a message. “Jeff McIntosh, Douglass county, Oregon II1%. We are on Telegram, and use it, regularly." So do you know who these people are? A No. Q__ Did they join your Telegram page? -I don't know. | really don't. Q Do you remember getting messages from them about Telegram? A No. No, Ido not, Q Let's flip back to page 11. Shannon Marie responds that "I have maybe 3 or 4 other's in my friends list who would probably be interested. | will work on that today." Someone named Karen Delph says, "Are you talking about AV or something else?" Shannon Marie says, "Something else, would you like me to send you the link?" And eventually you respond, "something else." What is "AV"? A The only thing | can think of, "AV" is the Angry Viking. Q_ Was this a Telegram site for Angry Viking? A Idon't know. | don't remember, Q__Itseems you said "something else," so, at that time, what would that else have been? A Yeah, | don't remember.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 42 Were you often inviting people to Angry Viking's Telegram site? A --Idon't remember. I really don't, Q So, for instance, do you know who Jeff Mcintosh is, the person who said “Douglass county, Oregon II1%6"? A No, do not. Q Do you know who Dan Markle is? "I sent a pm but I'm interested." A No, Ido not. Q Do you have any idea why all these people are interested in je ining this, Telegram site based on your post? A No, Ido not. Q Do you remember what you talked about on Telegram around this time? A No, sir, 1 do not, Q Was there ever a discussion about civil war? A | really don't know. Q Okay. Well, if we go to page 19 of this exhibit, this is a post you made on November 18th: "I really hope everyone on here has made peace with god and who ever and is ready to take back our country because the shit is coming people." And it looks like you post a link to your Parler account. Do you recognize that as a Parler account belonging to you? A No, | do not. Q — Doyou remember using Parler? A No, | do not. Q__ Inthe course of providing documents for this deposition, from what you responded to me earlier, did you check if you had a Parler account?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 43 A No. I don't ~ | don't remember ever having one. Q Okay. And thinking about the December 12, 2020, rally in Washington, D. . did you talk to other groups, like the Proud Boys, before you went? A No, sir. Q Okay. | want to show you a post that you made on November 24th. It's page 10 of exhibit 2. "This is Reaper. Washington plaza in Washington DC December 12s the meeting place of patriots and proud boy's are meeting up to counter blm and antifa. It's time to show them who owns the street's we are done sitting back.” Were you talking to Proud Boys about going to the December 12th rally? A No, sir. Q —_Howdid you know the Proud Boys would be in Washington, D.C., on December 12th? A | don't remember. Q And, back tol questions about patriots, this sentence structure is set up so that you're -- the "patriots and proud boy's are meeting up to counter blm and antifa." So why would that be necessary if BLM and antifa are patriots? A ! don't know. What did you expect BLM and antifa to be doing in Washington, D.C., on December 12th? A | don't - | don't know what they'd be doing. Hopefully just nothing. a HR Thank you.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 44 —_ Q You said earlier you didn't expect there to be any sort of hostile group activity in D.C. in November or December. Do you remember now any mention of potentially dangerous groups being there, given this post? A No, | do not. Q Sowhat do you mean when you say "done sitting back"? What kind of activity does that imply to you, reading the post? A honestly, | don't remember. | don't remember, you know, saying that or anything. | don't know what that could've meant at that time. | don't know. Q Thanks. oy Q__ Reading it today, though, | think IEEE was trying to get at, what is ~ how do you take this post today? A Just arant. Maybe people just -- people just to show up for a rally. Q Why did you feel the need to rant? AI mean, | don't know why | ranted that day about that. | mean --I don't know. It makes you feel better to get whatever off your chest at that time, | guess. Q So we've seen a number of posts, though, where you're mentioning similar language about patriots, and I'm trying to - we'll scroll down a little bit here, Earlier on November 24th, you said, "This is Reaper i hope all on here are ready to go to work if Biden gets in because we all will half to do the right thing in order to save this country.once again we shall rise to defend her.” So there seems to be a common theme of, you know, protecting the country against some sort of enemy; it seems like President Biden here. So do you remember what you were ranting against at that time in general?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 45 A No, sir, Ido not. Q_— Well, why would people need to rise up to save the country? - | really don't know. —_ Q This postlEMiust showed you was on November 24th, and you say there, “if Biden gets in." So, obviously, by that point, the election had been called for President Biden a few weeks beforehand. Did you bs ve at the eof this comment that there might be a chance that President Biden would not take office? A Ireally-- Idon't--I don't know. | mean, | really don't. Q And— A its Q Goahead. A It’s been so long back, | don’t know. Q And returning to IEEEEE's question, do you have any sense of what you meant by rising to defend our country against, what it seems to be, the threat of the President-elect? How else do you read that comment? A No, sir, Ido not. Q Okay. Q__ I'm going to scroll to page 16 and 17, just to try again just for your memory. So, on November 20th, it looks like you posted what I'll calla meme. It says, “This is Reaper. Lets see who agrees with this. Are you ready to give up everything to do the right thing when the time comes?" That post was at 6:17 p.m, ‘And earlier in the day, at 8:10 a.m., you posted, "I abide by the law's of the10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 46 constitution not by the law's of a tyrant governor." Someone named Scott Stoebe, s , says, "By the constitution we should of already been hanging motherfuckers," and you reply, "agreed brother." How do you take that post? At --I don't know. I mean, at that time -- | mean, | don't know what | was thinking at that time, Q__Isthere any other way to read you responding to Mr. Stoebe in this way other than that you agreed with his point, that people should've been hanging? A don't know ~ now, we're not like that, We don't go and just hang people. I mean, that could ~- that could mean anything. I mean, I really I honestly, | don't know. Q Sol guess the first question is, do you know Mr. Stoebe? A No, Ido not. Q__ But he has commented on your Facebook posts before? Or — do you recognize his name? A No, sir, | do not, Okay. So what other meanings could "hanging motherfuckers" have? That ~that's him. That's his, | guess, his belief, his way of talking. Q But you do say, "agreed brother.” So what are you agreeing to? A Imean,| don't agree to that. So | don't know what | was thinking at that time. | don't know. Q__Atthe time, were you worried about the direction of the country? A Nnn--- Qit'sjusta~ A No.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 a7 Q Well, just help us out a little bit, Mr. Kuntz, because it's a pretty extreme statement. And there's a series of similar posts that evoke -- that seem to evoke a sense of, like you said, ranting or outrage. So we're just trying to understand what it was that was making you angry or upset or concerned at the time. At -- [really honestly do not know at that time. | don't know what | was thinking or even doing that day. Q Well, not just that day; in general around this time. Following the 2020 election and, you know, up through these rallies so far, that's the time period we're talking about, Do you think it had anything to do with the 2020 election? A Do | think? Q Doyou think, yes. A Idon't know. I don't think so. Q Do you have reason to believe it was something else that you were angry about? A | -- 1 don't know. Q Okay. a HE Sure. —: Q__Sol'm wondering if you can give us any more clarity on who you think Mr. Stoebe might have meant when he was talking about, quote/unquote, "motherfuckers" who should be hanged. Do you have any recollection of who that is? A - Ihave no idea. Q__Isthis the kind of content that you regularly saw on your Facebook? Because, for me, this would stand out in my memory.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 48 A People ~ people post whatever. | don't --I mean, | can't stop them from posting stuff, you know, on what they post on mine or anything, I mean, | ~I don't know what this was about or anything. | really don't know. Q_ And so | believe —[EEEE if you could scroll up just to see the initial post. So this is what the post was about, that it was the laws of the Constitution and not a tyrant Governor. Who was the tyrant Governor you're talking about there? A |--Lwould say Andy Beshear. Q Right. Governor of Kentucky at the time. Why would you have characterized him as a tyrant in this post in November 2020? A I--like | said, | really don't know. I don't know what was going on at that time. Q Well, | think one thing that was going on was that the election had happened 2 couple of weeks prior, and President Trump was heavily contesting, as I'm sure you remember, his loss. So do you think that there was anything that the Governor was doing related to those efforts that would've struck your anger? A Ireally-- | really don't know why | posted that. ’ Were you upset about the COVID lockdowns at the time? Well, yeah. I'm sure everybody was. Would that have been a possible reason for this post? Oe Idon't know, I really do not know. fd Q__ Soisit fair to say that the tyrant Governor might be one of the people that Mr. Stoebe is referring to in his comment below? That's directly what you were saying,10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 49 so- A [honestly do not know why | posted this or what it was about, if | was mad or not mad or anything. | really do not know. QQ Ub-huh. ‘A That's the best answer that | can give you, is | don't know. HEE Well, thinking of that — unless you have anything further on that, I] = HE (ot on this post, no. — Q So, back to the December 12th rally, do you remember what happened that day? A December the 12th? Q The rally in Washington, D.C. What did you do that day? A Walked around with a bunch of people, a few million people, and —I mean, that's, I guess, basically about it. Q And know you mentioned earlier that someone named Chrissie might've gone with you, along with Dan Wire. Did any other people go with you to Washington, D.C, for the December 12th rally? A No, not with us. No. Q Were the Grey Ghost Patriot Rangers -- did they go as a group? A No. No. Q Did you have any conversations with other Three Percenter groups who went to D.C. that day? A Didi? Q Yes.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 50 A {don't remember. Q And you were not there to provide security to anybody? No. Q Okay. Well, we'll move on to leading up to the January 6th rally. ME BE 50 con't mind, before you go on to that — Hb, sure. Yeah, please. _ QI was hoping you could help us understand, Mr. Kuntz, some of your broader motivation in this time period. Because | know sometimes it's hard to pin down what you were thinking when there's a particular social media post we're putting in front of you. Understood that, My question then would be, what were some other issues that were animating you at the time period we're discussing, late 2020? You mentioned the COVID lockdowns as a source of anger for you just a couple minutes ago. Was that animating your activities throughout the year? A No, I don’t think | said that | was angry. I mean, | just said everybody was angry at that time. So — Q — Sowere you angry about the COVID lockdowns? A Well, as far as | know, everybody, you know, was mad about that, you know, being locked down and not being able to do your normal things. | would say people were upset. Q And were you ever involved in any armed protests or protest activity related to the COVID lockdowns? A Are you asking if we come out armed against something because of10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 51 lockdowns? Q.__ No, just if there was ~ you mentioned sometimes you have to bring arms to a protest if you think there are going to be other groups that are armed. And you said sometimes you don't go with any gear. So were there ever any activities related to the COVID-19 restrictions where you and your organization would appear at an event? A No, I don't I don't think so. Q Okay. How about -- oh, go ahead. Oh, that's okay. Go ahead. Q Allright. This is helpful for us just to better understand what was motivating you throughout this time period ‘And 2020 was obviously a really tumultuous year for everyone, and another issue that came up quite a lot in the middle of the year was the Black Lives Matter protests and associated events. So what did you think about those events when they started happening in the middle of the year? A Aslongas they were peaceful, | mean, | didn't have any problem -- | mean, I've talked toa lot of BLM people. You know, good people. They're really good people. There are bad apples in, | guess, every bunch, you could say. Q So the bad folks in that bunch, what do you think they were trying to accomplish? ‘A Ihave no idea. | wouldn't even suggest even saying anything on that — Q Okay. A =because | don't ~ Q_Insome of the posts that we've looked at, | think just the last post we looked at, or two posts ago, there was a reference to BLM and antifa in D.C. Did you see antifa involved in the BLM protests earlier in the summer in Kentucky?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 52 A Did see them? Q Uh-huh, Did you think they were -- did you think they were involved? A Oh. No, I think it was more -- well, I really don't know who was there or who was involved in it, which parties were what. Because there was so much going on at that time. Q_— More broadly, what do you think of when you think of antifa? A I'mtrying to answer this. | don't know what to think of them. You see so much on social media. So what do you believe? Other than—Idon't know. I don't know. | don't even want to answer that, because | don't know how to answer it. Q guess 'l put a finer point on it. Do you think that antifa represents a threat to the Constitution, to the safety of individuals? ‘A Again, | really don't know how to even answer that because of the ~ there's so much social media on it that | - | really don't know. Q Do you think that people in antifa act patriotically when they are involved in protests or riots? ‘A guess there's a general -- | mean, from what | see, like I said, there's good, there's bad. Q So, when you wrote that you needed to show antifa that you owned the streets in D.C. in December, was that a reference to the bad parts of antifa? A - | can't answer that, because | don't know why | - that that was posted at, that time or anything. Q Uh-huh. A Iean't, Sol ~Idon't know. Mi BE 2c to you.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 53 Thank you, Mr. Kuntz The Witness. Thank you. \— Mr. Kuntz, were you aware at the time -- so now we're going to move past the December 12th rally into late December 2020 and early January. Were you aware of a rally being held in Washington, D.C,, on January 6, 2021? A Yes. Q Do you remember when you learned about it? A The social-media-type stuff again, | guess —~ Q —_Doyou remember ~ ~ that point. Q — Doyou remember a tweet by former President Trump mentioning a wild protest in Washington, D.C.? A Awild protest? Q Yeah. 'llshare on my screen with you. One second. Thisis exhibit 4. So this is a tweet from December 19th in the early morning where Donald Trump mentions a report by Peter Navarro, and he says, "Big protest in D.C. on January 6th. Be there, will be wild!" Do you remember this post? A No, | do not. Q Do you remember hearing about this post? A No, Ido not. Q Did you want -- did you end up going to Washington, D.C., on January 6th? A Yes. Q —Doyou remember when you decided to go to Washington, D.C., on10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 54 January 6th? A No, Ido not. Q Sothisis exhibit 6. I'm not entirely sure what date it was posted. But you say, "This is Reaper. Washington D.C. is listing to us we have there attention for the 6th and the 20th that the militia groups are coming." And it looks like you responded to somebody. And, again, we have an incomplete post here. Said, "Ya he asked for patriots on the 6th i haven't seen him ask for the 20th yet but we are going then." Who asked for patriots on the 6th? ‘A I don't know exactly who posted stuff, but, | mean -- I don't -- I don't know. | don't even remember — remember that day. Q Okay, We'll show you exhibit 7. And, MINIM 1'| be there in a sec. So the first page here, as you might have become aware, someone submitted, it looks like, an email to the FBI on December 21st, attaching a post that you made. And this is the post. I can zoom in a little bit for you. A I'dappreciate Q_— Canyou see that? A Uh- Q Aliittle more? A Well, no, it needs to go up. Not too much. Q__ Sothis post is from you. It says "yesterday" when it was captured, so I'll represent to you that yesterday from December 21st when it was sent to the FBI would be December 20th.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 55. So, somewhere around December 20th, you post, "This is Reaper. | need a group from ohio that is going on tbe 20th to message me pls thank you." And in response, a Chuck Waller says, "Are y'all going to answer the Presidents call on the 6th?" And you say, "Yep." Was it your view that President Trump had called you to Washington, D.C,, on January 6th? A No, notacall. Imean -- no, 1 don't --I don't - I don't think so. Q How would you take that, your response, then? A How do | take that response? Q Yeah. You wrote "yep" in response to Chuck Waller's specific question asking if you are going to answer the President's call on the 6th A I--honestly, I don't know what I was thinking that day. I don't know. Q — Doyou remember going to Washington, D.C,, to see President Trump on, January 6th? A Yes. Q And that is why you went to D.C,, to support President Trump, correct? A Yes. Q So do you think President Trump called people to Washington, D.C., on January 6th? A - | don't know. Q Well, we just showed you the tweet where he said, be there, be wild. And now someone named ~ do you know who Chuck Waller is? A No, | do not. Q__ And do you know why you were asking for a group from Ohio? A No, | do not.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 56 Were you planning anything for January 20th? No, sir FD Were you planning on going to Washington, D.C., on January 20th? A fit was just, like, a just another protest rally, maybe. | don't know. Q Okay. me a CE hanks '— Q__ So|'m wondering ~ you said you hadn't been to D.C, before November 20th. Is that correct? A From November? Q You hadn't been to D.C. before this time period, correct? A Iwas there in November and December. Q__ Right, but before November, you had never visited beforehand. A Oh. No, I'd never ~ never seen it, never been there, nothing, Q So why was it important for you to go potentially four times, if you were going to go to a protest on the 20th, four times in 4 months four times in 3 months, actually? What was so important that brought you there after so many years where you hadn't been once? A Because | had a chance to go and see it. What was the chance? A Going and, you know -- and then to be ~it was a rally, and he was going and asked if | wanted to go. That's the only thing I can think, because I've never seen it. Q And why ~-it seems like from these messages that you were actually trying to organize more individuals to go. So | guess I'l ask again: What was so important10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 7 about that 3-month period, November 2020 to January 2021, that you wanted to go back so many times? A {don't know. Q Well, you said to [NN that you did think that President Trump wanted your support and you went to go see the President, right? A Are you talking about in January? Q Yes. ‘A {don't know what | was thinking at that time. Maybe. Q Well, | think you said earlier that you were going to see the President. A Well, for the rally on J6, yes, just to hear him -- his speech. Q — Why--were you there to support him? A To support him? Q Uh-huh. A Yes. Q Why do you think he needed your support on January 6th? ~ | don't know. Q__Didit have anything to do with his claims that the election was being stolen? Did ~can you say that again? Q__ Did President Trump's need for support on January 6th have any relationship to his claims that the election was being stolen from him? A don't know. Q Did you believe that was the case? A don't know -- | don't know how to answer it, because | don't know what | was thinking back then, because I don't know. Q Uh-huh.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 58 A don't ~ you know, | just don't know. Q_—Atthe time, were you aware that January 6th was the day that the Congress was certifying the results of the election? A Then, again, | ~ | don't know. Q That was a pretty prominent story in the news at the time. As a casual observer of the news, did you have any awareness of January 6th's importance in the election certification process? A Like | sai i, don't know what | was thinking there. Personally, I'm not a political person, | mean, on that type stuff. | don't keep 1 Q_— Mr. Kuntz, we're asking all these questions because it's -- and | want to move ontoexhibit 8. We're asking you all these questions because you have made repeated posts in the span of 3 months that indicate that you are paying attention, going to rallies, supporting President Trump. And it isa little difficult to believe, quite frankly, that you don't remember why you posted anything during the time. So this is a post by someone named C. James ~ I might mispronounce the last name -- Du, D-u, Buisson, B-u-i-s-5-o-n. Do you know who this person is? A don't think so. I don't think so. Q So this person says, "What do you guys think is going to happen Jan. 6th?" His post is December 21st. And if we go down to page 4 ~ sorry about that - you reply, "Hell you better be ready for it." And someone named Anthony Howard replies, "been ready since 9/11/2001 brother." So what do you need to be ready for on January 6th?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 59 A Idon't know. Togo? I don't know. | don't know what | was thinking at that time. Q Were you talking to people in the Grey Ghost Patriot Ranger about January 6th? A About going. I mean, other than the guy | rode with -- me and him talked. Q What did you guys talk about the day? A Idon't ~ I don't know what we talked about. Q Well, this post is 2 days after President Trump says, "Be there, will be wild!" And you say, "Hell you better be ready for it" on January 6th. What is there to be ready for? A don't know. Q Do you know who Anthony Howard is? A That name does not ring a bell. Q Okay. We'll goto exhibit 9. On Christmas Eve, December 24th, you post, or repost ~ I'm not sure if this is your own words or somebody else's that you have reposted ~- can you see this, Mr. Kuntz? A Imean, | see it there. Q —_Doyou want me to zoom in a little bit? A No, it looks -- that's okay. Q Soi looks like a letter to Members of Congress. "Most of you should be in prison for counterfeiting, fraud, conspiracy, grand theft, extortion, criminal invasion of privacy, racketeering, international drug trading, insider trading, and more. “Your decades of crime transformed our republic from the post revered to the10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 60 most feared on earth.” And we can skip to the last paragraph. "You're too late. We The People now have a detailed, long-term plan of action that includes taking you out of D.C. forever. Criminals masquerading as public servants, YOU ARE GOING DOWN. "Signed, We The People.” Why did you repost this? 1 don't know. Q_ What's the "detailed, long-term plan of action"? A “Detailed, long-term" ~I have no idea. I don't ever remember this post. Q And don't mean to be insulting about this question, but is there a medical reason or other reason that you don't remember what you were thinking during this time period? A No. Q__ There's no dependency on drugs or alcohol that would have impeded your memory ~ A Idon't do ~ Q_ — ~ during this time? A --drugs, and I'lldrink a beer or two occasionally. Other than that, that's it. Q Okay. So you agree, then, that you had your faculties about you when you were making these posts? A Well, yeah, | guess so. Q Yet you don't remember what you were thinking, feeling, just anything in general about what was going on that would've led you to put these posts on Facebook repeatedly.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 61 A No, Ido not. Q Do you know what martial law is, Mr. Kuntz? A Vaguely. I'm not not, like, to the T. | guess something -- lockdowns or something, | don't know, to that effect. Q If represented to you that martial law is when the government uses the military to take over the normal course of society and enforce strict laws in times of, you know, unrest or war, does that sound like a decent enough definition of martial law? A Yes. Q So, if we go back to exhibit 2 — oops, sorry page 6. I'm not entirely sure when you posted this, so I'll represent that to you. You say, "This is Reaper. What is your answer is it war or marshall law it must be one or the other a group has sent demands to the white" ~- | think a typo, White House ~ “its your choice." Why the dichotomy between martial law and war? A don't know why | posted that, Q_ If we scroll down one more page, it looks like you repost something from Dan Markle, who earlier you said you don't know. "TAKE YOUR PICK....WILL.IT BE WAR OR WILL IT BE MARSHALL LAW IN ORDER TO REFORM BIG BROTHER? THIS IS NOT A DRILLI!!! WE THE PEOPLE HAVE CONTACTED THE WHITE HOUSE." ‘And you note that the "Gray gost ky Rangers 3% group thats from the we the people." Do you know what you're talking about here? A have no idea. Q__ Is Dan Markle a member of the Grey Ghost Kentucky Patriot Rangers? A No.10 ul 2 3B 14 45 62 Q__ Did the Grey Ghost Kentucky Patriot Rangers ever submit a petition to the White House? A Not that I'm aware of. Q Do you remember signing a petition to the White House calling for the invocation of the Insurrection Act? A Who, me? Q Yes, you. A Not that I'm aware of. Q__ So, when you say "thats from the we the people," are you not referencing what some people have contacted the White House about? A That's I really don't know or remember anything about that. Q__Inexhibit 6, which we saw a little earlier, you talk about militia groups coming to D.C., you wrote, for the 20th, the 6th, or both. Which militia groups were you talking about? A 1-1 donot know.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 63 (12:21 p.m] a Q How did you know militia groups would be there? A {don't know. Q_ Did you see social media posts about militias coming to Washington, D.C., on those days? A Idonot know. I really don't. Q Exhibit 111is another post on Facebook: "This is Reaper to all. We will be meeting at the Lincoln Memorial 9:30 to start the march to the event at 10:30. This is to all groups so we can march in there as one big unit." And if we scroll down, someone questions: "At the Lincoln Memorial?" You seem to say: "Damn phone LOL." Was that a typo, the Lincoln Memorial? A Idon't know. I really don't. Q Do you believe that this post is about January 6th, being in D.C.? A don't know. Q — Soyouthen say: "I cannot say which groups will be there." How did you -- why did you say that? ‘A What, "damn phone"? Q No, "Icannot say which groups will be there." A Oh. I don't know. Q_ So did you have insider information about groups meeting up that you couldn't share with other people? A Idon't know. | really don't know.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 Q_— Were you in contact with other militia groups in January of 2021? A of 2021? Q Were you in contact with any other militia groups in January 2021, including the Oath Keepers, including groups like the Proud Boys, other Three Percenters? A don't know. Q__I'mjust trying to get a sense of — your post said this is so all groups can march as one big unit and then you responding to people saying you cannot tell them which groups are going to be there. Reading that today, would you say that you acted as if you had insider information about which groups are gathering in Washington, D.C.? ‘A What, by reading this? Qs Yes. A don't know. Q_ Let's go to exhibit 4, another Facebook post from yourself. Scroll down to the end. You make a comment about -- and, again, it's not perfectly synced so it's not. entirely clear what you were replying to, but you say: "Washington Monument on the 6th at 11." Did you plan to meet up with anybody at the Washington Monument at 11 o'clock on January 6th? A don't know. Q__ Did you end up meeting up with anybody in Washington, D.C., on January 6th? A don't think so. Q__ Did you march with a group of people in Washington, D.C., on January 6th? A mean, | went with the crowd, if that's what you're talking about, with the10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 65. crowd people. Q__ Did you start at the Washington Monument at 11 o'clock? A 1 do believe so. Q —Doyou know -do you remember who was there? Were there people dressed in military fatigues, for example? A Oh, God, | don't remember. Q Did you talk to any Oath Keepers while you were there? A don't remember, because | don't remember that there was so many people there. I'don't know who | talked to and who | didn't talk to, Sol don't know. If | knew, | would answer. Q How about Proud Boys? A What did he say? Q_ What about the Proud Boys? Mr. Wiest, Did you talk to any Proud Boys? The Witness. | don't know, because there was so many people there. | mean, | could have. _:, Q To your knowledge, though, you did not -- you don't remember speaking to any Proud Boys? A No, I do not. Q__ Did you expect any sort of violence in Washington, D.C., on January 6th? A No. Q We'll scroll up to the beginning of this post, and you note - if you need me to zoom in alittle bit ~ that it's time for people to start making hard choices. Its time to start standing up to the police. We follow the laws but a lot of officers are not. It is10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 66 time to start standing up against them and fighting back. Does that sound like you anticipated violence? A No. Q What would you describe standing up and fighting back against law enforcement to be, Mr. Kuntz? ‘A {don't know what | was thinking at that time. Q Was it your view that the police were on the side of acting like tyrants? I'm sorry, could you ask that question again? Q Were the police acting like tyrants? A Not--not that I can remember. Q__I'llpass it tolEMin one second, but you see that this name Scott Stoebe replies "on board" here. And you represented that you don't know him, but I will ask again because his name has appeared again. Do you recognize the name Scott Stoebe? A No, | do not. a The Witness. I'm not good with names anyway, but he does not -- I do not recall oy Q_ Mr. Kuntz, do you believe that violence against law enforcement is ever justified? A Is what now? Q Do you believe that violence against law enforcement is ever justified? ‘A _No, there should be no violence against an officer. That's why we got laws. Q_ What if those officers are acting like tyrants?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 o7 A Then they need to be dealt with appropriately. Q Soin this message, are you talking about how to deal with officers appropriately if they're acting like tyrants? A - like | said, | don't know because it's been so long since | guess | wrote that. So, | mean, | don't wish any harm to anybody. | mean, does that help? That's not me. Because | used to be Q__ I'm really more curious about what your intentions were on January 6th. | take that statement, but it seems to me that talking about standing up and fighting back against law enforcement is quite a lot different than what you were talking to us earlier about coordinating with law enforcement in Louisville over the summer of 2020. So why was there a change in how you viewed law enforcement? A I don't view it any different. | have the same respect for them as Ido the ones in Louisville. Q__ Even though you were — A They have to dealt with with - by their ~- their higher captains and whoever, not by us. Q But in this message, you say that you have to fight back and stand up to law enforcement who are acting like tyrants. A Yeah, but that could be, you know, file complaints against them or anything, It could mean that. It's not -- probably not meant to be towards -- any violence towards them, I don't take it that way. If you see one doing something wrong then — then go file your complaints, your papers, and what you need to do against that officer. ’ Q_— Why don't we scroll down alittle bit to page 2 and I'l read a little back-and-forth you had with a Jesse Giller who -- sorry, it starts here. Yeah. Jesse10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 68. Giller says: "Oaths never expire," showing an Oath Keeper patch. "I swear that | will support and defend the Constitution of the United States." You repl "We stand together," and a picture of the Grey Ghost Patriot Rangers ~ I'm sorry, Partisan Rangers patch, You ask Jesse: "Yes, sir. Are you going to D.C. onthe 6th?" Jesse replies: "Yes, we are." And then you ask: "We will be there. You all going armed or no?" And Jesse replies with advice to take two vehicles, one with arms, one without to be ready. And several years ago we went to overthrow Vomit" - not sure who Vomit is ~ but they didn't have enough unity. So you reply -- we don't know your reply. It doesn't look there. But | think HEE is asking about whether there might have been violence on January 6th towards police officers, and you're asking Mr. ~ or Jesse Giller about going to Washington, D.C, to D.C. armed. Why would you have wanted or needed to be armed in Washington, D.C.? ‘A I don't know why | was talking to him about that. | know we wasn't going armed. Q_ When you say "we," who is "we"? A Me and Live Wire. Q Dan Wire? A Dan. GE BI <0: to interrupt, | just wanted to scroll down. HR 0,1 was going to go there too. So thank you, a Q Alotof these posts we're discussing are about coordination, discussion between multiple organized groups who are going to attend D.C., the protests in D.C.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 69 So I'm confused, frankly, because if you were planning to file a complaint with an officer who was acting like a tyrant, why would that require a convoy of organized groups to go to D.C? A Idon't know. | don't know how many groups went to D.C. don't know none of that. I don't know who was all there. | know that me and Dan Wire were there. Now, with other groups that were there, that I don't know. There was no coordinating stuff. HE | think that’s all | have on this post, | | Thank you. oy a: Q Allittle further down, another back-and-forth with Mr. Scott Stoebe, Stoebe says: "If we don't win this, this whole world is fucked, guys. This is really for all the marbles." You say: "Yes, itis, Scott. If we fail the whole world will fail. They are watching and waiting on us to act." What kind of action are you talking about? A Atthat time, | do not know. Q So thisis talking about going to January 6th. Sorry, go ahead. This is talking about going to January 6th. We just saw your back-and-forth with a Jesse Giller about whether to go armed and Jesse's response about take one armed car and one not. ‘And now talking to Mr. Stoebe, who's the person, remember, who said people should already be hanging, and you said agreed, that if we fail the whole world ~ we fail the whole world and they're watching and waiting on us. Who is waiting on you and to do what? A Idon't know. | don't -- like | said, | don't remember this.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 70 Q__Soisit your posture then that you don't remember posting any of this stuff about heading to January 6th specifically in Washington, D.C.? A Imean,| know | was asked to go. It wasn't, | don't know, like I guess a planned thing. They just asked someone to go to a rally in D.C., and, okay. Q And who ~ it was Dan Wire who asked you? A Dan, yes. Q But you say, Okay. And it looks like, since you've been posting about it, since December 20th or so, there's a lot of discussion. So we're just having a hard time believing that you do not remember what you were expecting to do in Washington, D.C., that people were watching and waiting on you to act. A Show up toa Trump rally and walk with the people. Q So how would that fit ~ A There was no violence or anything like that intended. Q What did you mean by “if we fail the whole world"? A {don't know what that - what that means, | really don't. | don't know. Q What outcome were you hoping for on January 6th? What were you hoping the protest would accomplish? A don't know. Q You mentioned that you took part in a march with a large group of people. Why were you marching? A Just following with the people. Just walking with the people. Q —_Doyou remember what the people were saying? A Huh? Q —Doyou remember what the people were chanting?1 1 A Trump. | mean, that's about the extent of it, is_ Trump things a lot. 2 Q —_Doyou remember hearing the phrase "stop the steal"? 3 A Imean, they could have. | don't know. 4 Q But you were there to support President Trump, as you said. Was it your 5 hope that he would stay in office after January 6th? 6 A I'd say | don't know what | was thinking that day, | really don't. | was just 7 caught up in the moment with everybody. 8 Q Do you remember listening to President Trump's speech? 8 A Yeah, | mean, | was right there, what | could hear of it. | mean, you can't 10 really ~ you couldn't really hear where | was at. | was too far back, You can hear some 11 _ loudspeaker noise-type. R Q —Doyou remember him talking about Vice President Pence? 3 A No, Ido not, because I couldn't hear him clearly. 4 Q Do you remember anyone around you talking about Vice President Pence? 15 A No, do not. 16 Q_ Were you aware that the day that Vice President Pence, his responsibility 17 _ under the Constitution was to certify the electoral college vote for President Biden? 18 A don't know. 19 Q Were you communicating with any groups that day on Zello? 20 A don't know. a1 Q Do you use Zello? 2 A Zello, it's that walkie-talkie thing, ain't it? 23 Q Yeah. 24 A I think we used it one time for a little bit, but | don't think anything even 25 worked that day in D.C.10 ul 2 3B 14 45 16 v 18 1s 20 24 2 23 24 25 72 HERS". Wiest, | know you might enter an objection on these questions so feel free to step in. —_ Mr. Kuntz, did you march to the Capitol on January 6th? Mr. Wiest. Are you asking about whether or not he ~ HE | will be more precise. —_ Q Did you march towards the Capitol on January 6th? Mr. Wiest, You can answer that, The Witness. Yes, a: Q Do you know if you got onto the Capitol Grounds on January 6th? Mr. Wiest, I'm going to object and instruct the witness not to answer on the basis of the Fifth Amendment. HEE Noted for the record. a Q While you were marching, Mr. Kuntz, do you remember what people were saying? A No, | donot remember. HE EE <°:you have any follow-up? _’ Q__ I'm just still kind of struggling to understand your frame of mind while you were attending this rally. You mentioned in an earlier post we talked about that you wanted to show antifa that you owned the streets. Did you view marching after President Trump's speech as a10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 3 demonstration that you owned the streets? A Look, |really don’t know what | was thinking that day, you know, I really don't. It could have been referring to all the people walking the street. | don't ~| don't know. HE that's all have on this point, EE. Thanks. TR) by don’t we take a quick 5-minute recess. | think and | are almost done. We'll just confer quickly and then come back on the record at 12:48. Does that work for you, Mr. Kuntz and Mr. Wiest? Mr. Wiest, It does. MEA sight. We'll go on recess. [Recess.] HEV"! go back on the record then at 12:53. _, Q Just a few more questions, Mr. Kuntz Generally, are you aware of communications between different militia groups? Are there — basically, what I'm asking directly, are there Signal chats, Telegram chats, Zello channels that you know of that are broadly encompassing a lot of different militia groups across the country? A Yes. I'd say the Telegram is full of them. Q Are there specific ones that you can remember on Telegram, like, that would have a certain name? A No, Ido not, | mean, other than, you know, the groups that I've already told you. I mean, people really don't talk about their groups a lot, | guess, or post or -- their names of them, Q Was there a group named American Patriots Three Percent?10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 74 ‘A Whats it now? Q Do you remember if there was a Telegram group or chat titled American Patriots Three Percent? A AP3?_ I think there's some on there. Q And you immediately went to an abbreviation of it. Is that a standard group, American Patriots Three Percent? A I would say yeah, Q__ sit anational organization of some type? A {don't know if it's national or if it's just a local group or ~ or anything like that. Q And where did you hear about AP Three Percent? A I think | seen them once, or a couple times on ~ | can't remember if it was Facebook or Telegram where | seen them on there. Q Do you remember if they were talking at all about going to Washington, D.C, on January 6th? A No, sir, | do not, Q_—_Doyou remember the types of things in general that AP Three Percent would talk about? A No, Ido not. Q Was there a Telegram chat titled "American Militia, the Last Defense"? A don't ~ I don't want to say yes, but | don't want to say no either, because it sounds familiar. Q To the best of your recollection, it sounds familiar, you just -- you're not sure if there was or there wasn't? A Yeah.10 ul 2 3B 14 45 16 v 18 1s 20 24 22 23 24 25 75 That's okay. How about a Telegram chat titled "American Civil War 2.0"? A American Civil War 2.0? I'm not familiar with that one. Q Okay. How about "Civil War is Imminent"? A I'm not familiar with that one as well Q_ That's fine. In terms of ~ do you have a sense of why American Militia, the Last Defense sounded familiar? Is that phrase, "The Last Defense," something that you saw often paired with the word "militia"? A (don't know. | really don't know why or why it sounds a little familiar. | don't know. Q_— That's okay. Did you ever use MeWe, the social media site M-e-W-e? Mr. Wiest. ~MeWe. MEE Vee, sorry. The Witness. I don't think so, I mean, | don't think _, Q__ And in terms specifically and the same kind of question about these communication groups, were you aware of any chats or groups that were specific to talking about January 6th? A No, don't think so. Are you talking about just in general talking, or -- Q Yes. So not necessarily ones that you were a member of, but were you aware of any other chats out there that were titled things like D.C. protest January 6th, for example? A I mean, I'm not going to say no or say yes where I've seen, you know, stuff that ~ I mean, | think everybody was just posting about rallies. You know, that's normally what they do. People will post about stuf, rallies or whatever, ask people if