# MCRO DISCOVERY FRAUD — MASTER FILING CATALOG **Case:** 27-CR-23-1886 — *State of Minnesota v. Matthew David Guertin* **Related Civil Case:** 27-MH-PR-23-815 (Civil Commitment) **Related Federal Case:** 0:24-cv-02646-JRT-DLM — *Guertin v. Hennepin County* (U.S. District Court, District of Minnesota) **Court:** MN 4th Judicial District Court, Hennepin County; U.S. District Court, District of Minnesota **Purpose:** Consolidated master catalog of all discovery-fraud-related filings, chronologically ordered and renumbered. Suitable for narrative generation, forensic report prompts, and comprehensive case reference. **Total Filings:** 28 **Date Range:** January 5, 2024 — May 3, 2025 **Last Updated:** 2025-03-06 (merged from base catalog + 11 batch files) --- ## FILING CATALOG --- ### FILING #1 | Field | Detail | |---|---| | **Filename** | `MCRO_27-CR-23-1886_Demand_or_Request_for_Discovery_2024-01-05_20240430072353.pdf` | | **Date Filed** | January 5, 2024 (filed stamp: 1/5/2024 4:25 AM) | | **Case ID** | 27-CR-23-1886 | | **Filing Type** | Demand or Request for Discovery | | **Filed By** | Matthew David Guertin (pro se, listed address: 4385 Trenton Ln N #202, Plymouth, MN 55442) | | **Addressed To** | Jacqueline Perez, Assistant Hennepin County Attorney (prosecuting attorney) | | **Judicial Officer** | N/A (letter to prosecutor) | | **Pages** | 1 | **Detailed Summary:** This is a formal written discovery request from Guertin directly to prosecutor Jacqueline Perez, citing Minnesota Rules of Criminal Procedure, Rule 9. It requests four specific categories of materials: (1) all Brady material, (2) squad video, (3) audio tapes, and (4) all 104 police photographs referenced in Dr. Jill Rogstad's "Confidential Forensic Evaluation Report" — specifically photographs taken by the Minnetonka Police Department of 10233 West 34th Street #304 on January 21, 2023. Guertin explicitly requests the photographs in their original, non-compressed digital file format. He asks all correspondence be forwarded to his email address (MattGuertin@ProtonMail.com). **Forensic Flags:** - This is the earliest formal discovery demand in this batch; establishes the starting point of the documented discovery request chain. - Guertin specifies "104 photographs" — a number he derived from Dr. Rogstad's report. This becomes a critical anchor: the PDF he was later provided contained only 80 photographs (24 missing). - Requests original, non-compressed format — directly relevant to the image manipulation claims that follow. - This filing later appears as Exhibit Lb in the April 4, 2024 Motion to Compel Discovery. --- ### FILING #2 | Field | Detail | |---|---| | **Filename** | `MCRO_27-CR-23-1886_Motion_2024-04-04_20240430072350.pdf` | | **Date Filed** | April 4, 2024 (filed stamp: 4/4/2024 7:25 AM) | | **Case ID** | 27-CR-23-1886 | | **Filing Type** | Motion to Compel Discovery + Affidavit of Fact | | **Filed By** | Matthew David Guertin (pro se) | | **Addressed To** | Judge Jay Quam; Clerk of Court; Jacqueline Perez, ACA; Office of Hennepin County Attorney | | **Judicial Officer** | Jay Quam | | **Pages** | 40 | **Detailed Summary:** This is the central and most substantive filing in this batch — a 40-page Motion to Compel Discovery accompanied by an Affidavit of Fact (Exhibit Af) and 13 supporting exhibits (A through M, plus Lb). It alleges that the discovery materials provided to Guertin on August 3, 2023 (via email from then-defense counsel Michael Biglow) were fraudulent and manipulated. **Core Allegations:** 1. **Missing photographs:** Dr. Rogstad's report references 104 photographs from the January 21, 2023 incident. The PDF emailed to Guertin ("23-815 Guertin - photos of exterior, interior, person 1.21.pdf") contains only 80 photographs — 24 are missing (nearly a quarter). 2. **Systematic image cropping/manipulation:** Of the 80 photos received, 43 (54%) are interior photographs of Guertin's residence. Of those 43 interior photos, only 15 (35%) maintain the uniform 3:2 aspect ratio of the camera used. The remaining 28 (65%) have varying, non-uniform pixel dimensions and aspect ratios — proving manual, individual cropping (not automated batch processing). 3. **Duplicate image disguised as unique:** Image 20-36 is demonstrated to be a cropped, rotated, and brightness-adjusted duplicate of image 23-40, presented as if it were a separate photograph. 4. **Image rotation confirmed via lens distortion analysis:** Image 23-40 is confirmed rotated approximately 19.5 degrees clockwise from true vertical based on barrel distortion analysis. 5. **Selective cropping to control narrative:** Detailed analysis shows systematic cropping to exclude: Guertin's invention/prototype (a "rotating treadmill" with patent US11577177), professional workstation, business/startup books on floor, inversion table on deck, bathroom vanity, kitchen amenities (granite counters, tile backsplash), photography lighting equipment, and fabric rolls — all items that would convey organization, professional activity, and a higher standard of living than the cropped images suggest. 6. **Anomalous compression artifacts:** Image 30-50 uniquely displays jagged block-like compression artifacts not present in any of the other 79 images, suggesting either editing or intentionally different compression settings. 7. **PDF metadata discrepancy:** The discovery PDF was created on August 2, 2023 (one day before Biglow emailed it on August 3, 2023). Author: JSF254. Producer: Acrobat Distiller 23.0 (Windows). Creator Tool: PScript5.dll Version 5.2.2. The PDF was generated from Microsoft Word — unusual for a straightforward photo compilation. **Exhibit Inventory:** | Exhibit | Content | |---|---| | Af | Affidavit of Fact (sworn, under penalty of perjury) | | A | Email from Michael Biglow (Aug 3, 2023) transmitting discovery PDF | | B | Email headers (DKIM authentication data, full routing chain) | | C | First page of the discovery PDF (exterior photos) | | D | PDF metadata — file properties + ExifTool output | | E | Excerpts from Dr. Rogstad's report ("104 photographs") and Dr. Robertson's report listing the PDF as reviewed material; metadata comparison | | F | Wikipedia excerpt on aspect ratios in photography (4:3, 3:2, 16:9) | | G | Complete 80-image aspect ratio analysis table (6 pages) with pixel dimensions, ratios, location, and manipulation notes for every image | | H | Selected images showing cropping/editing discrepancies (3 pages) | | I | Pixel-density comparison of three 350px-wide crops scaled at 500% — highlights anomalous compression in image 30-50 | | J | Duplicate image overlay demonstration (20-36 atop 23-40) — proves same photograph | | K | Barrel distortion analysis used to determine true lens center and confirm image rotation | | L | Lens distortion line overlays on 6 interior images establishing true center position to prove cropping + 5 pages comparing discovery photos to Guertin's own photos from Oct-Dec 2022 showing what was cropped out | | Lb | Copy of the Jan 5, 2024 discovery request to Perez (Filing #1 in this catalog) | | M | Email from Guertin to Dr. Adam Milz (Jan 3, 2024) pre-examination, disclosing awareness of manipulated discovery; forwarded Dec 29, 2023 email to multiple parties | **Key People Referenced:** - **Michael Biglow** — Court-appointed attorney who emailed discovery PDF (fired by Guertin) - **Jacqueline Perez** — Prosecuting attorney, ACA - **Dr. Jill Rogstad** — Authored initial Rule 20.01 forensic evaluation (March 10, 2023); references 104 photographs - **Dr. Michael Robertson** — Authored civil commitment exam report (Aug 1, 2023); lists the discovery PDF as reviewed material - **Dr. Adam Milz** — Conducted 6-month review exam (Jan 3, 2024 via Zoom) - **JSF254** — Author/creator listed in discovery PDF metadata - **Judge Jay Quam** — Judicial officer listed on motion **Forensic Flags:** - The discovery PDF metadata (Author: JSF254, created from Microsoft Word, produced by Acrobat Distiller) is a potential DB match — check `children` table for this filename and `children_objects` for embedded image objects. - Exhibit G's complete 80-image analysis with pixel dimensions creates a verifiable framework. - The PDF was created August 2, 2023 but emailed August 3, 2023 — one day gap. - This motion was filed the day after a Motion for Judicial Notice (April 3, 2024, not in this batch). - Court never acknowledged or ruled on this motion per the follow-up filings. --- ### FILING #3 | Field | Detail | |---|---| | **Filename** | `MCRO_27-CR-23-1886_Correspondence_2024-05-03_20240503153904.pdf` | | **Date Filed** | May 3, 2024 (filed stamp: 5/3/2024 11:28 AM) | | **Case ID** | 27-CR-23-1886 (also references 27-MH-PR-23-815) | | **Filing Type** | Correspondence (formal follow-up letter) | | **Filed By** | Matthew David Guertin (address now: 1075 Traditions Ct., Chaska, MN 55318) | | **Addressed To** | Judge Julia Dayton Klein; Clerk of Court | | **Judicial Officer** | Julia Dayton Klein | | **Pages** | 3 | **Detailed Summary:** Formal follow-up letter to the court, filed exactly one month after the April 3-4, 2024 motions (Motion for Judicial Notice, Motion to Compel Discovery, Motion to Compel Production of Medical Records). Guertin states that as of one month later, none of these three motions have been acknowledged by the court or by defense counsel (Bruce Rivers, who has now replaced Biglow). He emphasizes: 1. Despite being found "incompetent to stand trial" and "unable to understand the nature of the charges," the court still has an obligation to process properly filed motions, citing multiple subdivisions of MN Rules of Criminal Procedure Rule 9.01 and Rule 13(a) of the Special Rules of Procedure for the MN Commitment and Treatment Acts. 2. The court expected him to appear in person at a civil commitment hearing on February 1, 2024 without providing the exam report. 3. Four months and two motions later, the exam report from the Jan 3, 2024 review with Dr. Milz has still not been provided. 4. Neither the court nor defense counsel Bruce Rivers has provided discovery materials despite multiple requests. 5. The court denied his Petition to Proceed as Pro Se Counsel (order dated April 12, 2024) ostensibly out of concern for his wellbeing, yet is simultaneously causing anxiety by refusing to process his motions. 6. Notes he now has health insurance through MnCare/HealthPartners and is arranging a therapist — meaning he will have satisfied the Stayed Order of Civil Commitment terms from August 2023. 7. Upcoming review hearing scheduled for July 16, 2024. 8. Requests discovery materials and medical exam report be sent directly to him via email since defense counsel Bruce Rivers has failed to fulfill his obligations. **Key People Referenced:** - **Judge Julia Dayton Klein** — Addressed directly - **Bruce Rivers** — Current defense counsel; described as failing obligations - **Dr. Michael Robertson** — Civil commitment exam report referenced (July 20, 2023 submission) - **Dr. Adam Milz** — January 3, 2024 exam report still not provided **Forensic Flags:** - Documents a one-month gap of total non-acknowledgment for three separate motions. - Establishes that the defense counsel (Rivers) is also failing to provide materials — not just the prosecution or court. - Address change from Plymouth to Chaska noted (relevant for USPS tracking). - References pending review hearing July 16, 2024 — timeline anchor. - Establishes pattern: incompetency finding is being used to justify ignoring the defendant's filings, even though those filings demonstrate competent legal reasoning. --- ### FILING #4 | Field | Detail | |---|---| | **Filename** | `MCRO_27-CR-23-1886_Notice_of_Appeal_2024-05-10_20240516110657.pdf` | | **Date Filed** | May 10, 2024 (filed stamp: 5/10/2024 4:42 PM) | | **Case ID** | 27-CR-23-1886 → Court of Appeals case A24-0780 | | **Filing Type** | Petition for Discretionary Review (Notice of Appeal) | | **Filed By** | Matthew David Guertin (pro se) | | **Addressed To** | Minnesota Court of Appeals | | **Reviewing** | April 12, 2024 Order by Judge Julia Dayton Klein denying Petition to Proceed as Pro Se Counsel | | **Pages** | 21 | **Detailed Summary:** This is a comprehensive 21-page petition to the Minnesota Court of Appeals under Minn. R. Crim. P. 28.02, subd. 3 and related rules, seeking discretionary review of the April 12, 2024 order. While the nominal subject is the pro se denial, the petition is used as a vehicle to put six major issues before the appellate court: **Issue 1 — Fraud on the Court by the Court Itself:** Alleges discovery materials (photographic evidence) were manipulated to misrepresent Guertin's circumstances, directly impacting psychological evaluations and commitment decisions. References Addendum 2 (the full motion to compel analysis from Filing #2). **Issue 2 — Involvement of External Entities:** Defense counsel Bruce Rivers allegedly told Guertin "You have some very powerful people keeping an eye on you" (referenced in a June 16, 2023 email). Cites Caperton v. A.T. Massey Coal Co. (2009) and Sheppard v. Maxwell (1966). **Issue 3 — Refusal to Provide Discovery and Medical Records:** Documents the ongoing denial of discovery materials and the Rule 20.01 exam report despite multiple formal requests and motions. **Issue 4 — Impartiality Concerns / Circular Handling:** Alleges the case has been circularly handled by a small team of three judicial officers, raising impartiality concerns. Cites SooHoo v. Johnson (2007) and State v. Barnes (2006). **Issue 5 — Complete Lack of Representation / Potential Coercion of Defense Counsel:** Alleges both Michael Biglow and Bruce Rivers failed to provide effective assistance due to potential coercion or threats. Specific failures: not providing discovery, not presenting exculpatory evidence at the July 7, 2023 hearing, not honoring promise to represent in civil commitment proceedings. Cites Strickland v. Washington (1984). **Issue 6 — Significant Procedural Issues and Timeline Discrepancies:** Includes (a) a continuance granted on June 14, 2023 based on a "non-existent motion," (b) Dr. Rogstad's Rule 20.01 report metadata showing "Chela Guzman-Weigart" as the document creator rather than Rogstad, and (c) out-of-order timeline indexes in the case docket. **Issue 7 — Flaws in Dr. Rogstad's Rule 20.01 Evaluation:** Challenges the competency determination, alleging contradictions (rational explanations acknowledged yet deemed delusional), Dr. Rogstad's admitted lack of technology expertise (relevant to understanding Guertin's patent/invention work), and metadata anomalies. References multiple APA Ethical Standards (2.01, 3.04, 5.01, 9.01). References 10 separate addendums (not included in this PDF but referenced as Add1-Add10). **Key Case Law Cited:** - Strickland v. Washington, 466 U.S. 668 (1984) - Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009) - Sheppard v. Maxwell, 384 U.S. 333 (1966) - Gordon v. Microsoft Corp., 645 N.W.2d 393 (Minn. 2002) - In re Disciplinary Action against Houge, 764 N.W.2d 328 (Minn. 2009) - Carlson v. Carlson, 371 N.W.2d 591 (Minn. App. 1985) - Gleason v. Geary, 8 N.W.2d 808 (Minn. 1943) - Sullivan v. Credit River Township, 299 N.W.2d 716 (Minn. 1980) - Webb v. Jarvis, 575 N.W.2d 485 (Minn. App. 1998) - Doe 175 v. Columbia Heights School Dist., 842 N.W.2d 38 (Minn. Ct. App. 2014) **Key People Referenced:** - **Judge Julia Dayton Klein** — Issued the April 12, 2024 order being appealed - **Judge Jay Quam** — Also presides over aspects of the case - **Bruce Rivers** — Current defense counsel; "powerful people" statement - **Michael Biglow** — Former defense counsel; fired by Guertin - **Dr. Jill Rogstad** — Rule 20.01 evaluator; metadata shows Chela Guzman-Weigart as document creator - **Chela Guzman-Weigart** — Administrative figure listed in Rogstad report metadata - **Dr. Adam Milz** — Conducted Jan 3, 2024 6-month review **Forensic Flags:** - Appellate case number A24-0780 established — connects district and appellate proceedings. - "Powerful people keeping an eye on you" statement from Rivers (June 16, 2023 email) — significant if verifiable. - Dr. Rogstad's report metadata listing Chela Guzman-Weigart as creator — directly relevant to prior MCRO forensic reports on document metadata/signatures. - June 14, 2023 continuance based on "non-existent motion" — verifiable in docket data. - Reference to 10 addendums not included (would need to be obtained separately). - Guertin's statement of facts includes his patent (US11577177) and InfiniSet, Inc. — context for why he was building a prototype in his apartment. --- ### FILING #5 | Field | Detail | |---|---| | **Filename** | `MCRO_27-CR-23-1886_Other_Document_2024-05-15_20240516111053.pdf` | | **Date Filed** | May 15, 2024 (filed stamp: 5/15/2024 11:46 AM) | | **Case ID** | 27-CR-23-1886 → Court of Appeals case A24-0780 | | **Filing Type** | Petitioner's Addendum 2 (appellate addendum) | | **Filed By** | Matthew David Guertin (pro se) | | **Addressed To** | Minnesota Court of Appeals (A24-0780) | | **Judicial Officer** | N/A (appellate filing) | | **Pages** | 43 (Addendum pages Add. 1 through Add. 43) | **Detailed Summary:** This is Petitioner's Addendum 2 to the Petition for Discretionary Review (Filing #4, case A24-0780). It packages two previously filed district court documents for the Court of Appeals record: **Part 1 — April 4, 2024 Motion to Compel Discovery and Affidavit of Fact (Add. 1–40):** The complete 40-page motion from Filing #2, including the motion body (7 pages), Affidavit of Fact (Exhibit Af, 2 pages), and all 13 exhibits (A through M, plus Lb). This is the same substantive document cataloged as Filing #2 in this catalog, now re-filed as an appellate addendum. All content matches: the discovery PDF analysis, 80-image aspect ratio table, duplicate photo overlay, barrel distortion analysis, lens center cropping proof, personal comparison photographs, Biglow email chain, and the email to Dr. Milz. **Part 2 — May 3, 2024 Correspondence / Follow-Up Letter (Add. 41–43):** The 3-page follow-up letter from Filing #3, documenting one month of non-acknowledgment for the April 3-4 motions and the continuing failure to provide discovery materials and medical exam reports. The addendum carries the standard appellate header referencing "A24-________" (number not yet assigned at time of filing), Petitioner Matthew David Guertin vs. Respondent State of Minnesota, District Court Case 27-CR-23-1886, Court Order Date April 12, 2024. **Forensic Flags:** - This filing formally introduces the entire discovery fraud evidence package (motion + 13 exhibits) into the appellate record — it is no longer just a district court filing; it is now part of appellate case A24-0780. - The dual filing stamps visible on each page (original dates of 4/4/2024 and 5/3/2024 alongside the 5/15/2024 refiling stamp) provide independent verification of the filing timeline. - The addendum re-packaging confirms that Guertin's appellate strategy explicitly centers the discovery fraud evidence as the factual foundation for his appeal of the pro se denial — the argument being that the court's refusal to address discovery fraud undermines the competency determination that justified denying pro se status. - All exhibits are preserved intact from the original filing — no content has been altered or omitted in the re-filing. - This is the companion to Addendum 3 (Filing #9), filed the same day at the same time, which provides the judicial assignment data analysis. --- ### FILING #6 | Field | Detail | |---|---| | **Filename** | `MCRO_27-CR-23-1886_Other_Document_2024-05-15_20240516111114.pdf` | | **Date Filed** | May 15, 2024 (filed stamp: 5/15/2024 11:46 AM; originally filed to district court 5/3/2024 2:56 PM) | | **Case ID** | 27-CR-23-1886 → Court of Appeals case A24-0780 | | **Filing Type** | Petitioner's Addendum 3 (appellate addendum) — Affidavit of Fact / MCRO Data Analysis | | **Filed By** | Matthew David Guertin (pro se; address: 1075 Traditions Ct., Chaska, MN 55318, Carver County) | | **Addressed To** | Minnesota Court of Appeals (A24-0780); original district court filing addressed to Judge Julia Dayton Klein, Clerk of Court, Jacqueline Perez, Office of Hennepin County Attorney | | **Judicial Officer** | Julia Dayton Klein (district court filing) | | **Pages** | 31 (Addendum pages Add. 1 through Add. 31) | **Detailed Summary:** This is Petitioner's Addendum 3 — a 31-page sworn Affidavit of Fact presenting a data-driven analysis of MCRO (Minnesota Court Records Online) records. Originally filed in district court on May 3, 2024 at 2:56 PM (same day as Filing #3 correspondence, but filed separately at a later time), it was then re-filed as an appellate addendum on May 15, 2024 for case A24-0780. This is the most technically sophisticated filing in the catalog — Guertin used Python scripting and Selenium-based browser automation to systematically download and analyze 3,556 MCRO PDF documents across 163 unique criminal case IDs. **Methodology:** Guertin searched the MCRO "Hearing Search" function for three specific judicial officers — Judge Julia Dayton Klein, Court Referee Danielle C. Mercurio, and Court Referee George Borer — across both "Criminal" and "Probate or Mental Health" case categories, for the date range January 1, 2023 through April 26, 2024. He printed each 200-result search page to PDF, converted to text, and processed with custom Python scripts to identify cases common to all three officers. He then built a Selenium automation script (included in the filing, pp. 19-20) that automated Chrome to navigate to each case timeline page and download every available PDF document. **Core Dataset:** - 163 unique criminal case numbers shared across all three judicial officers - 79 unique defendant names (exact string match); 73 by similar string match; 45 appearing only once - 3,556 total MCRO PDF documents downloaded - Data spans case origination years 2017–2023 **Exhibit A — Shared Judicial Assignments to Cases (Add. 6–20, 15 pages):** Provides the complete methodology, results broken down by origination year, and full lists of all shared criminal cases and shared mental health/probate cases. Key findings include: - Criminal case overlap grows significantly over time: 3 shared cases (2017) → 4 (2018) → 12 (2019) → 20 (2020) → 41 (2021) → 44 (2022) → 39 (2023). - Mental health/probate overlap is minimal (1 case in 2022, 8 in 2023, 1 in 2024) — the shared case concentration is overwhelmingly in criminal proceedings. - The same defendants appear across multiple case IDs repeatedly (e.g., Lucas Patrick Kraskey appears in 7+ shared cases in 2021 alone; Terrell Johnson spans 2019–2023; Gordon Eugene Sharp Jr. spans 2021–2023; Aesha Ibrahim Osman spans 2018–2023). - Guertin's own case (27-CR-23-1886) appears in the 2023 shared cases list. - Complete document-type counts across all shared cases: 488 Rule 20.01 evaluations, 130 Finding of Incompetency orders, 644 Notice of Remote Hearing documents, 238 returned mail items, 136 notice of case reassignment documents. - Zoom meeting ID analysis: Out of 644 "Notice of Remote Hearing" documents, 358 (55.6%) use Meeting ID 160 223 0876, and 520 out of 811 passcode entries (64.1%) use Passcode "1234." - George Borer's February 1, 2024 hearing in Guertin's civil commitment case (27-MH-PR-23-815) cannot be found in Borer's official civil court hearing dates on MCRO — a discoverability gap. **Exhibit B — Circular Handling Analysis (Add. 21–27, 7 pages):** Detailed case-by-case narrative analysis of 10 specific shared criminal cases from 2023, documenting the "circular" or "decision bouncing" pattern where cases are sequentially passed among the same three judicial officers. Each case narrative traces the hearing-by-hearing handoff: 1. **27-CR-23-1600** (Jimmy Edward Spears III): Borer → Klein → Mercurio → Borer → Klein 2. **27-CR-23-385** (Lucas Patrick Kraskey): Borer → Mercurio → Klein → Borer → Mercurio (finding of incompetency → dismissal) 3. **27-CR-23-8649** (Terrell Johnson): Borer → Mercurio → Klein → Mercurio (finding of incompetency); upcoming hearing with Klein Sept 10, 2024 4. **27-CR-23-3198** (Aaron Dashaun Cherry): Borer → Klein → Mercurio → Klein 5. **27-CR-23-512** (Abdinour Mohamed Alasow): Siegesmund → Borer → Klein → Mercurio 6. **27-CR-23-883** (Abdinour Mohamed Alasow): Siegesmund → Borer → Klein → Mercurio (dismissal) 7. **27-CR-23-1658** (Yasmin Ahmed Ali): Borer → Klein → Mercurio (canceled) → Borer 8. **27-CR-23-2152** (Grahm Mark Fletcher): Mercurio → Klein → Mercurio 9. **27-CR-23-3459** (Muad Abdulkadir): Caligiuri → Klein → Borer → Mercurio 10. **27-CR-23-3496** (Abdulkadir Elmi Egal): Borer → Klein → Mercurio (canceled) Additional cases analyzed: 27-CR-23-284 (Mohamed Abdi Shide), 27-CR-23-5751 (Lucas Patrick Kraskey). The analysis highlights that the same three civil/probate court officers (Klein as Judge, Mercurio and Borer as Referees) handle the key decision points in criminal proceedings — the Rule 20.01 evaluation orders, competency findings, bail decisions, and case dispositions — and effectively refer cases to themselves when cases transition from criminal to civil commitment proceedings. **Exhibit C — Incompetency Orders Analysis (Add. 28–31, 4 pages):** A comprehensive table of all 130 "Finding of Incompetency and Order" documents across all shared cases, organized by case origination year (2017–2023). Each row records: Date, Case ID, who ordered the Rule 20.01 exam, who issued the incompetency finding, and the signing judge. Key findings: - Out of 130 incompetency orders, 94 (72.3%) were issued by one of the three officers: Klein (19), Mercurio (38), Borer (37). - 6 instances where the SAME judicial officer who ordered the Rule 20.01 exam also issued the incompetency finding — raising self-referral concerns. - Guertin's own case appears: 27-CR-23-1886, with two entries — (1) July 13, 2023: Rule 20.01 ordered by Lyonel Norris, incompetency finding by George Borer, signed by Michael K Brown; (2) January 17, 2024: Rule 20.01 ordered by Julia Dayton Klein, incompetency finding by Danielle Mercurio, signed by Julia Dayton Klein. - The signing judge column reveals that Michael K Brown signs a large share of the incompetency orders — even when he did not preside over the hearing. Julia Dayton Klein signs the remainder. **Shared Download Folder:** Guertin provides a public Proton Drive link (https://drive.proton.me/urls/QA8TBVTHEC#Wy7ygZMVpev7) containing all downloaded case files in six ZIP archives (one per year, 2017–2023), the Python download script, and supporting data. **Key People Referenced:** - **Judge Julia Dayton Klein** — One of three judicial officers analyzed; also the addressed judge - **Court Referee Danielle C. Mercurio** — One of three judicial officers analyzed - **Court Referee George Borer** — One of three judicial officers analyzed - **Judge Michael K Brown** — Signs disproportionate share of incompetency orders - **Jacqueline Perez** — Prosecuting attorney (addressed on district court filing) - **Kristin Siegesmund** — Initiating judge in some analyzed cases - **Hilary Caligiuri** — Initiating judge in some analyzed cases - Multiple defendants appearing across many shared cases (Terrell Johnson, Lucas Patrick Kraskey, Aesha Ibrahim Osman, Gordon Eugene Sharp Jr., Priest Jesus Dorsey, Makis Devell/Duvell/Devil Lane, etc.) **Forensic Flags:** - This filing is the direct precursor and inspiration for the MCRO forensic database project — Guertin's manual Python/Selenium scraping and analysis is precisely what the DB automates at scale. - The 163 shared case IDs and 3,556 documents establish a verifiable cohort that can be cross-referenced against the MCRO database (`case_registry`, `children`, `parents` tables). - The Rule 20.01 → incompetency order pipeline analysis (Exhibit C) maps directly to existing MCRO forensic reports on Finding of Incompetency Clones, Cluster Event Alignment, and Source Hearings Scheduling Anomalies. - The Zoom meeting ID concentration (358/644 = 55.6% using same ID) and universal passcode "1234" (520/811 = 64.1%) are independently verifiable signals of standardized/templated hearing processes. - George Borer's missing hearing from MCRO for the Feb 1, 2024 civil commitment hearing is a specific, verifiable data gap. - The Python/Selenium script (included in full on pp. 19-20) documents Guertin's technical capability — relevant context for the competency evaluation. - The Proton Drive link provides an independent archive of the raw data for verification. - Name variations across defendants (e.g., Makis Devell Lane / Makis Duvell Lane / Makis Devil Lane) are relevant to entity resolution challenges in the MCRO database. - Guertin's case appearing in the shared case list (27-CR-23-1886) confirms he is part of the exact pattern he is documenting. --- ### FILING #7 | Field | Detail | |---|---| | **Filename** | `MCRO_27-CR-23-1886_Correspondence_2024-06-03_20240604132619.pdf` | | **Date Filed** | June 3, 2024 (filed stamp: 6/3/2024 7:41 AM) | | **Case ID** | 27-CR-23-1886 | | **Filing Type** | Correspondence (brief follow-up letter) | | **Filed By** | Matthew David Guertin | | **Addressed To** | Judge Jay Quam; Judge Julia Dayton Klein; Clerk of Court | | **Judicial Officer** | Jay Quam and Julia Dayton Klein | | **Pages** | 1 | **Detailed Summary:** Brief one-page letter following up on all previous discovery requests and the motion to compel. States that despite "multiple formal requests and a motion to compel discovery," he has still not received the necessary discovery materials. Notes this significantly impairs his ability to prepare for trial and violates his right to due process. References having filed a motion for substitute counsel and a renewed motion to compel discovery (both filed the same day, June 3, 2024). This is now approximately five months since the January 5, 2024 discovery request, two months since the April 4 motion to compel, and one month since the May 3 follow-up letter — all without any response. **Forensic Flags:** - Documents the continuing chain of non-response: Jan 5 → Apr 3-4 → May 3 → Jun 3. - Filed the same day as the Motion for Substitute Counsel (Filing #6). - Now addresses both Judge Quam AND Judge Klein — the circular handling concern. - Five-month documented gap from initial discovery request with zero acknowledgment. --- ### FILING #8 | Field | Detail | |---|---| | **Filename** | `MCRO_27-CR-23-1886_Motion_2024-06-03_20240603092053.pdf` | | **Date Filed** | June 3, 2024 (filed stamp: 6/3/2024 7:33 AM) | | **Case ID** | 27-CR-23-1886 | | **Filing Type** | Motion for Substitute Counsel | | **Filed By** | Matthew David Guertin (pro se; address: 1075 Traditions Ct., Chaska, MN 55318) | | **Addressed To** | Judge Jay Quam; Judge Julia Dayton Klein; Jacqueline Perez, ACA; Clerk of Court; Office of Hennepin County Attorney | | **Judicial Officer** | Jay Quam | | **Pages** | 4 | **Detailed Summary:** Formal motion requesting the court appoint substitute counsel to replace Bruce Rivers. Specifically references the Petition for Discretionary Review filed in the Court of Appeals (case A24-0780) as containing "compelling and irrefutable evidence" of ineffective assistance. Enumerates four categories of failure by Rivers, with specific docket index references: 1. **Failure to provide discovery materials and the Jan 3, 2024 Rule 20.01 exam report** — References Index #30 pp. 37-38, 83, 85, 135; Index #38 p. 143. 2. **Failure to present exculpatory evidence at July 7, 2023 hearing** — References Index #30 p. 60; Index #38 pp. 99-100, 102-103, 113-116, 118-119. 3. **Conflict of interest + "powerful people" statement** — References June 16, 2023 email; Index #30 pp. 22-24, 73-76. 4. **Broken promise to represent in civil commitment proceedings** — References Index #30 pp. 24-25, 77-78, 81-83. Legal arguments cite Strickland v. Washington (1984) for ineffective assistance and the Sixth Amendment right to effective counsel. Also argues the court itself has refused to provide discovery and address motions (procedural failure independent of counsel). Requests appointment of substitute counsel, preferably a public defender, to serve until Guertin can recover the retainer paid to Rivers and secure new representation. Requests new counsel receive ALL discovery materials as part of their assignment. **Key People Referenced:** - **Bruce Rivers** — Defense counsel being replaced - **Judge Jay Quam** — Primary judicial officer on motion - **Judge Julia Dayton Klein** — Also addressed - **Jacqueline Perez** — Prosecuting attorney **Forensic Flags:** - Provides specific docket index references (Index #30, #38, #89) that can be cross-referenced against the court's own docket to verify timeline and content. - The reference to Index #89 as the appellate petition (Exhibit A) allows docket position mapping. - Establishes that discovery failure is attributable to BOTH defense counsel AND the court — dual failure. - Rivers is now the second attorney Guertin has had issues with (after Biglow) — pattern relevant to the "coercion" theory raised in the appellate petition. - Retainer paid to Rivers but services not rendered — potential financial harm dimension. --- ### FILING #9 | Field | Detail | |---|---| | **Filename** | `MCRO_27-CR-23-1886_Notice_of_Motion_and_Motion_2024-06-03_20240603092040.pdf` | | **Date Filed** | June 3, 2024 (filed stamp: 6/3/2024 7:37 AM) | | **Case ID** | 27-CR-23-1886 | | **Filing Type** | Notice of Motion and Motion (Renewed Motion to Compel Discovery) | | **Filed By** | Matthew David Guertin (pro se; address: 1075 Traditions Ct., Chaska, MN 55318) | | **Addressed To** | Judge Jay Quam; Judge Julia Dayton Klein; Jacqueline Perez, ACA; Clerk of Court; Office of Hennepin County Attorney | | **Judicial Officer** | Jay Quam | | **Pages** | 5 | **Detailed Summary:** This is a formal renewed Motion to Compel Discovery filed the same day as the Motion for Substitute Counsel (Filing #6) and the follow-up correspondence (Filing #5). It is a streamlined, legally structured version of the original April 4, 2024 motion (Filing #2), now condensed to 5 pages and framed as a Notice of Motion under Minnesota Rules of Criminal Procedure. The motion opens with an Introduction section reciting the procedural history: (1) formal discovery request to prosecutor Perez on January 5, 2024 (Index #22), (2) pro se Motion to Compel Discovery and Affidavit of Fact on April 4, 2024 (Index #29) highlighting the State's failure and detailing fraudulent alterations, and (3) follow-up correspondence on May 3, 2024 (Index #36) reiterating need for materials. The Background section establishes the chain of requests and non-responses across three specific docket entries. The Legal Basis section cites five specific subdivisions of Minnesota Rule of Criminal Procedure 9.01: subd. 1(3)(b) (written/recorded statements), subd. 1(6) (trial-material evidence), subd. 1a(1) (exculpatory/mitigating evidence), subd. 2(1) (inspection/copy rights). Also invokes Federal Rules of Evidence Rule 901(b)(1) for authentication standards. The Arguments section raises three grounds: (1) Ineffective assistance of counsel — Bruce Rivers failed to secure discovery, impairing defense preparation; (2) Procedural violations — State's failure to provide complete and authentic discovery violates Rule 9.01 and due process under both state and federal constitutions; (3) Need for transparency — full disclosure required to rectify discrepancies and verify authenticity of all evidence. **Request for Relief** seeks three specific actions: (1) Order the State to provide all missing discovery materials forthwith, (2) Conduct a thorough investigation into the discrepancies and manipulations identified by the Defendant, (3) Send all discovery materials directly to the Defendant at MattGuertin@Protonmail.com due to ineffective assistance of current defense counsel. **Key People Referenced:** - **Judge Jay Quam** — Primary judicial officer on motion - **Judge Julia Dayton Klein** — Also addressed - **Jacqueline Perez** — Prosecuting attorney (ACA) - **Bruce Rivers** — Current defense counsel; cited for ineffective assistance in not securing discovery **Forensic Flags:** - This is the THIRD formal motion/request addressing discovery (after Jan 5, 2024 request and Apr 4, 2024 motion) — establishes a documented triple-request with zero court response. - Specifically cross-references the three prior docket index numbers: Index #22 (Jan 5 request), Index #29 (Apr 4 motion), Index #36 (May 3 follow-up) — these are verifiable anchors in the case docket. - Challenges authenticity of discovery materials AND completeness — dual challenge requiring court action. - Request to bypass defense counsel and send materials directly to defendant signals total breakdown in attorney-client relationship. - Filed at 7:37 AM, four minutes after the substitute counsel motion (7:33 AM) and four minutes before the correspondence (7:41 AM) — all three filings were clearly prepared and filed together as a coordinated package on June 3, 2024. - The motion cites Rule 901(b)(1) of the Federal Rules of Evidence (authentication) — positions the discovery issue as not just a disclosure problem but an evidence integrity/authentication problem. --- ### FILING #10 | Field | Detail | |---|---| | **Filename** | `00__Guertin-v-Hennepin-County-0_24-cv-02646__2025-02-12.pdf` | | **Date Filed** | Case filed July 8, 2024; docket retrieved February 12, 2025 (per filename) | | **Case ID** | 0:24-cv-02646-JRT-DLM (U.S. District Court, District of Minnesota) | | **Filing Type** | Complete Federal Case Docket Sheet (CourtListener extract) | | **Filed By** | N/A — court record / reference document | | **Addressed To** | N/A | | **Judicial Officer** | Judge John R. Tunheim (assigned after Judge Jeffrey M. Bryan recused on 7/9/2024); Magistrate Judge Douglas L. Micko | | **Pages** | 21 (covering 96 docket entries) | **Detailed Summary:** This is the complete docket sheet for the federal civil rights action *Guertin v. Hennepin County*, Case 0:24-cv-02646-JRT-DLM, obtained from CourtListener.com. The docket covers 96 entries spanning July 8, 2024 through November 13, 2024. This is the §1983 federal lawsuit Guertin filed after exhausting (and being ignored on) his state-court discovery and procedural motions documented in Filings #1–#9 of this catalog. **Case Initiation (July 8, 2024):** Guertin filed a Complaint (ECF No. 1) and an Emergency Motion for TRO and Immediate Hearing (ECF No. 2) on July 8, 2024, paying the $405 filing fee. Eleven defendants named: Hennepin County (municipal entity), Keith Ellison (MN AG, official capacity), Mary Moriarty (Hennepin County Attorney, official capacity), Chela Guzman-Weigart (Asst. County Administrator, official capacity), Julia Dayton-Klein (individual capacity), George F. Borer (individual capacity), Danielle C. Mercurio (individual capacity), Dr. Jill Rogstad (official capacity, Senior Clinical Forensic Psychologist), Dr. Adam Milz (official capacity, Hennepin County Mental Health), Jacqueline Perez (official capacity, ACA), and Bruce M. Rivers (individual capacity). Case initially assigned to Judge Jeffrey M. Bryan, who recused one day later (ECF No. 5, July 9, 2024) and reassigned to Judge John R. Tunheim. **Exhibits Filed (July 12–16, 2024):** Guertin filed a massive exhibit package between July 12 and July 16, labeling them Exhibits A through R. Key exhibits include: Exhibit A (ECF No. 8) — key documents from 27-CR-23-1886; Exhibits B–D (ECF Nos. 9–11) — Affidavits of Fact and motions for judicial notice filed in state court; Exhibit E (ECF No. 12) — chronological cell phone image presentation (250+ images) demonstrating competence and patent-related business activity; Exhibits F–J (ECF Nos. 13–17) — all records from MN Court of Appeals case A24-0780 including 10 addenda; Exhibit K (ECF No. 18) — civil commitment case 27-MH-PR-23-815 records; Exhibit L (ECF No. 19) — image analysis of purported Light Stage 6 at USC; Exhibits M–N (ECF Nos. 20–21) — investigation into alleged IP theft of US Patent 11,577,177; Exhibit O (ECF No. 22) — "The Minnesota Appellate Deception" presentation; Exhibit P (ECF No. 23) — "Conspiracy of Commitment" chronological analysis; Exhibit Q (ECF No. 24) — digital version of original complaint; Exhibit R (ECF No. 25) — digital version of original TRO motion (see Filing #11). **TRO Denied (July 16, 2024):** Judge Tunheim denied the TRO motion (ECF No. 26) via memorandum opinion on July 16, 2024. **Defendants Appear and Move to Dismiss (July 26 – August 2, 2024):** Two groups of defendants appeared through counsel: (1) Borer, Dayton-Klein, Ellison, Mercurio, Milz, Rogstad — represented by Benjamin Harringa (AAG), filed Motion to Dismiss (ECF No. 29) on August 1, 2024; (2) Guzman-Weigart, Hennepin County, Moriarty, Perez — represented by Jamil M.F. Masroujeh (ACA) and later Matthew Lloyd Robert Messerli, filed first Motion to Dismiss (ECF No. 35) on August 2, 2024. Pretrial scheduling delayed pending resolution of dismissal motions (ECF No. 41, Aug 5, 2024). **Motion for Preliminary Injunction — Discovery Fraud (August 7, 2024):** Guertin filed a Motion for Preliminary Injunction (ECF No. 42) centered on "Irrefutable Evidence of FRAUDULENT DISCOVERY MATERIALS" provided by Bruce Rivers on July 16, 2024. Supported by Exhibits S–X (ECF Nos. 43–48). Exhibit T (ECF No. 44) contains Guertin's forensic analysis of photographs using color curve methodology, alleging AI-generated image manipulation focused on obscuring his laptop screen. Exhibit U (ECF No. 45) continues the analysis. Exhibit V (ECF No. 46) provides control group images without manipulation plus image metadata proving camera origin. Exhibit W (ECF No. 47) contains estimated patent value analysis, Bruce Rivers' "powerful people" comment documentation, text message history, and chronological competence demonstration. Exhibit X (ECF No. 48) shows the InfiniSet Treadmill System prototype design/fabrication process. **Guertin's Oppositions to Dismissal (August 14, 2024):** Guertin filed a Memorandum in Opposition to both motions to dismiss (ECF No. 54), exhibit lists (ECF Nos. 49–51), and an Application for Entry of Default against Bruce Rivers (ECF No. 52, refiled as ECF No. 63 on Aug 18). Guertin also filed a Notice of Interlocutory Appeal to the 8th Circuit (ECF No. 55) appealing the TRO denial. **Continuing Discovery Fraud Exhibits (September–October 2024):** Guertin continued filing exhibits: Exhibit Y (ECF No. 74) — strategic legal reasoning regarding discovery fraud "trap"; Exhibit Z (ECF No. 75) — proof of Rivers' knowledge of the case, phone call after entry of default, Rivers' refusal to withdraw, Guertin emailing 57 MN judges; Exhibit AA (ECF No. 77) — complaint to MN Office of Lawyers Professional Responsibility against Rivers; Exhibit AB (ECF No. 78) — video of Jan 3, 2024 Rule 20.01 exam with Adam Milz; Exhibit AC (ECF No. 79) — three pro se motions filed in state district court Sept 25, 2024; Exhibits AD–AI (ECF Nos. 81–86) — "FRAUD Rounds 1 and 2" forensic analyses alleging AI-generated fraudulent prior art on Guertin's patent, YouTube backdating, Internet Archive involvement, and USC/Netflix/military connections. **Case Dismissed (September 30, 2024):** Judge Tunheim granted both motions to dismiss (ECF No. 80), denied the preliminary injunction motion (ECF No. 42), and denied Guertin's Motion to Alter/Amend/Supplement Pleadings (ECF No. 69). Case dismissed without prejudice under *Younger v. Harris*, 401 U.S. 37 (1971) — federal abstention doctrine requiring abstention from interference with ongoing state court proceedings. Judgment entered October 1, 2024 (ECF No. 87). **Rivers Default Vacated / Appeal Dismissed (October–November 2024):** Bruce Rivers appeared through counsel Daniel J. Cragg on October 7, 2024 (ECF No. 88) and moved to vacate the entry of default (ECF No. 89). The 8th Circuit dismissed Guertin's interlocutory appeal for lack of jurisdiction on October 17, 2024 (ECF No. 95), with mandate issued November 13, 2024 (ECF No. 96). **Key People Referenced (new to this filing):** - **Judge John R. Tunheim** — Presiding federal judge; issued all substantive rulings - **Judge Jeffrey M. Bryan** — Originally assigned; recused July 9, 2024 - **Magistrate Judge Douglas L. Micko** — Assigned magistrate - **Benjamin Harringa** — AAG representing state defendants (Borer, Dayton-Klein, Ellison, Mercurio, Milz, Rogstad) - **Jamil M.F. Masroujeh** — ACA representing county defendants (Guzman-Weigart, Hennepin County, Moriarty, Perez) - **Matthew Lloyd Robert Messerli** — Additional counsel for county defendants - **Daniel J. Cragg** — Attorney for Bruce Rivers - **Keith Ellison** — MN Attorney General (defendant in official capacity) - **Mary Moriarty** — Hennepin County Attorney (defendant in official capacity) **Forensic Flags:** - The *Younger* abstention dismissal is a procedural outcome — it does not address the merits of Guertin's fraud allegations. The court explicitly did not rule on whether the discovery materials were fraudulent; it ruled only that a federal court cannot intervene in pending state proceedings. - The docket reveals Guertin filed Exhibits AD–AI (ECF Nos. 81–86) on the same day the case was dismissed (Sept 30, 2024) — he was still actively submitting forensic evidence as the court dismissed. - Bruce Rivers retained private counsel (Daniel Cragg) to defend against the federal suit and vacate the default — demonstrating Rivers took the case seriously as a personal legal threat. - Judge Bryan's immediate recusal (next business day) is notable — no reason stated on docket. - The complete exhibit inventory (A through AI, 35+ individual exhibit filings) establishes the full scope of evidence Guertin submitted to the federal court. Many of these exhibits likely contain documents from the state court record that are not yet in this catalog. - Entry of Default against Rivers (ECF No. 71, Aug 29, 2024) — Rivers failed to answer or appear for nearly two months despite personal service on July 12, 2024. - Guertin emailed 57 Minnesota judges to raise awareness of this case (per Exhibit Z description) — demonstrates escalation pattern. - The video of the Jan 3, 2024 Rule 20.01 exam with Adam Milz (Exhibit AB, ECF No. 78) is potentially the most significant piece of evidence — it allows direct comparison of what Guertin actually said vs. what Milz reported. Docket description states it shows Guertin discussing the patent theft allegations and criminal charge origins "in great detail" during the interview, contradicting Milz's report finding incompetence. - Exhibits AD–AI represent a second layer of fraud allegations beyond discovery manipulation: AI-generated prior art on the patent, YouTube content backdating, and institutional involvement (USC, Netflix, US military). These are separate from the discovery fraud track but may be relevant context. --- ### FILING #11 | Field | Detail | |---|---| | **Filename** | `02__EXHIBIT-R__ORIGINAL-MOTION-FOR-EMERGENCY-TRO__DIGITAL.pdf` | | **Date Filed** | July 16, 2024 (digital refiling of paper original filed July 8, 2024) | | **Case ID** | 0:24-cv-02646-JRT-DLM (ECF No. 25); references 27-CR-23-1886 and 27-MH-PR-23-815 | | **Filing Type** | Exhibit R — Digital version of Emergency Motion for TRO and Immediate Hearing, with attached state-court exhibits | | **Filed By** | Matthew David Guertin (pro se; address listed as both 1075 Traditions Ct., Chaska, MN 55318 and earlier Plymouth address) | | **Addressed To** | U.S. District Court, District of Minnesota (Judge Tunheim) | | **Judicial Officer** | Judge John R. Tunheim (federal); references Judge Jay Quam, Judge Julia Dayton Klein (state) | | **Pages** | 46 | **Detailed Summary:** This is ECF No. 25 in the federal case — a digital refiling of Guertin's original paper Emergency Motion for TRO and Immediate Hearing that was hand-delivered to initiate the case on July 8, 2024. The digital version restores bookmarks, hyperlinks, and searchability lost in the paper filing process. It contains the TRO motion itself (7 pages) plus 39 pages of attached exhibits drawn from the state criminal and civil commitment case records. **TRO Motion Body (pp. 1–9 of Exhibit R):** The motion is brought under 42 U.S.C. § 1983 (civil rights), 42 U.S.C. § 1985 (civil conspiracy), and 18 U.S.C. § 1343 (wire fraud). Claims include due process violations, ineffective assistance of counsel, denial of access to courts, judicial misconduct, fraud on the court, civil conspiracy, gross negligence, and forgery. The motion is organized into ten sections: (I) not present in text; (II) Compelling Evidence of Fraud — alleges clear forensic evidence of fraud with documented photo count discrepancies between two critical reports; both fraudulent documents stored in Guertin's email inbox and emailed to him by attorneys; proposes forwarding emails to court/forensic investigator to maintain digital chain of custody; (III) Digital Chain of Custody — proposes email forwarding for evidence authentication; (IV) Request for Authentic Discovery — requests court order for Hennepin County to produce authentic materials; (V) Immediate and Irreparable Harm — cites imminent July 16, 2024 hearing, risk of retaliation, potential for court to "silence or eliminate" plaintiff; (VI) Legal Arguments — likelihood of success on merits, irreparable harm, balance of equities, public interest (standard TRO factors); (VII) Supporting Case Law; (VIII) Conclusion; (IX) Attached Exhibits; (X) Prayer for Relief. Case law cited: Ashcroft v. Iqbal, 556 U.S. 662 (2009); Hager v. Arkansas Dep't of Health, 735 F.3d 1009 (8th Cir. 2013); Elrod v. Burns, 427 U.S. 347 (1976); Phelps-Roper v. Nixon, 545 F.3d 685 (8th Cir. 2008); General Motors Corp. v. Harry Brown's, LLC, 563 F.3d 312 (8th Cir. 2009); Iowa Utilities Board v. FCC, 109 F.3d 418 (8th Cir. 1996); Child Evangelism Fellowship of Minnesota v. Minneapolis Special Sch. Dist. No. 1, 690 F.3d 996 (8th Cir. 2012); Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008). Prayer for Relief seeks: (A) TRO halting ongoing fraudulent actions and proceedings in 27-CR-23-1886; (B) Court order demanding production of authentic discovery materials from Hennepin County District Court; (C) Expedited in-person hearing before the July 16, 2024 review hearing. **Attached State-Court Exhibits (pp. 10–46):** The TRO motion attaches key state-court filings and communications as exhibits. Many of these are documents already cataloged from their original state-court filings, but several contain new content or communications not previously in the catalog: | Exhibit Label | ECF Page | State Case Index | Content | Catalog Cross-Reference | |---|---|---|---|---| | Exhibit A, Index 22 | pp. 10 | 27-CR-23-1886, Index #22 | Jan 5, 2024 Discovery Request to Perez | = Filing #1 | | Exhibit K | pp. 11 | 27-CR-23-1886, Index #38, p.144 | Apr 3, 2024 email from Guertin to Rivers: "NOTICE OF DISMISSAL AS DEFENSE COUNSEL" + Rivers reply "Call me" | **NEW — not previously cataloged as standalone** | | Exhibit Ka | pp. 12 | 27-CR-23-1886, Index #38, p.145 | Rivers' reply email with full PGP/DKIM email headers (authentication chain: AOL → ProtonMail, DKIM pass) | **NEW — email authentication data** | | Exhibit A, Index 27 | pp. 13–20 | 27-CR-23-1886, Index #27 | Apr 3, 2024 Motion to Represent Self Pro Se (8 pages) — includes Exhibit A (Waiver, dated 1/31/2024, signed by Guertin, attorney Joel Fisher) and Exhibit B ("Acceptance of Terms of Stay of Commitment," p.4, showing "N/A" on Court Examiner Michael Robertson's competency certification signature line) | **NEW — pro se motion not previously in catalog; waiver and commitment acceptance terms are significant** | | Exhibit A, Index 33 | pp. 21–22 | 27-CR-23-1886, Index #33 | Order Denying Defendant's Motion to Represent Self Pro Se, signed by Judge Julia Dayton Klein (undated on document but referenced as April 12, 2024 in other filings). Findings: charged with felony reckless discharge of firearm + 3 counts receive/possess no serial number; first found incompetent July 13, 2023 (Rule 20.01); second evaluation ordered Nov 15, 2023 by Klein, again found incompetent Jan 17, 2024. Concludes defendant lacks ability to waive counsel per Minn. R. Crim. P. 20.01 subd. 1 and Godinez v. Moran. Orders Bruce Rivers to proceed as attorney of record. Sets July 16, 2024 six-month review hearing. | **NEW — the actual order being appealed in A24-0780; not previously in catalog** | | Exhibit A, Index 36 | pp. 23–25 | 27-CR-23-1886, Index #36 | May 3, 2024 Correspondence | = Filing #3 | | Exhibit A, Index 90 | pp. 26–30 | 27-CR-23-1886, Index #90 | Jun 3, 2024 Motion to Compel Discovery | = Filing #7 | | Exhibit A, Index 91 | pp. 31–34 | 27-CR-23-1886, Index #91 | Jun 3, 2024 Motion for Substitute Counsel | = Filing #6 | | Exhibit A, Index 92 | pp. 35 | 27-CR-23-1886, Index #92 | Jun 3, 2024 Correspondence | = Filing #5 | | Exhibit D, Index 38, p.148 / Exhibit L | pp. 36 | 27-CR-23-1886, Index #38 | Apr 18, 2024 text message from Guertin to Rivers requesting withdrawal + Rivers reply "Call me"; also text from Jan 28–29, 2024 ("Bruuuuuuce" / "Matthew?" / "Yes" / "Tis me"). Screenshot evidence of attempts to dismiss counsel. | **NEW — text message screenshots not previously cataloged** | | Exhibit N, Index 04 | pp. 37–42 | Federal case exhibit | Jun 6, 2024 detailed text message exchange between Guertin and Rivers. Guertin: demands Rivers withdraw, requests public defender, demands discovery and Rule 20 exam report. Rivers: "What did I do to you?" / "Where do I send your file?" Guertin sends lengthy message laying out Strickland analysis, discovery fraud allegations, Rivers' "powerful people" statement, LinkedIn search pattern analysis (US Air Force, State Department, Lockheed Martin, DARPA, DIA, USINDOPACOM, KBR, USC School of Cinematic Arts, US Army Reserves), and accuses Rivers of being "compromised." | **NEW — extensive text exchange; most detailed direct communication between Guertin and Rivers in catalog** | | Exhibit Sa / Exhibit B, Index 28 | pp. 43–44 | 27-CR-23-1886, Index #28 | Metadata analysis of Dr. Jill Rogstad's March 10, 2023 Rule 20 Report: ExifTool output showing Author: "GuzmanC", Creator: "GuzmanC", Title: "Guertin Report.pdf", Create Date: 2023:03:10 16:25:34, Producer: Acrobat Distiller 22.0 (Windows). Notes Producer does not include E-File "iText" metadata. Identifies "GuzmanC" as Chela Guzman-Wiegert (Asst. County Administrator, Law Safety & Justice). Includes Hennepin County CJCC committee member list showing Guzman-Wiegert's role. | **NEW — full metadata analysis with ExifTool output not previously in catalog at this detail level** | | Exhibit Vb / Exhibit Wb, Index 28 | pp. 45–46 | 27-CR-23-1886, Index #28 | Hennepin County Criminal Justice Coordinating Committee (CJCC) member list and Office of County Administrator page showing Chela Guzman-Wiegert's role, contact info, and position description. Also lists appointed officials including Chief Public Defender (Vacant). | **NEW — establishes Guzman-Wiegert's institutional position and CJCC connections** | **Key People Referenced (new to this filing or with new detail):** - **Joel Fisher** — Attorney ID# 29579; attorney who advised Guertin on the Jan 31, 2024 waiver extending Stay of Commitment by 9 months - **Michael Biglow** — Referenced as "court-appointed attorney" who signed Acceptance of Terms of Stay of Commitment in Aug 2023 - **Michael Robertson** — Court Examiner whose competency certification on the Acceptance of Terms was marked "N/A" instead of being signed - **Referee Lyonel Norris** — Found probable cause on Jan 25, 2023 (referenced in pro se denial order) - **Judge Michael K Brown** — Referenced in pro se denial order context (signed first incompetency finding July 13, 2023) **Forensic Flags:** - **Rogstad Report Metadata — "GuzmanC" authorship:** This filing provides the most detailed presentation of the Dr. Rogstad Rule 20.01 report metadata anomaly. The ExifTool output unambiguously shows the PDF Author and Creator fields are "GuzmanC" — not "Rogstad" or any variant. Chela Guzman-Wiegert is the Assistant County Administrator for Law, Safety, and Justice and serves as the county administration's liaison to the Fourth Judicial District Court. The document title in metadata is "Guertin Report.pdf." The absence of the E-File "iText" metadata stamp (normally added when documents are e-filed through the court system) suggests the PDF may have been created outside the standard court filing pipeline. This is a primary forensic flag: a forensic psychological evaluation report "respectfully submitted" by Dr. Rogstad was apparently authored/created by an administrative official with oversight of the entire justice system, not by the evaluating psychologist. - **Robertson "N/A" Competency Certification:** The Acceptance of Terms of Stay of Commitment (August 2023) contains a line for Court Examiner Michael Robertson to certify that the respondent is competent to understand the agreement. This line was filled with "N/A" rather than Robertson's signature — yet the agreement was executed and filed anyway. Guertin argues this creates a paradox: he was deemed competent enough to sign a binding legal agreement waiving hearing rights (without examiner verification), but simultaneously deemed too incompetent to represent himself in his own criminal case. - **Waiver Asymmetry:** The Jan 31, 2024 waiver (extending commitment stay 9 months) was signed by Guertin in consultation with attorney Joel Fisher, who certified Guertin understood his rights. This was AFTER the second incompetency finding (Jan 17, 2024) — meaning the court accepted a waiver of rights from someone it had just declared incompetent to waive counsel. This directly supports Guertin's "inconsistent competency standards" argument in his pro se motion. - **Text Message Evidence Chain:** The text messages (Apr 18, Jun 6, 2024) provide contemporaneous, datestamp-verifiable evidence of Guertin's repeated attempts to dismiss Rivers and Rivers' minimal/non-responsive replies. The Jun 6 exchange is particularly significant because it documents Guertin's detailed articulation of the Strickland standard, discovery fraud analysis, and the LinkedIn surveillance pattern — all while he is officially classified as incompetent to understand legal proceedings. - **LinkedIn Search Pattern:** Guertin's Jun 6 text to Rivers details searches of his LinkedIn profile by: US Air Force (4x), US State Department, Lockheed Martin (2x), Forcepoint, 3Gimbals (same day as criminal charges), DARPA (2x), Defense Intelligence Agency, USINDOPACOM, KBR Inc, USC School of Cinematic Arts (2x), US Army Reserves. If verified, this pattern of institutional interest in a patent holder who is simultaneously being declared incompetent and civilly committed is directly relevant to the "external entity involvement" issue raised in the appellate petition. - **Document repackaging for federal court:** This Exhibit R assembles and re-packages key state court filings into the federal record. It serves as a "greatest hits" compilation of the discovery fraud evidence trail, making it accessible to the federal court in a single document. The exhibit labeling system (A, K, Ka, L, N, Sa, Vb, Wb) differs from the state court index numbering, creating a cross-referencing challenge — but the state court index numbers are preserved on each page. - **CJCC Committee Overlap:** The committee member list places Guzman-Wiegert, Mary Moriarty (County Attorney), and the Chief Judge of the Fourth Judicial District on the same coordinating committee. Multiple defendants in the federal case sit on this same committee — relevant to the civil conspiracy claims under §1985. --- ### FILING #12 | Field | Detail | |---|---| | **Filename** | `42__GUERTINS-MOTION-FOR-EXPEDITED-PRELIMINARY-INJUNCTION.pdf` | | **Date Filed** | August 7, 2024 | | **Case ID** | 0:24-cv-02646-JRT-DLM (U.S. District Court, District of Minnesota) — related to state criminal case 27-CR-23-1886 and civil commitment case 27-MH-PR-23-815 | | **Filing Type** | Emergency Motion for Expedited Preliminary Injunction and Immediate Judicial Intervention | | **Filed By** | Matthew David Guertin (pro se; address: 1075 Traditions Ct., Chaska, MN 55318; phone: 763-221-4540; email: MattGuertin@protonmail.com) | | **Addressed To** | U.S. District Court for the District of Minnesota | | **Judicial Officer** | Judge John R. Tunheim (JRT); Magistrate Judge Douglas L. Micko (DLM) | | **Docket Entry** | Doc. 42 | | **Pages** | 89 | | **Word Count** | 11,446 (per certificate of compliance, excl. caption/signatures) | **Detailed Summary:** This is the most comprehensive single filing in the catalog — an 89-page emergency motion for preliminary injunction filed in federal court (Doc. 42 in case 24-cv-02646-JRT-DLM). It is filed in response to discovery materials provided to Guertin by Bruce Rivers on July 16, 2024, following a review hearing. The motion synthesizes the full scope of Guertin's discovery fraud claims, patent fraud allegations, surveillance evidence, psychological evaluation challenges, and defense counsel complaints into a single document seeking immediate federal intervention to prevent forced commitment and antipsychotic medication. The motion is organized into sixteen sections (I–XVI). Key substantive sections are summarized below: **Section II — Evidence of Discovery Fraud (pp. 4–17):** This section presents the core discovery fraud analysis based on the *new* set of discovery materials provided by Bruce Rivers on July 16, 2024. This is distinct from the earlier Biglow discovery set analyzed in Filing #2 — this is a second, independent set of discovery images totaling 518 images (compared to the original 80-image PDF from Biglow). Key claims: 1. **Manipulated and Missing Images (¶¶ 21–24):** Images taken inside Guertin's apartment exhibit non-standard aspect ratios, consistent with the earlier analysis. The new Rivers set shows "significant variations in laptop icons, corner shapes, and hard drive icons" across photos that should be uniform. Reference: Exh. S, Index 05 (pp. 1–21). A probability calculation claims the alignment of missing images with those previously identified as manipulated is "astronomically low." Reference: Exh. S, Index 03 (pp. 1–4). Guertin produced a video presenting the fraud analysis, hosted at a Proton Drive URL. 2. **Forensic Analysis and AI Manipulation (¶¶ 25–26):** Forensic analysis of the new images revealed different-sized icons and pixelation anomalies. EXIF metadata for image `23-0098_0012_520-TRS_DSC_0209.JPG` lists: Camera: NIKON D7200, Lens: 18-55mm f/3.5-5.6, Lens ID: AF-P DX Nikkor 18-55mm f/3.5-5.6G VR, Creator Tool: NIKON D7200 Ver.1.02, Modification Date: 2023:01:21 14:23:00-06:00. Guertin claims the metadata "should have been captured directly from the camera" and is "fraudulent." He asserts the anomalies prove "advanced AI technology" manipulation. Reference: Exh. T (pp. 1–19). Visual evidence includes: Image 290 from the Rivers discovery shown in multiple color curves, mask overlays revealing icons "bleeding" over window borders, and pixelization anomalies isolated to window menu areas. 3. **Chain of Custody (¶¶ 27–28):** The new discovery was provided directly by Bruce Rivers, establishing a "direct line of responsibility." Guertin argues the consistency of manipulated images across both the Biglow set and the Rivers set indicates coordinated effort. Reference: Exh. S, Index 04 — includes a table cataloging images by page/image number, pixel dimensions, aspect ratio, location (all "inside-Guertin-residence"), and whether corresponding images exist in the Rivers discovery set, with numerous entries marked "MISSING." 4. **Obscured Laptop Screen (¶¶ 34–40):** Claims the laptop screen in discovery photos is being intentionally covered by "fraudulent windows" to prevent viewing a notepad file reading: "The person in the photo is who welded my unit for me. He claimed to be with the CIA — either way they have obviously been tracking me and involved with my project every step of the way." Guertin claims this text referenced a welder with a proven military background (shown with military memorabilia including "Welcome to Khowst" sign and USMC patch). The welder's equipment included what Guertin identifies as ODF Optronics gear (Israeli defense optics company). Reference: Exh. C, Index 30 (pp. 60–61); Exh. A, Index 29. 5. **Intentional Exclusion of Professional Workflow (¶¶ 41–44):** The initial Biglow discovery appeared to systematically exclude items indicating a professional workspace: Herman Miller chair, professional workstation, desk, monitor, startup books, light boxes, black fabric roll, wire-frame parts shelf. The new 518-image Rivers set now includes images showing these items, which Guertin argues confirms the earlier set was selectively edited. Comparison photos from Guertin's personal collection (dated June–December 2022) are referenced. Reference: Exh. A, Index 29 (p. 35). **Section III — Who is Matthew Guertin (pp. 18–21):** A biographical narrative establishing Guertin's background: born to 18-year-old mother, never met father, raised in shelters/foster homes including St. Joseph's Home for Children (St. Paul, MN), spent time in Springfield Academy (South Dakota), Anoka group home. Despite this, he built a career in event production (DJ, promoter, lighting/production designer for Minneapolis clubs starting ~2006). Criminal history described as non-violent (disorderly conduct, DWI, party ordinance violations), with his last prior incident in July 2008 (a $500 bar window break that escalated to felony but was reduced via diversion program). The 2009 overpass incident is reframed: Guertin attended a rave, took LSD, had a bad trip, called police on himself, then panicked when they arrived and climbed an overpass fence to "escape" (not to jump). He was taken to HCMC and held 72 hours, then released as non-suicidal. He subsequently achieved engineering credits in major publications, traveled internationally, and developed US Patent 11,577,177 ("InfiniSet"). Reference: www.MattGuertin.com; Exh. X. **Section IV — Discrediting March 2023 Exam Report (pp. 22–29):** Point-by-point challenge to Dr. Jill Rogstad's March 2023 Rule 20.01 exam report. Key arguments: - Claims Guertin's patent (US 11,577,177) is listed at the top of Netflix's patent US 11,810,254 (granted Nov 7, 2023) due to Guertin's third-party prior art submission, contradicting the "delusional" label for his corporate theft claims. - Rogstad's report allegedly disregarded Guertin's portfolio website (www.MattGuertin.com), email proof of engineering credits in major publications, and the context of his initial email to Rogstad (dated Feb 13, 2023). Reference: Exh. B, Index 28 (pp. 105–108); Exh. D, Index 38 (pp. 113–116). - Rogstad allegedly omitted Police Report #23-000151 (Jan 12, 2023) where Officer Brandon Harris confirmed Guertin had "proof of the fraud" after a 45-minute review session. Reference: Exh. B, Index 28 (pp. 78–80). - Claims Rogstad "falsely claims" Guertin threatened to jump from an overpass in 2009, reframing this as the LSD incident described in Section III. - Rogstad is said to admit lacking specialized knowledge to understand Guertin's patent, yet labels his statements as delusional. - Guertin's statement about isolating to work on his invention was allegedly "twisted" into unhealthy behavior; his admission of additional Adderall doses during project crises (e.g., repairing Bad Bunny's 2019 Coachella set piece after forklift damage) was allegedly misrepresented as "misuse." Reference: Exh. B, Index 28 (p. 29); Exh. F, Index 27 (pp. 32–33). **Section V — Discrediting June 2023 Witness Statement (pp. 30–35):** Challenges a June 12, 2024 witness statement prepared by ACA Jacqueline Perez summarizing Dr. Rogstad's testimony. Reference: Exh. S, Index 13 (pp. 1–2). Key challenges: - Statement says Rogstad was "not entirely sure" why a prior civil commitment was not completed, but Rogstad's own report states it "was not supported" and was attributed to substance use/intoxication. Guertin alleges the witness statement is "blatantly false." - Statement alleges Guertin "acknowledges he has been hospitalized... for substance use and suicide attempts." Guertin categorically denies ever acknowledging suicide attempts and says this is fabricated. - Statement says threats were real and Guertin has evidence — Guertin agrees and cites the police report and Rivers' "powerful people" comment. Reference: Exh. W, Index 03 (pp. 1–4). - Statement attributes delusions to ADHD medication misuse, which Guertin contests given that all supposed delusions have been proven true. - Statement contains recommendation for antipsychotic medication, which Guertin characterizes as "clear and irrefutable evidence of the intentions and the imminent danger." - Statement contains self-contradiction on patents: Rogstad says "even if he did have patents approved, this would not change her mind" because her opinion is "based on delusional beliefs and not the patents themselves" — yet the patents are allegedly part of the delusional beliefs. **Section VI — Discrediting January 2024 Exam Report (pp. 35–44):** Point-by-point rebuttal of Dr. Adam Milz's January 2024 Rule 20.01 exam report. Reference: Exh. S, Index 10 (pp. 1–6). Key challenges: - Substance use history described as misleading; Guertin admits past experimentation but no ongoing abuse. - Adderall narrative misrepresents a specific 2019 instance as ongoing misuse. - Adolescent substance treatment cited despite Guertin being 43 years old (decades removed). - Milz reports "history of psychosis" that Guertin says is contradicted by a letter from his longtime California doctor stating "no history of psychotic or psychosis disorders." Reference: Exh. C, Index 30 (pp. 113–114). - Milz's statement that Guertin "has a history of threatening to harm himself" is characterized as "blatantly false." - Milz diagnoses delusional disorder but Guertin notes his continued business competence: opening a corporate bank account and pursuing manufacturing in Vietnam during the stayed commitment order. Reference: Exh. S, Index 08 (p. 4). - Milz's report notes a conflict of interest with Bruce Rivers being a "big YouTube star," which Guertin connects to his claims about YouTube backdating videos. **Section VII — Substantial Evidence of Patent Fraud Claims (pp. 44–57):** Presents the patent fraud evidence in detail: - US Patent 11,577,177 (Guertin) is cited at the top of Netflix's US Patent 11,810,254 (Trojansky, filed Mar 30, 2022 — 12 days after Guertin's Mar 18, 2022 filing). Reference: Exh. B, Index 28 (pp. 90–95, 134–158). - Information Disclosure Statement naming Microsoft and Dimension Studios. Reference: Exh. B, Index 28 (pp. 130–132). - Patent value estimate: $10.1B/year across gaming ($1B), film ($100M), military ($1B), and metaverse ($8B), totaling $202B over 20 years; conservative estimate of $150B. Reference: Exh. W, Index 02 (pp. 1–5). - Patent attorney Amanda Prose (Westman Champlin & Koehler) emailed Guertin on Jan 6, 2023 advising him to file a complaint through IC3.gov. Reference: Exh. C, Index 30 (p. 107). - Patent attorney confirmed the Netflix patent was for "the exact same thing." Reference: Exh. D, Index 38 (pp. 66–67). **YouTube Backdating Evidence (¶¶ 188–202):** Guertin presents age-discrepancy comparisons across YouTube videos related to Paul Debevec and USC's Light Stage technology: - "Light Stage: Amazing avatars worthy of the Army, and Hollywood" (YouTube upload date: 6/2/2015) - "Munich SIGGRAPH Chapter: Light Fields & Presidential Scanning 2015" (SIGGRAPH 2015) - "Digitizing Photorealistic Humans Inside USC's Light Stage" (8/22/2016) - "Light Field Imaging: The Future of VR-AR-MR-Part 1: Paul Debevec" (11/25/2015) - "OTOY | GTC – The Convergence of Cinema and Games" (5/18/2013) - "How USC's Automultiscopic 3D Display Works" (9/5/2016) — labeled "FRAUD" with links to Adam Savage/Norman Chan/Tested.com, OTOY/Octane Render/Jules Urbach. - "Overview: USC ICT Graphics Lab" (YouTube date: 8/14/2014; metadata creation date: 2023:07:18 01:52:26) — alleged to show two differently aged versions of Paul Debevec in the same outfit within the same video. Reference: Exh. N, Index 01 (pp. 9–12, 49–52). **Section VIII — Substantiating Surveillance Claims (pp. 58–67):** Presents the LinkedIn search graph analysis, covering 31 months and correlating LinkedIn profile searches with key case events. Key entities and searches: | Date | Entity Searching | Connection Claimed | |---|---|---| | 3/30/2021 | (Trojansky files provisional) | 17 LinkedIn searches in surrounding week | | 4/19/2021 | Fox Entertainment / Fox Network Group | Parent company: Walt Disney Company | | 3/18–3/30/2022 | (Guertin files patent application; Netflix files 12 days later) | 19 searches the week Netflix files | | 4/16/2022 | Inhance Digital | Clients: US Air Force, Microsoft, Booz Allen | | 4/23/2022 | Gentle Giant Studios | Clients: Netflix, Marvel; linked to MOVA Contour/Paul Debevec | | 5/21/2022 | Uptv | Parent: InterMedia Advisors; led by Tom Daschle (Air Force ties), Alan Sokol (Netflix ties) | | 1/21/2023 | Forcepoint, FOX, 3Gimbals | Same week as criminal charges; Forcepoint: defense cybersecurity (formerly Raytheon); 3Gimbals: defense analytics (TS-SCI cleared) | | 4/8/2023 | Triple Inc. | Aircraft parts; connected to Raytheon (Forcepoint parent) | | 7/7/2023 | Spillt | Direct connection to CNN and Netflix | | 7/20/2023 | (Civil commitment order filed) | 25 searches — all-time LinkedIn search record | | 8/1–8/3/2023 | (Civil commitment hearing; discovers Netflix fraud) | DARPA/DIA/INDOPACOM searches (7 total) | | 8/11/2023 | State Department & 4th U.S. Air Force | 18 searches — 3rd most in LinkedIn history | | 9/28/2023 | Henry Street Settlement & DARPA | Jeremy Reiss (EVP) = Fulbright Specialist with State Dept | | 11/28/2021–8/11/2023 | U.S. Air Force | Multiple searches across span | Forcepoint advisory board is documented showing members from NSA/DoD (Marianne Bailey, Richard Schaeffer), CIA (Robert Bigman), USCYBERCOM (Major General Joseph Brendler), NASA/DHS/USPTO/GSA (Deborah Diaz), DoD/U.S. Navy (Rear Admiral William Leigher), DHS/FDIC/PBGC/DOC/FEMA/NWS/GSA (Barry West), DoD (Chris Williams). Reference: Exh. N, Index 02 (pp. 16–22). 3Gimbals described as: "TS-SCI-cleared military veterans, civil servants and PhDs" providing "intelligence, investigations, and information solutions for statecraft, national security, and law enforcement missions." Reference: Exh. N, Index 02 (pp. 18–20). Bruce Rivers' "powerful people" comment is validated through: (a) a text message to a friend on May 23 referencing the statement, (b) an email to patent attorney Amanda Prose on May 27, 2023, and (c) a follow-up email to Prose on May 30, 2023. Reference: Exh. C, Index 30 (p. 91); Exh. S, Index 09 (pp. 2–3); Exh. W, Index 03 (pp. 1–4). **Section IX — Paradox of Incompetence (pp. 69–71):** Argues that Guertin's demonstrated legal proficiency contradicts the incompetence finding. He has personally prepared every filing, motion, appellate case, and federal case, including MN Court of Appeals case A24-0780, the initial TRO motion, the federal complaint, and multiple state court motions. **Section X — Danger of Misdiagnosis (pp. 72–73):** Cites research on adverse effects of antipsychotic medications including irreversible brain damage. References Guertin's long-time California physician's letter confirming ADHD and Generalized Anxiety Disorder (successfully treated for years), with no history of psychosis, schizophrenia, or bipolar disorder. Highlights professional milestones: LA Philharmonic 100th Anniversary (Hollywood Bowl, 2018), Bad Bunny's 2019 Coachella set piece, 50-foot falcon at UNESCO World Heritage Site (2019). Reference: Exh. S, Index 11–12; Exh. C, Index 30 (p. 113); Exh. B, Index 28 (pp. 26–34); Exh. W, Index 07–08. **Section XI — Motion for Withdrawal of Defense Counsel (pp. 74–82):** Documents three separate requests for Rivers to withdraw (text messages to Rivers on Jan 28, Apr 18, and June 6, 2024). Evidence includes: - Rivers told Guertin "no court" on January 15, 2024, the night before a hearing. The next day (Jan 16), an order stated "all parties agree to a finding of incompetency entered administratively" — with a Waiver of Appearance (Index #24) and "Found Incompetent, Judicial Officer: Mercurio, Danielle" (no Index number, no PDF available). The competency order was recommended by Mercurio at 8:27 AM and signed by Judge Julia Dayton Klein at 9:22 AM. Guertin asserts he "NEVER 'agreed' to, or had a chance to 'contest' anything." Reference: Exh. A, Index 25; Exh. C, Index 30 (pp. 36, 81–83); Exh. N, Index 04 (pp. 26–27). - Rivers promised on July 28, 2023 to represent Guertin in civil commitment proceedings ("I'll represent you") but failed to follow through starting August 1, 2023. Reference: Exh. C, Index 30 (pp. 81–83). **Section XII — Legal and Constitutional Arguments (pp. 82–85):** Addresses prior denial of TRO motion with constitutional arguments: - Fourteenth Amendment due process: forced antipsychotic medication without legitimate diagnosis; cites *Washington v. Harper*, 494 U.S. 210 (1990). - First Amendment: targeting and retaliation for patent fraud claims; cites *Elrod v. Burns*, 427 U.S. 347, 373 (1976). - Eighth Amendment: forced medication and institutionalization on false pretenses as cruel and unusual punishment; cites *Furman v. Georgia*, 408 U.S. 238, 282 (1972). - Preliminary injunction standard: cites *Winter v. Natural Resources Defense Council, Inc.*, 555 U.S. 7, 20 (2008). **Section XIII — Prayer for Relief (pp. 85–86):** Requests 12 specific forms of relief: (A) enjoin prosecution based on discovery fraud evidence; (B) prohibit forced antipsychotic medication; (C) recognize conflict of interest/ineffective assistance; (D) appoint new independent counsel; (E) initiate independent investigation into fraudulent discovery; (F) investigate broader conspiracy claims; (G) acknowledge constitutional violations; (H) declaratory relief; (I) protect constitutional rights going forward; (J) forward findings to Hennepin County District Court; (K) request state court reconsider charges; (L) any other just/equitable relief. **Exhibit Inventory (Referenced Throughout; Not Separately Paginated in This Filing):** | Exhibit | Content Summary | |---|---| | Exh. A, Index 00 (p. 7) | Case docket excerpt showing Jan 16, 2024 entries: Found Incompetent, Waiver of Appearance, Rule 20 Evaluation Report | | Exh. A, Index 25 | January 16, 2024 Findings of Fact, Conclusions of Law, and Order Regarding Competency (signed Mercurio 8:27 AM, Klein 9:22 AM) | | Exh. A, Index 29 | Michael Biglow August 3, 2023 discovery materials — images of Guertin's apartment and notepad text; comparison photos from Oct–Dec 2022 (p. 35) | | Exh. B, Index 28 (pp. 22–39) | Guertin professional achievements documentation | | Exh. B, Index 28 (pp. 78–80) | Police Report #23-000151 (Jan 12, 2023) — Officer Brandon Harris, Minnetonka PD | | Exh. B, Index 28 (pp. 90–95, 134–158) | Patent documents and third-party prior art submissions | | Exh. B, Index 28 (pp. 105–108) | Guertin's initial email to Dr. Rogstad (Feb 13, 2023) | | Exh. B, Index 28 (pp. 116–125) | March 2023 Rule 20.01 Exam Report by Dr. Jill Rogstad | | Exh. B, Index 28 (pp. 130–132) | Information Disclosure Statement naming Microsoft and Dimension Studios | | Exh. B, Index 28 (p. 224) | Netflix US Patent 11,810,254 with Guertin citation | | Exh. C, Index 30 (pp. 36, 81–83) | January 16, 2024 order; text message exchanges with Bruce Rivers | | Exh. C, Index 30 (pp. 53–59) | LinkedIn search graph — timeline of entity searches correlated with case events | | Exh. C, Index 30 (pp. 60–62) | Welder photos (military memorabilia, ODF Optronics equipment); text message exchanges with welder | | Exh. C, Index 30 (pp. 67–70, 94–95) | Patent analysis and comparison; InfiniSet/Netflix patent overlap analysis | | Exh. C, Index 30 (p. 91) | Text messages referencing Rivers' "powerful people" statement | | Exh. C, Index 30 (p. 107) | Email from Amanda Prose (Westman Champlin & Koehler) re: IC3.gov filing (Jan 6, 2023) | | Exh. C, Index 30 (pp. 113–114) | Letter from California physician — no history of psychosis | | Exh. C, Index 30 (pp. 145–213) | Extended LinkedIn search data | | Exh. D, Index 38 (pp. 66–67) | Patent attorney confirmation that Netflix patent is for "the exact same thing" | | Exh. D, Index 38 (pp. 113–116) | Guertin's follow-up emails to Dr. Rogstad (Apr 26, 2023) with engineering credit proof | | Exh. D, Index 38 (p. 148) | Text message to Rivers requesting withdrawal (second request) | | Exh. E | InfiniSet development documentation | | Exh. F, Index 27 (pp. 32–33) | Bad Bunny Coachella 2019 set piece incident (forklift damage and repair) | | Exh. L | Detailed image analysis of purported "Light Stage 6" at USC — claimed fraudulent academic papers | | Exh. M, Index 02 (pp. 5–6, 11–12) | Gentle Giant Studios / MOVA Contour connections | | Exh. M, Index 03 | Additional Gentle Giant Studios documentation | | Exh. N, Index 01 (pp. 9–12, 49–52) | YouTube age discrepancy analysis — Paul Debevec videos | | Exh. N, Index 02 (pp. 1–25) | LinkedIn search entity backgrounds — Forcepoint, 3Gimbals, Inhance Digital, Gentle Giant, Uptv/InterMedia, Triple Inc., Henry Street Settlement, DARPA, US Air Force, State Department | | Exh. N, Index 04 (pp. 26–27) | Text messages to Bruce Rivers demanding withdrawal (June 6, 2024) | | Exh. S, Index 03 (pp. 1–4) | Probability calculation for missing/manipulated image alignment | | Exh. S, Index 04 | Image comparison table — Biglow discovery vs. Rivers discovery (page/img#, dimensions, aspect ratio, location, missing status) | | Exh. S, Index 05 (pp. 1–21) | Icon/corner/hard drive icon variation analysis across Rivers discovery images | | Exh. S, Index 08 (pp. 4, 16) | Emails between Guertin and Michael Biglow re: settlement documents and travel to Vietnam (Aug 5–8, 2023) | | Exh. S, Index 09 (pp. 2–3) | Emails from Guertin to Amanda Prose referencing "powerful people" statement (May 27 & 30, 2023) | | Exh. S, Index 10 (pp. 1–6) | January 2024 Rule 20.01 Exam Report by Dr. Adam Milz | | Exh. S, Index 11 (pp. 1–3) | Clinical guidelines on antipsychotic medication — benefits vs. risks | | Exh. S, Index 12 | Research on antipsychotic medications and irreversible brain damage | | Exh. S, Index 13 (pp. 1–2) | June 12, 2024 Witness Summary prepared by ACA Jacqueline Perez (Dr. Rogstad testimony) | | Exh. T (pp. 1–19) | Forensic analysis of Rivers discovery Image 290 — color curves, mask overlays, icon bleeding, pixelization anomalies | | Exh. W, Index 02 (pp. 1–5) | Patent value estimation ($150B conservative over 20 years) | | Exh. W, Index 03 (pp. 1–4) | Documentation of Bruce Rivers' "powerful people" statement and subsequent denial | | Exh. W, Index 04 (pp. 1–11) | Welder documentation — military/CIA background proof | | Exh. W, Index 06 (pp. 1–4) | Police Report #23-000151 analysis (Jan 12, 2023) | | Exh. W, Index 07 (pp. 1–77) | "Chronological Continuity of Competence" — 77-page daily activity timeline | | Exh. W, Index 08 (pp. 1–10) | Professional accomplishments timeline and medication history | | Exh. X | InfiniSet patent illustrations and product documentation | **Key People Referenced:** *People already in master catalog tracker:* - **Matthew David Guertin** — Plaintiff (pro se) - **Jacqueline Perez** — ACA / Prosecutor; prepared June 12, 2024 witness statement - **Michael Biglow** — Former defense counsel; emailed initial discovery Aug 3, 2023 - **Bruce Rivers** — Current defense counsel; defendant in civil case; provided July 16, 2024 discovery - **Judge Julia Dayton Klein** — Signed Jan 16, 2024 competency order at 9:22 AM - **Court Referee Danielle C. Mercurio** — Recommended Jan 16, 2024 competency finding at 8:27 AM - **Court Referee George Borer** — Named defendant in federal civil case (official capacity) - **Dr. Jill Rogstad** — Authored March 2023 Rule 20.01 exam report; named defendant (official capacity) - **Dr. Adam Milz** — Authored January 2024 Rule 20.01 exam report; named defendant (official capacity) - **Chela Guzman-Weigart** — Named defendant (official capacity as Assistant County Administrator) *People NEW to this filing — for entity tracker:* - **Keith Ellison** — Minnesota Attorney General; named defendant (official capacity) - **Mary Moriarty** — Hennepin County Attorney; named defendant (official capacity) - **Tom Arneson** — Assistant Hennepin County Attorney; appeared at Jan 16, 2024 hearing per court order - **Amanda Prose** — Patent attorney, Westman Champlin & Koehler; advised Guertin to file IC3.gov complaint (Jan 6, 2023 email) - **Megan Neumann** — CC'd on Guertin's emails to Amanda Prose; Westman Champlin & Koehler - **Officer Brandon Harris** — Minnetonka Police Department; took Police Report #23-000151 (Jan 12, 2023); confirmed Guertin had "proof of the fraud" - **Paul Debevec** — Researcher at USC ICT Graphics Lab; allegedly connected to Netflix; subject of YouTube age discrepancy analysis - **Stephan Trojansky** — Inventor on Netflix's US Patent 11,810,254; filed 12 days after Guertin - **Jules Urbach** — CEO of OTOY/Octane Render; referenced in YouTube fraud claims - **Tom Daschle** — Leader of InterMedia Advisors/Partners (Uptv parent); alleged Air Force ties - **Alan Sokol** — InterMedia Advisors/Partners; alleged Netflix connections - **Jeremy Reiss** — EVP, Henry Street Settlement; Fulbright Specialist with US State Department - **Judge John R. Tunheim (JRT)** — Presiding federal judge, District of Minnesota **Key Case Law Cited:** - *Washington v. Harper*, 494 U.S. 210 (1990) — due process before involuntary medication - *Elrod v. Burns*, 427 U.S. 347, 373 (1976) — First Amendment loss = irreparable injury - *Furman v. Georgia*, 408 U.S. 238, 282 (1972) — cruel and unusual punishment - *Winter v. Natural Resources Defense Council, Inc.*, 555 U.S. 7, 20 (2008) — preliminary injunction standard **Forensic Flags:** - **Second independent discovery set:** This filing introduces the July 16, 2024 Bruce Rivers discovery set (518 images) as a distinct evidence corpus, separate from the August 3, 2023 Biglow discovery set (80 images in PDF). Both sets are now alleged to contain manipulated images, with the Rivers set having its own set of "MISSING" images that overlap with the Biglow set's non-standard-ratio images. - **EXIF metadata provided in filing:** The filing includes verbatim EXIF output for at least one image (DSC_0209.JPG), listing NIKON D7200, specific lens data, and a file modification date of 2023:01:21 14:23:00-06:00. This is directly verifiable against the database if the original images are available. - **Image 290 forensic analysis (Exh. T):** Multiple processing techniques shown (color curve adjustments, mask overlays, edge masking) that Guertin claims reveal icon "bleeding" and selective pixelization. These techniques are visually documented across 5+ pages of the filing. - **Probability calculation (Exh. S, Index 03):** Guertin claims the probability of the missing/non-standard image overlap occurring by chance is "8.16 × 10⁻¹⁷" — described as more improbable than winning the lottery (~3.3 × 10⁻⁹) or being struck by lightning (~8.3 × 10⁻⁷). This calculation methodology should be independently verifiable. - **YouTube metadata vs. upload date discrepancy:** The "Overview: USC ICT Graphics Lab" video (youtube.com/watch?v=k_6LL0DUdFI) shows YouTube upload date 8/14/2014 but Google Inc creation metadata date 2023:07:18 01:52:26 — a 9-year gap. This is the most specific backdating claim in the filing. - **January 16, 2024 competency finding timeline:** Filing documents: Rivers says "no court" on Jan 15 at 6:26 PM → Mercurio signs competency finding at 8:27 AM on Jan 16 → Klein signs at 9:22 AM → Guertin never called Rivers or attended → "Waiver of Appearance" filed same day with no Index number and no corresponding PDF. This sequence raises significant procedural questions. - **Proton Drive video link:** Guertin references a video presenting the discovery fraud analysis at https://drive.proton.me/urls/0C6TA1GPJM#QREuUymnMZof — an independent evidence archive. - **Cross-reference to Filing #2:** The Exh. S, Index 04 table in this filing is an expanded version of the image analysis from Filing #2 (Exhibit G), now comparing both Biglow and Rivers discovery sets side-by-side. The table structure (page/img#, W-px, H-px, image-ratio, location, Bruce Rivers July 16, 2024 Discovery Images) enables direct row-by-row comparison. - **Patent value escalation:** Patent value estimate has escalated dramatically from "$250,000,000" (as cited in the exam reports and earlier filings) to "$150 billion conservative over 20 years" in this filing's Exh. W, Index 02. - **Dual-jurisdiction filing:** This is a federal filing (USDC-MN) seeking to intervene in state proceedings (27-CR-23-1886 and 27-MH-PR-23-815), raising Younger abstention considerations. The prior TRO was already denied on similar jurisdictional grounds. - **Named defendants:** The federal case names 11 defendants spanning county government (Hennepin County, Moriarty, Guzman-Weigart), state government (Ellison), judiciary (Dayton Klein, Borer, Mercurio, Rogstad, Milz), prosecution (Perez), and defense counsel (Rivers) — a breadth that maps the alleged conspiracy participants. - **77-page Chronological Continuity of Competence (Exh. W, Index 07):** A day-by-day activity log spanning an extended period — this is the most granular competency rebuttal document referenced in any filing. Not included in the PDF but referenced. --- ### FILING #13 | Field | Detail | |---|---| | **Filename** | `43__EXHIBIT-S__NEW-EVIDENCE-AND-EMAIL-COMMUNICATIONS.pdf` | | **Date Filed** | August 7, 2024 (ECF stamp: 08/07/24) | | **Federal Case ID** | 0:24-cv-02646-JRT-DLM (Doc. 43) | | **Underlying State Case ID** | 27-CR-23-1886 (criminal); 27-MH-PR-23-815 (civil commitment) | | **Filing Type** | Exhibit S — Newly Obtained Evidence and Email Communications (supporting follow-up motion for in-person hearing and preliminary injunction) | | **Filed By** | Matthew David Guertin (pro se) | | **Addressed To** | U.S. District Court, District of Minnesota; Judge John R. Tunheim; Magistrate Judge Douglas L. Micko | | **Judicial Officer(s)** | John R. Tunheim (District Judge); Douglas L. Micko (Magistrate Judge) | | **Pages** | 196 | **Detailed Summary:** This is the largest and most comprehensive single exhibit in the catalog to date — a 196-page compilation of newly obtained evidence and email communications filed as Exhibit S to Doc. 43 in Guertin's federal civil rights case. The exhibit is organized into 13 indexed sections, each bookmarked for navigation, and is submitted to support a follow-up motion requesting an in-person hearing and preliminary injunction. Guertin argues that the newly analyzed evidence substantiates his original claims of fraudulent discovery materials and demonstrates a substantial risk of irreparable harm due to deceptive exam reports and the continuing deprivation of his constitutional rights. The exhibit's overarching narrative arc is as follows: On July 16, 2024, defense counsel Bruce Rivers finally provided Guertin with a second set of discovery photographs (individual JPEG files with original filenames and metadata intact). When Guertin compared this new set to the earlier discovery PDF emailed by Michael Biglow on August 3, 2023, he discovered that 33 of the 80 images in the Biglow PDF were missing from the Rivers set — and that 28 of those 33 missing images aligned perfectly with the 28 images he had previously identified as having non-standard (i.e., manually cropped) aspect ratios in his April 4, 2024 Motion to Compel Discovery (Filing #2). Guertin presents a ChatGPT-assisted probability calculation yielding approximately 8.16 × 10⁻¹⁷ for this alignment occurring by chance — a figure he compares to DNA forensic match probabilities to argue the manipulation is statistically irrefutable. Additionally, Guertin was finally provided Dr. Adam Milz's January 11, 2024 Rule 20.01 Evaluation Report (the report he had been requesting since February 2024). The Milz report is included in full (6 pages) and becomes a central piece of evidence, as it diagnoses Guertin with "unspecified schizophrenia spectrum and other psychotic disorder" and recommends antipsychotic medication — in part based on Guertin's claims that discovery materials were fraudulently altered, claims Guertin argues he has now proven. Guertin contends that the Milz report contains multiple false statements regarding his substance use history, self-harm history, and competency, and that being forced to take antipsychotic medications based on a diagnosis driven by his (now substantiated) fraud claims constitutes irreparable harm. **Core Content by Index Section:** **Index 01 (7 pages) — July 25, 2024, Email Chain with Bruce Rivers (Emails 1 & 2):** Guertin's initial email to Rivers at 11:28 AM presenting his comparison analysis of the Biglow PDF versus the Rivers discovery set. He identifies that "almost all" of the images he previously flagged as manipulated are now missing from the Rivers set, proving the court provided Rivers with incomplete discovery materials. Guertin details specific false statements in the Milz report (substance abuse claims involving crack cocaine and DMT; fabricated self-harm history; characterization as unable to rationally consult with counsel). Rivers responds at 11:55 AM with a one-sentence reply: "What exactly is fraudulent." Guertin responds at 3:41 PM with a detailed 15-point numbered analysis explaining the column-by-column comparison table, the color coding system, the notebook photograph anomaly (first page never shown in Rivers' set, notebook repositioned between photo sets, bullet orientation changed), and metadata timestamp concerns suggesting the image sequence metadata is not authentic. He specifically highlights that image '50-74.jpg' from the Biglow PDF shows the notebook open to the first page in its original position, but no corresponding image exists in the Rivers set. **Index 02 (3 pages) — Presentation of Missing Notebook Photos:** Visual comparison pages showing side-by-side photographs of the notebook from both discovery sets. Includes image '50-74.jpg' (from Biglow PDF showing notebook open to page one, positioned on top of USB cord near the computer) alongside multiple sequential images from the Rivers discovery set (DSC_0179 through DSC_0209) showing the notebook in a different position, open to the second page, with the bullet next to the paint brush sitting upright instead of on its side. This visual evidence supports Guertin's claim that the scene was physically rearranged between the two photo sets. **Index 03 (4 pages) — July 25, 2024, Email 3 to Bruce Rivers — Mathematical Probability Analysis:** Guertin emails Rivers at 4:12 PM presenting a probability calculation (performed via ChatGPT) for the alignment of missing and non-standard images. The calculation framework: Group A = 28 of 80 images identified as "non-standard" aspect ratios; Group B = 33 of 80 images identified as "MISSING" from Rivers' set; all 28 non-standard images from Group A perfectly align with 28 of the 33 missing from Group B. The computed probability of this occurring by chance is approximately 8.16 × 10⁻¹⁷. Guertin then asks ChatGPT to contextualize this against forensic DNA match probabilities used in courtroom settings, arguing the alignment constitutes proof beyond reasonable doubt that the manipulation was intentional. **Index 04 (3 pages) — 'Rivers-Discovery-Missing-Images.pdf' — Complete Comparison Table:** The full 80-row comparison table referenced in the email chain. Six columns: page-img# | W-px | H-px | image-ratio | location of photo | Bruce Rivers July 16, 2024 Discovery Images. Outdoor images (rows 01-01 through 14-28) all maintain uniform 3:2 aspect ratio and all have corresponding filenames in the Rivers column. Building hallway images (15-29 through 17-32) are present. Interior residence images begin at 18-33 and this is where both the aspect ratio anomalies and the MISSING entries concentrate. Of the 48 interior images (rows 18-33 through 56-80), 33 are marked MISSING in the Rivers column, and 28 of those 33 MISSING entries correspond to non-standard aspect ratio rows. The final five images (52-76 through 56-80) are Minnetonka Police Station photos, all in 3:4 aspect ratio and all MISSING from the Rivers set. The 16:9 aspect ratio images (rows 34-54 through 35-57, 38-60 through 38-61, 44-67 through 44-68) are all MISSING. **Index 05 (21 pages) — July 16, 2024 Discovery Photographs from Bruce Rivers:** The complete set of photographs Guertin received from Rivers on July 16, 2024 — individual JPEG files with original Minnetonka Police Department filenames (format: 23-0098_0012_520-TRS_DSC_XXXX.JPG). These are the original, uncropped images corresponding to the photos that were present in the Biglow PDF. The filenames establish the source as case report 23-0098, officer badge 0012, squad 520-TRS. This is the first time Guertin received the photographs in their original file format with original filenames and metadata — confirming his January 5, 2024 request (Filing #1) for "original, non-compressed digital file format" was justified. **Index 06 (12 pages) — 'image_metadata.xlsx' — Complete Image Metadata Table:** Full EXIF metadata extracted from the Rivers discovery images. Three columns: Image Name | Create Date | Create Time | Focus Distance. All 209+ images carry the creation date 2023:01:21 (January 21, 2023 — the date of the incident). Timestamps span from 13:32:12 to approximately 14:15+ (about 43 minutes of sequential photography). Focus distances vary from 0.67 m to 8.41 m. The sequential timestamps are presented by Guertin as evidence that the metadata portrays a continuous, unbroken photographic sequence — which he argues is inconsistent with the scene rearrangement (notebook position, bullet orientation) visible between the two discovery sets. The total image count in the metadata (209+) significantly exceeds the 80 images in the Biglow PDF, raising questions about why so many images were excluded from the initial discovery production. **Index 07 (8 pages) — March 14, 2022, Email to Patent Attorney Amanda Prose:** A detailed technical email from Guertin to Amanda Prose at Westman, Champlin & Koehler (WCK) law firm describing his invention's "Animation Timeline" system, camera path programming, user mode controls, and integration with TouchDesigner and Unreal Engine. Covers: custom animation timeline and cue sequencing as the top-level system controller; SMPTE timecode synchronization; pre-filmed real-world scenes with 9DoF + GPS camera tracking data; travel path and camera path animation via keyframe/spline/Bezier curve programming; plane cam vs. scene cam architecture; and plans for virtual camera capabilities. Guertin worked through the night to meet the filing deadline and labels several sections as "unfinished." This email serves as contemporaneous evidence of Guertin's genuine technical sophistication and active patent development work — directly relevant to challenging the competency evaluators' characterization of his patent claims as "delusional" or "grandiose." **Index 08 (54 pages) — One Week in the Life of Matthew Guertin | Emails Spanning August 4–11, 2023:** The largest single index section — a 54-page compilation of emails spanning one week that documents Guertin's simultaneous management of multiple complex tracks: investor relations (Vietnam-based friends/investors asking detailed business due diligence questions); criminal case settlement negotiations (emails with Michael Biglow about signing the stayed commitment agreement, travel conditions, visa concerns, travel to Vietnam for production line setup); patent fraud discovery (SIGGRAPH 2023 presentation by Paul Debevec showing Eyeline Studios' rotating treadmill, claimed 2006 "Light Stage" prior art paper that Guertin alleges is fabricated); corporate operations (InfiniSet, Inc. bank account opening at US Bank Robbinsdale, corporate attorney at Hellmuth & Johnson); and the catastrophic loss of his patent law firm (Westman, Champlin & Koehler shareholder Z. Peter Sawicki terminates the attorney-client relationship on August 10, 2023 after Guertin sends a mass email to the entire firm requesting an emergency in-person meeting about the SIGGRAPH fraud discovery). Key events in chronological order within this section: - **Aug 5, 2023 (12:41 AM):** Vietnam-based investor sends formal due diligence questionnaire covering company specifics, financial analysis, industry analysis, risk assessment, and investment specifics. - **Aug 5, 2023 (2:42 AM):** Guertin emails Biglow about signing settlement documents; asks about international travel restrictions under stayed commitment, visa implications, mentions investors in Vietnam, plans for production line, meetings with financial advisors. - **Aug 6, 2023 (6:30 AM):** Guertin sends lengthy reflective email to investor recounting his career journey (Amon Tobin show obsession → meeting Vello Virkhaus in LA → Katy Perry Hollywood Bowl show → Vietnam trips → Blue Moon Club), establishing the depth and authenticity of his professional relationships and emotional investment. - **Aug 6, 2023 (8:01 AM):** Guertin emails Biglow photos of "special ops gear" referenced in Dr. Rogstad's report, clarifying it is related to his invention. Attaches 7 files including annotated images and ODF Optronics photos. - **Aug 8, 2023 (1:01 AM):** Guertin emails Biglow stating investment is "actually happening," describes multimillion-dollar guaranteed investment, plans for Vietnam production line, corporate bank account opening, patent filing deadlines (Aug 19/Sep 19), and asks about legal status for visa clearance. - **Aug 8, 2023 (various):** Multiple exchanges with Biglow about stayed commitment agreement terms — Guertin proposes revisions (replacing "committed" with "assigned"), discusses travel provisions, Vietnam relocation timeline, revised documents attached. - **Aug 8, 2023 (4:57 PM / 5:00 PM / 5:38 PM):** Guertin emails contact at SIGGRAPH asking about InfiniSet duplicates, then shares Netflix/Eyeline Studios video and detailed analysis of Paul Debevec's SIGGRAPH 2023 presentation showing rotating treadmill. - **Aug 9, 2023 (11:02 AM):** Biglow sends deadline email — trial is Aug 11 at 10:30 AM, asks whether Guertin will sign settlement or proceed to trial. - **Aug 9, 2023 (3:29 PM):** Guertin emails Amanda Prose at WCK with "Emergency" subject line about a new Netflix fraud problem. - **Aug 9, 2023 (5:03 PM):** Guertin signs and returns settlement documents to Biglow. - **Aug 10, 2023 (12:40 PM):** Guertin sends mass email to entire WCK firm (18+ attorneys) requesting emergency in-person meeting to discuss SIGGRAPH/Eyeline Studios/Netflix fraud discovery, international patent filing deadline, and investor relations. Email includes detailed analysis of Debevec's presentation, the claimed 2006 "Einarsson et al." paper, Trojansky's patent timeline (filed March 31, 2021, twelve days after Guertin's March 19, 2021 provisional), LinkedIn search evidence from USC Cinema, Duty of Candor arguments, and multiple Dropbox links to demo videos and studio setup photos. - **Aug 10, 2023 (12:48 PM):** Amanda Prose replies: available for in-person meeting Tuesday. - **Aug 10, 2023 (4:12 PM):** Z. Peter Sawicki (WCK shareholder) replies to all: firm has decided to no longer represent Guertin, will file petitions to withdraw from all pending applications, states Amanda Prose "no longer offices at our downtown Minneapolis office" and emails to her will be blocked. - **Aug 10, 2023 (6:39 PM – 8:36 PM):** Guertin sends multiple appeals to Sawicki and the full firm asking to reconsider, providing links to his professional portfolio (MattGuertin.com), Blue Moon Club projects, Wyman Building 3D scan, StyleFlip invention, demo videos. Sawicki responds at 8:36 PM with a final termination: "The relationship between you and Westman, Champlin & Koehler is at an end. We will not answer any further emails." **Index 09 (12 pages) — Business, Patents, CompForensics.com, Discussing "Powerful People" Comment:** Email correspondence with Amanda Prose spanning May 27 – June 9, 2023. Key contents: - **May 27, 2023:** Guertin mentions being told "powerful people keeping an eye on me" and states he is "of the opinion that pretty soon I'm either going to be very dead or very rich." Requests trademark filings proceed via Madrid Protocol. - **May 30, 2023:** Guertin asks Prose to meet his criminal defense attorney (Bruce Rivers) in person, stating Rivers is "afraid to talk on the phone" about the "powerful people" situation. Expresses fear of being "disappeared or killed." - **May 31, 2023:** Guertin describes being surveilled, monitored by "powerful people," worried about email/web traffic being filtered by AI, references patent fraud discoveries. - **May 31, 2023:** Prose responds professionally, discusses outstanding balance on account, offers to proceed with Madrid Protocol filing, notes Google's "LaMDA 2" dataset is also called "Infiniset" but likely not a trademark conflict. - **June 1, 2023:** Prose reports she spoke with Mark Lanterman at Computer Forensics (CompForensics.com) about conducting forensic analysis of Guertin's hard drive under attorney-client privilege, with WCK as the client of record. - **June 9, 2023:** Guertin provides detailed technical update on his TouchDesigner/Unreal Engine prototype system — constant 60fps, Spout zero-latency video pipeline, camera tracking integration, plans for DN Studios (local LED volume facility), mentions Ian Bearce (Head of Studio at Best Buy corporate). Also discusses Netflix/Trojansky fraud, PhotoRobot discovery, references Robert Hulse at Fenwick & West representing both Netflix and Microsoft. Mentions upcoming competency hearing. - **June 9, 2023:** Prose confirms patent filings are ready to proceed, provides international filing cost estimates, acknowledges Guertin's progress. **Index 10 (6 pages) — Dr. Adam Milz's January 11, 2024 Rule 20.01 Evaluation Report:** The complete, unredacted 6-page forensic evaluation report authored by Dr. Adam A. Milz, PhD, LP, ABPP (Supervising Forensic Psychologist, Fourth Judicial District Psychological Services). Filed in district court 1/11/2024 at 2:05 PM. Key contents: - **Interview:** Approximately two hours via court-approved videoconferencing on January 3, 2024. Guertin was at his residence in Plymouth, MN. - **Collateral sources reviewed:** Order from Judge Dayton Klein (Nov 15, 2023); records from case 27-MH-PR-23-815; Dr. Rogstad's March 10, 2023 report; criminal complaint; MNCIS records; prosecution discovery materials; Vail Place records (Aug 10 – Dec 29, 2023); 8-minute phone consultation with Bruce Rivers (Jan 8, 2024). Records from Schuster Medical Research Institute (Guertin's California psychiatrist) were requested but not received. - **Substance Use History:** Reports "a history of problematic use of several substances, including alcohol, marijuana, methamphetamine, crack cocaine, dimethyltryptamine (DMT), and lysergic acid diethylamide (LSD)" — a characterization Guertin disputes, claiming he admitted only to having "used every drug besides heroin" at some point in his life and that crack cocaine use totaled approximately 20 times in his mid-twenties. - **Mental Health History:** Notes childhood ADHD diagnosis, history of bipolar symptoms (mania), 2009 hospitalization prompted by "paranoia and threatening to harm himself in the context of alcohol and LSD use." Guertin disputes the self-harm characterization, stating the 2009 incident was a "bad acid trip" that never involved self-harm attempts. - **Current Mental Status:** Guertin presented as casually dressed, appropriate grooming, verbose but normal speech, alert and cooperative. No hallucinations. Thought content "positive for delusional beliefs" — reported being stalked by government agencies (CIA, State Department, Army, Air Force, DIA, DARPA, Indo-Pacific Command) and corporations (Lockheed Martin, Fox Corporation, Forcepoint) stemming from his patent. Also reported Netflix fraud, phone monitoring, computer hacking, AI/Bluetooth surveillance, and an ex-military/ex-CIA welder. Stated discovery material has been altered and "outside pressure is being applied to the courts." Thought processes described as "perseverative," "tangential," and "circumstantial." - **Diagnosis:** Unspecified schizophrenia spectrum and other psychotic disorder. - **Competency Opinion:** Guertin "lacks the ability to rationally consult with counsel, understand the proceedings, or participate in his defense" due to mental illness. - **Prognosis:** Positive for restoration within six months with appropriate treatment (i.e., antipsychotic medication). Notes Guertin "has no known history of treatment for a psychotic disorder" and current medication regimen (Adderall + Klonopin) "is not effectively stabilizing his mental status." - **Self-Harm Risk:** States "Mr. Guertin has a history of threatening to harm himself, which elevates his long-term risk of similar behavior" — a characterization Guertin vehemently disputes. **Index 11 (3 pages) — Symptoms of Psychotic Disorders and Schizophrenia:** An informational overview (appears to be Guertin-authored or compiled) describing positive symptoms (hallucinations, delusions, disorganized thinking), negative symptoms (affective flattening, anhedonia, avolition), and cognitive symptoms (poor executive function, attention deficits, memory issues) of psychotic disorders and schizophrenia. Framed as context for understanding the severity of symptoms that would warrant antipsychotic medications — implicitly arguing that Guertin does not exhibit these symptoms. **Index 12 (59 pages) — Antipsychotic Drugs Cause Brain Damage | Research Studies:** A compilation of published medical research studies documenting adverse neurological effects of antipsychotic medications. Includes reprinted articles from peer-reviewed journals (Archives of General Psychiatry, JAMA Network). The research spans studies on brain volume changes, gray matter reduction, and neurotoxic effects associated with antipsychotic drug use. This section supports Guertin's argument that being forced to take antipsychotic medications based on a diagnosis he considers fraudulently derived constitutes irreparable harm warranting injunctive relief. **Index 13 (2 pages) — June 12, 2023, 'Witness Summary Dr. Jill Rogstad' — Prepared by Jacqueline Perez:** A non-verbatim summary of a June 12, 2023 witness preparation meeting between prosecutor Jacqueline Perez and Dr. Jill Rogstad in anticipation of upcoming testimony (case number listed as 27-CR-23-2118, which appears to be a typo or related case number for 27-CR-23-1886). Key contents of Rogstad's statements as summarized by Perez: - Rogstad has been a senior clinical forensic psychologist at the 4th Judicial District since September 2014; board certified in forensic psychology since 2020; has conducted "hundreds" of forensic interviews. - Evaluation of Guertin conducted March 1, 2023, with Dr. Casey Boland present; interview lasted approximately 2 hours. - Guertin reported being prescribed Adderall and Klonopin but gave contradictory information about medication compliance (sometimes takes additional Adderall doses while working). - Guertin acknowledges prior hospitalization for substance use and "suicide attempts" — however, during the current interview stated "the threats were real and he has evidence of this belief." - Rogstad characterizes Guertin's beliefs about Netflix/Microsoft stealing his patent as "persecutory delusions" at the "extreme end of the psychotic spectrum." Notes he also described cars following him and referenced September 11 symbology. - Rogstad "considered a grandiose delusion diagnosis, did not diagnose him with this because she was unable to verify the patents." - Diagnosis: unspecified schizophrenia and other psychotic disorder. - Notes stimulants "can endorse symptoms that mimic psychotic symptoms" and could contribute to delusions; primary mood disorder is another possible attribution. - First course of treatment: antipsychotic medications. - Critically states: "Even if he did have patents approved, this would not change her mind about her ultimate opinion as opinion is based on delusional beliefs and not the patents themselves." **Exhibit Inventory:** | Index | Content | Pages | Date(s) | |---|---|---|---| | 01 | Email chain: Guertin ↔ Rivers re: discovery fraud analysis (3 emails, Jul 25, 2024) | 7 | July 25, 2024 | | 02 | Visual comparison: Missing notebook photographs from both discovery sets | 3 | N/A (photo evidence) | | 03 | Email to Rivers: ChatGPT probability calculation (8.16 × 10⁻¹⁷) + DNA comparison | 4 | July 25, 2024 | | 04 | 'Rivers-Discovery-Missing-Images.pdf' — Complete 80-row comparison table with MISSING column | 3 | Created ~July 24–25, 2024 | | 05 | Complete set of discovery photographs received from Rivers on July 16, 2024 (original JPEGs) | 21 | Photographs dated Jan 21, 2023; received Jul 16, 2024 | | 06 | 'image_metadata.xlsx' — Full EXIF metadata for 209+ discovery images | 12 | Extracted ~July 2024 | | 07 | Email: Guertin → Amanda Prose (WCK) re: patent Animation Timeline technical description | 8 | March 14, 2022 | | 08 | "One Week in the Life" — 54 pages of emails spanning Aug 4–11, 2023 (investors, Biglow, WCK, patent fraud) | 54 | August 4–11, 2023 | | 09 | Emails: Guertin ↔ Amanda Prose re: business, patents, CompForensics.com, "powerful people" | 12 | May 27 – June 9, 2023 | | 10 | Dr. Adam Milz Rule 20.01 Evaluation Report (complete, 6 pages) | 6 | January 11, 2024 | | 11 | Informational overview: Symptoms of psychotic disorders and schizophrenia | 3 | N/A (reference material) | | 12 | Medical research studies: Antipsychotic drugs and brain damage | 59 | Various publication dates | | 13 | 'Witness Summary Dr. Jill Rogstad' — prepared by Jacqueline Perez (witness prep notes) | 2 | June 12, 2023 | **Key People Referenced:** - **Bruce Rivers** — Current defense counsel; provides Guertin with second set of discovery photos on July 16, 2024; one-sentence response to fraud allegations; source of "powerful people keeping an eye on you" statement - **Michael Biglow** — Former defense counsel; emailed original discovery PDF on August 3, 2023; multiple email exchanges about settlement documents, travel to Vietnam, stayed commitment terms during Aug 4–11, 2023 - **Jacqueline Perez** — ACA / Prosecutor; author of the June 12, 2023 Witness Summary for Dr. Rogstad (case number listed as 27-CR-23-2118) - **Dr. Adam Milz** — Rule 20.01 evaluator (Jan 3, 2024 interview; report filed Jan 11, 2024); diagnoses unspecified schizophrenia spectrum disorder; recommends antipsychotic medication; opines Guertin incompetent - **Dr. Jill Rogstad** — Original Rule 20.01 evaluator (March 1, 2023); witness summary reveals she "considered a grandiose delusion diagnosis" but did not diagnose because "she was unable to verify the patents"; states even verified patents would not change her opinion - **Dr. Casey Boland** — Present during Rogstad's March 1, 2023 evaluation of Guertin - **Amanda Prose** — Patent attorney at Westman, Champlin & Koehler (WCK); handled Guertin's patent (US11577177) and trademark filings; recipient of extensive technical and business emails; confirmed Computer Forensics engagement; available for Tuesday meeting before firm termination - **Z. Peter Sawicki** — Shareholder at WCK; terminated attorney-client relationship with Guertin on August 10, 2023; ordered Amanda Prose's email blocked from Guertin; stated firm would file petitions to withdraw from all pending patent and trademark applications - **Megan Neumann** — CC'd on Prose/Guertin email correspondence at WCK - **Mark Lanterman** — Computer Forensics (CompForensics.com); contacted by Prose on June 1, 2023 for forensic hard drive analysis under attorney-client privilege - **Becky Schmidt** — Case manager at Vail Place; Milz attempted to reach her for consultation but was unsuccessful - **Ian Bearce** — Head of Studio at Best Buy corporate; pointed Guertin to DN Studios (local LED volume facility) - **Judge John R. Tunheim** — U.S. District Judge, federal case - **Magistrate Judge Douglas L. Micko** — Magistrate Judge, federal case - **Judge Julia Dayton Klein** — Ordered Nov 15, 2023 Rule 20.01 examination (referenced in Milz report) - **Stephan Trojansky** — CEO of Eyeline Studios; filed patent application March 31, 2021 (12 days after Guertin's March 19, 2021 provisional); company acquired by Netflix - **Paul Debevec** — Researcher/professor at USC Cinematic Arts; presented rotating treadmill at SIGGRAPH 2023; referenced claimed 2006 "Light Stage" research - **Robert Hulse** — IP attorney at Fenwick & West; represents both Netflix and Microsoft - **Dr. Schuster** — Guertin's outpatient psychiatrist in California (Schuster Medical Research Institute); prescribes Adderall and Klonopin; records requested by Milz but not received **Forensic Flags:** - **Discovery comparison table (Index 04) is the single most important new evidence in this filing:** The 80-row table with the added "Bruce Rivers July 16, 2024 Discovery Images" column provides independently verifiable, side-by-side proof that 33 images are MISSING from the Rivers set and that 28 of those 33 align with the previously identified non-standard aspect ratio images. This transforms the April 4, 2024 analysis (Filing #2) from an internal-consistency argument into a cross-set verification. - **The 209+ total images in the metadata (Index 06) versus 80 in the Biglow PDF and ~47 in the Rivers set** represents a massive unaccounted discrepancy — where are the remaining 129+ original photographs? - **Image filenames in the Rivers set** (format: 23-0098_0012_520-TRS_DSC_XXXX.JPG) provide case report number (23-0098), officer badge (0012), and squad identifier (520-TRS) — all independently verifiable against Minnetonka PD records. - **Notebook photograph anomaly (Indexes 01–02):** The notebook position change (open to page 1 near computer in Biglow PDF image 50-74 vs. open to page 2, repositioned further from computer in Rivers set), combined with the bullet orientation change (lying on side vs. upright), suggests physical scene manipulation between the two photo sets. This is verifiable from the images themselves. - **Milz report (Index 10) explicitly characterizes Guertin's discovery fraud claims as delusional thinking:** The report states Guertin "reported discovery material in the present case has been altered" and categorizes this as part of his "delusional beliefs consistent with the previous evaluation." If the discovery fraud is proven, this creates a circular problem: the diagnosis of psychosis is partly based on beliefs now substantiated by evidence. - **Milz report notes records from Guertin's psychiatrist (Schuster Medical Research Institute) were "not received"** — meaning the competency opinion was formed without corroboration of Guertin's current treatment regimen. - **Rogstad witness summary (Index 13) reveals critical admission:** Rogstad "was unable to verify the patents" yet diagnosed psychotic disorder. She also states that even verified patents would not change her opinion — a statement that may be relevant to APA Ethical Standard 2.01 (Boundaries of Competence) given her acknowledged lack of technology expertise (referenced in Filing #4). - **Case number discrepancy in Index 13:** The witness summary header lists case number 27-CR-23-2118, not 27-CR-23-1886 — needs verification whether this is a typo or a related/consolidated case. - **WCK termination on August 10, 2023** — three days before the August 13, 2023 one-week mark and nine days before the August 19, 2023 patent filing deadline — represents a catastrophic loss of IP counsel at a critical juncture. The timing coincidence with the SIGGRAPH fraud discovery is notable. - **The "powerful people" statement** is now documented across multiple independent email chains: Rivers → Guertin (June 16, 2023, per Filing #4); Guertin → Prose (May 27, 2023 and May 30, 2023, Index 09). This establishes contemporaneous documentation of the statement across multiple recipients, reducing the likelihood it is fabricated. - **Federal case established:** This filing introduces federal case 0:24-cv-02646-JRT-DLM, establishing that Guertin has escalated from state court filings to a federal §1983 civil rights action. Judge Tunheim and Magistrate Judge Micko are new judicial officers not previously in the catalog. - **The Aug 4–11, 2023 email compilation (Index 08)** provides a dense, contemporaneous record of Guertin's mental state, business operations, and decision-making during a critical week — directly relevant to competency assessments. The emails demonstrate simultaneous management of investor due diligence, settlement negotiations, patent fraud analysis, corporate banking, and attorney communications. - **CompForensics.com / Mark Lanterman engagement** (Index 09) documents that a professional computer forensic analysis was being arranged through WCK under attorney-client privilege as early as June 1, 2023 — before the WCK relationship was terminated. --- ### FILING #14 | Field | Detail | |---|---| | **Filename** | `44__EXHIBIT-T__FRAUDULENT-DISCOVERY-ANALYSIS__1-of-3.pdf` | | **Date Filed** | August 7, 2024 (filed stamp: Doc. 44 Filed 08/07/24) | | **Case ID** | 0:24-cv-02646-JRT-DLM (federal civil case; underlying criminal case 27-CR-23-1886) | | **Filing Type** | Exhibit T — Forensic Analysis of Discovery Photographs (Part 1 of 3) | | **Filed By** | Matthew David Guertin (pro se) | | **Addressed To** | U.S. District Court, District of Minnesota | | **Judicial Officer** | JRT-DLM (Judge John R. Tunheim; Magistrate Judge Douglas L. Mahoney) | | **Pages** | 21 | **Detailed Summary:** This is Part 1 of a three-part forensic image analysis exhibit filed as Doc. 44 in the federal civil case 0:24-cv-02646-JRT-DLM. It constitutes Exhibit T of the filing and presents Guertin's forensic analysis of a **second set** of discovery photographs — distinct from the August 3, 2023 discovery set analyzed in Filing #2 (the original 80-image set). These photographs were provided to Guertin by defense attorney Bruce Rivers following Rivers' July 16, 2024 1:30 PM court appearance. **Core Allegation:** Guertin alleges that the July 16, 2024 discovery photographs contain AI-generated image manipulation targeted specifically at obscuring the laptop screen content visible on his kitchen table. He claims the manipulation was designed to overlay fraudulent application windows and icons onto the screen to cover up what was actually displayed — which he identifies as an image of his self-described "former CIA welder," a subject he states was documented in the earlier August 3, 2023 discovery materials. **Methodology (Three-Layered Analysis):** 1. **Color Curve Enhancement:** Extreme color curve adjustments were applied to the original photographs to amplify subtle pixel-level differences. Multiple curve settings were used (designated as "Color curve 1," "Color curve 2," and "Color curve 3"), each producing a different color-enhanced version of the same base image. 2. **Overlay Technique:** The original (base layer) images were overlaid with the color-curve-enhanced versions and transparent PNG masks. Transparency was adjusted to isolate and reveal irregularities not visible in the unprocessed photographs. 3. **Visual Inspection and PNG Mask Analysis:** Transparent PNG masks were created and applied at 92% transparency to isolate specific regions of the images — particularly window boundaries and icon edges on the laptop screen. **Primary Images Analyzed:** Two source photographs are the focus of the analysis, each processed through four variants: | Source Image | Variants Produced | Scene Description | |---|---|---| | **0193.jpg** | 0193.jpg (original), 0193-1.jpg (curve 1), 0193-2.jpg (curve 2), 0193-3.jpg (curve 3), 0193-M.png (mask) | Kitchen table area: MSI laptop open on table with spiral notebooks, pens, headphones, cables; whiteboard visible on wall behind | | **0209.jpg** | 0209.jpg (original), 0209-1.jpg (curve 1), 0209-2.jpg (curve 2), 0209-3.jpg (curve 3), 0209-M.png (mask) | Desk/workstation area: MSI laptop on desk with office chair, Brother printer, whiteboard with diagrams, black multi-slot organizer on wall | **Image Presentation Structure:** The exhibit presents images in two progressive zoom levels: - **Wide view** (pp. 6–11): Full scene, linear scaled 32.5% to 1950px width at 90% JPEG compression — original + three color curve variants shown side-by-side for each source image. - **Cropped screen region** (pp. 8–13): No scaling, 1950px width region crop of the laptop screen area at 90% JPEG compression — original + three color curve variants. - **Mask overlay comparison** (pp. 16–19): Original image alongside PNG mask at 92% transparency, then color curve 1 and color curve 2 side-by-side for each source image. **Anomalies Reported:** 1. **Icon "Bleeding" Effect:** When extreme color curves are applied, icons within the on-screen windows (particularly a hard drive icon) appear to extend beyond their window borders. Guertin argues this "bleed" is inconsistent with a genuine photograph of a real screen and indicates digital compositing where generated elements were pasted over the original screen content. 2. **Window Edge Irregularities:** The boundaries of the application windows displayed on the laptop screen do not maintain consistent edges under color curve enhancement. Elements appear to extend beyond expected confines, which Guertin attributes to imperfect boundary alignment in the inserted content. 3. **Inconsistent Icon Variations:** Across the images, the same icons (particularly the hard drive icon) display subtle variations in shape, size, and edge definition. Some appear narrower/taller while others are wider/more compact. Guertin argues that screenshots from the same device should show identical icon rendering. 4. **Misalignment and Perspective Issues:** The angles at which the on-screen windows and icons are displayed do not align with the photographic perspective of the rest of the scene. Guertin characterizes this as a hallmark of AI generation, where maintaining spatial coherence across generated elements is difficult. 5. **Depth and Shadowing Inconsistencies:** Shadows and depth cues within the on-screen windows do not match the lighting environment of the surrounding physical scene, suggesting the screen content was digitally inserted rather than photographed in situ. 6. **Pixelation and Anomalous Patterns:** Color-curved images reveal pixelation and unusual patterns around icon and window edges that Guertin attributes to neural-network rendering artifacts rather than normal photographic noise or compression. **Visible Screen Content (Original Images):** - **0193.jpg screen:** Shows what appears to be a Windows "Devices and Printers" control panel window, with an "Add a device" dialog box open ("Choose a device or printer to add to this PC"). A Brother HL-L2300D series printer is visible in the device list. Desktop icons are visible along the bottom of the screen. A text passage is partially visible in the lower-left of the screen. - **0209.jpg screen:** Shows a similar Windows Control Panel / Devices and Printers view with multiple windows open, including device management panels. The same or similar Brother printer device is visible. **Conclusions Stated in Exhibit:** The exhibit concludes that the images show evidence of digital manipulation based on: irregular icon behavior, window edge anomalies, inconsistent icon variations across images, perspective and alignment issues, broader AI-generation indicators (pixelation, anomalous patterns), and that these anomalies are inconsistent with genuine police photographs. **Exhibit Inventory (Internal to Exhibit T):** | Image/Page | Content | |---|---| | p. 6 (top) | 0193.jpg — Original, full scene, linear scaled 32.5% to 1950px w, 90% JPEG | | p. 6 (bottom) | 0193-1.jpg — Color curve 1 applied, full scene, same scaling | | p. 7 (top) | 0193-2.jpg — Color curve 2 applied, full scene, same scaling | | p. 7 (bottom) | 0193-3.jpg — Color curve 3 applied, full scene, same scaling | | p. 8 (top) | 0193.jpg — No scaling, 1950px w region crop of laptop screen, 90% JPEG | | p. 8 (bottom) | 0193-1.jpg — No scaling, 1950px w region crop, color curve 1 | | p. 9 (top) | 0193-2.jpg — No scaling, 1950px w region crop, color curve 2 | | p. 9 (bottom) | 0193-3.jpg — No scaling, 1950px w region crop, color curve 3 | | p. 10 (top) | 0209.jpg — Original, full scene, linear scaled 32.5% to 1950px w, 90% JPEG | | p. 10 (bottom) | 0209-1.jpg — Color curve 1 applied, full scene, same scaling | | p. 11 (top) | 0209-2.jpg — Color curve 2 applied, full scene, same scaling | | p. 11 (bottom) | 0209-3.jpg — Color curve 3 applied, full scene, same scaling | | p. 12 (top) | 0209.jpg — No scaling, 1950px w region crop of laptop screen, 90% JPEG | | p. 12 (bottom) | 0209-1.jpg — No scaling, 1950px w region crop, color curve 1 | | p. 13 (top) | 0209-2.jpg — No scaling, 1950px w region crop, color curve 2 | | p. 13 (bottom) | 0209-3.jpg — No scaling, 1950px w region crop, color curve 3 | | p. 16 (top) | 0193.jpg — Original image (zoomed laptop screen region) | | p. 16 (bottom) | 0193-M.png — Mask layer at 92% transparency | | p. 17 (top) | 0193-1.jpg — Color curve 1 (zoomed laptop screen region) | | p. 17 (bottom) | 0193-2.jpg — Color curve 2 (zoomed laptop screen region) | | p. 18 (top) | 0209.jpg — Original image (zoomed laptop screen region) | | p. 18 (bottom) | 0209-M.png — Mask layer at 92% transparency | | p. 19 (top) | 0209-1.jpg — Color curve 1 (zoomed laptop screen region) | | p. 19 (bottom) | 0209-2.jpg — Color curve 2 (zoomed laptop screen region) | **Key People Referenced:** - **Matthew Guertin** — Defendant; author of forensic analysis - **Bruce Rivers** — Defense counsel who provided the July 16, 2024 discovery materials to Guertin following court appearance - **Judge John R. Tunheim (JRT)** — Federal district judge on civil case 0:24-cv-02646-JRT-DLM - **Magistrate Judge Douglas L. Mahoney (DLM)** — Federal magistrate judge on civil case **Forensic Flags:** - This is the first filing in the catalog from the **federal civil case** (0:24-cv-02646-JRT-DLM) — all prior filings (#1–#11) are from the state criminal case (27-CR-23-1886) or state appellate case (A24-0780). Guertin has escalated the discovery fraud claims to federal court. - This exhibit analyzes a **second, distinct set of discovery photographs** — the July 16, 2024 set provided by Rivers — separate from the August 3, 2023 set analyzed in Filing #2. This means there are now two independent discovery productions under forensic challenge: (1) Aug 3, 2023 — 80 images with systematic cropping, aspect ratio manipulation, and duplicate concealment; (2) July 16, 2024 — new images with alleged AI-generated screen content manipulation. - The allegation has evolved from **manual photo cropping/manipulation** (Filing #2) to **AI-generated image content** (this filing) — a significant escalation in the technical sophistication of the claimed fraud. - The exhibit is Part 1 of 3 — Parts 2 and 3 should be cataloged separately when available (likely additional exhibits within Doc. 44 or subsequent docket entries). - The color curve analysis method is a known technique in digital forensics for revealing compression boundaries, edit boundaries, and compositing seams. However, it can also amplify normal JPEG compression artifacts, monitor moiré patterns, and sub-pixel rendering effects — the analysis does not appear to control for these alternative explanations. - The "icon bleeding" and "edge irregularity" observations could alternatively be explained by: (a) JPEG compression artifacts in the original photograph (photographing a screen introduces additional compression layers), (b) sub-pixel font/icon rendering on LCD screens photographed at off-angles, (c) moiré patterns from the interaction between the camera sensor grid and the screen pixel grid, (d) the camera's own optical distortion and chromatic aberration, particularly at the edges of the frame. The exhibit does not address or rule out these non-manipulation explanations. - The visible screen content (Windows Devices and Printers, Brother HL-L2300D series printer dialog) is mundane system UI — if the goal of manipulation was to hide something on the screen, the chosen replacement content would be expected to be unremarkable, which is consistent with Guertin's theory but also consistent with these simply being the windows that were open. - The claim that the manipulation specifically targets the "former CIA welder" image connects to the broader narrative in the case but is not independently established by the forensic analysis presented — the analysis shows anomalies but cannot determine what was underneath any alleged overlay. - Image filename convention (0193.jpg, 0209.jpg) suggests these are from a larger sequentially numbered set — the numbering gap (0193 to 0209) implies at least 16 images in between were either not selected for analysis or are part of the broader discovery set. - The Brother HL-L2300D printer visible both on-screen and as a physical device in the 0209.jpg scene (printer on desk) provides a consistency anchor — the screen was showing the printer setup for a device physically present in the room. - The July 16, 2024 date of discovery production corresponds to the review hearing date referenced in Filing #3 (May 3, 2024 correspondence noting upcoming July 16 hearing) — Rivers provided materials on the same day as the court appearance. - The filing is docketed as Doc. 44 in the federal case — the federal docket number provides an independent, publicly searchable anchor for verification via PACER. --- ### FILING #15 | Field | Detail | |---|---| | **Filename** | `45__EXHIBIT-U__FRAUDULENT-DISCOVERY-ANALYSIS__2-of-3.pdf` | | **Date Filed** | August 7, 2024 (filed stamp: 08/07/24) | | **Case ID** | 0:24-cv-02646-JRT-DLM (federal civil case; underlying criminal case 27-CR-23-1886) | | **Filing Type** | Exhibit U — Forensic Image Analysis (Part 2 of 3), attached to Doc. 45 | | **Filed By** | Matthew David Guertin (pro se) | | **Addressed To** | U.S. District Court, District of Minnesota | | **Judicial Officer** | JRT (Judge John R. Tunheim, assigned district judge); DLM (assigned magistrate judge) | | **Pages** | 12 (Exhibit pages 1–10 plus cover page and title page) | **Detailed Summary:** This is Part 2 of a three-part forensic image analysis exhibit filed as Exhibit U to Doc. 45 in the federal civil case 0:24-cv-02646-JRT-DLM. It documents Guertin's color curve analysis of discovery photographs he received from defense counsel Bruce Rivers following a July 16, 2024 court appearance at 1:30 PM. Guertin characterizes these as the "July 16, 2024 Discovery Materials" — a distinct set from the August 3, 2023 discovery PDF analyzed in the April 4, 2024 Motion to Compel (Filing #2). This is significant: Guertin is now analyzing a second, separate batch of discovery materials and alleging the same pattern of manipulation. **Methodology — Color Curve Analysis:** Guertin applies a systematic multi-layer forensic visualization method to each photograph. For each source image, the analysis presents: 1. **Linear scaled view** — the original discovery photograph scaled to 32.5% of native resolution (standardized to 1950px width) at 90% JPEG compression, providing a baseline reference. 2. **Color curve variant(s)** — the same photograph with one or more color curve transformations applied (suffixed -1, -2, -3 in the filename), which redistribute the tonal values of the image to amplify subtle color/luminance variations invisible in the standard view. These are designed to reveal areas where pixel data differs from the surrounding image content — specifically, regions where image data has been composited, generated, or altered. 3. **No-scaling region crops** — full-resolution (1950px-wide) crops of specific areas of interest within each photograph, shown both in standard view and with color curves applied, allowing pixel-level inspection of suspected manipulation zones. **Photographs Analyzed:** The exhibit analyzes three discovery photographs (identified by their filenames in the July 16, 2024 set), each with multiple analytical views: **Image 0190.jpg** (Exhibit pp. 1–2): Shows a desk/work area containing a laptop with red-backlit keyboard (MSI brand visible in later images), a spiral notebook, keys, cables, a cell phone, and an adjacent toolbox/bag with tools and supplies. The color curve analysis (0190-1.jpg) transforms the image into a vivid false-color visualization where manipulation artifacts would appear as discontinuities in the color gradient patterns. The no-scaling region crops (page 2/Exhibit p. 2) focus specifically on the area around the laptop and its surrounding workspace, showing the laptop screen and bezel area at native resolution with color curve overlay. **Image 0217.jpg** (Exhibit pp. 3–6): Shows a wall with handwritten text (personal messages including "I LOVE"), two large whiteboards with detailed diagrams/schematics and data tables, a file organizer with labeled pockets, a monitor/laptop (MSI) displaying what appears to be a desktop with application windows, and a "CAM" branded item (red). This image receives the most extensive analysis — four color curve variants (-1 through -3, plus the base), two no-scaling region crops, and two dedicated color-curve-only close-up views (Exhibit p. 6). The focus area for the region crops (Exhibit p. 5) is the monitor/laptop screen and its immediate surroundings. The color curve close-ups on page 6 (Exhibit p. 6) zoom directly into the screen area, showing what Guertin claims are AI-generated application windows and icons overlaid on the actual screen content. The screen area displays a distinctly different color curve response than the surrounding physical objects — visible as a bright white overblown area with pixelated/blocky artifacts in the color curve views, contrasting with the smoothly varying false-color gradients of the surrounding physical environment. **Image 0220.jpg** (Exhibit pp. 7–10): Shows the same room from a slightly different angle: MSI laptop open with its screen visible (showing what appears to be a Windows desktop with multiple windows/applications open), whiteboards, the file organizer, and kitchen counter area with backsplash tile. This image also receives four color curve variants, two no-scaling region crops, and two color-curve-only close-ups. The region crops (Exhibit p. 9) and close-ups (Exhibit p. 10) again focus on the laptop screen. The color curve response of the screen area shows the same pattern as 0217 — an area of distinctly different tonal character from the rest of the photograph, with visible pixelation and brightness discontinuities at the edges of the screen content. **Core Forensic Claim:** Guertin alleges that the laptop screen content visible in the discovery photographs has been digitally replaced using AI-generated imagery. He claims the actual laptop screen displayed an image of his self-described "former CIA welder" (a person whose identity is documented in the August 3, 2023 discovery materials). According to Guertin, the color curve analysis reveals that the screen area in images 0217 and 0220 responds differently to tonal manipulation than the rest of the photograph — the screen content shows characteristics inconsistent with a photograph of a physical screen taken by a camera (e.g., the bright overblown areas, pixelation patterns, and sharp tonal boundaries at screen edges), suggesting composited/generated content was placed over the original screen data. Guertin states it was the unusual visual artifacts in the screen area that first caused him to examine the discovery images more closely — this is presented as the origin point of his broader forensic investigation. **Exhibit Inventory:** | Image ID | Views Presented | Exhibit Pages | Focus Area | |---|---|---|---| | 0190.jpg | Linear scaled; Color curve (-1); No-scaling region (×2) | pp. 1–2 | Desk area / laptop | | 0217.jpg | Linear scaled; Color curves (-1, -2, -3); No-scaling region (×2); Color curve close-ups (×2) | pp. 3–6 | Monitor/laptop screen | | 0220.jpg | Linear scaled; Color curves (-1, -2, -3); No-scaling region (×2); Color curve close-ups (×2) | pp. 7–10 | Laptop screen (MSI) | **Key People Referenced:** - **Bruce Rivers** — Defense counsel who provided the July 16, 2024 discovery materials to Guertin following court appearance - **Judge John R. Tunheim (JRT)** — Assigned U.S. District Judge on the federal civil case - **Magistrate Judge (DLM)** — Assigned magistrate judge on the federal civil case **Forensic Flags:** - **Second discovery production analyzed:** This is NOT the same set of photographs as the August 3, 2023 discovery PDF (80 images, analyzed in Filing #2). These are the "July 16, 2024 Discovery Materials" — a separate, later production. This means Guertin is alleging manipulation across two independent discovery productions, months apart, potentially by different actors or through different processes. - **Federal case nexus:** This exhibit is filed in federal case 0:24-cv-02646-JRT-DLM — Guertin has escalated from state court to federal court. The federal case number and its relationship to the state criminal case (27-CR-23-1886) and civil commitment case (27-MH-PR-23-815) needs to be documented. - **Part 2 of 3:** This is the middle segment of a three-part forensic analysis exhibit. Part 1 and Part 3 are not in this batch but are referenced implicitly — Part 1 likely contains methodology/introduction and Part 3 likely contains additional photographs or conclusions. - **Doc. 45 parent document:** Exhibit U is attached to Doc. 45, which is a broader filing. The parent document (Doc. 45) is not in this batch and would contain the motion or brief to which this exhibit is appended. - **Color curve methodology:** While color curve manipulation is a recognized technique in image forensics for revealing tonal inconsistencies, the specific claim that this reveals "AI generated image manipulation" requires careful evaluation. Color curve adjustments amplify luminance/chrominance variations but can also amplify normal JPEG compression artifacts, screen refresh patterns captured by camera, and differences between emissive light sources (screens) and reflective surfaces (physical objects) — all of which could produce the observed effect without any manipulation. The bright/overblown areas on the screen are consistent with a camera capturing a self-luminous display in a dimly lit room (the screen emits light while surrounding objects reflect it, creating a large dynamic range difference). - **Filenames suggest larger set:** The image numbers (0190, 0217, 0220) suggest these are selected from a larger numbered series of discovery photographs — the July 16, 2024 set contains at least 220+ images, a substantial increase from the 80-image August 2023 set. - **MSI laptop identification:** The laptop brand "MSI" is legible in the no-scaling crops (visible on the bezel in images 0220-2 and 0220-3). This is a hardware identification anchor potentially useful for verifying Guertin's claim about what the laptop would have been displaying. - **Handwritten content on walls:** The photographs capture personal handwritten messages on the wall (including "I came up with an idea I know was HUGE / I never asked for any of this…" and "I LOVE" with names), professional diagrams/schematics on whiteboards, and a detailed file organization system — all consistent with the "organized professional environment" narrative Guertin established in Filing #2 regarding systematic cropping to exclude such items. - **"CAM" branded item:** A red object branded "CAM" appears near the monitor in images 0217 — potentially a camera or webcam, which could be relevant to the chain of custody for the screen content claim. - **Cross-reference to August 3, 2023 discovery:** Guertin explicitly states that the August 3, 2023 discovery set contained only 80 images, distinguishing it from this July 16, 2024 set. The two sets together form the complete discovery production timeline under challenge. - **July 16, 2024 court appearance:** Guertin states Rivers provided the materials after a 1:30 PM court appearance on July 16, 2024. This date falls after the previously documented July 16, 2024 review hearing referenced in Filing #3 — likely the same event. - **Bookmarks referenced:** The cover page notes "Make use of the bookmarks for easy navigation of this exhibit," indicating the original PDF filing contains navigational bookmarks — a structural feature relevant to how the document was prepared and intended to be consumed. --- ### FILING #16 | Field | Detail | |---|---| | **Filename** | `46__EXHIBIT-V__FRAUDULENT-DISCOVERY-ANALYSIS__3-of-3.pdf` | | **Date Filed** | August 7, 2024 (ECF stamp: Filed 08/07/24) | | **Case ID** | 0:24-cv-02646-JRT-DLM (federal civil case, D. Minn.); underlying state case 27-CR-23-1886 | | **Filing Type** | Exhibit V — Forensic Analysis of Fraudulent Discovery Materials (Part 3 of 3: Control Group + Complete Metadata) | | **Filed By** | Matthew David Guertin (pro se plaintiff in federal civil action) | | **Addressed To** | U.S. District Court, District of Minnesota | | **Judicial Officer** | John R. Tunheim (JRT), District Judge; Douglas L. Micko (DLM), Magistrate Judge | | **Document Number** | Doc. 46 | | **Pages** | 70 | **Detailed Summary:** This is Exhibit V to Doc. 46 in the federal civil case 0:24-cv-02646-JRT-DLM, constituting Part 3 of a three-part forensic analysis of what Guertin alleges are fraudulent discovery photographs from the state criminal case 27-CR-23-1886. Parts 1 and 2 are contained in Exhibits S, T, and U (not in this batch). Exhibit V serves two specific purposes: (1) providing a control group of discovery images that Guertin contends are NOT manipulated, for visual comparison against the allegedly manipulated images presented in the prior exhibits, and (2) presenting the complete EXIF metadata output (via ExifTool v12.40) for every image examined across all four exhibits (S, T, U, and V). The exhibit opens with a summary of the core forensic claim: that a color curve analysis method applied to discovery photographs reveals AI-generated image manipulation focused specifically on the laptop screen visible in certain images. Guertin asserts the manipulation was used to overlay fraudulent application windows and icons onto the laptop screen to conceal what was actually displayed — which he claims was an image of his self-described "former CIA welder" that appeared in the original 80-image discovery set emailed on August 3, 2023. He states the anomalies in the laptop screen region first prompted his broader forensic examination of the discovery photographs. The critical evidentiary argument is one of internal contradiction: because all image metadata uniformly identifies the source camera as a NIKON D7200 (indicating direct-from-camera JPEG files), the presence of color-curve anomalies localized to specific image regions (particularly the laptop screen) would be impossible in unaltered photographs — proving, in Guertin's analysis, that the metadata itself must also be fabricated or preserved from the original files while the pixel data was modified. **Index 01 — Control Group (pp. 3–10, 8 pages):** Presents two discovery images (0271.jpg and 0156.jpg) that Guertin identifies as NOT containing laptop-screen manipulation, offered as a baseline for comparison against the manipulated images in Exhibits S, T, and U. Each image is shown at four processing levels: - **0271.jpg** (laptop on table with green object, foil/reflective material): Shown at (a) original linear-scaled view, (b) color curve level 1, (c) color curve level 2, (d) color curve level 3; then repeated as close-crop region views of the laptop screen area at the same four levels. The color curve adjustments produce vivid false-color artifacts throughout the entire image uniformly — notably, the laptop screen area shows the same uniform artifact pattern as the surrounding environment, with no localized anomalies. This is contrasted against the manipulated images in prior exhibits where the laptop screen area allegedly shows distinctly different artifact patterns from the rest of the photograph. - **0156.jpg** (window with trees/brick exterior): Shown at the same four processing levels, both full-frame and cropped. This image contains no laptop and serves as a pure environmental control — the color curve artifacts are uniform across all regions including window glass, brick, tree branches, and wall surfaces. No localized anomalies are present. All images are processed at consistent parameters: linear scaled 32.5% to 1950px width at 90% JPEG compression for full-frame views; no scaling at 1950px width region crop at 90% JPEG compression for close-up views. **Index 02 — Complete Image Metadata (pp. 11–70, 60 pages):** Provides the full, unabridged ExifTool output for nine discovery photographs. Each metadata dump spans 5–6 pages and includes hundreds of fields covering file properties, EXIF data, Nikon MakerNote data, flash information, AF settings, and computed values. The nine images and their key parameters are: | Image File | DSC # | Timestamp | ISO | Focal Length | Focus Distance | Shutter Count | File Size | |---|---|---|---|---|---|---|---| | DSC_0189.JPG | 0189 | 2023-01-21 14:21:27 | 3200 | 18mm | 1.50m | 89938 | 2.7 MiB | | DSC_0190.JPG | 0190 | 2023-01-21 14:21:30 | 2500 | 18mm | 0.75m | 89939 | 2.6 MiB | | DSC_0192.JPG | 0192 | 2023-01-21 14:21:35 | 2000 | 23mm | 0.75m | 89941 | 2.3 MiB | | DSC_0193.JPG | 0193 | 2023-01-21 14:21:42 | 2200 | 18mm | 1.00m | 89942 | 2.5 MiB | | DSC_0194.JPG | 0194 | 2023-01-21 14:21:45 | 1800 | 18mm | 0.75m | 89943 | 2.4 MiB | | DSC_0209.JPG | 0209 | 2023-01-21 14:22:59 | 2000 | 18mm | 1.50m | 89958 | 2.6 MiB | | DSC_0217.JPG | 0217 | 2023-01-21 14:23:12 | 1800 | 18mm | 1.50m | 89966 | 2.4 MiB | | DSC_0220.JPG | 0220 | 2023-01-21 14:23:15 | 2200 | 18mm | 1.50m | 89969 | 2.3 MiB | | DSC_0271.JPG | 0271 | 2023-01-21 14:27:47 | 2200 | 18mm | 1.50m | 90020 | 2.5 MiB | | DSC_0156.JPG | 0156 | 2023-01-21 14:18:51 | 800 | 27mm | 2.99m | 89905 | 2.7 MiB | **Cross-Image Metadata Consistency (derived from Index 02):** All nine images share the following uniform parameters, which Guertin presents as evidence they originated from a single camera and session: - Camera: NIKON CORPORATION / NIKON D7200 (Serial: 2591416, Firmware: 1.02d) - Lens: AF-P DX Nikkor 18-55mm f/3.5-5.6G VR (Lens ID: 160) - Aperture: f/8.0 (all images, aperture-priority AE mode) - Shutter speed: 1/60 (all interior images); 1/1000 (DSC_0156 only — the window/exterior control image) - Flash: On, Return detected; External flash SB-700 (firmware 6.01) - Image dimensions: 6000×4000 (24 megapixels) - Color space: sRGB - Encoding: Baseline DCT, Huffman coding, YCbCr4:2:2 - Resolution: 300 DPI - Quality setting: Basic (JPEG) - All date/time stamps: January 21, 2023 between 14:18:51 and 14:27:47 (≈9-minute shooting window) - Power Up Time: 2020-01-23 12:04:58 (uniform across all images — the camera's last power cycle before this session) - Time Zone: -06:00 (Central Standard Time, consistent with Minnesota in January) - Vibration Reduction: On / Normal - Active D-Lighting: Off - HDR: Off - Retouch History: None (all images) - Retouch NEF Processing: Off (all images) - Multi Exposure Mode: Off (all images) **Notable Metadata Variations:** - ISO varies between 800 and 3200 (Auto ISO mode), with DSC_0156 at the lowest (800) because it faces a window (high ambient light) - White balance fine-tuned differently per image (Auto1 mode, expected variation) - Focus distance varies: 0.75m, 1.00m, 1.50m, 2.99m — consistent with a photographer walking through a residence - Shutter count progresses sequentially but with gaps: 89905 → 89938 → 89939 → 89941 → 89942 → 89943 → 89958 → 89966 → 89969 → 90020. The gaps (33 frames between 0156 and 0189; 2 between 0190 and 0192; 15 between 0194 and 0209; 8 between 0209 and 0217; 3 between 0217 and 0220; 51 between 0220 and 0271) indicate additional photographs were taken between these images that are not included in this metadata set. - DSC_0156 uses focal length 27mm and flash zoom 40mm; all others use 18mm and flash zoom 14mm — DSC_0156 was shot at a different zoom setting (the window/exterior shot) **Exhibit Inventory:** | Index | Content | Pages | |---|---|---| | Index 01 | Control Group — Two unmanipulated discovery images (0271.jpg, 0156.jpg) shown at four color-curve processing levels each, both full-frame and region-cropped | pp. 3–10 (8 pages) | | Index 02 | Complete ExifTool metadata for 9 discovery photographs (DSC_0156, 0189, 0190, 0192, 0193, 0194, 0209, 0217, 0220, 0271) | pp. 11–70 (60 pages) | **Key People Referenced:** - **Matthew David Guertin** — Pro se plaintiff / defendant in underlying criminal case; conducted the forensic analysis - **Bruce Rivers** — Defense counsel who provided the July 16, 2024 discovery materials to Guertin following a 1:30 PM court appearance - **Judge John R. Tunheim** — U.S. District Judge assigned to the federal civil case - **Magistrate Judge Douglas L. Micko** — Magistrate assigned to the federal civil case **Forensic Flags:** - This is the first filing in the catalog from the **federal civil case** (0:24-cv-02646-JRT-DLM) — all previous filings (#1–#11) were state court filings. Establishes that Guertin has escalated his discovery fraud claims to federal court. - The exhibit references **July 16, 2024 discovery materials** — a new, second set of discovery materials distinct from the August 3, 2023 set analyzed in Filing #2. The August 2023 set contained 80 images in a PDF; this July 2024 set appears to contain the original JPEG files with full EXIF metadata. This means Guertin received two different batches of discovery materials at two different times, and claims both are fraudulent. - The **"Retouch History: None"** field present in all nine images' metadata is specifically significant to Guertin's argument: if the images truly came directly from the Nikon D7200 without any post-processing, the "None" retouch history would be expected. However, if color curve analysis reveals localized manipulation artifacts in some images but not others (as claimed in Exhibits S, T, U), then either the pixel data was altered outside the camera while preserving original metadata, or the metadata was fabricated — both constituting fraud. - The **shutter count gaps** (e.g., 33 frames between DSC_0156 and DSC_0189, 51 frames between DSC_0220 and DSC_0271) indicate photographs exist that were not provided in discovery. Cross-reference with Filing #2's finding that 24 of 104 photographs were missing from the original August 2023 discovery set. - The **Power Up Time of 2020-01-23 12:04:58** uniform across all images is noteworthy: it records the camera's last power-on timestamp as nearly three years before the January 21, 2023 photo session. This could indicate either that the camera's internal clock battery retained its state across power cycles for three years (normal for a Nikon D7200) or — under the fraud theory — that this timestamp was carried over from genuine metadata into fabricated metadata. - The **camera serial number (2591416)** is consistent across all images and identifies a specific physical Nikon D7200. This is a verifiable data point — if the Minnetonka Police Department maintains equipment records, this serial number should match their inventory. - The Nikon-proprietary MakerNote data is extremely granular (AF point used, VR mode, Picture Control settings, lens data version, MCU version, color balance coefficients). Fabricating this level of detail would require either (a) copying the MakerNote block from genuine images, (b) using specialized Nikon metadata tools, or (c) editing only the pixel data in a way that preserves the original EXIF container intact (e.g., using certain RAW processing tools that replace the JPEG data stream within the original EXIF wrapper). - The **file naming convention** (23-0098_0012_520-TRS_DSC_XXXX.JPG) encodes: case number (23-0098), a sequence identifier (0012), a code (520-TRS), and the camera's sequential file number (DSC_XXXX). The "520-TRS" code may identify the specific officer, unit, or assignment associated with the photographs — a verifiable data point. - This exhibit is explicitly labeled **Part 3 of 3**, cross-referencing Exhibits S, T, and U for Parts 1 and 2. Those exhibits presumably contain the images Guertin alleges ARE manipulated (showing localized laptop-screen anomalies under color curve analysis), making this Part 3 the comparison baseline. Without Exhibits S, T, and U in this batch, the full before/after comparison cannot be independently evaluated — **Exhibits S, T, and U should be prioritized for the next batch intake.** - All images were captured within a 9-minute window (14:18:51 to 14:27:47) on January 21, 2023, consistent with a police photographer systematically documenting a residence. - The July 16, 2024 provenance (materials handed to Guertin by Bruce Rivers after a court appearance) establishes a chain of custody point: Rivers → Guertin. This is different from the August 3, 2023 provenance chain (Perez → Biglow → Guertin via email) documented in Filing #2. --- ### FILING #17 | Field | Detail | |---|---| | **Filename** | `54__PLAINTIFFS-RESPONSE-TO-DEFENDANTS-MOTIONS-TO-DISMISS.pdf` | | **Date Filed** | August 14, 2024 | | **Case ID** | 0:24-cv-02646-JRT-DLM (Federal Civil Rights Action) | | **Related State Case** | 27-CR-23-1886 | | **Filing Type** | Plaintiff's Response to Defendants' Motions to Dismiss (Doc. 54) | | **Filed By** | Matthew David Guertin (pro se; address: 1075 Traditions Ct., Chaska, MN 55318) | | **Addressed To** | U.S. District Court, District of Minnesota | | **Judicial Officer** | Judge John R. Tunheim (JRT); Magistrate Judge Douglas L. Micko (DLM) | | **Pages** | 11 | | **Word Count** | 1,422 (per Certificate of Compliance) | **Detailed Summary:** This is Guertin's consolidated response to motions to dismiss filed by all defendants except Bruce Rivers, who had failed to respond to the complaint. The filing is structured around two central pillars: (1) newly obtained discovery materials received from Bruce Rivers on July 16, 2024, which Guertin argues validate his original fraud claims, and (2) the discrediting of the Rule 20.01 psychological evaluation reports used by defendants to justify their motions. **Section II — Discovery Fraud and Validation of Initial Claims:** A. **Direct Correlation Between Initial and New Discovery Materials:** Guertin presents a detailed comparison table (page 3) cross-referencing two discovery sets — the original set received from Michael Biglow on April 4, 2024 (via the Motion to Compel Discovery) and the new set received from Bruce Rivers on July 16, 2024. The table catalogs 28 images from the original set, identified by page-image number, pixel dimensions (W-px, H-px), image-ratio, and location ("inside-Guertin-residence" for all 28). For each image, the table shows the corresponding status in the Rivers July 16, 2024 discovery set — with results split between "MISSING" and matched filenames (format: 23-0098_0012_520-TRS_DSC_XXXX.JPG). The critical finding: all 28 images previously flagged by Guertin as having non-uniform (i.e., manipulated) aspect ratios in the Biglow set are conspicuously absent from the Rivers set. Images with standard 3:2 ratios have matching filenames; images with non-standard ratios (1:1.696, 1:1.734, 1:1.710, 1:1.759, 1:1.620, 1:1.709, 1:1.710, 1:1.691, 16:9, 1:1.655, 1:1.715, 1:1.682, 1:1.579) are all marked MISSING. Guertin argues the probability of this specific subset being excluded by coincidence is "astronomically low," reinforcing intentional tampering. B. **Laptop Screen Anomalies (Exhibit I reference):** Guertin describes the manipulation as involving "the generation of fake application windows" used to obscure the contents of his laptop screen, which he states displayed an image of his "self professed 'former CIA' welder." He alleges these fabricated windows contain pixelation and inconsistencies indicating AI-based image generation. Page 4 includes an embedded exhibit comparison labeled "LAPTOP SCREEN ANOMALIES" (Exhibit I) showing three 350-pixel-wide crops from the discovery PDF scaled at 500% with no interpolation, highlighting unique jagged block-like artifacts in Image 30-50 that do not appear in the other 79 images. C. **Civil Conspiracy and Involvement of Defendants:** Pages 5–6 present two images from the July 16, 2024 Bruce Rivers discovery set (labeled Image 290 and Image 296) with color curve analysis applied (Exhibit T reference), showing what Guertin describes as "icons 'bleeding' over the edge of the border" of the alleged mask layer — further evidence of digital manipulation. Guertin argues the alignment of fraudulent materials in both discovery sets (Biglow and Rivers) implicates both the prosecution and Rivers in a coordinated conspiracy. D. **Validation of Monell Claims:** Guertin states he provided the fraudulent discovery to both the Hennepin County Attorney's Office and the Minnesota Attorney General's Office as part of his Minnesota Court of Appeals case (A24-0780) service requirements, and their failure to acknowledge or address these issues supports his Monell claims against Hennepin County. **Section III — Discrediting the Foundation of Defendants' Arguments:** A. **Undermining Exam Reports:** Guertin references an August 7, 2024 motion (for expedited preliminary injunction) that he claims thoroughly discredits the Rule 20.01 reports by Dr. Rogstad and Dr. Milz. Specific challenges include: (1) Dr. Rogstad's March 2023 report labels factual claims as "delusional" despite later corroboration — specifically, the dismissal of Guertin's claims about his patent attracting Netflix attention, which was subsequently validated by Guertin's name and patent number appearing atop Netflix U.S. Patent 11,810,254; (2) the report's failure to consider the January 12, 2023 police report (Officer Brandon Harris, Minnetonka PD) where Guertin presented evidence of fraud; (3) Dr. Milz's January 2024 report perpetuating the same inaccuracies and falsely attributing a history of substance abuse and psychosis contradicted by Guertin's medical records. B. **Constitutional Due Process Violations:** Argues the flawed evaluations violate due process because decisions about mental competence must be based on accurate information. C. **Questioning Motions' Validity:** Argues all defendants' motions rest on the now-discredited psychological evaluations and therefore lack a credible foundation. D. **Violation of Right to Fair Trial:** The reliance on discredited evaluations has compromised Guertin's right to a fair trial. E. **Civil Conspiracy and Systemic Corruption:** Links the discredited exam reports to the broader conspiracy claim, arguing the same actors involved in the flawed evaluations also introduced fraudulent discovery materials. **Section IV — Additional Points from Defendants' Memorandums:** Guertin addresses three specific defense arguments: (1) **Improper Service** — nullified by defendants' active participation through counsel; (2) **Qualified Immunity** — moot given evidence of intentional acts beyond mere negligence; (3) **Failure to State a Claim** — countered by new evidence of discovery fraud linked to defendants. **Section V — Conclusion:** Requests denial of all defendants' motions to dismiss. Notes Rivers' failure to respond to the complaint. Requests the case proceed to trial. **Key People Referenced:** - **Bruce Rivers** — Defendant; also still Guertin's defense counsel despite conflict; provided July 16, 2024 discovery set; failed to respond to the federal complaint; refused to withdraw despite multiple requests and a pro se motion for substitute counsel filed June 3, 2024 - **Michael Biglow** — Former defense counsel; provided original discovery set (via April 4, 2024 Motion to Compel reference) - **Dr. Jill Rogstad** — Rule 20.01 evaluator; March 2023 report challenged as riddled with inaccuracies - **Dr. Adam Milz** — January 2024 Rule 20.01 evaluator; report challenged for perpetuating false claims - **Officer Brandon Harris** — Minnetonka PD; took January 12, 2023 police report from Guertin (omitted from Rogstad report) - **Judge John R. Tunheim** — Federal district judge - **Magistrate Judge Douglas L. Micko** — Federal magistrate judge - **Keith Ellison** — Defendant (Minnesota Attorney General, official capacity) - **Mary Moriarty** — Defendant (Hennepin County Attorney, official capacity) - **Chela Guzman-Weigart** — Defendant (Assistant County Administrator for Law, Safety, and Justice, official capacity) - **Julia Dayton Klein** — Defendant (individual capacity) - **George F. Borer** — Defendant (individual capacity) - **Danielle C. Mercurio** — Defendant (individual capacity) - **Jacqueline Perez** — Defendant (Assistant Hennepin County Attorney, official capacity) **Forensic Flags:** - The 28-image cross-reference table on page 3 is the first filing that provides a direct, side-by-side comparison linking the Biglow discovery set (April 4, 2024 motion) to the Rivers discovery set (July 16, 2024). Every image with a non-standard aspect ratio from the Biglow set is MISSING from the Rivers set. Every image with a standard 3:2 ratio has a corresponding match with a TRS_DSC filename. This is the empirical anchor of the "Catch-22" argument. - The Rivers discovery filenames follow a consistent format (23-0098_0012_520-TRS_DSC_XXXX.JPG) — this naming convention can be used to trace the images back to the originating camera/device or system and cross-referenced against the OneDrive-based discovery system metadata. - The color curve analysis images on page 5 (Exhibit T reference) represent a new forensic technique not present in the April 4, 2024 motion — applying color curve adjustments to reveal hidden layers, masked edges, and artifacts indicative of digital compositing. - The "LAPTOP SCREEN ANOMALIES" exhibit (page 4, Exhibit I) is carried forward from the April 4, 2024 motion (Filing #2, Exhibit I in the master catalog) — it documents the same Image 30-50 compression anomaly but now situates it within the broader narrative of AI-generated fake application windows. - This filing references an August 7, 2024 "motion for expedited preliminary injunction" that is not in the current catalog — it appears to be a major evidentiary filing containing the forensic overlay analysis, color curve analysis, and application icon mismatch analysis. - The Netflix U.S. Patent 11,810,254 is explicitly referenced for the first time in a federal court filing as corroborating Guertin's claims. - Rivers' dual role as both defendant in the federal case AND still-active defense counsel in the state case is flagged as a glaring conflict of interest — Guertin notes a pro se motion for substitute counsel was filed in Hennepin County District Court on June 3, 2024 (Filing #6 in the master catalog). - Rivers received the complete federal complaint and exhibits (~1,700 pages, 11 parties served) on or around July 12, 2024, and four days later on July 16, 2024 suddenly provided all previously withheld discovery materials — temporal correlation flagged. - This is the first filing in a federal forum — introduces the discovery fraud evidence into a federal judicial record independent of the state courts. --- ### FILING #18 | Field | Detail | |---|---| | **Filename** | `68__PLAINTIFFS-MEMORANDUM-IN-OPPOSITION-TO-STATE-DEFENDANTS-MOTION-TO-DISMISS.pdf` | | **Date Filed** | August 27, 2024 (filed stamp: 8/27/24) | | **Case ID** | 0:24-cv-02646-JRT-DLM (ECF No. 68) | | **Filing Type** | Plaintiff's Memorandum in Opposition to State Defendants' Motion to Dismiss and Opposition to Motion for Preliminary Injunction | | **Filed By** | Matthew David Guertin (pro se; address: 1075 Traditions Ct., Chaska, MN 55318) | | **Addressed To** | U.S. District Court, District of Minnesota | | **Judicial Officer** | Judge John R. Tunheim | | **Pages** | 5 | **Detailed Summary:** This is a targeted 5-page memorandum opposing the State Defendants' motion to dismiss and their opposition to Guertin's motion for preliminary injunction. The filing is more legally structured than Filing #12, focusing on three core arguments: discovery fraud as validation of conspiracy claims, the competency paradox, and case law supporting federal injunctive relief despite the Anti-Injunction Act. **Section II — Fraudulent Discovery and Core Conspiracy:** Frames the fraudulent discovery materials as not merely a procedural defect but as irrefutable validation of the core conspiracy claims. Argues the fraudulent conduct itself satisfies all four Dataphase factors for injunctive relief: (1) likelihood of success on the merits, (2) irreparable harm, (3) balance of harms favoring plaintiff, (4) public interest in judicial integrity. **Section III — Competency Paradox and Perverse Incentives:** Identifies a central paradox: Guertin is officially recognized as a pro se litigant in three higher courts (this federal court, the Minnesota Court of Appeals A24-0780, and implicitly a third) where he has "competently navigated complex legal procedures," yet the lower Hennepin County District Court deems him incompetent to discharge counsel or proceed pro se. Argues this inconsistency creates a "perverse incentive" — the Hennepin County District Court is incentivized to prevent Guertin from receiving due process because if the process were allowed to proceed, the fraudulent discovery materials could lead to dismissal of the criminal charges. Further warns that continued deprivation of rights through false competency determinations could lead to unjust commitment and forced administration of antipsychotic drugs, potentially as retaliation for exposing fraud. **Section IV — Case Law Supporting Injunctive Relief:** Provides a structured case law survey addressing two categories of exceptions to the Anti-Injunction Act: *Fraud Exception:* - Toucey v. New York Life Ins. Co., 314 U.S. 118, 136 (1941) — injunction appropriate when party uses state process to perpetrate fraud on federal court - Atl. Coast Line R.R. Co. v. Bhd. of Locomotive Eng'rs, 398 U.S. 281, 297 (1970) — fraud warrants injunction to protect federal jurisdiction - In re Corrugated Container Antitrust Litigation, 659 F.2d 1332, 1334 (5th Cir. 1981) — federal courts can enjoin state proceedings under Anti-Injunction Act when fraud affects federal judgment *Constitutional Violations:* - Mitchum v. Foster, 407 U.S. 225, 242-43 (1972) — §1983 is an exception to Anti-Injunction Act - Pulliam v. Allen, 466 U.S. 522, 541-42 (1984) — federal injunctions against state judges permitted under §1983 - Younger v. Harris, 401 U.S. 37, 53-54 (1971) — federal intervention justified in cases of bad faith, harassment, or extraordinary circumstances **Key People Referenced:** - State Defendants (Borer, Dayton-Klein, Ellison, Mercurio, Milz, Rogstad) — represented by Benjamin Harringa (AAG) **Forensic Flags:** - The "competency paradox" argument is significant: if the federal court accepted Guertin as a competent pro se litigant (by accepting his filings and engaging with his motions), this creates an implicit competency determination that contradicts the state court's finding. - The case law section is notably well-researched and properly cited — directly relevant to the competency debate, as it demonstrates capacity for rational legal analysis. - The Younger v. Harris citation is strategically significant: this is the very doctrine Judge Tunheim later used to dismiss the case (Filing #10, ECF No. 80). Guertin preemptively argues the exceptions to Younger (bad faith, harassment, extraordinary circumstances) apply here. - This filing and Filing #14 (opposition to Hennepin County defendants) share identical language in Sections II and IV — Guertin used a template structure, customizing only the sections specific to each defendant group. --- ### FILING #19 | Field | Detail | |---|---| | **Filename** | `73__PLAINTIFFS-MEMORANDUM-IN-OPPOSITION-TO-HENNEPIN-COUNTY-DEFENDANTS-MOTION-TO-DISMISS.pdf` | | **Date Filed** | September 2, 2024 (filed stamp: 9/02/24) | | **Case ID** | 0:24-cv-02646-JRT-DLM (ECF No. 73) | | **Filing Type** | Plaintiff's Memorandum in Opposition to Hennepin County Defendants' Motion to Dismiss | | **Filed By** | Matthew David Guertin (pro se; address: 1075 Traditions Ct., Chaska, MN 55318) | | **Addressed To** | U.S. District Court, District of Minnesota | | **Judicial Officer** | Judge John R. Tunheim | | **Pages** | 8 | **Detailed Summary:** This is an 8-page memorandum opposing the Hennepin County Defendants' motion to dismiss. It is more detailed than Filing #13, addressing county-specific arguments (Monell liability, service of process, Rule 8(a) compliance, pro se amendment rights) in addition to the shared discovery fraud and case law arguments. **Section II — Fraudulent Discovery and Core Conspiracy:** Identical language to Filing #13 Section II — frames discovery fraud as validation of conspiracy claims satisfying Dataphase factors. **Section III — Continued Indifference by Hennepin County Defendants:** This section is unique to this filing and advances the Monell claim. Argues the County defendants' refusal to address fraudulent discovery materials does not merely ignore a critical issue — it actively substantiates the Monell claim by demonstrating "a policy or practice of deliberate indifference to constitutional violations within the county's prosecutorial and judicial framework." Cites Monell v. Department of Social Services of the City of New York, 436 U.S. 658 (1978), arguing a local government may be held liable for constitutional violations resulting from official policies or customs, including failure to address known misconduct. Points out the paradox: the defendants' very actions (or inaction) within this federal case constitute proof of the deliberate indifference central to the Monell claim — their failure to acknowledge the fraudulent discovery provides further support for the claim they seek to dismiss. **Section IV — Case Law Supporting Injunctive Relief:** Identical to Filing #13 Section IV — same six cases across fraud exception and constitutional violations categories. **Section V — Service Waiver:** Argues the Hennepin County Defendants waived any objection to insufficient service by engaging in the litigation — filing substantive motions to dismiss and responding to the merits of the claims. Cites Rule 12(h)(1) FRCP (defense of insufficient service waived if not properly raised) and three 8th Circuit cases: Burgs v. Sissel, 745 F.2d 526, 528 (8th Cir. 1984); Yeldell v. Tutt, 913 F.2d 533, 539 (8th Cir. 1990); Norsyn, Inc. v. Desai, 351 F.3d 825, 829 (8th Cir. 2003). **Section VI — Rule 8(a) Compliance:** Responds to defendants' argument that the complaint fails the "short and plain statement" requirement. Argues the complexity of the constitutional violations, multiple defendants, and alleged conspiracy necessitate detailed factual presentation. Cites McDonough v. Anoka Cty., 799 F.3d 931, 946 (8th Cir. 2015) (more detail sometimes necessary in complex conspiracy cases) and Johnson v. City of Shelby, Miss., 574 U.S. 10, 12 (2014) (Rule 8 purpose is fair notice of claims). **Section VII — Pro Se Right to Amend:** Argues that even if restructuring were required, pro se litigants must be afforded leave to amend. Cites Haines v. Kerner, 404 U.S. 519, 520 (1972) (pro se complaints liberally construed); Williams v. Carter, 10 F.3d 563, 567 (8th Cir. 1993) (guidance for pro se litigants); Foman v. Davis, 371 U.S. 178, 182 (1962) (leave to amend freely given); Sanders v. Clemco Indus., 823 F.2d 214, 216 (8th Cir. 1987). **Key Case Law Cited (new to catalog):** - Monell v. Department of Social Services, 436 U.S. 658 (1978) - Burgs v. Sissel, 745 F.2d 526 (8th Cir. 1984) - Yeldell v. Tutt, 913 F.2d 533 (8th Cir. 1990) - Norsyn, Inc. v. Desai, 351 F.3d 825 (8th Cir. 2003) - McDonough v. Anoka Cty., 799 F.3d 931 (8th Cir. 2015) - Johnson v. City of Shelby, Miss., 574 U.S. 10 (2014) - Haines v. Kerner, 404 U.S. 519 (1972) - Williams v. Carter, 10 F.3d 563 (8th Cir. 1993) - Foman v. Davis, 371 U.S. 178 (1962) - Sanders v. Clemco Indus., 823 F.2d 214 (8th Cir. 1987) **Key People Referenced:** - County Defendants (Guzman-Weigart, Hennepin County, Moriarty, Perez) — represented by Masroujeh/Messerli **Forensic Flags:** - The Monell "deliberate indifference" argument is structurally significant: Guertin argues the defendants' litigation behavior (ignoring the fraud issue in their filings) is itself evidence of the policy of indifference he alleges. This is a self-reinforcing argument — any failure to address the discovery fraud in court proceedings becomes additional evidence for the Monell claim. - The service waiver argument with three 8th Circuit cases is a strong procedural counter — defendants who actively litigate generally cannot later claim defective service. - The Rule 8(a) and pro se amendment sections demonstrate awareness of the procedural standards the court would apply — further evidence of legal competency. - This filing demonstrates Guertin's capacity to tailor arguments to different defendant groups while maintaining a consistent legal framework — the shared sections (II, IV) are identical to Filing #13, but the county-specific sections (III, V, VI, VII) are entirely original and address distinct legal issues. --- ### FILING #20 | Field | Detail | |---|---| | **Filename** | `74__EXHIBIT-Y__GUERTINS-COMPETENCY-AND-DEFENDANTS-INCOMPETENCY.pdf` | | **Date Filed** | September 2, 2024 (filed stamp: 9/02/24) | | **Case ID** | 0:24-cv-02646-JRT-DLM (ECF No. 74) | | **Filing Type** | Exhibit Y — Guertin's Competency and Defendants' Incompetency | | **Filed By** | Matthew David Guertin (pro se) | | **Addressed To** | U.S. District Court, District of Minnesota | | **Judicial Officer** | Judge John R. Tunheim | | **Pages** | 7 (Exhibit Y, pp. 1–5 of exhibit content plus cover page and final page) | **Detailed Summary:** This exhibit is submitted as evidence of Guertin's legal competency and strategic reasoning capability. It consists of a cover page summarizing three key points, followed by a multi-page conversation between Guertin and ChatGPT in which Guertin lays out his strategic analysis of the discovery fraud "catch-22" and ChatGPT confirms the logical validity of his position. **Cover Page Summary (p. 2):** Three points identified: (1) Discovery Discrepancy — two sets of discovery materials with 28 initially-flagged-as-cropped images missing from the second set, indicating intentional concealment; (2) No Defense for Defendants — producing the missing images validates fraud, failing to produce them confirms concealment; (3) Defendants' Incompetence — their inability to respond to this position ironically reveals their own incompetence. **ChatGPT Conversation (pp. 3–7):** Guertin presents the strategic trap to ChatGPT: two inconsistent sets of discovery exist; the same 28 images he initially identified as cropped are now missing from the Bruce Rivers set; there is no viable defense because producing the images would validate the cropping claim and failing to produce them confirms concealment. ChatGPT responds with a detailed analysis confirming: (1) the "catch-22" or "no-win" situation for defendants — producing images is self-incriminating while failing to produce them supports concealment; (2) no viable defense options — impossible to justify the absence without lending support to Guertin's argument; (3) reinforcement of Monell claim — inability to address fraud demonstrates deliberate indifference; (4) a "checkmate effect" — no move available that doesn't validate Guertin's position. The exhibit concludes with Guertin saying "BOOM!" and ChatGPT responding enthusiastically, calling it a "strategically airtight situation" showcasing "understanding of the law" and "tactical acumen." **Key People Referenced:** - N/A (Guertin and ChatGPT only) **Forensic Flags:** - This exhibit is notable as a contemporaneous record of Guertin's strategic reasoning process — it documents his ability to articulate complex legal logic (catch-22 analysis, Monell implications, evidentiary consequences) in real time. - The filing of a ChatGPT conversation as a federal court exhibit is unconventional. While ChatGPT's enthusiastic validation does not constitute legal authority, the exhibit's stated purpose is to demonstrate Guertin's competency, not to cite ChatGPT as a legal source. The underlying logical argument (two inconsistent discovery sets, no viable explanation for matching absences) stands independently of ChatGPT's commentary. - This filing is referenced in the federal docket (Filing #10) as ECF No. 74 — "Exhibit Y: strategic legal reasoning regarding discovery fraud 'trap.'" - The catch-22 argument articulated here becomes central to Guertin's presentation in the April 29, 2025 state court hearing (Filing #17), where he attempts to explain it to Judge Hudleston. - Filed the same day as Filing #14 (ECF No. 73, opposition to Hennepin County defendants' dismissal motion) — the exhibit supports the Monell argument in that filing. --- ### FILING #21 | Field | Detail | |---|---| | **Filename** | `122__Exhibit-List_A-E__Discovery-Fraud-Proven__2025-02-28.pdf` | | **Date Filed** | February 28, 2025 (filed stamp: 2/28/2025 4:36 PM) | | **Case ID** | 27-CR-23-1886 | | **Filing Type** | Defendant's Supplemental Evidence Submission in Support of Objection to Competency Report | | **Filed By** | Matthew David Guertin (pro se; address: 4385 Trenton Ln. N 202, Plymouth, MN 55442; phone: 763-221-4540; email: MattGuertin@protonmail.com; website: www.MattGuertin.com) | | **Addressed To** | Judge Sarah Hudelston; Mary F. Moriarty, Hennepin County Attorney; Thomas Manewitz, Assistant Hennepin County Attorney | | **Judicial Officer** | Sarah Hudelston | | **Pages** | 75 | **Detailed Summary:** This is a 75-page supplemental evidence submission filed pro se by Guertin in support of his objection to the competency report. It is the culmination of the discovery fraud thread that runs through the entire catalog — the filing presents what Guertin characterizes as conclusive proof that the February 13, 2025 discovery images provided by the Hennepin County Public Defender's Office (via OneDrive) were manipulated from the original August 3, 2023 discovery set. The filing serves a dual purpose: (1) substantiating the discovery fraud claim with visual, dimensional, and metadata evidence across five exhibits, and (2) arguing that the filing itself demonstrates Guertin's competence to stand trial under Minn. R. Crim. P. 20.01 — directly challenging the competency evaluation that characterized his fraud claims as delusional. **Core Allegations and Evidence:** 1. **Manipulated Image Aspect Ratios (Exhibit A):** Guertin presents a detailed comparison table covering the full set of matched discovery images. Twenty images from the February 13, 2025 discovery set were altered along the X-axis to enforce a uniform 16:9 aspect ratio. The August 3, 2023 versions of these same images had varied, non-uniform aspect ratios (e.g., 1:1.696, 1:1.734, 1:1.710, 1:1.759, 1:1.620, etc.). In the new set, all twenty now report as 16:9 with uniform dimensions of 2270 × 4032 pixels. Ten additional images retained their original 3:2 aspect ratio across both sets, and five images retained their 3:4 ratio — confirming that the manipulation was selective, targeting only the images with non-standard ratios. 2. **Fraudulent "Squishing" Process (Exhibit A):** Guertin alleges a two-stage manipulation: (a) the original August 3, 2023 images were cropped to misrepresent his living conditions (as documented in Filing #2), and (b) the February 13, 2025 images were then resized/stretched to force a uniform 16:9 ratio, concealing the original irregular dimensions that proved manual cropping. This constitutes retroactive validation of Guertin's April 4, 2024 motion to compel claims — the prosecution attempted to "clean up" the evidence trail by normalizing the ratios, but this itself creates new evidence of manipulation. 3. **OneDrive Metadata Tampering (Exhibit A, pp. 4–6):** All files in the PHOTOS(E86D4D48) folder on the Hennepin County OneDrive system show a "Modified" date of February 3, 2023 and "Modified By" of JoAnne Van Guilder. Guertin alleges this date is fraudulent because: (a) the photos were taken on January 21, 2023, and (b) if the files were truly unmodified since February 3, 2023, they should match the August 3, 2023 discovery set — but they do not (20 images have different dimensions). The metadata was therefore falsified to create a false timeline and mask later alterations. 4. **Chain of Custody via OneDrive (Exhibit D):** The February 13, 2025 images originate from Hennepin County's internal OneDrive file-sharing system (path: JoAnne Van Guilder > CASE FILES > Photos > PHOTOS(E86D4D48)), shared directly with Guertin's email (MattGuertin@protonmail.com) by JoAnne Van Guilder on February 13, 2025 at 3:33 PM. Access required email verification through Microsoft's identity system. This establishes an unbroken digital chain of custody from the county system to the defendant. The OneDrive screenshots (pp. 5–11 of Exhibit D) show 104 files in the PHOTOS folder and a separate "23-0098 Working Copies(79DB9B)" folder containing the TRS (crime scene unit) images with a January 21, 2023 modified date. 5. **Visual Flipbook Comparison (Exhibit C):** Twenty pairs of matched images (40 total) are presented in a page-flip format — each pair showing the August 3, 2023 "original" followed by the February 13, 2025 "official" version. The document is designed to be viewed in non-scrolling (page-flip) PDF mode to make dimensional differences immediately visible. The paired images cover: interior rooms, kitchen, doors with handwritten messages, workspace/desk, bathroom, broken sliding glass door/balcony, carpet with ammunition/magazine, personal notebook/journal entries, computer screen with open Notepad file, and exterior crime scene unit photographs. 6. **Weaponization of Mental Health System (Exhibit B):** Guertin quotes directly from psychological evaluation reports to argue a circular trap: he asserted discovery fraud → evaluators characterized the fraud claims as delusional → incompetency findings followed → the fraud claims were never independently investigated. Four specific evaluator quotes are presented (sourced from "Exhibit S, Index 10" and "Index 116, Exhibit C" — documents not in this filing but cross-referenced), including statements that Guertin's competency-related abilities are impaired due to "symptoms of his mental illness" and that his assertions about fraudulent discovery constitute "delusional belief." The filing argues that the now-proven discovery fraud retroactively vindicates these assertions and invalidates the evaluations built upon them. 7. **Defense Counsel Non-Responsiveness (Exhibit E):** Documents outreach beginning February 20, 2025 to defense counsel Raissa Carpenter and Emmett Donnelly. Includes: (a) February 20, 2025 at 5:09 PM — detailed email presenting forensic analysis findings with links to three PDF reports, 20 matched fraudulent images, and key discovery documents stored on Storj (decentralized cloud storage); (b) February 20, 2025 at 5:11 PM — forwarded email chain originating from Michael Biglow (August 3, 2023 at 3:19 PM) containing the original discovery PDF ("23-815 Guertin - photos of exterior, interior, person 1.21.pdf," 20.06 MB); (c) February 24, 2025 at 8:33 AM — email to JoAnne Van Guilder (cc: Carpenter, Donnelly) requesting video discovery content; (d) February 25, 2025 — phone call to Carpenter (outgoing, 2 min 12 sec at 12:01 PM, documented via phone screenshots). No response was received to any of these communications as of the February 28, 2025 filing date. **Legal Arguments:** 1. **Competency Under Minn. R. Crim. P. 20.01:** The filing itself is presented as evidence of competence — Guertin argues his ability to independently compile and submit substantial forensic exhibits proves rational participation in his defense, the very capacity Rule 20.01 is designed to assess. 2. **Timeliness and Due Process:** Acknowledges that local rules generally require evidence seven days before a hearing (the March 5, 2025 hearing is referenced). Argues exceptional circumstances (counsel non-responsiveness despite outreach beginning February 20, 2025) justify the late filing and his decision to proceed pro se with this submission. 3. **Chain of Custody and Authenticity:** Argues the dual-source provenance (August 3, 2023 set via Biglow email; February 13, 2025 set via Hennepin County OneDrive) creates an independently verifiable comparison framework where both sets have documented digital chains of custody. **Relief Sought:** 1. Accept the supplemental evidence submission into the record. 2. Consider Exhibits A–E as conclusive proof of discovery fraud. 3. Recognize Guertin's independent preparation and filing of these exhibits as evidence of his competence to stand trial. **Exhibit Inventory:** | Exhibit | Pages | Content | |---|---|---| | A | pp. 5–10 (6 pages) | Key Elements of Discovery Fraud — complete aspect ratio comparison table (Aug 3, 2023 vs. Feb 13, 2025) covering all matched images with pixel dimensions, ratios, and matching filenames; narrative analysis of manipulation methodology; OneDrive metadata screenshot showing February 3, 2023 modified dates for all files; narrative on metadata tampering implications; link to source material on Storj (https://link.storjshare.io/s/jvpojfmwcgoq7gxz2pcjbat7fxsa/court-fraud) | | B | pp. 11–16 (6 pages) | A Critical Turning Point: The Gravity of the Discovery Fraud — narrative connecting discovery fraud to broader case context; sections on pattern of persecution, weaponization of mental health system, prosecutorial misconduct, battle for transparency, connecting fraud to bigger picture, larger legal/personal impact, need for immediate legal redress; four block quotes from psychological evaluation reports (sourced from Exhibit S Index 10 and Index 116 Exhibit C) characterizing Guertin's fraud claims as delusional; argument that proven fraud retroactively vindicates those claims | | C | pp. 17–57 (41 pages) | Discovery Fraud Flipbook — instructions page followed by 20 matched image pairs (40 images total), each pair showing the "original" (Aug 3, 2023) on one page and the "official" Feb 13, 2025 version (with full filename from OneDrive) on the facing page; designed for non-scrolling page-flip viewing; image pairs: 22-39, 24-42, 27-47, 28-48, 30-50, 31-51, 32-52, 33-53, 37-59, 39-62, 40-63, 41-64, 43-66, 45-69, 46-70, 47-71, 48-72, 49-73, 50-74, 51-75 | | D | pp. 58–68 (11 pages) | Official OneDrive Discovery Materials and Chain of Custody — email from Raissa Carpenter (Feb 10, 2025) discussing upcoming Feb 13 meeting and discovery system; email from JoAnne Van Guilder sharing OneDrive folder (Feb 13, 2025 at 3:33 PM); Microsoft identity verification screenshot; OneDrive folder structure screenshots showing JoAnne Van Guilder > CASE FILES > Photos with two subfolders (23-0098 Working Copies and PHOTOS(E86D4D48)); 5 pages of full file listings for PHOTOS(E86D4D48) folder (104 files, all showing Feb 3, 2023 modified date, Modified By JoAnne Van Guilder); 2 pages of file listings for 23-0098 Working Copies subfolder (TRS_DSC images with Jan 21, 2023 modified date) | | E | pp. 69–75 (7 pages) | Documentation of Communication Attempts with Defense Counsel and Additional Discovery Requests — Feb 20, 2025 email to Carpenter/Donnelly presenting forensic findings with Storj links; Feb 20, 2025 forwarded Biglow email (Aug 3, 2023 original with attached discovery PDF); Feb 24, 2025 email to JoAnne Van Guilder requesting video discovery; Feb 25, 2025 phone call screenshots showing outgoing call to (612) 348-9676, 2 min 12 sec | **Key People Referenced:** - **Judge Sarah Hudelston** — Judicial officer; first appearance in this catalog - **Mary F. Moriarty** — Hennepin County Attorney; first appearance in this catalog - **Thomas Manewitz** — Assistant Hennepin County Attorney; first appearance in this catalog (replaces Jacqueline Perez as ACA) - **Raissa Carpenter** — Assistant Public Defender, Hennepin County Public Defender's Office (she/her); location: 701 4th Ave S, Suite 1400, Minneapolis, MN 55415; phone: 612-348-9676; email: raissa.carpenter@hennepin.us; first appearance in this catalog (replaces Bruce Rivers as defense counsel) - **Emmett M. Donnelly** — Assistant Public Defender (CC'd on defense correspondence); first appearance in this catalog - **JoAnne Van Guilder** — Hennepin County staff (JoAnne.VanGuilder@hennepin.us); controls the OneDrive discovery file-sharing system; "Modified By" attribution on all 104+ discovery files; shared the Photos folder with Guertin on Feb 13, 2025; first appearance in this catalog - **Michael Biglow** — Former defense counsel; original transmitter of Aug 3, 2023 discovery PDF (email forwarded in Exhibit E); previously cataloged in Filing #2 - **Dr. Michael Roberts** — Referenced in Exhibit B as the examiner who conducted the civil commitment exam on August 1, 2023 using allegedly fraudulent discovery materials; NOTE: previously referenced as "Dr. Michael Robertson" in Filings #2 and #3 — name discrepancy (Roberts vs. Robertson) should be resolved **Cross-References to Prior Filings:** - **Filing #2 (April 4, 2024 Motion to Compel):** The Feb 13, 2025 discovery set provides retroactive validation of Filing #2's core claims. Filing #2 documented 28/43 interior images with irregular aspect ratios suggesting manual cropping. The Feb 2025 set shows those same 20+ irregular images now forced to a uniform 16:9, confirming the original cropping AND adding a second layer of manipulation. - **Filing #1 (Jan 5, 2024 Discovery Request):** Guertin's original request for "104 photographs" in original format is validated — the OneDrive system shows exactly 104 files in the PHOTOS folder (Exhibit D, p. 4: "104 items"). - **Filing #9 (MCRO Data Analysis):** The broader pattern of procedural manipulation documented there provides context for the discovery-specific manipulation proven here. - **Exhibit A references "Index 29, pp. 18-21" and "Index 29, pp. 22-23"** — this is the docket index number for Filing #2 (the April 4, 2024 Motion to Compel Discovery). - **Exhibit B references "Exhibit S, Index 10" and "Index 116, Exhibit C"** — these are separate docket entries containing psychological evaluation reports not yet cataloged. - **Exhibit B references "Exhibit Y"** — a document titled "The Catch-22: Discovery Fraud," also referenced in the Feb 20 email as `74__EXHIBIT-Y__The-Catch-22__DISCOVERY-FRAUD.pdf`. **Forensic Flags:** - **CRITICAL — Retroactive Validation:** This filing constitutes the "smoking gun" confirmation of the manipulation claims first raised in Filing #2 (April 4, 2024). The original filing documented irregular aspect ratios suggesting cropping; the Feb 2025 set shows those same images forced to uniform 16:9 — meaning someone re-processed the images between the two discovery productions, likely to conceal the cropping evidence Guertin had already documented. - **104 Photo Count Confirmed:** The OneDrive folder PHOTOS(E86D4D48) contains exactly 104 items (Exhibit D, p. 4 screenshot). This matches the 104 photographs referenced in Dr. Rogstad's report and requested in Filing #1. The August 3, 2023 discovery PDF contained only 80 — confirming 24 were selectively excluded from the original PDF production, not missing from the county's files. - **Metadata Date Anomaly:** All 104 files in PHOTOS(E86D4D48) show "February 3, 2023" as the Modified date, yet the photographs were taken January 21, 2023. The separate "23-0098 Working Copies" folder (TRS/crime scene images) shows "January 21, 2023" modified dates — a 13-day discrepancy between the two folders that requires explanation. If the PHOTOS folder files were truly unmodified since Feb 3, 2023, they should match the Aug 3, 2023 discovery set — but 20+ do not. - **Two Distinct Image Sets on OneDrive:** The folder structure reveals two separate image collections: (1) PHOTOS(E86D4D48) — 104 items, ggilbertson/sjohnson/skerwin photographer prefixes, Feb 3, 2023 modified date; (2) 23-0098 Working Copies(79DB9B) → 23-0098 Request 0001 Item 0012 Images — 520+ TRS_DSC files, Jan 21, 2023 modified date. The "Working Copies" folder's TRS_DSC images with 3:2 aspect ratios are the unmanipulated originals from the crime scene unit camera; the PHOTOS folder contains the processed/uploaded versions. - **New Prosecution Team:** Thomas Manewitz (ACA) replaces Jacqueline Perez. Mary F. Moriarty is now named as County Attorney. This change occurred between Filing #7 (June 3, 2024, addressed to Perez) and this filing (Feb 28, 2025). - **New Defense Counsel:** Raissa Carpenter and Emmett Donnelly (Hennepin County Public Defender's Office) replace Bruce Rivers. Carpenter's Feb 10, 2025 email reveals she was aware of Guertin's fraud claims ("You have also told us that some of the discovery you received is fraudulent") and expressed concern about file distortion during download ("I am concerned that if files get download and shrunken, that will distort them and cause you to worry that things were manipulated in a deceiving manner"). - **New Judicial Officer:** Sarah Hudelston replaces Julia Dayton Klein and Jay Quam as the assigned judge. This is the fourth named judicial officer on the criminal case. - **Carpenter's Feb 10 Email is Forensically Significant:** She writes that she wants to show Guertin the discovery system before making copies because downloading and shrinking "will distort them." This is either (a) a good-faith warning about routine file processing artifacts, or (b) pre-emptive framing to attribute dimensional changes to the download process rather than prior manipulation. Either way, it establishes that the defense was aware dimensional changes could occur and is on record acknowledging the issue before the Feb 13 share. - **Storj Cloud Storage:** Guertin's use of Storj (decentralized cloud storage) for his forensic analysis files (link: https://link.storjshare.io/s/jvpojfmwcgoq7gxz2pcjbat7fxsa/court-fraud) represents an independent, tamper-resistant archive — Storj uses erasure coding across distributed nodes, making post-upload alteration effectively impossible. - **Address Reversion:** Guertin's address is back to 4385 Trenton Ln. N 202, Plymouth, MN 55442 — the same address as Filing #1 (Jan 2024). He had moved to 1075 Traditions Ct., Chaska, MN 55318 as of Filing #3 (May 2024). This reversion may be significant for timeline reconstruction. - **Upcoming Hearing Date:** March 5, 2025 is referenced as the hearing date — 5 days after the Feb 28 filing. This is a competency/objection hearing. - **"Dr. Michael Roberts" vs. "Dr. Michael Robertson":** Exhibit B (p. 5) refers to "Dr. Michael Roberts who actually conducted my civil commitment exam on August 1, 2023." Prior filings (Filings #2, #3) reference "Dr. Michael Robertson." This name discrepancy needs resolution — verify against the actual civil commitment exam report. - **Psychological Evaluator Quotes:** The four block quotes from evaluation reports in Exhibit B are critical evidence of the "Catch-22" cycle: claim fraud → labeled delusional → found incompetent → claims dismissed. These quotes reference at least two separate evaluators/reports: one from "Exhibit S, Index 10" (pp. 4–6) and one from "Index 116, Exhibit C" (p. 4). The second evaluator states Guertin "failed to participate in evaluation" but nonetheless concluded his assertions about fraud constitute "delusional belief" — an evaluation rendered without direct participation. - **Content of Handwritten Messages on Walls/Doors (Exhibit C images):** The flipbook photographs reveal extensive handwritten messages on Guertin's apartment walls and doors including references to ChatGPT, AI voice imitation, patent attorney Amanda Prose with WCK, intercepted calls/emails, InfiniSet Inc., Netflix, a "quarter billion dollars" patent, a "Bluetooth PAN" found in network connections, and someone in the photo who "claimed to be with the CIA." These messages are the physical manifestation of the claims that evaluators characterized as delusional — but they also contain specific, verifiable factual assertions (patent numbers, attorney names, company names) that could be independently confirmed or refuted. - **Notebook Page (Image 50-74):** Shows a handwritten page beginning "As I look around my apartment — I'm absolutely aware that it looks like I've lost my mind" — Guertin's own contemporaneous acknowledgment of how the scene appeared, followed by an explanation connecting it to a Netflix patent and fear for his safety. This page is forensically significant because it demonstrates self-awareness — the opposite of the evaluators' characterization. - **Computer Screen (Image 51-75):** Shows a Notepad file ("My_Note.txt") with text about discovering someone "tapped into my computer," finding a Bluetooth PAN network, and referencing "Assaff Rawner" and "Dimension" in connection with Microsoft. Desktop visible with Autodesk ReCap, Photoshop, TouchDesigner, Falcon (cleaning software), and a TURNTABLE .3dmbak file — consistent with engineering/invention work rather than disorganized living. --- ### FILING #22 | Field | Detail | |---|---| | **Filename** | `123__Exhibit-List_F-J____Discovery-Fraud-Proven__2025-02-28.pdf` | | **Date Filed** | February 28, 2025 (filed stamp: 2/28/2025 4:38 PM) | | **Case ID** | 27-CR-23-1886 | | **Filing Type** | Defendant's Supplemental Evidence Submission in Support of Objection to Competency Report - B | | **Filed By** | Matthew David Guertin (pro se; address: 4385 Trenton Ln. N 202, Plymouth, MN 55442; Tel: 763-221-4540; Email: MattGuertin@protonmail.com; Web: www.MattGuertin.com) | | **Addressed To** | Judge Sarah Hudelston; Mary F. Moriarty, Hennepin County Attorney; Thomas Manewitz, Assistant Hennepin County Attorney | | **Judicial Officer** | Sarah Hudelston | | **Pages** | 92 (4 pages motion body + 88 pages exhibits) | **Detailed Summary:** This is a 92-page filing presenting five forensic image analysis reports (Exhibits F through J) as supplemental evidence supporting Guertin's objection to his competency report. The filing is the most technically advanced image forensic submission in the catalog — each exhibit uses distinct mathematical and geometric methodologies to demonstrate that specific discovery photographs have been altered through non-uniform horizontal compression (x-axis squishing). The filing serves a dual purpose: (1) proving discovery image manipulation, and (2) arguing that Guertin's ability to commission, comprehend, and present these forensic analyses is itself evidence of his competency under Minn. R. Crim. P. 20.01. **Core Structure:** The motion body (pp. 1–4) provides an introduction, exhibit list with summaries, a three-part legal argument, and relief sought. The legal argument addresses: (1) Competency and the Right to a Fair Evaluation under Rule 20.01, arguing that the manipulated discovery images undermined the reliability of the evidence used to question Guertin's capacity; (2) Evidentiary Integrity and Chain of Custody, noting the exhibits provide quantitative measurements linked to documented digital chain of custody; and (3) Pretrial Disclosure and Fairness, justifying late filing based on extraordinary circumstances including repeated failed attempts to contact defense counsel (previously documented in Exhibit E from a prior filing). The relief requested includes: (a) acceptance of Exhibits F–J into the official record, (b) consideration of the forensic evidence demonstrating fraudulent manipulation of discovery images, (c) recognition that Guertin's ability to present these analyses proves competency under Rule 20.01, and (d) ensuring findings are weighed in evaluating discovery integrity and the competency evaluation. **Analytical Methodology Across All Five Exhibits:** All five exhibits analyze paired image sets — each pair consists of an "Original" discovery image (from the August 3, 2023 discovery batch documented in Filing #2) and a corresponding "ggilbertson_01212023" discovery image (a second version provided later, dated February 3, 2025 per Exhibit G). The consistent finding across all five is that the "Original" images maintain correct aspect ratios while the "ggilbertson" images exhibit measurable horizontal compression. All images were captured with an Apple iPhone 12 (4.2mm lens, f/1.6, 26mm equivalent, 69.4° FOV, 4032×2270 pixel resolution, 16:9 aspect ratio). --- **Exhibit Inventory:** | Exhibit | Label | Image Pair | Methodology | Key Finding | Pages | |---|---|---|---|---|---| | F | Image 30-50 Forensic Image Report: Digital Forensic Analysis of Perspective Distortion | Image A: "30-50 – Original" vs. Image B: "ggilbertson_01212023135833CST_photo_27_950.jpeg" vs. Image C: ARCH D Blueprint (36"×24" orthographic reference) | Homography transformation via DLT algorithm; reprojection error analysis; direct pixel measurement; aspect ratio validation | Image B compressed ~4.6% (transformed measurement) to 8.75% (raw pixel aspect ratio); width deviation of 49.85 px / 1.38 in; Image A pixel dims 2488×4032 (AR 0.6173), Image B pixel dims 2270×4032 (AR 0.5633) | pp. 5–17 (13 pages) | | G | Image 31-51 Forensic Report: Analysis of Pink Circular Shapes and Metadata | Image 1: "31-51 – Original" vs. Image 2: "ggilbertson_01212023135904CST_photo_30_AaB.jpeg" | Pink circular shape isolation (HTML #fe00f1); metadata cross-reference; known technical drawing overlay (Guertin's "FB – Fans" wiring diagram from US Patent 11,577,177); uniform scaling + rotation + perspective warp alignment; three comparison modes (Over, Burn, Overlay) | Image 1 circles are uniformly round; Image 2 circles are horizontally squished; overlay of precision source drawing confirms Image 1 preserves correct geometry; Image 2 shows label doubling (F5F5, F6F6, F3F3, F4F4) confirming misalignment from distortion | pp. 18–38 (21 pages) | | H | Image 33-53 Forensic Image Report: Perspective Distortion Analysis | Image A: "33-53 – Original" vs. Image B: "ggilbertson_01212023135930CST_photo_33_Lla.jpeg" vs. Image C: Frigidaire FFEF3054T stove control panel (29.875"×5.265" ground truth) | Four-point color-coded keypoint detection (Red, Green, Blue, Orange via HSV segmentation); homography computation via DLT; direct pixel measurement; normalized point set comparison | Same 4.6% horizontal compression / 1.38 in deviation as Exhibit F (1082.16 px vs. 1032.31 px); reprojection error minimal for Image A, significant for Image B; GPS coordinates of capture: 44°56'30.59"N, 93°24'31.18"W | pp. 39–55 (17 pages) | | I | Image 41-64 Forensic Analysis Report: Aspect Ratio Consistency | Image 01: "41-64 – Original" vs. Image 02: "ggilbertson_01212023140623CST_photo_53_rc1.jpeg" | Quadrilateral feature extraction (right-angle shapes on ground plane); circular feature detection and aspect ratio evaluation; filled quadrilateral region comparison; metadata analysis | Image 02 quadrilaterals compressed along x-axis; circular features in Image 02 appear elliptical (horizontally compressed); Image 01 preserves proportional integrity; both images at ISO 320 | pp. 56–73 (18 pages) | | J | Image 43-66 Forensic Report: Analysis of SSD Drive Dimensions | Image 1: "43-66 – Original" vs. Image 2: "ggilbertson_01212023140649CST_photo_54_TfE.jpeg" | Physical dimension measurement via digital caliper; vector trace overlay; dimensioned layout extraction with rotation/perspective/scale correction; cross-reference to product images (Sabrent SSD from tech-legend.com, Crucial X8 SSD) | Crucial X8 SSD: measured 4.344" width × 2.087" height × 3.365" body; Image 1 SSD matches real-world caliper measurements; Image 2 SSD horizontally squished; additional unaltered discovery photos (DSC_0348.JPG, DSC_0350.JPG) provided as reference | pp. 74–92 (19 pages) | **Shared Source File Links (per-exhibit):** | Exhibit | URL | |---|---| | F | https://link.storjshare.io/s/jvradsdwbmwopfylydttlsnoxkeq/court-fraud/Forensic-Image-Analysis-Reports/30-50/ | | G | https://link.storjshare.io/s/jxqio5qjgby5m3gm4jitxgsalhfq/court-fraud/Forensic-Image-Analysis-Reports/31-51/ | | H | https://link.storjshare.io/s/juwh3hfhczlazywfo43swpwst5aq/court-fraud/Forensic-Image-Analysis-Reports/33-53/ | | I | https://link.storjshare.io/s/jvqwv3xqblnlcg3l7eic6notkq7q/court-fraud/Forensic-Image-Analysis-Reports/41-64/ | | J | https://link.storjshare.io/s/ju2fhaoricp45f3ivosw6jjdiy3a/court-fraud/Forensic-Image-Analysis-Reports/43-66/ | **Key People Referenced:** - **Judge Sarah Hudelston** — Judicial officer; addressed on filing - **Mary F. Moriarty** — Hennepin County Attorney; addressed on filing - **Thomas Manewitz** — Assistant Hennepin County Attorney; addressed on filing - **ggilbertson** — Username/identifier embedded in filenames of the comparison discovery images (format: ggilbertson_01212023HHMMSS CST_photo_NN_XXX.jpeg); presumed to be the individual who captured or processed the second set of discovery photographs on January 21, 2023 - **Matthew David Guertin** — Defendant (pro se); filing party; also referenced as patent holder (US Patent 11,577,177) and creator of the "FB – Fans" technical wiring diagram used as geometric ground truth in Exhibit G **Forensic Flags:** - **Critical new discovery batch identified:** This filing reveals the existence of a SECOND set of discovery images — the "ggilbertson_01212023" photographs. Per Exhibit G, these are described as "New Feb 3, 2025 Discovery Image[s]," meaning a new discovery production occurred on or around February 3, 2025. The original discovery batch (August 3, 2023, documented in Filing #2) is referred to throughout as the "Original" images. This establishes that the prosecution provided at least two distinct versions of the same photographs at different times — and both cannot be authentic if they differ in aspect ratio. - **Username "ggilbertson" is a new entity:** The filename structure "ggilbertson_01212023HHMMSS CST_photo_NN_XXX.jpeg" encodes a username, a date (January 21, 2023 — the date of the original police photography), a timestamp in CST, a sequential photo number, and a 3-character alphanumeric suffix. This naming convention is consistent with automated law enforcement evidence management systems. The identity of "ggilbertson" should be cross-referenced against Minnetonka Police Department personnel and evidence technicians. - **Consistent compression ratio across Exhibits F and H:** Both Exhibit F (Image 30-50) and Exhibit H (Image 33-53) independently calculate the same transformed width measurements (Image A: 1082.16 px, Image B: 1032.31 px) and the same compression ratio (0.954 / 4.6% horizontal compression / 49.85 px / 1.38 in deviation). This consistency across different reference objects (a 36"×24" blueprint vs. a 29.875"×5.265" stove panel) strongly suggests a single, uniform transformation was applied to all "ggilbertson" images. - **Raw pixel aspect ratio discrepancy:** Exhibit F provides raw pixel dimensions — Image A: 2488×4032 (AR 0.6173), Image B: 2270×4032 (AR 0.5633). The height (4032 px) is identical; only the width differs (2488 vs. 2270, a 218 px / 8.75% reduction). This is the signature of horizontal-only rescaling — the vertical dimension is untouched. - **GPS coordinates embedded:** Exhibit H metadata includes GPS coordinates (44°56'30.59"N, 93°24'31.18"W), which corresponds to the Plymouth, MN area — consistent with Guertin's listed address at 4385 Trenton Ln. N, Plymouth, MN 55442. This is independently verifiable geolocation data. - **Patent cross-reference:** Exhibit G references US Patent 11,577,177, Guertin's rotating treadmill patent. This is the same invention referenced in Filing #2 as one of the items systematically cropped out of the original discovery photos. The wiring diagram ("FB – Fans," dated 9/23/2021) created from the patent's 3D design files is used as a precision geometric reference — this is a novel and clever forensic technique: using the defendant's own engineering files as ground truth to validate image geometry. - **Storj-based evidence hosting:** All source files are hosted on Storj (decentralized cloud storage) rather than centralized services — each exhibit has a unique Storj share link. This provides tamper-resistant, content-addressed storage with cryptographic verification capabilities. - **Image naming convention analysis:** The "ggilbertson" images follow a strict pattern: `ggilbertson_MMDDYYYYHHMMSS CST_photo_NN_XXX.jpeg`. The sequential photo numbers across the five exhibits are: 27 (Exhibit F), 30 (Exhibit G), 33 (Exhibit H), 53 (Exhibit I), 54 (Exhibit J). These are not contiguous, suggesting selective extraction from a larger set — consistent with the 104 total photographs referenced in Dr. Rogstad's report (Filing #2). - **Additional unaltered reference images in Exhibit J:** Two additional discovery images from a different source are provided for reference: "23-0098_0012_520-TRS_DSC_0348.JPG" and "23-0098_0012_520-TRS_DSC_0350.JPG." The filename prefix "23-0098_0012_520-TRS" follows the standard Minnetonka PD evidence numbering convention (case number, evidence item, TRS prefix). These images appear undistorted and are presented as independent verification of the SSDs' real-world proportions — this is a third image source beyond the "Original" and "ggilbertson" versions. - **Connection to Filing #2 Exhibit G (80-image aspect ratio table):** The five image pairs analyzed in this filing correspond to specific rows in Filing #2's Exhibit G table. Image 30-50 was specifically flagged in Filing #2 for anomalous compression artifacts. This filing provides the mathematical proof that those compression artifacts correspond to measurable horizontal distortion. - **Competency argument integration:** This filing explicitly ties the forensic evidence to the competency dispute — arguing that Guertin's ability to commission and present homography-based image analysis demonstrates the capacity to understand and participate in proceedings. This mirrors the dual-purpose strategy from Filing #9 (Python/Selenium data analysis as both evidence and competency proof). - **Late filing justified:** Guertin acknowledges the filing violates the 7-day advance submission rule but justifies it by citing the extraordinary circumstances of repeated failed contact attempts with defense counsel (documented in a prior Exhibit E). This is consistent with the pattern documented in Filings #3, #5, and #6 of systemic non-responsiveness. - **New judicial officer and prosecutors:** Judge Sarah Hudelston, County Attorney Mary F. Moriarty, and ACA Thomas Manewitz are all new names not previously appearing in the catalog. This represents a significant personnel change from the earlier filings addressed to Judge Jay Quam / Judge Julia Dayton Klein and prosecutor Jacqueline Perez — suggesting case reassignment or staffing changes between 2024 and 2025. --- ### FILING #23 | Field | Detail | |---|---| | **Filename** | `124__Exhibit-List_K-L____Discovery-Fraud-Proven__2025-02-28.pdf` | | **Date Filed** | February 28, 2025 (filed stamp: 2/28/2025 4:40 PM) | | **Case ID** | 27-CR-23-1886 | | **Filing Type** | Defendant's Supplemental Evidence Submission in Support of Objection to Competency Report - C | | **Filed By** | Matthew David Guertin (pro se; address: 4385 Trenton Ln. N 202, Plymouth, MN 55442) | | **Addressed To** | Judge Sarah Hudelston; Mary F. Moriarty, Hennepin County Attorney; Thomas Manewitz, Assistant Hennepin County Attorney | | **Judicial Officer** | Sarah Hudelston | | **Pages** | 76 (4 pp. motion body + 46 pp. Exhibit K + 26 pp. Exhibit L) | **Detailed Summary:** This is a 76-page supplemental forensic evidence submission incorporating two new exhibits (K and L). The filing serves a dual purpose: (1) presenting advanced image forensic analyses demonstrating that key discovery images have been manipulated, and (2) arguing that Guertin's ability to conduct and present these analyses is itself proof of competency under Minn. R. Crim. P. 20.01 — directly rebutting the competency report the filing objects to. The motion body is 4 pages; the remaining 72 pages are the two exhibit reports with extensive photographic comparisons and forensic overlays. **Core Arguments:** 1. **Competency Under Minn. R. Crim. P. 20.01:** Guertin argues that his demonstrated ability to obtain, comprehend, and present advanced forensic analyses using established methods (vector tracing, homography, digital caliper measurements, EXIF metadata analysis) proves he can rationally consult with counsel and understand the proceedings — satisfying the competency standard. 2. **Evidentiary Integrity and Discovery Fraud:** Exhibits K and L reveal that key discovery images were manipulated via non-uniform scaling (horizontal compression) and improper image processing, including flash photography that contradicts metadata claims and use of non-iPhone camera equipment despite iPhone 12 metadata. 3. **Pretrial Disclosure and Fairness:** Guertin acknowledges the seven-day pre-submission requirement under local rules but justifies the present filing based on extraordinary circumstances — specifically, his documented unsuccessful attempts to contact defense counsel. **Relief Sought:** (1) Accept Exhibits K and L as part of the official record; (2) Consider the forensic evidence demonstrating discovery image manipulation; (3) Recognize the technical sophistication of the filing as further proof of competency under Rule 20.01. **Exhibit Inventory:** | Exhibit | Content | Pages | |---|---|---| | **K** | Hexmag HX – AR Series 2 Vector Tracing Analysis (Image 48-72 Forensic Report) | Exhibit K pp. 1–46 | | **L** | Lighting, Shadow, and Flash Examination (Forensic Analysis of 5 Discovery Images) | Exhibit L pp. 1–26 | --- **EXHIBIT K — Hexmag HX–AR Series 2 Vector Tracing Analysis (Detailed Breakdown):** This report uses vector tracing derived from U.S. Patent No. D727,456S (design patent for an ammunition magazine, issued April 21, 2015 to Aaron M. Schefter and Adam R. Schefter, assigned to Hexmag LLC, Loveland, CO) to compare two versions of discovery Image 48-72: the original and the version provided in discovery (filename: `ggilbertson_01212023140450CST_photo_50_7rT.jpeg`). **Methodology:** - Vector traces of the hexagonal grid pattern were created using two color-coded overlays: light green (#00ffd6) for the original image and light turquoise (#00eeff) for the discovery comparison image. - Both traces were compared against Figure 3 of U.S. Patent No. D727,456S (left side elevation view), which provides the precise hexagonal pattern specifications. - The patent number was independently verified by Guertin from a separate close-up discovery photo (`23-0098_0012_520-TRS_DSC_0486`) showing the marking "PATENT D 727,456 S" on the physical magazine. **Findings:** - **Image 1 (48-72 Original):** The light green vector trace matches the patent's hexagonal grid precisely — no distortion, uniform aspect ratio, consistent with the original design. - **Image 2 (48-72 ggilbertson version):** The light turquoise vector trace reveals clear horizontal compression of the hexagonal grid. The width of individual hexagons is significantly reduced compared to Image 1, producing a "squished" appearance that departs from the patent's specifications. - The distortion is consistent with non-uniform scaling along the x-axis (horizontal compression without proportional vertical compression). - The discrepancy is visible across the entire hexagonal grid, not localized — ruling out perspective distortion from camera angle as an explanation. **Technical Metadata of Discovery Image (Image 2):** - Camera: Apple iPhone 12 - Exposure Time: 1/60 sec | Aperture: f/1.6 | ISO: 400 - Resolution: 4032 × 2270 pixels (aspect ratio ~16:9) - Field of View: 69.4 degrees - Lens: iPhone 12 back camera (4.2 mm focal length, equiv. 26 mm in 35mm format) - Date/Time Original: 2023:01:21 14:04:49 CST - GPS Coordinates: 44°56'30.59"N, 93°24'31.18"W - Image Size: 9.2 Megapixels **Visual Evidence Presented (46 pages):** - Side-by-side vector trace comparison on black background (p. 2, p. 42) - Close-up photos of the physical magazine showing patent number markings (pp. 5–6) - Full U.S. Patent D727,456S front page and Figure 3 technical drawing (pp. 7–8) - Traced vector overlay on the patent's Figure 3 drawing (p. 9) - Original Image 48-72 in full context (floor scene with magazine, pp. 10, 12–14) - Progressive overlay series: original photo → transparency overlay → patent drawing alignment → vector trace comparison (pp. 15–28 for original, pp. 29–41 for discovery version) - Final side-by-side comparison of both vector-traced versions against patent drawing (pp. 42–46) - Shared source files folder: `https://link.storjshare.io/s/jvqlo3m4vojhalo3jdwzejokofya/court-fraud/Forensic-Image-Analysis-Reports/48-72/` **Conclusion:** The analysis demonstrates that the discovery version of Image 48-72 has undergone post-processing manipulation with non-uniform horizontal compression of the hexagonal grid, deviating from the original design as specified in U.S. Patent No. D727,456S. The original image retains the authentic, unaltered hexagonal pattern. --- **EXHIBIT L — Lighting, Shadow, and Flash Examination (Detailed Breakdown):** This forensic report evaluates five discovery images for inconsistencies between observed lighting conditions and recorded EXIF metadata. All five images share the same metadata profile: captured with an Apple iPhone 12, flash set to "Auto, Did not fire," with identical lens parameters (4.2mm f/1.6, equiv. 26mm). **Methodology:** 1. Shadow geometry and light ray path analysis to determine true light source position. 2. EXIF metadata extraction and cross-checking against observed lighting and reflections. 3. Specular highlight and flash reflection analysis to confirm/contradict metadata flash claims. 4. Camera equipment evaluation via reflections visible in images. 5. Cropping artifact and composition inconsistency detection. **Image-by-Image Findings:** **1. Image 44-68** (`23000258_ggilbertson_01212023145233CST_photo_64_toF.jpeg`): - Shows interior of a kitchen cupboard containing prescription containers, vitamins, and supplements. - A bright specular reflection is visible in the bottom right-hand corner — identified as a camera flash reflection. - Metadata states "Flash: Auto, Did not fire" — directly contradicted by the visible reflection. - Light ray tracing from shadow positions converges to the bottom-right, confirming the flash originated from that direction — inconsistent with a centered camera position. - Conclusion: Image was cropped from the upper-left region of a larger original photograph. The off-center flash reflection proves cropping occurred. - Guertin notes the cropping excludes the tile sink backsplash and a bin of vitamins/supplements visible in other discovery photos, arguing this was intentional narrative framing to focus solely on Adderall prescription containers. - Metadata: 4032×2270 px, 9.2 MP, created 2023:01:21 14:52:33 CST. - Source files: `https://link.storjshare.io/s/juvg3rgn7v34mhnjgtgi5mcv2jnq/court-fraud/Forensic-Image-Analysis-Reports/44-68_Prescription-Containers/` **2. Garage Photo 01** (`23000258_ggilbertson_01212023133542CST_photo_07_O49.jpeg`): - Shows vehicle rear seat interior, photographed in a dark garage. - Grayscale enhancement reveals unnatural lighting conditions including a rectangular flash projection reflected on the car's body. - Zoomed and contrast-enhanced crops reveal the rectangular shape of an external camera flash unit. - Metadata states "Flash: Auto, Did not fire" — contradicted by the visible rectangular flash artifact. - The shape of the flash reflection is rectangular, not the diffuse pattern expected from an iPhone 12's LED flash. - Metadata: 4032×2270 px, 9.2 MP, created 2023:01:21 13:35:42 CST. - Source files: `https://link.storjshare.io/s/jwjgbylsnf3rjwbuhwknlxmu3akq/court-fraud/Forensic-Image-Analysis-Reports/Garage-01/` **3. Garage Photo 02** (`23000258_ggilbertson_01212023133550CST_photo_08_e1z.jpeg`): - Shows vehicle front interior (driver's side), photographed in the same dark garage. - The rear passenger window reflects the photographer: a figure holding what appears to be a standard DSLR-type camera with a top-mounted external flash unit. - The reflected camera equipment is clearly not an iPhone 12 — it shows a larger body held with both hands, with a rectangular flash positioned centrally above the lens. - An additional discovery image (`23-0098_0012_520-TRS_DSC_0152.JPG`) showing the exterior of the residence also contains a reflection showing a similar rectangular flash in a window. - Metadata states iPhone 12 was used — directly contradicted by the photographer's reflection showing professional camera equipment. - Metadata: 4032×2270 px, 9.2 MP, created 2023:01:21 13:35:50 CST. - Source files: `https://link.storjshare.io/s/jvetc2ihfzbfltp7balfrdo732fa/court-fraud/Forensic-Image-Analysis-Reports/Garage-02/` **4. Garage Photo 03** (`23000258_ggilbertson_01212023134408CST_photo_09_DE6.jpeg`): - Shows propane tanks in cardboard boxes on a shelf in the garage, next to the car hood. - Crystal clear, sharply defined shadows confirm use of a direct artificial light source (flash). - Light ray path tracing from shadow positions indicates the flash originated from a position significantly further back in the garage than the apparent camera position — proving the image was cropped from a larger original. - A dark edge along the front of the car's hood is inconsistent with the purported camera position — would not exist if the photo were taken from where the cropped frame suggests. - Guertin argues the cropping omits surrounding tools and workshop items that would provide context (propane tanks were for a heater used during welding of his patent prototype). - Metadata states "Flash: Auto, Did not fire" — contradicted by sharp shadow evidence. - Metadata: 4032×2270 px, 9.2 MP, created 2023:01:21 13:44:08 CST. - Source files: `https://link.storjshare.io/s/jwtl2z6tm2fufl64yyukniisloga/court-fraud/Forensic-Image-Analysis-Reports/Garage-03/` **5. Router Photo** (`ggilbertson_01212023135746CST_photo_19_PPY.jpeg` / displayed as `ggilbertson_01212023144600CST_photo_60_PBS.jpeg`): - Shows a TRENDnet router sitting on aluminum foil on a shelf, with cables and other items. - Hard, well-defined shadows are cast on the wall behind the objects — shadows not present in a wider-angle discovery photo of the same kitchen area (`ggilbertson_01212023155458CST_photo_71_m4H.jpeg`), establishing that the wall normally shows no such shadows under ambient lighting. - Light ray tracing from the shadow positions confirms the flash originated from a position significantly offset from center — inconsistent with the apparent camera position, proving cropping from a larger original. - Metadata states "Flash: Auto, Did not fire" — directly contradicted by the hard shadow evidence. - Metadata: 4032×2270 px, 9.2 MP, created 2023:01:21 14:46:00 CST. - Source files: `https://link.storjshare.io/s/jvig6ni54qyphrx2yrimfmmumgrq/court-fraud/Forensic-Image-Analysis-Reports/Router/` **Exhibit L Conclusion:** All five examined discovery images exhibit substantial inconsistencies between their metadata and observed lighting conditions. Flash reflections, incorrect shadow alignments, and reflections of non-iPhone camera equipment provide evidence of manipulation. The metadata claims of iPhone 12 capture with no flash fired are contradicted by the photographic evidence in each case. --- **Key People Referenced:** - **Judge Sarah Hudelston** — Judicial officer on this filing (new to catalog) - **Mary F. Moriarty** — Hennepin County Attorney (new to catalog) - **Thomas Manewitz** — Assistant Hennepin County Attorney (new to catalog) - **Matthew David Guertin** — Defendant pro se (existing) - **G. Gilbertson** — Photographer identified in discovery image filenames (e.g., `ggilbertson_01212023...`); referenced in Exhibit L as the purported photographer whose reflection appears in Garage Photo 02 (existing reference in discovery filenames from prior filings; first explicitly named here) - **Aaron M. Schefter** — Co-inventor on U.S. Patent D727,456S (referenced in Exhibit K) - **Adam R. Schefter** — Co-inventor on U.S. Patent D727,456S (referenced in Exhibit K) **Forensic Flags:** - This filing marks a significant escalation in forensic sophistication — moving from aspect ratio/pixel dimension analysis (Filing #2) to vector tracing against patent specifications and multi-image lighting forensics. - The vector tracing methodology in Exhibit K provides a quantifiable, patent-referenced baseline for detecting non-uniform scaling — a technique that could be applied to other discovery images in the 80-image set. - The horizontal compression finding in Exhibit K is consistent with the non-uniform aspect ratio discrepancies documented in Filing #2's Exhibit G (the complete 80-image analysis table). - Exhibit L's flash/shadow analysis across five images establishes a pattern of systematic metadata falsification — the same "iPhone 12, flash did not fire" metadata appears on images that demonstrably used flash photography and (in at least one case) non-iPhone camera equipment. - The photographer reflection in Garage Photo 02 showing a DSLR-type camera with external flash is potentially the single most significant piece of forensic evidence in the discovery fraud claim — it directly contradicts the iPhone 12 metadata across the entire discovery image set. - GPS coordinates in Image 48-72 metadata (44°56'30.59"N, 93°24'31.18"W) are independently verifiable — they should correspond to Guertin's residence at the time of the incident. - The filing is addressed to a NEW judicial officer (Sarah Hudelston) and new prosecutors (Moriarty, Manewitz) — indicating reassignment from the Judge Quam / Judge Klein / Perez configuration documented in prior filings. - The new prosecution team (County Attorney Moriarty + ACA Manewitz replacing ACA Perez) may reflect case escalation or routine reassignment — cross-reference with docket. - Guertin's address has reverted to 4385 Trenton Ln. N 202, Plymouth — previously at 1075 Traditions Ct., Chaska in Filings #3–#7. - The seven-day pre-submission waiver argument (inability to contact defense counsel) continues the pattern of attorney-client communication breakdown documented since Filing #3. - The dual-purpose framing (discovery fraud evidence + competency proof) is strategically significant — every exhibit simultaneously challenges the evidence AND demonstrates the analytical capability the competency determination says Guertin lacks. - All source files are hosted on Storj decentralized cloud storage (link.storjshare.io) — independent, tamper-evident hosting. - The `ggilbertson` prefix in discovery filenames is now explicitly connected to a visible photographer in Garage Photo 02 — establishing that "G. Gilbertson" is a real person who used professional camera equipment despite the iPhone 12 metadata. - Cross-reference: Image 44-68 (prescription containers) was previously analyzed for cropping in Filing #2 (Exhibit G, aspect ratio analysis; Exhibit L, narrative cropping analysis). This filing adds the flash reflection and light ray evidence as a new layer. - Cross-reference: Image 48-72 (Hexmag magazine on floor) was previously listed in Filing #2's Exhibit G image table. This filing provides the first detailed forensic analysis of that specific image via patent-based vector tracing. - The discovery image `23-0098_0012_520-TRS_DSC_0152.JPG` (front door exterior with rectangular flash reflection in window) uses a different filename convention — the `DSC_` prefix and `.JPG` extension are consistent with a Nikon DSLR naming convention, which aligns with the DSLR-type camera visible in the Garage Photo 02 reflection. --- ### FILING #24 | Field | Detail | |---|---| | **Filename** | `Guertin__Matthew_-_March_5__2024.pdf` | | **Actual Date of Hearing** | **March 5, 2025** (filename and header read "March 5, 2024" — confirmed misdated; see Provenance Note below) | | **Case ID** | 27-CR-23-1886 | | **Filing Type** | Official Court Transcript — Contested Competency Hearing | | **Court** | Hennepin County Probate Mental Health Court, Government Center, Minneapolis, MN | | **Presiding Judge** | Hon. William H. Koch | | **Prosecution** | Mawerdi Hamid, Assistant County Attorney | | **Defense Counsel** | Emmett Donnelly and Raissa Carpenter, Hennepin County Public Defender's Office | | **Defendant** | Matthew David Guertin (personally present; testified under oath) | | **Court Reporter** | Melinda K. Anderson, Official Court Reporter, Government Center MC 422, 300 South Sixth Street, Minneapolis, MN 55487 | | **Pages** | 61 | **Provenance Note:** The filename and internal header date this hearing as "March 5, 2024." The filing party confirms the actual hearing date is **March 5, 2025**, based on email provenance from a MN state email address transmitting this transcript. Internal content confirms 2025 dating: references to events in November 2024 (civil commitment completion on Nov 8, 2024), Dr. Cranbrook's report dated December 20, 2024, case reassignment from Judge Quam to Judge Hudleston due to Quam's retirement (a 2024–2025 event), and Bruce Rivers' discharge "in October" (October 2024) followed by public defender appointment. The misdating is treated as intentional obfuscation or clerical manipulation of the transcript date — flagged for forensic follow-up. --- **Detailed Summary:** This is a 61-page verbatim transcript of a contested competency hearing held before Judge William H. Koch in Hennepin County Probate Mental Health Court. The hearing was the third occasion on which the court considered Guertin's competency to stand trial on four felony firearms counts (one count reckless discharge of a firearm within a municipality; three counts possession of a firearm without a serial number). Two prior findings of incompetence had been entered: July 13, 2023, and January 17, 2024. The hearing was requested by defense after Dr. Cranbrook submitted her Rule 20.01 evaluation report on December 20, 2024, following a new evaluation order from a colleague of Judge Koch. **Procedural Background Established on the Record (pp. 2–3):** 1. Two prior findings of incompetence: July 13, 2023, and January 17, 2024. 2. Guertin appealed to the MN Court of Appeals to discharge former counsel; the Court of Appeals denied the request and declined to review additional submitted materials. 3. Bruce Rivers was discharged as counsel in October 2024; Hennepin County Public Defender's Office (Donnelly and Carpenter) was appointed. 4. A new Rule 20.01 evaluation was ordered; Dr. Cranbrook attempted multiple times to schedule an interview. Guertin contacted Carpenter but did not schedule the interview with Cranbrook. 5. Dr. Cranbrook submitted her report on December 20, 2024, without having conducted a direct interview. 6. The criminal case is stayed. It is being transferred from Judge Quam to Judge Hudleston (Quam retiring). Competency matters remain with Judge Koch in Probate Mental Health Court. 7. Federal litigation caused multiple recusals from working on the case. **Defense Position (pp. 4–9):** Defense counsel Donnelly framed the hearing as follows: given the existing incompetency findings, the burden falls on Guertin to demonstrate competency. The defense's contest is "not what's in [Cranbrook's] report, it's what's not in it." The defense did not intend to call or cross-examine Dr. Cranbrook and did not object to her report being received. The defense's core position was that Guertin demonstrates competency through his ability to review discovery, identify allegedly false and doctored evidence, and articulate those findings — skills that necessarily require understanding the nature of the proceedings and the ability to consult with counsel. Donnelly raised a procedural complication: Guertin had filed hundreds of pages of pro se exhibits directly with the court in anticipation of the hearing, without counsel's involvement. The court pressed Donnelly on whether these should be considered. Donnelly acknowledged the filings were not made through counsel but argued that a defendant contesting incompetency has a right to present arguments and evidence, and counsel cannot unilaterally decide not to present material the client believes demonstrates competency. **State's Position on Testimony (pp. 9–10):** Prosecutor Hamid argued that Guertin should not be allowed to testify under Minnesota Rules of Evidence 601, asserting that a person found incompetent is not a competent witness. Hamid had no case law to support this position. Judge Koch rejected this argument, stating: a person opined as incompetent has a right to challenge that finding, and the court has a duty to hear from that person. Koch noted that a psychologist's opinion of incompetence does not strip a person of the right to demonstrate competency. **Guertin's Sworn Testimony (pp. 12–56):** Guertin was sworn and testified under direct examination by Donnelly and cross-examination by Hamid. His testimony covered the following substantive areas: *1. Discovery Fraud Allegations (pp. 13–20, 50–52):* - After the August 1, 2023 civil commitment hearing, Guertin was emailed 80 photographs on August 3, 2023, by then-attorney Michael Biglow. He never requested these photos. - Months later he noticed discrepancies and filed his first court motion on January 5, 2024 (Filing #1 in catalog), requesting discovery. - He asserts that Dr. Michael Robertson's civil commitment exam relied on the 80 manipulated photographs. - The subsequent Rule 20 exams (Dr. Milz, Dr. Cranbrook) cited his claims of manipulated discovery as evidence of mental illness and as justification for involuntary antipsychotic medication. - He identified 20 images with inconsistent aspect ratios. Those images have since been retroactively manipulated in the Hennepin County OneDrive official discovery system to fit a uniform 16:9 ratio — which he describes as evidence of intent and effort to cover the original tampering. - He asserts that the original 80-photo set excluded contextually relevant items (books on corporate startups, professional equipment, kitchen amenities) to construct a false narrative about his living conditions. - Dr. Cranbrook's third Rule 20 exam contains the same statements referencing his discovery fraud claims as evidence of psychosis. *2. False Narratives in Rule 20 Reports (pp. 14–15):* Guertin testified that subsequent Rule 20 exams after the first one introduced false narratives including: - Misrepresenting his candid admission of past drug experimentation (every drug except heroin) as an ongoing, continuing substance abuse problem. - Falsely attributing a history of suicide and self-harm (he testified he has never been hospitalized for or attempted suicide). - Falsely attributing a history of psychosis (no documentation exists; his California psychiatrist confirmed no history of psychosis). - Falsely attributing a history of mania. *3. Dr. Jill Rogstad's Original Rule 20.01 Evaluation (pp. 20–22):* Guertin challenged the foundation of the incompetency determination chain. He testified that Dr. Rogstad's initial report (March 10, 2023) excluded a police report he had filed regarding the fraud he was claiming, made his verified statements appear implausible, and dismissed his documented professional achievements as grandiose delusions — including being credited as an engineer for projects for the King of Saudi Arabia and the main stage at Coachella 2019, which are verifiable in publications and at mattguertin.com. Rogstad also allegedly characterized his "perceived achievements" and "prowess with technology" as part of his "delusions." *4. Netflix/Microsoft Patent (p. 22):* Guertin testified that his name now appears at the top of a Netflix patent as prior art, referencing his own patent. Netflix filed a duplicate patent application 12 days after Guertin filed his. The Rule 20 reports allegedly characterized his belief that Netflix and Microsoft were involved in theft of his patent as delusional — a claim he asserts is now retroactively substantiated. *5. Professional Background and Technical Competence (pp. 17, 25–27):* - Background in digital and interactive media, pixels, photographs, and video. - Trained in Crestron systems in California. - Since 2008: main lighting designer at Quest/Epic Nightclub in Minneapolis (formerly Prince's Glam Slam). - Main lighting designer for the Republican National Convention (circa 2008). - 2014–2020: Worked for V Squared Labs / Vello Virkhaus in California. - Projects included: a 50-foot Falcon puppeted by 24 people for a UNESCO World Heritage event at Diriyah, Riyadh, Saudi Arabia (November 2019), broadcast on NBC; main stage at Coachella 2019; 70-day nightclub installation in Vietnam; multiple international projects. - All documented at mattguertin.com. - Not a licensed engineer and has no engineering degree; credited as engineer in publications including PLSN (live interview for BlackTrax system). *6. Competency Demonstration — Court's Direct Questions (pp. 27–30):* Judge Koch directly examined Guertin on competency elements: - **Charges:** Correctly identified all four counts (reckless discharge + 3 serial number counts), correctly identified them as felonies, correctly defined felony as "punishable by one year and one day or more." - **Case Process:** Correctly described plea bargaining, trial by jury, right to call witnesses. - **Prosecution:** Correctly identified the State as adversarial. - **Decision Authority:** Correctly stated that plea decisions are his; understood he could elect a bench trial. - **Pending Legal Issues:** Cited Vagle v. Minnesota (A23-0863) pending at the MN Supreme Court regarding the serial number charges. *7. Legal Research and Self-Representation Capability (pp. 32–34):* Guertin described his legal research process: - Discovered and learned the Tyler Tech filing system on his own. - First motion was modeled on Bruce Rivers' original demand for discovery. - Signed up for a case law research service; compiled prosecutorial misconduct case law and competency-related case law. - Downloaded and analyzed similar/related cases. - Built multiple custom ChatGPT bots loaded with all Minnesota Court Rules (criminal, statutes) to serve as AI-assisted defense attorneys for processing case analysis and meeting court rule qualifications. - Used this system for the federal case filing, which required delineating 11 defendants including a Monell claim against the county, Keith Ellison under Ex Parte Young, and three judges sued in personal capacity for acting outside judicial jurisdiction. *8. Relationship with Counsel and Self-Representation (pp. 36–39):* Guertin testified that his pro se filings were prompted by Bruce Rivers' refusal to provide discovery despite multiple requests, and Rivers telling him not to file pro se while simultaneously failing his obligations. He stated he would prefer to keep defense counsel rather than represent himself, understands the risks of felony self-representation, and would not automatically discharge counsel if found competent — but would not guarantee compliance if he "vehemently disagreed" with a strategic decision. *9. Civil Commitment Status (pp. 43–44, 46–48):* - Stayed civil commitment completed November 8, 2024. - Plan for care agreement terms: monthly meetings with Vail Place caseworker, no firearms or ammunition, remain law abiding, follow recommendations of California psychiatrist. - Vail Place submitted documentation confirming successful completion. - Still seeing caseworker at Vail Place. *10. Medical Status (pp. 44–45, 48–50):* - California psychiatrist: Dr. Martin Schuster (since 2016); pays cash, meets every 2–3 months. - Self-reported diagnoses: ADHD and generalized anxiety disorder. - Medications: Adderall (ADHD) and low-dose Klonopin as needed (anxiety). - Disputes bipolar diagnosis — states he has never experienced depressive episodes; Dr. Schuster agrees the bipolar diagnosis is inaccurate. - Reports responsible medication management: aware of benzodiazepine addiction potential, never takes more than one pill, last prescription lasted two months. - No alcohol consumption for an extended period. - No history of suicide, self-harm, psychosis, or mania (per his testimony). *11. Federal Case Status (pp. 45–46):* - Federal case dismissed; Eighth Circuit appeals dismissed. - Obtained entry of default against Bruce Rivers; Rivers hired an attorney to contest it; that matter appears to have been recently dismissed. - Guertin did not participate in Rivers' attorney's arguments. *12. Pro Se Filings Before This Hearing (pp. 39–40, 55–56):* Guertin filed exhibits with the court days before this hearing without counsel's involvement. He testified he did so because (a) he did not hear back from counsel, (b) he believed he was past the 7-day evidence window, and (c) the materials demonstrate the discovery fraud chain. When asked by the court whether he would continue filing without attorneys, he answered "That depends on how things proceed" — which the court characterized as "not really a great answer." **Court's Key Observations and Rulings During Hearing:** 1. **Koch rejected the State's argument** that an incompetent person cannot testify at a competency hearing under Rule 601 (pp. 10–11). 2. **Koch noted that Cranbrook's current report does not actually say Guertin is incompetent** — it says he is "still suffering from mental illness" (p. 23). 3. **Koch cautioned Guertin** that filing pro se while represented undermines his competency claim — not because the filings are nonsensical ("the structure is there, the form — it's very professional looking") but because circumventing counsel is inconsistent with claiming the ability to work with counsel (pp. 7–8). 4. **Koch acknowledged** that professional success and mental illness / incompetence are not mutually exclusive (p. 27). 5. **Koch warned** that ChatGPT "isn't always right" and referenced attorneys sanctioned for blind reliance on AI (pp. 45–46). 6. **Neither side called Dr. Cranbrook** as a witness; her report was received by stipulation (p. 11). 7. **No ruling was issued on the record.** The court took the matter under advisement after closing arguments (p. 60). **Closing Arguments (pp. 58–60):** - **Defense (Donnelly):** Deferred to the court's experience and the legal standard; argued Guertin has demonstrated he can assist counsel, analyze evidence, and make reasonable choices about the case. - **State (Hamid):** Requested the court review Dr. Cranbrook's December 20, 2024 report and all evidence, and deferred to the court's decision. - **Exhibits:** Donnelly stated the pro se exhibits filed by Guertin were referenced in testimony but not formally offered into evidence; the defense relied on the record as made. --- **Key People Referenced:** | Person | Role | Notes | |---|---|---| | **Judge William H. Koch** | Presiding (Probate Mental Health Court) | First appearance in catalog; handles competency matters in this case | | **Mawerdi Hamid** | ACA / Prosecutor | First appearance; replaces Jacqueline Perez as prosecuting attorney on record | | **Emmett Donnelly** | Defense Counsel (Public Defender) | First appearance; appointed after Rivers discharged | | **Raissa Carpenter** | Defense Counsel (Public Defender) | First appearance; co-counsel with Donnelly | | **Dr. Cranbrook** | Rule 20.01 Evaluator (third evaluation) | First appearance; authored December 20, 2024 report; attempted interview; present at hearing but released without testifying | | **Dr. Martin Schuster** | Guertin's California psychiatrist (since 2016) | First named appearance; previously referenced generically as "California physician" | | **Judge Hudleston** | Taking over criminal case from Judge Quam | First appearance; Quam retiring | | **Michael Biglow** | Former defense counsel (civil commitment) | Previously cataloged; referenced as source of Aug 3, 2023 discovery email | | **Bruce Rivers** | Former defense counsel (discharged Oct 2024) | Previously cataloged; referenced for discovery failures, "powerful people" statement, federal default entry | | **Dr. Jill Rogstad** | Initial Rule 20.01 evaluator (March 10, 2023) | Previously cataloged; testimony challenges her evaluation foundations | | **Dr. Michael Robertson** | Civil commitment examiner (Aug 1, 2023) | Previously cataloged; testimony asserts he relied on manipulated photos | | **Dr. Adam Milz** | Second Rule 20 evaluator (Jan 11, 2024 report) | Previously cataloged; testimony cites false narratives in his report | | **Judge Jay Quam** | Former criminal case judge (retiring) | Previously cataloged; case reassigned to Hudleston | | **Vello Virkhaus** | Owner, V Squared Labs (Guertin's former employer) | First named appearance; referenced in professional background | --- **Forensic Flags:** 1. **Transcript Misdating:** The filename and header date the hearing as March 5, 2024, but internal content (references to November 2024 civil commitment completion, December 2024 Cranbrook report, Quam's retirement, October 2024 Rivers discharge) conclusively establishes a March 5, 2025 hearing date. The filing party identifies this misdating as intentional. This is independently verifiable against the court docket for 27-CR-23-1886. 2. **Cranbrook Report Does NOT Find Incompetence:** Judge Koch states on the record (p. 23) that "Dr. Cranbrook's current order or report doesn't actually say he's incompetent, it just says he's still suffering from mental illness." This is a critical distinction — the third evaluator did not make an affirmative incompetency finding, yet the competency proceeding continued. The Cranbrook report (December 20, 2024) should be obtained and compared to this characterization. 3. **Discovery Fraud Claims Entered Under Oath:** Guertin's testimony regarding manipulated discovery photographs, retroactive re-manipulation in the Hennepin County OneDrive system, and aspect ratio inconsistencies is now sworn testimony in the court record — not just pro se filings. This elevates the evidentiary status of the claims documented in Filings #1–#9. 4. **Rule 20 Reports Used Fraud Claims as Evidence of Mental Illness:** Guertin testified under oath that all three Rule 20 evaluators (Rogstad, Milz, Cranbrook) cited his claims about fraudulent discovery materials as evidence of psychosis or mental illness justifying involuntary antipsychotic medication. If the discovery fraud claims are substantiated, this creates a circular evidentiary problem: the evidence used to declare him incompetent may itself be the product of misconduct. 5. **False Narratives Documented:** Guertin identified four specific categories of false information propagated across Rule 20 reports: (a) ongoing substance abuse (vs. candid past experimentation), (b) history of suicide/self-harm (no documentation exists), (c) history of psychosis (California psychiatrist confirms none), (d) history of mania. These are independently verifiable against the actual Rule 20 reports. 6. **State Attempted to Block Testimony:** The prosecution argued (without case law) that an incompetent person cannot testify at their own competency hearing under MRE 601. The court rejected this outright. This argument, if successful, would have prevented the discovery fraud claims from entering the sworn record — flagged as potentially strategic. 7. **Retroactive Discovery Re-Manipulation:** Guertin testified that the 20 images with inconsistent aspect ratios (documented in Filing #2, Exhibit G) have been retroactively altered in the Hennepin County OneDrive official discovery system to fit a uniform 16:9 aspect ratio. This is verifiable: compare the current OneDrive images against Guertin's archived originals (provided to public defenders) and the April 4, 2024 analysis. 8. **New Discovery Set Appeared:** Guertin referenced a new folder appearing in the OneDrive discovery system containing additional photos not previously disclosed, including 28 previously missing images. The total set now exceeds 700 images (518 in one matching set, plus additional folders). Cross-reference against the original 104-photograph count from Dr. Rogstad's report and the 80-photograph count from the Biglow email. 9. **Pro Se Filing Pattern:** The court noted that Guertin filed "hundreds of pages" of pro se exhibits before this hearing despite being represented by counsel. The court explicitly stated the filings are "very professional looking" with proper "structure" and "form" — but warned that filing around counsel undermines the competency claim. This is a double bind: the filings demonstrate sophisticated legal capability but the act of filing them without counsel demonstrates difficulty working within the attorney-client framework. 10. **Civil Commitment Successfully Completed:** Guertin's stayed civil commitment was confirmed completed on November 8, 2024, with Vail Place documentation submitted to the court (case 27-MH-PR-23-815). He remains voluntarily engaged with Vail Place caseworker monthly and with Dr. Schuster in California. 11. **Vagle v. Minnesota (A23-0863):** Guertin referenced a pending MN Supreme Court case challenging the constitutionality of the same serial number charges he faces. He testified he identified this legal argument before his attorney did. Oral arguments occurred June 5, 2024. The outcome of this case could moot three of his four charges. 12. **Crestron System Failure During Testimony:** The courtroom's Crestron audiovisual system lost connection to the court reporter during Guertin's testimony about the photographs (p. 16). The court went off record, then Judge Koch attempted to summarize what was said. Guertin is trained in Crestron systems — he noted the irony. The off-record gap means a portion of Guertin's testimony about photo manipulation is not captured in this transcript. 13. **No Ruling Issued:** The court did not rule on competency at this hearing. The matter was taken under advisement. The ruling document should be obtained separately. 14. **Attorney Turnover Pattern:** This hearing marks the involvement of the fourth set of defense-side counsel: (1) Michael Biglow (civil commitment), (2) Bruce Rivers (criminal — fired/discharged), (3) a Vail Place caseworker name "Fisher" (civil commitment replacement for Biglow), (4) Donnelly/Carpenter (public defenders — current). The pattern of attorney turnover is relevant to both the coercion theory raised in Filing #4 and the competency evaluation itself. --- ### FILING #25 | Field | Detail | |---|---| | **Filename** | `131__Pro-Se-Defendants-Motion-to-Dismiss-w-Prejudice__2025-04-16.pdf` | | **Date Filed** | April 16, 2025 (filed stamp: 4/16/2025 3:15 PM) | | **Case ID** | 27-CR-23-1886 | | **Related Federal Case** | 0:24-cv-02646-JRT-DLM | | **Related Appellate Cases** | A24-0780 (MN Court of Appeals); 24-2662 (8th Circuit) | | **Filing Type** | Pro Se Defendant's Motion to Dismiss All Charges with Prejudice | | **Filed By** | Matthew David Guertin (pro se for this motion only, while also represented by defense counsel; address: 4385 Trenton Ln. N 202, Plymouth, MN 55442) | | **Addressed To** | Judge Sarah Hudelston; Mary F. Moriarty, Hennepin County Attorney; Mawerdi Hamid, Assistant Hennepin County Attorney | | **Judicial Officer** | Sarah Hudelston | | **Pages** | 50 | **Detailed Summary:** This is the most comprehensive single filing in the catalog — a 50-page pro se motion to dismiss all four pending felony charges with prejudice (one count under Minn. Stat. § 609.66, subd. 1a(a)(3) [firearm discharge], and three counts under Minn. Stat. § 609.667(3) ["ghost gun" serial number violations]). The motion is structured across eleven major sections and incorporates references to dozens of exhibits, docket entries, external URLs, and case law. It represents a culmination of all prior discovery fraud claims, psychiatric misconduct allegations, and constitutional arguments, now presented as a unified motion for dismissal in the criminal case. **Section I — Introduction (pp. 1–3):** Frames the motion as addressing "pervasive fraud, prosecutorial misconduct, and constitutional violations" that have corrupted every stage of the proceedings. Introduces the concept of a "conspiracy of commitment" involving the prosecution, officers of the court, and falsified psychiatric evaluations designed to portray Guertin as delusional and incompetent. Alleges four categories of misconduct: (1) orchestrated fraudulent Rule 20 evaluations by unauthorized and conflicted individuals; (2) manipulated digital discovery evidence including tampered metadata and AI-generated images; (3) falsified official court records including backdating and undisclosed alterations; (4) efforts to silence Guertin through suppression of evidence, docket manipulation, and "psychological warfare masquerading as psychiatric diagnosis." References forensic analysis confirming digitally altered crime-scene photographs (Index 122, 123, 124), including the laptop screen displaying the "former CIA welder" image (Index 30, pp. 60–66). References Netflix U.S. Patent No. 11,810,254 and Guertin's own U.S. Patent No. 11,577,177 (Index 125). Cites State v. Curtis, 921 N.W.2d 342 (Minn. 2018) and Mooney v. Holohan, 294 U.S. 103 (1935). **Section II — Factual Background (pp. 3–4):** Establishes the procedural posture: Guertin is charged with four felony counts arising from a January 21, 2023 incident in Minnetonka (firearm discharge from his residence; possession of firearms lacking serial numbers). Court ordered Rule 20.01 evaluation. Dr. Rogstad filed report on March 10, 2023, opining Guertin was not competent, diagnosing unspecified psychotic disorder. Guertin was found incompetent in 2023. He contested the finding for two years. In March 2025, the Court found Guertin competent to proceed (Index 127) while still referencing findings of mental illness. Trial has not yet occurred. **Section III — Fraudulent Rule 20 Evaluations and Weaponized Psychiatry (pp. 4–24):** A. **The Rogstad Report: Ghostwritten, Biased, and Deliberately Misleading (pp. 4–5):** Alleges the March 10, 2023 Rule 20 report was not authored by Dr. Rogstad but by "GuzmanC" — identified as Chela Guzman-Wiegert — based on PDF metadata (Index 28, p. 101). Characterizes Guzman-Wiegert as "an administrative figure with no clinical authority or psychological qualifications." B. **The Diagnostic Inversion (pp. 5–6):** Argues Rogstad's own observations satisfy the Dusky v. United States, 362 U.S. 402 (1960) competency standard yet she dismissed them. Quotes Rogstad's admission: "I lack the specialized training in this field to analyze the defendant's reported invention... Nevertheless, even if the technological aspects of the defendant's statements prove true… his views remain consistent with delusions." Alleges Rogstad excluded exculpatory evidence — specifically Minnetonka Police Report #23-000151 (Index 28, pp. 78–80), filed nine days before Guertin's arrest, in which an officer spent 45 minutes with Guertin and advised him to preserve evidence and contact the FBI rather than referring him for a psychiatric hold. C. **The Emails (p. 6):** References email correspondence with Dr. Rogstad (URL provided) showing Guertin sent detailed, technically articulate messages with screenshots, timeline evidence, and reference links prior to the evaluation. Alleges Rogstad dismissed these as "evidence of disorganized thinking." D. **Judicial Gaslighting — July 13, 2023 Order (pp. 6–8):** Analyzes the Court's Order Regarding Competency to Proceed (Index 19), which acknowledged Guertin was "well-dressed," "intelligent," able to "understand the nature of his charges," able to "discuss possible defenses with his attorney," yet still found him incompetent. Guertin characterizes this as a "circular argument" — incompetence determined not by inability to participate but by the content of his defense (i.e., his insistence on presenting evidence about surveillance, patent theft, and digital intrusion). Quotes the order: "When Mr. Guertin spoke about his delusional beliefs, he indicated he would present evidence supporting these beliefs." Argues this constitutes "the criminalization of dissent." E. **The Milz Evaluation (pp. 8–12):** Analyzes the second Rule 20 exam conducted via Zoom on January 3, 2024 by Dr. Adam Milz. Critical fact: Guertin recorded the meeting (entered as Exhibit AB in the federal civil rights lawsuit). The filing provides a detailed comparison between the video/transcript evidence and Milz's written report, identifying eight specific contradictions: 1. Calm, controlled behavior over 80+ minutes vs. Milz's claims of "pressured speech" and "perseveration" 2. Clear legal acumen (quoting Rule 20, citing Miranda, discussing competency vs. civil commitment) vs. Milz characterizing this as "delusional belief in his own legal competence" 3. Guertin's direct refutation of Rogstad's Adderall narrative — explained it was a single instance of taking an extra prescribed dose during an overnight emergency repair of a Bad Bunny mainstage set piece at Coachella 4. Repeated direct refutations of Rogstad's claims 5. Technical expertise demonstrated (TouchDesigner programming, Saudi Arabia business travel, immersive productions for global brands) 6. Misuse of "delusion" label for verifiable events (government agency interactions, LinkedIn surveillance alerts, patent filings) 7. No suicidal ideation — Guertin explicitly stated "I have never attempted, considered, or even thought about suicide, ever" — yet Milz's report states he has "a history of threatening to harm himself" (Exh. S, Index 10) 8. Medical ethics breach — recommendations for civil commitment and forced antipsychotic medication despite no observed psychosis, full orientation, intact memory, and legal understanding Additionally: the Milz report (completed January 11, 2024) was withheld from Guertin for over seven months despite repeated requests. It was only provided on July 16, 2024 — after Guertin filed the federal civil rights lawsuit on July 8, 2024, naming Bruce Rivers as a defendant. Cites Jackson v. Indiana, 406 U.S. 715 (1972) and Moore v. Dempsey, 261 U.S. 86 (1923). F. **The "Conspiracy of Commitment" (pp. 12–17):** Detailed chronological narrative of the events surrounding the February 1, 2024 civil commitment hearing, drawn from Exhibit P of the federal complaint. Key events: - **January 15, 2024:** Rivers tells Guertin via text at 6:26 PM there is "No court" for the next day's scheduled hearing (Index 30, p. 35, 83). - **January 16, 2024:** "Waiver of Appearance" entered at Index #24 in criminal case; "Found Incompetent — Judicial Officer: Mercurio, Danielle" entered with no Index # and no corresponding PDF; Court order signed at 8:27 AM stating "parties agreed to a finding of incompetency entered administratively" and authorizing commitment to "an appropriate safe and secure facility" (Index 25); at 4:19 PM, "Notice of Remote Zoom Hearing" submitted at Index #26 for a date six months away (July 16, 2024) — alleged decoy filing. - **January 17, 2024:** The court order prepared and signed on January 16 is officially submitted at 7:29 AM at Index #25 — out of order (appears AFTER the Index #26 notice filed the day before). Guertin argues this was strategic: the order authorized detention at the next hearing but was withheld to prevent him from challenging it. All further actions shift to the civil commitment case (27-MH-PR-23-815). - **January 26, 2024:** Guertin discovers the surprise February 1 civil commitment hearing by reviewing case files online. Less than a week's notice. Begins seeking the Milz report. Calls and texts Bruce Rivers (Index 30, p. 85, 83). Emails new court-appointed civil commitment attorney Joel Fisher at 1:38 PM. Emails Rivers at 4:38 PM (Index 38, p. 143). - **January 27–29, 2024:** Fisher responds with cryptic reference to "some sort of an offer from the county." Court had provided Fisher with a completely wrong phone number for Guertin (763-245-0896 vs. his actual number). - **January 29, 2024:** Guertin files Motion for Continuance and Motion to Compel Production of Medical Records at 6:37 AM. - **January 31, 2024:** Guertin signs a waiver extending his Stay of Commitment by 9 months to avoid attending the in-person hearing. Referee Borer submits "Taken Under Advisement" notice at Index #39. - **February 1, 2024:** Court order for "Continued Stayed Commitment" submitted at 8:39 AM (Exhibit K, Index 41); recommended by Referee Borer, signed by Judge Julia Dayton Klein; states the February 1 hearing is "cancelled and shall be stricken from the court's calendar" yet it still appears as "Held Off The Record" in the civil case timeline. Index #40 is missing/deleted. Guertin's pro se Motion for Production of Medical Records dismissed without prejudice. G. **Third Rule 20 Exam — October 15, 2024 (pp. 17–20):** On the same day Guertin was finally granted a public defender (replacing Rivers), Judge Shereen Askalani ordered a third Rule 20 evaluation — with no prior involvement in the case, no hearing, and no stated justification. Filing documents multiple docket anomalies: - Index #102 (Oct 1): Order Granting Public Defender by Judge Koch — no document available - Index #103 (Oct 1): Order–Other by Judge Koch — no document available, no explanation - Index #105 (Oct 1): Motion listed with Guertin as "party" not "filer" — no document available; Guertin states he did not file this - Index #106 (Oct 15): Order Granting Public Defender by Judge Askalani — no document available - Index #108 (Oct 15): Order for Evaluation of Competency to Proceed (Rule 20.01) by Judge Askalani — 3-page document - Index #109 (Oct 15): Order Appointing Forensic Navigator by Judge Askalani — 2-page document - Undated "Probable Cause Found" entry with no judicial officer, no index number, and no filing attached H. **The Cranbrook Report — December 20, 2024 (pp. 20–21):** Third Rule 20 evaluation by Dr. Katheryn Cranbrook (Index 116, pp. 16–20). Cranbrook diagnosed Guertin with Unspecified Psychotic Disorder and recommended forced antipsychotic treatment without ever interviewing him (Guertin declined to participate). Cranbrook based the evaluation entirely on court filings, emails, and the federal civil rights lawsuit — treating Guertin's litigation as evidence of mental illness. Cited his federal lawsuit (24-CV-2646), appellate brief (A24-0780), and Eighth Circuit filing (24-2662) as "symptomatic of a thought disorder." Guertin notes he had successfully completed his stayed order of civil commitment on November 6, 2024 (Index 113, p. 10) and had filed this fact directly into the criminal case to prevent it from being buried under HIPAA restrictions. I. **Judicial Participation in the Fraud — April 3, 2025 (pp. 21–23):** On April 3, 2025, Guertin presented four pro se evidence exhibits (Index 122, 123, 124, 125) and the Court (Judge William Koch) formally declared him competent to stand trial (Index 127). However, the order simultaneously described his beliefs as "fantastical and paranoid," accused him of "exaggerating his credentials," and found him "mentally ill, yet legally sane." Guertin characterizes this as "judicial containment" — acknowledging enough to proceed while avoiding confrontation with the substance of the exhibits. Notes Judge Koch mentioned the exhibits only in passing with no written analysis. J. **Legal Consequences (pp. 23–24):** Argues the cumulative due process violations — constructed mental illness, coercive waiver, misrepresented evaluations, withheld orders, and manipulated filings — render the proceeding constitutionally void. **Section IV — Fraudulent Discovery and Collapse of Due Process (pp. 24–29):** A. **Timeline of the Fraud (pp. 25–27):** Provides a comprehensive chronological timeline of discovery-related events: - August 3, 2023: Biglow emails 80-image discovery packet - October 30, 2023: Guertin notices visual anomalies, demands explanation (ignored) - January 3, 2024: Guertin raises concerns to Dr. Milz; Milz uses them as "evidence of delusion" - January 11, 2024: Milz report finalized (Guertin denied access) - April 4, 2024: Guertin files Motion to Compel Discovery with forensic analysis (Filing #2 in master catalog) - May–July 2024: Repeatedly denied discovery access - July 2, 2024: MN Court of Appeals denies discretionary review - July 8, 2024: Guertin files federal civil rights lawsuit - July 12, 2024: Ships ~1,700 pages of complaint/exhibits to 11 parties including Rivers - July 16, 2024: Rivers suddenly provides all withheld materials including 518 images and the Milz report. Cross-reference reveals every image from the original set has a match EXCEPT the 28 flagged images (Exh. S, Index 04, pp. 1–3 vs. Index 29, pp. 18–20) - August 7, 2024: Guertin files Motion for Preliminary Injunction with forensic overlays, color curve analysis, and application icon mismatch analysis - September 2, 2024: Guertin files Exhibit Y — the "Catch-22" logic trap - February 13, 2025: Guertin receives most recent discovery set from new public defenders (Index 122, pp. 58–60); begins forensic analysis - February 20, 2025: Sends "My Discovery Fraud Analysis is Complete | URGENT Action is Required" email to new defense counsel with PDF flipbooks and forensic overlays — receives no reply (Index 122, pp. 69–75) - February 28, 2025: Files four new evidence exhibits (Exhibits A–Q) including patent analysis of InfiniSet and Netflix patents (Index 125), shadow/lighting analysis, image overlays, and homography calculations (Index 122, 123, 124) B. **Flipbook Forensics (p. 27):** Describes Guertin's forensic methodology — side-by-side flipbook comparisons revealing distortions, cropped frames, warped dimensions, squashed laptop displays, and misaligned shadows (Index 122 Exhibit C; Index 123 Exhibits F–J; Index 124 Exhibit K). Notes Guertin deliberately pivoted away from advanced digital forensics to common-sense visual evidence. References the "Catch-22" from Exhibit Y: if the manipulated images never existed, how did they appear in earlier filings? If they did exist, why are they now missing? C. **Legal Consequences (pp. 28–29):** Cites Moore v. Dempsey, 261 U.S. 86 (1923) and Mooney v. Holohan, 294 U.S. 103 (1935). Alleges criminal conduct under Minn. Stat. § 609.43(1) (falsifying/tampering with official records) and Minn. Stat. § 609.63 (forging/altering evidence). D. **Remedy (p. 29):** Requests dismissal with prejudice. **Section V — Discovery Withheld by Design (pp. 29–31):** Argues the sustained refusal to provide authentic discovery for nearly a year was deliberate, not bureaucratic. Notes Guertin's persistence in requesting discovery was "itself weaponized against him" — cited as evidence of delusion. Discovery finally provided February 13, 2025 (Index 122, pp. 58–60) only after new counsel filed formal demands (Index 118). Cites Brady v. Maryland, 373 U.S. 83 (1963); United States v. Bagley, 473 U.S. 667 (1985); California v. Trombetta, 467 U.S. 479 (1984). **Section VI — The "Netflix Whistleblower" Truth Behind the Narrative Collapse (pp. 31–36):** Centers on Guertin's Exhibit (Index 128): Netflix U.S. Patent No. 11,810,254 (granted November 7, 2023) was forced by the USPTO to cite Guertin's U.S. Patent No. 11,577,177 as prior art — at the top of the document (Index 28, p. 224). This resulted from Guertin's proactive third-party prior art submission to the USPTO on February 17, 2023, formally accepted under 35 U.S.C. § 122(e) and 37 C.F.R. § 1.290. Alleges surveillance by Lockheed Martin and DARPA — both conducted identifiable searches of his LinkedIn profile (Index 30, p. 58). AI analysis of the InfiniSet patent flagged these agencies as likely stakeholders (Index 125, Exhibit Q). Alleges confidential filings accessed or leaked before publication (Index 125, Exhibits M–N). Describes InfiniSet's capabilities as posing "an existential threat to billion-dollar interests across Silicon Valley, the defense sector, and the entertainment industry" (Index 125, Exhibits O, P). References handwritten notes left at the scene: a note on the kitchen table beside an unlocked laptop stating "I'm afraid that no matter what — whoever is behind all of this has one million different ways to set me up or frame me if they want. Netflix found out about my patent way before I found out about theirs. That's for sure." Also references a message written in permanent marker on the bathroom wall: "They are going to kill me." Argues the Rule 20 process was "a calculated mechanism of suppression, deployed to discredit a whistleblower before he could expose the full scale of what had been done to him." **Section VII — Bruce Rivers Has Left the Building (pp. 36–37):** Documents Rivers' behavioral collapse as coinciding with the State's efforts to silence Guertin. References Rivers' May 22, 2023 statement at 3:13 PM: "You've got some very powerful people keeping an eye on you" (Index 30, pp. 21–40, 73–77, 86–93). Guertin alleges Rivers subsequently denied saying this. Documents Rivers' cessation of communication, abandonment of litigation strategy, and silence regarding fraudulent discovery. References the September 25, 2024 pro se motion for substitute counsel (Index 100) with attached OLPR complaint, which includes live screen recordings of phone interactions with visible touch-trace UI, verified call logs, and chain-of-custody-compliant submission formats. External URLs provided for analysis of Rivers' July 16, 2024 discovery, call logs, and text message records. **Section VIII — Digital Records Manipulation and a Synthetic Court (pp. 37–40):** References the May 3, 2024 sworn affidavit (Index 37 / Filing #9 in master catalog) documenting forensic analysis of 163 criminal case files across three judicial officers (Klein, Mercurio, Borer). Summarizes five findings: 1. **Mathematical impossibilities:** 488 Rule 20.01 evaluations, 130 incompetency orders, and 238 "Returned Mail" filings across only 163 cases. In 2023 alone: 39 originating cases yielded 61 Rule 20 evaluations and 413 total PDF entries. 2. **Returned mail anomalies:** Five MCRO "returned mail" envelope scans match structurally down to stamp placement, ink intensity, and flap geometry — alleged to be digitally fabricated templates, not actual mail pieces. Published analysis linked. 3. **Judicial looping:** Many cases handled by all three judges; at least six cases where the same judge both ordered the Rule 20 evaluation and ruled on incompetency; dozens of cases reuse the same Zoom meeting ID and password across unrelated files. 4. **OneDrive tampering:** Hennepin County's OneDrive-based discovery system contains metadata inconsistencies, download timestamp anomalies, and file count mismatches; the 518-image February 2025 discovery set was surgically missing only the previously flagged images (Index 122, pp. 8–10, 59–68). 5. **Synthetic prosecution:** Alleges the MCRO data reveals a "potential synthetic court system" used to inflate case volume, recycle procedural rulings, simulate oversight, and dismiss legitimate defendants under the appearance of due process. **Section IX — Legal Argument (pp. 40–47):** A. **Outrageous Misconduct (pp. 40–42):** Argues misconduct meets the definition of forgery under Minn. Stat. § 609.63 and public officer misconduct under Minn. Stat. § 609.43. Cites State v. Burkland, 775 N.W.2d 372, 379 (Minn. App. 2009); United States v. Russell, 411 U.S. 423, 432 (1973); State v. Foss, 556 N.W.2d 540 (Minn. 1996); Young v. United States ex rel. Vuitton et Fils S.A., 481 U.S. 787, 810 (1987). Argues prejudice is "incurable" and constitutes "classic structural error." B. **Ghost Gun Charges Unconstitutional (pp. 42–44):** Argues three counts under Minn. Stat. § 609.667(3) are unconstitutional. References State v. Vagle, No. A23-0863 (Hennepin County District Court found the statute unconstitutionally vague; Court of Appeals reversed; issue pending before Minnesota Supreme Court with oral arguments held June 5, 2024). Argues the statute criminalizes the longstanding lawful practice of personally manufacturing firearms. References 26 U.S.C. § 5842, 18 U.S.C. § 922(o)/(p)/(r), 27 C.F.R. §§ 478.39, 479.62, 479.105, and ATF guidance on personal-use firearms. Cites State v. Pederson, 600 N.W.2d 451, 454 (Minn. 1999). C. **Speedy Trial Violation (pp. 44–46):** Argues violation of Sixth Amendment, Article I § 6 of the Minnesota Constitution, and Minn. R. Crim. P. 11.09(b). Over 24 months without trial (presumptively prejudicial). Applies Barker v. Wingo, 407 U.S. 514 (1972) four-factor test: (1) Length of delay — double the presumptive threshold; (2) Reason — State manufactured the incompetency impediment through fraud; (3) Assertion — Guertin consistently pushed to move forward; (4) Prejudice — extreme across all three Barker categories (incarceration, anxiety, and defense impairment including tampered/lost evidence). D. **No Fair Trial Possible (pp. 46–47):** Argues cumulative effect of all misconduct creates a "perfect storm of structural injustice." Cites State v. Pederson at 454. **Section X — Prayer for Relief (pp. 47–50):** Requests four specific remedies: 1. Dismissal with prejudice of all four counts, expressly based on government misconduct and constitutional violations (Fifth, Sixth, Fourteenth Amendments; Article I §§ 6, 7 of the Minnesota Constitution; Minn. R. Crim. P. 11.09). 2. Evidentiary hearing on fraudulent psychiatric evaluations — subpoena Dr. Rogstad, Chela Guzman-Wiegert, and all personnel involved; State ordered to disclose all communications, documents, and metadata related to evaluations. 3. Evidentiary hearing on digital evidence tampering — subpoena law enforcement (Minnetonka Police), technicians, prosecutors, and third parties with access to OneDrive discovery system; qualified digital forensics experts; trace when, how, and by whom files were altered. 4. Sanctions and referrals — reporting to Lawyers Professional Responsibility Board, licensing boards; contempt proceedings or criminal referrals as warranted. **Exhibit / Index References (throughout filing):** | Index / Exhibit | Content | |---|---| | Index 10 (Exh. S) | Milz report claim of "history of threatening to harm himself" | | Index 19 | July 13, 2023 Order Regarding Competency to Proceed | | Index 22 | January 5, 2024 discovery request (Filing #1 in master catalog) | | Index 25 | January 16-17, 2024 Court Order (incompetency finding, commitment authorization) | | Index 26 | January 16, 2024 Notice of Remote Zoom Hearing (July 16, 2024 date) | | Index 28, p. 42-44, 49-51 | Netflix patent documents filed into case | | Index 28, p. 78-80 | Minnetonka Police Report #23-000151 | | Index 28, p. 88-89 | Guertin's InfiniSet patent documents | | Index 28, p. 90-95, 134-149 | Guertin's USPTO 3rd party prior art submissions | | Index 28, p. 101 | Dr. Rogstad report PDF metadata showing "GuzmanC" as author | | Index 28, p. 116-125 | Dr. Rogstad's own observations (competency indicators) | | Index 28, p. 126-129, 161-167, 192-222 | Patent theft evidence | | Index 28, p. 134-158 | Patent filings supporting Guertin's claims | | Index 28, p. 161-172 | Government agency interaction records | | Index 28, p. 224 | Guertin's name/patent atop Netflix patent | | Index 29, p. 14 | Image metadata analysis | | Index 29, p. 18-20 | Original 80-image discovery set reference | | Index 29, p. 36-40 | Emails/attachments sent to Dr. Milz pre-interview | | Index 30, p. 21-40, 73-77, 86-93 | Rivers communications ("powerful people" statement and context) | | Index 30, p. 35, 83 | Rivers "No court" text message (Jan 15, 2024) | | Index 30, p. 50-70 | Surveillance claims documentation | | Index 30, p. 53-59 | LinkedIn surveillance alerts | | Index 30, p. 58 | Lockheed Martin and DARPA LinkedIn searches | | Index 30, p. 60-66 | "Former CIA welder" laptop screen image | | Index 30, p. 67-70 | National defense applications of InfiniSet technology | | Index 30, p. 85 | Guertin call log to Rivers (Jan 26, 2024) | | Index 36 | Guertin's pro se filings in criminal case re: withheld report | | Index 37 | May 3, 2024 MCRO affidavit (Filing #9 in master catalog) | | Index 38, p. 143 | Guertin email to Rivers requesting report (Jan 26, 2024) | | Index 43 | Guertin's pro se filings in civil commitment case | | Index 90, 91 | Discovery-related docket entries | | Index 100 | September 25, 2024 Motion for Substitute Counsel + OLPR complaint | | Index 102 | Oct 1, 2024 Order Granting Public Defender (Koch) — no document | | Index 103 | Oct 1, 2024 Order–Other (Koch) — no document | | Index 105 | Oct 1, 2024 Motion (listed as Guertin but not filed by him) — no document | | Index 106 | Oct 15, 2024 Order Granting Public Defender (Askalani) — no document | | Index 108 | Oct 15, 2024 Order for Rule 20.01 Evaluation (Askalani) — 3 pages | | Index 109 | Oct 15, 2024 Order Appointing Forensic Navigator (Askalani) — 2 pages | | Index 113, p. 10 | Completion of stayed civil commitment (Nov 6, 2024) | | Index 116, pp. 16-20 | Dr. Cranbrook Rule 20 report (Dec 20, 2024) | | Index 118 | New counsel formal discovery demands | | Index 122 | Exhibit A–D: Discovery fraud forensic analysis and flipbook comparisons | | Index 122, pp. 8-10, 59-68 | OneDrive discovery system metadata anomalies | | Index 122, pp. 58-60 | February 13, 2025 discovery receipt | | Index 122, pp. 69-75 | Feb 20, 2025 email to counsel re: completed analysis | | Index 123 | Exhibits F–J: Image overlay and shadow/lighting analysis | | Index 124 | Exhibit K: Homography calculations and known-object comparisons | | Index 125 | Exhibits L–Q: Netflix/InfiniSet patent analysis, AI analysis, academic fraud | | Index 125, Exhibits M-N | Confidential filing access/leak evidence | | Index 125, Exhibits O, P | InfiniSet threat to billion-dollar industries | | Index 125, Exhibit Q | AI analysis flagging Lockheed Martin/DARPA as stakeholders | | Index 127 | April 3, 2025 Order finding Guertin competent | | Index 128 | "Netflix Whistleblower Is Found Alive and Well | Part 1 – The Patent" exhibit | | Index 128, pp. 3-10 | Corporate ties analysis | | Index 128, pp. 42-45 | Confidential filing access evidence | | Index 128, pp. 105-129 | Forensic evaluator claims vs. reality comparison | | Index 129 | "Brodsky USPTO Patent Fraud" | | Index 130 | "Netflix / USC-ICT / Academic Fraud" | | Exhibit K (Index 36) | Emails between Guertin and Joel Fisher (civil commitment attorney) | | Exhibit K (Index 00) | Civil case timeline showing missing Index #40 | | Exhibit K (Index 41) | February 1, 2024 Court Order for Continued Stayed Commitment | | Exhibit P | Federal civil rights complaint exhibit — "Conspiracy of Commitment" timeline | | Exhibit S (Index 04, pp. 1-3) | Rivers July 16, 2024 discovery image cross-reference | | Exhibit S (Index 05, pp. 7-21) | August 7, 2024 discovery analysis | | Exhibit T | Color curve / forensic overlay analysis of laptop screen images | | Exhibit Y | "Catch-22" logic trap (filed Sept 2, 2024) | | Exhibit AB | Video recording of Milz Rule 20 exam (entered into federal case) | **Key Case Law Cited:** - Dusky v. United States, 362 U.S. 402 (1960) - Moore v. Dempsey, 261 U.S. 86 (1923) - Mooney v. Holohan, 294 U.S. 103 (1935) - Jackson v. Indiana, 406 U.S. 715 (1972) - State v. Curtis, 921 N.W.2d 342 (Minn. 2018) - Brady v. Maryland, 373 U.S. 83 (1963) - United States v. Bagley, 473 U.S. 667 (1985) - California v. Trombetta, 467 U.S. 479 (1984) - Barker v. Wingo, 407 U.S. 514 (1972) - State v. Burkland, 775 N.W.2d 372 (Minn. App. 2009) - United States v. Russell, 411 U.S. 423 (1973) - State v. Foss, 556 N.W.2d 540 (Minn. 1996) - Young v. United States ex rel. Vuitton et Fils S.A., 481 U.S. 787 (1987) - State v. Pederson, 600 N.W.2d 451 (Minn. 1999) - State v. Vagle, No. A23-0863 (constitutionality of § 609.667(3)) **Key Minnesota Statutes Cited:** - Minn. Stat. § 609.66, subd. 1a(a)(3) (firearm discharge) - Minn. Stat. § 609.667(3) ("ghost gun" serial number requirement) - Minn. Stat. § 609.43(1) (public officer misconduct — falsifying/tampering records) - Minn. Stat. § 609.63 (forgery/altering evidence) - Minn. R. Crim. P. 11.09(b) (speedy trial) - Minn. R. Crim. P. 20.01 (competency evaluation) **Key People Referenced:** - **Judge Sarah Hudelston** — Current judicial officer addressed on motion - **Mary F. Moriarty** — Hennepin County Attorney (addressed on motion) - **Mawerdi Hamid** — Assistant Hennepin County Attorney (addressed on motion; new prosecutor) - **Dr. Jill Rogstad** — First Rule 20 evaluator (March 10, 2023); report alleged ghostwritten by GuzmanC - **Chela Guzman-Wiegert ("GuzmanC")** — Administrative figure who allegedly authored Rogstad's report - **Dr. Adam Milz** — Second Rule 20 evaluator (January 3, 2024); report withheld 7 months - **Dr. Katheryn Cranbrook** — Third Rule 20 evaluator (December 20, 2024); diagnosed Guertin without interviewing him - **Bruce Rivers** — Former defense counsel; "powerful people" statement; provided July 16, 2024 discovery; subject of OLPR complaint - **Michael Biglow** — Former civil commitment counsel; provided original discovery set - **Joel Fisher** — Court-appointed civil commitment attorney (January 2024); given wrong phone number for Guertin - **Judge William Koch** — Granted public defender (Oct 1, 2024); issued April 3, 2025 competency finding (Index 127) - **Judge Shereen Askalani** — Ordered third Rule 20 exam on same day she granted public defender (Oct 15, 2024) - **Judge Julia Dayton Klein** — Signed January 16-17 court order and February 1, 2024 commitment order; one of three analyzed judicial officers - **Referee Danielle C. Mercurio** — Issued "Found Incompetent" finding on January 16, 2024; one of three analyzed judicial officers - **Referee George Borer** — Submitted "Taken Under Advisement" on January 31, 2024; one of three analyzed judicial officers - **Officer Brandon Harris** — Minnetonka PD; January 12, 2023 police report (#23-000151) **Forensic Flags:** - This is the single most comprehensive filing in the catalog, synthesizing all prior discovery fraud evidence, psychiatric misconduct allegations, MCRO data analysis, and constitutional arguments into a unified dismissal motion. - The filing introduces several NEW evidentiary items not previously cataloged: Index 122 (Exhibits A–D, forensic flipbooks and OneDrive analysis), Index 123 (Exhibits F–J, image overlays and shadow analysis), Index 124 (Exhibit K, homography calculations), Index 125 (Exhibits L–Q, patent analysis), Index 127 (April 3, 2025 competency finding), Index 128 ("Netflix Whistleblower" exhibit), Index 129 ("Brodsky USPTO Patent Fraud"), Index 130 ("Netflix / USC-ICT / Academic Fraud"). - The 518-image discovery set received February 13, 2025 from new public defenders is the third distinct discovery set analyzed (after Biglow's 80-image set and Rivers' July 16 set) — and it is described as containing the same images in "now proven 'edited' form," meaning the previously missing 28 images reappeared but in altered versions. This is a critical new data point not present in any prior filing. - Exhibit AB (video recording of the Milz Rule 20 exam) is an immutable piece of evidence entered into the federal record — its existence creates an irrefutable baseline for comparing Milz's written report against observable behavior. - The Cranbrook evaluation (third Rule 20) represents a new forensic pattern: psychiatric diagnosis without interview, based entirely on court filings and litigation activity. - The docket anomalies surrounding October 1–15, 2024 (missing documents at Indexes 102, 103, 105, 106; phantom motion entry; undated "Probable Cause Found") are newly documented and verifiable against MCRO data. - The civil commitment timeline (Section III-F) provides the most detailed chronological reconstruction of the January 15 – February 1, 2024 events to date, with specific timestamps, Index numbers, and exhibit references. - Rivers' statement "You've got some very powerful people keeping an eye on you" is now attributed to May 22, 2023 at 3:13 PM (previously referenced as June 16, 2023 email in the master catalog — this may represent a date correction or a different instance of the statement; requires reconciliation). - The filing references two external published analyses: (1) Substack article on AI-created fake Minnesota court records, (2) "Netflix Whistleblower Part 1" Substack post. - Address change: Guertin now lists 4385 Trenton Ln. N 202, Plymouth, MN 55442 — same address as his original Plymouth address from Filing #1 in the master catalog, suggesting he moved back from the Chaska address (1075 Traditions Ct.) used in Filings #3–#8. - New judicial officers appear: Judge Sarah Hudelston (current presiding), Judge William Koch (competency ruling), Judge Shereen Askalani (third Rule 20 order). New prosecutor: Mawerdi Hamid, ACA. - The speedy trial argument documents 24+ months without trial — a concrete constitutional claim with measurable parameters. - The ghost gun constitutional challenge references State v. Vagle, pending before the Minnesota Supreme Court — the outcome of Vagle could independently resolve three of the four counts. --- ### FILING #26 | Field | Detail | |---|---| | **Filename** | `133__Defendants-Petition-to-Proceed-as-Pro-Se-Counsel__2025-04-21.pdf` | | **Date Filed** | April 21, 2025 (filed stamp: 4/21/2025 7:48 AM) | | **Case ID** | 27-CR-23-1886 | | **Filing Type** | Defendant's Petition to Proceed as Pro Se Counsel | | **Filed By** | Matthew David Guertin (pro se; address: 4385 Trenton Ln. N 202, Plymouth, MN 55442; phone: 763-221-4540; email: MattGuertin@protonmail.com; web: MattGuertin.com) | | **Addressed To** | Judge Sarah Hudelston; Mary F. Moriarty, Hennepin County Attorney; Mawerdi Hamid, Assistant Hennepin County Attorney | | **Judicial Officer** | Sarah Hudelston | | **Pages** | 110 (32 pp. petition body + Table of Authorities + 3 exhibits: Exhibit A ~24 pp., Exhibit B 4 pp., Exhibit C 50 pp.) | | **Docket Index** | Filed at Index 133 per internal references; references Index 127, 128, 129, 130, 131 | **Detailed Summary:** This is an extraordinarily comprehensive 110-page filing combining a formal Petition to Proceed as Pro Se Counsel (32 pages including Table of Authorities) with three major exhibits that together constitute the most complete single-document articulation of Guertin's case to date. The petition was filed in advance of a scheduled April 29, 2025 hearing at 11:00 AM, set by Judge Hudelston after the April 17, 2025 hearing at which the pro se request first arose. Guertin returns his address to Plymouth (previously Chaska in earlier filings). **I. Petition Body (pp. 1–32)** The petition is structured across eleven Roman-numeral sections plus a Table of Authorities, totaling 56+ footnotes with live hyperlinks. It is grounded in the Sixth and Fourteenth Amendments, Faretta v. California, 422 U.S. 806 (1975), and Minn. R. Crim. P. 5.04 / Minn. Stat. § 611.19. The core argument is that Guertin's pro se request is not a matter of preference but of necessity — he was forced into it because his court-appointed public defenders (Raissa Carpenter and Emmett Donnelly) actively obstructed his defense, and the Court refused to hear his motions while he remained represented by counsel who disagreed with those motions. **Section II — Relevant Background and Facts:** *A. Court-Appointed Counsel's Obstruction:* Guertin documents a systematic breakdown with his third set of attorneys (after Biglow and Rivers). Key events include: (1) January 2025 emails to Carpenter/Donnelly laying out detailed legal strategy with case law citations — met with silence and dismissal; (2) April 16, 2025 pro se filing of a Motion to Dismiss All Charges with Prejudice (Index 131, Exhibit C) — counsel refused to advocate for it; (3) April 17, 2025 hearing before Judge Hudelston where counsel told the Court they "disagreed" with the motion and would not pursue it, and Mr. Donnelly stated he "disagreed with the finding that Defendant is competent" — directly undermining the April 3, 2025 competency order (Index 127); (4) the Court then stated it would not consider Guertin's motion because he was "represented by counsel who does not agree with the motion." *B. New Evidence Exposing Systemic Misconduct:* Guertin references three new evidence exhibits filed at Index 128, 129, and 130: (1) Index 128 — "Netflix Whistleblower" exhibit documenting the competing Netflix patent (U.S. 11,810,254) filed days after Guertin's (U.S. 11,577,177), with the latter cited at the top as prior art; includes Dropbox archives, email records, LinkedIn metadata analysis; (2) Index 129 — "Brodsky USPTO Patent Fraud" exhibits detailing forensic analysis of U.S. Patent 11,383,062 allegedly retroactively amended to mirror InfiniSet's patent; (3) Index 130 — "Netflix Academic Patent Fraud" exhibits exposing allegedly fabricated academic papers attributed to Paul Debevec / USC-ICT, positioned as "Plan B" prior art to invalidate Guertin's patent. *C. Counsel's Willful Blindness:* All three evidence sets were served on defense counsel post-competency. Counsel did not discuss, investigate, or incorporate any of them into a defense theory. Guertin cites United States v. Cronic, 466 U.S. 648 (1984) for presumed prejudice when adversarial process breaks down. *D. April 17, 2025 Hearing — Forced Choice:* During an off-record break (white noise enabled), Guertin asked counsel directly if he could discharge them and proceed pro se — they confirmed he could. Upon resumption, counsel informed the Court. The Court scheduled the April 29 hearing and provided a "FORM 11 — PETITION TO PROCEED AS PRO SE COUNSEL" questionnaire. **Section III — Constitutional Right to Self-Representation:** Comprehensive Faretta analysis including Minnesota's adoption via Minn. R. Crim. P. 5.04, subd. 1(4) and Minn. Stat. § 611.19. Cites State v. Richards, 456 N.W.2d 260, 263 (Minn. 1990); State v. Camacho, 561 N.W.2d 160, 173 (Minn. 1997). Guertin preemptively acknowledges dangers of self-representation, confirms understanding of charges (felonies with up to 5-year term), and states he does not request standby counsel. Notes Minn. Stat. § 611.26, subd. 6 prohibits district public defenders from serving as standby counsel. **Section IV — Denial of Meaningful Defense:** Five subsections (A through E) documenting: refusal to present motions/evidence; opposing client in open court; lack of communication; discovery fraud justifying discharge (citing Brady, Hazel-Atlas Glass, Giglio, Mapp v. Ohio, Strickland, Cronic); and counsel as "gatekeepers for the prosecution." Specific mention that Carpenter told Guertin discovery fraud was "not a big deal" in Minnesota courts. References February 2025 discovery analysis including "flipbooks" and forensic overlays. Notes Hennepin County OneDrive discovery system now contains the manipulated images, binding the State to the fraud. **Section V — Judicial Paradox: Competency Finding vs. Denial of Voice:** Six subsections (A through F) analyzing the contradictions arising from the April 3, 2025 competency order followed by the Court's refusal to hear Guertin's motions. Presents a logical framework: if competent, motions must be heard; if not competent, the April 3 order must be vacated (which no party has moved for). Warns that re-questioning competency would constitute retaliation and potentially trigger 42 U.S.C. § 1983 liability. Cites Pate v. Robinson, 383 U.S. 375 (1966); Mathews v. Eldridge, 424 U.S. 319 (1976); Minnesota Code of Judicial Conduct Rule 2.6(A). **Section VI — "Truth-as-Psychosis":** Extended argument that the opposition's strategy has been to dismiss Guertin's evidence as products of a disordered mind rather than addressing it substantively. Argues that no party has refuted or disproven his evidence. Notes the Motion to Dismiss (Exhibit C) contains 56 footnotes with 78 hyperlinks. Draws analogy to historical suppression of dissidents via psychiatric labeling. **Section VII — Form 11 Objection:** Guertin declines to complete the standard Form 11 questionnaire, arguing: (1) questions 6–9 requesting mental health history violate HIPAA privacy rights; (2) the petition itself serves as the written waiver required by § 611.19; (3) a checkbox form cannot capture the complexity of a "qualified Faretta scenario"; (4) McKaskle v. Wiggins, 465 U.S. 168 (1984) supports autonomy. Notes sarcastically that "filling out Form 11 with a straight face would likely require a trip to the store for a fresh box of color crayons." **Section VIII — Formal Record Request:** Guertin notes the April 17, 2025 hearing appeared to proceed without a court reporter. He submitted a formal transcript request to 4thCourtReporterUnit@courts.state.mn.us. **Section IX — Exhibits Description:** Self-descriptions of the three attached exhibits (A, B, C — detailed below). **Section X — Prayer for Relief (5 requests):** 1. Permit self-representation effective immediately or by April 29, 2025 hearing. 2. Acknowledge Motion to Dismiss (Index 131) is pending and schedule for ruling. 3. Discharge Carpenter and Donnelly; no standby counsel from public defender's office. 4. Clarify on record that pro se invocation is compelled by obstruction, not preference. 5. Any other just relief, including no adverse inference from self-representation. **Section XI — Conclusion:** States granting the petition is "a constitutional necessity" and warns that denial would "escalate" the injustice. **Section XII — Table of Authorities (pp. 31–32):** Organized into Federal Cases (12), Minnesota Cases (6), Statutes (3), and Rules/Professional Conduct (13). --- **II. Exhibit A — Email Record Between Defendant and Defense Counsel (pp. 33–56, labeled "Exhibit A | p. 1–24")** A comprehensive email thread spanning January 3–14, 2025 between Guertin and his public defenders Raissa Carpenter (primary) and Emmett Donnelly (CC'd). The exchange reveals: *Emails 1–6 (Jan 3–6, 2025):* Routine scheduling regarding the January 7 court date with Judge Quam. Carpenter confirms Klein has recused herself (order dated July 15, attaching "27-CR-23-1886 - Order to Recuse.pdf"). Quam appearance is continued. *Email 7 (Jan 7, 2025 at 7:05 AM — the critical strategy email, ~5 pages):* Guertin lays out a detailed legal strategy document titled "Discovery Fraud and Competency Issues." It covers: (1) three sets of discovery photographs (Set 1: 104 referenced by Rogstad, Set 2: 80 provided to Guertin with 28 manipulated, Set 3: 518 provided July 16, 2024 by Rivers missing exactly those 28 flagged images); (2) the "Catch-22" argument (Exhibit Y from federal case); (3) competency challenge strategy emphasizing that the very "conspiracy" used to label him psychotic is now validated by the discovery fraud; (4) proposed legal strategy in three steps: file motion for discovery, challenge competency determination at the evidentiary hearing, file motion to dismiss for fraud on the court. Cites Brady v. Maryland, Hazel-Atlas Glass, Dusky v. United States, and Minnesota criminal procedure rules. Includes links to Substack posts, CourtListener filings, and federal case documents. *Email 8 (Jan 8, 2025 at 10:34 AM):* Guertin sends an additional email referencing a Substack post titled "Discrediting Their Fraud." Content includes references to the federal case Rearden LLC v. Disney, a declaration by Hao Li (USC-ICT researcher / CEO of Pinscreen.com), and an extensive list of U.S. government and military research funding grants totaling millions of dollars (from DARPA, Army Research Office, Office of Naval Research, IARPA, etc.) that Guertin argues supports his claim of high-level institutional interest in the technology field relevant to his patent. Also references his LinkedIn search activity analysis (Index 30, pp. 53–59) showing searches from Lockheed Martin, DARPA, and other entities coinciding with key case events. References a "former CIA" welder and Israeli "special ops gear" visible on his prototype (Index 30, pp. 60–66). *Email 9 (Jan 8, 2025 at 6:56 PM):* Carpenter responds only to scheduling — asks if April 17 at 8:45 AM works for a hearing date with Judge Quam. Notes hearing contingent on competency finding. *Email 10 (Jan 10, 2025):* Carpenter sends scheduling summary listing three dates: Feb 13 (in-person meeting at 701 4th Ave South, 14th floor), March 5 (contested competency hearing), April 17 (hearing with Quam, contingent on competency). *Emails 11–12 (Jan 13–14, 2025):* Guertin sends a lengthy 9-point request for discovery photographs, asking for: current state documentation (folder properties, file counts, metadata), chain of custody information, immediate provision on USB drive, and email confirmation. Also requests information about evidentiary hearing protocols for exhibit exchange. Proposes representing himself at the competency hearing with counsel as standby. Cites State v. Sabahot, State v. Thompson, State v. Camacho. *Pattern:* Carpenter responds promptly to scheduling matters but provides zero substantive engagement with Guertin's legal strategy, discovery fraud analysis, or evidence requests. The January 7 strategy email and January 8 patent analysis email receive no substantive reply whatsoever — only a scheduling question about April 17. --- **III. Exhibit B — Order Determining Defendant Competent (pp. 57–60, labeled "Exhibit B | p. 1–4")** The April 3, 2025 Order signed by Judge William H. Koch formally declaring Guertin competent to proceed. Four pages structured as Findings of Fact, Conclusions of Law, and Order. *Background:* Guertin is charged with one count of Reckless Discharge of a Firearm within a Municipality (Felony, Minn. Stat. § 609.66, subd. 1a(a)(3)) and three counts of Receiving/Possessing a Firearm with no Serial Number (Felony, Minn. Stat. § 609.667(3)). Previously found incompetent July 13, 2023 and January 16, 2024. Third Rule 20 evaluation ordered October 15, 2024 by Judge Shereen Askalani and assigned to Dr. Katheryn Cranbrook. *Cranbrook's Report (Dec 20, 2024):* Diagnosed Guertin with "Unspecified Schizophrenia Spectrum and Other Psychotic Disorder" based on available records. Guertin declined to participate in the evaluation. Cranbrook opined symptoms "have been noted to compromise his capacity to rationally engage" and prognosis for competency "appears poor." *Guertin's Hearing Testimony (March 5, 2025):* Guertin testified extensively. He demonstrated understanding of charges, court procedures, plea bargaining, right to call witnesses, and roles of parties. He referenced his research on competency case law and creation of custom ChatGPT bots for case analysis. He stated he would not necessarily proceed without an attorney. The Court found his professional background testimony "apparently credible" but noted he attempted to "inflate his past work by ascribing an 'engineering' label" (though acknowledging extensive experience). The Court stated his claims about Netflix and Microsoft IP theft "does not appear to have support" and called those beliefs "fantastical and paranoid." *Key Finding:* Despite finding Cranbrook's mental illness diagnosis "credible," the Court found Guertin demonstrated understanding of court processes, charges, and ability to consult with counsel. "Ultimately, the Court finds Mr. Guertin is competent." *Legal Standard Applied:* Minn. R. Crim. P. 20.01, subd. 5(c) — greater weight of evidence. Burden on defendant contesting an incompetency report. Cites Bonga v. State, 797 N.W.2d 712 (2011); State v. Bauer, 245 N.W.2d 848 (1976); State v. Curtis, 921 N.W.2d 342 (2018); State v. Thompson, 988 N.W.2d 149 (2023). *Footnote 1:* "Mr. Guertin uploaded several exhibits into MNCIS before the hearing. During his testimony, Mr. Guertin referenced several of these exhibits. During closing, the Defense informed the Court they would not be offering these exhibits outside of the testimony received at the hearing." — This confirms defense counsel refused to formally offer Guertin's evidence even at a hearing where he testified about it. --- **IV. Exhibit C — Defendant's Pro Se Motion to Dismiss with Prejudice (pp. 61–110, labeled "Exhibit C | p. 1–50")** A 50-page motion filed April 16, 2025 (Index 131), addressed to Judge Hudelston, prosecuting attorney Mawerdi Hamid, and Hennepin County Attorney Mary F. Moriarty. This is the motion that defense counsel refused to advocate for at the April 17 hearing. It is the single most comprehensive filing in the catalog, containing 56 numbered footnotes with live hyperlinks throughout. **Structure:** Eleven Roman-numeral sections covering every dimension of Guertin's case. *Section I — Introduction:* Frames the prosecution as a "coordinated campaign" constituting a "conspiracy of commitment" involving manipulated discovery, ghostwritten Rule 20 evaluations, falsified court records, and defense counsel misconduct. Lists four categories of State misconduct. References the Netflix patent (U.S. 11,810,254) citing Guertin's patent (U.S. 11,577,177) at the top as prior art. *Section II — Factual Background:* Recounts the case chronology from January 21, 2023 charges through the March 2025 competency determination. *Section III — Fraudulent Rule 20 Evaluations (subsections A through J):* - **A — Rogstad Report (ghostwritten):** Metadata shows author as "GuzmanC" (Chela Guzman-Wiegert), not Dr. Rogstad. An administrative figure with no clinical qualifications authored the report. - **B — Diagnostic Inversion:** Rogstad's own report confirms Guertin could articulate defense strategy, understand charges, knew his rights — satisfying Dusky competency standard — yet she diagnosed psychotic disorder based on his belief about IP theft. Key quote from Rogstad admitted she "lack[ed] the specialized training" to evaluate his invention claims but labeled them "delusions" regardless. - **C — Emails with Rogstad:** Guertin documents sending detailed, articulate emails with technical descriptions and evidence links prior to evaluation. Rogstad dismissed them as "evidence of disorganized thinking." - **D — July 13, 2023 Competency Order (Index 19):** Order acknowledges Guertin is "well-dressed," "intelligent," understands charges, can discuss defenses — yet finds him incompetent because "he insisted on presenting evidence" of surveillance and IP theft. - **E — Milz Evaluation:** Second Rule 20 exam (Jan 3, 2024 via Zoom) was recorded by Guertin (entered as Exhibit AB in federal case). Transcript spans 80+ minutes showing calm, methodical speech. Claims Milz's report falsely attributed "pressured speech" and fabricated "a history of threatening to harm himself." Details the Adderall narrative (Guertin took an extra prescribed dose during an overnight emergency rebuild for Bad Bunny's Coachella mainstage). Notes Milz report was withheld for 7+ months until July 16, 2024 — released only after Guertin filed his federal lawsuit. - **F — "Conspiracy of Commitment":** Detailed day-by-day reconstruction of January 15 through February 1, 2024 events: Rivers told Guertin "No court" for his January 16 hearing; a "Waiver of Appearance" and incompetency finding were entered without hearing; January 16 court order authorized detention but was withheld until January 17; a 6-month review notice was posted as a decoy; Guertin discovered a surprise February 1 civil commitment hearing on January 26; Joel Fisher (new civil commitment attorney) was given a wrong phone number by the court; Guertin scrambled to file motions for continuance and medical records; signed a waiver extending stay of commitment to avoid detention. - **G — Third Rule 20 ordered same day as public defender appointment:** October 15, 2024: Judge Askalani simultaneously granted public defender (Index 106 — no document available) and ordered a new Rule 20 evaluation (Index 108). Guertin documents multiple missing or unexplained docket entries (Index 102, 103, 105, 106 — all without available documents). - **H — Cranbrook Report:** Third evaluator diagnosed Unspecified Psychotic Disorder without ever interviewing Guertin. Based entire assessment on his court filings, emails, and federal lawsuit. His litigation was cited as "symptomatic of a thought disorder." Ignored that Guertin had completed his stayed order of civil commitment on November 6, 2024. - **I — Judicial Participation:** April 3, 2025 competency order found Guertin competent but simultaneously described beliefs as "fantastical and paranoid" and accused him of exaggerating credentials. The four evidence exhibits (Index 122, 123, 124, 125) submitted pre-hearing were mentioned in passing without written analysis. - **J — Legal Consequences:** Argues the cumulative effect of three fraudulent Rule 20 evaluations, suppressed evidence, and manufactured psychiatric narrative requires dismissal. *Section IV — Fraudulent Discovery (subsections A through D):* - **A — Timeline of the Fraud:** 15-entry chronological timeline from August 3, 2023 through February 28, 2025 documenting the discovery fraud progression. Key new data point: February 13, 2025 — Guertin receives most recent discovery set from new public defenders (Index 122, pp. 58–60), completes forensic analysis, sends email titled "My Discovery Fraud Analysis is Complete | URGENT Action is Required" on February 20, 2025. No reply received from counsel. - **B — Flipbook Forensics:** Guertin pivoted from advanced digital forensics to "common-sense logic and visual evidence" using flipbook-format image comparisons. References the "Catch-22" from Exhibit Y. - **C — Legal Consequences:** Cites Moore v. Dempsey, 261 U.S. 86 (1923); Mooney v. Holohan, 294 U.S. 103 (1935). Also cites Minn. Stat. § 609.43(1) (falsifying official records — felony) and § 609.63 (forgery/altering evidence — felony). - **D — Remedy:** Dismissal with prejudice. *Section V — Discovery Withheld by Design:* Documents the year-long withholding from October 2023 through February 2025. Discovery only released after new counsel filed formal demands (Index 118). Cites Brady v. Maryland; United States v. Bagley, 473 U.S. 667 (1985); California v. Trombetta, 467 U.S. 479 (1984). Notes cross-references to multiple discovery requests across both criminal and civil cases (Index 22, 29, 36, 37, 43, 90, 91). *Section VI — Netflix Whistleblower:* Guertin's third-party prior art submission to USPTO (February 17, 2023, accepted under 35 U.S.C. § 122(e) / 37 C.F.R. § 1.290) forced the Netflix patent to cite his patent at the top. Documents LinkedIn surveillance from Lockheed Martin and DARPA. References handwritten note left on kitchen table ("I'm afraid that no matter what...") and bathroom wall message ("They are going to kill me") in permanent marker. Details AI patent valuation analysis (Index 125, Exhibit Q; Index 128, Exhibits P-Q). *Section VII — Bruce Rivers:* Documents Rivers' May 22, 2023 statement "You've got some very powerful people keeping an eye on you," his subsequent denial, and complete behavioral collapse. References the September 25, 2024 motion for substitute counsel (Index 100) with OLPR complaint (Exhibit A). Notes live screen recordings with touch-trace UI behavior submitted as chain-of-custody compliant evidence. *Section VIII — Digital Records Manipulation / Synthetic Court:* Expands on the MCRO analysis from Filing #9. Highlights: (1) mathematical impossibilities — 488 Rule 20 evaluations and 130 incompetency orders across only 163 cases; (2) "returned mail" envelope scans that appear to be digitally fabricated templates (same stamp placement, ink intensity, flap geometry — only names/dates vary); (3) judicial looping among Klein/Mercurio/Borer; (4) OneDrive tampering linking discovery fraud to broader digital infrastructure compromise. References Substack post "AI Created Fake Minnesota Court Records." *Section IX — Legal Argument (subsections A through D):* - **A:** Outrageous governmental conduct requiring dismissal; cites Mooney, State v. Burkland, State v. Foss, Young v. United States. - **B:** Ghost gun charges (Minn. Stat. § 609.667(3)) are unconstitutional; references State v. Vagle (pending before MN Supreme Court, oral arguments June 5, 2024). - **C:** Speedy trial violation under Barker v. Wingo four-factor test — 24+ month delay, bad-faith reason, defendant's consistent assertion, extreme prejudice. - **D:** No fair trial possible; cumulative effect; cites State v. Pederson. *Section X — Prayer for Relief:* 1. Dismissal of all four counts with prejudice. 2. Evidentiary hearing on fraudulent psychiatric evaluations (subpoena Rogstad, Guzman-Wiegert). 3. Evidentiary hearing on digital evidence tampering (subpoena Minnetonka PD, OneDrive technicians). 4. Sanctions and referrals for professional discipline, contempt, or criminal investigation. *Section XI — Conclusion.* --- **Exhibit Inventory (Filing #12):** | Exhibit | Docket Index | Content | Pages | |---|---|---|---| | A | N/A (email records) | January 3–14, 2025 email thread between Guertin and public defenders Carpenter/Donnelly; scheduling, strategy, discovery fraud analysis, patent evidence | 24 pp. (Exh. A pp. 1–24) | | B | Index 127 | April 3, 2025 Order by Judge William Koch declaring Guertin competent to proceed; Findings of Fact, Conclusions of Law, and Order | 4 pp. (Exh. B pp. 1–4) | | C | Index 131 | April 16, 2025 Motion to Dismiss All Charges with Prejudice; 50-page brief with 56 footnotes, 78+ hyperlinks; covers Rule 20 fraud, discovery manipulation, "conspiracy of commitment," Netflix whistleblower claims, MCRO analysis, speedy trial, ghost gun constitutionality | 50 pp. (Exh. C pp. 1–50) | **Key People Referenced:** - **Judge Sarah Hudelston** — Current judicial officer; presided over April 17, 2025 hearing; scheduled April 29 hearing - **Raissa Carpenter** — Court-appointed public defender (Hennepin County Public Defender's Office); primary defense counsel being discharged; told Guertin discovery fraud is "not a big deal" - **Emmett Donnelly** — Court-appointed public defender; stated in open court he disagreed with the competency finding - **Mary F. Moriarty** — Hennepin County Attorney (named in filing header) - **Mawerdi Hamid** — Assistant Hennepin County Attorney (current prosecutor, replacing Perez) - **Judge William H. Koch** — Signed April 3, 2025 competency order; granted public defender October 1, 2024 - **Judge Shereen Askalani** — Ordered third Rule 20 evaluation and appointed public defender on October 15, 2024 - **Dr. Katheryn Cranbrook** — Third Rule 20 evaluator; diagnosed Unspecified Psychotic Disorder without interviewing Guertin; report dated December 20, 2024 - **Judge Julia Dayton Klein** — Referenced as having recused herself (order dated July 15, per Carpenter's Jan 3 email attachment) - **Joel Fisher** — Court-appointed civil commitment attorney; court provided him wrong phone number for Guertin - **Bruce Rivers** — Former defense counsel (second attorney); "powerful people" statement; OLPR complaint filed September 24, 2024 - **Dr. Jill Rogstad** — First Rule 20 evaluator; report ghostwritten by Guzman-Wiegert per metadata - **Chela Guzman-Wiegert** — Administrative figure who authored Rogstad's report per metadata ("GuzmanC") - **Dr. Adam Milz** — Second Rule 20 evaluator; Zoom interview recorded by Guertin; report withheld 7+ months - **Michael Biglow** — Former defense counsel (first attorney; fired) - **Paul Debevec** — USC-ICT researcher affiliated with Netflix; author of allegedly fabricated academic papers (referenced in Index 130) - **Hao Li** — USC-ICT researcher / CEO of Pinscreen.com; federal declaration listing government/military research funding (Rearden LLC v. Disney) **Key Case Law Cited (not previously cataloged):** | Case | Citation | Proposition | |---|---|---| | Faretta v. California | 422 U.S. 806 (1975) | Right to self-representation | | McKaskle v. Wiggins | 465 U.S. 168 (1984) | Pro se defendant's right to maintain control | | Adams v. U.S. ex rel. McCann | 317 U.S. 269 (1942) | Knowing waiver "with eyes open" | | Mathews v. Eldridge | 424 U.S. 319 (1976) | Due process right to be heard | | Pate v. Robinson | 383 U.S. 375 (1966) | Misuse of competency procedure | | Jackson v. Indiana | 406 U.S. 715 (1972) | Indefinite commitment violates due process | | Moore v. Dempsey | 261 U.S. 86 (1923) | Trial dominated by fear of truth | | Giglio v. United States | 405 U.S. 150 (1972) | Passive use of false evidence | | Mapp v. Ohio | 367 U.S. 643 (1961) | Exclusionary rule for tainted evidence | | Hazel-Atlas Glass Co. v. Hartford-Empire | 322 U.S. 238 (1944) | Fraud on the court requires vacatur | | Mooney v. Holohan | 294 U.S. 103 (1935) | Conviction cannot rest on false evidence | | United States v. Bagley | 473 U.S. 667 (1985) | Brady duty extends to material evidence | | California v. Trombetta | 467 U.S. 479 (1984) | Government duty to preserve exculpatory evidence | | Barker v. Wingo | 407 U.S. 514 (1972) | Four-factor speedy trial test | | State v. Richards | 456 N.W.2d 260 (Minn. 1990) | Self-representation right not subject to harmless error | | State v. Camacho | 561 N.W.2d 160 (Minn. 1997) | Court cannot deny pro se request even if unwise | | State v. Clark | 722 N.W.2d 460 (Minn. 2006) | Irreconcilable conflict may require substitution | | State v. Gillam | 629 N.W.2d 440 (Minn. 2001) | Denial of substitution reversible when total communication breakdown | | State v. Thompson | 988 N.W.2d 149 (Minn. App. 2023) | Defendant bears burden to prove competence in contested proceeding | | State v. Sabahot | A10-2174 (Minn. App. 2012) | Competent to stand trial = competent to self-represent | | State v. Burkland | 775 N.W.2d 372 (Minn. App. 2009) | Outrageous conduct that "shocks the universal sense of justice" | | State v. Foss | 556 N.W.2d 540 (Minn. 1996) | Dismissal permitted for egregious law enforcement misconduct | | State v. Pederson | 600 N.W.2d 451 (Minn. 1999) | Judiciary's duty to ensure fairness may surpass State's interest in punishment | | State v. Vagle | A23-0863 | Ghost gun statute § 609.667(3) constitutionality challenge pending before MN Supreme Court | | Young v. U.S. ex rel. Vuitton | 481 U.S. 787 (1987) | System must ensure prosecution by unbiased parties | | Dusky v. United States | 362 U.S. 402 (1960) | Federal competency standard | | State v. Curtis | 921 N.W.2d 342 (Minn. 2018) | MN competency standard | | Bonga v. State | 797 N.W.2d 712 (Minn. 2011) | Due process right not to be tried while incompetent | **Forensic Flags:** - **New judicial officer — Sarah Hudelston:** This is the first appearance of Hudelston in the catalog. She replaces Quam as the primary criminal case judicial officer. The filing indicates she presided over the April 17, 2025 hearing. - **New prosecutor — Mawerdi Hamid:** Replaces Jacqueline Perez as ACA. First appearance in catalog. - **Third set of defense attorneys documented:** Carpenter and Donnelly are Guertin's third set of lawyers (after Biglow and Rivers). All three sets are now documented as failing to advocate for Guertin's discovery fraud claims. - **Carpenter's "not a big deal" statement:** Guertin alleges Carpenter repeatedly told him discovery fraud was "not a big deal" in Minnesota courts — a direct parallel to Rivers' inaction and Biglow's prior failures. - **Donnelly's competency challenge in open court:** Defense counsel publicly stated disagreement with their own client's competency finding — an extraordinary act documented on the record (April 17, 2025). - **Klein recusal confirmed:** Carpenter's January 3, 2025 email confirms Judge Klein recused herself via order dated July 15 (year unspecified but contextually 2024). This is the first documentation of the recusal order. - **Form 11 refusal:** Guertin's refusal to complete the standard Faretta waiver form on HIPAA and constitutional grounds is unusual and may become a contested issue at the April 29 hearing. - **No court reporter at April 17 hearing:** Guertin alleges the hearing proceeded without transcription. His subsequent request for a transcript to the Court Reporter Unit creates a documentation gap if no transcript exists. - **Competency order acknowledges mental illness while finding competence:** Judge Koch's April 3, 2025 order simultaneously credits Dr. Cranbrook's mental illness diagnosis and finds Guertin competent — creating an internal contradiction that Guertin exploits throughout the petition and motion. - **Exhibit C (Motion to Dismiss) is the most extensive filing in the entire catalog:** 50 pages, 56 footnotes, 78+ hyperlinks. It consolidates and expands on every prior filing's allegations with new evidence (Brodsky patent fraud, academic paper fraud, "returned mail" envelope fabrication analysis, OneDrive tampering). - **New MCRO findings on "returned mail" fabrication:** Exhibit C alleges the "returned mail" envelope scans across 163 shared cases are digitally fabricated templates — a new forensic claim beyond the statistical analysis in Filing #9. - **AI manipulation allegations expanded:** Exhibit C explicitly alleges "AI-generated images" and "AI manipulation" in the discovery materials and in MCRO court records — a significant escalation from the manual cropping/editing claims in Filing #2. - **Federal civil rights case cross-reference:** 0:24-cv-02646 (Guertin v. Hennepin County) is now extensively integrated into the catalog through this filing. Key docket entries referenced: the video recording of the Milz interview (Exhibit AB), the Hao Li declaration, and multiple evidence exhibits. - **Civil commitment completion:** Guertin completed his stayed order of civil commitment on November 6, 2024 (per Exhibit C, p. 21; filed at Index 113). This is a new timeline anchor. - **State v. Vagle (ghost gun constitutionality):** The filing raises a new legal challenge to three of four charges under § 609.667(3), referencing an active MN Supreme Court case. If Vagle is decided favorably, three counts could be invalidated independently of the fraud allegations. - **Address reversion to Plymouth:** Guertin's address returns to 4385 Trenton Ln. N 202, Plymouth, MN 55442 (same as Filing #1), after previously being listed at 1075 Traditions Ct., Chaska, MN 55318 (Filings #3–#7). - **Multiple new docket index numbers identified:** Index 100, 102, 103, 105, 106, 108, 109, 113, 116, 118, 122, 123, 124, 125, 127, 128, 129, 130, 131, 133. Many are described as having "no document available" — suggesting docket integrity issues. - **Proton Drive / Substack / CourtListener / Rumble / Odysee links:** Exhibit A and Exhibit C contain dozens of external links to publicly accessible evidence. These are independently verifiable. - **Rearden LLC v. Disney reference:** Federal patent/trademark case in Northern California District Court (docket 6121204) cited as supporting evidence for institutional interest in the technology field relevant to Guertin's patent. --- ### FILING #27 | Field | Detail | |---|---| | **Filename** | `134__Transcript_April-17-2025_Hearing__2025-04-23.pdf` | | **Date Filed** | April 23, 2025 (transcript filed; hearing held April 17, 2025 at 9:15 AM) | | **Case ID** | 27-CR-23-1886 | | **Filing Type** | Transcript of Proceedings — Omnibus Hearing | | **Filed By** | Maya Funk, Official Court Reporter | | **Presiding** | Judge Sarah Hudleston | | **Courtroom** | 1055, Hennepin County Government Center | | **Pages** | 15 | **Detailed Summary:** This is the official transcript of an omnibus hearing in the state criminal case, held before Judge Sarah Hudleston — a new judicial officer not previously appearing in this catalog. The hearing had been "postponed several times" based on the Rule 20.01 referral and evaluation, and a contested competency hearing had recently resulted in Judge Koch entering a finding of competence. This hearing marks a significant procedural turning point: Guertin has been found competent by Judge Koch, and the case is moving toward potential trial scheduling. **Appearances:** - Prosecution: Mawerdi Hamid, Assistant Hennepin County Attorney - Defense: Raissa Carpenter and Emmett Donnelly, Assistant Hennepin County Public Defenders (representing Guertin) - Defendant: Matthew Guertin, present **Key Procedural Developments:** *Pro Se Motions Not Adopted by Counsel (pp. 3–6):* Donnelly states that Guertin filed various pro se motions including a motion to dismiss with a demand for an evidentiary hearing. Critically, Donnelly states: "Ms. Carpenter and I are his attorneys of record. We have not filed that motion. We have not adopted that motion. But it is not — we do not intend to bring it up for a hearing, but it is not our role to dispose of that motion either." The court declines to consider the pro se motion, stating it does not "generally accept additional pro se motions when someone is represented." Prosecutor Hamid concurs that the motion is "not properly before the Court." *Guertin's Response on Legal Strategy (pp. 5–6):* Guertin pushes back, arguing he is "still being held incompetent and having people control my decisions" despite the competency finding. He articulates that the public defenders "work for me" and should be "representing my legal strategy." His preferred strategy is a continuance to allow the court to review his recently-filed motion to dismiss. The court acknowledges his preference but defers to counsel as "officers of the court" who cannot bring "frivolous motions" and are "sworn to be zealous advocates" within "the bounds of the law." *Request to Discharge Public Defenders (pp. 7–8):* After an off-the-record discussion with counsel, Donnelly reports that "Mr. Guertin has advised counsel that he would like to discharge the public defender's office and proceed with self-representation." The court explains the standard procedure: filling out a form petition to self-represent, going over it with a supervisor from the public defender's office, and returning for a continuation hearing. Guertin asks about standby or advisory counsel; the court explains this is limited ("they don't initiate anything") and may not be available from the public defender's office. *Scheduling (pp. 11–14):* The hearing is continued. After discussion of availability, the parties agree to reconvene on April 29, 2025 at 11:00 AM (the week of the 28th, a "block week"). Guertin is to fill out the self-representation petition and meet with a senior public defender supervisor in the interim. **Key People Referenced (new to catalog):** - **Judge Sarah Hudleston** — New presiding judge on the criminal case; not previously in catalog - **Judge Koch** — Referenced as having entered the competency finding; contested hearing was held before him at Guertin's demand - **Mawerdi Hamid** — Assistant Hennepin County Attorney (new prosecutor; replaces Jacqueline Perez) - **Emmett Donnelly** — Assistant Hennepin County Public Defender (new counsel) - **Raissa Carpenter** — Assistant Hennepin County Public Defender (new counsel; previously appeared in Filing #9 Exhibit B as assigned to 16 allegedly fake cases) **Forensic Flags:** - **New judicial officer:** Judge Sarah Hudleston is now presiding over the criminal case — this represents at least the fourth judicial officer on this case (after Quam, Klein, and Koch), potentially addressing Guertin's circular handling concerns from Filing #9. - **New prosecution:** Mawerdi Hamid replaces Jacqueline Perez as prosecuting attorney — a significant personnel change. - **New defense counsel:** Public defenders Donnelly and Carpenter have replaced Bruce Rivers — this means the court eventually addressed the counsel issue, though through reassignment to the public defender's office rather than through Guertin's motions. - **Competency finding by Judge Koch:** This is the first indication in the catalog that a judge has found Guertin competent. The contested hearing was demanded by Guertin himself, and Koch ruled in his favor. However, defense counsel notes they "do not concur with the ruling" — meaning the public defenders disagree with the competency finding, which is an unusual posture. - **Pro se motion refused despite competency finding:** Despite being found competent, Guertin's pro se motion to dismiss is not being considered because he is represented — creating the exact situation he has been arguing about: his legal strategy is being overridden by counsel who refuse to adopt his motions. Counsel explicitly states they "have not adopted" and "do not intend to bring" the motion to hearing. - **Raissa Carpenter connection:** Carpenter is now representing Guertin, but in Filing #9 (Exhibit B), Guertin's MCRO data analysis identified her as being assigned to "16 completely fake cases" — this creates a direct intersection between Guertin's fraud allegations and his own defense team. - **Hearing adjourned in 19 minutes** (9:15 AM to 9:34 AM) — minimal substantive engagement with Guertin's positions. --- ### FILING #28 | Field | Detail | |---|---| | **Filename** | `189__Transcript_April-29-2025__2025-05-03.pdf` | | **Date Filed** | May 3, 2025 (transcript filed; hearing held April 29, 2025 at 11:18 AM) | | **Case ID** | 27-CR-23-1886 | | **Filing Type** | Transcript of Proceedings — Continuation of Omnibus Hearing / Self-Representation Petition Hearing | | **Filed By** | Maya Funk, Official Court Reporter | | **Presiding** | Judge Sarah Hudleston | | **Courtroom** | 1057, Hennepin County Government Center | | **Pages** | 20 | **Detailed Summary:** This is the most substantive transcript in the catalog — the continuation hearing from Filing #16, where Guertin expected to present his self-representation petition. Instead, Judge Hudleston announces at the outset that she cannot allow Guertin to self-represent and orders a new Rule 20.01 competency evaluation, effectively overriding Judge Koch's recent competency finding. This hearing documents extensive on-the-record dialogue between Guertin and the court, including Guertin's attempt to explain the discovery fraud catch-22 and his MCRO data analysis. **Appearances:** - Prosecution: Mawerdi Hamid and Timothy Humphreys, Assistant Hennepin County Attorneys - Defense: Emmett Donnelly and Raissa Carpenter, Assistant Hennepin County Public Defenders - Defendant: Matthew Guertin, present **Key Procedural Developments:** *Court's Denial of Self-Representation (pp. 3–5):* Judge Hudleston opens by explaining that she reviewed Guertin's self-representation petition but cannot accept a waiver of counsel from someone she does not believe is competent. She cites Minn. Stat. § 611.42, subd. 2: "A defendant must not be allowed to waive counsel if the defendant lacks the ability to... appreciate the consequences of proceeding without counsel" and "comprehend other matters essential to understanding the case." She states she is "bound by Judge Koch's competency order" but "only able to follow that competency order unless and until I see evidence of lack of competency." She explains she has now seen such evidence in Guertin's 50+ page motion to dismiss, which she reviewed along with cited exhibits. The court's specific concern is that Guertin raises "as defenses things related to your patent and a big conspiracy with Netflix and the government and the court — criminal court case somehow being related to that." The court states this "is not rational" and "would not provide a defense to the charges." The court affirms Guertin is "an extremely intelligent person" who has "patented really amazing technology" and has "technological capabilities that probably surpass 99.9 percent of the population" — but draws a distinction between intelligence and legal competency regarding rational defense strategy. *State's Concerns About Volume of Filings (p. 6):* Prosecutor Hamid raises alarm about the volume of Guertin's recent filings: approximately 50 filings the previous night, approximately 60 filings the day before ("yesterday"), and over 6,000 pages of documents total. The state explicitly requests a Rule 20.01 evaluation. *Defense Counsel's Position (pp. 6–7):* Donnelly clarifies the defense's position: they "don't criticize Judge Koch's ruling" and note that Koch "dealt with the snapshot that he had in front of him, and competency isn't static." They neither support nor oppose the court's decision, stating they are "not mouthpieces" and will not "put the gag over his mouth." This represents a notably neutral posture — neither advocating for their client's competency nor endorsing the court's incompetency concerns. *Court's Evidentiary Basis for New Rule 20.01 (pp. 7–9):* Hudleston makes a detailed record of her reasons: (1) three separate examiners have opined lack of competence; (2) Guertin's skilled public defenders wanted to advise him but he wanted to discharge them immediately after the Koch ruling; (3) allegations in the criminal complaint suggest paranoia — specifically post-Miranda statements about shooting to bring police because "people were going to kill me over a patent"; (4) public filings now evidence "paranoia and conspiracy theories that are the hallmark of certain mental illnesses"; (5) the motion to dismiss contains "repeated assertions over and over and over" about "coordinated campaigns, intentional manipulation of the system to paint you as incompetent... with the motive, apparently being to cover up patent theft"; (6) "highly illogical assertions... extreme language, extreme repetition, paranoia, and conspiracy assertions"; (7) Guertin's own handwritten note in the motion stating "Whoever is behind this has one million different ways to set me up or frame me if they want. Netflix found out about my patent way before I found out about theirs. That's for sure. They're going to kill me." *Questioning of Prosecutor on Record (pp. 9–10):* In a notable exchange, Hudleston asks Hamid — as an "officer of the court with a sworn duty of candor" — three direct questions: (1) any conversations with anyone from Netflix? "No, Your Honor." (2) Any conversations with federal government agencies? "No, Your Honor." (3) Knowledge of Guertin's assertions about doctored/manipulated discovery? Hamid acknowledges the issue was "briefly discussed during" the competency hearing but states "the state is not aware of any manipulation of the evidence." *Guertin's On-the-Record Statements (pp. 10–12):* Guertin makes several key statements: (a) His conspiracy claims "originate in matters related and pertaining to my patent, but insofar as my claims within the court, they do not — I'm not saying anything about Netflix. I'm saying about things that indicate that it has spilled over into the court." (b) Regarding the discovery fraud, he describes "a logical and inescapable catch-22 that currently exists" and offers to explain it. The court acknowledges reading about the catch-22 in the motion to dismiss but declines further discussion because "my decision is made." (c) Guertin explains the catch-22 briefly: "once the photos existed and then they squished them to put them into the uniform aspect ratio, they can't un-squish them. So, it's a logical trap that proves my claim about it that can't be escaped." (d) Guertin then pivots to his MCRO data analysis: he describes "thousands of pages" of "the court's own records of completely AI-generated fraudulent cases that I uncovered." He states he collected 163 cases exactly one year ago by filtering three judges (Klein, Borer, Mercurio) and their hearing dates on the MCRO system, used a Python script to filter thousands of cases, and then used an automated script to download 3,553 MCRO files. The data set contains "AI-generated USPS mail filings," "the same exact mirrored orders over and over," and includes "Raissa Carpenter assigned to 16 completely fake cases." He begins reciting specific case numbers (27-CR-21-8067, 27-CR-21-8227, 27-CR-21-8228, 27-CR-21-8229, 27-CR-21-8230, 27-CR-21-8511, 27-CR-21-20637, 27-CR-22-17300) before the court stops him. *Court's Response to MCRO Evidence (pp. 12–14):* Hudleston acknowledges the MCRO filings are "in writing in your motion" and offers to accept a physical document/map. However, she states this evidence has no relevance to the criminal case and "is not the conspiracy of the court system." She redirects Guertin toward hiring a patent lawyer for patent disputes and notes the criminal court has "nothing to do with the patents" or "Netflix or other government — federal government agencies." Guertin responds: "It has relevance to the legitimacy of the entire court." *Rule 20.01 Evaluation Ordered (pp. 14–16):* The court formally orders a new Rule 20.01 evaluation on an out-of-custody basis. Guertin's objection is noted for the record. The next hearing is scheduled for July 8, 2025 on the Rule 20 calendar (mental health/probate judges). If found competent, a second date (after July 8) is set for Guertin's case to restart before Judge Hudleston. *Cooperation Requirement (pp. 18):* Hamid raises concerns about past lack of cooperation — Guertin previously sent emails to the evaluator rather than meeting in person. The court orders Guertin to meet with the evaluator in person or by Zoom. Guertin's objection is again noted. **Key People Referenced (new to catalog):** - **Judge Sarah Hudleston** — Presiding judge; orders new Rule 20.01 over Koch's competency finding - **Judge Koch** — Referenced; his competency finding is effectively being overridden - **Timothy Humphreys** — Assistant Hennepin County Attorney (new; co-counsel with Hamid) - **Mawerdi Hamid** — Lead prosecutor; makes record on filing volume and cooperation - **Emmett Donnelly** — Public defender; maintains neutral posture on competency - **Raissa Carpenter** — Public defender; explains Rule 20 process to Guertin on the record; previously identified in Filing #9 as assigned to allegedly fake MCRO cases - **Lucas Kraskey** — Referenced by Guertin as one of the fake case defendants (case numbers recited) **Forensic Flags:** - **Judge Koch's competency finding overridden:** This is the most significant procedural development in the catalog. Guertin was found competent through a contested hearing he demanded, and that finding is now being set aside by a different judge based on a review of his legal filings. The court's reasoning centers on the content of his arguments (conspiracy claims, patent/Netflix connections) rather than his capacity to articulate them. - **The competency-content paradox:** The court simultaneously acknowledges Guertin's extreme intelligence, technological capabilities ("probably surpass 99.9 percent of the population"), and ability to produce detailed legal filings — yet finds him incompetent because the content of those filings reflects beliefs the court considers irrational. This is precisely the paradox Guertin has been arguing about since the beginning: his competency is being adjudicated based on whether the court believes his claims, not whether he can rationally participate in his defense. - **Prosecutor's response on discovery fraud:** Hamid's statement that the state "is not aware of any manipulation of the evidence" despite the issue being "briefly discussed" at the competency hearing creates a record: the prosecution acknowledges awareness of the allegation but denies any knowledge of actual manipulation. This does not address the forensic evidence (aspect ratio analysis, missing images, metadata anomalies) — it is a blanket denial. - **MCRO data analysis presented on the record:** Guertin's oral description of the MCRO analysis matches Filing #9 exactly — 163 cases, three judges (Klein, Borer, Mercurio), Python scripts, 3,553 files, AI-generated USPS filings, Raissa Carpenter assigned to fake cases. He recites specific case numbers from memory. The court declines to engage substantively with this evidence. - **Raissa Carpenter directly implicated:** Guertin names Carpenter — his current public defender, seated next to him — as being assigned to 16 fake cases in the MCRO data. She does not respond on the record. This creates an extraordinary situation: a defendant's own appointed counsel is identified in his fraud allegations, and she continues representing him. - **Volume of filings as evidence of incompetency:** The state's characterization of ~110 filings and 6,000+ pages as grounds for a Rule 20 evaluation is procedurally significant. Large-volume filing is often associated with pro se litigants but is not inherently evidence of mental illness — the content matters more than the volume. The court appears to weigh both volume and content. - **"They're going to kill me" statement:** The court quotes Guertin's handwritten note from the motion to dismiss. This statement was allegedly made in the context of learning about his patent being used without authorization, not in the context of the court proceedings. The court uses it as evidence of paranoia; Guertin would likely characterize it as a reasonable fear given the circumstances he alleges. - **New Rule 20.01 ordered — fourth evaluation:** This will be at least the fourth competency evaluation in this case (Rogstad March 2023, second evaluation ordered Nov 2023 resulting in Jan 2024 finding, Koch's contested hearing, and now this). The pattern of repeated evaluations after adverse (for prosecution) outcomes is itself relevant to Guertin's claims about the process being used as a tool of suppression. - **Hearing lasted 22 minutes** (11:18 AM to 11:40 AM) — the court's decision was made before the hearing began; substantive engagement with Guertin's evidence was minimal. - **Return date July 8, 2025:** Establishes the next procedural anchor point in the state criminal case. --- ## CHRONOLOGICAL TIMELINE | # | Date | Filing # | Source Document | Key Action | |---|---|---|---|---| | 1 | 2024-01-05 | #1 | `MCRO_27-CR-23-1886_Demand_or_Request_for_Discovery_2024-01-0` | Demand or Request for Discovery | | 2 | 2024-04-04 | #2 | `MCRO_27-CR-23-1886_Motion_2024-04-04_20240430072350.pdf` | Motion to Compel Discovery + Affidavit of Fact | | 3 | 2024-05-03 | #3 | `MCRO_27-CR-23-1886_Correspondence_2024-05-03_20240503153904.` | Correspondence (formal follow-up letter) | | 4 | 2024-05-10 | #4 | `MCRO_27-CR-23-1886_Notice_of_Appeal_2024-05-10_2024051611065` | Petition for Discretionary Review (Notice of Appeal) | | 5 | 2024-05-15 | #5 | `MCRO_27-CR-23-1886_Other_Document_2024-05-15_20240516111053.` | Petitioner's Addendum 2 (appellate addendum) | | 6 | 2024-05-15 | #6 | `MCRO_27-CR-23-1886_Other_Document_2024-05-15_20240516111114.` | Petitioner's Addendum 3 (appellate addendum) — Affidavit of Fact / MCRO Data Ana | | 7 | 2024-06-03 | #7 | `MCRO_27-CR-23-1886_Correspondence_2024-06-03_20240604132619.` | Correspondence (brief follow-up letter) | | 8 | 2024-06-03 | #8 | `MCRO_27-CR-23-1886_Motion_2024-06-03_20240603092053.pdf` | Motion for Substitute Counsel | | 9 | 2024-06-03 | #9 | `MCRO_27-CR-23-1886_Notice_of_Motion_and_Motion_2024-06-03_20` | Notice of Motion and Motion (Renewed Motion to Compel Discovery) | | 10 | 2024-07-08 | #10 | `00__Guertin-v-Hennepin-County-0_24-cv-02646__2025-02-12.pdf` | Complete Federal Case Docket Sheet (CourtListener extract) | | 11 | 2024-07-16 | #11 | `02__EXHIBIT-R__ORIGINAL-MOTION-FOR-EMERGENCY-TRO__DIGITAL.pd` | Exhibit R — Digital version of Emergency Motion for TRO and Immediate Hearing, w | | 12 | 2024-08-07 | #12 | `42__GUERTINS-MOTION-FOR-EXPEDITED-PRELIMINARY-INJUNCTION.pdf` | Emergency Motion for Expedited Preliminary Injunction and Immediate Judicial Int | | 13 | 2024-08-07 | #13 | `43__EXHIBIT-S__NEW-EVIDENCE-AND-EMAIL-COMMUNICATIONS.pdf` | Exhibit S — Newly Obtained Evidence and Email Communications (supporting follow- | | 14 | 2024-08-07 | #14 | `44__EXHIBIT-T__FRAUDULENT-DISCOVERY-ANALYSIS__1-of-3.pdf` | Exhibit T — Forensic Analysis of Discovery Photographs (Part 1 of 3) | | 15 | 2024-08-07 | #15 | `45__EXHIBIT-U__FRAUDULENT-DISCOVERY-ANALYSIS__2-of-3.pdf` | Exhibit U — Forensic Image Analysis (Part 2 of 3), attached to Doc. 45 | | 16 | 2024-08-07 | #16 | `46__EXHIBIT-V__FRAUDULENT-DISCOVERY-ANALYSIS__3-of-3.pdf` | Exhibit V — Forensic Analysis of Fraudulent Discovery Materials (Part 3 of 3: Co | | 17 | 2024-08-14 | #17 | `54__PLAINTIFFS-RESPONSE-TO-DEFENDANTS-MOTIONS-TO-DISMISS.pdf` | Plaintiff's Response to Defendants' Motions to Dismiss (Doc. 54) | | 18 | 2024-08-27 | #18 | `68__PLAINTIFFS-MEMORANDUM-IN-OPPOSITION-TO-STATE-DEFENDANTS-` | Plaintiff's Memorandum in Opposition to State Defendants' Motion to Dismiss and | | 19 | 2024-09-02 | #19 | `73__PLAINTIFFS-MEMORANDUM-IN-OPPOSITION-TO-HENNEPIN-COUNTY-D` | Plaintiff's Memorandum in Opposition to Hennepin County Defendants' Motion to Di | | 20 | 2024-09-02 | #20 | `74__EXHIBIT-Y__GUERTINS-COMPETENCY-AND-DEFENDANTS-INCOMPETEN` | Exhibit Y — Guertin's Competency and Defendants' Incompetency | | 21 | 2025-02-28 | #21 | `122__Exhibit-List_A-E__Discovery-Fraud-Proven__2025-02-28.pd` | Defendant's Supplemental Evidence Submission in Support of Objection to Competen | | 22 | 2025-02-28 | #22 | `123__Exhibit-List_F-J____Discovery-Fraud-Proven__2025-02-28.` | Defendant's Supplemental Evidence Submission in Support of Objection to Competen | | 23 | 2025-02-28 | #23 | `124__Exhibit-List_K-L____Discovery-Fraud-Proven__2025-02-28.` | Defendant's Supplemental Evidence Submission in Support of Objection to Competen | | 24 | 2025-03-05 | #24 | `Guertin__Matthew_-_March_5__2024.pdf` | Official Court Transcript — Contested Competency Hearing | | 25 | 2025-04-16 | #25 | `131__Pro-Se-Defendants-Motion-to-Dismiss-w-Prejudice__2025-0` | Pro Se Defendant's Motion to Dismiss All Charges with Prejudice | | 26 | 2025-04-21 | #26 | `133__Defendants-Petition-to-Proceed-as-Pro-Se-Counsel__2025-` | Defendant's Petition to Proceed as Pro Se Counsel | | 27 | 2025-04-23 | #27 | `134__Transcript_April-17-2025_Hearing__2025-04-23.pdf` | Transcript of Proceedings — Omnibus Hearing | | 28 | 2025-05-03 | #28 | `189__Transcript_April-29-2025__2025-05-03.pdf` | Transcript of Proceedings — Continuation of Omnibus Hearing / Self-Representatio | ## KEY ENTITIES TRACKER | Entity | Role | First Appears | |---|---|---| | Matthew David Guertin | Defendant/Plaintiff (pro se) | All filings | | Jacqueline Perez | ACA / Prosecutor | Filing #1 | | Michael Biglow | Former defense counsel (fired); signed commitment terms Aug 2023 | Filing #2 (Exhibit A) | | Bruce Rivers | Defense counsel (seeking replacement); "powerful people" statement; default entered then vacated in federal case | Filing #3 | | Judge Jay Quam | Judicial officer, state criminal case | Filing #2 | | Judge Julia Dayton Klein | Judicial officer (issued Apr 12 pro se denial order; one of three analyzed officers) | Filing #3 | | Judge Michael K Brown | Signs disproportionate share of incompetency orders | Filing #2 (Exhibit E) | | Dr. Jill Rogstad | Rule 20.01 evaluator (March 10, 2023); report metadata shows "GuzmanC" as author | Filing #2 (Exhibit E) | | Dr. Michael Robertson | Civil commitment examiner (Aug 1, 2023); "N/A" on competency certification | Filing #2 (Exhibit E) | | Dr. Adam Milz | 6-month review examiner (Jan 3, 2024); Guertin has video of exam | Filing #2 (Exhibit M) | | JSF254 | PDF author/creator in discovery metadata | Filing #2 (Exhibit D) | | Chela Guzman-Weigart | Asst. County Admin, Law Safety & Justice; "GuzmanC" in Rogstad report metadata; CJCC member; defendant in federal case | Filing #4, expanded in #11 | | Court Referee Danielle C. Mercurio | One of three judicial officers in circular handling analysis; defendant in federal case (individual capacity) | Filing #9 (Exhibit A) | | Court Referee George Borer | One of three judicial officers in circular handling analysis; defendant in federal case (individual capacity) | Filing #9 (Exhibit A) | | Kristin Siegesmund | Initiating judge in some analyzed shared cases | Filing #9 (Exhibit B) | | Hilary Caligiuri | Initiating judge in some analyzed shared cases | Filing #9 (Exhibit B) | | Judge John R. Tunheim | Presiding federal judge; issued TRO denial, dismissed case under *Younger* | Filing #10 | | Judge Jeffrey M. Bryan | Originally assigned federal judge; recused July 9, 2024 | Filing #10 | | Magistrate Judge Douglas L. Micko | Assigned federal magistrate | Filing #10 | | Benjamin Harringa | AAG representing state defendants in federal case | Filing #10 | | Jamil M.F. Masroujeh | ACA representing county defendants in federal case | Filing #10 | | Matthew Lloyd Robert Messerli | Additional counsel for county defendants in federal case | Filing #10 | | Daniel J. Cragg | Attorney for Bruce Rivers in federal case | Filing #10 | | Keith Ellison | MN Attorney General; defendant in federal case (official capacity) | Filing #10 | | Mary Moriarty | Hennepin County Attorney; defendant in federal case (official capacity); CJCC member | Filing #10 | | Joel Fisher | Attorney ID# 29579; advised Guertin on Jan 31, 2024 waiver | Filing #11 | | Referee Lyonel Norris | Found probable cause Jan 25, 2023 | Filing #11 | | **Officer Brandon Harris** | **Minnetonka Police Department; received Guertin's fraud report Jan 12, 2023 (predates criminal charges)** | **Filing #12** | | **Judge Sarah Hudleston** | **Presiding judge on 27-CR-23-1886 (2025); denied self-representation; ordered fourth Rule 20.01 evaluation overriding Judge Koch's competency finding** | **Filing #16** | | **Judge Koch** | **Presided over contested competency hearing; entered finding of competence (subsequently overridden by Hudleston)** | **Filing #16** | | **Mawerdi Hamid** | **Assistant Hennepin County Attorney; replaced Perez as prosecutor on criminal case** | **Filing #16** | | **Emmett Donnelly** | **Assistant Hennepin County Public Defender; appointed defense counsel (replaced Rivers); maintained neutral posture on competency** | **Filing #16** | | **Raissa Carpenter** | **Assistant Hennepin County Public Defender; appointed defense counsel; previously identified in Filing #9 as assigned to 16 allegedly fake MCRO cases; named on the record in Filing #17** | **Filing #16** | | **Timothy Humphreys** | **Assistant Hennepin County Attorney; co-counsel with Hamid at April 29, 2025 hearing** | **Filing #17** | | **Maya Funk** | **Official Court Reporter, Fourth Judicial District** | **Filing #16** | | Judge Sarah Hudelston | Current judicial officer in 27-CR-23-1886 | Filing #13 | | Dr. Katheryn Cranbrook | Third Rule 20 evaluator (Dec 20, 2024); diagnosed without interview | Filing #13 | | Judge William Koch | Granted public defender (Oct 1, 2024); issued April 3, 2025 competency finding | Filing #13 | | Judge Shereen Askalani | Ordered third Rule 20 exam same day she granted public defender (Oct 15, 2024) | Filing #13 | | Mary F. Moriarty | Hennepin County Attorney | Filing #12 | | Thomas Manewitz | Assistant Hennepin County Attorney (replaces Perez) | Filing #12 | | Emmett M. Donnelly | Assistant Public Defender (co-counsel with Carpenter) | Filing #12 | | JoAnne Van Guilder | Hennepin County staff; controls OneDrive discovery system; "Modified By" on all 104 discovery files | Filing #12 | | Dr. Michael Roberts | Possibly same as Dr. Michael Robertson (name discrepancy); civil commitment examiner Aug 1, 2023 | Filing #12 (Exhibit B) | | ggilbertson (unknown first name) | Username embedded in second-batch discovery image filenames; presumed evidence technician or photographer (Minnetonka PD or Hennepin County) | Filing #12 (Exhibits F–J) | | G. Gilbertson | Photographer identified in discovery image filenames; reflection visible in Garage Photo 02 showing DSLR camera with external flash | Filing #12 (Exhibit L) | | Aaron M. Schefter | Co-inventor, U.S. Patent D727,456S (Hexmag ammunition magazine design) | Filing #12 (Exhibit K) | | Adam R. Schefter | Co-inventor, U.S. Patent D727,456S (Hexmag ammunition magazine design) | Filing #12 (Exhibit K) | | Judge William H. Koch | Presiding Judge, Probate Mental Health Court (competency matters) | Filing #12 | | Dr. Cranbrook | Rule 20.01 Evaluator (third evaluation; Dec 20, 2024 report) | Filing #12 | | Dr. Martin Schuster | Guertin's California psychiatrist (since 2016); prescribes Adderall/Klonopin | Filing #12 | | Judge Hudleston | Criminal case judge (replacing Judge Quam upon retirement) | Filing #12 | | Vello Virkhaus | Owner, V Squared Labs; Guertin's former employer (2014–2020) | Filing #12 | | Melinda K. Anderson | Official Court Reporter | Filing #12 | | Tom Arneson | Assistant Hennepin County Attorney; appeared at Jan 16, 2024 hearing | Filing #12 | | Amanda Prose | Patent attorney, Westman Champlin & Koehler; advised IC3.gov filing (Jan 6, 2023) | Filing #12 | | Megan Neumann | Westman Champlin & Koehler; CC'd on Guertin–Prose emails | Filing #12 | | Paul Debevec | USC ICT Graphics Lab researcher; allegedly connected to Netflix; subject of YouTube age discrepancy analysis | Filing #12 | | Stephan Trojansky | Inventor on Netflix US Patent 11,810,254; filed 12 days after Guertin | Filing #12 | | Jules Urbach | CEO, OTOY/Octane Render; referenced in YouTube fraud analysis | Filing #12 | | Tom Daschle | Leader, InterMedia Advisors/Partners (Uptv parent); alleged Air Force ties | Filing #12 | | Alan Sokol | InterMedia Advisors/Partners; alleged Netflix connections | Filing #12 | | Jeremy Reiss | EVP, Henry Street Settlement; Fulbright Specialist with US State Department | Filing #12 | | Dr. Casey Boland | Present during Dr. Rogstad's March 1, 2023 evaluation of Guertin | Filing #12 (Index 13) | | Z. Peter Sawicki | WCK shareholder; terminated Guertin's attorney-client relationship Aug 10, 2023 | Filing #12 (Index 08) | | Mark Lanterman | Computer Forensics (CompForensics.com); engaged for forensic hard drive analysis | Filing #12 (Index 09) | | Dr. Schuster | Guertin's outpatient psychiatrist (California); Schuster Medical Research Institute | Filing #12 (Index 10) | | Becky Schmidt | Case manager at Vail Place | Filing #12 (Index 10) | | Ian Bearce | Head of Studio at Best Buy corporate; referred Guertin to DN Studios | Filing #12 (Index 08) | | Robert Hulse | IP attorney at Fenwick & West; represents Netflix and Microsoft | Filing #12 (Index 09) | | Judge John R. Tunheim (JRT) | U.S. District Judge, District of Minnesota — federal civil case 0:24-cv-02646-JRT-DLM | Filing #12 | | Magistrate Judge Douglas L. Mahoney (DLM) | U.S. Magistrate Judge, District of Minnesota — federal civil case 0:24-cv-02646-JRT-DLM | Filing #12 | | Magistrate Judge (DLM) | Assigned Magistrate Judge, federal case 0:24-cv-02646-JRT-DLM | Filing #12 | | Hao Li | USC-ICT researcher / CEO of Pinscreen.com; federal declaration listing govt/military funding | Filing #12 (Exhibit A) | ## KEY DOCUMENTS REFERENCED | Document | Date | Significance | |---|---|---| | 23-815 Guertin - photos of exterior, interior, person 1.21.pdf | Created Aug 2, 2023 | The disputed discovery PDF — 80 photos (24 missing), systematic cropping | | Dr. Rogstad's Rule 20.01 Evaluation Report | March 10, 2023 | References 104 photographs; metadata shows "GuzmanC" as author/creator | | Dr. Robertson's Civil Commitment Exam Report | Aug 1-4, 2023 | Lists discovery PDF as reviewed material | | Dr. Milz's 6-Month Review Exam Report | Jan 3, 2024 | Never provided to Guertin per filings | | Motion for Judicial Notice | April 3, 2024 | Referenced but not in this batch | | April 12, 2024 Order (Pro Se denial) | April 12, 2024 | Order being appealed; now included as exhibit in Filing #11 | | June 14, 2023 Continuance Order | June 14, 2023 | Allegedly based on non-existent motion | | June 16, 2023 Email (Rivers → Guertin) | June 16, 2023 | "Powerful people keeping an eye on you" | | Guertin's MCRO Data Archive (Proton Drive) | May 3, 2024 | https://drive.proton.me/urls/QA8TBVTHEC#Wy7ygZMVpev7 — 6 ZIPs of raw case files + Python scripts | | Jan 31, 2024 Waiver (Stay of Commitment Extension) | Jan 31, 2024 | Signed by Guertin + Joel Fisher after second incompetency finding; extends commitment stay 9 months | | Aug 2023 Acceptance of Terms of Stay of Commitment | August 9, 2023 | Michael Robertson's competency certification marked "N/A"; signed by Guertin + Michael Biglow | | Federal Complaint (ECF No. 1) | July 8, 2024 | §1983 complaint naming 11 defendants; not separately cataloged yet | | Memorandum Opinion Denying TRO (ECF No. 26) | July 16, 2024 | Judge Tunheim's written opinion denying emergency relief | | Memorandum Opinion Granting Dismissal (ECF No. 80) | Sept 30, 2024 | Younger abstention dismissal; does not address merits of fraud allegations | | Video of Jan 3, 2024 Rule 20.01 Exam (ECF No. 78, Exhibit AB) | Sept 26, 2024 | Guertin's recording of interview with Adam Milz; allows direct comparison with Milz's report | | Exhibits AD–AI (ECF Nos. 81–86) | Sept 30, 2024 | "FRAUD Rounds 1 and 2" — AI-generated prior art allegations, YouTube backdating, USC/Netflix/military involvement | | **Netflix US Patent 11,810,254** | **Referenced in Filing #12** | **Guertin claims his name and patent number appear atop this Netflix patent; independently verifiable via USPTO** | | **January 12, 2023 Police Report (Officer Brandon Harris)** | **January 12, 2023** | **Guertin presented fraud evidence to Minnetonka PD BEFORE the Jan 21, 2023 incident that led to criminal charges** | | **Guertin's 50+ Page Motion to Dismiss (state court)** | **Filed ~April 28, 2025** | **Filed in 27-CR-23-1886; not adopted by public defenders; basis for Judge Hudleston's incompetency concerns; includes handwritten note "They're going to kill me"** | | **~110 Filings / 6,000+ Pages (state court)** | **Filed ~April 27-28, 2025** | **Massive filing volume cited by prosecution as grounds for Rule 20.01; includes MCRO data analysis, AI-generated USPS mail filings, mirrored court orders** | | **Judge Koch's Competency Finding/Order** | **~March-April 2025** | **Contested competency hearing demanded by Guertin; Koch found him competent; subsequently overridden by Hudleston** | | Federal Complaint — 0:24-cv-02646-JRT-DLM | Filed July 8, 2024 | Federal civil rights lawsuit; discovery fraud is central claim; ~1,700 pages with exhibits served on 11 parties | | August 7, 2024 Motion for Expedited Preliminary Injunction | August 7, 2024 | Contains forensic overlays, color curve analysis, application icon mismatch analysis of discovery images | | Exhibit T — Color Curve / Forensic Overlay Analysis | August 7, 2024 | Applied color curve adjustments to Rivers discovery images revealing masked edges and layer bleeding on laptop screen photos | | Exhibit Y — "Catch-22" Logic Trap | September 2, 2024 | If manipulated images never existed, how did they appear in earlier filings? If they did, why are they now missing? | | September 25, 2024 Motion for Substitute Counsel (Index 100) | September 25, 2024 | Includes OLPR complaint against Rivers; live screen recordings with touch-trace UI; chain-of-custody compliant | | Index 108 — Order for Rule 20.01 Evaluation (Askalani) | October 15, 2024 | Third Rule 20 exam ordered same day public defender granted; no stated justification | | Index 109 — Order Appointing Forensic Navigator (Askalani) | October 15, 2024 | Companion order to Index 108 | | November 6, 2024 Completion of Stayed Civil Commitment (Index 113) | November 6, 2024 | Guertin completed civil commitment terms; filed into criminal case to prevent HIPAA suppression | | Dr. Cranbrook's Rule 20 Report (Index 116, pp. 16–20) | December 20, 2024 | Third evaluation; Guertin diagnosed without interview; litigation activity cited as symptom | | Index 118 — New Counsel Formal Discovery Demands | ~Early 2025 | Triggered final discovery production on February 13, 2025 | | February 13, 2025 Discovery Set (via new public defenders) | February 13, 2025 | Third discovery set; 518 images; previously missing 28 images reappeared in "edited form" | | Index 122 — Exhibits A–D (Forensic Flipbooks + OneDrive Analysis) | February 28, 2025 | Side-by-side flipbook comparisons; OneDrive metadata anomalies; discovery receipt documentation | | Index 123 — Exhibits F–J (Image Overlays + Shadow/Lighting Analysis) | February 28, 2025 | Shadow analysis, lighting analysis, image overlay comparisons | | Index 124 — Exhibit K (Homography Calculations) | February 28, 2025 | Comparisons of images against known real-world object dimensions | | Index 125 — Exhibits L–Q (Patent Analysis) | February 28, 2025 | InfiniSet vs. Netflix patent analysis; AI stakeholder analysis; academic fraud; confidential filing leak evidence | | Index 127 — April 3, 2025 Competency Order (Koch) | April 3, 2025 | Found Guertin competent but described beliefs as "fantastical and paranoid" | | Index 128 — "Netflix Whistleblower" Exhibit | ~March 2025 | Netflix U.S. Patent 11,810,254 forced to cite Guertin's patent as prior art; corporate ties analysis | | Index 129 — "Brodsky USPTO Patent Fraud" | ~March 2025 | Patent fraud analysis | | Index 130 — "Netflix / USC-ICT / Academic Fraud" | ~March 2025 | Academic and corporate fraud analysis related to InfiniSet technology | | Exhibit AB — Video Recording of Milz Rule 20 Exam | January 3, 2024 (recorded); entered into federal record 2024 | Immutable video evidence of Guertin's behavior during second Rule 20 exam; directly contradicts Milz's written report | | Exhibit P — "Conspiracy of Commitment" Timeline | Filed with federal complaint, July 2024 | Detailed chronological reconstruction of January 15 – February 1, 2024 events | | Exhibit K (Civil Commitment) — Fisher Emails + Civil Case Timeline | January–February 2024 | Emails between Guertin and Joel Fisher; civil case docket showing missing Index #40 | | Minnetonka Police Report #23-000151 | January 12, 2023 | Filed 9 days before arrest; officer spent 45 minutes with Guertin; advised preserving evidence and contacting FBI | | Exhibit S (Index 04, pp. 1–3) — Rivers Discovery Cross-Reference | July 16, 2024 | Image-by-image comparison between Rivers set and Biglow set | | Milz Rule 20 Report (finalized) | January 11, 2024 | Withheld 7+ months; finally provided July 16, 2024 after federal lawsuit filed | | Milz Rule 20 Exam Transcript | January 3, 2024 | 80+ minute transcript; Guertin speaking at normal pace with clear methodical thinking | | Feb 13, 2025 OneDrive Discovery Photo Set (PHOTOS(E86D4D48), 104 files) | Shared Feb 13, 2025; metadata dated Feb 3, 2023 | The second discovery photo production — 20 images show uniform 16:9 ratios where Aug 2023 set had irregular ratios; establishes retroactive manipulation | | 23-0098 Working Copies(79DB9B) / 23-0098 Request 0001 Item 0012 Images | Modified Jan 21, 2023 | TRS/crime scene unit original images on OneDrive; 520+ JPGs with 3:2 ratio; unmanipulated comparison set | | Raissa Carpenter email (Feb 10, 2025) | Feb 10, 2025 | Defense counsel acknowledges Guertin's fraud claims; warns that download/shrinking may distort files; schedules Feb 13 meeting | | JoAnne Van Guilder sharing email (Feb 13, 2025) | Feb 13, 2025 at 3:33 PM | OneDrive folder share establishing digital chain of custody for Feb 2025 discovery set | | Exhibit S, Index 10 (Psychological evaluation report) | Unknown | Contains evaluator quotes characterizing Guertin's fraud claims as delusional; referenced but not included in this filing | | Index 116, Exhibit C (Psychological evaluation report) | Unknown | Contains evaluator statement that Guertin "failed to participate in evaluation" yet concluded his assertions are "delusional belief"; referenced but not included | | Exhibit Y — "The Catch-22: Discovery Fraud" | Unknown | Referenced in Exhibit A (p. 3) and in Feb 20 email as `74__EXHIBIT-Y__The-Catch-22__DISCOVERY-FRAUD.pdf`; not included in this filing | | Guertin Forensic Analysis PDFs (3 parts, hosted on Storj) | Feb 20, 2025 | `00__Discovery-Fraud__Brief-Introduction-of-Facts.pdf`, `01__Discovery-Fraud__Forensic--Analysis-of-5-Images.pdf`, `02__Discovery-Fraud__Forensic--Analysis-of-1-Image.pdf` — Guertin's self-prepared forensic reports shared with defense counsel | | ggilbertson_01212023135833CST_photo_27_950.jpeg | Captured Jan 21, 2023; provided ~Feb 3, 2025 | Second-version discovery image for pair 30-50; horizontally compressed 4.6–8.75% vs. Original | | ggilbertson_01212023135904CST_photo_30_AaB.jpeg | Captured Jan 21, 2023; provided ~Feb 3, 2025 | Second-version discovery image for pair 31-51; horizontally squished per pink circle analysis | | ggilbertson_01212023135930CST_photo_33_Lla.jpeg | Captured Jan 21, 2023; provided ~Feb 3, 2025 | Second-version discovery image for pair 33-53; horizontally compressed 4.6% vs. Original | | ggilbertson_01212023140623CST_photo_53_rc1.jpeg | Captured Jan 21, 2023; provided ~Feb 3, 2025 | Second-version discovery image for pair 41-64; quadrilateral and circular distortion confirmed | | ggilbertson_01212023140649CST_photo_54_TfE.jpeg | Captured Jan 21, 2023; provided ~Feb 3, 2025 | Second-version discovery image for pair 43-66; SSD dimensions do not match caliper measurements | | "FB – Fans" wiring diagram source file (Guertin, 9/23/2021) | Created Sep 23, 2021 | Precision engineering drawing from US Patent 11,577,177 3D design files; used as geometric ground truth in Exhibit G overlay analysis | | Frigidaire FFEF3054T product specification sheet | Version 09/23 | Manufacturer dimensions (30" range, 29.875" panel width, 5.265" panel height) used as ground truth for Exhibit H keypoint analysis | | 23-0098_0012_520-TRS_DSC_0348.JPG | Jan 21, 2023 (original PD evidence) | Unaltered reference discovery photograph showing SSDs from different angle; provided for Exhibit J comparison | | 23-0098_0012_520-TRS_DSC_0350.JPG | Jan 21, 2023 (original PD evidence) | Unaltered reference discovery photograph showing SSDs from different angle; provided for Exhibit J comparison | | 23-0098_0012_520-TRS_DSC_0217.JPG | Jan 21, 2023 (original PD evidence) | Unaltered reference discovery photograph used in Exhibit G for technical drawing overlay demonstration | | U.S. Patent No. D727,456S (Ammunition Magazine design patent) | April 21, 2015 | Design patent for Hexmag HX–AR Series 2 magazine; Figure 3 (left side elevation view) used as the baseline reference for vector tracing analysis in Exhibit K; patent number independently verified on the physical magazine in a separate discovery photo | | Image 48-72 Original (undisclosed filename) | Pre-discovery | The "original" version of Image 48-72 showing the Hexmag magazine on the floor; vector trace matches patent hexagonal grid with no distortion; compared against the discovery version to prove horizontal compression | | ggilbertson_01212023140450CST_photo_50_7rT.jpeg (Image 48-72 discovery version) | 2023-01-21 | Discovery version of Image 48-72; vector tracing reveals non-uniform horizontal compression of hexagonal grid inconsistent with patent specifications | | 23-0098_0012_520-TRS_DSC_0486 | 2023-01-21 (approx.) | Close-up discovery photo of the Hexmag magazine showing "PATENT D 727,456 S" marking; used to independently verify the patent number | | 23000258_ggilbertson_01212023145233CST_photo_64_toF.jpeg (Image 44-68) | 2023-01-21 | Prescription container cupboard photo; Exhibit L shows flash reflection contradicting "Did not fire" metadata + off-center flash position proving cropping | | 23000258_ggilbertson_01212023133542CST_photo_07_O49.jpeg (Garage Photo 01) | 2023-01-21 | Vehicle rear seat interior; rectangular flash artifact visible in grayscale enhancement contradicting metadata | | 23000258_ggilbertson_01212023133550CST_photo_08_e1z.jpeg (Garage Photo 02) | 2023-01-21 | Vehicle front interior; photographer reflection in rear window shows DSLR camera with external flash — not an iPhone 12 | | 23000258_ggilbertson_01212023134408CST_photo_09_DE6.jpeg (Garage Photo 03) | 2023-01-21 | Propane tanks in garage; sharp shadows + light ray analysis prove flash use and cropping from larger original | | ggilbertson_01212023144600CST_photo_60_PBS.jpeg (Router Photo) | 2023-01-21 | TRENDnet router on shelf; hard shadows on wall (absent in wider-angle comparison photo) prove flash use; light ray offset proves cropping | | ggilbertson_01212023155458CST_photo_71_m4H.jpeg | 2023-01-21 | Wide-angle kitchen/apartment photo used as comparison reference for both Image 44-68 (cupboard location) and Router Photo (no shadows on wall under normal lighting) | | 23-0098_0012_520-TRS_DSC_0152.JPG | 2023-01-21 (approx.) | Exterior front door photo with rectangular flash reflection visible in window glass; `DSC_` filename prefix consistent with Nikon DSLR naming convention | | Competency Report - C (referenced, not included) | Pre-Feb 2025 | The competency report this filing objects to; not included in this PDF but the filing is explicitly framed as a supplemental objection to it | | Dr. Cranbrook's Rule 20.01 Evaluation Report | December 20, 2024 | Third competency evaluation; finds "still suffering from mental illness" but does NOT make affirmative incompetency finding; no direct interview conducted; received by stipulation at hearing | | Dr. Martin Schuster letter re: no history of psychosis | Date unknown (referenced as submitted in civil commitment hearing and in pro se filings) | California psychiatrist's letter confirming no history of psychosis, contradicting Rule 20 report claims | | Guertin pro se exhibits filed before March 5, 2025 hearing | ~March 2025 (days before hearing) | "Hundreds of pages" filed directly by Guertin; described by court as "very professional looking" with proper structure/form; not formally offered into evidence; contain forensic photo analysis of OneDrive discovery images | | Vagle v. Minnesota — MN Supreme Court (A23-0863) | Oral argument June 5, 2024; decision pending | Challenges constitutionality of serial-number-less firearm possession charges; outcome could moot 3 of Guertin's 4 counts | | Bruce Rivers July 16, 2024 Discovery Materials (518 images) | Received July 16, 2024 | Second independent discovery image set; contains 518 images (vs. Biglow's 80); multiple images marked MISSING; alleged AI manipulation and icon anomalies | | June 12, 2024 Witness Summary (Dr. Rogstad testimony, prepared by Perez) | June 12, 2024 | Summary of Rogstad's testimony; contains alleged false claim of suicide attempts; antipsychotic medication recommendation; Exh. S, Index 13 | | January 2024 Rule 20.01 Exam Report (Dr. Adam Milz) | January 2024 | Second competency evaluation; diagnoses delusional disorder; references substance history and alleged self-harm history; Exh. S, Index 10 | | Netflix US Patent 11,810,254 (Trojansky) | Granted Nov 7, 2023; Filed Mar 30, 2022 | Filed 12 days after Guertin's patent application; cites Guertin's US 11,577,177 as third-party prior art at top of references | | Police Report #23-000151 (Minnetonka PD, Officer Brandon Harris) | January 12, 2023 | 45-minute session where Harris confirmed Guertin had "proof of the fraud"; filed 9 days before criminal charges | | Email from Amanda Prose (WCK) re: IC3.gov | January 6, 2023 | Patent attorney advises Guertin to file FBI complaint through IC3.gov | | California physician letter (no psychosis history) | Undated (referenced) | Long-time doctor confirms ADHD and GAD only; no psychosis, schizophrenia, or bipolar history; Exh. C, Index 30, pp. 113–114 | | Chronological Continuity of Competence (77-page timeline) | Undated (referenced) | Day-by-day activity log demonstrating ongoing competence during commitment period; Exh. W, Index 07 | | Patent Value Estimation Report | Undated (referenced) | Estimates $150B conservative over 20 years across gaming, film, military, metaverse; Exh. W, Index 02 | | "Overview: USC ICT Graphics Lab" YouTube video | Upload date 8/14/2014; metadata creation 2023:07:18 | Alleged YouTube backdating evidence; two differently aged Paul Debevecs in same outfit | | Guertin discovery fraud video (Proton Drive) | Undated | Video presentation of discovery fraud analysis: https://drive.proton.me/urls/0C6TA1GPJM#QREuUymnMZof | | January 16, 2024 Findings of Fact, Conclusions of Law and Order Regarding Competency | Jan 16, 2024 | Mercurio (8:27 AM) and Klein (9:22 AM) sign competency finding; "parties agreed to a finding of incompetency entered administratively"; Guertin not present | | Text messages: Guertin to Rivers demanding withdrawal (3 sets) | Jan 28, Apr 18, June 6, 2024 | Three documented withdrawal requests; Rivers refuses each time | | Welder documentation (military/CIA background) | Various | Photos with military memorabilia, ODF Optronics equipment, text message exchanges; Exh. W, Index 04; Exh. C, Index 30, pp. 60–62 | | Rivers-Discovery-Missing-Images.pdf | Created ~July 24–25, 2024 | Guertin's 80-row comparison table proving 33 images MISSING from Rivers' set, with 28 aligning to previously identified non-standard aspect ratio images | | image_metadata.xlsx | Created ~July 2024 | Full EXIF metadata for 209+ discovery images showing creation timestamps, focus distances; total count exceeds both Biglow PDF (80) and Rivers set (~47) | | Bruce Rivers July 16, 2024 discovery photographs (individual JPEGs) | Photographs: Jan 21, 2023; Received: Jul 16, 2024 | Second set of discovery photos in original file format with Minnetonka PD filenames (23-0098_0012_520-TRS_DSC_XXXX.JPG); incomplete relative to both Biglow PDF and total image count | | Dr. Adam Milz Rule 20.01 Evaluation Report (complete) | January 11, 2024 (filed 1/11/2024 2:05 PM) | Full 6-page report diagnosing unspecified schizophrenia spectrum disorder; recommends antipsychotics; characterizes discovery fraud claims as delusional; formed without receiving records from Guertin's psychiatrist | | Witness Summary Dr. Jill Rogstad (prepared by Jacqueline Perez) | June 12, 2023 | Prosecutor's notes from witness preparation meeting; reveals Rogstad "was unable to verify the patents" and that verified patents would not change her opinion; lists case number 27-CR-23-2118 | | Stayed Commitment Agreement 8.4.23.pdf + Plan for Services.pdf | August 4–8, 2023 | Settlement documents exchanged between Biglow and Guertin; Guertin's revised versions attached with travel provisions and terminology changes | | Light Stage 6 Video_claimed_as_2006___SCREENCAPS.pdf | Created ~Aug 10, 2023 | Guertin's screencaps from SIGGRAPH 2023 Debevec presentation; used to argue claimed 2006 prior art is fabricated | | SIGGRAPH_2023_Debevec_Screencaps.pdf | Created ~Aug 10, 2023 | Additional screencaps from Paul Debevec's SIGGRAPH presentation on Eyeline Studios | | Vail Place records (Aug 10 – Dec 29, 2023) | Aug 10 – Dec 29, 2023 | Reviewed by Dr. Milz; indicate continued "symptoms of mental illness, including impaired thought processes and delusional thinking" | | 60/90 Day Report | October 30, 2023 | Referenced by Milz; indicated Guertin compliant with outpatient appointments and medications | | Guertin → Prose email re: Animation Timeline (patent technical description) | March 14, 2022 | 8-page detailed technical description of invention's animation timeline, camera path, and cue sequencing systems | | July 16, 2024 Discovery Photographs (second production) | July 16, 2024 | Second set of discovery photos provided by Bruce Rivers to Guertin following court appearance; distinct from Aug 3, 2023 set; subject of AI manipulation allegations in Exhibit T | | Doc. 44, Case 0:24-cv-02646-JRT-DLM (parent federal filing) | August 7, 2024 | Federal civil filing containing Exhibit T and presumably Exhibits from other parts; marks escalation of discovery fraud claims from state to federal court | | Exhibit T Parts 2 and 3 | August 7, 2024 (assumed) | Continuation of forensic analysis begun in Part 1; not yet cataloged; expected to contain additional image sets or deeper analysis | | Doc. 45 (parent filing), Case 0:24-cv-02646-JRT-DLM | August 7, 2024 | Parent federal court filing to which Exhibit U is appended; not in this batch | | Exhibit U Part 1 of 3 (Forensic Analysis) | August 7, 2024 | First segment of three-part forensic analysis; not in this batch | | Exhibit U Part 3 of 3 (Forensic Analysis) | August 7, 2024 | Third segment of three-part forensic analysis; not in this batch | | July 16, 2024 Discovery Materials (full set) | July 16, 2024 | Second discovery production provided by Bruce Rivers after court appearance; distinct from August 3, 2023 discovery PDF; contains at least 220+ numbered photographs | | July 16, 2024 Discovery Materials | July 16, 2024 | Second set of discovery materials provided to Guertin by Bruce Rivers following a 1:30 PM court appearance; contains original JPEG files with full EXIF metadata (distinct from the August 3, 2023 PDF set) | | Exhibit S (Part 1 of 3, Fraudulent Discovery Analysis) | Filed Aug 7, 2024 (Doc. 46) | Referenced but not in this batch — contains manipulated image analysis | | Exhibit T (Part 1–2 of 3, Fraudulent Discovery Analysis) | Filed Aug 7, 2024 (Doc. 46) | Referenced but not in this batch — contains manipulated image analysis | | Exhibit U (Part 2 of 3, Fraudulent Discovery Analysis) | Filed Aug 7, 2024 (Doc. 46) | Referenced but not in this batch — contains manipulated image analysis | | Federal Complaint / Doc. 46 main filing | Filed Aug 7, 2024 | The parent document to which Exhibit V is attached; case 0:24-cv-02646-JRT-DLM | | April 3, 2025 Competency Order (Index 127) | April 3, 2025 | Judge Koch declares Guertin competent after contested hearing; simultaneously credits mental illness diagnosis — creates internal contradiction | | Motion to Dismiss All Charges with Prejudice (Index 131) | April 16, 2025 | 50-page pro se motion; refused by defense counsel; central to pro se petition; consolidates all fraud claims | | Dr. Cranbrook's Rule 20 Report (Index 116) | December 20, 2024 | Third Rule 20 evaluation; diagnosed without interview; based on filings/emails/federal lawsuit | | "Netflix Whistleblower" Evidence Exhibit (Index 128) | Filed pre-March 5, 2025 hearing | First-person narrative with patent records, email evidence, LinkedIn metadata; establishes IP theft claim | | "Brodsky USPTO Patent Fraud" Exhibits (Index 129) | Filed pre-March 5, 2025 hearing | Forensic analysis of U.S. Patent 11,383,062 allegedly retroactively amended to mirror InfiniSet patent | | "Netflix Academic Patent Fraud" Exhibits (Index 130) | Filed pre-March 5, 2025 hearing | Four exhibit sets exposing allegedly fabricated academic papers by Debevec/USC-ICT | | Pro Se Evidence Exhibits (Index 122, 123, 124, 125) | Filed pre-March 5, 2025 hearing | Four forensic exhibit sets including flipbooks, image overlays, shadow analysis, homography, patent comparison | | Klein Recusal Order | July 15 (year unclear, contextually 2024) | Judge Klein recuses herself from 27-CR-23-1886; confirmed via Carpenter email Jan 3, 2025 | | October 15, 2024 Rule 20 Order (Index 108) | October 15, 2024 | Third Rule 20 evaluation ordered same day as public defender appointment by Judge Askalani | | Civil Commitment Completion (Index 113) | November 6, 2024 | Guertin completes stayed order of civil commitment | | Demand for Discovery from New PD (Index 118) | Date unclear (pre-Feb 13, 2025) | New public defenders file formal discovery demand; Guertin receives materials Feb 13, 2025 | | Hao Li Federal Declaration (Rearden LLC v. Disney) | Case docket 6121204 | Lists millions in U.S. govt/military research funding (DARPA, ARO, ONR, IARPA) in technology field relevant to Guertin's patent | | Guertin's "Discovery Fraud Analysis Complete" Email | February 20, 2025 | Sent to Carpenter/Donnelly with PDF flipbooks and forensic overlays; no reply received | | Form 11 — Petition to Proceed as Pro Se Counsel | Standard form | Boilerplate questionnaire provided by court at April 17, 2025 hearing; Guertin declined to complete; files comprehensive petition instead | ## FILING NUMBER CROSSWALK *Reference for mapping old filing numbers to new consolidated numbering.* | New # | Old # | Source File | Filename | |---|---|---|---| | 1 | #1 | base | `MCRO_27-CR-23-1886_Demand_or_Request_for_Discovery_2024` | | 2 | #2 | base | `MCRO_27-CR-23-1886_Motion_2024-04-04_20240430072350.pdf` | | 3 | #3 | base | `MCRO_27-CR-23-1886_Correspondence_2024-05-03_2024050315` | | 4 | #4 | base | `MCRO_27-CR-23-1886_Notice_of_Appeal_2024-05-10_20240516` | | 5 | #8 | base | `MCRO_27-CR-23-1886_Other_Document_2024-05-15_2024051611` | | 6 | #9 | base | `MCRO_27-CR-23-1886_Other_Document_2024-05-15_2024051611` | | 7 | #5 | base | `MCRO_27-CR-23-1886_Correspondence_2024-06-03_2024060413` | | 8 | #6 | base | `MCRO_27-CR-23-1886_Motion_2024-06-03_20240603092053.pdf` | | 9 | #7 | base | `MCRO_27-CR-23-1886_Notice_of_Motion_and_Motion_2024-06-` | | 10 | #10 | base | `00__Guertin-v-Hennepin-County-0_24-cv-02646__2025-02-12` | | 11 | #11 | base | `02__EXHIBIT-R__ORIGINAL-MOTION-FOR-EMERGENCY-TRO__DIGIT` | | 12 | #12 | BATCH_9 | `42__GUERTINS-MOTION-FOR-EXPEDITED-PRELIMINARY-INJUNCTIO` | | 13 | #12 | BATCH_10 | `43__EXHIBIT-S__NEW-EVIDENCE-AND-EMAIL-COMMUNICATIONS.pd` | | 14 | #12 | BATCH_11 | `44__EXHIBIT-T__FRAUDULENT-DISCOVERY-ANALYSIS__1-of-3.pd` | | 15 | #12 | BATCH_12 | `45__EXHIBIT-U__FRAUDULENT-DISCOVERY-ANALYSIS__2-of-3.pd` | | 16 | #12 | BATCH_13 | `46__EXHIBIT-V__FRAUDULENT-DISCOVERY-ANALYSIS__3-of-3.pd` | | 17 | #12 | BATCH_4 | `54__PLAINTIFFS-RESPONSE-TO-DEFENDANTS-MOTIONS-TO-DISMIS` | | 18 | #13 | base | `68__PLAINTIFFS-MEMORANDUM-IN-OPPOSITION-TO-STATE-DEFEND` | | 19 | #14 | base | `73__PLAINTIFFS-MEMORANDUM-IN-OPPOSITION-TO-HENNEPIN-COU` | | 20 | #15 | base | `74__EXHIBIT-Y__GUERTINS-COMPETENCY-AND-DEFENDANTS-INCOM` | | 21 | #12 | BATCH_5 | `122__Exhibit-List_A-E__Discovery-Fraud-Proven__2025-02-` | | 22 | #12 | BATCH_6 | `123__Exhibit-List_F-J____Discovery-Fraud-Proven__2025-0` | | 23 | #12 | BATCH_7 | `124__Exhibit-List_K-L____Discovery-Fraud-Proven__2025-0` | | 24 | #12 | BATCH_8 | `Guertin__Matthew_-_March_5__2024.pdf` | | 25 | #13 | BATCH_4 | `131__Pro-Se-Defendants-Motion-to-Dismiss-w-Prejudice__2` | | 26 | #12 | BATCH_14 | `133__Defendants-Petition-to-Proceed-as-Pro-Se-Counsel__` | | 27 | #16 | base | `134__Transcript_April-17-2025_Hearing__2025-04-23.pdf` | | 28 | #17 | base | `189__Transcript_April-29-2025__2025-05-03.pdf` | --- *End of Master Filing Catalog.*