# MCRO Master Filing Catalog — FINAL UNIFIED ## Case: 27-CR-23-1886 — State of Minnesota v. Matthew David Guertin ### Court: Hennepin County District Court, Fourth Judicial District ### Compiled: 2026-03-06 | Analyst: MCRO Forensic Document Analysis ### Filings Cataloged: #1–#25 (All Batches 1–18 merged) --- ## Filing #1 — Defendant's Motion for Judicial Notice of Indisputable Facts | Field | Detail | |---|---| | Filing # | 1 | | Date Filed | April 3, 2024, 7:56 AM | | Filed By | Matthew David Guertin, Defendant Pro Se | | Document Type | Notice of Motion and Motion for Judicial Notice | | Case/Court | 27-CR-23-1886, Fourth Judicial District Court, Hennepin County, Minnesota | | Pages | 271 | | Bates / Doc ID | E-filed; PDF Producer: PyPDF2; modified using iText 7.1.16 (Minnesota Judicial Branch; licensed version). PDF creation date: 2024-04-03T14:12:23+00:00. Modified: 2024-04-30T07:24:03-05:00. Filename: MCRO_27-CR-23-1886_Notice_of_Motion_and_Motion_2024-04-03_20240430072407.pdf | --- ### Comprehensive Summary This is a 271-page pro se motion filed by Defendant Matthew David Guertin requesting the Court take judicial notice, pursuant to Federal Rule of Evidence 201 (applied via Minnesota Rule of Evidence 9.01), of facts documented across approximately 56 exhibits labeled A through Zb (using a sequential lettering system: A–Z, then Oa/Aa–Za, then Ab–Zb). The motion is addressed to Judge Jay Quam, the Clerk of Court, ACA Jacqueline Perez, and the Office of the Hennepin County Attorney. **Core Thesis of the Motion:** The Defendant seeks to establish, through documentary evidence entered into the court record, that: (1) he is a highly accomplished technical professional with a documented career in visual effects, projection mapping, and engineering spanning from 2014 to present; (2) he is the legitimate inventor and patent holder of US Patent 11,577,177 ("Motorized Rotatable Treadmill and System for Creating the Illusion of Movement"), assigned to his company InfiniSet, Inc.; (3) his patent was filed 12 days before a substantially similar patent application by Stephan Trojansky (filed March 31, 2021), whose company was acquired by Netflix for approximately $125 million; (4) his concerns about corporate patent theft by Netflix, Microsoft, and others are grounded in documented facts, not delusion; (5) the forensic psychological evaluation by Dr. Jill Rogstad that found him incompetent to stand trial was flawed, biased, and potentially compromised by conflicts of interest (specifically the document metadata showing "GuzmanC" — identified as Chela Guzman-Wiegert, Assistant County Administrator — as the author/creator of the report); (6) procedural irregularities in both his criminal and civil cases suggest improper handling; and (7) his competency to manage complex legal and business affairs is demonstrated by his independent management of patent prosecution, trademark filings, business registration, and correspondence with federal agencies. **The Criminal Charges (Context):** On January 21, 2023, Guertin was arrested after firing a gun from his apartment in Minnetonka, MN. He was charged with four felony counts: (I) Reckless Discharge of a Firearm Within a Municipality (Minn. Stat. 609.66.1a(a)(3)); (II-IV) three counts of Receiving/Possessing a Firearm Without a Serial Number (Minn. Stat. 609.667(3)) — for an automatic rifle, a full-size pistol, and a compact pistol. Guertin stated he fired to summon police because he believed his electronic devices were compromised and he feared for his life due to entities targeting his patent. He was yelling "I'm going to die because they stole my patent." Body armor and additional ammunition were found. Bail was set at $50,000 by Judge Edward Thomas Wahl on January 24, 2023. **Competency Proceedings:** Dr. Jill Rogstad conducted a Rule 20.01 evaluation (report dated March 10, 2023), diagnosing Guertin with "Unspecified Schizophrenia Spectrum and Other Psychotic Disorder (primary)" and opining he was incompetent to proceed. Referee George Borer found Guertin incompetent on July 13, 2023, adopted by Judge Michael Browne. A second evaluation by Dr. Adam Milz (referenced in January 2024 order) reached the same conclusion. A civil commitment case (27-MH-PR-23-815) was opened. Dr. Michael Robertson conducted a third examination (report dated August 4, 2023) reaching a similar diagnostic conclusion but suggesting the possibility of substance-induced symptoms from prescribed Adderall and Klonopin, and recommending a trial period without those medications. **The Patent Dispute Narrative:** Guertin filed a provisional patent application on March 19, 2021 (No. 63/163,135). Stephan Trojansky filed a provisional patent on March 31, 2021 (No. 63/168,558) — 12 days later. Guertin's patent (US 11,577,177) was granted February 14, 2023. Guertin filed third-party prior art against Trojansky/Netflix application 17/709,126, which was reviewed and entered into the record by USPTO Examiner Abderrahim Merouan. Netflix's patent US 11,810,254 was published November 7, 2023, and cites Guertin's patent as prior art (cited by third party). The motion argues this USPTO citation validates Guertin's concerns and contradicts the characterization of his beliefs as delusional. **The Rogstad Report Metadata Issue:** Guertin highlights that the PDF metadata of Dr. Rogstad's March 10, 2023 report lists "GuzmanC" as author/creator, and the document title field reads "Conservator (All Powers; Unlimited Duration)" rather than anything related to a forensic evaluation. Guertin identifies GuzmanC as Chela Guzman-Wiegert, the Assistant County Administrator for Law, Safety, and Justice, who sits on the Hennepin County Criminal Justice Coordinating Committee alongside the Chief Judge, Court Administrator, Sheriff, Minneapolis Mayor, and Police Chief. Guertin argues this raises serious conflict-of-interest and integrity concerns about the report's preparation. **Procedural Anomalies Alleged:** The motion documents several procedural irregularities: (a) a missing index #40 in civil case 27-MH-PR-23-815; (b) index #25 (incompetency order filed 1/17/2024) appearing AFTER index #26 (notice of hearing filed 1/16/2024) in the criminal case; (c) the January 17, 2024 incompetency order being signed the morning of January 16, 2024, before the scheduled 1:30 PM hearing — with the parties agreeing to incompetency "administratively" before the hearing; (d) the Notice of Remote Zoom Hearing (Exhibit Mb) lacking the standard timestamp. **The Waiver Under Duress:** On January 31, 2024, facing a February 1 hearing where the court order explicitly contemplated direct commitment "to an appropriate safe and secure facility," Guertin signed a waiver extending his Stayed Order of Commitment for 9 months, waiving rights under Minn. Stat. 253B.05 subd. 3, 08, and .09. **Congressional Outreach:** Guertin contacted Senator Amy Klobuchar's office in September 2023 detailing the alleged patent fraud. He received a response from Hanna Welch (Constituent Advocate) who offered to contact the USPTO on his behalf. Extensive email correspondence is included showing Guertin providing documentation and links to evidence. **Relief Requested:** The Court take judicial notice of facts in Exhibits A through Zb and make them part of the record. --- ### Legal Issues & Arguments Raised - **Judicial Notice (FRE 201 / MRE 9.01):** Request for judicial notice of facts "capable of accurate and ready determination by resort to sources whose accuracy cannot reasonably be questioned." - **Competency Challenge:** Indirect challenge to two separate findings of incompetency by demonstrating Defendant's capacity to manage complex patent prosecution, trademark filings, corporate registration, correspondence with federal agencies, filing of police reports, and preparation of this 271-page motion. - **Conflict of Interest / Forensic Report Integrity:** Metadata of Rogstad report authored by "GuzmanC" (Chela Guzman-Wiegert), a senior county administrator on the CJCC, raises questions about report preparation and impartiality. Document title metadata ("Conservator (All Powers; Unlimited Duration)") inconsistent with a forensic evaluation report. - **Patent Validity / Prior Art:** Guertin's patent predates Trojansky/Netflix by 12 days; USPTO officially accepted Guertin's patent as third-party prior art against Netflix's application. - **Procedural Due Process Concerns:** Out-of-sequence index numbers, pre-signed court orders before hearings, missing index numbers, coerced waiver of rights under threat of involuntary commitment. - **Alleged Corporate Patent Fraud:** Claims of AI-generated fraudulent prior art, manipulation of Internet Archive, coordination between Netflix, Microsoft, Mark Roberts Motion Control, PhotoRobot, Google, and others. - **Alleged Government Surveillance:** LinkedIn profile searches by DARPA, Defense Intelligence Agency, US Army Reserves, US Air Force, INDOPACOM, US State Department, and Paul Debevec (USC/Netflix). - **Google "InfiniSet" Dataset:** Google named its LaMDA pre-training dataset "Infiniset" — same name as Defendant's trademarked company — alleged to be intentional flooding of search results. --- ### Factual Allegations & Key Assertions - Guertin filed provisional patent 63/163,135 on March 19, 2021; Trojansky filed 63/168,558 on March 31, 2021 (12-day gap). - Netflix acquired Trojansky's Scanline VFX for ~$125M (Netflix Q1 2022 shareholders letter). - Guertin's granted patent US 11,577,177 (Feb. 14, 2023) was entered as third-party prior art against Netflix application 17/709,126, signed off by USPTO Examiner Merouan on March 7, 2023. - Netflix patent US 11,810,254 (Nov. 7, 2023) lists "11,577,177 B2 † 2/2023 Guertin" in its references († = cited by third party). - On January 12, 2023, Guertin filed police report #23-000151 with Minnetonka PD detailing suspected patent theft — Officer Brandon Harris spoke with him for 45 minutes and agreed the issue was "beyond the scope of the local police department." - On January 21, 2023, Guertin fired approximately 20 rounds from three unserialized firearms (an automatic rifle, full-size pistol, compact pistol) to "get the police to respond." Body armor recovered from apartment. - Dr. Rogstad's report PDF metadata: Author = "GuzmanC"; Title = "Conservator (All Powers; Unlimited Duration)"; Creator = "GuzmanC"; Producer = "Acrobat Distiller 22.0 (Windows)" (notably missing the iText/e-file metadata). - July 13, 2023 incompetency order PDF metadata: Author = "Danielle C. Mercurio"; Title = "Conservator (All Powers; Unlimited Duration)"; signed by Referee George Borer, adopted by Judge Michael Browne. - Guertin registered InfiniSet, Inc. with Delaware SOS (July 18, 2022) and MN SOS as foreign corporation (Nov. 13, 2022). - Guertin filed INFINISET trademark (USPTO Serial #90618638, filed April 1, 2021) and international trademark via WIPO (Registration #1,739,675, June 1, 2023) in multiple countries, paying $4,320.33. - Guertin filed reports with: FBI (IC3.gov), FTC (Report #159606444), Plymouth PD (Report #23033797), and SFO (UK). - Guertin contacted Senator Amy Klobuchar's office; received substantive response from Hanna Welch offering to contact USPTO. - Guertin personally filed USPTO petition for extension of time (37 CFR 1.136(a)), confirmed delivered March 5, 2024, $128 payment cashed March 7, 2024. - Dr. Rogstad noted in her report that Guertin's patent attorney could not be reached to verify claims. Defense counsel Bruce Rivers was also unreachable. - Dr. Michael Robertson's civil commitment examiner's report (Aug. 4, 2023) noted: "beyond his hypomanic to manic presentation, there was no evidence of overt symptoms of psychosis or delusions, unless his various descriptions of his hugely successful and sought after patent, turns out to be a delusion itself, but there was no current evidence provided which would suggest any of Mr. Guertin's claims of his engineering prowess and development are false." - Guertin's patent attorney withdrew from continuation application US 18/108,858 on August 21, 2023. - January 16, 2024 incompetency order was signed by Referee Mercurio at 8:27 AM and Judge Dayton Klein at 9:22 AM — before the scheduled 1:30 PM hearing. - Google's LaMDA paper (arXiv:2201.08239, published Jan 20-Feb 10, 2022) names its pre-training dataset "Infiniset." --- ### Procedural Posture This motion is filed during a period of suspended criminal proceedings due to two findings of incompetency (July 13, 2023 and January 16, 2024). A civil commitment case (27-MH-PR-23-815) runs parallel. Guertin signed a waiver on January 31, 2024, extending his stayed commitment for 9 months. A review hearing is scheduled for July 16, 2024 (via Zoom). The criminal case status is "Dormant" per MNCIS. Guertin is proceeding pro se on this motion, though Bruce Rivers remains listed as lead attorney in the criminal case. The motion appears designed to build a comprehensive factual record to support a future competency restoration argument or to lay groundwork for appellate review. --- ### Exhibit / Attachment Inventory The following exhibits are described in the motion text (pp. 1–21) and supported by documentary evidence in the remaining pages (pp. 22–271): | Exhibit | Date | Description | |---|---|---| | A | 4/2/2014 | Derivative.ca blog article recognizing Guertin's TouchDesigner 3D project | | B | 6/28/2016 | Related to alleged patent fraud — intentionally concise | | C | 6/28/2016 | Hollywood Reporter article re: Digital Domain MOVA tech ban; quotes on VFX tech/DOD interest | | D | 7/17/2017 | Rearden LLC v. Walt Disney Company complaint (MOVA tech patent/copyright infringement) | | E | 9/30/2018 | Hollywood Bowl LA Phil 100th Anniversary — Guertin credited as "chief technical artist" by XiteLabs | | F | 9/30/2018 | MattGuertin.com portfolio — Hollywood Bowl show | | G | April 2019 | Bad Bunny Coachella set piece — Guertin credited for "LED Eye Design, Fabrication & Implementation" by XiteLabs | | H | April 2019 | MattGuertin.com portfolio — Bad Bunny Eye | | I | April 2019 | PLSN magazine credits Guertin for Coachella set piece design/fabrication | | J | April 2019 | MattGuertin.com portfolio — Bad Bunny 360 Pre-Vis system | | K | Aug-Nov 2019 | 50-foot Falcon structure — Guertin credited as "Falcon Design, Fabrication Direction and Engineering" | | L | Aug-Nov 2019 | MattGuertin.com portfolio — Falcon | | M | Aug-Nov 2019 | Video conference/workshop on 50-foot Falcon creation (BlackTrax showcase) | | N | Nov 2020 | Guertin's Vimeo page setup (Vimeo.com/MattGuertin) | | O | Nov 2020 | MattGuertin.com personal portfolio website development | | P | 2/13/2021 | Domain registration: infiniset.com (GoDaddy WHOIS record, creation date 2/13/2021) | | Q | 2/13/2021 | InfiniSet.com static page with logo | | R | 3/19/2021 | First provisional patent application (No. 63/163,135) filed with USPTO | | S | 3/31/2021 | Trojansky provisional patent (No. 63/168,558) filed — 12 days after Guertin | | T | 4/1/2021 | INFINISET trademark application (USPTO Serial #90618638) | | U | 6/30/2021 | Eyeline Studios registered as foreign corp with CA SOS, signed by "Scott Miller" | | V | 6/30/2021 | Eyeline Studios contact page showing Trojansky as President, Scott Miller as COO | | W | 11/22/2022 | Netflix press release re: Scanline VFX/Eyeline Studios acquisition | | X | 1/20/2022 | Google LaMDA paper v1 (arXiv:2201.08239v1) — dataset named "Infiniset" | | Y | 1/21/2022 | Google LaMDA paper v2 — same "Infiniset" dataset name | | Z | 2/10/2022 | Google LaMDA paper v3 — same "Infiniset" dataset name | | Oa | 3/18/2022 | Guertin US Patent application 17/698,420 filed | | Aa | 3/30/2022 | Trojansky/Netflix US Patent application 17/709,126 filed | | Ba | 3/31/2022 | Trojansky/Netflix PCT application US2022/022914 filed | | Ca | 4/19/2022 | Netflix Q1 2022 shareholders letter — $125M for Scanline + gaming company | | Da | 6/8/2022 | Yuval Brodsky US Patent application 17/843,960 filed | | Ea | 6/24/2022 | PCT examiner's report for Guertin — references Brodsky as prior art; all dates identical (6/24) | | Fa | 7/12/2022 | Yuval Brodsky US Patent 11,383,062 published | | Ga | 7/18/2022 | InfiniSet Inc. registered with Delaware SOS (File #6917475); notarized 2/2/2024 | | Ha | 9/22/2022 | Guertin PCT WO 2022/198028 published | | Ia | 9/22/2022 | Brodsky application 17/843,960 published | | Oa(2) | 9/22/2022 | Guertin US application 17/698,420 published (note: duplicate exhibit label "Oa") | | Ja | 11/13/2022 | InfiniSet Inc. registered with MN SOS as foreign corporation | | Ka | 12/15/2022 | Netflix patent assignment — Eyeline Studios GmbH to Netflix, Inc., signed by Trojansky | | La | 1/12/2023 | Minnetonka PD Police Report #23-000151 — patent theft complaint (Officer Brandon Harris) | | Ma | 1/21/2023 | Arrest incident — criminal charges filed; criminal complaint included (pp. 81–87) | | Na | 2/13/2023 | Continuation patent application US 18/108,858 filed | | Oa(3) | 2/14/2023 | US Patent 11,577,177 officially published/granted | | Pa | 2/17/2023 | Third-party prior art submission against Netflix app. 17/709,126 | | Qa | 3/1/2023 | Patent assignment — Trojansky/Eyeline to Netflix, signed by Greg Lunt (Greenberg Traurig) | | Ra | 3/7/2023 | USPTO Examiner Merouan signs off on Guertin's third-party prior art | | Sa | 3/10/2023 | Dr. Jill Rogstad's forensic evaluation report — metadata analysis + full report (pp. 100–125) | | Ta | 3/16/2023 | IDS filed for continuation patent referencing Microsoft and Dimension Studios | | Ua | 3/26/2023 | Notice of Good Standing — InfiniSet Inc. from Delaware SOS | | Va | 3/27/2023 | USPS certified mail evidence — communications with Netflix, Eyeline, Scanline, others (pp. 151–158) | | Wa | 3/27/2023 | Assignment document — Trojansky/Eyeline to Netflix, signed by Lunt | | Xa | 5/3/2023 | FBI IC3 report filed re: PhotoRobot fraud (full text included, pp. 161–165) | | Ya | 5/3/2023 | FTC Report #159606444 filed re: PhotoRobot/Mark Roberts Motion Control (pp. 166–167) | | Za | 6/1/2023 | International trademark application #97699805 for INFINISET ($4,320.33) | | Ab | 6/1/2023 | WIPO international trademark registration #1,739,675 | | Bb | 7/13/2023 | Incompetency order — metadata shows author "Danielle C. Mercurio", title "Conservator (All Powers; Unlimited Duration)" (pp. 173–181) | | Cb | 8/4/2023 | Dr. Michael Robertson examiner's report for civil commitment (pp. 182–186) | | Db | 8/21/2023 | Patent attorney withdrawal from continuation app US 18/108,858 | | Eb | 9/7/2023 | Plymouth PD Police Report #23033797 — informational report re: patent fraud (pp. 189–190) | | Fb | 9/20/2023 | Email to/from Senator Amy Klobuchar's office (pp. 191–214) | | Gb | 10/3/2023 | Response from Hanna Welch (Klobuchar office) with Privacy Act Release Form | | Hb | 10/12/2023 | Certified mail to Klobuchar office (USPS tracking #70223330000065385050) | | Ib | Undated | Referee Danielle C. Mercurio's MN Judicial Branch biography — US Army JAG background | | Jb | 11/7/2023 | Netflix patent US 11,810,254 published — cites Guertin 11,577,177 as prior art | | Kb | 12/5/2023 | Non-Final Office Action for continuation app US 18/108,858 | | Lb | 1/5/2024 | Guertin's discovery motion requesting 104 police photographs (p. 232) | | Mb | 1/16/2024 | Notice of Remote Zoom Hearing — allegedly missing timestamp (pp. 233–234) | | Nb | 1/16/2024 | Missing index #40 in civil case 27-MH-PR-23-815 (p. 235) | | Ob | 1/16/2024 | Out-of-sequence indices #25/#26 in criminal case (p. 236) | | Pb | 1/17/2024 | January 2024 incompetency order — signed morning of 1/16 before 1:30 PM hearing (pp. 237–240) | | Qb | 1/30/2024 | Motion for Continuance in civil case (pp. 241–250) | | Rb | 1/30/2024 | Motion for Production of Medical Records (Dr. Milz report) (pp. 251–252) | | Sb | 1/31/2024 | Waiver of commitment hearing rights — extending stayed commitment 9 months (p. 253) | | Tb | 2/20/2024 | MN SOS verification — InfiniSet Inc. active/good standing, Guertin listed as CEO (p. 254) | | Ub | 3/4/2024 | USPTO Petition for Extension of Time — delivered 3/5/2024, $128 cashed 3/7/2024 (pp. 255–261) | | Vb | Undated | CJCC committee member roster including Guzman-Wiegert (p. 262) | | Wb | Undated | Hennepin County website — Guzman-Wiegert role description (p. 263) | | Xb | 11/8/2023 | Robins Kaplan article on Generative AI, LLMs, and Fair Use After Warhol (p. 264) | | Yb | 11/15/2023 | FCC Notice of Inquiry FCC 23-101 on AI voice cloning (pp. 265–269) | | Zb | January 2024 | Robins Kaplan Business Litigation Quarterly — Bryan Mechell article on generative AI and copyright (p. 271) | --- ### Visual Evidence Inventory - **[Pages 1–21] Court filing stamps:** Each page bears the electronic filing stamp "27-CR-23-1886 / Filed in District Court / State of Minnesota / 4/3/2024 7:56 AM" in the upper right corner. Consistent across all 271 pages. Small RGB images (401×463px, 72 DPI) with alpha masks — these are the standard MN e-filing watermark stamps. - **[Page 22] Derivative.ca blog screenshot:** Shows a 3D-generated image from Kinect tracking project. URL and technical description visible. JPEG image (2301×1302px, 300 DPI). No anomalies detected. - **[Page 23] Hollywood Reporter article screenshot:** Digital Domain MOVA Tech article by Scott Johnson, dated June 28, 2016. Header image shows motion capture scene. Photo credited to Twentieth Century Fox. - **[Page 24] Hollywood Reporter quotes page:** Appears to be a Defendant-prepared summary page with direct quotes from the article. Typed document, not a direct screenshot. - **[Page 25] Court complaint cover page:** Rearden LLC v. Walt Disney Company (Case 3:17-cv-04006), filed 7/17/17, Northern District of California. Appears to be first page of complaint downloaded from hbsscreative.com. - **[Pages 26, 28, 30, 32, 34] XiteLabs.com portfolio pages:** Screenshots of production credits for Hollywood Bowl, Bad Bunny, and Falcon projects. Guertin's name prominently credited. - **[Pages 27, 29, 31, 33, 35, 36] MattGuertin.com portfolio screenshots:** Personal portfolio pages showing project imagery. Low detail in text extraction; appear to be full-page screenshots. - **[Page 37] GoDaddy WHOIS results:** Screenshot of WHOIS lookup for infiniset.com, showing creation date 2/13/2021, registrar GoDaddy. - **[Page 38] InfiniSet.com under construction page:** Shows InfiniSet logo with "© 2024 · InfiniSet, Inc." - **[Pages 39–41] USPTO documents:** Trojansky patent application publication, Guertin trademark application. - **[Page 42–43] Eyeline Studios contact page:** Screenshot showing Trojansky as President, Perry Kain as Executive Producer, Scott Miller as COO. - **[Page 44] Netflix press release:** Web archive screenshot of November 22, 2021 announcement. - **[Pages 45–48] Google LaMDA papers:** Three versions of arXiv:2201.08239 showing "Infiniset" dataset name in Section E, with tables of model hyperparameters and pre-training data composition. - **[Pages 49–50] Patent application publications:** Trojansky application and PCT filing, with technical drawings visible. - **[Page 51] Netflix Q1 2022 shareholders letter:** Page 5 showing $125M acquisition cost for Scanline + Boss Fight Entertainment. - **[Pages 52–80] Various patent documents, USPTO records:** Multiple pages of patent drawings, specifications, prior art references. Many pages extracted as image-only (scanned/screenshot content). - **[Pages 81–87] Criminal complaint:** Full complaint filed 1/24/2023, including Statement of Probable Cause, Order of Detention ($50,000 bail), Defendant Fact Sheet, and Statute Grid. Multiple court filing stamps visible (1/24/2023). - **[Pages 88–89] Guertin patent pages:** US 2023/0182034 A1 (continuation) and US 11,577,177 B2 (granted patent) — showing Guertin as inventor, InfiniSet Inc. as assignee. - **[Pages 100–101] Rogstad report metadata analysis:** Defendant-prepared pages showing report excerpt alongside extracted metadata fields (Author: GuzmanC; Title: Guertin Report.pdf; Creator: GuzmanC; Producer: Acrobat Distiller 22.0 (Windows)). Also shows CJCC member list and Guzman-Wiegert role description. - **[Pages 102–128] Email correspondence:** Series of email printouts between Guertin and various parties (Bruce Rivers, Jill Rogstad, patent attorney), including email header data. Appear to be direct exports from ProtonMail. - **[Pages 130–150] Patent and corporate documents:** Patent drawings, Delaware SOS registration, certified mail receipts, USPS tracking records. - **[Pages 151–158] USPS Tracking pages:** Screenshots of 20+ USPS certified mail tracking numbers showing deliveries to Netflix executives (Ted Sarandos, Greg Peters, Spencer Wang, David Hyman, Amy Reinhard), Eyeline Studios (Trojansky, Scott Miller), Scanline VFX, Fenwick & West LLP (Robert Hulse). All delivered March-April 2023. - **[Pages 161–167] FBI IC3 and FTC reports:** Full text of reports filed against Mark Roberts Motion Control/PhotoRobot. - **[Pages 168–172] Trademark documents:** USPTO application #97699805, WIPO certificate #1,739,675. - **[Pages 173–181] Incompetency order with metadata analysis:** Full order text plus Defendant's metadata analysis showing "Danielle C. Mercurio" as author and "Conservator (All Powers; Unlimited Duration)" as document title. - **[Pages 182–186] Robertson examiner's report:** Full 5-page report for civil commitment case 27-MH-PR-23-815. - **[Pages 189–190] Plymouth PD report:** ICR# 23033797, Officer Beauchane #147. - **[Pages 191–214] Klobuchar correspondence:** Extensive email chain including full letter to Senator Klobuchar, response from Hanna Welch, Privacy Act Release Form, follow-up emails with links and documentation. - **[Pages 219–222] USPS tracking for Klobuchar mailing:** Tracking #70223330000065385050, delivered 10/13/2023 at 1:24 PM to Minneapolis, MN 55415 (Klobuchar's office). - **[Page 223] Referee Mercurio biography:** MN Judicial Branch website screenshot showing military (US Army-National Guard JAG) background, Army Commendation Medal, Meritorious Service Medal. - **[Page 224] Netflix patent US 11,810,254:** Front page showing "11,577,177 B2 † 2/2023 Guertin" in References Cited (†= cited by third party). Primary Examiner: Abderrahim Merouan. Attorney: Greenberg Traurig, LLP. - **[Pages 232–240] Criminal case documents:** Discovery motion, Notice of Hearing, MNCIS Register of Actions screenshots, January 2024 incompetency order. - **[Pages 241–252] Civil case motions:** Motion for Continuance, attached emails with Joel Fisher, Motion for Production of Medical Records. - **[Page 253] Waiver form:** Blank waiver form for extending stayed commitment 9 months. - **[Page 254] MN SOS business record:** Screenshot from MN Secretary of State showing InfiniSet Inc. "Active / In Good Standing," filed 11/13/2022, Matthew Guertin listed as CEO. - **[Pages 255–261] USPTO petition:** USPS tracking for petition delivery to USPTO Alexandria, VA. Signed for by "E BARFIELD" on March 5, 2024. - **[Pages 262–263] CJCC and County Administrator pages:** Website screenshots showing committee members and Guzman-Wiegert's role. - **[Pages 264–271] AI/Copyright articles and FCC documents:** Robins Kaplan articles, FCC Notice of Inquiry FCC 23-101 on voice cloning/AI. --- ### Key People Referenced | Name | Role/Affiliation | Context | |---|---|---| | Matthew David Guertin | Defendant, Pro Se; CEO/Inventor, InfiniSet, Inc. | Subject of criminal and civil proceedings; patent holder US 11,577,177 | | Jay Quam | Judicial Officer, 4th Judicial District | Assigned judge on criminal case | | Jacqueline Perez | Asst. Hennepin County Attorney | Lead prosecutor | | Bruce Rivers | Defense Attorney | Lead attorney for Defendant in criminal case | | Jill E. Rogstad, Ph.D., LP, ABPP | Senior Clinical Forensic Psychologist, 4th Judicial District | Conducted Rule 20.01 evaluation (March 2023); diagnosed incompetency | | Casey Boland, Ph.D. | Forensic psychology postdoctoral fellow | Conducted bulk of Rogstad interview under supervision | | Adam A. Milz, Ph.D., LP, ABPP | Psychologist, Hennepin County Psychological Services | Conducted second competency evaluation (Jan. 2024) | | Michael Robertson, Psy.D., LP | Independent examiner | Conducted civil commitment examination (Aug. 2023) | | George Borer | Referee of District Court | Signed first incompetency order (July 13, 2023) | | Michael Browne | Judge of District Court | Adopted first incompetency order | | Danielle C. Mercurio | Referee of District Court | Signed second incompetency order (Jan. 16, 2024); identified as author in metadata; former US Army JAG | | Julia Dayton Klein | Judge of District Court | Ordered second Rule 20 evaluation (Nov. 2023); adopted Jan. 2024 order | | Lyonel Norris | Referee of District Court | Found probable cause (Jan. 25, 2023) | | Toddrick Barnette | Judge of District Court | Co-ordered Rule 20 evaluation | | Chela Guzman-Wiegert ("GuzmanC") | Asst. County Administrator, Law/Safety/Justice; CJCC member | Identified via PDF metadata as author/creator of Rogstad's forensic report | | Stephan Trojansky | Inventor; CEO, Scanline VFX / Eyeline Studios | Filed competing patent application 12 days after Guertin | | Scott Miller | COO, Eyeline Studios | Signed CA SOS filing | | Greg Lunt | Attorney, Greenberg Traurig LLP | Signed patent assignment from Eyeline to Netflix | | Assaff Rawner | CEO, Mark Roberts Motion Control | Directed Guertin to PhotoRobot; subject of FBI/FTC reports | | Paul Debevec | Professor, USC; associated with Netflix/Eyeline Studios | Alleged involvement in fraudulent prior art | | Yuval Brodsky | Patent applicant (17/843,960 / US 11,383,062) | Referenced as prior art to Guertin's PCT application | | Amy Klobuchar | US Senator (Minnesota) | Contacted by Guertin regarding patent fraud; office responded | | Hanna Welch | Constituent Advocate, Office of Sen. Klobuchar | Handled Guertin's correspondence | | Joel Fisher | Court-appointed civil commitment attorney | Assigned in case 27-MH-PR-23-815 | | Michael Biglow | Previous civil commitment attorney | Inactive per MNCIS | | Melanie Anne Engh-Liska | Previous civil commitment attorney | Inactive per MNCIS | | Lea De Souza | Asst. Hennepin County Attorney | Lead attorney for petitioner in civil commitment | | Tom Arneson | Asst. Hennepin County Attorney | Appeared at Jan. 2024 criminal hearing | | Tom Prochazka | Asst. Hennepin County Attorney | Contacted by Rogstad as collateral | | Erin Goltz | Prosecuting attorney | Approved original criminal complaint | | Edward Thomas Wahl | District Court Judge | Set bail / issued Order of Detention | | Brandon Harris | Officer, Minnetonka PD | Took police report #23-000151 (Jan. 12, 2023) | | Krystal Beauchane | Officer, Plymouth PD | Took police report #23033797 (Sept. 7, 2023) | | Abderrahim Merouan | USPTO Patent Examiner | Signed off on Guertin's third-party prior art submission; listed as Primary Examiner on Netflix patent | | Amanda M. Prose | Patent attorney, Westman Champlin & Koehler | Guertin's patent attorney (firm withdrew Aug. 2023) | | Dr. Schuster | California psychiatrist | Guertin's prescribing physician (Adderall/Klonopin); wrote letter supporting Guertin | | Keith Moore, RN | Hennepin County | Authored Pre-Petition Screening Report (7/17/2023) | | Sara Gonsalves | Hennepin County Court Administrator | CJCC member | | Kerry Meyer | Chief Judge, 4th Judicial District | CJCC member | | Hilary Caligiuri | Presiding Judge, Criminal Court | CJCC member | | Jacob Frey | Mayor of Minneapolis | CJCC member | | Brian O'Hara | Chief of Police, Minneapolis PD | CJCC member | | Dawanna Witt | Sheriff, Hennepin County | CJCC member | --- ### Key Entities / Organizations Referenced - InfiniSet, Inc. (Delaware C-Corp; MN foreign corp) — Guertin's company - Netflix, Inc. - Eyeline Studios GmbH / Eyeline Studios - Scanline VFX - Microsoft Corporation - Google (LaMDA / "Infiniset" dataset) - Mark Roberts Motion Control (MrMoCo.com) - PhotoRobot (alleged AI-generated company/website) - Dimension Studios - Hennepin County District Court — Fourth Judicial District - Hennepin County Psychological Services - Hennepin County Criminal Justice Coordinating Committee (CJCC) - Hennepin County Attorney's Office - USPTO (U.S. Patent and Trademark Office) - WIPO (World Intellectual Property Organization) - Westman, Champlin & Koehler, P.A. (patent attorneys) - Greenberg Traurig, LLP (Netflix patent attorneys) - Fenwick & West LLP (Trojansky patent attorneys) - Robins Kaplan LLP (Minneapolis law firm — articles cited) - FBI / IC3 - FTC - FCC - US Senate (Klobuchar office) - Plymouth Police Department - Minnetonka Police Department - Delaware Secretary of State - Minnesota Secretary of State - California Secretary of State - Internet Archive / Wayback Machine - DARPA, Defense Intelligence Agency, US Army Reserves, US Air Force, INDOPACOM, US State Department (LinkedIn searches alleged) - Derivative (TouchDesigner software) - XiteLabs (Los Angeles production company) - PLSN (Projection, Lights, and Staging News) - Hennepin County Medical Center (HCMC) - LA Philharmonic Orchestra - Coachella Music Festival - BlackTrax / Cast Software - Serious Fraud Office (SFO), UK - USC Cinema (Paul Debevec affiliation) --- ### Dates & Deadlines Mentioned | Date | Event | |---|---| | 4/2/2014 | Derivative.ca article on Guertin (Exhibit A) | | 6/28/2016 | Digital Domain MOVA tech articles (Exhibits B, C) | | 7/17/2017 | Rearden v. Disney complaint (Exhibit D) | | 9/30/2018 | LA Phil 100th Anniversary / Hollywood Bowl show (Exhibits E, F) | | April 2019 | Bad Bunny Coachella (Exhibits G-J) | | Aug-Nov 2019 | 50-foot Falcon project (Exhibits K-M) | | Nov 2020 | Vimeo page setup; portfolio development (Exhibits N, O) | | 2/13/2021 | infiniset.com domain registered (Exhibit P) | | 3/19/2021 | Guertin provisional patent 63/163,135 filed (Exhibit R) | | 3/31/2021 | Trojansky provisional patent 63/168,558 filed (Exhibit S) | | 4/1/2021 | INFINISET trademark application filed (Exhibit T) | | 6/30/2021 | Eyeline Studios registered in CA (Exhibits U, V) | | 1/20/2022–2/10/2022 | Google LaMDA papers v1-v3 with "Infiniset" dataset (Exhibits X-Z) | | 3/18/2022 | Guertin patent app 17/698,420 filed (Exhibit Oa) | | 3/30/2022 | Trojansky/Netflix app 17/709,126 filed (Exhibit Aa) | | 4/19/2022 | Netflix Q1 2022 shareholders letter (Exhibit Ca) | | 6/8/2022 | Brodsky patent application filed (Exhibit Da) | | 6/24/2022 | PCT examiner report for Guertin (Exhibit Ea) | | 7/18/2022 | InfiniSet Inc. registered with DE SOS (Exhibit Ga) | | 9/22/2022 | Multiple publications: Guertin PCT, Brodsky, Guertin US app (Exhibits Ha, Ia, Oa(2)) | | 11/13/2022 | InfiniSet Inc. registered with MN SOS (Exhibit Ja) | | 11/22/2022 | Netflix Scanline VFX acquisition press release (Exhibit W) | | 12/15/2022 | Netflix patent assignment from Eyeline (Exhibit Ka) | | 1/12/2023 | Minnetonka PD police report #23-000151 (Exhibit La) | | 1/21/2023 | Arrest / incident date | | 1/24/2023 | Criminal complaint filed | | 1/25/2023 | Probable cause found; Rule 20 evaluation ordered | | 2/13/2023 | Continuation patent app 18/108,858 filed (Exhibit Na); email to Rogstad | | 2/14/2023 | US Patent 11,577,177 granted (Exhibit Oa(3)) | | 2/17/2023 | Third-party prior art submitted against Netflix (Exhibit Pa) | | 3/1/2023 | Rogstad interview conducted | | 3/7/2023 | USPTO Examiner Merouan approves prior art submission (Exhibit Ra) | | 3/10/2023 | Rogstad report filed (Exhibit Sa) | | 3/16/2023 | IDS filed for continuation patent (Exhibit Ta) | | 3/26/2023 | Delaware Notice of Good Standing (Exhibit Ua) | | 3/27/2023 | Certified mail to Netflix et al. (Exhibit Va) | | 5/3/2023 | FBI IC3 and FTC reports filed (Exhibits Xa, Ya) | | 6/1/2023 | International trademark filings (Exhibits Za, Ab) | | 7/7/2023 | Competency hearing | | 7/13/2023 | First incompetency order (Exhibit Bb) | | 7/20/2023 | Civil commitment case 27-MH-PR-23-815 filed | | 8/1/2023 | Robertson examination | | 8/4/2023 | Robertson report (Exhibit Cb) | | 8/21/2023 | Patent attorney withdrawal (Exhibit Db) | | 9/7/2023 | Plymouth PD report #23033797 (Exhibit Eb) | | 9/20/2023 | Email to Klobuchar office (Exhibit Fb) | | 10/3/2023 | Hanna Welch response (Exhibit Gb) | | 10/12/2023 | Certified mail to Klobuchar (Exhibit Hb) | | 11/7/2023 | Netflix patent US 11,810,254 published (Exhibit Jb) | | 11/8/2023 | Robins Kaplan AI article (Exhibit Xb) | | 11/15/2023 | FCC NOI on AI voice cloning (Exhibit Yb); Rule 20 re-evaluation ordered | | 12/5/2023 | Non-Final Office Action for continuation (Exhibit Kb) | | 1/5/2024 | Discovery motion for police photos (Exhibit Lb) | | 1/16/2024 | Second incompetency order signed (AM); hearing scheduled (PM) (Exhibits Mb-Pb) | | 1/17/2024 | Second incompetency order filed | | 1/30/2024 | Motion for Continuance; Motion for Medical Records (Exhibits Qb, Rb) | | 1/31/2024 | Waiver signed (Exhibit Sb) | | 2/1/2024 | Civil commitment hearing (waived) | | 2/20/2024 | MN SOS verification of InfiniSet Inc. (Exhibit Tb) | | 3/4/2024 | USPTO petition mailed (Exhibit Ub) | | 3/5/2024 | USPTO petition delivered | | 4/3/2024 | **THIS MOTION FILED** | | 7/16/2024 | Scheduled criminal review hearing (Zoom) | --- ### Forensic Flags & Anomalies 1. **Rogstad Report Metadata Anomaly (CRITICAL):** PDF author field = "GuzmanC"; document title = "Conservator (All Powers; Unlimited Duration)." The creator is identified as Chela Guzman-Wiegert, Assistant County Administrator for Law, Safety, and Justice, who sits on the CJCC. The document title suggests the template used was for a conservatorship proceeding, not a forensic evaluation. The Producer field shows "Acrobat Distiller 22.0 (Windows)" WITHOUT the iText modification stamp typical of Minnesota Judicial Branch e-filed documents — raising questions about the filing chain. 2. **Incompetency Order Metadata (CRITICAL):** The July 13, 2023 incompetency order's metadata also shows Author = "Danielle C. Mercurio" and Title = "Conservator (All Powers; Unlimited Duration)" — the same anomalous template title. This suggests systemic use of an inappropriate document template or a deeper connection between the two documents. 3. **Pre-Signed Order (SIGNIFICANT):** The January 16, 2024 incompetency order was signed by Referee Mercurio at 8:27 AM and Judge Dayton Klein at 9:22 AM — hours before the 1:30 PM hearing. Incompetency was agreed upon "administratively" before the hearing occurred. 4. **Index Number Inversion:** Criminal case index #25 (filed 1/17/2024) appears AFTER index #26 (filed 1/16/2024), disrupting chronological sequence. 5. **Missing Index Number:** Civil case 27-MH-PR-23-815 is missing index #40. 6. **Notice of Hearing Missing Timestamp:** Exhibit Mb allegedly lacks the standard e-filing timestamp. 7. **Rogstad Could Not Verify Patent Claims:** Rogstad acknowledged in her report that she lacked technological expertise, attempted to contact Guertin's patent attorney without success, and was unable to verify the factual basis of his patent claims — yet still characterized his beliefs as delusional. 8. **Robertson Report Ambiguity:** Dr. Robertson's examiner report notably states there was "no evidence of overt symptoms of psychosis or delusions, unless his various descriptions of his hugely successful and sought after patent, turns out to be a delusion itself, but there was no current evidence provided which would suggest any of Mr. Guertin's claims of his engineering prowess and development are false." 9. **Referee Mercurio Military Background:** Mercurio's biography shows extensive US Army-National Guard JAG service — flagged by Defendant in context of alleged military interest in his patent technology. 10. **Google "Infiniset" Dataset Naming:** Google's LaMDA paper (multiple versions Jan-Feb 2022) names its pre-training dataset "Infiniset" — identical to Guertin's trademarked company name. Guertin's trademark application was filed April 1, 2021. The LaMDA paper was first published January 20, 2022. 11. **Duplicate Exhibit Labels:** The label "Oa" is used three times (for different documents dated 3/18/2022, 9/22/2022, and 2/14/2023), creating potential confusion in the record. 12. **Pro Se Filing Competency Paradox:** The Defendant, found incompetent to stand trial on two occasions, independently prepared and filed this 271-page motion with organized exhibits, legal citations, metadata analysis, and procedural arguments. 13. **PDF Metadata Chain:** The filing PDF's Producer field shows "PyPDF2; modified using iText® 7.1.16 ©2000-2021 iText Group NV (Minnesota Judicial Branch; licensed version)" — the PyPDF2 component indicates the document was assembled programmatically before being processed through the court's e-filing system. 14. **Bruce Rivers Communication Issues:** Guertin's emails show difficulty obtaining his own evaluation reports from defense counsel; Joel Fisher had an incorrect phone number. 15. **Coerced Waiver Allegation:** Guertin asserts the January 31, 2024 waiver extending his commitment stay was signed under duress — the alternative being potential detention and direct commitment to a secure facility per the court order. --- ### Cross-References This is the first filing cataloged. No prior batch cross-references exist. Internal cross-references within this filing: - The criminal complaint (included as part of Exhibit Ma, pp. 81–87) is the foundational charging document. - Dr. Rogstad's report (Exhibit Sa, pp. 116–125) is the primary clinical document challenged. - The Minnetonka PD police report #23-000151 (Exhibit La) is cross-referenced in both Rogstad's report and the FBI/FTC filings. - The incompetency orders (Exhibits Bb and Pb) each reference Dr. Rogstad's findings. - The civil commitment case 27-MH-PR-23-815 is the parallel proceeding referenced throughout. --- ## Filing #2 — Defendant's Affidavit of Fact (May 6, 2024) | Field | Detail | |---|---| | Filing # | 2 | | Date Filed | May 6, 2024 (Filed in District Court at 2:45 PM) | | Filed By | Matthew David Guertin, Pro Se ("Is Currently Without Effective Counsel") | | Document Type | Affidavit of Fact (sworn under penalty of perjury) | | Case/Court | 27-CR-23-1886, Fourth Judicial District Court, Hennepin County, Minnesota | | Pages | 148 | | Bates / Doc ID | MCRO_27-CR-23-1886__Other_Document_2024-05-06_20240507123002 | --- ### Comprehensive Summary This is a 148-page sworn Affidavit of Fact filed pro se by Defendant Matthew David Guertin on May 6, 2024, addressed to Judge Julia Dayton Klein, the Clerk of the Fourth Judicial District Court, Assistant Hennepin County Attorney Jacqueline Perez, and the Office of the Hennepin County Attorney. The stated purpose of the filing is to submit into the official court record "all of the additional email exchanges" the defendant recently located that he considers relevant to his criminal case and the "bigger picture" of alleged patent fraud he claims underlies both his criminal proceeding (27-CR-23-1886) and his civil commitment proceeding (27-MH-PR-23-815). **Core Narrative:** The defendant asserts that he is the inventor of a patented "Motorized Rotatable Treadmill and System for Creating the Illusion of Movement" (US Patent 11,577,177), filed as a provisional patent application on March 19, 2021. He claims that Stephan Trojansky, acting on behalf of Netflix, Inc. and through Eyeline Studios/Scanline VFX, filed a substantially similar patent application just 12 days later on March 31, 2021, constituting patent theft. The defendant alleges this is part of a massive, coordinated fraud operation involving Netflix, government agencies, the Internet Archive (Wayback Machine), the courts, and intelligence entities. The defendant argues that these claims — which were classified as "delusional" by forensic psychologist Dr. Jill Rogstad in her March 10, 2023 Rule 20.01 exam report leading to a finding of incompetency to stand trial — are in fact substantiated by the documentary evidence presented in this affidavit. He points specifically to the fact that his name and patent now appear at the top of the subsequently granted Netflix patent (US Patent 11,810,254) as a submitted and reviewed Third Party Prior Art reference, which he contends validates his claims and undermines the competency determination. **The Affidavit Structure:** The document consists of a 32-page narrative introduction and exhibit summary (pp. 1–32), followed by 116 pages of exhibits (pp. 33–148). The exhibits are organized as Exhibits A through L (with extensive sub-exhibits designated by lowercase letters, e.g., Aa, Ab, Ac through Al, Ba through Bd, Da through Db, Ea, Fa through Fd, Ga through Gb, Ia through Ic, Ja through Ji, Ka, and L). **Key Themes Across All Exhibits:** 1. **Patent Priority & Alleged Theft:** The defendant presents a timeline showing his provisional patent application preceded the Trojansky/Netflix filing by 12 days, and that his patent attorney (Amanda Prose of Westman, Champlin & Koehler / WCK) confirmed the substantial similarities between the two applications and strategized regarding third-party prior art submissions to the USPTO. 2. **Competency Challenge:** The defendant extensively argues that the March 10, 2023 Rule 20.01 exam by Dr. Jill Rogstad was fundamentally flawed because it characterized his factual patent-related claims as "delusional" symptoms of "Unspecified Schizophrenia Spectrum and Other Psychotic Disorder (primary)." He argues the now-granted Netflix patent containing his name as prior art proves his claims were factual, not delusional. He quotes Dr. Rogstad's own acknowledgment of her lack of technological expertise and her statement that "even if the technological aspects of the defendant's statements prove true...his views remain consistent with delusions." 3. **Defense Counsel Complaints (Bruce Rivers):** A major thread involves the defendant's escalating frustration with his defense attorney Bruce Rivers, whom he retained shortly after his January 21, 2023 arrest. The defendant documents repeated instances of: failure to provide discovery materials; failure to present exculpatory evidence at the July 7, 2023 competency hearing (presenting only the granted patent, not additional exhibits the defendant prepared); advising against presenting evidence; failure to respond to communications; and an alleged phone statement on May 22, 2023 about "powerful people keeping an eye on" the defendant, which Rivers later denied making. The email chain culminates in the defendant's April 3, 2024 notice of dismissal of Bruce Rivers as defense counsel. 4. **Alleged Internet Archive / Wayback Machine Fraud:** The defendant presents extensive spreadsheet analyses (Exhibit Ba) showing what he claims are systematic timestamp discrepancies in archived PhotoRobot.com webpages on the Wayback Machine. He alleges these discrepancies show that historical web pages were being fraudulently backdated to create a false impression of prior art/obviousness against his patent. He collected 780 individual archived web pages from 62 blog URLs and analyzed their JavaScript/CSS file timestamps versus claimed archive dates. 5. **Alleged Court System Corruption:** The defendant claims that discovery materials provided in his case were intentionally altered — specifically that 24 photographs were removed from the original 104 photographs — and that these altered materials were provided to the second examiner, Michael Robertson, corrupting the basis of his evaluation. He filed his own "Demand or Request for Discovery" which was accepted into the record but claims he never received the requested materials. 6. **Procedural Anomalies:** The defendant identifies what he considers suspicious scheduling irregularities, including: a June 14, 2023 hearing that was cancelled the day before based on a "scheduling conflict" motion by Bruce Rivers, but for which no formal Motion for Continuance appears in the MCRO record; a court order referencing a non-existent motion; the cancelled hearing being listed as "Held Off the Record"; and out-of-sequence index numbering in the court record. 7. **Surveillance & Intelligence Claims:** The defendant presents a "LinkedIn Search Graph" (referenced but with the graph itself included as an attachment to Exhibit J) purporting to show searches of his LinkedIn profile by entities including Forcepoint, 3Gimbals, USC Cinema, and the US Army, which he interprets as evidence of surveillance. He connects these to his claims about government involvement in patent theft, citing Forcepoint and 3Gimbals' advertised capabilities in "statecraft," "overmatch," and "disruptive capabilities." 8. **January 21, 2023 Incident Context:** The defendant provides extensive context for the incident resulting in his criminal charges (firing a gun and writing on walls at his apartment at 10233 W 34th Street, Minnetonka, MN), framing it as a rational response to fear generated by his discovery of what he perceived as a sophisticated surveillance and fraud operation targeting him and his intellectual property, compounded by discovering a "Personal Area Network" adapter on his computer, phone tampering (YouTube playlists reordered, a playlist titled "shooting" appearing at the top of his account), and his belief that a welder he hired who claimed CIA and Marine Corps connections may have been part of the operation. 9. **Connections to MOVA Contour / Steve Perlman Litigation:** The defendant draws parallels between his situation and a federal case (3:17-cv-04006, Northern District of California) filed by Rearden LLC against entities he claims are the same ones involved in his patent dispute, involving stolen "MOVA Contour" facial capture technology. He connects this to Paul Debevec, whom he accuses of being fraudulently credited with achievements actually belonging to Steve Perlman and MOVA Contour technology. 10. **Contacts with Government Officials:** The defendant references communications with Senator Amy Klobuchar's office (via Hanna Welch), the FBI, the Secret Service, the FTC, and local police, claiming no meaningful response or investigation from any agency. --- ### Legal Issues & Arguments Raised - **Competency to Stand Trial (Minn. R. Crim. P. 20.01):** Defendant challenges the March 10, 2023 finding of incompetency, arguing the evidentiary basis for the diagnosis (his patent claims) has been objectively validated by the granted Netflix patent listing his name as prior art. - **Ineffective Assistance of Counsel:** Implicit throughout; defendant documents defense attorney Bruce Rivers' alleged failures to present exculpatory evidence, provide discovery, respond to communications, and pursue the defendant's interests. - **Discovery Violations (Rule 9.01, subd. 1(6)):** Defendant alleges prosecution/court failed to provide original, unaltered discovery materials and claims altered discovery was sent to the second mental health examiner. - **Fraud on the Court:** Defendant alleges the Hennepin County court system itself is participating in or facilitating the larger patent fraud operation by manipulating discovery and suppressing his case. - **Sixth Amendment — Right to Public Trial:** Defendant raised (in Exhibit I email to Bruce Rivers) that Zoom hearings violate the public trial clause because they require special access codes. - **Procedural Due Process:** Defendant identifies anomalies in hearing scheduling, missing motions for continuance, and hearings "held off the record." - **Right to Self-Representation:** Defendant filed a Motion to Proceed Pro Se (referenced in Exhibit K) and formally dismissed Bruce Rivers as defense counsel. - **Civil Commitment Challenge:** Defendant references the stayed order of civil commitment (27-MH-PR-23-815) and his opposition to commitment proceedings, including a February 1, 2024 hearing he claims was a complete surprise. --- ### Factual Allegations & Key Assertions - Defendant filed a provisional patent application for his "Motorized Rotatable Treadmill" on March 19, 2021. - Stephan Trojansky / Netflix filed a substantially similar patent application on March 31, 2021 (12 days later). - Defendant's patent (US 11,577,177) was granted; Netflix's patent (US 11,810,254) was also granted despite the defendant's Third Party Prior Art submission. - Defendant's name and patent appear at the top of the granted Netflix patent as reviewed prior art. - Defendant's patent attorney Amanda Prose confirmed substantial similarities between the two applications in emails dated November 8, 2022. - Defendant discovered the Netflix/Trojansky application on approximately November 6, 2022, after being pointed to "PhotoRobot Virtual Catwalk" by Assaff Rawner (CEO, Mark Roberts Motion Control) on October 31, 2022, and then searching the USPTO database. - Defendant prepared and sent a comprehensive evidence packet to Bruce Rivers via Dropbox on November 11, 2022 (288mb), prior to retaining him as defense counsel. - Defendant conducted extensive personal digital forensic investigation of Internet Archive/Wayback Machine pages for PhotoRobot.com beginning December 9, 2022, collecting 4.6GB of data. - Defendant filed a police report with Minnetonka PD (Case #23-000151) on January 12, 2023 regarding alleged wire fraud and conspiracy. - Defendant was arrested on January 21, 2023, following the firearm incident at his residence. - Defendant sent a detailed email to Minnetonka PD Detective Samantha Johnson on January 30, 2023 (Exhibit C). - Dr. Jill Rogstad conducted the Rule 20.01 exam meeting on March 1, 2023 and issued her report on March 10, 2023. - Defendant sent email to Dr. Rogstad on April 26, 2023 (Exhibit G) providing evidence contradicting her report, with Bruce Rivers CC'd. - A July 7, 2023 in-person hearing was held; defendant claims only his granted patent was submitted as an exhibit, and Bruce Rivers advised against presenting additional evidence. - The July 13, 2023 court order upheld incompetency finding. - A January 3, 2024 six-month review was conducted over Zoom by Dr. Adam Milz; defendant claims he was never provided with the resulting exam report. - A civil commitment hearing on February 1, 2024 was a "complete surprise" to the defendant. - Defendant filed a "Demand or Request for Discovery" that was accepted into the case record on January 5, 2024. - Defendant sent formal notice of dismissal of Bruce Rivers on April 3, 2024. - Defendant sent a text message to Bruce Rivers on April 18, 2024 reiterating request for withdrawal. - Defendant states he was advised by his mental health case worker and his court-appointed civil commitment attorney to seek new criminal defense counsel. - A welder the defendant hired to work on his prototype claimed CIA and Marine Corps background; defendant photographed what he describes as "special ops" wireless PTZ throw cameras found atop his prototype during welding. - Defendant claims his phone was accessed without a warrant while in police custody (settings changed, YouTube playlists reordered, a "shooting" playlist appeared, a "neural radiance fields" playlist went missing). - Defendant claims discovery of Paul Debevec presenting defendant's patented technology at SIGGRAPH 2023 on behalf of Netflix/Eyeline Studios, while concealing his position as VP of ACM-SIGGRAPH. - Defendant asserts connections between the patent situation and Barack Obama's connections to Netflix. - Defendant prepared an investor pitch for "InfiniSet, Inc." and claims the technology has applications in filmmaking, gaming, healthcare, rehabilitation, and training simulations. --- ### Procedural Posture This Affidavit was filed on May 6, 2024, approximately one month after the defendant began representing himself pro se following dismissal of Bruce Rivers as defense counsel (April 3, 2024). It follows: - The defendant's April 3, 2024 "Motion for Judicial Notice" (heavily cross-referenced throughout) - The defendant's April 9, 2024 "Affidavit of Fact" (heavily cross-referenced throughout) - The defendant's April 4, 2024 "Motion to Compel Discovery and Affidavit of Fact" - The defendant's May 5, 2024 "Follow-up Correspondence" regarding the court's refusal to rule on his motions The filing sits within the context of: the defendant having been found incompetent to stand trial, a stayed order of civil commitment, the defendant's transition to pro se representation, and his aggressive campaign to submit what he considers exculpatory evidence into the record. --- ### Exhibit / Attachment Inventory **Exhibit A** — Email from defendant to Bruce Rivers (Nov 11, 2022, 7:51 AM) re: "Matt Guertin Patent / Netflix Patent" with Dropbox link (288mb). Includes full email PGP header. [p.33] **Exhibit Aa** — Screenshot of Dropbox link folder contents ("Bruce_Rivers_Packet") [p.34] **Exhibit Ab** — Detailed file list of Dropbox folder contents with cross-references to prior filings [p.35] **Exhibit Ac** — Nevada Secretary of State entity information page for Eyeline Studios, Inc. (Entity #E6491832020-9, formed 05/07/2020, Domestic Corporation). Officers: Stephan Trojansky (President/Director), Reg Thompson, Stephen Zager. 1,000,000 shares common stock. [p.36] **Exhibit Ad** — Eyeline Studios LinkedIn page, SignalHire hiring page, and EyelineStudios.com contact page (3 pages). Contains highlighted job titles and statements about "reinventing filmmaking" and "virtual production." Employee list includes Claire Bee (Volumetric Capture), Lukas Lepicovsky (VP Supervisor), Jonathan Reynolds (Unreal Generalist), and ~27 others. [pp.37-39] **Exhibit Ae** — Screenshot from defendant's demo video ("My_Invention_Demo___Bruce_Rivers.mp4") showing custom animated watermarks: "CONFIDENTIAL VIDEO for Bruce Rivers," "PATENT PENDING – CONFIDENTIAL," "INVENTED BY MattGuertin@ProtonMail.com" [p.40] **Exhibit Af** — 13-page document: background research on Robert Hulse (patent attorney at Fenwick & West) including firm history, Hulse's bio, representative clients (including Netflix, Facebook, Google), practice areas (AI, AR/VR, interactive entertainment/games), Digital Media & Entertainment practice overview. [pp.41-53] **Exhibit Ag** — Post Magazine article "Virtual production becomes a reality" (Jan/Feb 2022), 9 pages. Features interviews with Steve Jelley (Dimension Studios), Carlos Fueyo (Eyeline Studios VAD art director/VP supervisor), and Ian Milham (ILM VP supervisor). Contains highlighted Fueyo quote about Eyeline being "set to redefine the way in which productions are made" and a "big announcement in the months to come." [pp.54-62] **Exhibit Ah** — Scanline VFX website printouts (3 pages). Includes "About" page stating Scanline is "Empowered by Netflix" and that Eyeline Studios is "Scanline's virtual production division." Also includes a March 24, 2020 press release about remote work signed by Stephan Trojansky as President of Scanline VFX, referencing proprietary "Eyeline Next" video conferencing technology. [pp.63-65] **Exhibit Ai** — Two emails from patent attorney Amanda Prose (WCK) to defendant, both dated November 8, 2022. First email (8:58 AM) discusses research on Trojansky/Netflix PCT application, strategy for third-party prior art submission (deadline April 6, 2023), duty of candor, and confirmation of defendant's patent nearing allowance. Second email (2:43 PM) discusses monitoring Netflix application status, submitting PhotoRobot material, patent allowance pre-check, continuation application strategy, and assignment to InfiniSet, Inc. [pp.66-67] **Exhibit Aj** — Granted patent claims (Claims 14-20) from US Patent 11,577,177 for "Motorized Rotatable Treadmill and System for Creating the Illusion of Movement." [p.68] **Exhibit Ak** — Draft amendment prepared by Amanda Prose (WCK) for patent application 17/698,420, responding to Office Action dated August 17, 2022. Cancels claims 1-13, amends claim 17, responds to §102 and §103 rejections. Marked "DRAFT ONLY – CLIENT CONFIDENTIAL." [pp.69-73] **Exhibit Al** — Follow-up email to Bruce Rivers (Nov 11, 2022, 7:53 AM): "My provisional application was filed on March 19th, 2021 Trojansky/Netflix was filed on March 31st, 2021 I win." Includes PGP header. [p.74] **Exhibit Am** — Follow-up email to Bruce Rivers (Nov 11, 2022, 7:57 AM): sharing portfolio website www.MattGuertin.com. Includes PGP header. [p.75] **Exhibit B** — Email to Bruce Rivers (Jan 13, 2023, 5:14 PM) with subject "Bruce. You gotta help me get a bunch of eyes on this." Discusses real-time editing of Internet Archive pages, Dropbox link (4.6GB), attached spreadsheet. Asks about federal investigators. Includes PGP header. [pp.76-77] **Exhibit Ba** — Screenshots of spreadsheet "DATA_ANALYSIS_ALL_WEB_FILES_tutorials_how-to-film-models.xlsx" attached to Exhibit B email. Multiple pages of detailed date comparison tables showing "Claimed Archive Date," "Internal Archive Date," and "Collection Date" columns with defendant's annotations highlighting date mismatches. The spreadsheets span pages 78-84, including both raw data views and cleaned-up versions with highlighted anomalies. [pp.78-84] **Exhibit Bb** — Dropbox directory screenshots showing folder structure of 4.6GB evidence collection. Main directory: "Data_Analysis_and_Files_Proving_Fraud_at_Internet_Archive_1up." Subfolders include: "05-2022-12-15_through_2022-12-20_FIRST_FULL_COLLECT," "tutorials_how-to-film-models," "02-2023-01-01_through_2023-01-07_EVERY_WAYBACK_SAVE_PER_PAGE." The EVERY_WAYBACK_SAVE_PER_PAGE directory contains 781 directories with 41,522 total files; the root directory contains 1,330 directories with 78,226 files total. [pp.85-88] **Exhibit Bc** — AI analysis of file tree data for "2023-01-01_through_2023-01-07_EVERY_WAYBACK_SAVE_PER_PAGE" folder. Analysis discusses indicators of automated content creation, including consistent naming conventions, repeated file patterns, standardized structures, and timestamp discrepancies. Includes excerpt of actual file tree showing directory structure. [pp.89-91] **Exhibit Bd** — Contents of "NOTES_AND_BACKGROUND.txt" file (last modified Jan 11, 2023, 5:26 AM). Defendant's notes explaining his investigation methodology, focus on specific Wayback Machine archive dates, discovery of September 2022 saves that appeared unexpectedly, and his focus on language analysis of PhotoRobot website changes. Also includes Proton Drive share link. [pp.92-93] **Exhibit C** — Email to Det. Samantha Johnson, Minnetonka PD (Jan 30, 2023, 4:46 PM), CC Bruce Rivers. Re: Case #23-000151. Lengthy email discussing: Personal Area Network adapter discovery, statistical analysis of Wayback Machine date discrepancies, defendant's self-taught background, AI-generated video concerns, request for property retrieval. Signed as "Matthew Guertin, CEO/Founder, InfiniSet, Inc." Includes PGP header. [pp.94-98] **Exhibit D** — Email to Bruce Rivers (Feb 7, 2023, 2:22 AM) re: "I found the other picture / Matthew D Guertin." Discusses welder with claimed CIA/Marines background, "special ops wireless PTZ throw cameras" found on defendant's prototype, concerns about apartment key access. Originally intended for Det. Johnson. References 5 image attachments. Includes PGP header. [pp.99-101] **Exhibit Da** — Two photographs showing what defendant describes as "special ops gear" (wireless PTZ throw cameras) sitting atop defendant's aluminum floor base prototype piece. File names: "signal-2022-01-08-17-01-30-423.jpg" and "signal-2022-01-08-17-01-36-314.jpg." [p.102] **Exhibit Db** — Reply email from Bruce Rivers (Feb 7, 2023, 6:22 AM): "Good I'll take a look at it if I think it needs to be sent and I will send it." Sent from iPhone. Includes full PGP/DKIM headers showing AOL origin. [pp.103-105] **Exhibit E** — Email to Bruce Rivers (Feb 9, 2023, 11:57 AM). Forwarded email from Psychological Services regarding Rule 20.01 exam scheduling. No body text, single PDF attachment. Includes PGP header. [p.106] **Exhibit Ea** — Attached PDF: Letter from Dr. Jill Rogstad, PsyD, LP (Senior Clinical Forensic Psychologist, Fourth Judicial District) dated February 9, 2023, scheduling defendant's psychological evaluation, requesting contact by February 21, 2023. On Minnesota Judicial Branch / Psychological Services letterhead (300 S. 6th Street, Suite C-509, Minneapolis MN 55487-0351). [p.107] **Exhibit F** — Email to Bruce Rivers (Feb 10, 2023, 4:35 PM) with subject "Police looked through my phone without a warrant." Reports YouTube playlists and Samsung Notes reordered. Includes PGP header. [p.108] **Exhibit Fa** — Follow-up email to Bruce Rivers (Feb 10, 2023, 5:00 PM) with 3 YouTube screenshot attachments. Notes "shooting" playlist appearing at top of "most recently added." Includes PGP header. [p.109] **Exhibit Fb** — Three screenshot images of defendant's YouTube account showing playlists including one titled "shooting" and one titled "ChatGTP" (defendant's misspelling of ChatGPT). [p.110] **Exhibit Fc** — Follow-up email to Bruce Rivers (Feb 10, 2023, 5:03 PM). States he was searching for his "neural radiance fields" playlist. Includes PGP header. [p.111] **Exhibit Fd** — Follow-up email to Bruce Rivers (Feb 10, 2023, 5:08 PM): "My playlist for neural radiance fields is missing." Includes PGP header. [p.112] **Exhibit G** — Email to Dr. Jill Rogstad (Apr 26, 2023, 1:37 PM), CC Bruce Rivers. Subject: "Need help overcoming these very realistic 'psychotic delusions' I still seem to be experiencing..." Sarcastically toned email citing published articles crediting defendant as engineer/technologist (PLSN Magazine/XiteLabs, BlackTrax/XiteLabs, Disguise/LA Philharmonic, Derivative.ca/TouchDesigner). References redacted text message about invention "revolutionizing the industry." Includes 12 image attachments and reference to ODF Optronics (Israeli special ops gear manufacturer). Includes PGP header. [pp.113-117] **Exhibit Ga** — Three image attachments from the Rogstad email: redacted messenger screenshot about "revolutionizing the industry," a second messenger screenshot, and a Brave browser screenshot of ODF Optronics. [p.118] **Exhibit Gb** — Second email to Dr. Rogstad (Apr 26, 2023, 1:56 PM), CC Bruce Rivers. Attaches certified mailer images (17.23MB PDF), accepted USPTO third-party prior art filing form, and USPTO EFS Web screencap. Opens with: "Do you think the executives at Netflix thought these certified mailers which contained my patent were even real when they received them?" Includes PGP header. [pp.119-120] **Exhibit H** — Email to Bruce Rivers (May 27, 2023, 6:43 PM) regarding June 14, 2023 @ 9:00 AM hearing. States he is "turning it into an event and inviting all of my friends." Includes PGP header. [p.121] **Exhibit I** — Email to Bruce Rivers (Jun 9, 2023, 12:39 PM) with subject "The 6th Amendment." Argues Zoom hearings violate public trial rights. Includes PGP header. [p.122] **Exhibit Ia** — Reply from Bruce Rivers (Jun 9, 2023, 1:50 PM): "I'll request an in person appearance." Full DKIM/PGP headers from AOL. [pp.123-124] **Exhibit Ib** — Email to Bruce Rivers (Jun 9, 2023, 2:03 PM): Joking comment about "fake ass, PhotoRobot, AI generated Judge." Includes PGP header. [p.125] **Exhibit Ic** — Email to Bruce Rivers (Jun 10, 2023, 5:13 AM). Extensive email covering: phone cloning concerns, AI filtering of communications, patent office digitization, reference to "powerful people keeping an eye on him," desire to sell InfiniSet Inc. outright, demands for case dismissal and record expungement, firearm rights restoration. States: "PAY ME AND THEN LEAVE ME THE FUCK ALONE." References InfiniSet Inc. international filing deadline of September 19th. Includes PGP header. [pp.126-129] **Exhibit J** — Email to Bruce Rivers (Jan 10, 2024, 4:59 PM) re: "Matt Guertin / LinkedIn Search Graph." Discusses Forcepoint and 3Gimbals LinkedIn searches near January 21, 2023; USC Cinema and US Army searches; Paul Debevec's SIGGRAPH 2023 presentation; Netflix patent grant despite prior art submission; allegations of corruption in Hennepin County Courts; altered discovery materials; demand for discovery under Rule 9.01; references to Barack Obama's Netflix connections. Attaches 5 files (LinkedIn PGP Headers zip, LinkedIn Search Graph PNG, Guertin patent PDF, Netflix patent PDF, Demand for Discovery PDF). Includes PGP header. [pp.130-132] **Exhibit Ja** — Follow-up email to Bruce Rivers (Jan 10, 2024, 5:03 PM): "And who exactly is incompetent....me? I don't think so." Includes PGP header. [p.133] **Exhibit Jb** — Follow-up email to Bruce Rivers (Jan 10, 2024, 5:12 PM) with "Introducing_InfiniSet.pdf" attachment. Notes he was never actively on LinkedIn. Includes PGP header. [p.134] **Exhibit Jc** — InfiniSet, Inc. investor pitch document (1 page). Describes the technology as a "revolutionary and literal leap into immersive motion technology" with applications in virtual production, filmmaking, gaming, healthcare, rehabilitation, and training. Compares potential to "Apple in 1980, Amazon in 1997, or Bitcoin in 2010." [p.135] **Exhibit Jd** — Email to Bruce Rivers (Jan 12, 2024, 2:16 PM). Emotional email describing extreme stress, fear for life, references to government agencies contacted (Amy Klobuchar, FBI, FTC, police), theft allegations, impending homelessness. States: "They stole my invention, conducted illegal intelligence operations on me, hacked into my computers, and scared the living shit out of me." Includes PGP header. [pp.136-137] **Exhibit Je** — Reply from Bruce Rivers (Jan 12, 2024, 3:04 PM): "Call me." Full DKIM/PGP headers from AOL/Yahoo. [pp.138-139] **Exhibit Jf** — Email to Bruce Rivers (Jan 12, 2024, 3:37 PM): "can you email the discovery then please?" Includes PGP header. [p.140] **Exhibit Jg** — Email to Bruce Rivers (Jan 14, 2024, 12:00 PM): "Can my court date on Tuesday be over Zoom then?" Includes PGP header. [p.141] **Exhibit Jh** — Email to Bruce Rivers (Jan 15, 2024, 3:02 PM): "YO." Includes PGP header. [p.142] **Exhibit Ji** — Email to Bruce Rivers (Jan 26, 2024, 4:38 PM): Requests psychological evaluation report from January 3, 2024 six-month review by Dr. Adam Milz. Includes PGP header. [p.143] **Exhibit K** — Email to Bruce Rivers (Apr 3, 2024, 7:07 AM) with subject "NOTICE OF DISMISSAL AS DEFENSE COUNSEL." Attaches filed Motion to Proceed as Pro Se. Requests formal Withdrawal of Representation. Includes PGP header. [p.144] **Exhibit Ka** — Reply from Bruce Rivers (Apr 3, 2024, 7:38 AM): "Call me." Full DKIM/PGP headers. [pp.145-146] **Exhibit L** — Text message screenshot (Apr 18, 2024, 7:27 AM) to Bruce Rivers requesting withdrawal from criminal case, and Rivers' reply "Call me." References advice from mental health case worker and civil commitment attorney to seek new counsel. [p.148] --- ### Visual Evidence Inventory - **[Page 34] Screenshot:** Dropbox folder view of "Bruce_Rivers_Packet" showing folder listing with file icons and folder structure. Low-resolution screen capture, text partially garbled by OCR. - **[Pages 37-38] Screenshots:** Eyeline Studios LinkedIn page and SignalHire hiring page. LinkedIn page shows company logo, "About us" section with employee count (201-500), founding year (2020). SignalHire page shows employee directory with names and titles. Both appear to be standard webpage captures. - **[Page 39] Screenshot:** EyelineStudios.com contact page showing staff names and roles. Partially garbled by OCR, contains some encoding artifacts. - **[Page 40] Video Screenshot:** Screen capture from defendant's demo video ("My_Invention_Demo___Bruce_Rivers.mp4") showing what appears to be mechanical/engineering equipment with custom animated text watermarks overlaid. Image is dark with visible text overlays. - **[Pages 41-53] Website Printouts:** Multiple pages from Fenwick & West LLP website including firm history page, Robert Hulse attorney profile page (with headshot photo), representative clients list, publications list, presentations list, Digital Media & Entertainment practice page. Professional website layout with firm branding. - **[Pages 54-62] Article Printout:** Post Magazine article with header graphics, embedded photographs (Steve Jelley headshot, Carlos Fueyo headshot, Ian Milham headshot, multiple LED volume/virtual production stage photographs showing large LED screen installations, soundstage setups). Article text interspersed with images of virtual production environments and Stagecraft stages. - **[Pages 63-65] Website Printouts:** Scanline VFX website "About" section with company branding, Netflix partnership badge/logo, awards listing, and a press release page dated March 24, 2020 with Stephan Trojansky listed as Company Contact/President. - **[Page 64] Organizational Chart/Graphic:** Appears to be a Scanline VFX studio locations graphic or organizational layout. Heavily garbled by OCR extraction — text is scrambled and largely illegible, suggesting this is a complex image-based layout rather than text. - **[Page 36] Table/Database Print:** Nevada Secretary of State entity information page for Eyeline Studios, Inc. Rendered as a structured data table showing entity details, registered agent information, officer information (with addresses), and share structure. Clean government database printout format. - **[Pages 78-84] Spreadsheet Screenshots:** Multiple full-page screenshots of defendant's data analysis spreadsheet with columns for "Claimed Archive Date," "Internal Archive Date," "Collection Date," and file names. Contains defendant's margin annotations in blue/colored text boxes explaining observed patterns. Some pages show cleaner reformatted versions of the same data. Data is dense with timestamps and file paths. - **[Pages 85-88] Directory Screenshots:** File explorer/directory views of Dropbox folder contents at multiple levels. Shows folder hierarchy, file counts, modification dates. One page shows a file listing in what appears to be Windows Explorer with 60+ entries including file sizes and dates. Another shows deeply nested folder structures. - **[Pages 79-84] Spreadsheet Data (Alternate Views):** Additional spreadsheet views including what appear to be rotated/landscape orientations of the same timestamp analysis data, with different highlighting and annotation schemes. - **[Page 87] Directory Listing:** Large file manager view showing ~60 files in the "EVERY_WAYBACK_SAVE_PER_PAGE / REPORT" subfolder with file names like "blog_*" entries, modified dates, and file sizes. - **[Page 102] Photographs (2):** Two photographs filed as "signal-2022-01-08-17-01-30-423.jpg" and "signal-2022-01-08-17-01-36-314.jpg." These show what defendant describes as "special ops" wireless PTZ throw cameras sitting on what appears to be a circular aluminum base piece (the floor base of defendant's invention prototype). The images appear to be taken in a workshop/welding environment. The objects on the prototype appear to be small, dark-colored devices. - **[Page 107] Official Letter:** Minnesota Judicial Branch letterhead document from Dr. Jill Rogstad, dated February 9, 2023. Contains official Minnesota Judicial Branch logo/header. Clean document scan. - **[Page 110] Phone Screenshots (3):** Three Samsung phone screenshots of YouTube app showing playlist listings. Visible playlist titles include "shooting" (with gun-related video thumbnails), "ChatGTP," and others. Standard Android/Samsung UI elements visible. - **[Page 118] Screenshots (3):** Three image attachments from the Rogstad email: (1) Facebook Messenger screenshot with text about "revolutionizing the industry" (heavily redacted with black bars), (2) a second messenger screenshot (also redacted), (3) a Brave browser screenshot showing ODF Optronics website. - **[Page 135] Text Document:** InfiniSet, Inc. investor pitch — appears as a formatted text document, not image-based. Clean text layout. - **[Page 148] Text Message Screenshot:** Samsung Messages app screenshot showing text exchange between defendant and Bruce Rivers. Defendant's message requests withdrawal from case and mentions advice from case worker and civil commitment attorney. Rivers' reply: "Call me." - **[Throughout, pp.1-148] Court Filing Stamps:** Every page contains a header stamp reading "27-CR-23-1886" and "Filed in District Court / State of Minnesota / 5/6/2024 2:45 PM." These are standard e-filing stamps. - **[Page 32] Electronic Signature:** Defendant signs with "/s/ Matthew Guertin" — electronic signature block format, not a wet signature. --- ### Key People Referenced | Person | Role / Affiliation | Context | |---|---|---| | **Matthew David Guertin** | Defendant / Pro Se / Inventor / CEO InfiniSet, Inc. | Affiant; residing at 1075 Traditions Court, Chaska, MN (Carver County); formerly at 10233 W 34th St #304, Minnetonka, MN | | **Judge Julia Dayton Klein** | Judge, Fourth Judicial District | Presiding judge; signed June 14, 2023 continuance order and July 13, 2023 incompetency order | | **Jacqueline Perez** | Assistant Hennepin County Attorney | Prosecutor; named recipient of affidavit | | **Bruce Rivers** | Defense Attorney (riverslawyers@aol.com) | Defendant's retained criminal defense counsel; longtime friend (~20 years); recipient of majority of email exhibits; formally dismissed April 3, 2024 | | **Dr. Jill Rogstad, PsyD, LP** | Senior Clinical Forensic Psychologist, Fourth Judicial District | Conducted March 1, 2023 Rule 20.01 exam; issued March 10, 2023 report finding defendant incompetent; diagnosed "Unspecified Schizophrenia Spectrum and Other Psychotic Disorder (primary)" | | **Michael Robertson** | Psychologist / Second Examiner | Conducted defendant's second mental health exam; defendant alleges he received altered discovery materials | | **Dr. Adam Milz** | Psychologist | Conducted January 3, 2024 six-month review over Zoom; defendant claims he was never provided the resulting report | | **Amanda Prose** | Patent Attorney, Westman Champlin & Koehler (WCK), Reg. No. 72,345 | Defendant's patent attorney (aprose@wck.com); confirmed similarities between Guertin and Netflix patent applications | | **Megan Neumann** | Patent Attorney, WCK | CC'd on Amanda Prose's emails (mneumann@wck.com) | | **Stephan Trojansky** | President, Scanline VFX / Eyeline Studios | Named inventor on Netflix patent application; President/Director of Eyeline Studios, Inc. (Nevada) | | **Paul Debevec** | VP ACM-SIGGRAPH / Professor USC / Netflix affiliate | Defendant claims he presented defendant's patented technology at SIGGRAPH 2023 on behalf of Netflix/Eyeline Studios | | **Robert Hulse** | Patent Attorney, Fenwick & West LLP | Attorney of record for Netflix/Trojansky patent application | | **Assaff Rawner** | CEO, Mark Roberts Motion Control | Pointed defendant to "PhotoRobot Virtual Catwalk" in October 31, 2022 email | | **Steve Perlman** | Inventor, MOVA Contour technology / Rearden LLC | Referenced in connection to federal case 3:17-cv-04006 involving stolen facial capture technology | | **Carlos Fueyo** | VAD Art Director/VP Supervisor, Eyeline Studios | Quoted in Post Magazine article about Eyeline redefining filmmaking | | **Steve Jelley** | Co-founder/Joint Managing Director, Dimension Studios | Interviewed in Post Magazine article about virtual production | | **Ian Milham** | Virtual Production Supervisor, ILM | Interviewed in Post Magazine about Stagecraft stages | | **Det. Samantha Johnson** | Detective, Minnetonka Police Department | Assigned to defendant's criminal case post-arrest; recipient of January 30, 2023 email | | **Officer Harris** | Officer, Minnetonka Police Department | Took defendant's original fraud complaint on January 12, 2023 | | **Hanna Welch** | Staff, Sen. Amy Klobuchar's office | Defendant emailed on October 16, 2023 regarding his situation | | **Reg Thompson** | Officer, Eyeline Studios, Inc. | Listed on Nevada SOS filing | | **Stephen Zager** | Officer, Eyeline Studios, Inc. | Listed on Nevada SOS filing | | **Greg Hermanovick** | Creator, TouchDesigner / SideFX Software | Referenced in defendant's email to Rogstad | | **Nigel Denton-Howes** | VP, Eyeline Studios | Listed on LinkedIn page | | **Scott Miller** | COO, Eyeline Studios | Listed on SignalHire page | --- ### Key Entities / Organizations Referenced | Entity | Context | |---|---| | **InfiniSet, Inc.** | Defendant's company; intended assignee of patent | | **Netflix, Inc.** | Defendant alleges patent theft via Trojansky application | | **Eyeline Studios, Inc.** | Nevada corporation (formed 05/07/2020); virtual production division of Scanline VFX; defendant alleges involvement in patent theft | | **Scanline VFX** | Visual effects studio; parent entity of Eyeline Studios; "empowered by Netflix" | | **Fenwick & West LLP** | Law firm representing Netflix/Trojansky patent application | | **Westman, Champlin & Koehler, P.A. (WCK)** | Defendant's patent law firm (Minneapolis) | | **USPTO (United States Patent and Trademark Office)** | Patent applications and grants | | **PhotoRobot** | Company whose website defendant alleges was used for fraudulent prior art creation via Internet Archive manipulation | | **Internet Archive / Wayback Machine** | Defendant alleges pages were fraudulently backdated | | **Minnetonka Police Department** | Handled both defendant's fraud complaint and subsequent criminal case | | **Hennepin County Attorney's Office** | Prosecution | | **Fourth Judicial District, Hennepin County** | Court of jurisdiction | | **Minnesota Judicial Branch Psychological Services** | Dr. Rogstad's employer | | **ACM-SIGGRAPH** | Professional organization; Paul Debevec allegedly VP | | **Forcepoint** | Technology company; defendant claims searched his LinkedIn near Jan 21, 2023 | | **3Gimbals** | Technology company; defendant claims searched his LinkedIn; specializes in "overmatch" and "disruptive capabilities" | | **USC Cinema** | University of Southern California film school; Paul Debevec affiliation | | **U.S. Army** | Defendant claims searched his LinkedIn; alleges involvement in patent theft | | **Mark Roberts Motion Control** | Company whose CEO pointed defendant to PhotoRobot | | **Rearden LLC / Rearden MOVA LLC** | Steve Perlman's companies; filed case 3:17-cv-04006 | | **Digital Domain** | VFX company referenced in MOVA Contour context | | **ODF Optronics** | Israeli manufacturer of special operations equipment | | **ILM (Industrial Light & Magic)** | Referenced for Stagecraft virtual production stages | | **Dimension Studios** | UK virtual production studio featured in Post Magazine article | | **Proton Mail / Proton Drive** | Defendant's email and file sharing service | | **XiteLabs** | Company where defendant worked as creative technologist | | **Derivative.ca / TouchDesigner** | Software platform; featured defendant's work in 2014 | | **Senator Amy Klobuchar's Office** | Defendant contacted regarding his situation | | **FBI** | Defendant attempted to contact; spoke with Chicago agent | | **Secret Service** | Defendant claims he spoke with an agent | | **FTC (Federal Trade Commission)** | Defendant contacted | --- ### Dates & Deadlines Mentioned | Date | Event | |---|---| | March 19, 2021 | Defendant's provisional patent application filed | | March 31, 2021 | Trojansky/Netflix provisional patent application filed (12 days later) | | October 31, 2022 | Assaff Rawner email pointing defendant to PhotoRobot | | ~November 6, 2022 | Defendant's initial discovery of Trojansky/Netflix patent application | | November 8, 2022 | Two emails from patent attorney Amanda Prose confirming similarities | | November 11, 2022 | Defendant's initial email to Bruce Rivers with evidence packet | | December 9, 2022 | Defendant began downloading/archiving PhotoRobot website from Internet Archive | | January 11, 2023 | NOTES_AND_BACKGROUND.txt last modified date | | January 12, 2023 | Defendant filed police report (Case #23-000151) with Minnetonka PD; attempted FBI contact | | January 13, 2023 | Defendant email to Bruce Rivers with 4.6GB evidence | | January 21, 2023 | Arrest date (firearm incident at residence) | | January 30, 2023 | Defendant email to Det. Johnson | | February 7, 2023 | Defendant email to Bruce Rivers with "special ops gear" photos | | February 9, 2023 | Dr. Rogstad scheduling letter; defendant forwards to Rivers | | February 10, 2023 | Defendant emails to Rivers about phone tampering | | February 14, 2023 | Defendant's patent issue date (mentioned in Exhibit C) | | March 1, 2023 | Rule 20.01 exam meeting with Dr. Rogstad | | March 10, 2023 | Dr. Rogstad's Rule 20.01 exam report date | | April 4, 2023 | Last formal Motion for Continuance by Bruce Rivers in record | | April 6, 2023 | Deadline for third-party prior art submission in Netflix application (per Amanda Prose) | | April 26, 2023 | Defendant emails to Dr. Rogstad with evidence | | May 22, 2023 | Phone call with Bruce Rivers at 3:13 PM (alleged "powerful people" comment) | | May 27, 2023 | Defendant email about June 14 hearing | | June 9-10, 2023 | Defendant emails about 6th Amendment / Zoom hearings | | June 13, 2023 | Bruce Rivers allegedly requested continuance | | June 14, 2023 | Scheduled hearing at 9:00 AM; cancelled; listed as "Held Off the Record"; continuance order filed at 2:34 PM | | July 7, 2023 | In-person competency hearing | | July 13, 2023 | Court order upholding incompetency finding | | October 16, 2023 | Defendant email to Hanna Welch (Klobuchar's office) | | January 3, 2024 | Six-month review meeting with Dr. Adam Milz (Zoom) | | January 5, 2024 | Defendant's Demand for Discovery filed/accepted | | January 10, 2024 | Defendant emails to Rivers re: LinkedIn Search Graph | | January 12, 2024 | Defendant emails Rivers about life being destroyed; Rivers replies "Call me" | | January 15, 2024 | Defendant text to Rivers at 6:26 PM about Jan 16 court date | | January 16, 2024 | Scheduled court date | | January 26, 2024 | Defendant requests psychological eval report from Rivers | | February 1, 2024 | Civil commitment hearing (surprise to defendant) | | March 1, 2024 | Defendant facing housing deadline | | April 3, 2024 | Defendant files Motion to Proceed Pro Se; emails dismissal to Rivers; defendant's "Motion for Judicial Notice" filed | | April 4, 2024 | Defendant's "Motion to Compel Discovery and Affidavit of Fact" | | April 9, 2024 | Defendant's prior "Affidavit of Fact" | | April 18, 2024 | Defendant text to Rivers requesting withdrawal | | May 5, 2024 | Defendant's "Follow-up Correspondence" filed | | May 6, 2024 | THIS FILING — Affidavit of Fact | | September 19, [2023] | International patent filing cutoff mentioned | --- ### Forensic Flags & Anomalies 1. **Competency Determination vs. Objective Evidence:** The central forensic issue is the apparent conflict between the competency evaluation's characterization of defendant's patent claims as delusional symptoms and the subsequent objective confirmation (defendant's name on granted Netflix patent) that his core factual claims about patent similarity were accurate. 2. **Dr. Rogstad's Self-Acknowledged Limitations:** Rogstad's own report states she lacks "specialized training" in technology matters and was unable to verify defendant's claims with his patent attorney, yet proceeded to diagnose despite acknowledging that "even if the technological aspects of the defendant's statements prove true...his views remain consistent with delusions." 3. **Missing/Altered Discovery Materials:** Defendant alleges 24 photographs removed from 104 original discovery photographs, and that these altered materials were sent to the second examiner. This allegation, if verified, would constitute a serious due process violation. 4. **June 14, 2023 Hearing Irregularities:** Multiple anomalies identified: no formal Motion for Continuance in MCRO record; hearing listed as "Held Off the Record" despite cancellation; continuance order filed at 2:34 PM (after scheduled 9:00 AM hearing); index numbering appears out of sequence (#16 ruling, then #17 "Taken Under Advisement"). 5. **Defense Counsel Non-Responsiveness Pattern:** Documented pattern of Bruce Rivers' "Call me" responses to substantive written communications, repeated failures to provide discovery, and alleged advisement against presenting exculpatory evidence at the July 7, 2023 hearing. 6. **Evidence Preservation:** Defendant's extensive documentation practices (full PGP email headers, Dropbox links with timestamps, file trees, metadata preservation) demonstrate a systematic approach to evidence preservation that appears inconsistent with the profile described in the incompetency evaluation. 7. **Email Authentication:** Every exhibit email includes complete PGP headers, DKIM signatures, SPF records, and server routing information, allowing independent verification of send/receive times and authenticity. 8. **Proton Mail Usage:** Defendant uses Proton Mail (end-to-end encrypted) while Bruce Rivers uses AOL. Headers consistently show Rivers' emails lack recipient encryption (X-Pm-Recipient-Encryption: riverslawyers%40aol.com=none). 9. **Self-Representation Quality:** The 148-page filing, while at times informal in tone, demonstrates organization (lettered exhibit system with sub-exhibits), cross-referencing to prior filings, and legal argumentation capabilities that may be relevant to competency assessments. 10. **Timeline of Escalation:** The email chain shows a clear chronological escalation from calm evidence-sharing (Nov 2022) to increasing frustration (Jan-Jun 2023) to desperate fear (Jan 2024) to formal counsel dismissal (Apr 2024), providing a documented emotional trajectory. 11. **Defendant's Substack Posts:** References to public Substack posts (MattGuertin.substack.com) with specific URLs suggest defendant was publicly disseminating his theories, which could have investigative or legal significance. 12. **Welder/CIA Connection:** Defendant's claims about a welder with CIA/Marines background and photographs of alleged "special ops gear" on his prototype — shared with Bruce Rivers who acknowledged receipt — were apparently not presented at the competency hearing despite their direct relevance to claims characterized as delusional. --- ### Cross-References This filing heavily cross-references the following previously filed documents (which should be cataloged as separate filings when processed): - **April 3, 2024 "Motion for Judicial Notice"** — Referenced extensively with specific exhibit and page citations (Exhibits Bb, C, Ca, D, Gb, Ha, Hb, Jb, O, Oa, R, S, Sa, Ta, U, V, Va, W and their page numbers) - **April 9, 2024 "Affidavit of Fact"** — Referenced extensively (Exhibits A, B, Ba, C, D, Ea, H, I, J, K, L, V and their page numbers) - **April 4, 2024 "Motion to Compel Discovery and Affidavit of Fact"** — Referenced regarding discovery fraud claims - **May 5, 2024 "Follow-up Correspondence"** — Referenced regarding court's refusal to rule on motions - **March 10, 2023 Rule 20.01 Exam Report** (Dr. Jill Rogstad) — Extensively quoted and challenged - **July 13, 2023 Court Order** — Referenced as upholding incompetency finding - **January 5, 2024 "Demand or Request for Discovery"** — Attached as exhibit to Exhibit J email - **April 3, 2024 Motion to Proceed Pro Se** — Attached as exhibit to Exhibit K email - **Case 27-MH-PR-23-815** — Civil commitment proceedings - **Case 3:17-cv-04006** (N.D. Cal.) — Rearden LLC v. [entities] regarding MOVA Contour technology - **US Patent 11,577,177** (Guertin/InfiniSet) - **US Patent 11,810,254** (Trojansky/Netflix — with Guertin listed as prior art) - **Patent Application 17/698,420** and **17/843,960** (Guertin applications) - **Trojansky/Netflix Patent Application US 2022/0319115** --- ## Filing #3 — Defendant's Affidavit of Fact | Field | Detail | |---|---| | Filing # | 3 | | Date Filed | April 9, 2024 (filed at 9:22 AM) | | Filed By | Matthew David Guertin, Defendant Pro Se | | Document Type | Affidavit of Fact (sworn under penalty of perjury) | | Case/Court | 27-CR-23-1886, Hennepin County District Court, Fourth Judicial District | | Pages | 213 | | Bates / Doc ID | MCRO_27-CR-23-1886_Affidavit-Other_2024-04-09_20240430072354 | ### Comprehensive Summary This 213-page sworn affidavit, filed pro se by defendant Matthew David Guertin, constitutes the most expansive single filing in the case record to date. It is addressed to Judge Jay Quam, the Clerk of Court, ACA Jacqueline Perez, and the Hennepin County Attorney's Office. Guertin affirms under penalty of perjury that all statements are true and correct. The affidavit serves multiple simultaneous purposes: (1) it provides Guertin's comprehensive first-person narrative of all events leading to and following the January 21, 2023 incident (a firearm discharge in his apartment that led to a police/SWAT response and criminal charges); (2) it details his allegations of patent fraud involving Netflix, PhotoRobot, the Internet Archive, and Paul Debevec/USC-ICT; (3) it documents his claims of surveillance by government/military/intelligence entities supported by LinkedIn search notification emails with PGP-authenticated headers; (4) it catalogues procedural complaints about his defense counsel Bruce Rivers, court-appointed attorney Michael Biglow, forensic examiner Dr. Jill Rogstad, and Judicial Referee Danielle C. Mercurio; (5) it explains and justifies his decision to proceed pro se; and (6) it challenges the competency determination and civil commitment proceedings (27-MH-PR-23-815). **Core Narrative — Patent & Alleged Fraud:** Guertin holds US Patent 11,577,177 (granted February 14, 2023) for a motorized rotatable treadmill system integrated into LED virtual film sets ("InfiniSet"). He filed his provisional patent on or around March 19, 2021. He discovered that Stephan Trojansky filed a patent application (linked to Netflix, acquired for approximately $100 million) just 12 days after Guertin's provisional filing. Guertin alleges two rounds of patent fraud: *Round 1 (PhotoRobot & Internet Archive):* After Assaff Rawner, CEO of Mark Roberts Motion Control, pointed Guertin to PhotoRobot's "Virtual Catwalk" product on October 31, 2022, Guertin began investigating the product's web history. On December 9, 2022, he created the Internet Archive account "PatentlyFalse" and began archiving PhotoRobot.com. He claims to have discovered real-time alterations to the Internet Archive's records — specifically, an archive save count changed from 45 to 47 within a five-minute window between two PDF screen captures, suggesting backdated entries were being injected. He alleges the Internet Archive itself was facilitating the fraud. He discussed these findings extensively with his patent attorney Amanda Prose at Westman, Champlin & Koehler (WCK), who supported his filing an ic3.gov complaint. *Round 2 (Netflix & Paul Debevec):* On August 8, 2023, Guertin discovered a SIGGRAPH 2023 YouTube video featuring Paul Debevec (Netflix/EyeLine Studios) showing a rotating treadmill similar to his patented technology at approximately the 59-minute mark. He emailed his patent attorney with subject line "Emergency" on August 9, 2023. After receiving no response, he emailed the entire WCK firm on August 10, 2023. The firm terminated the client relationship, citing 37 CFR 11.116(b)(1) (withdrawal without material adverse effect). The firm shareholder also noted that Amanda Prose's emails would no longer reach her, as their system had been modified. Despite this, the firm later sent a referral letter with Guertin's IP files (delivered by courier, with a USB drive), contradicting the stated withdrawal rationale. Guertin further alleges he documented video evidence of fraud using a multi-source capture setup (three video sources, two audio sources, resulting in 4K/60fps recordings) showing YouTube video metadata with creation dates inconsistent with their purported upload dates. He claims age discrepancies in Paul Debevec's appearances across different YouTube videos suggest recent AI-generated production backdated on the platform. He published analysis on his Substack (MattGuertin.substack.com) and Rumble channel, including a 45-minute documentary titled "Matthew David Vs. Goliath." **Core Narrative — The January 21, 2023 Incident:** Guertin describes the firearm discharge as a desperate act born from an acute stress reaction precipitated by his patent fraud investigations, perceived electronic surveillance, computer anomalies (BSOD, unauthorized BIOS changes, cryptic new user accounts), the discovery of AI-generated video content, and the failure of multiple agencies (FBI, local police, US Secret Service, forensic specialists) to provide meaningful assistance. He characterizes it as a calculated effort to summon police intervention when he felt trapped and unable to get help through conventional channels. **Core Narrative — Defense Counsel Issues:** Guertin details extensive grievances against his former attorney Bruce Rivers: - Rivers allegedly told Guertin during a May 22, 2023 phone call that his son had reviewed AI-generated video evidence and that Guertin had "some very powerful people keeping an eye on" him, then refused to discuss it further over the phone, stating he didn't trust the line was secure. - Rivers subsequently denied or downplayed this statement in a later in-person meeting. - On January 15, 2024, Rivers texted Guertin "No court" and "Nothing has changed" regarding a scheduled January 16 hearing. However, on January 16, a court order was signed (by Referee Mercurio at 8:27 AM and Judge Julia Dayton Klein at 9:22 AM) stating that "Prior to the hearing, the parties agreed to a finding of incompetency entered administratively" — an agreement Guertin claims he never consented to. - Despite assurances of representation in the civil commitment case, Rivers did not represent Guertin at the August 1, 2023 civil hearing (he was on a cross-country motorcycle trip documented on his YouTube channel "CLR Bruce Rivers"). - Rivers never provided the Dr. Adam Milz exam report despite multiple requests via text (January 26, 28, 29, 2024) and email (January 26, 2024). - Rivers allegedly told Guertin during a January 2024 phone call, "You already have the discovery materials" — which Guertin disputes, noting the only discovery he received were allegedly manipulated documents from court-appointed attorney Michael Biglow. **Core Narrative — Court-Appointed Attorney Michael Biglow:** On August 1, 2023, Guertin provided Biglow with extensive documentation to challenge Dr. Rogstad's incompetency report, including his patent, police report, FBI/FTC reports, IRS income records ($218,385 in 2019), and professional accomplishment links. Biglow forwarded only one document — a letter from California psychiatrist Dr. Martin Schuster — and did so just six minutes before the Zoom hearing began. **Core Narrative — Competency Determination:** Guertin challenges Dr. Jill Rogstad's competency evaluation report (dated March 10, 2023), arguing she dismissed his legitimate patent fraud concerns as delusional, mischaracterized his professional claims (e.g., describing himself as an "engineer"), and overlooked critical evidence he provided, including the Minnetonka Police Report #23-000151 (filed January 12, 2023, nine days before the incident). He presents Dr. Martin Schuster's April 7, 2023 letter as a counter-opinion, in which Dr. Schuster (Guertin's treating psychiatrist since September 15, 2016) diagnoses ADHD and Generalized Anxiety Disorder with no history of psychosis, Schizophrenia, or Bipolar Disorder, and describes Guertin as "not at risk of harming anyone." **Core Narrative — Civil Commitment:** The Order of Civil Commitment was filed July 20, 2023 (case 27-MH-PR-23-815). Guertin learned of it on July 28 via letter from Biglow. The January 16-17, 2024 court order by Referee Mercurio includes language about the defendant potentially being "committed directly to an appropriate safe and secure facility." Guertin includes an AI-generated language analysis of this order arguing it presumes and plans for his detainment. **Core Narrative — LinkedIn Surveillance Evidence:** Guertin presents a detailed timeline graph (Exhibit A, spanning pages 53-59) correlating automated LinkedIn search notification emails with key dates in his case. He claims authenticated (PGP-verified) searches from military, intelligence, and government entities. An all-time record of 25 searches in a single week preceded July 20, 2023 — the date the civil commitment order was filed. **Core Narrative — MCRO Criminal History Repopulation:** Guertin asserts that his Hennepin County MCRO court records, which showed essentially a clean slate in early 2023, were suddenly repopulated by early 2024 with historical records dating back to 2002, including minor parking violations and infractions. He interprets this as deliberate manipulation. **Core Narrative — Military Applications:** Guertin includes an AI-generated (ChatGPT4) analysis of his patent's potential military training simulation applications, arguing his technology has broad defense implications that explain the military/intelligence interest shown in his LinkedIn searches. ### Legal Issues & Arguments Raised - Lack of informed consent regarding January 16, 2024 incompetency agreement - Ineffective assistance/abandonment by defense counsel Bruce Rivers - Inadequate advocacy by court-appointed counsel Michael Biglow - Challenge to Dr. Jill Rogstad's competency evaluation as unfounded - Alleged patent fraud conspiracy involving Netflix, PhotoRobot, Internet Archive, YouTube, Paul Debevec, and others - Alleged electronic surveillance and monitoring of defendant's communications - Alleged manipulation of court records (MCRO history repopulation) - Alleged manipulation of discovery materials (referenced in separate April 4, 2024 filing) - Due process violations in civil commitment proceedings - Conflict of interest regarding Bruce Rivers' YouTube presence and the alleged YouTube-facilitated fraud - Right to proceed pro se - Wire fraud and criminal conspiracy allegations against third parties (international scope) ### Factual Allegations & Key Assertions - Guertin holds US Patent 11,577,177 (granted Feb 14, 2023) - His provisional patent was filed approximately March 19, 2021, 12 days before Trojansky's filing - Guertin's 2019 gross income from Xite LLC was $218,385 - Internet Archive save count changed from 45 to 47 in 5-minute window on December 9, 2022 - PatentlyFalse Internet Archive account created Dec 9, 2022 at 2:45 AM - Minnetonka Police Report #23-000151 filed January 12, 2023 (9 days before incident) - US Secret Service Chicago office agent acknowledged criminal conspiracy and wire fraud in Guertin's case during 22-minute call on January 15, 2023 - Former CIA welder called Guertin minutes after his Secret Service call on January 15, 2023 - Bruce Rivers stated "you have some very powerful people keeping an eye on you" on May 22, 2023 - Rivers later refused to discuss this over phone, citing security concerns - FBI and FTC fraud reports filed May 3, 2023 - UK Serious Fraud Office report filed May 19, 2023 - Dr. Martin Schuster has treated Guertin since September 15, 2016, with no psychosis diagnosis - Biglow forwarded only Dr. Schuster's letter (of 16 attached files) 6 minutes before August 1, 2023 hearing - January 16, 2024 court order signed at 8:27 AM and 9:22 AM, before the scheduled 1:30 PM hearing - Bruce Rivers texted "No court" and "Nothing has changed" evening of January 15, 2024 - Netflix patent US 11,810,254 published November 7, 2023 - Paul Debevec's SIGGRAPH 2023 video discovered August 8, 2023 - WCK firm terminated client relationship August 10-16, 2023 - International patent filing deadline was September 19, 2023; EPO deadline was October 18, 2023 - MCRO criminal history showed near-clean slate in early 2023 but 14 results by March 13, 2024 ### Procedural Posture Filed April 9, 2024, after Guertin dismissed Bruce Rivers and elected to proceed pro se. This affidavit accompanies or supports several concurrent pro se filings, including an April 3, 2024 "Motion for Judicial Notice" and an April 4, 2024 "Motion to Compel Discovery and Affidavit of Fact." Criminal proceedings were suspended pending competency restoration under the January 16-17, 2024 court order. Civil commitment case 27-MH-PR-23-815 was active with a stayed order of commitment. Guertin had agreed to extend the stayed order by 9 months under what he characterizes as duress. ### Exhibit / Attachment Inventory The affidavit includes 32 labeled exhibits spanning pages 53-213: | Exhibit | Description | Pages | |---|---|---| | A | LinkedIn Search and Count Graph Timeline (7 pages, Dec 2020 – Nov 2023) | 53-59 | | B | Special Ops Gear (ODF Optronics EyeBall) and Prototype photos with patent drawing comparison | 60-61 | | C | Text message screenshots with "former CIA welder" (29 images spanning Nov 2022 – Feb 2023) | 62-66 | | D | Military Training Simulations Analysis (Substack post, ChatGPT4 output, 4 pages) | 67-70 | | E | Emails to Bruce Rivers (May 2, 2023) re: FTC report and safety concerns (2 emails) | 71-72 | | F | Email to Bruce Rivers (June 16, 2023) re: AI videos, FBI report, conflict of interest, "powerful people" (3 pages) | 73-76 | | G | Email to Bruce Rivers (August 1, 2023) requesting urgent guidance on civil commitment | 77-78 | | H | Text messages with Bruce Rivers (May 25, 2020 – Jan 29, 2024, 12 screenshot pages) | 79-83 | | I | Call history logs with Bruce Rivers (5 pages of phone records) | 84-85 | | J | Text messages with various friends re: safety concerns; technical discussions with business partner | 86-93 | | K | Comparative patent analysis: InfiniSet vs. Netflix patent (ChatGPT-generated, 2 pages) | 94-95 | | L | Email from Assaff Rawner, CEO of Mark Roberts Motion Control (October 31, 2022) | 96 | | M | Internet Archive account emails (Dec 9 – Dec 29, 2022): signup, welcome, removal policy inquiry and response | 97-101 | | N | Email exchanges with patent attorney Amanda Prose / WCK (Jan 5-6, 2023, 6 pages) | 102-107 | | O | Emails to Michael Biglow (August 1, 2023): evidence submission and single forwarded document | 108-111 | | P | 2019 IRS Wages and Income Transcript (Xite LLC, $218,385 non-employee compensation) | 112 | | Q | Letter from Dr. Martin Schuster, CA Psychiatrist (April 7, 2023, 2 pages) | 113-114 | | R | Handwritten criminal defense notes for meeting with Bruce Rivers | 115 | | S | Letter from WCK (Steven M. Koehler) upon termination of representation (Aug 16, 2023, 3 pages) | 116-118 | | T | AI-generated analysis of January 16-17, 2024 court order language (2 pages) | 119-120 | | U | MCRO criminal history search results (March 13, 2024, 14 results, 6 pages) | 121-126 | | V | Personal cell phone records (Dec 14, 2022 – Feb 13, 2024, multiple billing periods, ~9 pages) | 127-135 | | W | PGP Technical Overview Simplified (educational document, ~9 pages including MxToolbox & DNSChecker output) | 136-144 | | X | LinkedIn email (11/28/2021): US Air Force Academy search — PDF, HTML, PGP header | 145-152 | | Y | LinkedIn email (01/16/2022): US Air Force search — PDF, HTML, PGP header | 153-159 | | Z | LinkedIn email (07/17/2022): Dept of the Air Force search — PDF, HTML, PGP header | 160-166 | | Aa | LinkedIn email (12/17/2022): USC Cinema & US Army Reserve search — PDF, HTML, PGP header | 167-174 | | Ba | LinkedIn email (01/21/2023): Forcepoint & 3Gimbals search — PDF, HTML, PGP header | 175-182 | | Ca | LinkedIn email (02/05/2023): USC Cinema (2nd) search — PDF, HTML, PGP header | 183-190 | | Da | LinkedIn email (07/20/2023): State of Rhode Island search (25 searches record) — PDF, HTML, PGP header | 191-197 | | Ea | LinkedIn email (08/03/2023): DARPA, DIA, INDOPACOM search — PDF, HTML, PGP header | 198-205 | | Fa | LinkedIn email (08/11/2023): US Air Force (4th) & US Dept of State search — PDF, HTML, PGP header + MxToolbox analysis | 206-213 | ### Visual Evidence Inventory - [Pages 53-59] LinkedIn Search & Count Graph (Exhibit A): Seven full-page color timeline graphs on dark backgrounds. Each page is a full-page raster image with the court filing header overlaid. The graphs plot LinkedIn weekly search counts against a timeline of events from Dec 2020 through Nov 2023, with annotated milestones, entity logos, and search counts. Notable visual elements include corporate/government logos (US Air Force, DARPA, Fox, Netflix, Lockheed Martin, etc.) placed alongside corresponding search dates. The graph shows a peak of 25 searches in the week preceding July 20, 2023. Text is small and densely packed. Pages appear to be designed in a graphic design application. An "EXHIBIT A" label with a circular badge/icon appears on page 53 (upper right). - [Page 60] Exhibit B — Patent Design Drawing vs. Prototype Comparison: Full-page composite image showing (left) the patent drawing FIG. 19 and (right) a photograph of the physical prototype. Below this comparison are photos of an ODF Optronics "EyeBall" surveillance device placed on/near the prototype. Annotations include: "ODF Optronics 'globally renowned' EyeBall," "an all seeing eye on Guertin's prototype," "'TARGETED' – ODF Optronics brand identity," and "welder conducts intelligence op tech demo." A circular exhibit badge appears upper right. - [Page 61] Exhibit B continued — Six photographs of prototype welding process, each labeled with EXIF timestamps ranging from January 12-28, 2022. Photos show metal framework/structural components being welded, appearing to be the physical prototype of the InfiniSet system. - [Pages 62-66] Exhibit C — Text message screenshots with "former CIA welder": Multiple phone screenshots (labeled former-CIA-welder-01 through former-CIA-welder-29) showing iMessage conversations. Text is partially legible due to compression and small size. Conversations span November 2022 through February 2023 and include discussions about the patent, alleged fraud, AI, Netflix, and personal safety. Some screenshots contain MMS/image references. An "EXHIBIT C" badge appears on page 62. - [Pages 67-70] Exhibit D — Substack post screenshots showing the military training simulation analysis. Page 67 shows a Substack header with title and a ChatGPT conversation interface screenshot. Pages 68-70 show the text content of the analysis. An exhibit badge appears on page 67. - [Page 71] Exhibit E header — Email from Guertin to Bruce Rivers (May 2, 2023) as rendered Proton Mail printout. Exhibit badge visible upper right. - [Pages 73-76] Exhibit F — Two long emails to Bruce Rivers (June 16, 2023) printed from Proton Mail. Exhibit badge on page 73. - [Pages 77-78] Exhibit G — Email to Bruce Rivers (Aug 1, 2023) and forwarded Biglow Zoom link email. Exhibit badge on page 77. - [Pages 79-83] Exhibit H — Text message screenshots (Bruce-Rivers-Texts-01 through -29): 29 phone screenshots arranged in 3x2 grids per page, showing iMessage conversations with Bruce Rivers from May 2020 through January 2024. The screenshots document discussions about patent filing, legal referrals, expungement inquiries, YouTube channel references, "No court" message exchange, and failed attempts to obtain the Dr. Milz exam report. An "EXHIBIT H" badge appears on page 79. - [Pages 84-85] Exhibit I — Call history screenshots (Bruce-Rivers-Calls-01 through -05): Phone call log screenshots showing dates, times, and durations of calls between Guertin and Rivers spanning November 2022 through January 2024. Exhibit badge on page 84. - [Pages 86-93] Exhibits A (supplemental), H (supplemental), W (supplemental), J, K, and additional text screenshots: These pages contain a dense collage of text message screenshots with friends (labeled A-01 through A-03, H-01/H-02, W-01 through W-15, J-01 through J-04, K-01 through K-07, MS-01, WO-01/WO-02, CN-01/CN-02, S-01 through S-12). Content includes: safety warning messages sent to friends about "powerful people keeping an eye on me"; highly technical discussions about Unreal Engine, TouchDesigner, video plane rendering, and camera systems (demonstrating technical competence); discussions about patent fraud allegations; and personal safety concerns. Some images contain handwritten notes. - [Pages 94-95] Exhibit K — ChatGPT-generated comparative patent analysis text. Exhibit badge on page 94. - [Page 96] Exhibit L — Assaff Rawner email (Oct 31, 2022). Rendered email printout. Exhibit badge visible. - [Pages 97-101] Exhibit M — Internet Archive emails: Account verification (Dec 9, 2:45 AM), welcome email (Dec 9, 2:46 AM), Guertin's removal policy inquiry (Dec 15, 2022), and Internet Archive response via Zendesk (Dec 29, 2022). Exhibit badges visible. - [Pages 102-107] Exhibit N — Email chain with Amanda Prose/WCK (Jan 5-6, 2023): Detailed fraud discussion emails. Prose's responses acknowledge the situation's complexity and support ic3.gov filing. Exhibit badge on page 102. - [Pages 108-111] Exhibit O — Emails to Michael Biglow (Aug 1, 2023): Guertin's proactive evidence submission (16 attachments listed) and Biglow's email forwarding only Dr. Schuster's letter at 2:24 PM (6 minutes before 2:30 PM hearing). Exhibit badge on page 108. - [Page 112] Exhibit P — IRS Wages and Income Transcript (2019): Shows $218,385.00 non-employee compensation from Xite LLC, Calabasas, CA. Contains "Sensitive Taxpayer Data" header banner. Exhibit badge visible. - [Pages 113-114] Exhibit Q — Dr. Martin Schuster letter (April 7, 2023): Two-page typed letter on what appears to be personal letterhead. Contains clinical history since 2016, diagnoses of ADHD and GAD, explicit statement of no psychosis/schizophrenia history, and opinion that Guertin is not at risk of harming anyone. Signature block visible at bottom of page 114 (partially redacted/obscured). Exhibit badge on page 113. - [Page 115] Exhibit R — Handwritten notes: Full-page scan of handwritten meeting preparation notes. Handwriting is in ink, generally legible with some difficulty. Notes cover criminal defense strategy points and explicit requests for discovery materials. Exhibit badge visible. - [Pages 116-118] Exhibit S — WCK termination letter from Steven M. Koehler (Aug 16, 2023): Three-page typed letter on WCK firm letterhead detailing patent matters status, foreign filing deadlines, and return of files. Includes referral to Patent International — contradicting the stated withdrawal reason. Exhibit badge on page 116. - [Pages 119-120] Exhibit T — AI-generated court order analysis (2 pages of formatted analysis text). Exhibit badge on page 119. - [Pages 121-126] Exhibit U — MCRO search results (March 13, 2024): Six-page web printout showing 14 case results dating from 2002-2023, including the civil commitment case, parking violations, DWI, disorderly conduct, and the current criminal case. MCRO logo and page headers visible. Exhibit badge on page 121. - [Pages 127-135] Exhibit V — Cell phone billing records: Multiple pages of detailed call, text, and data usage records from multiple billing periods (Dec 14, 2022 – Feb 13, 2024). Format is standard carrier billing statement with columns for date/time, direction, number, destination, type, and duration. The records corroborate timing of calls described in the affidavit narrative. Data usage section shows significant mobile internet consumption (e.g., 2,510 MB on Dec 16, 2022 — consistent with claimed digital forensic evidence collection). Exhibit badge on page 127. - [Pages 136-144] Exhibit W — PGP Technical Overview: Educational document explaining email authentication via PGP for a non-technical audience. Includes two demonstration outputs: (1) MxToolbox email header analysis of the August 11, 2023 LinkedIn email showing source IP 108.174.0.206 (LinkedIn Corporation, New York), and (2) DNSChecker.org email header analysis showing WHOIS data confirming LinkedIn Corporation IP allocation. Exhibit badge on page 136. - [Pages 145-213] Exhibits X through Fa — LinkedIn notification emails (9 sets, each containing 3 components): Each exhibit set follows the same triple-authentication pattern: 1. **PDF print** of the rendered LinkedIn email showing search count, company logos of searching entities, and Guertin's profile link 2. **Raw HTML source code** of the email with entity names highlighted/bolded in the source (alt text of company logo images reveals searching entity names) 3. **Full PGP email headers** including DKIM signatures, SPF pass results, DMARC pass results, server routing information, and spam scoring All emails originate from LinkedIn's IP range (108.174.x.x), pass DKIM authentication with both linkedin.com and maile.linkedin.com signatures, and are addressed to MattGuertin@Protonmail.com. Each email links to the LinkedIn profile "mattguertin612." Each exhibit page set includes a small circular exhibit badge in the upper right area. ### Key People Referenced | Person | Role | Context | |---|---|---| | Matthew David Guertin | Defendant, Pro Se; Inventor/Founder/CEO of InfiniSet, Inc. | Author of affidavit; DOB 07/17/1981; resides 4385 Trenton Ln N #202, Plymouth, MN 55442 | | Judge Jay Quam | Judge, Fourth Judicial District Court | Named addressee of the affidavit | | Jacqueline Perez | Assistant Hennepin County Attorney | Named addressee; prosecution | | Bruce Rivers | Former defense attorney; YouTube personality ("CLR Bruce Rivers") | Extensive allegations of miscommunication, abandonment, conflict of interest | | Michael Biglow | Court-appointed attorney (civil commitment); Biglow Law Offices, Minneapolis | Alleged inadequate advocacy; forwarded only 1 of 16 documents before hearing | | Dr. Jill Rogstad | Forensic psychologist | Prepared competency evaluation report filed March 10, 2023; met with Guertin March 1, 2023 | | Dr. Adam Milz | Psychologist | Conducted 6-month psychological review via 2-hour Zoom on January 3, 2024; exam report never provided to Guertin | | Dr. Martin Schuster | Guertin's treating psychiatrist (California); clinical trial researcher | Treating since Sept 15, 2016; authored April 7, 2023 letter rebutting Rogstad's findings | | Judicial Referee Danielle C. Mercurio | Judicial Referee, Hennepin County | Drafted and signed Jan 16-17, 2024 court order at 8:27 AM | | Judge Julia Dayton Klein | District Court Judge | Co-signed Jan 16-17, 2024 order at 9:22 AM | | Tom Arneson | Assistant Hennepin County Attorney | Represented plaintiff at January 16 hearing per court order text | | Amanda Prose | Former patent attorney at WCK | Communicated with Guertin about alleged fraud; supported ic3.gov filing | | Steven M. Koehler | Shareholder, Westman, Champlin & Koehler | Authored termination letter; provided referral contradicting withdrawal rationale | | Z. Peter Sawicki | WCK attorney | Initially notified Guertin of firm termination via email Aug 10, 2023 | | Assaff Rawner | CEO, Mark Roberts Motion Control (UK) | Pointed Guertin to PhotoRobot "Virtual Catwalk"; alleged mastermind of fraud per Guertin | | Paul Debevec | Researcher, Netflix/EyeLine Studios/USC-ICT | Featured in SIGGRAPH 2023 video; alleged participant in Round 2 fraud | | Stephan Trojansky | Patent applicant (Netflix acquisition ~$100M) | Filed patent application 12 days after Guertin's provisional; US20220319115A1 | | "Former CIA welder" (name redacted) | Associate of Guertin; welding contractor | Welded prototype Jan 2022; text conversations about fraud; alleged FBI/Secret Service connections | | Lea DeSouza | Hennepin County (civil commitment proceedings) | CC'd on Biglow's email forwarding Dr. Schuster letter | | Dr. Alpert | Guertin's general practitioner (California) | Referred Guertin to Dr. Schuster in 2016 | ### Key Entities / Organizations Referenced InfiniSet, Inc. (Guertin's company), Netflix Inc., PhotoRobot (Czech Republic), Mark Roberts Motion Control (UK), Internet Archive (archive.org/Wayback Machine), USC School of Cinematic Arts / USC-ICT, YouTube/Google/Alphabet, EyeLine Studios, Xite LLC (Calabasas, CA / XiteLabs), Westman Champlin & Koehler P.A. (WCK), Biglow Law Offices, Hennepin County District Court (Fourth Judicial District), Hennepin County Attorney's Office, Minnetonka Police Department, FBI, FTC, US Secret Service (Minneapolis/Chicago), UK Serious Fraud Office (SFO), USPTO, United States Air Force / Air Force Academy / Dept of the Air Force, United States Army / Army Reserve, USC-ICT, DARPA, Defense Intelligence Agency (DIA), U.S. Indo-Pacific Command (INDOPACOM), U.S. Department of State, State of Rhode Island, Forcepoint, 3Gimbals, ODF Optronics, Fox Entertainment / Fox Corporation / Fox Network Group, A&E Networks, Walt Disney Company, Lockheed Martin, Moody's Analytics, Warner Bros Discovery / Warner Media, Uber Freight, UKG (Ultimate Kronos Group), MSG Entertainment / Sphere Entertainment, Datadog, Morgan Stanley, Bain and Company, Thermo Fisher Scientific, John Hopkins Bloomberg School of Public Health, Brigham and Women's Hospital, University of Rhode Island, Raytheon/Triple Inc, UPTV, Janes Defence, Pixxel, Boise State University, KBR Inc (Halliburton), Newsmax, Relievant Medical, Kimberly Clark, United Health Group, NFL Network, Henry Street Settlement, Origami Energy Tech, Spillt, Silverspoon Animation, HealthEdge, Sensi Media, Cape Cod Community College, Bay Path University, Worcester State University, Gentle Giant Studios, InHance Digital, Hubbard Broadcasting, Reelz, Australian Capital Territory, Realize Medical, Ottawa Hospital & University, Epic Games, Exeter Hospital/Beth Israel Lahey Health, Silverstein Properties, Proton Mail, CompForensics.com, Carney Forensics, DigitalInvestigations.com, TouchDesigner/Derivative, Unreal Engine, PRG (lighting), disguise (media server), BlackTrax/CAST Software, PLSN (publication), ic3.gov, MAXQDA, Dropbox ### Dates & Deadlines Mentioned | Date | Event | |---|---| | Late 2020 | MattGuertin.com created; LinkedIn profile established | | ~Feb 3, 2021 | InfiniSet concept conceived | | ~Mar 19, 2021 | Guertin files provisional patent | | Mar 30-31, 2021 | Trojansky files his patent application | | Jun 2021 | Netflix allegedly hires Paul Debevec | | Jun 30, 2021 | EyeLine Studios registered with CA SOS | | Nov 14, 2021 | Netflix acquisition press release (~$100M to Trojansky) | | Nov 28, 2021 | First LinkedIn search: US Air Force Academy | | Jan 16, 2022 | LinkedIn: US Air Force search | | Jan 31, 2022 | Prototype welding completed | | Mar 18, 2022 | Guertin files patent application | | Mar 27, 2022 | Netflix files patent application | | Jul 17, 2022 | LinkedIn: Dept of the Air Force search | | Oct 31, 2022 | Assaff Rawner email pointing to PhotoRobot | | Nov 6, 2022 | Guertin discovers Trojansky/Netflix patent application | | Dec 5, 2022 | Text exchange with former CIA welder about Netflix/patent | | Dec 9, 2022 | PatentlyFalse Internet Archive account created (2:45 AM); website archiving begins | | Dec 15, 2022 | Guertin contacts Internet Archive about removal policy | | Dec 17, 2022 | LinkedIn: USC Cinema & US Army Reserve search | | Dec 23-24, 2022 | Text exchanges; archive count discrepancy discovered | | Jan 5-6, 2023 | Email exchanges with patent attorney about alleged fraud | | Jan 12, 2023 | Minnetonka PD Police Report #23-000151 filed | | Jan 14, 2023 | Text to welder about FBI/fraud evidence | | Jan 15, 2023 | Calls to forensic services, Secret Service (22 min), incoming call from welder | | Jan 18-19, 2023 | AI video discovery; second visit to Minnetonka PD (lobby closed); black SUVs | | Jan 21, 2023 | **Firearm discharge incident — police/SWAT response** | | Jan 21, 2023 | LinkedIn: Forcepoint & 3Gimbals search | | Jan 25, 2023 | First court appearance; $50,000 bail posted | | Feb 5, 2023 | LinkedIn: USC Cinema (2nd search) | | Feb 14, 2023 | US Patent 11,577,177 officially granted | | Feb 20, 2023 | 3rd Party Prior Art Submission against Netflix approved by USPTO | | Mar 1, 2023 | Meeting with Dr. Jill Rogstad | | Mar 10, 2023 | Dr. Rogstad's evaluation report filed | | Apr 7, 2023 | Dr. Schuster letter authored | | May 2, 2023 | Email to Bruce Rivers about FTC report and safety concerns | | May 3, 2023 | FBI (ic3.gov) and FTC fraud reports filed | | May 19, 2023 | UK Serious Fraud Office report filed | | May 22, 2023 | Rivers tells Guertin about "powerful people" (phone call at 3:13 PM) | | May 23, 2023 | Guertin sends safety warning messages to friends | | Jun 6/16, 2023 | Email to Rivers about conflict of interest, "powerful people," FBI report | | Jul 7, 2023 | Omnibus court hearing; competency contest attempted | | Jul 20, 2023 | **Order of Civil Commitment filed (27-MH-PR-23-815)** | | Jul 20, 2023 | LinkedIn: State of Rhode Island search; all-time record 25 searches in one week | | Jul 28, 2023 | Guertin discovers civil commitment via Biglow letter; texts Rivers | | Aug 1, 2023 | Civil commitment hearing (Zoom); Guertin not represented by Rivers; Biglow forwards only 1 document | | Aug 3, 2023 | LinkedIn: DARPA, DIA, INDOPACOM search | | Aug 4, 2023 | Stayed Order of Commitment granted | | Aug 8, 2023 | Paul Debevec SIGGRAPH video discovered | | Aug 9, 2023 | "Emergency" email to Amanda Prose | | Aug 10, 2023 | Email to entire WCK firm; dropped as client | | Aug 11, 2023 | LinkedIn: US Air Force (4th) & US Dept of State search; 18 searches in one week | | Aug 16, 2023 | WCK termination becomes official; Koehler letter and IP files returned | | Sep 19, 2023 | International patent filing deadline (from PCT/US2022/020919) | | Nov 7, 2023 | Netflix patent US 11,810,254 B2 published | | Oct 18, 2023 | EPO filing deadline | | Jan 3, 2024 | Dr. Adam Milz 6-month review (2-hour Zoom) | | Jan 15, 2024 | Rivers texts "No court" and "Nothing has changed" | | Jan 16, 2024 | Incompetency order signed (Mercurio 8:27 AM, Klein 9:22 AM) without Guertin's knowledge/consent | | Jan 17, 2024 | Order filed in case 27-CR-23-1886 at 7:29 AM | | Jan 26, 2024 | Guertin requests Milz exam report from Rivers (text + email) | | Jan 28-29, 2024 | Follow-up attempts to reach Rivers | | Jan 30, 2024 | Pro se "Motion for Production of Medical Records" and "Motion for Continuance" filed in civil case | | Jan 31, 2024 | Agreement to extend Stayed Order of Commitment by 9 months (under alleged duress) | | Mar 13, 2024 | MCRO criminal history search showing repopulated records | | Apr 3, 2024 | Pro se "Motion for Judicial Notice" filed in criminal case | | Apr 4, 2024 | Pro se "Motion to Compel Discovery and Affidavit of Fact" filed | | **Apr 9, 2024** | **This Affidavit of Fact filed** | | Jul 2024 | Next scheduled competency review (per Jan 16-17 order) | ### Forensic Flags & Anomalies 1. **Consent/Due Process Flag:** The January 16, 2024 court order states "the parties agreed to a finding of incompetency entered administratively" — but Guertin's text exchange with Rivers the evening before shows Rivers stating "No court" and "Nothing has changed," directly contradicting any knowing agreement. The order was signed hours before the scheduled 1:30 PM hearing time, suggesting pre-preparation. 2. **Attorney Conduct Flag:** Bruce Rivers' alleged statement about "powerful people keeping an eye on" Guertin, followed by refusal to discuss over phone, followed by later denial in person, raises questions about attorney candor or potential coercion/intimidation. 3. **Selective Forwarding Flag:** Biglow's forwarding of only 1 of 16 documents to the examiner and opposing counsel — 6 minutes before the hearing — raises concerns about adequacy of representation at a critical juncture. 4. **Discovery Manipulation Flag:** Guertin references fraudulent discovery materials received from Biglow on August 3, 2023, detailed in his separate April 4, 2024 filing. He also claims the only discovery he ever received was from Biglow, not from Rivers. 5. **Criminal History Repopulation Flag:** The sudden reappearance of historical records (2002-2012) in the MCRO system between early 2023 and early 2024, including records from outside Hennepin County and petty misdemeanor parking tickets, warrants investigation into whether records were manually re-activated. 6. **Attorney Termination Timing Flag:** WCK's termination of the attorney-client relationship came immediately after Guertin raised Netflix fraud allegations and occurred just before critical international patent filing deadlines (Sept 19 and Oct 18, 2023). The firm's stated reason (no adverse effect) contradicts the referral letter acknowledging ongoing need for patent counsel. 7. **LinkedIn Search Pattern Flag:** The correlation between government/military LinkedIn profile searches and critical case dates (especially the all-time peak of 25 searches in the week before the civil commitment filing) is asserted but requires independent verification. The automated LinkedIn emails do pass DKIM/SPF/DMARC authentication per the PGP headers provided, which authenticates that the emails were genuinely sent by LinkedIn. However, LinkedIn search appearance notifications reflect which entity profiles the searchers are associated with, not necessarily who authorized the searches. 8. **PDF Metadata Note:** Document was created April 9, 2024 using LibreOffice 7.3 "Draw" (not Writer), modified using iText 7.1.16 (Minnesota Judicial Branch licensed version) on April 30, 2024. The modification date (April 30) is later than the filing date (April 9), suggesting the court's e-filing system processed/stamped the document after filing. 9. **Document Scale Flag:** At 213 pages, this pro se affidavit is extraordinarily voluminous and includes extensive raw HTML source code from LinkedIn emails, full PGP headers, phone billing records, and other technical data that would typically be presented in a more condensed or summarized format in a court filing. 10. **"Former CIA Welder" Flag:** The individual's name is redacted throughout but his alleged CIA affiliation, his timely phone call immediately after Guertin's Secret Service conversation, and his early reference to AI as the mechanism behind the alleged fraud all raise questions about this person's actual identity and role. ### Cross-References - References April 3, 2024 pro se "Motion for Judicial Notice" filed in 27-CR-23-1886 (contains Exhibits Xa, Ya, Qb, Rb referenced herein) - References April 4, 2024 pro se "Motion to Compel Discovery and Affidavit of Fact" filed in 27-CR-23-1886 (details alleged fraudulent discovery materials from Biglow) - References civil case 27-MH-PR-23-815 (Commitment - Mentally Ill) - References Minnetonka PD Police Report #23-000151 (filed Jan 12, 2023) - References Dr. Jill Rogstad competency evaluation report (filed Mar 10, 2023) - References January 16-17, 2024 court order by Referee Mercurio/Judge Klein - References January 30, 2024 pro se "Motion for Production of Medical Records" (civil case) - References January 30, 2024 pro se "Motion for Continuance" (civil case) - References July 20, 2023 Order of Civil Commitment - References August 4, 2023 Stayed Order of Commitment - References WCK's USPTO withdrawal filing under 37 CFR 11.116(b)(1) - References FBI ic3.gov report (filed May 3, 2023) - References FTC report (filed May 3, 2023) - References UK SFO report (filed May 19, 2023) - Filing #1 — Motion for Judicial Notice (Apr 3, 2024) — heavily cross-referenced throughout - Filing #2 — Affidavit of Fact (May 6, 2024) — shares extensive overlapping evidence and arguments --- ## Filing #4 — Defendant's Motion to Submit Evidence Exhibits B and C Into the Official Record (with Exhibits B & C attached) | Field | Detail | |---|---| | Filing # | 4 | | Date Filed | April 14, 2025, 10:30 AM | | Filed By | Matthew David Guertin, Defendant Pro Se (while represented by counsel) | | Document Type | Motion to Submit Evidence Exhibits + Attached Exhibits B & C | | Case/Court | 27-CR-23-1886 / Hennepin County District Court, Fourth Judicial District | | Pages | 46 total (4-page motion + 27-page Exhibit B + 15-page Exhibit C) | | Bates / Doc ID | 129___Exhibits-B-C_Brodsky-USPTO-Patent-Fraud__2025-04-14.pdf | ### Comprehensive Summary This filing is a pro se motion by Defendant Matthew David Guertin seeking to admit into the official court record two additional evidence exhibits — Exhibit B (Brodsky Patent Fraud Presentation) and Exhibit C (Brodsky Patent Forensic Analysis). The Defendant states he is proceeding pro se for this specific motion while simultaneously represented by counsel on other aspects of the case. **The Motion (Pages 1–4):** The 4-page motion is addressed to Judge Sarah Hudelston, Hennepin County Attorney Mary F. Moriarty, and Assistant County Attorney Mawerdi Ahmed Hamid. Guertin argues the exhibits are relevant, material, and authenticated under the Sixth and Fourteenth Amendments and Minnesota Rules of Evidence 401–403. He contends the exhibits support the factual foundation established in a prior Exhibit A ("Netflix Whistleblower is Found Alive and Well – Part 1") and that together they form a documented sequence of fraud. He argues the exhibits are relevant to: (1) the credibility of mental health assessments filed against him; (2) the factual legitimacy of his intellectual property claims; and (3) the broader motive and backdrop behind his prosecution. The motion characterizes the exhibits as directly contradicting the basis for labeling the Defendant "psychotic," "delusional," or otherwise impaired. The Defendant describes the exhibits as having been prepared using "established forensic techniques" containing citations to publicly available federal patent filings and metadata. He requests the Court admit both exhibits and acknowledge their relevance to the question of whether his claims of corporate patent theft and government collusion are "rooted in evidence or illness." The concluding language is confrontational in tone, describing the U.S. Patent and Trademark system as "a weaponized infrastructure, engineered not to protect innovation, but to usurp it — through advanced AI manipulation, strategic surveillance, and institutional protocols designed to retroactively rewrite digital history on demand." The motion is signed with an electronic signature (/s/ Matthew D. Guertin), listing address as 4385 Trenton Ln. N 202, Plymouth, MN 55442, phone 763-221-4540, email MattGuertin@protonmail.com, website www.MattGuertin.com. **Exhibit B — Brodsky Patent Fraud Presentation (Pages 5–31, labeled Exhibit B pp. 1–27):** A 27-page document styled as a comprehensive legal-technical analysis of alleged fraud in U.S. Patent 11,383,062 (the "Brodsky Patent"), assigned to Newton VR Ltd. and invented by Yuval Brodsky. The report systematically compares the Brodsky patent against InfiniSet Inc.'s U.S. Patent 11,577,177, which covers a motorized rotatable treadmill system for immersive virtual environments, invented by Matthew Guertin and assigned to InfiniSet, Inc. The report is organized into 14 sections: *Section 1 — Executive Summary:* Alleges the Brodsky patent evolved through claim amendments introduced after InfiniSet's confidential provisional filing (March 19, 2021) but before public disclosure, incorporating elements that mirror InfiniSet's core innovations. Highlights that both patents share the same publication date (September 22, 2022) as statistically improbable. Notes Stephan Trojansky filed a duplicate patent application just 12 days after InfiniSet's provisional filing. References a Netflix $100 million investment in South Korea on May 20, 2022, featuring Scanline VFX head Trojansky alongside KOTRA President Yu Jeong-yeol and Trade Minister Ahn Duk-geun. States LinkedIn search data shows significant spikes on Guertin's dormant profile by Netflix-connected entities. *Section 2 — Introduction:* Restates the comparison framework and alleges the Brodsky patent is a "deliberate, strategically fraudulent attempt to appropriate and preempt InfiniSet's pioneering technology." *Section 3 — Background and Context:* Details InfiniSet's patent (US 11,577,177), which features a proprietary pancake slip ring for uninterrupted power/data transfer during 360° rotations, an endless-loop belt mechanism for omnidirectional locomotion, and AI-driven feedback control systems. Describes the Brodsky patent (US 11,383,062) as originally focused on a gravity simulation system that later underwent claim amendments adding omnidirectional treadmill integration, locomotion support systems, and immersive visual stimulation systems. The InfiniSet provisional filing is dated March 19, 2021. The Brodsky original filing is identified as 2016. Both were published September 22, 2022. *Section 4 — Timeline Anomalies and Publication Date Synchronization:* Argues the synchronized publication date is statistically unlikely, and that Brodsky's continuation claims were amended after InfiniSet's provisional filing but before publication, suggesting insider knowledge. *Section 5 — Strategic Claim Amendments Targeting InfiniSet's Innovations:* Five subsections detail alleged overlap: (5.1) Integration of an Omnidirectional Treadmill — Brodsky's revised claims reference a "locomotion support device" paralleling InfiniSet's endless-loop belt; (5.2) Immersive Visual Stimulation Systems — Brodsky's "visual stimulation system" mirrors InfiniSet's LED/green screen film set integration; (5.3) Multidirectional Movement and System Control — Brodsky's claims for 360-degree, multi-degree-of-freedom movement overlap with InfiniSet's synchronization system; (5.4) Implicit Incorporation of Supportive Infrastructure — Brodsky references a "communication bus" that suggests continuous operation capability similar to InfiniSet's slip ring mechanism; (5.5) Summary of Alignment. *Section 6 — Ambiguities in Terminology and Blurred Definitions:* Argues Brodsky's use of "Omnidirectional Treadmill" (ODT) to simultaneously refer to passive (bowl-like surface), active (motorized belt), and dynamic (shape-shifting actuators) embodiments violates definiteness requirements under 35 U.S.C. § 112. Contrasts this with InfiniSet's precise mechanical descriptions. *Section 7 — Technical and Mechanical Inconsistencies:* Details conflicting embodiments in Brodsky's treadmill design, identifies impractical harness configurations (original vs. alternate with slender pistons), and notes inadequate power distribution claims (single small battery claimed to power all components without detailed power management). *Section 8 — Procedural and Disclosure Irregularities:* Four subsections cover: (8.1) Inadequate and overbroad disclosure; (8.2) Retroactive claim amendments and timing issues; (8.3) Missing Israeli priority document IL265092A — searches in major patent databases failed to locate this referenced priority document; (8.4) Examiner oversight and procedural lapses. *Section 9 — Forensic Analysis of Patent Drawings:* Reports analysis using pixel distribution, compression artifact detection, color/grayscale examination, and frequency domain analysis. Concludes drawings are digitally created using high-precision CAD/vector tools and intentionally post-processed to simulate scanned images. Fourier Transform results reveal radial symmetry consistent with algorithmically generated images. *Section 10 — Evidence Suggesting High-Level Fraud:* Synthesizes all findings into six subsections alleging preemptive claim amendments, synchronized publication anomalies, ambiguous terminology, missing historical records, examiner oversight, and corroboration from both patent disclosures. *Section 11 — Additional Timeline and Corporate Evidence:* Profiles key individuals and entities: Stephan Trojansky (founder of Scanline VFX and Eyeline Studios, CEO of Eyeline, inventor on US Patent 11,810,254 assigned to Netflix); Matthew Guertin (CEO of InfiniSet, inventor of US 11,577,177); Netflix (acquired Scanline VFX/Eyeline Studios, $100M South Korea deal); Brodsky (Yuval Brodsky, Tel Aviv, Newton VR Ltd., Tel Aviv-Yafo). Provides detailed timeline of suspicious events: - March 19, 2021: InfiniSet provisional filing - March 31, 2021: Trojansky's duplicate application (12 days later) - November 22, 2021: Netflix acquires Scanline VFX/Eyeline Studios (~$100M) - May 20, 2022: Netflix announces $100M South Korea VFX investment (ceremony in The Korea Times with Trojansky, KOTRA President Yu Jeong-yeol, Trade Minister Ahn Duk-geun) - June 8, 2022: Brodsky continuation filing - June 24, 2022: KIPO completes PCT search on InfiniSet's application - November 7, 2023: Netflix Patent 11,810,254 granted Reports LinkedIn evidence showing a search of Guertin's dormant profile in the week leading up to May 21, 2022, by UPtv — an organization linked to executives including Alan Sokol and Tom Daschle with ties to Sony Pictures Digital Productions, Lockheed Martin, Telemundo, and the US Air Force. *Section 12 — Broader Implications and Impact on USPTO Integrity:* Discusses market disruption, systemic examination issues, and calls for congressional/regulatory review. *Section 13 — Recommendations and Strategic Responses for InfiniSet:* Recommends post-grant review, inter partes review, litigation preparation, patent claim strengthening, cross-licensing negotiations, and formal report to USPTO. *Section 14 — Conclusion:* Restates all findings and calls for aggressive legal challenges. **Exhibit C — Forensic Analysis of U.S. Patent 11,383,062 (Brodsky Patent) File History (Pages 32–46, labeled Exhibit C pp. 1–15):** A 15-page forensic analysis in two parts examining the USPTO Image File Wrapper (IFW) documents for Application 16/329,231. *Part 1 — Image Grid Forensics of IFW Documents:* Analyzed 18 composite image grids (ID 01.png through 18.png), each containing six pairs of IFW document pages. Left images are originals; right images are processed (grayscale threshold with inverted colors). Key findings: - Regular 16×16 pixel tiling patterns detected in applicant-submitted documents — described as a "checkerboard or lattice overlay" visible in thresholded images, symptomatic of digitally rendered images rather than genuine scans. - Unnatural grayscale banding — entire regions flip from light to dark at 40–80% threshold settings, indicating artificially flat gray values not consistent with physical paper scans. - Lack of anti-aliasing on text — jagged, pixel-stepped edges with no intermediate shades, suggesting digital typesetting rather than scanned text. - Uniform background and tone — consistent gray level corner-to-corner, unlike real scans with uneven lighting and paper texture. - Critical finding: anomalies appear ONLY in externally submitted (applicant/attorney) documents, NOT in USPTO-generated documents. Cross-referenced with USPTO Patent Center record for Application 16/329,231. - Examples compared: Preliminary Amendment (Feb. 28, 2019) shows checkerboard pattern; Non-Final Rejection (May 28, 2020) shows irregular noise consistent with genuine scan. An attorney email printout's signature line and firm logo show identical pixel intensity across each 16×16 cell. *Part 2 — Audit of Prosecution History and Procedural Anomalies:* Chronological review of USPTO dossier: Initial Filing (Feb.–July 2019): Application entered U.S. national phase Feb. 28, 2019 from PCT application WO2018/042442. Duplicate document entries found (Specification as doc #02 and #17, Claims as #03 and #18, etc.). Missing Oath/Declaration noted. Multiple permission documents and formality correspondence on May 7, 2019. First Examination Phase (2020): Non-Final Office Action date discrepancy (labeled "Paper No. 20200511" but officially dated May 28, 2020). No applicant-filed IDS — all prior art from examiner. Applicant's Amendment filed Aug. 27, 2020 (docs #44–50) exhibits digital artifacts. Final Rejection Nov. 25, 2020. Second Examination Phase (2021–2022): After-Final response and AFCP request Jan. 2021. RCE filed Feb. 25, 2021. Four examiner interviews total — described as "far above average": 1. Jan 7/21, 2021 — post-final-rejection interview 2. Mar 16, 2021 — post-RCE interview 3. Oct 28, 2021 — telephonic interview 4. Mar 9, 2022 — interview on date of allowance Key mislabeled documents: "Appendix to the specification" (Doc #59, 01/21/2021) is actually an email from attorney Mordechai Americus to Examiner Moore providing an interview agenda. "Office Action Appendix" (Doc #89, 11/02/2021) is actually an interview agenda for Oct 28, 2021 telephonic interview. Dual Notices of Allowance: Mar 9, 2022 (doc #97) and Mar 31, 2022 (doc #104) — described as "highly unusual." Comments on Reasons for Allowance filed May 25, 2022, signed by attorney Mark M. Friedman. Issue Fee paid June 7, 2022. Patent issued July 12, 2022 as US 11,383,062. "Smoking Guns" summary: (1) Digitally fabricated applicant submissions evidenced by 16×16 grid artifacts exclusive to incoming documents; (2) Mischaracterized documents in file (email buried as "appendix to specification"); (3) Heavy off-record communication via four interviews; (4) Timeline coordination with third-party events (claim amendments mirroring competitor technology, same-day publication); (5) Dual Notice of Allowance; (6) No appeal and quick turnaround despite significant prior art overlap. ### Legal Issues & Arguments Raised - Defendant's Sixth and Fourteenth Amendment right to present evidence in his defense - Minnesota Rules of Evidence 401–403 (relevance, materiality, unfair prejudice balancing) - Credibility of mental health assessments filed against the Defendant - 35 U.S.C. § 112 — Indefiniteness and enablement deficiencies in Brodsky patent claims - Allegations of patent fraud through retroactive claim construction - Allegations of insider access to confidential USPTO filing data - Allegations of coordinated corporate-level patent theft involving multiple entities - Allegations of USPTO procedural failures and examiner oversight - Allegations of digitally fabricated documents submitted to the USPTO (IFW forensics) - Allegations of mislabeled/mischaracterized documents in the patent prosecution file ### Factual Allegations & Key Assertions - Brodsky Patent (US 11,383,062) claim amendments were introduced after InfiniSet's confidential provisional filing (March 19, 2021) but before its public disclosure, incorporating elements mirroring InfiniSet's core innovations - Both patents published on the same date (September 22, 2022) — characterized as statistically improbable - Stephan Trojansky filed a duplicate patent application just 12 days after InfiniSet's provisional filing (March 31, 2021) - Netflix acquired Scanline VFX/Eyeline Studios for approximately $100 million (November 22, 2021) - Netflix announced $100M South Korea investment on May 20, 2022, featuring Trojansky alongside Korean officials — timed days before Brodsky's June 8, 2022 continuation filing - KIPO completed PCT search on InfiniSet's application June 24, 2022, only 16 days after Brodsky's continuation — for the first time, Brodsky references appeared as prior art against InfiniSet - LinkedIn search spikes on Guertin's dormant profile by Netflix-connected entities, including UPtv (linked to Alan Sokol, Tom Daschle, Sony Pictures Digital Productions, Lockheed Martin, Telemundo, US Air Force) - Israeli priority document IL265092A referenced by Brodsky patent family cannot be located in public databases - 16×16 pixel grid artifacts detected exclusively in applicant-submitted IFW documents, not in USPTO-generated documents - Attorney email mislabeled as "Appendix to the specification" in prosecution file - Interview agenda mislabeled as "Office Action Appendix" - Two Notices of Allowance issued (March 9 and March 31, 2022) without explanation - Patent drawings are digitally generated and post-processed to simulate scanned appearance - Netflix Patent 11,810,254 granted November 7, 2023 with Trojansky as inventor, despite InfiniSet's patent listed as prior art ### Procedural Posture This filing is a pro se motion to admit evidence into the record of a criminal case. The Defendant is charged in a criminal matter (nature of charges not specified in this filing but referenced in context of mental health evaluations). The Defendant has been subject to Rule 20 psychiatric evaluations. This filing follows a prior Exhibit A submission ("Netflix Whistleblower is Found Alive and Well – Part 1") and is filed simultaneously with Filing #5 (Exhibits D–G). The motion explicitly addresses the Defendant's argument that his patent fraud claims are evidence-based rather than evidence of mental illness. ### Exhibit / Attachment Inventory | Exhibit | Title | Pages | Description | |---|---|---|---| | Exhibit B | Brodsky Patent Fraud Presentation (US Patent 11,383,062 — High Level Patent Fraud Presentation) | 27 (pp. 5–31) | Comprehensive legal-technical analysis alleging fraud in the Brodsky patent through systematic comparison with InfiniSet's patent, timeline anomaly analysis, and corporate evidence | | Exhibit C | Forensic Analysis of U.S. Patent 11,383,062 (Brodsky Patent) File History | 15 (pp. 32–46) | Two-part forensic investigation: (Part 1) Image grid forensics of IFW documents detecting 16×16 pixel tiling artifacts; (Part 2) Audit of prosecution history identifying procedural anomalies | ### Visual Evidence Inventory - **[Page 42 / Exhibit C p. 11] USPTO Certified Copy of Foreign Priority Application:** Image of a U.S. Patent and Trademark Office certification document dated September 12, 2017. The document certifies a true copy from USPTO records for Application Number 62/382,279, Filing Date September 01, 2016. The certification bears a cursive signature identified as the Under Secretary of Commerce for Intellectual Property and Director of the United States Patent and Trademark Office (signature appears to read "Michelle K. Lee" or similar). The document includes the ornate "THE UNITED STATES OF AMERICA / TO ALL TO WHOM THESE PRESENTS SHALL COME" header with decorative border and eagle seal. Below the certification is the USPTO seal (circular seal with eagle). The caption reads "14__Certified-Copy-of-Foreign-Priority-Application__02-28-2019-02_.png." A large watermark is visible across the entire page reading "MINNESOTA JUDICIAL" in diagonal text — this is a court filing watermark. The annotation below states "Externally submitted document | Original on the left – Processed on the right." - **[Page 43 / Exhibit C p. 12] Comparison Pair — PCT Abstract and USPTO Notice:** Two side-by-side comparison images. TOP PAIR: Left side shows an original PCT International Application cover page (WO 2018/042442 A1) published March 08, 2018, titled "IMMERSIVE MULTISENSORY SIMULATION SYSTEM," with a technical drawing showing a figure on a platform with various numbered components (Fig. 1A). The applicant is listed as NEWTON VR LTD. (IL); inventors include BRODSKY, Yuval and SHAPIRO, Alexander, with others. Agent is listed as FRIEDMAN, Mark, Modia Aviv Tower, 54th Floor. Right side shows the same document after threshold processing — visible grid artifacts (diagonal striped pattern of black and white blocks) are clearly visible in the processed version, demonstrating the 16×16 pixel tiling anomaly described in the report. Caption reads "20__Abstract__02-28-2019-1_.png." Annotation states the grid artifacts are produced by selecting gray pixels in 40-80% range and making them black, everything else white. BOTTOM PAIR: Left side shows an internal USPTO document — "Notice of Missing Requirements — Mailed" dated 05-07-2019, from USPTO to Dr. Mark M. Friedman regarding Application 16/329,231, First Named Inventor Yuval BRODSKY, Atty. Docket No. 63783. Lists missing items including Small Entity Status, Priority Document, various copies of international filings, fees, etc. Right side shows the same after threshold processing — no grid artifacts visible, displaying only random noise consistent with genuine scanned documents. Caption: "27__Notice-of-DO_EO-Missing-Requirements-Mailed__05-07-2019-1_.png." This pair directly demonstrates the contrast between applicant-submitted documents (showing artifacts) and USPTO-generated documents (showing no artifacts). - **[Page 44 / Exhibit C p. 13] Figure 1 — Processed Applicant-Submitted Document:** Upper portion shows a patent drawing (Fig. 1A from the Brodsky patent) depicting an isometric view of a person standing on a platform/treadmill assembly with numbered components (208, 601, 200, 206, 237, 50, 205, 207, 236, 240, 20, 226, 260, 401, 225a, 4, 230, 242, 401, 225b, 2, 103). The drawing shows a figure standing on what appears to be a circular treadmill platform with mechanical supports. Below the drawing is a large processed (thresholded) image showing the same page — a predominantly black background with visible grid patterns and scattered light pixels, demonstrating the 16×16 pixel tiling artifact. The caption reads: "Figure 1: Processed image of an applicant-submitted document (Brodsky patent file) revealing a uniform 16×16 pixel grid artifact in the background. This synthetic-looking checkerboard pattern suggests the page was computer-generated - likely using an AI image generation model - rather than a natural scan." - **[Page 45 / Exhibit C p. 14] Processed Foreign Priority Application Certificate:** Full-page processed/thresholded version of the USPTO certification document from Page 42. The processed image shows a dramatic black-and-white diagonal striped pattern with clearly visible regular tiling across the entire document area. The certification text box and USPTO seal are still partially visible but surrounded by the pronounced artificial pattern. The text from the original certificate is partially readable in the processed version. This image serves as evidence of the digital artifact pattern in the externally submitted priority document. - **[Page 46 / Exhibit C p. 15] Block Diagram with Grid Artifacts:** Upper portion shows a technical block diagram labeled "Single MSS Station" depicting a system architecture with a "Software Bus" connecting multiple control modules (ODT Control, GMS Control, Tactile Control, Body Tracking Control, Visualization Control, Audio Control, Atmospheric Control) to corresponding device modules below. A connection to "other MSS Stations" is shown on the left, and what appears to be a server/database icon on the upper right. Below the block diagram is a full-page processed image showing extremely pronounced diagonal striped tiling patterns — alternating black and white diagonal bands covering the entire lower portion of the page. This is described as one of the most dramatic examples of the 16×16 pixel tiling artifact, with the regular pattern being unmistakable evidence of digital generation according to the report. ### Key People Referenced | Person | Role/Affiliation | Context | |---|---|---| | Matthew David Guertin | Defendant; CEO of InfiniSet, Inc.; Inventor of US Patent 11,577,177 | Filing party; alleges patent fraud targeting his invention | | Sarah Hudelston | Judge, Hennepin County District Court | Presiding judicial officer | | Mary F. Moriarty | Hennepin County Attorney | Prosecution | | Mawerdi Ahmed Hamid | Assistant Hennepin County Attorney | Prosecution | | Yuval Brodsky | Inventor, based in Tel Aviv, Israel | Named inventor on US 11,383,062; alleged participant in fraud | | Stephan Trojansky | Founder of Scanline VFX and Eyeline Studios; CEO of Eyeline; Patent inventor | Filed duplicate patent application March 31, 2021; inventor on Netflix's US 11,810,254; photographed in South Korea ceremony | | Mordechai Americus | Attorney for Brodsky patent applicant | Sent email to Examiner Moore mislabeled as "Appendix to the specification" | | Mark M. Friedman | Attorney for Brodsky patent applicant (Dr.) | Signed Comments on Statement of Reasons for Allowance; listed as agent on PCT filing | | Examiner Moore | USPTO Patent Examiner | Examined Application 16/329,231 | | Alan Sokol | Executive linked to UPtv | Referenced in connection with LinkedIn surveillance of Guertin | | Tom Daschle | Political figure linked to UPtv | Referenced in connection with LinkedIn surveillance; ties to government/military entities | | Yu Jeong-yeol | KOTRA President | Photographed with Trojansky at South Korea ceremony | | Ahn Duk-geun | South Korean Trade Minister | Photographed with Trojansky at South Korea ceremony | ### Key Entities / Organizations Referenced | Entity | Context | |---|---| | InfiniSet, Inc. | Guertin's company; holder of US Patent 11,577,177 | | Newton VR Ltd. (Tel Aviv-Yafo, Israel) | Assignee/applicant on Brodsky patent US 11,383,062 | | Netflix, Inc. | Acquired Scanline VFX/Eyeline Studios; assignee of US Patent 11,810,254; $100M South Korea deal | | Scanline VFX | Trojansky's VFX company, acquired by Netflix | | Eyeline Studios | Trojansky's company, acquired by Netflix | | USPTO (United States Patent and Trademark Office) | Granted allegedly fraudulent patents; alleged procedural failures | | KIPO (Korean Intellectual Property Office) | Conducted PCT search on InfiniSet's application | | KOTRA (Korea Trade-Investment Promotion Agency) | Involved in Netflix/South Korea ceremony | | UPtv | Linked to LinkedIn surveillance of Guertin | | Sony Pictures Digital Productions | Linked to UPtv executives | | Lockheed Martin | Linked to UPtv executives | | Telemundo | Linked to UPtv executives | | US Air Force | Linked to UPtv executives | | The Korea Times | Reported on Netflix $100M South Korea deal ceremony | | Hennepin County District Court | Case venue | ### Dates & Deadlines Mentioned | Date | Event | |---|---| | September 1, 2016 | Brodsky provisional/priority application filing date (62/382,279) | | September 12, 2017 | USPTO certified copy of foreign priority application | | March 8, 2018 | PCT Publication WO2018/042442 A1 | | February 28, 2019 | Brodsky application enters US national phase; Preliminary Amendment filed | | May 7, 2019 | USPTO Notice of Missing Requirements | | June 17, 2019 | Response to Pre-Exam Formalities | | October 10, 2019 | Application published as US 2019/0307982 A1 | | May 28, 2020 (possibly May 11, 2020) | Non-Final Office Action (date discrepancy flagged) | | August 27, 2020 | Applicant's Amendment/Request for Reconsideration | | November 25, 2020 | Final Rejection | | January 7, 2021 | Applicant interview request | | January 12, 2021 | Attorney Americus email (mislabeled in IFW) | | January 21, 2021 | Examiner interview held | | January 25, 2021 | After-Final response and AFCP request | | February 25, 2021 | RCE filed | | March 16, 2021 | Examiner interview (post-RCE) | | March 19, 2021 | InfiniSet provisional filing date (US 11,577,177) | | March 31, 2021 | Trojansky's duplicate patent application (12 days after InfiniSet) | | April 18, 2021 | Supplemental Amendment filed; Applicant interview summary filed | | August 16, 2021 | New Non-Final Rejection | | October 28, 2021 | Telephonic interview | | November 4, 2021 | Applicant's Amendment response | | November 22, 2021 | Netflix acquires Scanline VFX/Eyeline Studios | | March 9, 2022 | First Notice of Allowance; Examiner interview; Interview Summary | | March 31, 2022 | Second Notice of Allowance | | May 20, 2022 | Netflix $100M South Korea announcement | | May 21, 2022 | LinkedIn search alert — UPtv search of Guertin's profile | | May 25, 2022 | Comments on Statement of Reasons for Allowance | | June 7, 2022 | Issue Fee paid | | June 8, 2022 | Brodsky continuation filing | | June 22, 2022 | Issue Notification | | June 24, 2022 | KIPO completes PCT search on InfiniSet | | July 12, 2022 | Patent US 11,383,062 issued | | September 22, 2022 | Both InfiniSet and Brodsky patents published (same date) | | November 7, 2023 | Netflix Patent 11,810,254 granted | | April 14, 2025 | This motion filed | ### Forensic Flags & Anomalies 1. **Pro se filing while represented by counsel:** Defendant explicitly states he is proceeding pro se "for this motion" while represented by counsel — unusual procedural posture suggesting possible disagreement with counsel on this filing strategy. 2. **16×16 pixel tiling artifacts in IFW documents:** The central forensic claim is that applicant-submitted documents in the Brodsky patent prosecution exhibit regular digital tiling patterns not present in USPTO-generated documents, suggesting fabrication or digital manipulation. Visual evidence provided in pages 43–46 shows dramatic contrast between processed applicant vs. USPTO documents. 3. **Missing Israeli priority document IL265092A:** Exhaustive searches in public patent databases reportedly failed to locate this foundational document, disrupting the priority chain. 4. **Dual Notices of Allowance (March 9 and March 31, 2022):** Two NOAs issued without intervening action or explanation — characterized as "highly unusual." 5. **Mislabeled prosecution documents:** Attorney email categorized as "Appendix to the specification" (Doc #59); interview agenda categorized as "Office Action Appendix" (Doc #89) — could indicate intentional obfuscation or clerical error. 6. **Date discrepancy in Office Action:** Non-Final Rejection labeled "Paper No. 20200511" (May 11) but officially dated May 28, 2020. 7. **Duplicate document entries at national phase entry:** Same documents appear to be entered twice (Specification as doc #02 and #17, etc.). 8. **Four examiner interviews:** Described as "far above average," creating potential for off-record negotiation. 9. **Synchronized publication date:** Both InfiniSet and Brodsky patents published September 22, 2022. 10. **12-day gap between InfiniSet filing and Trojansky's duplicate application:** March 19 to March 31, 2021. 11. **Pattern of threshold-processed images showing artificial tiling in applicant documents:** The visual evidence presented is the most tangible forensic claim in this filing — the comparison images on pages 43–46 show a stark difference between applicant-side and USPTO-side documents. 12. **Tone and rhetoric of motion:** Confrontational language ("expose the machine," "weaponized infrastructure") may affect judicial reception. 13. **No independent expert authentication disclosed:** The forensic analysis appears to be prepared by or for the Defendant, with no named independent forensic expert or professional credentials cited. ### Cross-References - References Exhibit A ("Netflix Whistleblower is Found Alive and Well – Part 1") — prior filing, not in this batch - Filed simultaneously with Filing #5 (Exhibits D–G, same date 4/14/2025) - InfiniSet US Patent 11,577,177 - Brodsky US Patent 11,383,062 (Application 16/329,231) - Netflix US Patent 11,810,254 - PCT Publication WO2018/042442 - Israeli Patent IL265092A (referenced but reportedly missing) --- --- ## Filing #5 — Defendant's Motion to Submit Evidence Exhibits D, E, F, and G Into the Official Record (with Exhibits D–G attached) | Field | Detail | |---|---| | Filing # | 5 | | Date Filed | April 14, 2025, 10:33 AM | | Filed By | Matthew David Guertin, Defendant Pro Se (while represented by counsel) | | Document Type | Motion to Submit Evidence Exhibits + Attached Exhibits D, E, F, and G | | Case/Court | 27-CR-23-1886 / Hennepin County District Court, Fourth Judicial District | | Pages | 36 total (4-page motion + 11-page Exhibit D + 11-page Exhibit E + 7-page Exhibit F + 3-page Exhibit G) | | Bates / Doc ID | 130___Exhibits-D-E-F-G_Netflix-Academic-Patent-Fraud__2025-04-14.pdf | ### Comprehensive Summary This is a companion pro se motion filed three minutes after Filing #4, seeking admission of four additional evidence exhibits (D through G) into the official court record. The Defendant again states he is proceeding pro se for this motion while represented by counsel. **The Motion (Pages 1–4):** Addressed to Judge Hudelston, County Attorney Moriarty, and Assistant County Attorney Hamid. The motion characterizes the four exhibits as exposing "systemic misconduct, intellectual property targeting, and academic falsification campaigns" that have surrounded and shaped the context of the criminal charges. Guertin argues these exhibits "unmask the architecture of the fraud itself" and that ignoring them "would expose this Court to future scrutiny not just for oversight, but for willful suppression of verified, properly filed, and independently sourced evidence." The legal basis asserted is the Sixth and Fourteenth Amendments (U.S. Constitution) and Article I, Section 6 of the Minnesota Constitution, plus Minnesota Rules of Evidence 401–403. The Defendant contrasts the exhibits with the mental health reports filed against him, stating the evaluators "repeatedly failed to interview him, cite underlying evidence, or acknowledge procedural contradictions." The central factual claim is that three purported 2006 USC ICT papers (authored by or attributed to Paul Debevec and colleagues) describe technology that could not have existed in 2006, were likely fabricated or backdated after InfiniSet's 2021 filing, and were strategically distributed to create a false narrative of prior art targeting InfiniSet's US Patent 11,577,177. Relief sought: (1) Admit Exhibits D–G; (2) Acknowledge relevance to claims of fraud, retaliatory evaluation, and targeted suppression; (3) Take judicial notice of contradictions between these exhibits and Rule 20 psychiatric reports; (4) Preserve the filings for appeal, civil litigation, and federal review. The motion closes with confrontational language: "Either it permits these exhibits and confronts the facts, or it contributes to a growing public file of complicity." Signed identically to Filing #4. **Exhibit D — Overview of Netflix/Debevec Patent Fraud (Pages 5–15, labeled Exhibit D pp. 1–11):** An 11-page forensic analysis report styled as a comprehensive overview of suspected fraudulent prior art targeting US Patent 11,577,177. Integrates Matthew Guertin's August 10, 2023 email to WCK LLP (Westman, Champlin, Koehler — described as "his Minneapolis IP Firm") with two independent research reports. *Section I — Executive Summary:* Lists key findings: fraudulent prior art (2006 papers exhibit anachronistic claims, self-referential citations, lack of independent corroboration); targeted overlap with InfiniSet's patent; duty of candor violations by Netflix/Trojansky; legal and financial implications. *Section II — Background:* Details Guertin's discovery of Paul Debevec's SIGGRAPH 2023 presentation showing a motorized rotatable treadmill at the 59-minute mark of a "Light Stage" video, citing a purported 2006 research paper. Notes USC Cinema and US Army Reserves both conducted LinkedIn searches of Guertin's profile during the same week following his discovery. Discusses material risks to Netflix investors including SEC scrutiny under Rule 10b-5, shareholder lawsuit risk, loss of investor trust, and regulatory penalties. Characterizes Netflix's "half-billion-dollar bet on Trojansky's 'invention'" as "a house-of-cards scenario for shareholder value." *Section III — Analysis of Fraudulent Prior Art:* Three subsections: (A) Technological Implausibility — Papers claim to process 10 million images in 40 seconds using 2006-era hardware (0.1 teraflops vs. 2014's 2 teraflops). Authentic sources confirm markerless motion capture was error-prone in 2006. Papers never cited in authoritative surveys. (B) Self-Referential and Anachronistic Citations — Debevec served as Vice President of SIGGRAPH (2008–2011), undisclosed during his 2023 SIGGRAPH presentation. Over 50% of the 2006 papers' references cite SIGGRAPH-affiliated work. Closed citation loop with only USC-ICT authors. Inconsistent institutional naming ("Centers for Creative Technologies" vs. "Institute for Creative Technologies"). (C) Overlap with InfiniSet's Patent — Table comparing three patent claims: (1) Motorized treadmill + turntable — 2006 paper describes "Treadmill placed on turntable" (Sec. 1.1); (2) Retroreflective surfaces — paper describes "Retroreflective treadmill surface" (Sec. 5.1); (3) Synchronized motion control — paper describes "Time-synced cameras and lighting" (Sec. 4). *Section IV — Legal Implications:* Three subsections: (A) Duty of Candor Violations (37 CFR § 1.56) — Argues Netflix/Trojansky failed to disclose the 2006 papers despite direct knowledge through Debevec's collaboration with Eyeline Studios. Notes Debevec presented the "Light Stage" treadmill at SIGGRAPH 2023, citing his own 2006 paper, and included Trojansky's name in the "Special Thanks" credits. Presents two mutually exclusive conclusions: either the papers are legitimate (in which case duty of candor was violated by withholding material art) or they are fraudulent (in which case duty of candor was violated by concealing fabrication). Either constitutes inequitable conduct under Therasense, Inc. v. Becton, Dickinson & Co. (Fed. Cir. 2011). Notes that it was only through Guertin's successful third-party prior art submission that InfiniSet's patent was officially included in Netflix's granted patent. (B) Antitrust and Fraud Claims — Alleges the 2006 papers were fabricated after March 19, 2021 and retroactively dated to 2006. Claims papers were cited as prior art in Debevec's 2015 patent (US 8,988,599) after InfiniSet's filing, implying USPTO records were tampered with. Papers were strategically distributed to DTIC.mil, IEEE Xplore, and university databases. Alleges Sherman Act § 2 violations (predatory monopolization, market foreclosure, consumer harm). Alleges fraudulent use of .mil domain implicating federal systems. Alleges tortious interference with business relationships. (C) Recommended Actions — Forensic audit of USPTO records for Debevec's 2015 patent; subpoena DTIC.mil and academic hosts; DOJ criminal referral under 18 U.S.C. § 371 and § 1030; antitrust litigation under Sherman Act § 2; Civil RICO (18 U.S.C. § 1962); California UCL claims; USPTO post-grant review petitions; "Fraudulent Prior Art" appendix in international patent applications. *Section VI — Conclusion:* Characterizes the scheme as "a recent, malicious campaign to retroactively invalidate InfiniSet's patent through fabricated prior art, corrupt USPTO records, and abuse of government platforms." **Exhibit E — Chronological Contradictions: Exposing Fraudulent 2006 Prior Art Targeting InfiniSet's Motorized Treadmill Patent (Pages 16–26, labeled Exhibit E pp. 1–11):** An 11-page analytical report examining the three purported 2006 papers: "Relighting Character Motion for Photoreal Simulations," "Relighting Human Locomotion with Flowed Reflectance Fields," and "Virtual Cinematography: Relighting through Computation." Organized into several major sections: *Plenoptic Function and Light Field Claims:* Argues the papers overstate the extent of what was achieved. Notes that a 2015 source states dense light field recording is "still a high-dimensional, difficult problem." The papers give the impression of near-complete plenoptic capture of a human performance, but the method actually captured only a "highly constrained subset" requiring perfectly repeatable cyclic motion and a turntable-synchronized 3-camera rig. *Conflicts with Authentic Sources:* Cites the Rearden LLC v. Walt Disney Company complaint describing MOVA Contour's debut at SIGGRAPH 2006 as the actual breakthrough of that era. Notes the MOVA complaint never mentions the USC papers. Argues that if the USC system worked as advertised, it would have been similarly adopted for films — the absence of adoption proves the papers' claims are overstated. *Technological Implausibilities in 2006:* Details the enormous data requirements (potentially 10 million+ images per take), the processing limitations of 2006-era hardware, and the lack of real-time output or live demonstrations. Notes that even by 2018, methods were still emerging to handle challenging performances with hybrid sensor setups. Cites HybridFusion (2018) noting TotalCapture used "more than 500 cameras." *Citation and Reference Anomalies:* Two of three papers share nearly the same author list and content. "Relighting Character Motion" admits it "overviews the techniques and results presented by [Einarsson et al, 2006]" — the companion paper. Identifies this as a "self-referential loop." The tech report includes a government contract number and DoD "Report Documentation Page" with Nov 1, 2006 approval date. None published in premier venues (SIGGRAPH or top journals). Reference lists stop at 2005. Inconsistent institutional naming between papers. *Additional Inconsistencies:* Lack of follow-up publications after 2006; triumphal tone without quantitative error analysis or limitation discussion; duplicated language between papers; suspicious clustering of three publications in mid-2006; heavy use of buzzwords. Sources cited: The three 2006 papers themselves; "Breaking the Barriers to True Augmented Reality" (arxiv, 2015); "HybridFusion: Real-Time Performance Capture" (ECCV 2018); Rearden LLC v. The Walt Disney Company complaint (4:17-cv-04006). **Exhibit F — Beyond the Uncanny Valley: How 2006 Technological Limits Disprove the USC ICT Papers' Validity (Pages 27–33, labeled Exhibit F pp. 1–7):** A 7-page report using "The Uncanny Valley in Games and Animation" (Tinwell, 2014) as sole authoritative source to discredit the 2006 papers. *2006: State of the Art vs. Extraordinary Claims:* Discusses the "Mary Smith" tech demo at E3 2006 (Quantic Dream's "The Casting" on PlayStation 3), which was criticized as uncanny, with unnatural expressions, wooden facial movement, and asynchronous lip-sync. Arguments: if a true solution for photoreal human rendering existed in 2006, such failures would not have plagued high-profile demos. Notes no reference to any 7D "plenoptic" capture achievement in 2006 in Tinwell's comprehensive survey. *Expert Testimony:* Cites Peter Plantec's 2007 prediction that a fully believable virtual human was "two more years" away, directly contradicting any claim of a 2006 breakthrough. Cites Plantec's 2008 declaration that Image Metrics' "Emily" project "finally built a bridge across the Uncanny Valley" — noting this was a collaboration with Paul Debevec's team at USC. Argues that Plantec's astonishment at the 2008 achievement proves nothing comparable existed in 2006. *Technical Feasibility:* Details limitations of markerless motion capture (citing Kehl & Van Gool, 2006), complexity of high-fidelity reflectance capture (Emily project required specialized scanning of individual skin pores in 2008), and rendering/data processing power (Digital Ira 2013 required "nearly five trillion mathematical operations per second" and two teraflops — vs. 2006's ~0.1 teraflop hardware). *Lack of Peer Recognition:* Notes Tinwell's book cites numerous 2006–2010s milestones but never mentions the three USC relighting papers. Debevec is credited for Digital Emily (2008) and Digital Ira (2013) but no 2006 relighting achievement. Absence from unbiased survey literature characterized as "highly conspicuous." Source cited: "The Uncanny Valley in Games and Animation" (Tinwell, 2014); the three 2006 papers. **Exhibit G — Illusion by Design: The 2006 Academic Fabrication Targeting InfiniSet's 'Illusion of Movement' Patent (Pages 34–36, labeled Exhibit G pp. 1–3):** A compact 3-page report analyzing specific overlaps between the 2006 paper "Relighting Human Locomotion with Flowed Reflectance Fields" and InfiniSet's US Patent 11,577,177. Five areas of overlap identified: 1. **Core Apparatus — Rotating Treadmill + Turntable:** Patent Claims 1, 4, 8–10 cover a motorized treadmill on a turntable; the 2006 paper describes "a treadmill placed on a turntable that 'slowly rotates the person's direction'" (Sec. 1.1, Fig. 1). 2. **Retroreflective/Matte Surfaces for Compositing:** Patent Claims 12–13 describe monochrome/green screen surfaces; the 2006 paper uses a "retroreflective treadmill surface" and gray background (Sec. 5.1, Fig. 6). 3. **Synchronized Motion Control:** Patent Claims 14–16 involve synchronizing treadmill speed with camera movement; the 2006 paper adjusts speeds to match the subject's "natural walking/running cycle" (Sec. 4). 4. **Integration with Virtual Environments:** Patent Claims 12–13, 24–26 describe LED/green screen environments; the 2006 paper composites subjects into "real and virtual environments" using alpha channels and shadows. 5. **Safety and Calibration Features:** Patent Claims 8–10 mention tactile references ("shallow channels") for user positioning; the 2006 paper uses "shallow channels cut into the board beneath the treadmill belt" (Sec. 3). Additionally identifies patent-specific element targeting: floor lights for ground-plane illumination (Patent Claim 4 vs. 2006 paper's "140 floor light units" in Sec. 3); vibration cues for user positioning (Patent Claims 5–6 vs. 2006 paper's "tracking frames" in Sec. 4). Concludes the 2006 paper "appears strategically constructed to invalidate InfiniSet's patent." ### Legal Issues & Arguments Raised - Sixth and Fourteenth Amendment right to present a complete defense (U.S. Constitution) - Article I, Section 6 of the Minnesota Constitution (right to present evidence) - Minnesota Rules of Evidence 401–403 (relevance, authentication, unfair prejudice) - Allegations of fabricated/backdated academic prior art (three purported 2006 USC ICT papers) - 37 CFR § 1.56 — Duty of Candor violations by Netflix/Trojansky in patent prosecution - Inequitable conduct under Therasense, Inc. v. Becton, Dickinson & Co. (Fed. Cir. 2011) - Sherman Act § 2 — predatory monopolization through fabricated prior art - 18 U.S.C. § 371 — conspiracy to defraud the United States - 18 U.S.C. § 1030 — computer fraud (altering USPTO records) - 18 U.S.C. § 1962 — Civil RICO (pattern of racketeering) - California Unfair Competition Law (UCL) - Tortious interference with business relationships - SEC Rule 10b-5 — failure to disclose material fraud to investors - Credibility challenge to Rule 20 psychiatric evaluations - Judicial notice request regarding contradictions between exhibits and psychiatric reports ### Factual Allegations & Key Assertions - Three purported 2006 USC ICT papers were fabricated or backdated after InfiniSet's March 19, 2021 filing to create false prior art - The 2006 papers describe technology (7D plenoptic capture, processing 10 million images in 40 seconds) that was impossible with 2006-era hardware (0.1 teraflops) - Paul Debevec presented at SIGGRAPH 2023 showing a motorized rotatable treadmill at the 59-minute mark, citing his own 2006 paper, while including Trojansky in "Special Thanks" - Debevec was Vice President of SIGGRAPH (2008–2011) and failed to disclose this during his 2023 presentation - The 2006 papers have a "closed citation loop" with only USC-ICT authors cited; over 50% of references are SIGGRAPH-affiliated - The papers were never cited in authoritative surveys (e.g., Tinwell 2014) or industry milestone documentation - The 2006 papers were strategically distributed to DTIC.mil, IEEE Xplore, and university databases after 2021 - The papers were allegedly inserted into Debevec's 2015 patent (US 8,988,599) records after InfiniSet's filing - USC Cinema and US Army Reserves conducted LinkedIn searches of Guertin's profile in the same week following his discovery of the alleged fraud - The "Mary Smith" demo at E3 2006 and Peter Plantec's 2007–2008 statements confirm photoreal human rendering was unsolved until at least 2008 - Emily project (2008) was headed by Debevec himself — the first perceived crossing of the uncanny valley - MOVA Contour's 2006 SIGGRAPH debut was the actual recognized breakthrough of that era - The Rearden LLC v. Walt Disney Company complaint never mentions the USC papers - None of the three 2006 papers were published in premier venues (SIGGRAPH proceedings or top journals) - Reference lists in the papers stop at 2005, with no post-2006 follow-up publications - Inconsistent institutional naming ("Centers for Creative Technologies" vs. "Institute for Creative Technologies") ### Procedural Posture Filed simultaneously with Filing #4 (three minutes later). Part of a sequence of evidence submissions beginning with a prior Exhibit A. The Defendant seeks to build a documentary record supporting his defense that his patent fraud claims are factually grounded rather than delusional, specifically to counter Rule 20 psychiatric evaluations. The request for judicial notice and preservation for appeal/civil litigation/federal review signals the Defendant's intent to use these filings beyond the criminal case. ### Exhibit / Attachment Inventory | Exhibit | Title | Pages | Description | |---|---|---|---| | Exhibit D | Overview of Netflix/Debevec Patent Fraud (Forensic Analysis Report: Suspected Fraudulent Prior Art Targeting US Patent 11,577,177) | 11 (pp. 5–15) | Overview synthesizing Guertin's August 2023 email to WCK LLP with two research reports; covers duty of candor violations, antitrust claims, and recommended legal actions | | Exhibit E | Chronological Contradictions: Exposing Fraudulent 2006 Prior Art Targeting InfiniSet's Motorized Treadmill Patent | 11 (pp. 16–26) | Detailed analysis of three 2006 papers' plenoptic function claims, conflicts with authentic sources, technological implausibilities, and citation anomalies | | Exhibit F | Beyond the Uncanny Valley: How 2006 Technological Limits Disprove the USC ICT Papers' Validity | 7 (pp. 27–33) | Analysis using Tinwell (2014) as sole authoritative source to demonstrate 2006 technology could not support the papers' claimed achievements | | Exhibit G | Illusion by Design: The 2006 Academic Fabrication Targeting InfiniSet's 'Illusion of Movement' Patent | 3 (pp. 34–36) | Claim-by-claim comparison of the 2006 paper "Relighting Human Locomotion" against InfiniSet's US Patent 11,577,177 | ### Visual Evidence Inventory - **[No images/visual elements in this PDF]** — This filing is entirely text-based with no photographs, screenshots, diagrams, stamps, or other visual elements. All pages appear to be native PDF text (not scanned). ### Key People Referenced | Person | Role/Affiliation | Context | |---|---|---| | Matthew David Guertin* | Defendant; CEO of InfiniSet, Inc.; Inventor of US Patent 11,577,177 | Filing party; alleges academic fraud targeting his patent | | Sarah Hudelston* | Judge, Hennepin County District Court | Presiding judicial officer | | Mary F. Moriarty* | Hennepin County Attorney | Prosecution | | Mawerdi Ahmed Hamid* | Assistant Hennepin County Attorney | Prosecution | | Paul Debevec | USC ICT researcher; former VP of SIGGRAPH (2008–2011); Eyeline Studios collaborator | Co-author/attributed author of 2006 papers; presented at SIGGRAPH 2023; led Emily Project (2008); involved with Digital Ira (2013); co-author on US 8,988,599 | | Stephan Trojansky* | CEO of Eyeline Studios; founder of Scanline VFX; Netflix patent inventor | Named in Debevec's SIGGRAPH 2023 "Special Thanks"; sole alleged inventor of technology assigned to Netflix | | Peter Plantec | Animation author/expert | 2007: predicted photoreal human 2 years away; 2008: declared Emily crossed uncanny valley | | Angela Tinwell | Author, "The Uncanny Valley in Games and Animation" (2014) | Sole authoritative source for Exhibit F; comprehensive survey of realistic animation milestones | | Per Einarsson (et al.) | USC ICT researchers | Authors of "Relighting Human Locomotion with Flowed Reflectance Fields" (2006) | | Mary Smith | Virtual character (Quantic Dream's "The Casting") | E3 2006 demo criticized for uncanny effects — cited as evidence of 2006 technology limitations | | Kehl & Van Gool | Researchers (markerless mo-cap, 2006) | Cited in Tinwell (2014) for limitations of 2006 markerless capture | \* = Previously referenced in Filing #4 ### Key Entities / Organizations Referenced | Entity | Context | |---|---| | InfiniSet, Inc.* | Guertin's company; holder of US Patent 11,577,177 | | Netflix, Inc.* | Acquired Scanline VFX/Eyeline; assignee of patents; alleged participant in fraud scheme | | USC ICT (University of Southern California Institute for Creative Technologies) | Origin of purported 2006 papers; Debevec's institutional affiliation; funded by US Army/US Military | | SIGGRAPH (ACM Special Interest Group on Computer Graphics) | Venue for Debevec's 2023 presentation; Debevec was VP 2008–2011 | | Eyeline Studios* | Trojansky's company; Debevec collaborator | | Scanline VFX* | Trojansky's VFX company | | WCK LLP (Westman, Champlin, Koehler) | Guertin's Minneapolis IP law firm; recipient of August 10, 2023 email | | USPTO* | Patent office; alleged procedural failures and record tampering | | DTIC.mil (Defense Technical Information Center) | US DoD platform; allegedly used to host fraudulent 2006 papers | | IEEE / IEEE Xplore | Published "Virtual Cinematography" article; academic repository | | Eurographics | Published symposium paper "Relighting Human Locomotion" | | SEC (Securities and Exchange Commission) | Referenced regarding potential Rule 10b-5 investigation of Netflix | | FTC (Federal Trade Commission) | Referenced regarding potential antitrust action | | DOJ (Department of Justice) | Referenced regarding potential criminal referral | | USC Cinema | Referenced for LinkedIn surveillance of Guertin (Dec. 2022, Feb. 2023) | | US Army / US Military | Funds USC ICT; US Army Reserves conducted LinkedIn search of Guertin | | Image Metrics | Company behind Emily project (2008) — first perceived uncanny valley crossing | | Quantic Dream | Developed "The Casting" / Mary Smith demo (E3 2006) | | Rearden LLC | Plaintiff in Rearden LLC v. Walt Disney Company (4:17-cv-04006); developed MOVA Contour | | MOVA Contour | Facial performance capture system debuted at SIGGRAPH 2006 | | Hennepin County District Court* | Case venue | \* = Previously referenced in Filing #4 ### Dates & Deadlines Mentioned | Date | Event | |---|---| | 2006 (mid-year) | Purported date of three USC ICT papers; E3 2006 Mary Smith demo; MOVA Contour debut at SIGGRAPH 2006 | | November 1, 2006 | Government approval date on "Relighting Character Motion" tech report | | 2007 | Peter Plantec predicts photoreal humans "two more years" away | | 2008 | Emily Project — first perceived crossing of uncanny valley (Debevec + Image Metrics) | | 2008–2011 | Debevec served as VP of SIGGRAPH | | 2013 | Digital Ira project (USC ICT / NVIDIA) | | 2015 | Debevec's US Patent 8,988,599 (alleged post-2021 insertion of 2006 paper references) | | March 19, 2021* | InfiniSet provisional filing | | August 10, 2023 | Guertin's email to WCK LLP describing his discovery | | 2023 (SIGGRAPH) | Debevec's "Light Stage" presentation at 59-minute mark | | December 2022, February 2023 | USC Cinema LinkedIn surveillance of Guertin | | April 14, 2025 | This motion filed | \* = Previously referenced in Filing #4 ### Forensic Flags & Anomalies 1. **Academic papers allegedly fabricated/backdated:** Central allegation that three 2006 papers were created after March 2021 and retroactively distributed — an extraordinary claim requiring extraordinary evidence. The supporting arguments are primarily circumstantial (technological implausibility, citation patterns, lack of peer recognition) rather than forensic metadata analysis of the actual documents. 2. **No forensic metadata analysis of the 2006 papers themselves:** Unlike Exhibit C's pixel-level analysis of Brodsky IFW documents, Exhibits E and F rely on contextual/historical analysis rather than direct digital forensics of the 2006 paper files (creation dates, PDF metadata, server upload timestamps, etc.). This is a notable gap given the claim that the papers were fabricated post-2021. 3. **Sole-source methodology in Exhibit F:** Using only one book (Tinwell 2014) as the authoritative source for an entire analytical report is methodologically limited and potentially vulnerable to challenge. 4. **Debevec's dual role:** The report establishes that Debevec is both an author of the allegedly fraudulent 2006 papers AND a collaborator with Netflix/Trojansky via Eyeline Studios AND was VP of SIGGRAPH AND led the Emily project that "crossed the uncanny valley" in 2008 — this web of connections is either evidence of a conspiracy or evidence of a prominent researcher's normal career trajectory in a specialized field. 5. **Claim of DTIC.mil hosting as evidence of government abuse:** Characterizing papers hosted on a .mil domain as evidence of "exploitation of government infrastructure for corporate espionage" and "national security implications" is aggressive framing that may not withstand scrutiny — DTIC commonly hosts defense-funded research. 6. **Pro se filing while represented by counsel:** Same procedural note as Filing #4 — filed three minutes later, suggesting both were prepared together as a coordinated submission. 7. **Request for judicial notice of contradictions with Rule 20 reports:** This is a strategic move to formally link the patent fraud claims to the competency evaluation proceedings. 8. **Confrontational closing language:** "Either it permits these exhibits and confronts the facts, or it contributes to a growing public file of complicity" — this rhetoric may affect judicial reception. 9. **USC Cinema LinkedIn surveillance timing:** Alleged LinkedIn searches by USC Cinema coinciding with Guertin's discovery of prior patent fraud (the "PhotoRobot / Web Archive" fraud referenced but not detailed) — if verified, this surveillance pattern is significant, but no authentication documentation is provided in this filing for the LinkedIn data. 10. **Scope creep from criminal defense:** The motion's recommendations section includes federal criminal referrals, SEC investigations, civil RICO, and antitrust litigation — far exceeding the scope of a state criminal defense motion. ### Cross-References - References Exhibit A ("Netflix Whistleblower is Found Alive and Well – Part 1") — prior filing, not in this batch - Filed simultaneously with Filing #4 (Exhibits B & C, same date 4/14/2025) - References "Round 1" fraud involving PhotoRobot, Mark Robert's Motion Control, and the Web Archive — prior investigation, details not in this batch - InfiniSet US Patent 11,577,177* - Netflix US Patent 11,810,254* - Debevec US Patent 8,988,599 - Netflix applications US20220319115A1 and WO2022212761A1 - Rearden LLC v. The Walt Disney Company (4:17-cv-04006) - Therasense, Inc. v. Becton, Dickinson & Co. (Fed. Cir. 2011) - Guertin's August 10, 2023 email to WCK LLP \* = Previously referenced in Filing #4 --- --- ## Filing #6 — Affidavit: The Attempted Assassination of Matthew Guertin | Field | Detail | |---|---| | Filing # | 6 | | Date Filed | April 28, 2025 at 10:18 AM | | Filed By | Matthew David Guertin, Defendant Pro Se | | Document Type | Affidavit (sworn declaration under penalty of perjury) | | Case/Court | 27-CR-23-1886 / Hennepin County District Court, Fourth Judicial District | | Pages | 21 | | Bates / Doc ID | Filename: 141__Affidavit__Attempted-Assassination-of-Matthew-Guertin__2025-04-28.pdf; MCRO Index not specified in document | ### Comprehensive Summary This 21-page sworn affidavit, filed pro se by defendant Matthew David Guertin, presents what the filer characterizes as the results of a self-conducted forensic audit of 163 case files centered on his own criminal case (27-CR-23-1886). The core allegation is that a "synthetic court ecosystem" exists within the Hennepin County 4th Judicial District — a system of AI-generated or fabricated court records, dockets, defendants, and psychiatric evaluations — and that this system was constructed and deployed specifically to target Guertin for permanent institutional elimination through psychiatric commitment. The affidavit is structured in nine numbered sections (Roman numerals I–IX) and proceeds as follows: **Section I — Exposing a Synthetic Court Ecosystem:** Guertin claims that his forensic audit of 163 case files reveals a "completely fabricated 'synthetic court' matrix." He asserts that dozens of filings and entire dockets were AI-generated or doctored, not genuine judicial actions. He cites repeated boilerplate text, "impossible procedural loops," and "cloned metadata" across unrelated cases. He specifically identifies identical conditional release terms appearing word-for-word across multiple cases as evidence of mass templating rather than genuine judicial action. He further claims that scanned envelopes and letterhead show repeated USPS stamps and identical handwriting — "cloning artifacts" indicating digital assembly, not unique physical mailings. He concludes the evidence portrays an orchestrated scheme to manufacture false grounds for declaring him incompetent or committing him. **Section II — Fabricated Filings With Many Red Flags:** This section is divided into three subsections: - **II.A (Mass-Production of Synthetic Case Files):** Guertin claims "stylometric analysis" confirms non-human authorship across the 163-case dataset. He cites boilerplate language reused mechanically, identical punctuation, carbon-copied conditional-release instructions, and "template drift" (e.g., AI misspelling names inconsistently such as "Makis Devil Lane" vs. "Makis Duvell Lane"). - **II.B (Troubled Nunns and Misbehaving Priests):** Guertin highlights specific defendant names he considers fabricated: "Priest Jesus Dorsey" (combining a religious title as a first name with a common surname) and "Angelic Denise Nunn" / "Angelic Denise Schaefer" (an unexplained surname change and a rare first name suggesting AI-generated name drift). - **II.C (Repeat, Repeat, Repeat, Offenders):** Guertin identifies defendants with allegedly implausible numbers of case files. He names "Lucas Patrick Kraskey" as a name tied to a large number of "Finding of Incompetency" orders across 2020–2023, and "Terrell Johnson" as associated with approximately 10 case numbers from 2019–2023. He asserts these are synthetic personas recycled to mass-produce court orders. **Section III — Filing Sequence and Docket Deconstruction:** This section details what Guertin calls "Case Flow Cloning" — a scripted procedural loop he claims is repeated across the synthetic cases: - **III.A (An Established Pattern):** Guertin identifies an 8-step pattern: (1) Case initiation, (2) Boilerplate interim release conditions, (3) Bench warrant cycle (defendant "fails to appear"), (4) Returned mail entries with similar handwriting/stamp artifacts, (5) Rule 20 evaluation orders (often assigning Dr. Adam Milz), (6) Incompetency findings, (7) Hearing resets and conditional release, (8) Loop/Repeat. He specifically references duplicate returned mail filings in cases 27-CR-17-1555, 27-CR-17-8342, and 27-CR-17-22909 as proving that "origin" cases dating back to 2017 were themselves fabricated. - **III.B (Case Flow Cloning):** Guertin asserts the mathematical odds of dozens of independent defendants following identical docket sequences are "effectively zero." He cites temporal anomalies (filings timestamped within seconds of each other indicating batch backdating), index irregularities (missing or skipped docket numbers with retroactive insertions), and the "Sandra Vongsaphay" case as an example. - **III.C (Authenticity):** Guertin contrasts the alleged synthetic cases with his own, which he claims contains "organic irregularities" (defense motions, family interventions, appeal filings) that no synthetic case can replicate. He characterizes the synthetic ecosystem as a "pipeline of failure" designed to generate the appearance of "hopeless incompetency and permanent disposal." **Section IV — The Mother's Letter: A Smoking-Gun AI Duplication:** Guertin describes what he calls the most irrefutable single piece of evidence: - **IV.A (Communication Intercept):** On April 12, 2024, Guertin's mother mailed a handwritten letter to Judge Jay Quam. It was docketed at 2:10 PM but instead of reaching Quam, it was diverted to Judge Julia Klein's clerk, Lee Cuellar, who replied under Judge Klein's name at 4:42 PM. Guertin claims that at 2:03 PM the same day, a fabricated individual named "Sandra Phitsanoukanh Vongsaphay" sent a letter from jail echoing the same tone and requests, and Cuellar responded to Sandra at 4:38 PM using identical language and format. - **IV.B (AI Generated Clone Created of Authentic Letter):** Guertin claims forensic examination shows his mother's envelope and handwriting are genuine, while Sandra's envelope bears identical Forever-stamp markings and fonts found in known "synthetic return mail." - **IV.C (Smoking Gun):** Guertin asserts that injecting the duplicate plea into the record allowed the system to dismiss the real mother's letter as "just another inmate letter," camouflaging it in synthetic noise. **Section V — The Entire Simulation was Downloaded A Year Ago:** Guertin describes how he obtained and analyzed the 163-case dataset: - **V.A (Targeting the Control Structure):** He describes manually printing MCRO search results for Judges Klein, Mercurio, and Borer (up to 200 hearings per judge), converting PDFs to text using pdftotext, writing custom Python scripts to parse, clean, and cross-reference data, isolating cases handled jointly by all three judges between January 1, 2023 and April 26, 2024, deploying a Chrome development build to systematically download filings, and rotating VPN locations to evade download caps — all in a single extended early-morning session. - **V.B (Triggering Panic):** Guertin claims the MCRO system displayed an emergency shutdown banner the very next day — an unscheduled maintenance notice that conflicted with a pre-existing scheduled maintenance banner — which he interprets as administrators scrambling to regain control. - **V.C (Locking the Evidence):** He states he filed an initial forensic analysis into the court record late Friday afternoon before any back-end alterations could be made. - **V.D (Backstory Revealed):** Guertin alleges the synthetic cases served as a contrived backstory to justify his permanent disappearance. He claims the fake Rule 20 evaluations cite "unspecified schizophrenia" mirroring his actual case, and that Judge Jay Quam (officially listed as his judge of record) never met him but his name was placed on fake files for credibility. **Section VI — Synthetic Narrative Construction:** Guertin examines the earliest cases in the synthetic dataset: - **VI.A (A Seven Year 'Competency Education Course'):** The 2017 "State v. Adrian Wesley" filings allegedly demonstrate retroactive construction, containing mental health allegations ("delusional thinking," "technology paranoia," "dangerousness to others") that mirror language later used against Guertin in his Rule 20 evaluations. He claims this proves his psychiatric entrapment was scripted years in advance. - **VI.B (The Mysterious 'Kristen Otte'):** Guertin identifies "Kristen Otte" as listed in the backend Odyssey database as an evaluator in his competency process, despite allegedly never conducting any examination, filing any report, or communicating with him. He interprets this as a "fingerprint of synthetic narrative construction merging with live judicial process." **Section VII — The Judicial Theater Department:** This section identifies the personnel Guertin alleges formed a closed loop of collusion: - **VII.A (Julia Dayton-Klein, Danielle Mercurio, and George Borer):** Guertin claims only cases involving these three judges made it into the 163-case synthetic dataset, and that attorneys were systematically recycled at rates exceeding statistical possibility. He names public defender Susan Herlofsky, private attorneys Warsame Ali and Robert Sorensen, and prosecutor Thomas Stuart Arneson. He notes Arneson was misfiled in at least one docket as defense counsel. - **VII.B (Raissa Carpenter):** Guertin claims his current public defender appears in at least 14 synthetic cases as defense counsel for fabricated defendants, including the "Lucas Patrick Kraskey" cluster. In case 27-CR-22-24627 (State v. Rex Allen Basswood, Jr.), Carpenter is allegedly simultaneously listed as both an "inactive attorney" for the State and "active and inactive defense attorney" for the same defendant. Guertin concludes Carpenter was intentionally inserted into his defense team. - **VII.C (Dr. Adam Milz):** Guertin connects Dr. Milz (who evaluated him January 3, 2024) to the fabricated Basswood case and other synthetic competency assessments. - **VII.D (An Organized Cast of Judicial Characters):** Guertin claims Carpenter was linked to synthetic defendants months before being assigned to his case, and that both Carpenter and Emmett Donnelly tried to convince him not to fight his incompetency determination, refused to respond to his forensic analysis of discovery photos, and fought against his preferred legal strategy at the April 17, 2025 hearing before Judge Hudleston. He also references his prior "conflicted counsel" Bruce Rivers, whom he forced the court to discharge. - **VII.E (Lee Cuellar):** Guertin identifies Cuellar as the clerk who signed off on both the mother's letter and the fabricated Vongsaphay letter with identical language and structure. **Section VIII — Institutional Collapse and Systemic Fallout:** Guertin argues the exposure represents an "existential threat to the judiciary itself" and presents a "Logic-Based Catch-22": suppressing the exposure leads to internal corrosion while confronting it leads to explosive collapse. He expands the conspiracy theory to include "national defense-level surveillance operations" triggered by his filing of "disruptive intellectual property — the InfiniSet patent," escalating through "military-affiliated LinkedIn monitoring" and "defense contractor flagging" before reaching judicial containment. **Section IX — The Only Logical Conclusion:** Guertin concludes the synthetic system was designed to "permanently eliminate him — personally, professionally, and existentially." He characterizes the operation as "domestic psychological warfare" and claims his survival and exposure constitute "the first time a high-value target of a synthetic judicial elimination program has survived long enough to expose the system from the inside." The document is signed under penalty of perjury with electronic signature "/s/ Matthew D. Guertin," dated April 28, 2025, listing his address as 4385 Trenton Ln. N 202, Plymouth, MN 55442, phone 763-221-4540, email MattGuertin@protonmail.com, and website www.MattGuertin.com. ### Legal Issues & Arguments Raised - Allegation of a "synthetic court ecosystem" operating within the 4th Judicial District using AI-generated records, fabricated defendants, and forged court filings - Claim that 163 case files linked to Guertin's case are AI-generated or fabricated - Allegation of conspiracy involving multiple judges (Klein, Mercurio, Borer) to use psychiatric commitment as a weapon against Guertin - Claim that Rule 20 evaluations were based on fabricated evidence and conducted by compromised evaluators - Allegation that assigned defense counsel (Raissa Carpenter) was deliberately embedded to sabotage his defense - Claim that the MCRO digital case management system was used to insert fraudulent records - Assertion that his mother's letter to the court was intercepted and mirrored by a fabricated correspondence to create noise - Claim that Judge Jay Quam (judge of record) played only a "manufactured role" and never met Guertin - Allegation of national-security-level targeting related to his "InfiniSet patent" - Due process violations (Fourteenth Amendment implications) - Right to effective assistance of counsel violations (Sixth Amendment implications) - Allegation of judicial fraud and obstruction of justice - Claim of fabricated psychiatric narratives constituting "psychiatric warfare" ### Factual Allegations & Key Assertions - 163 case files were forensically audited and found to be AI-generated or fabricated - Identical boilerplate conditional release language appears across unrelated cases - Name misspellings and "drift" (e.g., "Makis Devil Lane" / "Makis Duvell Lane") indicate AI generation - "Priest Jesus Dorsey" and "Angelic Denise Nunn/Schaefer" are alleged synthetic identities - "Lucas Patrick Kraskey" and "Terrell Johnson" are alleged template personas with implausible numbers of cases - Cases 27-CR-17-1555, 27-CR-17-8342, 27-CR-17-22909 contain duplicate returned mail filings - Sandra Vongsaphay's letter was filed at 2:03 PM on April 12, 2024, seven minutes before Guertin's mother's letter at 2:10 PM - Lee Cuellar responded to Vongsaphay at 4:38 PM and to Guertin's mother at 4:42 PM with identical language - Guertin used pdftotext, Python scripts, and a Chrome development build to download filings - Guertin rotated VPN servers during extraction to evade detection - MCRO displayed an emergency shutdown banner the day after Guertin's data extraction - Guertin filed his forensic analysis late Friday afternoon to "lock" it before alterations - "Kristen Otte" listed in Odyssey database as evaluator despite allegedly never examining Guertin - In case 27-CR-22-24627, Carpenter listed in contradictory roles (inactive attorney for State / active-inactive defense attorney) - Prosecutor Thomas Stuart Arneson misfiled as defense counsel in at least one case - 2017 "State v. Adrian Wesley" case contains mental health language mirroring Guertin's later evaluations - Guertin claims his InfiniSet patent triggered national-security surveillance leading to judicial targeting - Carpenter and Donnelly attempted to convince Guertin not to fight incompetency determination - Carpenter and Donnelly refused to respond to Guertin's forensic analysis of discovery photos - Carpenter and Donnelly fought against Guertin's legal strategy at the April 17, 2025 hearing ### Procedural Posture This affidavit was filed on April 28, 2025 at 10:18 AM — the same day as the companion affidavit (Filing #7). It appears to be filed as a standalone sworn declaration rather than in support of a specific pending motion, though it references and builds upon arguments from a previously filed Motion to Dismiss. It was filed pro se by Guertin after his defense counsel (Carpenter and Donnelly) allegedly refused to pursue his preferred legal strategy. The document references an April 17, 2025 hearing before Judge Sarah Hudleston. It is addressed to Judge Hudleston, County Attorney Mary F. Moriarty, and ACA Mawerdi Hamid. The judicial officer of record is listed as "Sarah Hudelston" (note misspelling in header — "Hudelston" vs. "Hudleston" in the address line). ### Exhibit / Attachment Inventory No exhibits are physically attached to this specific PDF. However, the document references the following exhibits and supporting materials: - Exhibits A and B of "Synthetic Court Evidence set" (digital forensic breakdown of envelopes) - A forensic analysis filed on a Friday afternoon (date not specified but contextually late April/early May 2024) - MCRO Affidavit filed May 3, 2024 (referenced as "Index 37" in companion filing) - Previously filed Motion to Dismiss (referenced as "Index 131" in companion filing) - Discovery photos (referenced as proven fraudulent, with analysis at Index 122, 123, 124 per companion filing) - Guertin's mother's handwritten letter to Judge Jay Quam (April 12, 2024) - "Sandra Phitsanoukanh Vongsaphay" letter (April 12, 2024) - Lee Cuellar response letters (April 12, 2024) - 163-case dataset of MCRO downloads - Python scripts and pdftotext conversion outputs - Odyssey database screenshot showing Kristen Otte listing ### Visual Evidence Inventory - [Page 11] [Screenshot — Odyssey Database]: A screenshot of the MCRO/Odyssey case management system for case 27-CR-23-1886, "State of Minnesota vs MATTHEW DAVID GUERTIN." The screenshot is overlaid on a watermarked background showing the Minnesota Judicial Branch seal. Visible fields include: - **Case Information:** Location: Hennepin Criminal Downtown; Category: Criminal; Case Type: Crim/Traf Mandatory; Case Initiation Date: 1/24/2023; Case #: 27-CR-23-1886; Assigned to Judge: Hudleston, Sarah. - **Party Information table** with columns: Party Type, Party Name, Lead Attorney. Entries include: - Jurisdiction: State of Minnesota — Lead Attorney: MAWERDI HAMID (+4 m…) - Defendant: MATTHEW DAVID GUE… — Lead Attorney: RAISSA CARPENTER (+… [highlighted in red/orange]) - Examiner: Regional Psychological S… - Examiner: Kristen Otte [**highlighted in yellow**] - Examiner: Jill Rogstad - Examiner: Adam Milz - Examiner: Katheryn Cranbrook - Pagination shows "1–7 of 7 items" - Below the table: "Enter details for this Party" section showing Party Type: Examiner; First Name: Kristen; Last Name: Otte; Lead Attorney field showing "Click to select Lead Attorney" - **Anomaly Flags:** The yellow highlighting on "Kristen Otte" and "Examiner" row appears to be manually applied (screenshot annotation) by the filer to draw attention to this entry. The red/orange highlighting on "RAISSA CARPENTER" similarly appears to be annotation. The screenshot appears to be a genuine capture of the Odyssey system interface, though the highlighting is editorial. - [All Pages] [Court Filing Stamp]: Every page bears the standard MCRO e-filing stamp in the upper right area: "27-CR-23-1886 Filed in District Court / State of Minnesota / 4/28/2025 10:18 AM" — confirming genuine filing through the court's electronic system. - [Page 21] [Electronic Signature Block]: The signature block reads "/s/ Matthew D. Guertin" — an electronic signature, standard for pro se e-filings. ### Key People Referenced | Person | Role/Affiliation | Context | |---|---|---| | Matthew David Guertin | Defendant, Pro Se filer | Author and subject of the affidavit | | Sarah Hudleston (also "Hudelston") | Judge, District Court | Judicial Officer of record; addressed in filing | | Mary F. Moriarty | Hennepin County Attorney | Addressed in filing | | Mawerdi Hamid | Assistant Hennepin County Attorney | Prosecutor; addressed in filing | | Julia Dayton Klein | Judge, Probate/Mental Health Division | Alleged central conspirator; ordered Rule 20, intervened in criminal case | | Danielle Mercurio | Referee (now Judge) | Alleged conspirator; made incompetency findings | | George Borer | Referee | Alleged conspirator; declared Guertin incompetent | | Jay Quam | Judge | Officially listed judge of record; Guertin claims he never met Quam | | Raissa Carpenter | Public Defender | Guertin's current assigned counsel; alleged embedded saboteur | | Emmett Donnelly | Defense attorney (role unspecified) | Co-counsel or supervisor; alleged co-saboteur with Carpenter | | Bruce Rivers | Former defense counsel | Prior attorney Guertin forced to be discharged for conflict | | Dr. Adam Milz | Forensic psychologist / Rule 20 examiner | Conducted January 3, 2024 evaluation; appears in synthetic cases | | Jill Rogstad | Rule 20 examiner | Listed as examiner in Odyssey | | Katheryn Cranbrook | Rule 20 examiner | Listed as examiner in Odyssey | | Kristen Otte | Listed evaluator in Odyssey | Allegedly never conducted an examination; "phantom" evaluator | | Lee Cuellar | Judicial Clerk to Judge Klein | Responded to both mother's letter and Vongsaphay letter | | Susan Herlofsky | Public Defender | Appears across synthetic cases | | Warsame Ali | Private attorney | Appears across synthetic cases | | Robert Sorensen | Private attorney | Appears across synthetic cases | | Thomas Stuart Arneson | Prosecutor | Assigned to Guertin's real case; misfiled as defense in another | | Guertin's mother (unnamed) | Family member | Wrote handwritten letter to Judge Quam on April 12, 2024 | | Sandra Phitsanoukanh Vongsaphay | Alleged synthetic defendant | Allegedly fabricated identity; letter mirrors mother's letter | | Priest Jesus Dorsey | Alleged synthetic defendant | Implausible name cited as AI-generated | | Angelic Denise Nunn / Schaefer | Alleged synthetic defendant | Name drift across cases cited as AI evidence | | Lucas Patrick Kraskey | Alleged synthetic defendant | Tied to large number of incompetency orders | | Terrell Johnson | Alleged synthetic defendant | Associated with ~10 case numbers 2019–2023 | | Adrian Wesley | Alleged synthetic defendant | Earliest (2017) case in synthetic pool | | Rex Allen Basswood, Jr. | Alleged synthetic defendant | Case 27-CR-22-24627; Carpenter listed in contradictory roles | | Temeka Nichols | Alleged synthetic defendant | Dr. Milz listed as evaluator | | Makis Devil(l)/Duvell Lane | Alleged synthetic defendant | Name spelling inconsistencies cited as AI drift | ### Key Entities / Organizations Referenced - Hennepin County District Court, Fourth Judicial District - Minnesota Court Records Online (MCRO) - Odyssey Case Management System (backend database) - USPS (postal service; envelope artifacts cited) - Hennepin County Attorney's Office - Minnesota Judicial Branch - InfiniSet (Guertin's patent / intellectual property) - National defense / military surveillance apparatus (vaguely referenced) - LinkedIn (referenced re: military-affiliated monitoring) - ChatGPT (referenced as tool Guertin used in his forensic analysis) ### Dates & Deadlines Mentioned | Date | Event | |---|---| | January 24, 2023 | Case 27-CR-23-1886 initiated | | 2017 | Earliest synthetic cases (Adrian Wesley) allegedly backdated to this year | | 2019–2023 | Range of Terrell Johnson's alleged synthetic cases | | 2020–2023 | Range of Lucas Patrick Kraskey's alleged synthetic cases | | January 1, 2023 – April 26, 2024 | Window of hearing activity in Guertin's compiled dataset | | April 12, 2024 | Mother's letter filed at 2:10 PM; Vongsaphay letter filed at 2:03 PM; Cuellar responses at 4:38 PM and 4:42 PM | | Late April / early May 2024 | Guertin's MCRO data extraction session | | May 3, 2024 | MCRO Affidavit filed (per companion filing) | | April 17, 2025 | Hearing before Judge Hudleston | | April 28, 2025 | This affidavit filed at 10:18 AM | ### Forensic Flags & Anomalies 1. **Misspelling of Judge's Name:** The document header identifies the judicial officer as "Sarah Hudelston" while the address line reads "Sarah Hudleston" — inconsistency within the same document. 2. **ChatGPT-Assisted Analysis:** Guertin openly admits using ChatGPT to assist in his forensic examination of the case files. This raises questions about the reliability and methodology of the claimed "stylometric analysis" and "forensic" conclusions, as the very AI tool he claims generated the fraudulent records is the same type of tool he used to analyze them. 3. **Circular Methodology Concern:** Guertin filtered the 163-case dataset to include only cases involving the three judges he already suspected. This introduces selection bias — the uniformity he found may partly reflect that he selected for cases within a specific judicial assignment pattern. 4. **VPN Usage Admission:** Guertin admits to rotating VPN servers to evade MCRO download caps and detection, which may itself constitute unauthorized access or terms-of-service violations. 5. **Self-Referential Escalation Pattern:** The document escalates from local judicial fraud to national-security-level conspiracy (InfiniSet patent, military surveillance, defense contractor flagging) without providing supporting documentation for the latter claims within this filing. 6. **Scope of Claims vs. Evidence Presented:** While the document makes sweeping claims about 163 fabricated cases, the evidence presented within the four corners of this specific filing consists primarily of the author's interpretive narrative rather than attached exhibits. 7. **Timing:** Filed at 10:18 AM, two minutes before the companion affidavit at 10:20 AM — suggesting coordinated filing of both documents. ### Cross-References - Filing #7 (this batch) — companion affidavit filed same day at 10:20 AM - Motion to Dismiss (referenced as Index 131 — not yet cataloged in this batch) - MCRO Affidavit filed May 3, 2024 (referenced as Index 37 — not yet cataloged) - Discovery photo forensic analysis (referenced as Indices 122, 123, 124 — not yet cataloged) - Federal civil rights case (case number not specified in this document) - 8th Circuit appeal (referenced but not detailed) - MN Court of Appeals filing (referenced but not detailed) --- --- ## Filing #7 — Affidavit of Exposure: Judicial Simulation and Psychiatric Entrapment | Field | Detail | |---|---| | Filing # | 7 | | Date Filed | April 28, 2025 at 10:20 AM | | Filed By | Matthew David Guertin, Defendant Pro Se | | Document Type | Affidavit (sworn declaration under penalty of perjury) | | Case/Court | 27-CR-23-1886 / Hennepin County District Court, Fourth Judicial District | | Pages | 37 | | Bates / Doc ID | Filename: 145__Affidavit-of-Exposure__Judicial-Simulation-and-Psychiatric-Entrapment__2025-04-28.pdf; MCRO Index not specified in document | ### Comprehensive Summary This 37-page sworn affidavit is the companion document to Filing #6, filed two minutes later at 10:20 AM on the same date. While Filing #6 presents the macro-level theory of a "synthetic court ecosystem," this filing provides a detailed first-person chronological account of Guertin's personal experience within the alleged system, presents comparative forensic analysis of specific documents, includes multiple embedded screenshots and images as evidence, and concludes with formal demands for relief. It is substantially more granular, evidence-rich (in terms of embedded visual exhibits), and personally narrated than Filing #6. The affidavit is structured in nine numbered sections (I–IX): **Section I — No One Was Ever Supposed to See This:** Guertin introduces the filing as a declaration of fact documenting a "synthetic judicial containment system" operating inside the 4th Judicial District. He describes the system as a "closed-loop pipeline designed to contain, suppress, and discredit real people." He recounts his methodology: he documented, extracted, and downloaded thousands of court filings, then pieced together what he characterizes as backdated filings, synthetic defendant names, AI-generated USPS envelopes, recycled psychiatric evaluations, and a procedural simulation running parallel to real court operations. He states that when he began proving it, the system responded "not with justice, but with containment." **Section II — The Conspiracy of Commitment Is Not a Theory — It's a Protocol:** This is the most detailed chronological section of either filing, providing a personal timeline of events from January 24, 2023 through early 2024: - January 24, 2023: First document filed in his newly created criminal case docket. - First 164 days: Guertin alleges multiple hearings were canceled the day before and rescheduled, preventing him from attending his first court hearing for 164 days. - June 14, 2023: A court order granted a continuance "for a non-existent motion." - Guertin claims his previously cleared criminal history was repopulated all the way back to 2002 with every minor offense since age 21. - August 4, 2023: Guertin was granted a stayed order of civil commitment following a Zoom hearing. He states he was "never supposed to be granted" this, triggering "Plan B." - October 30, 2023: A positive 60–90 Day Report was filed stating Guertin was complying with all terms, benefiting from provisional discharge, not posing danger, and recommending the stay remain through February 10, 2024. - November 15, 2023: Judge Julia Dayton Klein issued a new "Order for Competency to Proceed" in the criminal case — just 103 days after the stayed civil commitment and only two weeks after the positive report. Guertin asserts no Rule 20 exam had been requested, no concern was raised by case management, no motion was made by prosecution, and there was "absolutely no legal basis" for restarting the Rule 20 process. - January 3, 2024: Guertin participated in a second Rule 20 exam with Dr. Adam Milz over Zoom. A January 16 review hearing was scheduled. - January 15, 2024: Guertin texted defense attorney Bruce Rivers about the next day's hearing. Rivers responded at 6:26 PM: "No court." - January 16, 2024: At 8:26 AM, a document titled "Commitment Order (MI, DD)" was authored and signed by Referee Danielle Mercurio at 8:27 AM, then by Judge Julia Dayton Klein at 9:22 AM. Guertin claims this order: stated he had agreed to a finding of incompetency; was entered many hours before the hearing he was told didn't exist; was filed out of sequence with non-standard timestamp formatting. A "Waiver of Appearance" was entered at Index #24. At 4:19 PM, a Notice of Hearing was filed for a July 16, 2024 Zoom appearance six months away — creating the "illusion that everything was stable." - January 17, 2024: The January 16 order was filed into the docket at 7:29 AM. - January 22, 2024: A sheriff was dispatched to serve Guertin an Order to Appear in his civil commitment case. - January 26, 2024: Guertin discovered a surprise civil commitment hearing scheduled for February 1 by chance while reviewing case files online. - January 30, 2024: Guertin filed two pro se documents: a Request for Continuance and a Motion for Production of Medical Records. - January 31, 2024: Guertin signed a Waiver extending his Stayed Order of Civil Commitment nine months — a tactical decision to avoid appearing February 1 before Referee George Borer. - February 1, 2024: A court order was issued: "Cancelled and stricken from the calendar." Yet the MCRO docket marked the hearing as "Held Off the Record." Index #40 in the civil docket is described as "missing. Deleted. Erased." - January 11, 2024: Dr. Adam Milz authored his Rule 20 evaluation, which Guertin claims was sealed from him for seven months. Guertin alleges the report falsely stated he had "a history of threatening to harm himself, which elevates my long-term risk of similar behavior" and characterizes this as a "pretext" to "justify disappearance." - Guertin claims he secretly video-recorded his January 3, 2024 Zoom Rule 20 evaluation with Dr. Milz and submitted it into his federal civil rights case eight months later. Guertin references three specific Rule 20 reports: 1. **Rogstad report:** Allegedly omitted his Minnetonka Police report despite listing it under "documents reviewed," then characterized his mention of "FBI" and "Minnetonka Police" as nonsensical, while paradoxically recommending he contact the FBI. 2. **Milz report:** Allegedly refused to acknowledge his submitted evidence and is contradicted by the secret Zoom recording. 3. **Cranbrook report:** Authored without ever meeting him; used his pro se federal civil rights lawsuit as circular justification for further evaluation; labeled him "psychotic" and recommended forced antipsychotic medication. Guertin identifies six judicial officers as responsible for everything: Judge Julia Dayton Klein, Referee George Borer, Referee Danielle Mercurio, and references their cross-jurisdiction activity from criminal to civil commitment dockets. He also notes the court provided his attorney with the wrong phone number. **Section III — Documenting the Simulation Infrastructure:** Guertin presents the same categories of evidence as Filing #6 but with additional detail: - **III.A (Recycled Defendants):** Lists the same synthetic names as Filing #6 (Angelic Denise Nunn/Schaefer, Priest Jesus Dorsey, Makis Devell/Devil/Duvell Lane) and describes them as "language model drift outputs." - **III.B (AI-Generated USPS Envelopes):** Claims forensic analysis of returned mail envelopes shows identical handwriting, same stamps, no barcode variance (described as impossible for real USPS mail), and image compression overlays revealing "direct layer reuse." References "Exhibits A and B of the Synthetic Court Evidence set." - **III.C (Psychiatric Evaluations Written Without Interviews):** Claims evaluations were based on falsified discovery images, forged timestamps, and manipulated environmental photos — references Indices 122, 123, 124 for forensic image analysis. - **III.D (Judge Looping and Synthetic Rotation Patterns):** Reiterates the Klein/Borer/Mercurio closed loop. - **III.E (The MCRO Audit That Broke the Illusion):** References MCRO Affidavit filed May 3, 2024 (Index 37, Exhibit D) and the subsequent emergency shutdown banner. **Section IV — The Synthetic Judicial Loop: Data-Driven Evidence of Systemic Containment:** This section provides quantitative analysis from "Exhibit G" — a structured spreadsheet: - **IV.A (Closed-Loop Judicial Control):** Reiterates the dataset was filtered for Klein, Borer, and Mercurio. - **IV.B (Unnatural Role Rotation):** Describes a pattern where Mercurio initiates Rule 20, Borer makes incompetency finding, Klein signs final order. - **IV.C (Irregular Dominance of a Single Judge):** Presents numerical claims from Exhibit G: - Klein issued initial Rule 20.01 evaluation orders in 33 cases - Klein signed 46 psychiatric incompetency orders - Klein performed both roles in 10 cases - Klein exercised total control (initiate, determine, sign) in at least 4 cases: 27-CR-20-7092, 27-CR-21-933, 27-CR-21-6229, 27-CR-22-18938 - In Guertin's own case, Klein both ordered the initial Rule 20 and signed the final incompetency determination, despite Borer issuing the recommendation and Mercurio being identified in document metadata as the actual author. - **IV.D (What Exhibit G Objectively Proves):** Guertin acknowledges this exhibit does not contain evidence of forged documents or AI synthesis, but argues it proves outsized control by a small subset of judicial officers. **Section V — A Synthetically Created and Weaponized MCRO Docket:** This section presents the duplicate-letter evidence with embedded visual exhibits: - **V.A (The Duplicate Letter):** Detailed account of the April 12, 2024 letter events (same as Filing #6 Section IV) but with embedded images of the actual documents. - **V.B (Comparative Forensic Examination):** Presents two side-by-side comparison tables analyzing authentic vs. synthetic handwriting and envelopes across multiple features (line structure, ink flow, line integration, letter variability, human imperfections, emotive pressure for letters; postmark, stamp overlay, return address ink, envelope texture, smudging, emotive pressure for envelopes). - **V.C (Technical Forensic Indicators of Syntheticity):** Lists four indicators: uniform handwriting generation, flat image layers, digital barcode injection, and absence of physical interactions. - **V.D (Conclusion):** Recommends the Vongsaphay letter be excluded from evidentiary use and calls for USPS forensic specialist examination. **Section VI — Synthetic Return Mail for the Synthetic Cases:** Guertin presents further evidence on the Vongsaphay identity: - Vongsaphay's zip code is documented as 55415 in the April 12 Cuellar document, but as 55404 in the docket PDF downloaded April 29, 2024 - The docket shows an "Active Warrant" on April 29, 2024, even though the letter was supposedly written from Hennepin County Jail - The only warrant in the case file was issued September 12, 2023 and cleared February 26, 2024 - Vongsaphay was released from jail three days before the letter was supposedly written from jail - Vongsaphay's docket has out-of-sequence indexes: 1, 3, 27–29, 19, 20, 10, 11 **Section VII — Duplicate Fake Addresses Seals the Deal:** Guertin presents what he calls the final proof — the Vongsaphay returned mail address (740 E 17th Street) matches the address used for "Angelic Denise Nunn" across multiple returned mail filings, suggesting the same fabricated address was recycled for different synthetic defendants. Multiple pages of returned mail envelope scans are presented showing "Angelic Denise Nunn" at 740 17th St/Ave variations in Minneapolis MN 55404. **Section VIII — Demands for Systemic Relief and Oversight:** Guertin formally demands: - **A.** Immediate dismissal of case 27-CR-23-1886 with prejudice - **B.** Permanent termination of all psychiatric monitoring, Rule 20 orders, or court-imposed mental health actions - **C.** Full third-party audit of Minnesota's MCRO system by an entity independent of the Minnesota Judicial Branch - **D.** An immediate independent investigation, suggesting: - Minnesota Office of the Legislative Auditor - US DOJ Civil Rights Division - Federally appointed Special Master or Independent Oversight Panel - Specific focus on 10 mental health/probate cases: 27-MH-PR-22-1394, 27-MH-PR-23-224, 27-MH-PR-23-358, 27-MH-PR-23-892, 27-MH-PR-23-1020, 27-MH-PR-23-1021, 27-MH-PR-23-1181, 27-MH-PR-23-1241, 27-MH-PR-23-1461, 27-MH-PR-24-9 - All cases involving Klein, Borer, and Mercurio in Rule 20 proceedings - All active cases with incompetency determinations contested by defendants - All cases where Klein's decisions converted criminal defendants into civil respondents - All cases with fabricated service filings, missing docket indices, "Held Off the Record" orders, out-of-sequence indexes **Section IX — Final Declaration and Affirmation Under Penalty of Perjury:** Guertin reiterates his claims, states his survival account, and signs under penalty of perjury with the same signature block as Filing #6. ### Legal Issues & Arguments Raised - All arguments from Filing #6, plus: - Specific due process violations: January 16, 2024 backdated commitment order entered before hearing; defendant told "no court" by counsel while order was being signed - Ineffective assistance of counsel: Bruce Rivers' "No court" text on January 15 while order was being prepared for January 16 - Fabricated waiver of appearance at Index #24 - Right to be present at proceedings - Unlawful civil commitment: surprise February 1, 2024 hearing scheduled without proper notice - Destruction/alteration of court records: Index #40 missing from civil docket - Withholding of exculpatory evidence: Rule 20 report withheld for seven months - Fabrication of medical evidence: psychiatric reports based on falsified discovery - Violation of right to confront evidence: sealed evaluations used against defendant - Cross-jurisdictional judicial overreach: Judge Klein (probate) intervening in criminal case - Circular psychiatric logic: federal civil rights lawsuit used to justify further psychiatric evaluation - Request for dismissal with prejudice - Request for permanent termination of all psychiatric monitoring - Request for independent third-party MCRO system audit - Request for federal/independent investigation of judicial misconduct - Specific case numbers identified for investigation ### Factual Allegations & Key Assertions - All factual allegations from Filing #6, plus: - First hearing did not occur until 164 days after case initiation - June 14, 2023 continuance granted on non-existent motion - Criminal history repopulated back to 2002 - August 4, 2023 stayed civil commitment via Zoom - October 30, 2023 positive 60–90 Day Report filed - November 15, 2023 Klein ordered new competency evaluation without basis — 103 days after stayed commitment, 16 days after positive report - January 3, 2024 Zoom Rule 20 with Dr. Milz - January 11, 2024 Milz report authored and sealed - January 15, 2024 Bruce Rivers texted "No court" at 6:26 PM - January 16, 2024 "Commitment Order (MI, DD)" signed by Mercurio at 8:27 AM and Klein at 9:22 AM; Waiver of Appearance at Index #24; Notice of Hearing for July 16 filed at 4:19 PM - January 17, 2024 order filed at 7:29 AM - January 22, 2024 sheriff dispatched to serve civil commitment appearance order - January 26, 2024 Guertin discovered surprise February 1 hearing by chance - January 30, 2024 pro se Request for Continuance and Motion for Production of Medical Records filed - January 31, 2024 Guertin signed waiver extending stayed commitment nine months - February 1, 2024 hearing "Cancelled and stricken" yet marked "Held Off the Record"; Index #40 missing - Court provided Guertin's attorney wrong phone number - Guertin secretly video-recorded January 3 Zoom evaluation; submitted it to federal case eight months later - Milz report stated Guertin had "a history of threatening to harm himself" - Rogstad report omitted Minnetonka Police report; recommended contacting FBI while calling his mention of FBI nonsensical - Cranbrook report authored without meeting Guertin; used federal lawsuit as justification - Judge Klein issued initial Rule 20 orders in 33 cases per Exhibit G - Klein signed 46 incompetency orders per Exhibit G - Klein performed all three roles in cases 27-CR-20-7092, 27-CR-21-933, 27-CR-21-6229, 27-CR-22-18938 - Vongsaphay zip code discrepancy: 55415 in Cuellar document vs. 55404 in docket - Vongsaphay had active warrant on April 29, 2024 per docket, but warrant issued 9/12/2023 and cleared 2/26/2024 - Vongsaphay letter supposedly from jail but she was released three days prior - Vongsaphay docket has out-of-sequence indexes: 1, 3, 27–29, 19, 20, 10, 11 - Vongsaphay address (740 E 17th Street) matches Angelic Denise Nunn address - MCRO Affidavit filed May 3, 2024 at Index 37 ### Procedural Posture Filed April 28, 2025 at 10:20 AM — two minutes after companion Filing #6. The document functions as both a detailed factual account and a formal demand for relief (dismissal with prejudice, termination of psychiatric monitoring, third-party audit, independent investigation). It builds upon a previously filed Motion to Dismiss (Index 131), a prior MCRO Affidavit (Index 37, May 3, 2024), and forensic image analyses (Indices 122, 123, 124). Guertin references filings in MN Court of Appeals, MN Federal District Court, and 8th Circuit Court of Appeals. The document is addressed to Judge Hudleston, County Attorney Moriarty, and ACA Hamid. It was filed pro se. ### Exhibit / Attachment Inventory The filing references but does not appear to physically attach the following exhibits (some are embedded as images within the document): - **Exhibit D:** MCRO Affidavit filed May 3, 2024 (Index 37) - **Exhibit F:** Referenced in demands section (procedural loop patterns) - **Exhibit G:** Structured spreadsheet mapping judicial officers to Rule 20 proceedings - **Exhibit I:** Guertin's mother's letter to Judge Jay Quam - **Exhibits A and B:** Synthetic Court Evidence set (digital forensic breakdown) - Index 122, 123, 124: Forensic image analyses of discovery photos - Index 131: Motion to Dismiss - 27-CR-23-2480: Entire Vongsaphay case file (submitted as evidence) - The filing also references "many additional exhibits submitted into the record" without specific enumeration ### Visual Evidence Inventory - [Page 11 — carried over from Filing #6 equivalent content] [Screenshot — Odyssey Database]: This page contains the same Odyssey screenshot described in Filing #6 (see Filing #6 Visual Evidence Inventory). The screenshot shows case information, party information table with Kristen Otte highlighted in yellow and Raissa Carpenter highlighted in red. Watermarked with Minnesota Judicial Branch seal. - [Page 14] [Court Filing Stamp + Handwritten Letter Excerpt]: The page contains a scan/image of the beginning of Guertin's mother's handwritten letter. Visible text in handwriting reads: "March 23, 2024 27-CR-23-1886" on the first line and "Dear Honorable Judge Jay Quam's Courts" on the second line. The handwriting appears organic with natural baseline variation and ink pressure changes. Above this is the court e-filing stamp showing "27-CR-23-1886 / Filed in District Court / State of Minnesota / 4/12/2024 2:10 PM" — confirming the April 12, 2024 filing time. - [Page 15] [Official Court Letterhead — Lee Cuellar Response]: An image of official Minnesota Judicial Branch letterhead from the Probate/Mental Health Division, 4th Floor Courts Tower, Hennepin County Government Center, 300 South Sixth Street, Minneapolis MN 55487. The letterhead includes the Minnesota Judicial Branch seal/logo and the text "FOURTH JUDICIAL DISTRICT" with a link to www.mncourts.gov/district/4. Date shown: April 12, 2024. The e-filing stamp reads "27-CR-23-1886 / Filed in District Court / State of Minnesota / 4/12/2024 4:42 PM." - [Page 15] [Handwritten Letter — Sandra Vongsaphay]: Below the Cuellar letterhead, an image shows a handwritten letter with the header addressed to "Judge DAYTON Klein" and listing case numbers: 27-CR-21-5142, 27-CR-22-18824, 27-CR-23-2480, 27-CR-23-16937. Date written: 4/8/2024. Visible handwritten text begins: "I need help understanding what is happening with my case. I don't understand..." The handwriting appears on lined paper. The e-filing stamp shows "27-CR-23-2480 / Filed in District Court / State of Minnesota / 4/12/2024 2:03 PM." - [Page 16] [Official Court Letterhead — Lee Cuellar Response to Vongsaphay]: Another Minnesota Judicial Branch letterhead image, identical format to the one on page 15. E-filing stamp: "27-CR-23-2480 / Filed in District Court / State of Minnesota / 4/12/2024 4:38 PM." Date: April 12, 2024. - [Page 17] [Handwriting Comparison — Mother's Letter Excerpt]: An image showing several lines of handwriting from Guertin's mother's letter. Visible text (partial): "...InfiniSet since 2021 he was been granted his first patent forward with his dreams..." The handwriting shows natural variation, pressure changes, and organic flow. Below this is a separate handwriting image labeled as from Sandra Vongsaphay's letter, showing text: "a language I do not need at an advocate or ... to ensure my rights..." This writing appears on ruled/lined paper with different characteristics than the mother's letter. - [Pages 19] [Envelope Comparison Images]: Two zoomed/cropped images at the top of the page showing handwriting details from envelopes — one showing "M." and "Quam" (from the mother's envelope) and one showing address details. These appear to be high-magnification crops meant to show handwriting character differences. Below these are comparison tables (rendered as text tables, not images). - [Page 20] [USPS Barcode/Stamp Close-up]: A high-magnification image showing a USPS barcode region — appears to be a series of dots/dashes in a machine-readable barcode format. Below this is a zoomed image showing "U S A ★ F O R E V E R" text from what appears to be a Forever stamp — presented to show alleged digital rendering artifacts. The image quality suggests high-zoom examination of stamp details. - [Page 22] [MCRO Docket Screenshot — Vongsaphay Address 55415]: A screenshot showing defendant information from the court system: "SANDRA PHITSANOUKANH VONGSAPHAY / 401 S 4TH AVE S STE 100 / MINNEAPOLIS MN 55415" — formatted as a typed/displayed address block. Below this, another screenshot section showing: "Defendant / Vongsaphay, Sandra [Active Warrant badge in red] / DOB: 01/01/1981 / MINNEAPOLIS, MN 55404-1601 / Case Details (Register of Actions) / Search executed on 04/29/2024 06:02 PM." A second screenshot below shows the same defendant name with Active Warrant badge and identical search execution timestamp, with the zip code shown as 55404. **Anomaly flagged by filer:** The address in the Cuellar document shows 55415 while the docket shows 55404 — a discrepancy. - [Page 23] [Vongsaphay Envelope Scan]: A scanned envelope image showing return address: "Phitsanoukanh Vongsaphay / Avenue STE 100 / S MN 55415" and recipient: "Judge DAYTON Klein / 300 S 6th St / Minneapolis MN 55487." Postmark area shows "MINNEAPOLIS MN 553..." and "10 APR 2024 PM 4 L" with "USA ★ F" stamp visible. In the lower left, a stamp reading "HENNEPIN COUNTY JAIL" (inverted) and "MAILED FROM HENNEPIN COUNTY JAIL" (inverted) are visible. Below this: Warrant history showing "Inactive Warrants: Vongsaphay, Sandra Bench Warrant-fail to appear at a hearing / Judicial Officer: Dayton Klein, Julia / 02/26/2024 10:41 AM Status: Warrant Cleared by Wt Office / 09/12/2023 01:30 PM Status: Issued Active." **Anomaly flagged by filer:** Letter supposedly from jail, but warrant cleared 2/26/2024 and she was released. - [Page 24] [Vongsaphay Docket Screenshots]: Multiple docket entry screenshots showing: - 04/26/2024: Order for Conditional Release, Judicial Officer: Olson, Joel, Index #32 - 04/12/2024: Correspondence, Index #31 - 04/04/2024: Finding of Incompetency and Order, Judicial Officer: Browne, Michael K, Index #27 (5 pages) - 04/02/2024: Notice of Remote Hearing with Instructions, Index #29 (2 pages) - 04/02/2024: Motion, Judicial Officer: Dayton Klein, Julia, Party: Attorney Irfanullah, Christine, Index #28 - 03/29/2024: Rule 20 Evaluation Report, Index #26 - 03/16/2023: Notice of Intent to Prosecute, Index #12 (1 page) - 03/08/2023: Finding of Incompetency and Order, Judicial Officer: Dayton Klein, Julia, Index #10 (5 pages) - 03/07/2023: Motion, Judicial Officer: Dayton Klein, Julia, Party: Attorney Herlofsky, Susan, Index #11 - 02/01/2023: E-filed Comp-Order for Detention, Index #1 (Unknown pages) - 01/31/2023: Application for Public Defender, Index #3 **Anomaly flagged by filer:** Index numbers are out of sequence: 1, 3, 27–29, 19, 20, 10, 11 — some index numbers are missing or appear in non-chronological order. - [Page 25] [Vongsaphay Envelope Return Address + Address Block]: A handwritten return address image: "Phitsanoukanh Vongsaphay / Avenue STE 100 / S MN 55415" followed by a typed address block: "SANDRA PHITSANOUKANH VONGSAPHAY / 401 S 4TH AVE S STE 100 / MINNEAPOLIS MN 55415." These are presented to compare the handwritten and typed versions of the same address. - [Page 26] [Vongsaphay Returned Mail Envelope + Angelic Denise Nunn Returned Mail]: Top image: A scanned returned mail envelope from "PROBATE/MENTAL HEALTH DIVISION / FOURTH JUDICIAL DISTRICT COURT / C-400 HENNEPIN COUNTY GOVERNMENT CENTER / MINNEAPOLIS, MINNESOTA 55487-0340" addressed to "SANDRA VONGSAPHAY / 740 EAST 17TH STREET / MINNEAPOLIS MN 55404" with USPS "Return to Sender" markings showing "-R-T-S- 554044049-1N 009 08/26" and "RETURN TO SENDER / ATTEMPTED – NOT KNOWN / UNABLE TO FORWARD / RETURN TO SENDER." Filed in District Court stamp: AUG 31 2023. **Critical anomaly:** The address here is 740 East 17th Street — different from the 401 S 4th Ave S Ste 100 shown in other documents. Bottom section: A returned mail envelope from "HENNEPIN COUNTY DISTRICT COURT / FOURTH JUDICIAL DISTRICT / 300 SOUTH SIXTH STREET / MINNEAPOLIS, MINNESOTA 55487-0332" addressed to "ANGELIC DENISE NUNN / 740 E 17th Street / Minneapolis MN 55404." NIXIE marking: "553 FE 1260 0005/06/23." Filed in District Court: MAY 09 2023. Below this, another envelope for "ANGELIC DENISE NUNN / 772 FULLER AVE / ST PAUL MN 55104" — Filed in District Court: FEB 18 2020. NIXIE marking: "553 FE 1260 0002/17/." **Critical anomaly flagged by filer:** Sandra Vongsaphay and Angelic Denise Nunn share the same address (740 E 17th Street, Minneapolis MN 55404). - [Pages 27–30] [Compilation of Angelic Denise Nunn / Schaefer Returned Mail Envelopes]: Four dense pages containing approximately 20+ scanned returned mail envelopes, all addressed to "ANGELIC DENISE NUNN" or "ANGELIC DENISE SCHAEFER, AKA ANGELIC" at variations of "740 17th" addresses (740 17TH ST E, 740 17TH AVE NE, 740 E 17TH STREET, 740 17th Street, 740 17TH AVE, 740 17TH STREE) in Minneapolis MN 55404 (or occasionally 55408). Various return addresses from court divisions: Probate/Mental Health Division (55487-0340), Fourth Judicial District (55487-0332), Criminal/Traffic Division C1153 (55487-0419), Criminal Centralized Unit RM#160 Juvenile Justice Center (55415-1573). Filed dates range from FEB 18 2020 through OCT/NOV 2023. USPS postage amounts shown: $0.000.4, $0.000.42, $0.000.45, $0.000.47, $0.000.49, $0.000.63, $0.000.71. NIXIE codes consistently show "553 FE 1260" with varying dates. Multiple envelopes show USPS "Return to Sender" with reasons: "NOT KNOWN," "NOT DELIVERABLE AS ADDRESSED," "UNCLAIMED." One envelope references Court File 20033. Case numbers visible on some envelopes include 27CR203544, 27CR311977, 27CR311978, 27CR222003, 27CR9315671. **Anomalies flagged by filer:** (1) Same address (740 17th variations) used for both Vongsaphay and Nunn/Schaefer — suggesting recycled synthetic addresses; (2) Address variations (ST E, AVE NE, STREET, STREE) suggest inconsistent generation; (3) Multiple envelopes across different court divisions and years all returned to sender at the same address; (4) The sheer volume of returned mail for a single defendant is characterized as anomalous. - [All Pages] [Court Filing Stamp]: Every page bears: "27-CR-23-1886 Filed in District Court / State of Minnesota / 4/28/2025 10:20 AM" - [Page 37] [Electronic Signature Block]: "/s/ Matthew D. Guertin" — identical format to Filing #6. ### Key People Referenced All persons from Filing #6, plus: | Person | Role/Affiliation | Context | |---|---|---| | Bruce Rivers | Former defense attorney | Texted "No court" on January 15, 2024; later discharged for conflict | | Christine Irfanullah | Attorney | Listed as party on Vongsaphay motion, 04/02/2024 | | Michael K. Browne | Judicial Officer | Signed Vongsaphay Finding of Incompetency, 04/04/2024 | | Joel Olson | Judicial Officer | Signed Vongsaphay Order for Conditional Release, 04/26/2024 | | Guertin's mother (unnamed) | Family member | Author of April 12, 2024 handwritten letter; handwriting samples shown | ### Key Entities / Organizations Referenced All entities from Filing #6, plus: - Minnesota Office of the Legislative Auditor (proposed investigator) - US Department of Justice, Civil Rights Division (proposed investigator) - Minnetonka Police Department (filed police report referenced in Rule 20 evaluations) - FBI (Rogstad report recommended contacting; Guertin's mention characterized as nonsensical) - MN Court of Appeals (Guertin filed cases there) - MN Federal District Court (federal civil rights case) - 8th Circuit Court of Appeals (Guertin filed appeal) - Hennepin County Jail (Vongsaphay letter supposedly from there) - Juvenile Justice Center, Criminal Centralized Unit RM#160 (return address on some envelopes) ### Dates & Deadlines Mentioned All dates from Filing #6, plus: | Date | Event | |---|---| | January 24, 2023 | First document filed in Guertin's case | | June 14, 2023 | Court order granting continuance on non-existent motion | | August 4, 2023 | Stayed order of civil commitment via Zoom | | September 12, 2023 | Vongsaphay bench warrant issued | | October 30, 2023 | Positive 60–90 Day Report filed | | November 15, 2023 | Klein orders new competency evaluation | | February 10, 2024 | Date through which stay was recommended to remain | | January 3, 2024 | Second Rule 20 exam with Dr. Milz (Zoom) | | January 11, 2024 | Milz Rule 20 report authored | | January 15, 2024 | Rivers texts "No court" at 6:26 PM | | January 16, 2024 | Commitment Order signed (Mercurio 8:27 AM, Klein 9:22 AM); Waiver of Appearance at Index #24; Notice of Hearing filed 4:19 PM for July 16, 2024 | | January 17, 2024 | January 16 order filed at 7:29 AM | | January 22, 2024 | Sheriff dispatched to serve civil Order to Appear | | January 26, 2024 | Guertin discovers surprise Feb 1 hearing | | January 30, 2024 | Pro se Request for Continuance and Motion for Production of Medical Records filed | | January 31, 2024 | Guertin signs waiver extending stayed commitment 9 months | | February 1, 2024 | Hearing cancelled/stricken; marked "Held Off the Record"; Index #40 missing | | February 26, 2024 | Vongsaphay warrant cleared | | April 8, 2024 | Date Vongsaphay letter was written | | April 29, 2024 | Guertin downloaded Vongsaphay docket PDF (search executed 06:02 PM) | | May 3, 2024 | MCRO Affidavit filed (Index 37) | | July 16, 2024 | Scheduled Zoom hearing per January 16 notice | | 2002 | Earliest date of repopulated criminal history | ### Forensic Flags & Anomalies 1. **All flags from Filing #6 apply**, plus: 2. **Vongsaphay Zip Code Discrepancy:** 55415 in Cuellar document vs. 55404 in MCRO docket — documented with screenshots on page 22. 3. **Vongsaphay Jail/Release Contradiction:** Letter supposedly written from Hennepin County Jail on April 8, 2024, but warrant cleared February 26, 2024 and she was released prior to the letter date. Envelope bears "MAILED FROM HENNEPIN COUNTY JAIL" stamps. 4. **Vongsaphay Address Inconsistencies:** Three different addresses appear: 401 S 4th Ave S Ste 100 (Cuellar document), 740 East 17th Street (returned mail), and the docket listing. 5. **Shared Address — Vongsaphay and Nunn:** Both alleged synthetic defendants share 740 E 17th Street, Minneapolis MN 55404 as a mailing address. 6. **Angelic Denise Nunn Address Variations:** The same defendant's address appears as 740 17TH ST E, 740 17TH AVE NE, 740 E 17TH STREET, 740 17th Street, 740 17TH AVE, 740 17TH STREE — inconsistent across filings. 7. **Angelic Denise Nunn/Schaefer Name Change:** Same person appears under two surnames without explanation in the record. 8. **Vongsaphay Docket Index Sequence:** Indexes appear out of order (1, 3, 27–29, 19, 20, 10, 11) — potentially indicative of retroactive insertions or system sorting anomalies. 9. **Volume of Returned Mail:** The 20+ returned mail envelopes for Nunn/Schaefer across multiple years and court divisions is characterized as anomalous for a single defendant. 10. **USPS Postage Amounts:** The machine-printed postage amounts ($0.000.4x range) appear to be Pitney Bowes presorted first-class rates, which is normal for court bulk mailings — this does not inherently indicate forgery, though the filer claims the envelopes themselves are synthetic. 11. **Filing #6 and #7 Overlap:** Substantial content overlap between these two companion filings — many sections repeat the same arguments with different emphasis or added detail. 12. **DOB for Vongsaphay:** Listed as 01/01/1981 — a "placeholder" date of birth (January 1) that could be a default entry for unknown DOBs or could be legitimate. 13. **Secret Recording:** Guertin admits to secretly recording his Zoom Rule 20 evaluation with Dr. Milz on January 3, 2024. Minnesota is a one-party consent state for recording, so this may be legally permissible, but it raises questions about whether it was conducted in compliance with any applicable court orders or evaluation protocols. 14. **"Held Off the Record" vs. "Cancelled":** The February 1, 2024 hearing was simultaneously marked as "Cancelled and stricken from the calendar" by court order and "Held Off the Record" in MCRO — a contradiction worth investigating regardless of the synthetic-system theory. 15. **Missing Index #40:** The deletion of a docket entry is a significant anomaly that could have multiple explanations but warrants investigation. 16. **Commitment Order Timing:** The January 16, 2024 commitment order signed at 8:27 AM / 9:22 AM, combined with Rivers' "No court" text the evening before, presents a factual conflict worth examining. ### Cross-References - Filing #6 (this batch) — companion affidavit filed same day at 10:18 AM - Index 37: MCRO Affidavit, filed May 3, 2024 (referenced as Exhibit D) - Index 131: Motion to Dismiss (previously filed) - Indices 122, 123, 124: Forensic image analyses of discovery photos - Index #24: Waiver of Appearance (January 16, 2024) - Index #40: Missing docket entry in civil case (February 1, 2024) - Case 27-CR-23-2480: Vongsaphay case file (submitted as evidence exhibit) - Case 27-CR-21-5142: Vongsaphay-related case number - Case 27-CR-22-18824: Vongsaphay-related case number - Case 27-CR-23-16937: Vongsaphay-related case number - Case 27-CR-20-7092: Klein total-control case per Exhibit G - Case 27-CR-21-933: Klein total-control case per Exhibit G - Case 27-CR-21-6229: Klein total-control case per Exhibit G - Case 27-CR-22-18938: Klein total-control case per Exhibit G - 10 MH/PR cases: 27-MH-PR-22-1394, 27-MH-PR-23-224, 27-MH-PR-23-358, 27-MH-PR-23-892, 27-MH-PR-23-1020, 27-MH-PR-23-1021, 27-MH-PR-23-1181, 27-MH-PR-23-1241, 27-MH-PR-23-1461, 27-MH-PR-24-9 - Federal civil rights case (case number not specified) - 8th Circuit appeal (case number not specified) - MN Court of Appeals case (case number not specified) --- --- ## Filing #8 — Defendant's Evidence Exhibit A: "Netflix Whistleblower Is Found Alive and Well | Part 1 – The Patent" | Field | Detail | |---|---| | Filing # | 8 | | Date Filed | April 10, 2025, 11:08 AM | | Filed By | Matthew David Guertin, Defendant Pro Se | | Document Type | Defendant's Evidence Exhibit with attached 140-page narrative exhibit (Exhibit A) | | Case/Court | 27-CR-23-1886, Hennepin County District Court, Fourth Judicial District, State of Minnesota | | Pages | 153 (13 pages legal motion + 140 pages Exhibit A) | | Bates / Doc ID | Index 128; filename: 128___Exhibit-A_Netflix-Whistleblower-Part-1__2025-04-10.pdf | --- ### Comprehensive Summary This filing is a two-part document: (1) a 13-page pro se legal motion addressed to Judge Sarah Hudelston, Hennepin County Attorney Mary F. Moriarty, and Assistant County Attorney Mawerdi Ahmed Hamid; and (2) a 140-page narrative exhibit titled "Netflix Whistleblower Is Found Alive and Well | Part 1 – The Patent." **Part 1: The Legal Motion (pp. 1–13)** The motion seeks admission of Exhibit A into the court record. Guertin argues that the Court's March 5, 2025 order finding him competent to proceed nevertheless perpetuated unsupported findings of mental illness. He contends Exhibit A provides "publicly verifiable evidence" contradicting these mental illness findings and exposing what he calls a "high-level criminal conspiracy" involving patent theft by Netflix, certain U.S. military elements, defense contractors, and big tech companies. The motion's core legal arguments are organized into three sections: *Section I (Introduction):* Guertin asserts he has been "held hostage" by the Court for over 26 months through "intentionally deceptive reports about his mental health." He identifies the manipulated discovery photos as proven and "locked in" to the official record, tied to metadata tampering within Hennepin County's OneDrive discovery sharing system. He asserts the manipulation proves a criminal conspiracy linked to the origination of his charges. He cites his federal civil rights lawsuit filed July 8, 2024, in MN Federal District Court (Guertin v. Hennepin County) and his August 7, 2024 Motion for Expedited Preliminary Injunction. He reproduces paragraphs 208–223 from that federal filing, detailing LinkedIn search data allegedly showing surveillance by the Defense Intelligence Agency (DIA), DARPA, US Indo-Pacific Command, US State Department, US Air Force, State of Rhode Island, Forcepoint, Triple Inc., Inhance Digital, Uptv/InterMedia, Henry Street Settlement, and Gentle Giant Studios—all cross-linked to demonstrate a coordinated monitoring campaign. He provides external links to LinkedIn search analysis documents, email archives, correspondence with Dr. Jill Rogstad (Rule 20 examiner), and the online version of Exhibit A on Substack. *Section II (Argument):* Three arguments are raised: (A) Patent fraud and misappropriation—Guertin's US Patent No. 11,577,177 vs. Netflix's US Patent No. 11,810,254 (filed 12 days after his, listing his name/patent at the top); (B) Manipulated discovery and judicial complicity—images tampered via Hennepin County's OneDrive, contradictory competency/mental illness findings; (C) Systemic conspiracy—powerful government, military, and judicial actors participating through targeted LinkedIn searches and falsified evidence supporting false diagnoses. *Section III (Relief Sought):* (1) Admit Exhibit A into the record; (2) Correct the record on competency and acknowledge Exhibit A contradicts findings of incompetency/psychotic disorder; (3) Order comprehensive review of all discovery materials and competency evaluations, impose sanctions on responsible parties; (4) Grant further relief as deemed just and proper. The motion is signed by Guertin pro se, dated April 10, 2025, with address at 4385 Trenton Ln. N 202, Plymouth, MN 55442, phone 763-221-4540, email MattGuertin@protonmail.com. **Part 2: Exhibit A — The Narrative (Exhibit A pp. 1–140)** Exhibit A is a highly detailed, first-person narrative written by Guertin in a literary/journalistic style, telling the complete story of his invention, the alleged patent theft, and the events culminating in his arrest on January 21, 2023. It is structured as follows: **Opening Materials (pp. 1–4):** A market projection table valuing the "Infinite Movement" treadmill patent at $390 billion over 20 years across film/TV, gaming, fitness, military, education, licensing, and software markets. Page 2 contains a reproduced page from Guertin's federal civil rights complaint (Doc. 77, filed 09/24/24, p. 25 of 128). Page 3 features satirical "review quotes" attributed to obviously fictional reviewers with punning names referencing key players in the case (e.g., "Paul Debunkvec / Distinguished Fellow of Synthesis @ TruthGrift Systems™," "Stephan TrojanHeist / Founder of Scamline VFX™ and EyeLie Studios™," "Foolz Yurbach / Yeshiva of Temporal Optics @ Holodreck Systems™," "AssHat Wronger / CEO of PhotoNoBot® / Creator of the Virtual CopyCatwalk™," "Ari Embezzuel / Rabbinical Head of Retroactive Innovation @ Holodreck Systems™"). These are intentional wordplay on names like Paul Debevec, Stephan Trojansky, and Eyeline Studios—all central figures/entities in Guertin's conspiracy claims. **Background/Biography (pp. 4–16):** Extensive biographical narrative covering Guertin's childhood fascination with lighting and electronics, RadioShack hobby, high school party lighting rigs, discovery of rave culture at age 19, CAD education, nightclub lighting career in Minneapolis, transition to Los Angeles for professional production work (including LED installations, immersive experiences, projection mapping), work at Xite Labs in Calabasas, international projects (Vung Tau, Vietnam; Saudi Arabia), 3D scanning with Faro S150 scanner, photogrammetry expertise, StyleFlip.com DJ skins business (2008), COVID-19 return to Minneapolis, Grant Park Chicago virtual scanning project for Lollapalooza virtual performance, and the November 2020 visit to Xite Labs' new virtual production LED stage that planted the seed for InfiniSet. **The Invention — InfiniSet (pp. 17–20):** Detailed description of the moment of invention in early February 2021. Guertin's core insight: virtual production had limitless environments but the person was always stuck in one spot. The solution was a motorized, rotatable treadmill that tracks the user's direction and velocity, rotating both person and virtual environment in sync to create the illusion of infinite movement. Filed provisional patent March 19, 2021. Trademarked "InfiniSet." Formed InfiniSet, Inc. as a Delaware C-Corp. **Patent Filing Timeline & Attorney Correspondence (pp. 20–27):** Extensive email correspondence with IP attorney Amanda Prose and paralegal Megan Neumann at the WCK law firm, documenting: provisional patent filing (March 19, 2021); non-provisional Track One patent application; PCT international application filed June 28, 2022; International Publication WO 2022/198028 (September 22, 2022); US Patent Publication US 2022/0297024 A1 (September 22, 2022); detailed technical progress on the prototype including servo motors, planetary gears, treadmill belt mechanics, and LED lighting. **The PhotoRobot Diversion & Netflix Patent Discovery (pp. 28–41):** On October 31, 2022, Guertin received an email from Assaff Rawner, CEO of Mark Roberts Motion Control (MRMC), in response to Guertin's inquiry about integrating the Bolt Cinecam. Rawner included a link to PhotoRobot's "Virtual Catwalk"—a rotating treadmill product that alarmed Guertin. On November 5, 2022, Guertin searched the USPTO database and discovered Netflix's patent application (later US Patent No. 11,810,254) filed by Stephan Trojansky, addressed to Netflix HQ in Silicon Valley, filed just 12 days after Guertin's provisional filing (March 31, 2021 vs. March 19, 2021). His attorney Amanda Prose confirmed his claims appeared strong and that the situation was essentially "winning the lottery." **Strategic Response & Welder Connection (pp. 41–50):** Guertin consulted attorney Bruce Rivers ("CLR Bruce Rivers"), a well-known YouTube legal commentator and longtime personal attorney. He met with another local IP attorney who also described it as "winning the lottery." Guertin told everyone about the Netflix discovery as a protective strategy. Text exchanges with his welder (referred to as "Jeffrey"), who had claimed to be "former CIA," are reproduced in full. The welder had texted "Have they got to you yet?" on December 5, 2022. Guertin's analysis of the situation—that Netflix's best option was to buy his patent rather than harm him—is laid out. **PhotoRobot Website Fraud Investigation (pp. 50–62):** Starting early December 2022, Guertin investigated PhotoRobot's website using the Wayback Machine, discovering that language on the "Virtual Catwalk" page had been recently altered to include terms like "infinite" and "filming" that aligned with his patent claims. He created a Wayback Machine account under the username "PatentlyFalse" on December 9, 2022, and began systematic downloads and comparisons. He used MAXQDA text analysis software, Google Docs compare function, and custom spreadsheets. He contacted the Internet Archive about removal policies (December 15, 2022) and received a response from Wayback Machine Director Mark Graham (December 29, 2022). **The JavaScript Timestamp Discovery (pp. 64–66):** In early January 2023, Guertin discovered that JavaScript files within archived PhotoRobot pages contained timestamp anomalies—nearly all showing dates clustering around December 9, 2022 (the date he created his Wayback Machine account), regardless of their supposed archive date. He interpreted this as evidence that present-day versions of the website were being injected into past archive dates—a "smoking gun." **FBI & Minnetonka Police Contacts (pp. 72–76):** On January 12, 2023, Guertin drove to the FBI field office in Brooklyn Center, MN, waited on hold 25 minutes, spoke to an agent about "wire fraud," was asked about money being wired (confused wire fraud with wire transfer), and was hung up on. He then went to the Minnetonka Police Department where Officer Brandon Harris documented his findings in Report #23-000151. Harris acknowledged the evidence was extensive but stated Minnetonka PD lacked the resources for digital fraud. **Cracking the Code & Escalation (pp. 74–89):** On January 13, 2023, Guertin sent Amanda Prose his "smoking gun" spreadsheets, including five detailed data analysis files. He also emailed Bruce Rivers asking for help finding federal investigators. He emailed Robert Hulse at Fenwick (the IP attorney on the Netflix/Trojansky patent) from a burner Gmail account. Amanda Prose responded noting she was "not surprised at the FBI reaction" and calling the email to the Netflix patent attorney "an interesting move." **Discovery of AI-Generated Content (pp. 83–91):** On January 17, 2023, Guertin discovered what he believed were AI-generated deepfake videos, AI-written articles (attributed to "Samantha McDonald" with 2,500 articles and "Madeline Streets" with 540 articles on FootwearNews.com), and a 47-minute Zoom call featuring people he believed were deepfakes. He questioned whether PhotoRobot itself was a real company, claiming their 76-page product catalog contained AI-generated images of equipment. He sent seven groups of PDF evidence to Amanda Prose (~150MB total). Amanda confirmed receipt and shared the Weinhoffer v. Davie Shoring case (23 F.4th 579, 5th Cir. 2022) regarding limitations of Wayback Machine evidence. **The Bluetooth Discovery & Psychological Break (pp. 93–100):** On January 19, 2023, after disconnecting his computer from the internet entirely, Guertin found evidence of continued external communications through a Bluetooth Personal Area Network using the built-in wireless adapter of his X399 TAICHI motherboard. He discovered two antennas still screwed onto the motherboard's built-in adapter. This convinced him that the threat was physically proximate—within 30 feet, possibly in the neighboring apartment unit. This event is described as "the flipping of the switch" that triggered an extreme fear response. Guertin became convinced he would be killed. **Barricading and Wall Writing (pp. 97–110):** Over January 19–21, 2023, Guertin taped deadbolts shut, covered windows and patio door with Mylar space blankets, barricaded the rear door with a custom LED light bar, and barricaded the front door with a scissor jack and conduit pipe. He painted large black letters across his living room wall with patent numbers, "MY PATENT," "NETFLIX PATENT," "KILL ME STEAL," "TROJANSKY," "EYELINE STUDIOS," and other text. He wrote on a wall column: "I didn't want to have to do this but it was the only way I could be sure that my call actually got through. They all went up into the sky out my bedroom window. I hope I don't die but this was the best option I could think of – Matt." He wrote "They are going to kill me / Stealing my patent / 'Illusion of movement' / CASE # 23-000151 / 2pm" on another wall. He taped an FBI business card to a wall and wrote "I went to the FBI in Brooklyn Center first — before Mntka PD — who knows if that call actually got through." **The Gunshots — January 21, 2023 (pp. 110–125):** On Saturday morning, January 21, 2023, after approximately three hours of sleep over several days and no Adderall (prescription unfillable due to supply chain issues), Guertin decided to fire his AR-15 (self-built in 2020) from his bedroom window as an "analog signal" to guarantee police response. He describes his reasoning: he could not trust phone calls (believing they could be intercepted/faked by AI), believed his life was in imminent danger, and saw firing the weapon as a mathematically predictable way to force a police response. He chose Saturday morning for safety reasons (daylight, neighbors home as witnesses, alert officers). He first threw patent documents out the window, then fired one shot upward through the bedroom window, shattering the glass. He then fired three more shots. He cut his hand on broken glass. **The Standoff & Surrender (pp. 125–138):** Police surrounded the building. Guertin demanded to speak only to a Minnetonka officer. An officer confirmed identity by accurately describing the police station lobby mural. Guertin asked about snipers he spotted in the trees; the officer told him not to worry about them. Guertin asked to eat before surrendering. He ate Triscuits, salami, cheese, and a banana for approximately 30 minutes while SWAT snipers watched. He then dismantled the front door barricade, extended his hands palms-open through the doorway, was handcuffed (initially too tight), and led to a squad car. He was driven to the Minnetonka Police Station where he experienced a full panic attack/hyperventilation episode in an interview room. He describes wanting to go to jail simply to sleep. **Sequel Teaser & Appendix (pp. 138–140):** A brief epilogue noting that Part 2 will cover the court proceedings. An appendix lists online resources including: Substack page (Matt1Up.Substack.com), Storj file sharing links, Rumble page, Odysee page, Instagram, YouTube, Vimeo, MattGuertin.com, federal civil rights lawsuit on CourtListener (Docket 68925331), 8th Circuit appeal (Docket 69060054), Guertin's patent on Google Patents (US11577177B2), and the Netflix/Trojansky patent (US11810254B2). **PDF Metadata:** Created April 10, 2025, using PyPDF2, modified using iText 7.1.16 (Minnesota Judicial Branch licensed version). This indicates the document was processed through the Minnesota Judicial Branch's electronic filing system. --- ### Legal Issues & Arguments Raised - **Admission of Exhibit A into official court record** as conclusive evidence of patent theft and corrective record - **Challenge to mental illness findings** in Court's March 5, 2025 competency order—Guertin argues findings of psychotic disorder are unsupported by the full factual record - **Discovery fraud / evidence tampering** — manipulation of discovery photos and metadata via Hennepin County's OneDrive system - **Judicial complicity** in maintaining false narrative through reliance on manipulated evidence and deceptive mental health reports - **Patent misappropriation** — US Patent 11,577,177 (Guertin) vs. US Patent 11,810,254 (Netflix/Trojansky), filed 12 days apart - **Conspiracy under 42 U.S.C. § 1983** (civil rights deprivation) — referenced from parallel federal lawsuit - **Violation of constitutional rights** through false competency/incompetency determinations over 26+ months - **Request for sanctions** against judicial, prosecutorial, and administrative personnel - **Request for comprehensive evidentiary review** of all discovery materials and competency evaluations - **Wayback Machine evidentiary reliability** — cites Weinhoffer v. Davie Shoring, 23 F.4th 579 (5th Cir. 2022) --- ### Factual Allegations & Key Assertions - Guertin conceived InfiniSet (motorized rotatable treadmill for virtual production) in early February 2021 after visiting Xite Labs' LED volume stage in November 2020 - Filed provisional patent application March 19, 2021—his first ever - Stephan Trojansky filed a nearly identical patent application (later US 11,810,254) on March 31, 2021—12 days after Guertin's - Trojansky/Netflix patent lists Guertin's name and patent at the top - The Netflix patent address traces to Netflix corporate HQ in Silicon Valley - Guertin's patent was published September 22, 2022 (WO 2022/198028 and US 2022/0297024 A1) - On October 31, 2022, MRMC CEO Assaff Rawner sent Guertin a link to PhotoRobot's "Virtual Catwalk," triggering the investigation - PhotoRobot's website was being actively altered to insert language matching Guertin's patent claims, verified via Wayback Machine comparisons - JavaScript timestamp anomalies in archived PhotoRobot pages showed clustering around December 9, 2022 - Guertin claims the Internet Archive itself was either complicit or compromised - AI-generated deepfake videos, AI-written articles, and fabricated company content were discovered on FootwearNews.com and related sites - Guertin's computer experienced a Blue Screen of Death on January 2, 2023, which he attributes to remote hacking - A Bluetooth Personal Area Network was discovered active on his disconnected workstation on January 19, 2023 - Guertin's welder ("Jeffrey"), who claimed to be "former CIA," texted "Have they got to you yet?" on December 5, 2022 - Guertin visited the FBI field office in Brooklyn Center on January 12, 2023, and was dismissed - Guertin filed Minnetonka Police Report #23-000151 on January 12, 2023, with Officer Brandon Harris - Guertin was unable to refill his Adderall prescription due to COVID supply chain disruptions - Guertin fired four AR-15 rounds from his bedroom window on January 21, 2023, as a deliberate signal to force police response - He threw patent documents out the window before/after shooting - He had written extensively on his apartment walls documenting the conspiracy - He barricaded both apartment doors and covered windows with Mylar - SWAT responded; Guertin surrendered peacefully after eating - LinkedIn search data from his profile allegedly shows searches by DIA, DARPA, US Indo-Pacific Command, US State Department, US Air Force, State of Rhode Island, Forcepoint, Triple Inc., Inhance Digital, Uptv/InterMedia, Henry Street Settlement, and Gentle Giant Studios during critical periods of his case (July–August 2023) - 25 LinkedIn searches occurred in the week of July 20, 2023—the same day a civil commitment order was filed against him - Discovery photos provided to the psychologist conducting his August 1, 2023 civil commitment exam are alleged to have been manipulated --- ### Procedural Posture This filing responds to the Court's March 5, 2025 order finding Guertin competent to proceed while maintaining findings of mental illness. It is filed more than 26 months after Guertin's initial charges originated on January 21, 2023. The filing sits within the context of: - Ongoing criminal proceedings (27-CR-23-1886) with multiple prior competency evaluations - A federal civil rights lawsuit (Guertin v. Hennepin County, 0:24-cv-02646-JRT-DLM, filed July 8, 2024) - An 8th Circuit appeal - A prior Rule 20 examination (initial meeting March 1, 2023, with Dr. Jill Rogstad) - A civil commitment exam on August 1, 2023 - A civil commitment order filed July 20, 2023 - An order staying civil commitment (August 3/4, 2023) - Prior omnibus hearing on July 7, 2023 - Prior submissions of evidence regarding discovery photo manipulation and metadata tampering The document is filed pro se and is characterized as a defendant's evidence exhibit rather than a formal motion, though it requests specific relief. --- ### Exhibit / Attachment Inventory The 153-page PDF is a single integrated document containing: | Label | Description | |---|---| | Cover Motion (pp. 1–13) | Legal motion requesting admission of Exhibit A | | Exhibit A (pp. 1–140, internal pagination) | Full narrative document "Netflix Whistleblower Is Found Alive and Well \| Part 1 – The Patent" | | Market Projection Table (Exh. A p. 1) | Revenue projections for US Patent 11,577,177 totaling $390B over 20 years | | Federal Complaint Excerpt (Exh. A p. 2) | Reproduced page from CASE 0:24-cv-02646-JRT-DLM Doc. 77, p. 25 of 128, filed 09/24/24 | | Satirical Review Quotes (Exh. A p. 3) | Five fictional reviews with punning names referencing case figures | | Embedded Email Correspondence (throughout) | ~70+ email excerpts between Guertin and Amanda Prose/Megan Neumann (WCK), Bruce Rivers, Assaff Rawner (MRMC), Internet Archive, and others, spanning March 2021 – January 2023 | | Embedded Text Message Transcripts (throughout) | Text exchanges with "former CIA" welder Jeffrey, and personal friends | | Appendix Resource Links (Exh. A pp. 139–140) | URLs for Substack, Storj files, Rumble, Odysee, Instagram, YouTube, Vimeo, MattGuertin.com, CourtListener dockets, Google Patents | **Cross-referenced exhibits from other filings (cited but not included in this PDF):** - Index 125, Exhibit M (Netflix patent comparison) - Index 125, Exhibit N (LinkedIn search background investigation documents) - Index 125, Exhibit Q (LinkedIn searches by government entities during commitment proceedings) - Index 125, Exhibit S (email correspondence with Amanda Prose) - Index 30 (LinkedIn search count graph and related data, multiple page references) --- ### Visual Evidence Inventory - **[Motion p. 4 / Exh. A related] [Annotated Timeline Infographic]:** Color-coded timeline graphic showing LinkedIn search activity from July 2023 through August 2023 correlated with court events. Left column shows events (omnibus hearing 7/7/23, civil commitment filed 7/20/23, mental health hearing 8/1/23, stayed commitment 8/3-4/23, Netflix fraud discovery 8/8/23, State Dept/Air Force search 8/11/23, evidence collection 8/12-15/23). Right side shows numbered search counts (3, 25, 7, 18) with official seals/logos of: SpillIt, State of Rhode Island, DIA, DARPA, US Indo-Pacific Command, US Department of State, US Air Force. Red and blue timeline connections link events to search spikes. **Notable:** This is a defendant-created infographic, not an official court or government document. - **[Motion p. 5] [Three Mobile Phone Screenshots - Text Messages]:** Three screenshots of text message conversations. (1) Message labeled "Me" at 8:12 AM, May 23, discussing conversation with Bruce Rivers about AI-produced videos and "powerful people keeping an eye on you." (2) Messages to a contact whose name is redacted (green "S" avatar), dated May 23-24, discussing court hearing being moved to Zoom and concerns about communications being monitored. (3) Message labeled "Me" at 11:18 PM, May 24, expressing fear of being "monitored and watched by 'powerful people'" and worry they will kill him. **Anomaly note:** Contact name in middle screenshot is blacked out/redacted. - **[Motion p. 6] [Email Screenshot]:** Email from mattguertin (MattGuertin@protonmail.com) to Amanda Prose (aprose@wck.com), CC Megan Neumann (mneumann@wck.com), dated Saturday May 27, 2023 at 5:42 AM, subject "Re: Update." Content discusses forensic analysis services, trademark filings, Madrid PDF v3, "powerful people keeping an eye on me," and states "I'm of the opinion that pretty soon I'm either going to be very dead or very rich." - **[Motion p. 7] [Email Screenshot]:** Email from mattguertin to Amanda Prose, CC Megan Neumann, dated Wednesday May 30, 2023 at 8:27 PM, subject "Re: Update." Content urges Amanda to speak with his criminal defense attorney in person, references "very powerful people keeping an eye on me" from a "well known attorney who works in the federal court system," and states "I'm afraid I'm going to be disappeared or killed." - **[Motion p. 8] [Composite Image - Forcepoint/Government Cybersecurity]:** A defendant-created slide titled "1/21/23 – 'Forcepoint, FOX, and 3Gimbals' conduct a search for Guertin's LinkedIn page." Below is a screenshot of the Forcepoint website ("Global Government Cybersecurity") with a quote from Major General Joe Brendler, U.S. Army (Retired), praising Forcepoint as a "trusted mission partner of the U.S. Government for over two decades." URL https://www.forcepoint.com/ visible. **Note:** This is a defendant-assembled exhibit connecting a LinkedIn search to a government cybersecurity contractor. - **[Exh. A p. 14] [Photograph of Apartment Interior]:** Wide-angle color photograph of Guertin's apartment living room showing large black handwritten text spray-painted on the white walls. Visible text includes: "MY PATENT," "WO 2022," "198028 A1," "022914," "NETFLIX PATENT," "PCT/US2022," "020919," "WO2022/212761," "KILL ME STEAL" with arrow, "TROJANSKY A1," "EYELINE STUDIOS." The room contains a green screen setup (bright green backdrop material on wall and floor), wooden slats on the floor, a yellow item, storage bins, and various equipment. A doorway to a hallway is visible. Additional writing visible on walls near the doorway. **Forensic note:** This photograph appears to be from the January 21, 2023 crime scene and shows the condition of the apartment when police would have entered. The writing documents patent numbers and entities Guertin was alleging were involved in the conspiracy. - **[Exh. A p. 15] [Five Photographs of Apartment Interior]:** 1. **Broken sliding glass door/window:** Color photo showing shattered glass in a sliding patio door frame. A red fire extinguisher lies on the balcony deck among broken glass. Snow visible outside. Balcony railing and winter trees visible. Chair on balcony. **Forensic note:** This appears to document the window broken by gunfire on January 21, 2023. 2. **Handwritten message on wall column (B&W photo):** Black and white photograph of a structural column in the apartment covered with handwritten text in black marker: "I didn't want to have to do this but it was the only way I could be sure that my call actually got through. They all went up into the sky out my bedroom window. I hope I don't die but this was the best option I could think of – Matt." Apartment interior visible on both sides showing disorder—items on surfaces, furniture. **Forensic note:** This is Guertin's written explanation of the gunshots, left for police to find. 3. **Handwritten journal page (notebook paper):** Large photograph of a handwritten page on lined notebook paper with sections highlighted in yellow. Text discusses looking around his apartment, awareness it looks like he's lost his mind, the Netflix patent filed 12 days after his, Netflix spending "at least 1/4 billion dollars," fear of being killed, files he's been collecting as proof, "A QUARTER BILLION DOLLARS," belief a "hit" has been put out on him, and discovery of the Netflix patent after emailing Mark Roberts Motion Control CEO. Yellow highlighting emphasizes: "Netflix found out about my patent way before I found out about theirs. That's for sure," "There's a lot of things I was never supposed to realize or figure out," and "the existence of the Netflix patent." **Forensic note:** This appears to be physical writing from the January 19-21, 2023 period documenting Guertin's state of mind. 4. **Wall writing - "They are going to kill me":** Color photograph of white wall/door surface with handwritten text: "They are going to kill me" (with "kill" underlined), "Stealing my patent," "'Illusion of movement'" (in quotes), "CASE # 23-000151," "2pm." **Forensic note:** The case number matches the Minnetonka Police Report filed January 12, 2023. "Illusion of movement" references the patent title. 5. **Wall writing with FBI card:** Color photograph of white wall with FBI business card taped to it using blue painter's tape (card appears to be standard "U.S. Department of Justice / Federal Bureau of Investigation" format). Below it is handwritten text: "I went to the FBI in Brooklyn Center first — before Mntka PD — who knows if that call actually got through." Below that, in very large letters at bottom of frame: "MNTKA PD" (partially visible). **Forensic note:** The FBI card corroborates the narrative's account of visiting the FBI Brooklyn Center field office on January 12, 2023. - **[Throughout document] [Repeated watermark/header image]:** A 401×463 pixel image appears on every page—this is the Minnesota Judicial Branch electronic filing header/watermark containing the case number, filing date, and court designation. --- ### Key People Referenced | Person | Role/Affiliation | Context | |---|---|---| | **Matthew David Guertin** | Defendant, pro se; inventor; founder of InfiniSet, Inc. | Central figure; author of Exhibit A; patent holder US 11,577,177 | | **Judge Sarah Hudelston** | Judicial Officer, Hennepin County District Court | Presiding judge; issued March 5, 2025 competency order | | **Mary F. Moriarty** | Hennepin County Attorney | Named recipient of motion | | **Mawerdi Ahmed Hamid** | Assistant Hennepin County Attorney | Named recipient of motion; prosecutor | | **Amanda Prose** | IP Attorney, WCK law firm (aprose@wck.com) | Guertin's patent attorney throughout 2021–2023; primary recipient of investigation emails | | **Megan Neumann** | Paralegal/Associate, WCK law firm (mneumann@wck.com) | Handled patent filings, trademark, PCT application | | **Bruce Rivers ("CLR Bruce Rivers")** | Criminal defense attorney, YouTube legal commentator (1.3M+ subscribers) | Guertin's longtime personal attorney; consulted on Netflix situation Nov 2022–Jan 2023 | | **Assaff Rawner** | CEO, Mark Roberts Motion Control (MRMC) | Sent Guertin the PhotoRobot link Oct 31, 2022; Guertin later accuses him of orchestrating fraud | | **Gordon Eschke** | Employee, MRMC | Forwarded Guertin's initial inquiry to Rawner | | **Stephan Trojansky** | Named inventor on Netflix patent US 11,810,254 | Filed patent March 31, 2021 (12 days after Guertin); referenced punningly in satirical quotes as "TrojanHeist" | | **Robert Hulse** | IP Attorney, Fenwick & West LLP | Listed on Trojansky/Netflix patent; Guertin sent anonymous evidence email to him | | **Officer Brandon Harris** | Minnetonka Police Department | Filed Police Report #23-000151 on Jan 12, 2023; described as having "the most perfect full beard" | | **Mark Graham** | Director, Wayback Machine / Internet Archive | Responded to Guertin's inquiry about archive removal policies | | **"Jeffrey" (Welder)** | Guertin's welder; self-described "former CIA" | Welded prototype components; texted "Have they got to you yet?"; Guertin suspected him of intelligence connections | | **Dr. Jill Rogstad** | Psychologist | Conducted initial Rule 20 examination (meeting March 1, 2023) | | **Paul Debevec** | Historical figure in VFX/Light Stage technology | Referenced via satirical name "Paul Debunkvec"; Guertin claims his Light Stage technology is "fraudulently represented" | | **Jeremy Reiss** | Executive VP, Henry Street Settlement; Fulbright Specialist with US Dept of State | LinkedIn search connection between Henry Street Settlement and State Department | | **Tom Daschle** | Leader of InterMedia Advisors/Partners | Connections to US Air Force and Netflix cited | | **Alan Sokol** | Associated with InterMedia Advisors/Partners | Connections to Netflix cited | | **Major General Joe Brendler** | U.S. Army (Retired); quoted endorsing Forcepoint | Visible in image on p. 8 of motion | --- ### Key Entities / Organizations Referenced | Entity | Type | Context | |---|---|---| | **Netflix** | Entertainment company | Alleged patent theft via US Patent 11,810,254; Q1-2022 investor report; $100M alleged acquisition budget | | **InfiniSet, Inc.** | Guertin's company (Delaware C-Corp) | Patent assignee; "corporate HQ" was his apartment | | **Mark Roberts Motion Control (MRMC)** | Robotic camera company (UK) | CEO sent PhotoRobot link; maker of Bolt Cinecam; Guertin alleges CEO orchestrated fraud | | **PhotoRobot** | Czech-based photography robotics company | "Virtual Catwalk" product; Guertin alleges extensive website fraud | | **WCK Law Firm** | IP law firm | Guertin's patent attorneys (Prose, Neumann) | | **Fenwick & West LLP** | IP law firm | Attorneys for Netflix/Trojansky patent | | **Internet Archive / Wayback Machine** | Digital archive | Guertin alleges complicity or compromise in serving fake archived pages | | **USPTO** | Federal patent office | Granted both Guertin's and Netflix's patents | | **FBI (Brooklyn Center field office)** | Federal law enforcement | Guertin visited Jan 12, 2023; dismissed | | **Minnetonka Police Department** | Local law enforcement | Filed Report #23-000151; responded to Jan 21, 2023 shots fired | | **Defense Intelligence Agency (DIA)** | US military intelligence | Allegedly searched Guertin's LinkedIn | | **DARPA** | Defense research agency | Allegedly searched Guertin's LinkedIn | | **US Indo-Pacific Command** | US military command | Allegedly searched Guertin's LinkedIn | | **US State Department** | Federal agency | Allegedly searched Guertin's LinkedIn | | **US Air Force / 4th US Air Force** | Military branch | Allegedly searched Guertin's LinkedIn multiple times | | **State of Rhode Island** | State government | Allegedly searched Guertin's LinkedIn on July 20, 2023 | | **Forcepoint** | Government cybersecurity firm (former Raytheon subsidiary) | Searched Guertin's LinkedIn week of Jan 21, 2023 | | **Triple Inc.** | Aircraft parts manufacturer | Connections to Raytheon/Forcepoint | | **Inhance Digital** | Digital company (clients: US Air Force, Microsoft, Booz Allen) | Searched Guertin's LinkedIn April 16, 2022 | | **Uptv / InterMedia Advisors/Partners** | Media companies | Connections to Netflix via Daschle/Sokol | | **Gentle Giant Studios** | Entertainment production (clients: Netflix, Marvel) | Linked to MOVA Contour technology | | **Henry Street Settlement** | Nonprofit (NYC) | Jeremy Reiss connection to State Department | | **SpillIt** | Entity/company | Shown in timeline infographic; "has a direct connection to CNN and Netflix" | | **Xite Labs** | Virtual production studio (Calabasas, CA) | Guertin's former workplace; LED volume stage | | **FootwearNews.com** | Online publication | Guertin alleges hosted AI-generated articles by fake authors | | **1WorldSync.com** | Data syndication company | Referenced as related to PhotoRobot fraud network | | **Eyeline Studios** | VFX company | Written on apartment walls; connected to Trojansky | | **Hennepin County District Court** | State court | Guertin alleges complicity in conspiracy | | **MN Federal District Court** | Federal court | Venue for civil rights lawsuit (0:24-cv-02646-JRT-DLM) | | **8th Circuit Court of Appeals** | Federal appellate court | Guertin filed pro se appeal | | **Snap36** | Former US distributor for PhotoRobot | Referenced in investigation | | **StyleFlip.com** | DJ skins business | Guertin's 2008 business venture, still operating in Minneapolis | | **Booz Allen** | Consulting/defense contractor | Client of Inhance Digital | | **Raytheon** | Defense contractor | Former parent of Forcepoint | | **Microsoft** | Technology company | Client of Inhance Digital | | **Marvel** | Entertainment company | Client of Gentle Giant Studios | --- ### Dates & Deadlines Mentioned | Date | Event | |---|---| | Early February 2021 | Guertin conceives InfiniSet invention | | March 19, 2021 | Guertin files provisional patent application (first ever) | | March 31, 2021 | Trojansky/Netflix files competing patent application (12 days later) | | November 28, 2021 | Earliest US Air Force search of Guertin's LinkedIn | | April 8, 2023 (retroref) | Triple Inc. searches Guertin's LinkedIn | | April 16, 2022 | Inhance Digital searches Guertin's LinkedIn | | April 23, 2022 | Gentle Giant Studios searches Guertin's LinkedIn | | May 21, 2022 | Uptv searches Guertin's LinkedIn | | June 28, 2022 | PCT patent search report and written opinion received | | August 2, 2022 | Trademark Office Final Action on INFINISET | | September 22, 2022 | Patent applications published (WO 2022/198028 and US 2022/0297024 A1) | | October 31, 2022 | MRMC CEO Assaff Rawner emails Guertin with PhotoRobot link | | November 5, 2022 | Guertin discovers Netflix patent; emails Amanda Prose "Please tell me it is going to be okay" | | November 8–9, 2022 | Guertin processes Netflix discovery; emails about corporate structure, $100M price | | November 11, 2022 | Guertin calls/emails Bruce Rivers about Netflix situation | | November 14, 2022 | InfiniSet, Inc. registered in Minnesota | | December 5, 2022 | Welder texts "Have they got to you yet?" | | December 9, 2022 | Guertin creates Wayback Machine account ("PatentlyFalse") | | December 12, 2022 | Guertin reports PhotoRobot website alterations to attorney | | December 15, 2022 | Guertin contacts Internet Archive about removal policies | | December 28, 2022 | Guertin identifies MRMC CEO as "mastermind" | | December 29, 2022 | Mark Graham (Wayback Machine Director) responds | | January 2, 2023 | Blue Screen of Death event; first signs of alleged hacking; Guertin claims Wayback Machine is serving fake pages | | January 4, 2023 | Amanda Prose requests call about Dropbox materials | | January 5, 2023 | JavaScript timestamp glitch discovered | | January 12, 2023 | Guertin visits FBI (Brooklyn Center) and Minnetonka PD; Police Report #23-000151 filed | | January 13, 2023 | "Smoking gun" spreadsheets sent to attorney; emails to Bruce Rivers and Robert Hulse (Fenwick) | | January 17, 2023 | Discovery of AI-generated content; seven groups of PDFs sent to attorney | | January 18, 2023 | AI deepfake video discovery; Wayback Machine case law shared by attorney; second failed police station visit | | January 19, 2023 | Bluetooth Personal Area Network discovery; psychological break begins; Guertin begins barricading apartment | | January 21, 2023 | Guertin fires AR-15 from bedroom window; SWAT response; peaceful surrender; arrest | | March 1, 2023 | First Rule 20 exam meeting with Dr. Jill Rogstad | | May 23–30, 2023 | Text messages and emails about being monitored by "powerful people" | | July 7, 2023 | Omnibus court hearing | | July 20, 2023 | Order of civil commitment filed; 25 LinkedIn searches (all-time weekly record) | | July 27, 2023 | DARPA/DIA/INDOPACOM LinkedIn searches | | August 1, 2023 | Mental health court hearing over Zoom; civil commitment exam | | August 3-4, 2023 | Stayed Order of Commitment granted | | August 8, 2023 | Guertin discovers Netflix fraud (per timeline graphic) | | August 11, 2023 | State Department and 4th US Air Force LinkedIn searches | | September 28, 2023 | Henry Street Settlement and DARPA LinkedIn searches | | July 8, 2024 | Federal civil rights lawsuit filed (Guertin v. Hennepin County) | | August 7, 2024 | Motion for Expedited Preliminary Injunction filed in federal court | | September 24, 2024 | Federal complaint Doc. 77 filed (page reproduced in Exhibit A) | | March 5, 2025 | Court order finding defendant competent to proceed, with continued mental illness findings | | April 10, 2025 | This filing date | --- ### Forensic Flags & Anomalies 1. **Self-representation and narrative framing:** The 140-page Exhibit A is written in a literary/journalistic prose style with chapter titles, dramatic pacing, and third-person narration—highly unusual for a court filing. This suggests the document was originally prepared for public consumption (Substack) and repurposed as a court exhibit. 2. **Satirical "review quotes" on page 3:** The fictional reviewer names are elaborate wordplay directly mocking key figures in the case (Debevec → "Debunkvec," Trojansky → "TrojanHeist," Eyeline Studios → "EyeLie Studios"). This is provocative content submitted to the Court and could affect judicial reception. 3. **Market projection table:** Claims $390 billion in 20-year revenue potential across multiple industries for a single patent—an extraordinarily speculative valuation with no cited methodology. 4. **Discovery photo manipulation claims:** The filing repeatedly references proven manipulation of discovery photos via Hennepin County's OneDrive system. If this claim is supported elsewhere in the record (referenced as "now irrefutably proven" and "locked in"), it would be a significant due process issue regardless of the patent conspiracy claims. 5. **LinkedIn search data:** The core surveillance claim rests on LinkedIn analytics showing searches by government/military entities. The provenance and authentication of this data is not established within this document—it references other exhibits (Index 125, Exhibit Q; Index 30) and external file repositories. 6. **Temporal correlation claims:** Guertin draws correlations between LinkedIn search spikes and court events (e.g., 25 searches on the exact day civil commitment was filed). While presented as evidence of coordinated surveillance, these correlations are not independently verified within this filing. 7. **Adderall discontinuation:** The narrative mentions Guertin was unable to refill his Adderall prescription in the days preceding January 21, 2023, due to COVID supply chain disruptions. This is potentially significant for the competency/mental health evaluations. 8. **Sleep deprivation:** Guertin reports approximately three hours of sleep over multiple days preceding the gunshot incident. Combined with Adderall discontinuation, this represents significant physiological stress factors. 9. **Apartment as both crime scene and evidence repository:** The photographs show the apartment simultaneously served as Guertin's living space, prototype fabrication studio, evidence archive, and the scene of the January 21 incident. The wall writings, while dramatic, are internally consistent with the narrative and create a contemporaneous record. 10. **PDF metadata:** The document was created using PyPDF2 and modified by iText 7.1.16 licensed to the Minnesota Judicial Branch. This confirms processing through the official court e-filing system. 11. **Email authenticity offer:** Guertin repeatedly offers to forward original emails for forensic verification—a notable transparency gesture that could be significant for authentication purposes. 12. **Dual nature of document:** The filing simultaneously: (a) requests formal legal relief from the Court, and (b) functions as a 140-page public-facing narrative designed for viral distribution (with Substack links, social media links, donation links). This dual purpose is unusual and raises questions about whether the Court will treat it as a proper legal submission. 13. **Firearm details:** Guertin states he built the AR-15 himself in 2020 as part of a "self-defense project." The weapon had been "untouched for over two years" before January 21, 2023. 14. **Multiple failed help-seeking attempts:** The narrative documents a systematic pattern of seeking help through proper channels (FBI, local police, patent attorney, criminal attorney, Secret Service reference) before resorting to the gunshot signal—potentially relevant to mens rea and mental state analysis. 15. **"Former CIA" welder:** The welder's text "Have they got to you yet?" and the subsequent claim that the welder called Guertin five minutes after a Secret Service call (discussing the same topic) are presented as evidence of surveillance but could have alternative explanations. --- ### Cross-References *(Note: Prior batch catalogs not yet available. Cross-references to external filings cited within this document:)* - **Index 125, Exhibit M** — Netflix patent comparison (US 11,577,177 vs. US 11,810,254) - **Index 125, Exhibit N** — LinkedIn search background investigation documents (Index 02, multiple page ranges) - **Index 125, Exhibit Q** — LinkedIn searches by government/military entities during commitment proceedings - **Index 125, Exhibit S** — Email correspondence (Index 09, pp. 02–03) - **Index 30** — LinkedIn search count graph and related data (pp. 58, 146, 153, 160, 206) - **Federal Case: Guertin v. Hennepin County, 0:24-cv-02646-JRT-DLM** (MN Federal District Court, filed July 8, 2024) - **Federal Doc. 42** — Motion for Expedited Preliminary Injunction (filed August 7, 2024), pp. 59–69 cited - **Federal Doc. 77** — Filed September 24, 2024, p. 25 of 128 reproduced - **8th Circuit Appeal** — CourtListener Docket 69060054 - **Minnetonka Police Report #23-000151** — Filed January 12, 2023, Officer Brandon Harris - **Weinhoffer v. Davie Shoring, 23 F.4th 579 (5th Cir. 2022)** — Case on Wayback Machine evidentiary reliability, cited by Amanda Prose - **US Patent 11,577,177** (Guertin) — "Motorized Rotatable Treadmill and System for Creating the Illusion of Movement" - **US Patent 11,810,254** (Netflix/Trojansky) — The alleged duplicate patent - **WO 2022/198028** — PCT international publication - **US 2022/0297024 A1** — US patent publication - **Court Order, March 5, 2025** — Finding defendant competent with continued mental illness findings --- ## Filing #9 — Defendant's Motion for Substitute Counsel | Field | Detail | |---|---| | Filing # | 9 | | Date Filed | June 3, 2024 | | Filed By | Matthew David Guertin (Defendant, Pro Se) | | Document Type | Motion for Substitute Counsel | | Case/Court | 27-CR-23-1886 / Fourth Judicial District, Hennepin County, MN | | Pages | 4 | | Bates / Doc ID | MCRO_27-CR-23-1886_Motion_2024-06-03_20240603092053.pdf | ### Comprehensive Summary This is a pro se motion by defendant Matthew David Guertin requesting the court appoint substitute counsel to replace his current attorney, Bruce Rivers. Guertin asserts serious allegations of ineffective assistance of counsel against Rivers, supported by evidence he states is already part of the case record. The motion is addressed to Judge Jay Quam, Judge Julia Dayton Klein, Assistant Hennepin County Attorney Jacqueline Perez, the Clerk of Court, and the Hennepin County Attorney's Office. Guertin's central argument is that his Sixth Amendment right to effective assistance of counsel has been compromised. He details multiple instances of alleged attorney misconduct by Rivers, including: failure to provide discovery materials and the January 3, 2024 Rule 20.01 exam report prepared by Dr. Adam Milz; failure to present exculpatory evidence during Guertin's July 7, 2023 court hearing; a conflict of interest and a statement allegedly made by Rivers about "powerful people keeping an eye on" Guertin during a June 16, 2023 email communication; and a broken promise to represent Guertin in civil commitment proceedings. Each allegation is supported by specific cross-references to other index numbers within the case docket (primarily Index #30 and #38). Guertin further argues that the court itself has refused to provide necessary discovery materials and has failed to address his other motions, compounding the violation of his due process rights. He invokes Strickland v. Washington, 466 U.S. 668 (1984) as the legal standard for ineffective assistance. The motion requests that new counsel (preferably a public defender) be appointed, and that the new counsel receive all discovery materials. Guertin states this appointment is needed as an interim measure until he can recover the retainer paid to Rivers and secure new private defense counsel. The motion also emphasizes the court's obligation to ensure a fair trial. ### Legal Issues & Arguments Raised - Ineffective assistance of counsel under the Sixth Amendment and Strickland v. Washington - Failure to provide discovery materials (including Rule 20.01 exam report by Dr. Adam Milz) - Failure to present exculpatory evidence at July 7, 2023 hearing - Attorney conflict of interest - Breach of promise to represent in civil commitment proceedings - Court's refusal to provide discovery materials and address defense motions - Due process violations - Right to a fair trial ### Factual Allegations & Key Assertions - Bruce Rivers failed to provide discovery materials and the January 3, 2024 Rule 20.01 exam report by Dr. Adam Milz (Index #30, pp. 37–38, 83, 85, 135; Index #38, p. 143) - Rivers failed to present exculpatory evidence in his possession at the July 7, 2023 hearing (Index #30, p. 60; Index #38, pp. 99–100, 102–103, 113–116, 118–119) - Rivers had a conflict of interest and mentioned "powerful people keeping an eye on" Guertin in a June 16, 2023 email (Index #30, pp. 22–24, 73–76) - Rivers promised to represent Guertin in civil commitment proceedings but failed to do so (Index #30, pp. 24–25, 77–78, 81–83) - The above allegations were raised in Guertin's petition for discretionary review in the Minnesota Court of Appeals, case A24-0780 - The court has refused to provide discovery and has not addressed Guertin's other pending motions ### Procedural Posture Filed during the pendency of the criminal case while Guertin was still represented by Bruce Rivers. This motion follows Guertin's earlier filing of a petition for discretionary review in the Minnesota Court of Appeals (A24-0780) and appears to precede his federal civil rights action. The motion is directed at Judges Quam and Klein, indicating both were involved at this stage. ### Exhibit / Attachment Inventory - No exhibits are directly attached; the motion references the following case docket entries: - Index #89: "Exhibit A" — evidence submitted in Court of Appeals case A24-0780 - Index #30: Extensive evidence of Rivers' misconduct (multiple page references) - Index #38: Additional evidence of Rivers' misconduct (multiple page references) ### Visual Evidence Inventory - [Page 1] Court stamp/header: Standard filing header showing "27-CR-23-1886 Filed in District Court State of Minnesota 6/3/2024 7:33 AM" — appears in standard format, no anomalies noted. - [Pages 1 and 4] Signature block: Electronic signature "/s/ Matthew Guertin" with address at 1075 Traditions Ct., Chaska, MN 55318 and phone 763-221-4540. - No photographs, screenshots, diagrams, or other visual elements beyond standard filing headers. ### Key People Referenced - **Matthew David Guertin** — Defendant, Pro Se filer - **Bruce Rivers** — Current defense counsel, subject of motion for replacement - **Jay Quam** — Judge, Fourth Judicial District (addressed in motion) - **Julia Dayton Klein** — Judge, Fourth Judicial District (addressed in motion) - **Jacqueline Perez** — Assistant Hennepin County Attorney - **Dr. Adam Milz** — Author of January 3, 2024 Rule 20.01 exam report - **Michael Biglow** — Referenced indirectly as court-appointed attorney who delivered "Set B" discovery (per later filings) ### Key Entities / Organizations Referenced - Hennepin County Attorney's Office - Minnesota Court of Appeals (case A24-0780) - Fourth Judicial District Court, Hennepin County ### Dates & Deadlines Mentioned - June 3, 2024 — Date of filing - January 3, 2024 — Date of Dr. Adam Milz's Rule 20.01 exam report - July 7, 2023 — Court hearing where exculpatory evidence was allegedly not presented - June 16, 2023 — Email from Rivers referencing "powerful people" - A24-0780 — Petition for Discretionary Review in MN Court of Appeals (date not specified) ### Forensic Flags & Anomalies - Guertin alleges that Rivers told him "powerful people" were "keeping an eye on him" during a May 22, 2023 phone call (mentioned in later filings) and a June 16, 2023 email — this is presented as evidence of a conflict of interest. - Guertin claims the court itself has refused to provide discovery materials, suggesting systemic obstruction beyond just attorney misconduct. - The motion is addressed to both Judge Quam and Judge Klein, raising questions about which judge was actually presiding at this point. ### Cross-References - Index #30 (case docket) — Extensive evidence of Rivers' misconduct - Index #38 (case docket) — Additional evidence - Index #89 (case docket) — Exhibit A referenced in Court of Appeals case A24-0780 - MN Court of Appeals case A24-0780 --- --- ## Filing #10 — Defendant's Motion for Court-Wide Judicial Notice and Sworn Affidavit (Docket Anomalies) | Field | Detail | |---|---| | Filing # | 10 | | Date Filed | December 27, 2024 | | Filed By | Matthew David Guertin (Defendant, Pro Se) | | Document Type | Motion for Judicial Notice and Affidavit | | Case/Court | 27-CR-23-1886 / Fourth Judicial District, Hennepin County, MN (Index #115) | | Pages | 19 | | Bates / Doc ID | 115__Pro-Se-Defendants-Judicial-Notice__Docket-Anomalies__2024-12-27.pdf | ### Comprehensive Summary This is a comprehensive sworn affidavit and motion for "court-wide judicial notice" filed by Guertin pro se. The document catalogs 25 "indisputable facts" (labeled A through Y) drawn from the publicly accessible case docket of 27-CR-23-1886, arguing that the docket contains numerous procedural anomalies, missing documents, out-of-sequence filings, and other irregularities that collectively demonstrate systemic misconduct. Guertin frames the motion as an urgent request made under penalty of perjury, asserting that most of the facts cited are verifiable directly from the public docket. He makes the unusual request for a "court-wide" judicial notice, encouraging anyone within the Hennepin County Courts to read and share the motion with other judicial officers, claiming that the credibility of the entire court system is being discredited. The 25 "indisputable facts" cover the entire procedural history of the case from February 2023 through December 2024, and include: **Facts A–C (Early Hearing Anomalies):** Guertin's original 02/22/2023 hearing was reset to 04/04/2023, then canceled, then reset to 04/11/2023, then canceled again, showing a pattern of repeated scheduling disruptions. **Fact D (Order Without Motion):** On 06/14/2023, Judge Julia Dayton Klein granted an "order for continuance" for which no corresponding motion for continuance exists in the case record. An evidentiary hearing on that same date was held "off the record." **Fact E (Missing Documents and No-Index Filing):** On 01/16/2024, Guertin's review hearing was canceled; a "waiver of appearance" was filed with no corresponding PDF document; and a finding of incompetency was entered with no index number and no downloadable PDF. **Fact F (Out-of-Sequence Index Numbers):** On 01/16/2024, a notice of remote hearing (Index #26) was filed for a Zoom hearing six months in the future (July 16, 2024). The finding of incompetency was entered at Index #25 on 01/17/2024 — meaning Index #26 was filed BEFORE Index #25, which is out of sequential order. **Fact G (Notice of Appeal):** On 05/10/2024, Guertin filed a 21-page pro se notice of appeal at Index #53. **Facts H–K (Fee Waiver Fabrication):** On 05/23/2024, an "affidavit to request fee waiver" was entered at Index #77 attributed to Guertin but with no corresponding PDF document. Guertin categorically denies ever filing such an affidavit. On 05/23/2024 and 05/30/2024, Judge Klein issued orders denying fee waivers (Index #81 and #89 respectively), which Guertin states also appear in his Minnesota Court of Appeals case A24-0780. **Fact L (Judge Recusal):** On 07/16/2024, Judge Klein submitted an order of recusal (Index #95) resulting from Guertin naming her as a defendant in his federal civil rights case, Guertin v. Hennepin County (0:24-cv-02646). **Facts M–O (Case Reassignment and Unexplained Rule 20 Reports):** Following Klein's recusal, the case was reassigned to Judge William Koch. Rule 20 Progress Reports were submitted on 07/16/2024 (Index #96) and 09/11/2024 (Index #99), despite Guertin asserting he never participated in any meeting or exam that would generate such reports. **Fact P (Chronological Impossibilities):** On 10/01/2024, Guertin appeared before Judge Koch. The docket indicates this hearing was originally scheduled for 09/24/2024 but was reset on 07/16/2024 to 10/01/2024. Guertin argues this is chronologically impossible since he attended a hearing on 07/16/2024 as originally planned, and the 10/01/2024 hearing originated from his 09/25/2024 motion for substitute counsel. Attached to this motion was a 116-page ethics complaint against Bruce Rivers submitted to the Minnesota Office of Lawyers Professional Responsibility (also filed in the federal case at Index #77). **Facts Q–S (Duplicate Public Defender Appointments):** On 10/01/2024, Judge Koch granted a public defender (Index #102) with no corresponding PDF document. On 10/15/2024, Judge Askalani granted a second public defender order (Index #106), meaning Guertin was granted a public defender twice. **Fact T (Competency Evaluation Ordered):** On 10/15/2024, Judge Askalani found probable cause to question Guertin's competency and ordered a Rule 20.01 evaluation (Index #108 and #109). **Fact U (Rule 20 Report Without Exam):** On 12/20/2024, a Rule 20 Evaluation Report was submitted (Index #112) despite Guertin asserting he never participated in a third Rule 20 exam. **Fact V (Unlisted Attorney):** Guertin was assigned public defender Raissa Carpenter, who introduced a second attorney, Emmett Donnelly, who dominated their only in-person meeting. Guertin notes that Donnelly is NOT listed as an attorney of record, though he is CC'd on Carpenter's emails. The docket shows Carpenter as lead attorney, with Rivers listed as inactive. **Fact W (Five State Attorneys):** Five active attorneys represent the State, three of whom are named "Thomas" (Thomas Franklin Manewitz, Thomas Stuart Arneson, Thomas James Prochazka). Guertin finds this unusual. **Fact X (MCRO Analysis — Alleged Fake Case Files):** On 05/03/2024, Guertin filed a 31-page affidavit (Index #37) containing his analysis of publicly accessible MCRO court records. He searched cases involving Judges Klein, Mercurio, and Borer, identified overlapping cases, and concluded that many defendants appear to be fake/AI-generated identities based on unusual names, name variations (e.g., "MAKIS DEVELL LANE" vs "MAKIS DEVIL LANE"), and "robotic" language in police reports. He provides a Proton Drive download link for the analyzed case files and details his methodology (date range Jan 2023 – Apr 2024, Criminal and Probate/Mental Health categories). **Fact Y (October 7 / Hamas Footage Claims):** Guertin claims to have conducted an analysis of October 7 Hamas attack footage, concluding it was fabricated. He references a video interview he conducted with Max Igan on BitChute and Rumble as evidence of his competence. He connects this to the broader patent theft narrative. The document concludes with a request that the court take judicial notice of Facts A through Y and make them part of the record. Guertin affirms under penalty of perjury that the content is true and correct. ### Legal Issues & Arguments Raised - Request for judicial notice of docket anomalies as "indisputable facts" - Due process violations stemming from docket irregularities - Missing/phantom documents in the case record - Out-of-sequence index numbers suggesting record manipulation - Orders issued without corresponding motions - Fabricated fee waiver affidavit attributed to Guertin - Rule 20 evaluation reports produced without defendant's participation - Duplicate public defender appointments - Competency of the defendant (implicit challenge to competency proceedings) - Alleged fabrication of court records across multiple cases (MCRO analysis) ### Factual Allegations & Key Assertions - Multiple hearing cancellations and resets between Feb–Apr 2023 - 06/14/2023 order for continuance has no corresponding motion in the record - 06/14/2023 evidentiary hearing held "off the record" - 01/16/2024 waiver of appearance and incompetency finding lack PDF documents - Index #26 filed before Index #25 (out of sequence) - Remote hearing notice filed 6 months before scheduled date - Guertin never filed an affidavit for fee waiver (contradicting docket entry at Index #77) - Two orders denying fee waiver also appear in appeals case A24-0780 - Judge Klein recused after being named in federal case 0:24-cv-02646 - Rule 20 Progress Reports (Index #96 and #99) filed without defendant participation - Chronological impossibilities in hearing scheduling and reset dates - 116-page ethics complaint against Bruce Rivers filed with MN OLPR - Public defender granted twice (Index #102 and #106) - Emmett Donnelly acting as de facto counsel but not listed as attorney of record - Rule 20 Evaluation Report (Index #112) submitted without third exam taking place - Five state attorneys assigned, three named "Thomas" - MCRO analysis of 163 cases reveals alleged fake defendant names and AI-generated documents - Specific name variations flagged: MAKIS DEVELL LANE vs MAKIS DEVIL LANE, PRIEST JESUS (DORSEY), ANGELIC DENISE NUNN vs ANGELIC DENISE SCHAEFER - October 7 attack footage analysis and interview with Max Igan (Rumble/BitChute) ### Procedural Posture Filed December 27, 2024, four days before a scheduled competency hearing on December 31, 2024. The filing references Index #114 (a related judicial notice motion filed the previous day) and Index #112 (the Rule 20 Evaluation Report Guertin had not yet received). The case has been through multiple judges (Klein, Koch, Askalani) and Guertin is now represented by public defender Raissa Carpenter after previously being represented by Bruce Rivers. ### Exhibit / Attachment Inventory - **Exhibit A (MCRO Analysis Methodology):** Detailed description of data collection from MCRO, date range Jan 1, 2023 – Apr 26, 2024, covering Criminal and Probate/Mental Health categories for three judicial officers - **Shared case file tables:** Organized by origination year (2017, 2019, 2020, 2021, 2022, 2023) listing all case numbers and defendant names identified in the cross-analysis - **Download link:** https://drive.proton.me/urls/QA8TBVTHEC#Wy7ygZMVpev7 — six separate .zip files spanning 2017–2023, plus Python download script - **Video links:** BitChute and Rumble URLs for interview with Max Igan ### Visual Evidence Inventory - [Page 3] Docket screenshot — 04/04/2023 hearing entry: Shows "Omnibus Hearing" before Judicial Officer Quam, Jay at GC-C1459, status "Cancelled; Other," with Date Updated 02/21/2023. Notes "Reset by Court to 04/04/2023 11:00 AM - Session/Hearing Moved Same" and "Date/Time - Not Rescheduled," Original Hearing Date 02/22/2023 01:30 PM. Appears to be a standard MCRO screenshot with Minnesota Judicial Branch watermark visible in background. - [Page 3] Docket screenshot — 04/11/2023 hearing entry: Shows "Review Hearing" before Judicial Officer Dayton Klein, Julia at GC-C559, status "Cancelled; Other," with Date Updated 04/04/2023. Notes "Reset by Court to 04/11/2023 01:30 PM - By agreement," Original Hearing Date 04/04/2023 01:30 PM. MN Judicial Branch watermark visible. - [Page 4] Docket screenshot — Three entries dated 06/14/2023 and 04/04/2023: "Taken Under Advisement" (Index #17, J.O. Dayton Klein), "Order for Continuance" (Index #16), and "Request for Continuance" (Index #15). Order has a 1-page PDF icon. - [Page 4] Docket screenshot — 06/14/2023 hearing entry: "Evidentiary Hearing" before Dayton Klein at GC-C559, Result: "Held Off the Record." MN Judicial Branch watermark visible. - [Page 4] Docket screenshot — 01/16/2024 hearing entry: "Review Hearing" before Mercurio, Danielle at GC-C556, status "Cancelled; Other." - [Page 5] Docket screenshot — Two entries: "Found Incompetent" (01/16/2024, J.O. Mercurio, Danielle — notably NO index number and NO PDF icon) and "Waiver of Appearance" (01/16/2024, Index #24 — NO PDF icon). **ANOMALY FLAGGED:** Missing index number on incompetency finding; no downloadable document for either entry. - [Page 5] Docket screenshot — Two entries: "Finding of Incompetency and Order" (01/17/2024, J.O. Mercurio, Index #25, 4 pages) and "Notice of Remote Hearing with Instructions" (01/16/2024, Index #26, 2 pages). **ANOMALY FLAGGED:** Index #26 has an earlier date than Index #25 — out of sequential order. - [Page 5] Docket screenshot — "Notice of Appeal" (05/10/2024, Party: Defendant GUERTIN, MATTHEW DAVID, Index #53, 21 pages). - [Page 6] Docket screenshot — "Affidavit to Request Fee Waiver" (05/23/2024, Party: Defendant GUERTIN, MATTHEW DAVID, Index #77 — NO PDF icon). **ANOMALY FLAGGED:** Missing document. - [Page 6] Docket screenshot — "Order Denying Fee Waiver" (05/23/2024, J.O. Dayton Klein, Julia, Index #81, 1 page). - [Page 6] Docket screenshot — "Taken Under Advisement" (05/30/2024, J.O. Dayton Klein, Julia, Index #87). - [Page 7] Docket screenshot — "Order Denying Fee Waiver" (05/30/2024, Index #89, 1 page). - [Page 7] Docket screenshot — "Order to Recuse" (07/15/2024, J.O. Dayton Klein, Julia, Index #95, 1 page). Note: text says 07/16/2024 but docket entry shows 07/15/2024. - [Page 8] Docket screenshot — 07/16/2024 hearing entry: "Review Hearing" before Koch, William H. at GC-C457, Result: "Held On the Record." Notes: "Date Updated: 07/16/2024, Reset by Court to 07/16/2024 01:30 PM - Judge Recusal, Original Hearing Date: 07/16/2024 01:30 PM." - [Page 8] Docket screenshot — "Rule 20 Progress Report" (07/16/2024, Index #96 — NO PDF icon). - [Page 8] Docket screenshot — "Rule 20 Progress Report" (09/11/2024, Index #99 — NO PDF icon). - [Page 9] Docket screenshot — 10/01/2024 hearing entry: "Hearing" before Koch, William H. at GC-C457, Result: "Held On the Record." Notes: "Date Updated: 07/16/2024, Reset by Court to 10/01/2024 01:30 PM - By agreement, Original Hearing Date: 09/24/2024 01:30 PM." **ANOMALY FLAGGED:** Guertin argues this chronology is impossible. - [Page 10] Docket screenshot — Two entries: "Order-Other" (10/01/2024, J.O. Koch, Index #103 — NO PDF icon) and "Order Granting Public Defender" (10/01/2024, J.O. Koch, Index #102 — NO PDF icon). **ANOMALY FLAGGED:** Two orders with no downloadable documents. - [Page 10] Docket screenshot — 10/15/2024 hearing entry: "Hearing" before Askalani, Shereen at PSF 141, Result: "Held On the Record." - [Page 11] Docket screenshot — Two entries: "Order Granting Public Defender" (10/15/2024, J.O. Askalani, Index #106) and "Hearing Held In-Person" (10/15/2024). **ANOMALY FLAGGED:** Second public defender order. - [Page 11] Docket screenshot — Four entries from 10/15/2024: "Notice of Hearing" (Index #110, 1 page), "Order Appointing Forensic Navigator" (J.O. Askalani, Index #109, 2 pages), "Order-Evaluation for Competency to Proceed (Rule 20.01)" (J.O. Askalani, Index #108, 3 pages), and "Probable Cause Found." - [Page 12] Docket screenshot — Two entries: "Rule 20 Evaluation Report" (12/20/2024, Index #112) and "Rule 20 Report Distributed" (12/20/2024). - [Page 12] Docket screenshot — Party/Attorney information panel: Shows Defendant GUERTIN, MATTHEW DAVID (DOB 07/17/1981, CHASKA, MN 55318), Self-Represented Litigant, Attorneys Active: CARPENTER, RAISSA (Lead Attorney), Attorneys Inactive: RIVERS, BRUCE MICHAEL. **NOTE:** Simultaneously listed as "Self-Represented Litigant" and having an active attorney (Carpenter). - [Page 13] Docket screenshot — Jurisdiction/Attorney panel for the State: Shows State of Minnesota, Attorneys Active: MANEWITZ, THOMAS FRANKLIN (Lead), ARNESON, THOMAS STUART, COLE, JUDITH L, MURPHY, ELIZABETH DORENE, PROCHAZKA, THOMAS JAMES. Attorneys Inactive: COLE, JUDITH L, PEREZ, JACQUELINE. - [Page 13] Docket screenshot — "Affidavit-Other" (05/03/2024, Index #37, 31 pages). - [Pages 14–17] MCRO Analysis data tables and methodology description: Shows methodology box ("Exhibit A" label visible), search criteria, data processing description, and extensive case listing tables organized by origination year (2017, 2019–2023). Guertin's own case (27-CR-23-1886) is highlighted in yellow in the 2023 table. - [Page 14] Download link box: Shows shared folder URL for Proton Drive with case file origination dates 2017–2023 and note about Python download script. ### Key People Referenced - **Matthew David Guertin** — Defendant, Pro Se filer (DOB 07/17/1981) - **Jay Quam** — Judge, addressed in motion - **Julia Dayton Klein** — Judge, multiple docket entries; recused 07/15/2024; named defendant in federal case - **Danielle C. Mercurio** — Court Referee/Judge; finding of incompetency 01/16/2024 - **William H. Koch** — Judge; took over case after Klein recusal - **Shereen Askalani** — Judge; public defender and competency evaluation orders 10/15/2024 - **Bruce Rivers** — Former defense counsel (inactive); subject of 116-page ethics complaint - **Raissa Carpenter** — Current public defender (lead attorney) - **Emmett Donnelly** — Second public defender, not listed as attorney of record - **Thomas Franklin Manewitz** — Lead State Attorney - **Thomas Stuart Arneson** — State Attorney - **Thomas James Prochazka** — State Attorney - **Judith L. Cole** — State Attorney (active and inactive) - **Elizabeth Dorene Murphy** — State Attorney - **Jacqueline Perez** — Former State Attorney (inactive) - **Max Igan** — Interviewer (BitChute/Rumble) - **George Borer** — Referee, one of three judicial officers in MCRO analysis ### Key Entities / Organizations Referenced - Hennepin County Courts / Fourth Judicial District - Minnesota Court Records Online (MCRO) - Minnesota Court of Appeals (case A24-0780) - U.S. District Court, District of Minnesota (Guertin v. Hennepin County, 0:24-cv-02646) - Minnesota Office of Lawyers Professional Responsibility - CourtListener.com - Proton Drive (file sharing) - BitChute / Rumble (video platforms) ### Dates & Deadlines Mentioned - 02/22/2023 — Original hearing date - 02/21/2023 — Hearing reset to 04/04/2023 - 04/04/2023 — Canceled and reset to 04/11/2023; Request for Continuance (Index #15) - 04/11/2023 — Hearing canceled - 06/14/2023 — Order for Continuance without motion; hearing "off the record" - 01/16/2024 — Review hearing canceled; waiver of appearance; incompetency finding; remote hearing notice (Index #26) for July 16, 2024 - 01/17/2024 — Finding of Incompetency and Order (Index #25) - 05/03/2024 — MCRO analysis affidavit (Index #37) - 05/10/2024 — Notice of Appeal (Index #53) - 05/22/2023 — Phone call where Rivers mentioned "powerful people" - 05/23/2024 — Alleged fee waiver affidavit (Index #77) and order denying (Index #81) - 05/30/2024 — Second order denying fee waiver (Index #89) - 07/08/2024 — Federal civil rights case filed - 07/15/2024 — Order to Recuse (Index #95) - 07/16/2024 — Review hearing before Koch; Rule 20 Progress Report (Index #96) - 09/11/2024 — Rule 20 Progress Report (Index #99) - 09/24/2024 — Original hearing date per docket - 09/25/2024 — Motion for substitute counsel filed - 10/01/2024 — Hearing before Koch; orders (Index #102, #103) - 10/15/2024 — Hearing before Askalani; second public defender order; competency evaluation order - 12/12/2024 — Raissa Carpenter email "Next Steps on Court Case" - 12/20/2024 — Rule 20 Evaluation Report (Index #112) - 12/27/2024 — This motion filed - 12/31/2024 — Scheduled competency hearing ### Forensic Flags & Anomalies - **Missing PDF documents:** Multiple docket entries (waiver of appearance, found incompetent, fee waiver affidavit, Rule 20 Progress Reports, public defender orders) lack downloadable PDF documents - **Out-of-sequence index numbers:** Index #26 filed 01/16/2024 BEFORE Index #25 filed 01/17/2024 - **Order without corresponding motion:** 06/14/2023 Order for Continuance has no motion for continuance in the record - **"Off the record" hearing:** 06/14/2023 evidentiary hearing held off the record on same day as the unsupported order - **Six-month advance filing:** Notice of Remote Hearing for July 16, 2024 filed on January 16, 2024 - **Fabricated fee waiver:** Guertin denies filing the affidavit for fee waiver at Index #77 (no PDF exists) - **Duplicate public defender orders:** Two separate judges issued orders granting public defenders (Index #102 and #106) - **Unlisted attorney of record:** Emmett Donnelly operating as de facto counsel but not listed in case docket - **Simultaneous status:** Docket shows Guertin as both "Self-Represented Litigant" and having active attorney Carpenter - **Rule 20 reports without examination:** Three Rule 20 reports submitted (Index #96, #99, #112) despite Guertin asserting he never participated in the corresponding exams - **Chronological impossibilities in scheduling:** Oct 1, 2024 hearing indicated as reset on July 16, 2024 from original date of Sept 24, 2024 — but the July 16 hearing actually took place - **Recusal date discrepancy:** Text says Klein recused 07/16/2024, but docket screenshot shows order date 07/15/2024 - **Three "Thomas" attorneys:** Three of five state attorneys share the first name Thomas (Manewitz, Arneson, Prochazka), noted by Guertin as unusual ### Cross-References - Index #114 — Related judicial notice motion filed the previous day - Index #112 — Rule 20 Evaluation Report - Index #37 — MCRO Analysis Affidavit - Index #53 — Notice of Appeal - MN Court of Appeals case A24-0780 - Federal case Guertin v. Hennepin County (0:24-cv-02646) - CourtListener docket link: https://www.courtlistener.com/docket/68925331/guertin-v-hennepin-county/ - Federal case Index #77 — Ethics complaint against Bruce Rivers --- --- ## Filing #11 — Defendant's Supplemental Evidence Submission (Exhibits M–Q: Netflix Patent Theft) | Field | Detail | |---|---| | Filing # | 11 | | Date Filed | February 28, 2025 | | Filed By | Matthew David Guertin (Defendant, Pro Se) | | Document Type | Supplemental Evidence Submission in Support of Objection to Competency Report – D | | Case/Court | 27-CR-23-1886 / Fourth Judicial District, Hennepin County, MN (Index #125) | | Pages | 23 | | Bates / Doc ID | 125__Exhibit-List_M-Q__Netflix-Patent-Theft__2025-02-28.pdf | ### Comprehensive Summary This filing is Guertin's fourth supplemental evidence submission ("D") in support of his objection to the competency report. It is addressed to Judge Sarah Hudelston (now assigned to the case) and Assistant Hennepin County Attorney Thomas Manewitz. The filing presents five exhibits (M through Q) consisting of detailed technical and financial analyses comparing Guertin's InfiniSet patent (US 11,577,177) to Netflix's patent (US 11,810,254), and argues that Guertin's ability to produce these sophisticated analyses is itself proof of his competency, contradicting the March 10, 2023 forensic evaluation by Dr. Jill Rogstad. **Exhibit M — Analysis of InfiniSet Patent v. Netflix Patent:** An executive summary and detailed comparison arguing that InfiniSet's US Patent 11,577,177 (priority date February 14, 2023) anticipates and renders obvious Netflix's US Patent 11,810,254 (granted November 7, 2023). The analysis contends the patents describe essentially identical technology — a treadmill integrated with LED virtual film sets for unlimited movement — differing primarily in terminology ("motorized rotatable treadmill" vs "omnidirectional treadmill"). InfiniSet's patent was submitted as third-party prior art during Netflix's prosecution. The analysis concludes Netflix's patent should be challenged for lack of novelty and non-obviousness. The exhibit includes direct excerpts from both patents' abstracts and descriptions and provides external links to the full analysis document and supporting patent background materials on Storj. **Exhibit N — Advanced Technology Comparison:** A comprehensive side-by-side analysis of advanced technological capabilities disclosed in both patents, covering: (1) immersive digital environments (VR, AR, metaverse), (2) real-time tracking and cueing, (3) digital twin creation, (4) simulation training and gaming applications, (5) remote connectivity and multi-system integration, and (6) advanced multi-sensor integration. The analysis concludes that InfiniSet's patent broadly and fundamentally encompasses all advanced capabilities that Netflix claims, and that differences are superficial (level of detail/segmentation rather than substantive innovation). **Exhibit O — Disruptive Technology Report ("Infinite Movement" Treadmill):** A general-audience overview explaining the disruptive potential of US Patent 11,577,177, written in accessible language. Describes how the treadmill creates an "illusion of infinite movement" by combining belt motion with turntable rotation. Highlights integration possibilities with AI-generated worlds (OpenAI Sora, Inworld AI), holographic/light field displays, and digital twins. Details applications across film/TV, gaming, fitness, military training, education, and virtual tourism. Positions the technology as potentially "as commonplace as smartphones." **Exhibit P — Ballpark Financial Valuation Report (20-Year Global Exclusivity Model):** A hypothetical financial model projecting the patent's value assuming worldwide exclusivity for 20 years. Key projections: total addressable market of $1.45 trillion; 20-year gross revenue of $390 billion across hardware sales ($280B across industries), licensing ($70B), and software subscriptions ($40B); net profit post-tax of $176 billion; NPV at 8% discount rate of $68 billion. Sensitivity analysis ranges from $85B NPV (worst case) to $220B NPV (best case). Emerging tech multipliers (AI content, light field displays, metaverse) could add $100B+. The "Risks" section uniquely lists: "Theft by the US and Israeli 'Military Entertainment Industrial Complex'"; illegal surveillance of the inventor by intelligence agencies; declaration of incompetency by "a completely corrupt Hennepin County Court system"; unjust commitment and forced medication; and patent litigation. Final ballpark estimate: $100B–$200B total economic impact. **Exhibit Q — National Defense & Investment Opportunities Report:** Draws on the Declaration of Hao Li from federal case 3:17-cv-04006-JST to establish alignment between the patent's technology and existing defense research. Details existing investments: U.S. Army/ARO ($2.8M for avatar digitization, $1.4M for virtual humans), ONR ($591K for human digitization), DARPA/IARPA ($419K for GLAIVE program), and USC ICT ($8.89M in federal grants). Identifies potential military training contracts targeting the Army's $10B Synthetic Training Environment program and partnerships with Lockheed Martin, Northrop Grumman, and defense startups like Anduril Industries. The legal argument section invokes Minn. R. Crim. P. 20.01, arguing that Guertin's ability to compile and present these analyses demonstrates competency to understand proceedings, consult with counsel, and participate in his defense. It challenges the March 10, 2023 evaluation by Dr. Rogstad, arguing that new exhibits reveal discovery materials were manipulated and that the evaluation's conclusions are unreliable. Guertin acknowledges the filing is late relative to the seven-day pretrial disclosure rule but argues extraordinary circumstances justify it. The relief sought requests: (1) acceptance of Exhibits M–Q into the official record; (2) consideration of the analyses as evidence of manipulated discovery; (3) recognition that Guertin's analytical capacity proves competency; (4) appropriate relief to rectify the flawed competency determination. ### Legal Issues & Arguments Raised - Competency under Minn. R. Crim. P. 20.01 — demonstrated through ability to produce complex analyses - Challenge to March 10, 2023 forensic evaluation by Dr. Jill Rogstad - Patent infringement / intellectual property theft (InfiniSet US 11,577,177 vs Netflix US 11,810,254) - Prior art and obviousness arguments against Netflix patent - Discovery fraud — manipulated discovery materials - Late filing justification under extraordinary circumstances - Due process violations ### Factual Allegations & Key Assertions - InfiniSet US Patent 11,577,177 granted Feb 14, 2023 (priority date 12 days before Netflix filing) - Netflix US Patent 11,810,254 granted Nov 7, 2023 - InfiniSet's patent was submitted as third-party prior art during Netflix prosecution - Both patents describe functionally identical technology - Terminology differences are superficial ("rotatable" vs "omnidirectional") - LED volume/virtual film set configuration is standard industry practice - Patent technology has applications in VR/AR, metaverse, digital twin creation, simulation training, gaming, and remote connectivity - 20-year NPV estimated at $68B–$150B - Military/defense alignment with ARO, ONR, DARPA, and USC ICT research programs - Dr. Rogstad's 2023 evaluation relied on manipulated discovery evidence - Guertin's analytical output contradicts incompetency finding ### Procedural Posture Filed February 28, 2025, as the fourth in a series of supplemental evidence submissions ("D") challenging the competency finding. The case has been reassigned to Judge Sarah Hudelston. Thomas Manewitz is now lead state attorney. This appears to be filed in advance of a competency hearing, with Guertin acknowledging it falls outside the normal seven-day pretrial disclosure window. ### Exhibit / Attachment Inventory - **Exhibit M** — Analysis of InfiniSet Patent vs Netflix Patent (3 pages within filing, with external link to full report) - **Exhibit N** — Advanced Technology Comparison of Both Patents (4 pages within filing, with external link) - **Exhibit O** — Disruptive Technology Report: "Infinite Movement" Treadmill (3 pages) - **Exhibit P** — Ballpark Financial Valuation Report, 20-Year Global Exclusivity Model (4 pages) - **Exhibit Q** — National Defense & Investment Opportunities Report (4 pages, references Declaration of Hao Li from case 3:17-cv-04006-JST) - **External links referenced:** - Full analysis: https://link.storjshare.io/raw/.../InfiniSet-Patent__Compared-to-Netflix-Patent-Report.pdf - Patent background documents: https://link.storjshare.io/s/.../court-fraud/The-Patent-is-the-Motive/ - Declaration of Hao Li: https://storage.courtlistener.com/recap/gov.uscourts.cand.314347/gov.uscourts.cand.314347.139.7.pdf ### Visual Evidence Inventory - [Page 16, Exhibit P] Table — Market size and revenue projections table showing industry segments, addressable markets, penetration rates, and 20-year revenue estimates. Rendered as text, not image. - [Page 17, Exhibit P] Table — Cost structure table (R&D $20B, Manufacturing $90B, Marketing $50B, Legal $10B, Total $170B). Text-based. - [Page 15, Exhibit O] Table — Industry application table showing Film/TV, Gaming, Fitness, Education, and Military use cases. Text-based. - No photographs, screenshots, or image-based visual elements in this filing. All content appears to be native digital text. - Standard court filing headers on each page: "27-CR-23-1886 Filed in District Court State of Minnesota 2/28/2025 4:42 PM" ### Key People Referenced - **Matthew David Guertin** — Defendant/Patent holder/CEO of InfiniSet, Inc. - **Sarah Hudelston** — Judge, Fourth Judicial District (now presiding) - **Thomas Manewitz** — Assistant Hennepin County Attorney (lead state counsel) - **Mary F. Moriarty** — Hennepin County Attorney - **Dr. Jill Rogstad** — Author of March 10, 2023 forensic evaluation - **Hao Li** — Declarant in case 3:17-cv-04006-JST; Director of USC ICT Vision and Graphics Lab ### Key Entities / Organizations Referenced - InfiniSet, Inc. (Delaware corporation, registered as foreign corp in MN) - Netflix (patent holder US 11,810,254) - USPTO (Patent and Trademark Office) - U.S. Army / Army Research Office (ARO) - Office of Naval Research (ONR) - DARPA / IARPA - USC Institute for Creative Technologies (ICT) - Lockheed Martin - Northrop Grumman - Anduril Industries - CAE / Bohemia Interactive Simulations - Meta / Sony / Apple / Roblox - OpenAI (Sora) / Midjourney / Inworld AI - U.S. Army Synthetic Training Environment (STE) - DoD Simulation and Training Technology Center (STTC) ### Dates & Deadlines Mentioned - February 14, 2023 — InfiniSet patent granted (US 11,577,177) - February 26, 2023 — Netflix provisional filing date (12 days after InfiniSet priority) - November 7, 2023 — Netflix patent granted (US 11,810,254) - March 10, 2023 — Dr. Jill Rogstad forensic evaluation report - February 28, 2025 — This filing date - 7-day pretrial disclosure rule (local rules) — acknowledged as potentially exceeded ### Forensic Flags & Anomalies - Guertin alleges the same technology was patented by Netflix just 12 days after his own provisional filing, with his name listed atop the Netflix filing - InfiniSet patent was submitted as third-party prior art during Netflix prosecution — raising question of how Netflix patent was still granted - Risks section of Exhibit P explicitly lists "Theft by the US and Israeli 'Military Entertainment Industrial Complex'" and "Illegal surveillance operations" as valuation risks — embedding conspiracy allegations within a financial model - The entire filing is styled as a competency rebuttal, using technical output as proof of mental fitness ### Cross-References - March 10, 2023 forensic evaluation by Dr. Jill Rogstad - Minn. R. Crim. P. 20.01 (competency standard) - Federal case 3:17-cv-04006-JST (Declaration of Hao Li) - US Patent 11,577,177 (InfiniSet) - US Patent 11,810,254 (Netflix) - Prior supplemental evidence submissions A, B, C (not in this batch) --- --- ## Filing #12 — Civil Rights and RICO Complaint with Jury Demand | Field | Detail | |---|---| | Filing # | 12 | | Date Filed | June 25, 2025 | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Civil Rights and RICO Complaint with Jury Demand | | Case/Court | Federal: 0:24-cv-02646-JRT-DLM / U.S. District Court, District of Minnesota (Doc. 116); also references new case number 25-cv-____ | | Pages | 121 | | Bates / Doc ID | 116__EXHIBIT_CIVIL_RIGHTS_AND_RICO_COMPLAINT_WITH_JURY_DEMAND__2025-06-25.pdf | ### Comprehensive Summary This is a 121-page federal civil rights and RICO complaint filed by Guertin pro se in the U.S. District Court for the District of Minnesota. Docketed as Doc. 116 in existing case 0:24-cv-02646-JRT-DLM, it appears to be either an amended complaint or new complaint within the existing federal action. It names over 30 individual defendants plus 100 Doe defendants, asserting claims under 42 U.S.C. §§ 1983 and 1985, and 18 U.S.C. §§ 1961–1968 (RICO). **Core Theory:** The complaint alleges that a coalition of state officials, county prosecutors, judges, public defenders, mental health professionals, and administrators orchestrated a "synthetic case matrix" — a system of fabricated court cases, falsified documents, and fake defendants — designed to deprive Guertin of due process, declare him incompetent, and suppress his patented technology (US Patent 11,577,177). Guertin claims to be the only real human defendant within an otherwise entirely synthetic legal universe of 163 criminal cases. **Digital Forensic Evidence (Sections IV–XVII):** The complaint's evidentiary foundation rests on a digital forensic analysis Guertin conducted on April 29–30, 2024, in which he downloaded 3,601 PDF court documents across 163 criminal cases from the MCRO system using custom Python automation, search-filter bypass methods, and VPN rotation. Key forensic findings include: 1. **SHA-256 Authentication:** 99.6% (3,585) of the documents bear X.509 SHA-256 digital signatures from the Hennepin County Courts. Guertin argues these signatures make the documents self-authenticating under Federal Rule of Evidence 902(14), and that the court's own infrastructure "co-signed the proof of its own misconduct." 2. **55 Post-Dated Signatures:** Documents with digital signatures timestamped after their filing dates — described as forensically impossible in legitimate document handling. 3. **371 Timestamp Duplicates:** Identical byte-for-byte timestamp blocks reused across hundreds of orders, different case numbers, and varying judges — indicating mass document cloning. 4. **1,183 Duplicate Signature Images:** Identical cropped-image judicial signature graphics reused across thousands of documents, sometimes with different judge names. 5. **40 Fabricated USPS Return Scans:** Identical envelope scan images reused across multiple dockets, with recurring addresses (740 E 17th Street, 1010 Curry Avenue) appearing in over a dozen cases. 6. **AI-Generated Filings:** PDFs containing entire court filings as embedded 2-bit binary images (rather than native digital documents) with no scan artifacts, suggesting AI-generated or diffusion-based document fabrication. 7. **"Mother's Letter" Incident (Section VI):** On April 12, 2024, a synchronized sequence across Guertin's case and a fabricated defendant's case ("Sandra Phitsanoukanh Vongsaphay," case 27-CR-23-2480) involving: a fake inmate letter at 2:03 PM, Guertin's mother's genuine letter at 2:10 PM, Judge Klein's preemptive order at 2:28 PM, and near-identical clerk responses at 4:38 PM and 4:42 PM — all with matching SHA-256 hash values. 8. **127 Cloned Incompetency Orders (Section VII):** 129 "Finding of Incompetency and Order" documents (127 cloned from the same template plus 2 authentic originals) attributed to metadata author "barbj" spanning 105 synthetic case numbers. Guertin's own January 17, 2024 incompetency order is identified as the master template. 9. **Metadata Authors "barbj," "hernandezke," "GuzmanC," and "Nehring, Alisha":** Centralized authorship patterns across hundreds of documents. "barbj" authored 137 documents across 105 cases. "hernandezke" authored 225 documents across 101 cases. The initial Rule 20 evaluation attributed to Dr. Rogstad was actually authored by "GuzmanC." Two separate Rule 20 evaluations (attributed to Dr. Milz and Dr. Cranbrook) share identical metadata showing authorship by "Hines, Anne." 10. **PDF Toolchain Evidence:** Consistent use of Adobe XMP Core 5.1.0-jc003, PScript5.dll Version 5.2.2, and Acrobat Distiller — enterprise-grade automated PDF generation tools not available to ordinary court personnel. 11. **Embedded Font Tracking Codes (Section XVII):** Over 1,000 documents contain hidden CFF (Compact Font Format) data strings that function as concealed tracking identifiers, enabling silent updates or overwriting of court documents after filing. **Defendant-Specific Claims (Sections XVIII–XXII):** The complaint details claims against each named defendant: *State Officials:* Tim Walz (Governor), Keith Ellison (AG), Alisha Nehring (MDH attorney) — charged with failure of oversight, constructive knowledge of fraud, supervisory liability. *County Officials:* Hennepin County (Monell liability), Mary Moriarty (County Attorney), Judith Cole (Sr. Asst. County Attorney), Chela Guzman-Wiegert (metadata author "GuzmanC"), Michael Berger (Chief Public Defender). *Judicial Officers:* Kerry W. Meyer (Chief Judge), Hilary Caligiuri (Presiding Criminal Judge), Todd Fellman (Presiding Juvenile Judge), Sarah Hudleston, William Koch, Julia Dayton-Klein, Danielle Mercurio, Michael K. Browne, Lisa K. Janzen, Carolina A. Lamas, Shereen Askalani, George F. Borer. Each judge is connected to specific docket anomalies, synthetic cases, and/or duplicate signature hashes. *Legal Counsel:* Mawerdi Hamid, Jacqueline Perez, Emmett Donnelly, Raissa Carpenter, Bruce Rivers. *Mental Health Professionals:* Dr. Jill Rogstad, Dr. Adam Milz, Dr. Katheryn Cranbrook, Dr. Kristen A. Otte. *Doe Defendants:* John Does 1–50 and Jane Does 1–50, believed to include court IT administrators, Odyssey system engineers, DHS contractors, military/intelligence actors, and executives from Light Field Labs, OTOY, Google/Alphabet, YouTube, the World Economic Forum, and USC (ICT, Cinema, Shoah Foundation). **RICO Claims (Section XXIV):** Alleges an enterprise under 18 U.S.C. § 1961(4) consisting of court officials, forensic examiners, public defenders, and IT operators, operating continuously from January 2023 through the present. Predicate acts include mail fraud, wire fraud, obstruction of justice, false statements, witness tampering, and conspiracy. The enterprise's objective is alleged to be eliminating Guertin's ability to commercialize US Patent 11,577,177, which Guertin values at over $100 billion NPV. **Relief Sought (Sections XXV–XXVII):** (1) Preliminary and permanent injunction halting all state criminal proceedings; (2) declaratory judgment invalidating all synthetic psychiatric evaluations and court orders; (3) referral to DOJ/federal grand jury for criminal investigation; (4) protective order against further psychiatric examination, forced medication, or commitment; (5) expungement of synthetic/altered records; (6) compensatory, punitive, and treble damages (reserved for post-discovery); (7) jury trial demanded on all issues; (8) evidentiary preservation orders directed at MN Judicial Branch, Hennepin County, DHS, and Odyssey system administrators. ### Legal Issues & Arguments Raised - 42 U.S.C. § 1983 — Due process (5th, 14th Amendments), access to courts (1st Amendment), right to counsel (6th Amendment), cruel and unusual punishment (8th Amendment) - 42 U.S.C. § 1985 — Conspiracy to deprive equal protection - 18 U.S.C. § 1962(c) — RICO participation (conducting enterprise through pattern of racketeering activity) - 18 U.S.C. § 1962(d) — RICO conspiracy - 18 U.S.C. §§ 1341, 1343 — Mail and wire fraud - 18 U.S.C. § 1512 — Witness tampering / obstruction - 18 U.S.C. § 1519 — Falsification of records - 18 U.S.C. § 1001 — False statements - 18 U.S.C. § 505 — Forgery of public documents - 18 U.S.C. § 1028 — Identity document fraud - 18 U.S.C. § 1702 — Obstruction of correspondence - 18 U.S.C. § 371 — Conspiracy to defraud the United States - 18 U.S.C. § 242 — Deprivation of rights under color of law - Federal Rule of Evidence 902(14) — Self-authenticating digital evidence - Monell v. Department of Social Services — Municipal entity liability - Judicial immunity — argued to be overcome by acts outside legitimate judicial function ### Factual Allegations & Key Assertions - 3,601 PDF documents downloaded from MCRO across 163 cases on April 29–30, 2024 - 99.6% bear X.509 SHA-256 digital signatures from Hennepin County Courts - Only 16 PDFs lack signatures - Guertin is the only identifiable real person among 163 defendants - 55 documents bear post-dated digital signatures - 371 instances of timestamp reuse across orders - 1,183 duplicate judicial signature images - 40 fabricated USPS return-mail filings - Image-based (2-bit) court filings indicate AI generation - 127 cloned "Finding of Incompetency and Order" documents sharing author "barbj" - Metadata author "hernandezke" across 225 documents / 101 cases - Rule 20 evaluations attributed to Dr. Rogstad, Dr. Milz, and Dr. Cranbrook actually authored by "GuzmanC" and "Hines, Anne" - "Mother's Letter" incident: synchronized cross-docket document manipulation on April 12, 2024 - Alisha Nehring authored 28 filings including the fraudulent June 14, 2023 Order for Continuance in Guertin's case, with metadata title referencing synthetic defendant "Adrian Wesley" - "Odyssey Merge Batch Print Job" metadata signatures across multiple cases - Discovery fraud across "Sets A–D" spanning the case history - Enterprise metadata toolchain: Adobe XMP Core 5.1.0-jc003, PScript5.dll, Acrobat Distiller - Over 1,000 documents contain hidden CFF font tracking codes - Patent theft motive: InfiniSet US 11,577,177 predates Netflix US 11,810,254 by 12 days - InfiniSet Inc. is Guertin's Delaware corporation - Doe Defendants may include Google, Alphabet, YouTube, Light Field Labs, OTOY, WEF, USC, DARPA, military/intelligence actors ### Procedural Posture Filed June 25, 2025 as Doc. 116 in the existing federal case 0:24-cv-02646-JRT-DLM (Guertin v. Hennepin County), before Judge John R. Tunheim with Magistrate Judge Douglas L. Micko. The complaint header also references a new case number "25-cv-____" suggesting it may be intended as a new action. This appears to be the most comprehensive federal filing to date, superseding or supplementing the original 2024 complaint. References a concurrent emergency motion for stay in state appellate case A25-0882 filed June 4, 2025. References a fourth Rule 20 evaluation ordered on April 29, 2025 by Judge Hudelston. ### Exhibit / Attachment Inventory The complaint references numerous external resources and previously filed exhibits rather than attaching them: - MnCourtFraud.com/File/Complaint.pdf — Digital bookmarked version of this complaint - MnCourtFraud.com and MnCourtFraud.Substack.com — Extensive sub-pages for each evidentiary topic - ZIP archives of MCRO case files (2017.zip through 2023.zip) at MnCourtFraud.com - Specific file URLs for signature hashes, metadata files, and forensic reports - 08_MCRO_files-with-no-signature.xlsx - 09_MCRO_file-metadata.xlsx - ERRORS_finding-of-incompetency-and-order.xlsx - MnCourtFraud.com/File/JULY-13__guertin.csv and JULY-13__links.csv - Exhibit P from prior federal case (Doc. 23 — "Conspiracy of Commitment") - Exhibit W from prior federal case (Doc. 47, pp. 43/167 — metadata evidence from Bruce Rivers discovery) - Declaration of Hao Li from case 3:17-cv-04006-JST (Doc. 139.7) - Netflix Patent Motive & Valuation addendum (Doc. 103 from 24-cv-2646) - A25-0882 Emergency Motion for Stay (Doc. 115 from 24-cv-2646) - Multiple MnCourtFraud.Substack.com article links per section ### Visual Evidence Inventory - This document was extracted via pdftotext and the PDF itself was not visually inspected page by page due to its 121-page length. The text references numerous external images of signature hashes hosted at MnCourtFraud.com (e.g., debcc04a.....b1d764a6.png, f609be80.....e15a1eee.png, 3ff3cad7.....e30a84d9.png, 18d03912.....b3f87d4d.jpg, 3aeb71e9.....198e5764.png, e3e4157a.....8e9d3550.png, 1ac840c5.....735a6ead.png) but these are referenced by URL, not embedded. - [Pages 1–2] Caption and party listing appears in standard federal court filing format - [Page 18, Section VI] Table — Timeline of "Mother's Letter" incident with specific timestamps (2:03 PM, 2:10 PM, 2:28 PM, 4:38 PM, 4:42 PM) - [Page 34] Table — Metadata values for Nehring-authored order (Title, Author/Creator, Company, File Name fields with evidentiary impact) - [Page 38] Metadata display — Rule 20 evaluation metadata showing Author: GuzmanC, XMP Toolkit, and other fields - [Page 121] Signature block: "/s/ Matthew D. Guertin" with address at 4385 Trenton Ln. N 202, Plymouth, MN 55442 ### Key People Referenced *State Officials:* - **Tim Walz** — Governor of Minnesota - **Keith Ellison** — Minnesota Attorney General - **Alisha Nehring** — MN Department of Health Attorney; metadata author of 28 filings *County Officials:* - **Mary Moriarty** — Hennepin County Attorney - **Judith L. Cole** — Sr. Assistant Hennepin County Attorney - **Chela Guzman-Wiegert** — Assistant County Administrator; metadata author "GuzmanC" - **Michael Berger** — Chief Public Defender, Hennepin County *Judicial Officers:* - **Kerry W. Meyer** — Chief Judge, 4th District - **Hilary Caligiuri** — Presiding Criminal Judge, 4th District - **Todd Fellman** — Presiding Juvenile Judge, 4th District - **Sarah Hudleston** — Judge, 4th District (current trial judge) - **William H. Koch** — Judge, 4th District - **Julia Dayton-Klein** — Judge, 4th District - **Danielle C. Mercurio** — Judge, 4th District - **Michael K. Browne** — Judge, 4th District - **Lisa K. Janzen** — Judge, 4th District - **Carolina A. Lamas** — Judge, 4th District - **Shereen Askalani** — Judge, 4th District - **George F. Borer** — Referee, 4th District - **Lee Cuellar** — Judicial Clerk, 4th District *Legal Counsel:* - **Mawerdi Hamid** — Asst. Hennepin County Attorney (uses @ag.state.mn.us address) - **Jacqueline Perez** — Asst. Hennepin County Attorney - **Emmett M. Donnelly** — Hennepin County Public Defender - **Raissa Carpenter** — Hennepin County Public Defender - **Bruce M. Rivers** — Private defense counsel *Mental Health Professionals:* - **Dr. Jill Rogstad** — Senior Clinical Forensic Psychologist - **Dr. Adam Milz** — Hennepin County Psychological Services - **Dr. Katheryn Cranbrook** — Hennepin County Psychological Services - **Dr. Kristen A. Otte** — Hennepin County Psychological Services *Metadata-Identified Individuals:* - **"barbj"** — Metadata author of 137 documents / 105 cases - **"hernandezke" / "HernandezKE"** — Metadata author of 225 documents / 101 cases - **"GuzmanC" (Chela Guzman-Wiegert)** — Metadata author of Rule 20 evaluation - **"Hines, Anne"** — Actual author of evaluations attributed to Dr. Milz and Dr. Cranbrook - **"HoopmanA" / "Hoopmana"** — Metadata author of case reassignment notices - **Andrew Reiland II** — Metadata author of filing attributed to Carpenter - **Camille A. King** — Metadata author of filing attributed to Carpenter - **"Hansen, Isabel"** — Metadata author of Judge Koch's competency order - **"burrowsp"** — Metadata author of Rule 20.01 evaluation order and forensic navigator appointment - **Amanda Burg** — Referenced as associated with Nehring and Cole in document fabrication *Other:* - **Sandra Phitsanoukanh Vongsaphay** — Alleged fabricated defendant (case 27-CR-23-2480) - **Adrian Michael Wesley** — Alleged foundational synthetic defendant (2017 cases) - **Hao Li** — Director, USC ICT Vision and Graphics Lab - **Tom Arneson** — Prosecutor mistakenly listed as defense counsel in 11 cloned filings ### Key Entities / Organizations Referenced - U.S. District Court, District of Minnesota - Hennepin County / Fourth Judicial District Court - Minnesota Court Records Online (MCRO) - Tyler Technologies / Odyssey Case Management System - Minnesota Department of Health - Minnesota Department of Human Services (DHS) - Hennepin County Criminal Justice Coordinating Committee - Hennepin County Public Defender's Office - Hennepin County Psychological Services - Minnesota Court of Appeals (A24-0780, A25-0882) - U.S. Eighth Circuit Court of Appeals - InfiniSet, Inc. (Delaware corporation) - Netflix - Light Field Labs / OTOY / Google LLC / Alphabet Inc. / YouTube - World Economic Forum - USC ICT / USC Cinema / USC Shoah Foundation - DARPA / U.S. State Department / U.S. Army / Air Force - U.S. Department of Justice - Adobe (XMP Core, PDF Library, Acrobat Distiller, PScript5.dll) - USPS - MnCourtFraud.com / MnCourtFraud.Substack.com - CourtListener.com - MattGuertin.com / MattGuertin.Substack.com ### Dates & Deadlines Mentioned - January 2023 – present — Alleged enterprise operation period - April 29–30, 2024 — MCRO document download dates - January 1, 2023 – April 26, 2024 — MCRO search date range - March 10, 2023 — Dr. Rogstad Rule 20 evaluation - January 11, 2024 — Dr. Milz Rule 20 evaluation - June 14, 2023 — Nehring-authored Order for Continuance in Guertin's case - January 16–17, 2024 — Incompetency finding/waiver/remote hearing sequence - April 12, 2024 — "Mother's Letter" incident - July 15, 2024 — Klein Order to Recuse (Nehring-authored per metadata) - July 16, 2024 — Bruce Rivers provided USB flash drive with discovery - August 7, 2024 — Exhibit W metadata filed in federal record - December 20, 2024 — Rule 20 evaluation (Dr. Cranbrook, metadata author "Hines, Anne") - December 30, 2024 — Cranbrook evaluation received via email from Carpenter; Carpenter files "Objection to Competency" (metadata author Andrew Reiland II) - January 14, 2025 — "Demand or Request for Discovery" (metadata author Camille A. King) - January 30–31, 2025 — Case assigned to Judge Hudelston; "Notice of Case Reassignment" (metadata "Odyssey Merge Batch Print Job") - February 13, 2025 — Discovery "Set D" provided - March 5, 2025 — Hearing (competency determination) - April 3, 2025 — Judge Koch's order determining competency (metadata author "Hansen, Isabel"), produced nearly a month after hearing - April 17, 2025 — Scheduled hearing before Hudelston - April 29, 2025 — Fourth Rule 20 evaluation ordered; forensic navigator appointed - May 10, 2024 — First petition for discretionary review - June 4, 2025 — Emergency Motion for Stay in A25-0882 - June 25, 2025 — This complaint filed ### Forensic Flags & Anomalies - **Central forensic claim:** 162 of 163 criminal cases sharing the same three judicial officers appear to involve synthetic/fabricated defendants and documents - **Post-dated signatures:** 55 court documents bear digital signatures timestamped after filing dates - **Timestamp cloning:** 371 instances of byte-for-byte duplicate timestamps across different orders and cases - **Signature image reuse:** 1,183 duplicate signature graphics, sometimes mismatched to judge names - **Fabricated mail:** 40 identical USPS return-mail scans reused across synthetic cases - **2-bit image filings:** Court documents rendered as binary images rather than native text, lacking scan artifacts - **Mother's Letter incident:** Synchronized cross-docket manipulation with matching SHA-256 hashes between response letters - **Metadata author misattribution:** Multiple Rule 20 evaluations attributed to different examiners but sharing identical metadata authors (GuzmanC, Hines Anne) - **"barbj" centralization:** Single metadata author responsible for 127 of 129 incompetency orders - **"hernandezke" centralization:** 225 documents including notices of hearing and Rule 20 evaluation orders - **Nehring cross-contamination:** Order for Continuance in Guertin's case contains metadata title referencing synthetic defendant "Adrian Wesley" - **Enterprise PDF toolchain:** Uniform use of Adobe XMP Core 5.1.0-jc003, PScript5.dll, Acrobat Distiller - **CFF font tracking codes:** Hidden strings embedded in 1,000+ documents enabling post-filing modification - **Role reversal errors:** Prosecutor Tom Arneson listed as defense counsel in 11 cloned filings — template propagation artifact - **4th Rule 20 evaluation:** Ordered April 29, 2025 based solely on Guertin's legal filings, alleged to be retaliatory ### Cross-References - Federal case 0:24-cv-02646-JRT-DLM (Guertin v. Hennepin County) — this is Doc. 116 - State criminal case 27-CR-23-1886 - State appellate cases A24-0780, A25-0882 - Federal case 3:17-cv-04006-JST (Declaration of Hao Li) - Prior federal filings: Doc. 23 (Exhibit P), Doc. 47 (Exhibit W), Doc. 77 (ethics complaint), Doc. 103 (patent valuation), Doc. 115 (emergency motion) - Filing #9 (Motion for Substitute Counsel) — referenced via Bruce Rivers allegations - Filing #10 (Judicial Notice / Docket Anomalies) — many of the same docket anomalies are expanded here - Filing #11 (Exhibit List M-Q) — patent theft narrative expanded here - Synthetic case 27-CR-23-2480 (Sandra Phitsanoukanh Vongsaphay) - "Adrian Wesley" cases: 27-CR-17-1555, 27-CR-17-8342, 27-CR-17-22909 --- --- --- ## Filing #13 — Exhibit AA: Guertin's MN OLPR Complaint Against Bruce M. Rivers | Field | Detail | |---|---| | Filing # | 13 | | Date Filed | September 24, 2024 (filed in federal case); complaint itself dated September 23, 2024; USPS delivered September 24, 2024 to MN OLPR | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Federal Court Exhibit (Exhibit AA) — containing formal ethics complaint to Minnesota Office of Lawyers Professional Responsibility | | Case/Court | 0:24-cv-02646-JRT-DLM (Guertin v. Hennepin County et al.) / U.S. District Court, District of Minnesota; underlying complaint directed to MN OLPR re: 27-CR-23-1886 / Fourth Judicial District, Hennepin County, MN | | Pages | 128 | | Bates / Doc ID | Doc. 77 in 0:24-cv-02646-JRT-DLM; source filename: 77__EXHIBIT-AA__Guertins-MN-OLPR-Complaint-Against-Bruce-M-Rivers.pdf | ### Comprehensive Summary This 128-page document is Exhibit AA filed as Doc. 77 in Guertin's federal civil rights case (0:24-cv-02646-JRT-DLM) on September 24, 2024. It contains three indexed components: (1) USPS delivery confirmation of the physical complaint to the MN OLPR; (2) an email copy of the complaint sent to the MN OLPR; and (3) the full 117-page formal ethics complaint Guertin submitted against his criminal defense attorney, Bruce M. Rivers, to the Minnesota Office of Lawyers Professional Responsibility. The complaint is structured as a detailed legal brief with fifteen numbered sections (Sections I–XV), a comprehensive table of contents, links to seven video evidence downloads hosted on Proton Drive and Storj, and extensive embedded screenshots, emails, text messages, call logs, court documents, forensic image analyses, and other visual exhibits. **Section I (pp. 1–2):** The standard MN OLPR complaint form. Guertin identifies himself as a former client of Rivers. Rivers is identified at 701 Fourth Ave S., Suite 300, Minneapolis, MN 55415, with phone numbers 612-339-3939 and 612-472-2343. Guertin indicates he hired Rivers in early February 2023. The complaint is signed electronically "/s/ Matthew D. Guertin" dated September 14, 2024 (the form date) with supporting documents attached. **Section II (pp. 3–4): Background and Nature of the Cases.** Guertin identifies five related proceedings: (a) criminal case 27-CR-23-1886 (Hennepin County); (b) civil commitment case 27-MH-PR-23-815 (Hennepin County); (c) pro se Petition for Discretionary Review, A24-0780 (MN Court of Appeals); (d) pro se federal civil rights case, Guertin v. Hennepin County, 24-cv-02646-JRT-DLM (D. Minn.); and (e) pro se interlocutory appeal, Matthew Guertin v. Hennepin County, 24-2662 (8th Circuit Court of Appeals). Guertin states he is under a stayed order of civil commitment based on incompetency findings he contests. His charges consist of one count of Reckless Discharge of Firearm Within a Municipality (Minn. § 609.66.1a(a)(3)) and three counts of Firearm-Serial Number-Receive/Possess With No Serial Number (Minn. § 609.667(3)). Guertin notes the three serial-number charges are subject to the pending Minnesota Supreme Court decision in State v. Vagle, 999 N.W.2d 909 (Minn. Ct. App. 2023), which challenges the statute as constitutionally vague. Guertin argues his stayed commitment status places him in a "gray area" that allows pursuit of his federal case without triggering Heck v. Humphrey, 512 U.S. 477 (1994). **Section III (pp. 5–14): Guertin and Rivers' Longstanding Relationship.** Guertin recounts a nearly 25-year relationship with Rivers, beginning when Rivers represented him pro bono on a "Pedestrian on the Freeway" ticket related to writing "Fire Denny Green" in snow outside the Minnesota Vikings' training facility — an incident that received local and national media attention. Guertin retained Rivers for various legal matters over the years, the last time being in 2007. In April 2020, Guertin reconnected with Rivers after returning from Los Angeles due to COVID. Guertin then consulted Rivers on various legal questions and shared details of his patent venture. On November 11, 2022, Guertin called Rivers at 6:48 AM to discuss his discovery of the Stephan Trojansky patent application that appeared to cover the same technology as Guertin's soon-to-be-granted US Patent 11,577,177. Guertin sent Rivers an informational packet by email within the hour. On January 13, 2023, Guertin emailed Rivers seeking help investigating the patent fraud he claimed to be witnessing. **Section III-C (pp. 13–14): Origination of Criminal Charges.** Guertin describes his January 21, 2023 arrest, stating he fired a gun into the air to "call" the police because he believed his electronic devices were hacked and that those responsible for the patent fraud had been surveilling him via Bluetooth outside his apartment. He characterizes this as an acute stress reaction after sitting frozen in fear for nearly two days, followed by an intentional decision to get arrested and exit the apartment safely. **Section IV (pp. 15–57): Conspiracy Utilizing Fraudulent Discovery.** This is the longest and most forensically detailed section, divided into two sub-parts: *Sub-part A (pp. 15–34): First Set of Fraudulent Discovery — Originated From Within the Court.* Guertin alleges that court-appointed attorney Michael Biglow emailed him unsolicited discovery photos on August 3, 2023 — a PDF titled "23-815 Guertin – photos of exterior, interior, person 1.21" containing 80 police photographs. Guertin notes Dr. Rogstad's March 2023 Rule 20.01 report references 104 photographs, a discrepancy of 24 from the 80 in the Biglow PDF. On January 3, 2024, Guertin emailed Dr. Adam Milz about the fraudulent discovery before his Rule 20 exam. On January 5, 2024, he filed his first ever pro se motion — a "Demand or Request for Discovery" explicitly seeking "All 104 police photographs." On April 4, 2024, Guertin submitted a "Motion to Compel Discovery" containing a forensic analysis he personally conducted, which found that 28 out of 80 images — all taken inside his apartment — had been selectively cropped to non-uniform aspect ratios. Guertin's analysis utilized barrel distortion (wide-angle lens "fish-eye" effect) to estimate the original center positions of the photos before cropping. He alleges the cropping was designed to conceal evidence of his patent work, including books on corporate startups, filming/lighting equipment, his professional workstation, and his invention (a bright green "centerpiece" in his living room/fabrication studio). He further identified pixelation artifacts in image "30-50" showing his laptop screen. His April 4 and June 3, 2024 motions, plus a May 3 correspondence, were all ignored by the court and by Rivers. *Sub-part B (pp. 35–57): Second Set of Fraudulent Discovery — Originated Directly from Bruce Rivers.* On July 16, 2024 — after filing his federal civil rights complaint on July 8, 2024 — Guertin attended a review hearing, after which Rivers instructed him to go to Rivers' office to receive discovery on a USB flash drive. After examining the USB contents approximately a week later, Guertin cross-referenced the 518 images on the USB against the original 80 images. He discovered the same 28 images he had identified as cropped in the first set were entirely missing from the second set. Guertin argues this proves Rivers obtained the fraudulent second set of discovery after Guertin's April 4, 2024 motion made the cropping public knowledge. Additionally, Guertin alleges that all images of his laptop screen in the July 16 discovery had been manipulated using "advanced AI," whereas the first set had only a single manipulated laptop image. He submitted this analysis as "Exhibit Y" in his federal case on September 2, 2024. He concludes that the discovery fraud implicates Rivers, the prosecution, the court, and external "powerful" influences, invalidating all of his Hennepin County proceedings. **Section V (pp. 59–73): Rivers' Refusal to Withdraw as Defense Counsel.** Guertin documents three direct requests for Rivers to withdraw (April 3, 2024 email; April 18, 2024 text; June 6, 2024 text), plus his pro se Motion for Substitute Counsel filed June 3, 2024 (ignored by the court). He notes Rivers has an "Entry of Default" against him in the federal case yet still refuses to withdraw. Guertin states he feels "held hostage" by Rivers and the court, unable to defend himself. He includes an April 22–23, 2024 email exchange with his civil commitment attorney (Joel Fisher) in which he explains his concerns and Fisher responds. He also references "Exhibit Z" filed September 9, 2024, containing a ChatGPT analysis of his August 7, 2024 "Motion for Preliminary Injunction" detailing Rivers' failures. On September 13, 2024, Guertin met with his mental health case worker and obtained an email from the case worker during their meeting documenting his concerns about Rivers. **Section VI (pp. 73–84): Knowledge of Federal Case and Conflicts of Interest.** Guertin documents: Rivers personally signed for the federal summons on July 15, 2024; at the July 16 hearing, Rivers discussed the case in the hallway, told Guertin "It's going to get dismissed," and repeatedly lied about already providing discovery; Judge Klein recused herself from the bench mid-hearing after being named a defendant in the federal suit; Rivers made a sarcastic comment to Judge Koch on the remote screen referencing "my client filed a federal lawsuit against the entire court"; on July 18 Rivers texted from a new number; on August 18 Guertin filed a corrected Request for Entry of Default against Rivers; on August 29 the clerk entered default against Rivers; that same day Rivers called Guertin for 15 minutes and 35 seconds, oscillating between accusing Guertin of incompetence and assuring him all charges would be dismissed if he simply accepted the incompetency finding. Guertin also identifies a YouTube-related conflict of interest he raised with Rivers in a June 16, 2023 email that was never addressed. **Section VII (pp. 85–96): "Powerful People" Statement and Patent Valuation.** Guertin recounts the pivotal May 22, 2023 phone call at 3:13 PM when Rivers allegedly stated "Yeah I did, you have some very powerful people keeping an eye on you." Rivers then deflected and said "We'll talk about it in person/later, I don't trust that this line is secure." The next day Guertin sent duplicate text messages to multiple friends documenting Rivers' statement. Guertin then presents evidence of LinkedIn searches by "USC Cinema" and the US Army Reserves — both entities he connects to Paul Debevec (Netflix/Eyeline Studios). He includes his LinkedIn search chronological analysis, his patent's military training simulation implications, and a conservative 20-year patent valuation estimate. He argues billions of dollars in patent value validates the existence of "powerful people" monitoring him. **Section VIII (pp. 96–100): Failure to Follow Through on Legal Promise.** Guertin recounts that on July 28, 2023 he first learned — through a letter from court-appointed attorney Michael Biglow — that a petition for civil commitment had been filed against him and that he had been found incompetent on July 13, 2023. Rivers had not informed Guertin of these developments despite being retained for $10,000. When Guertin contacted Rivers, Rivers promised to represent him in the civil commitment proceedings. On August 1, 2023, the day of the hearing, Rivers was "nowhere to be found" and did not respond to Guertin's outreach, leaving Guertin without guidance. **Section IX (pp. 101–104): Failure to Present Exculpatory Evidence.** Guertin alleges Rivers failed to present any exculpatory evidence at the July 7, 2023 competency hearing and advised Guertin not to present his own prepared evidence. Guertin states he had provided Rivers with duplicate documents he also gave to Dr. Rogstad during the March 3, 2023 Rule 20 exam, delivered to Rivers' office in a sealed manila envelope. Rivers was also CC'd on emails to Rogstad containing additional information. Examples of exculpatory evidence cited include the Minnetonka PD Report #23-000151 filed January 12, 2023. **Section X (pp. 104–105): Misleading Statements / Lack of Informed Consent.** On January 15, 2024, Rivers told Guertin "no court," which was followed the next day by an order stating "all parties agree to a finding of incompetency prior to the hearing." Guertin alleges this amounted to obtaining his acquiescence through misleading statements without informed consent. **Section XI (pp. 106–107): Refusal to Provide Discovery or Rule 20 Exam.** Guertin reiterates that he did not receive the January 2024 Rule 20 exam report or discovery materials until July 16, 2024 — only after filing his federal lawsuit against Rivers. He states he still has not received authentic discovery materials. **Section XII (pp. 108–111): Rivers Must Immediately Withdraw.** Guertin summarizes all allegations: gaslighting, lying, "playing dumb," concealing and disseminating fraudulent discovery, actively supporting the false incompetency narrative, and discouraging pro se filings. He notes that Rivers' January 2024 comment that pro se filings might make the court think Guertin was not represented was what prompted Guertin to continue filing more motions. Guertin characterizes Rivers' behavior as so bizarre and contrary to his 25-year-known character that it constitutes a "bright, flashing red emergency light." **Section XIII (pp. 112–113): Preferred Legal Strategy.** Guertin lists seven demands: (0) immediate halt to fraud within the courts; (1) Rivers must withdraw; (2) continuance of October 1, 2024 review hearing pending new counsel; (3) contest competency determination due to fraudulent discovery; (4) formal Motion to Compel Discovery for all 104+ authentic photos including the 28 missing images; (5) if prosecution cannot produce authentic photos, a Motion to Dismiss under Rule 9; (6) any third Rule 20 exam must be conducted by a neutral third party with zero Hennepin County affiliations. **Section XIV (pp. 114–116): Documented Refusal of 3rd Rule 20 Exam.** Guertin documents his refusal to participate in a third Rule 20 exam, communicated to examiner Katheryn Cranbrook who emailed him on August 5, 2024. He notes his criminal case record (27-CR-23-1886) shows two "Rule 20 Progress Report" entries despite his never having participated in a third exam. **Section XV (p. 117): Verification.** Signed under penalty of perjury, dated September 23, 2024, with electronic signature "/s/ Matthew D. Guertin." ### Legal Issues & Arguments Raised - Ineffective assistance of counsel under the Sixth Amendment and Strickland v. Washington, 466 U.S. 668 (1984) - Attorney conflict of interest (Rivers named as defendant in Guertin's federal civil rights case while continuing representation; YouTube-related conflict) - Conspiracy to introduce fraudulent discovery materials into criminal case proceedings - Spoliation/manipulation of evidence (28 cropped images in first discovery set; same 28 images missing from second set; alleged AI manipulation of laptop screen photos) - Failure to provide discovery materials in violation of court rules (Rule 9) - Failure to present exculpatory evidence at July 7, 2023 competency hearing - Failure to inform client of incompetency finding and civil commitment petition - Breach of promise to represent in civil commitment proceedings - Misleading statements resulting in lack of informed consent regarding January 2024 incompetency stipulation - Refusal to withdraw as defense counsel despite direct requests and being named as federal defendant - Refusal to follow client's preferred defense strategy - Constitutional vagueness of Minn. § 609.667(3) (pending in State v. Vagle) - Due process violations in competency proceedings - Entry of Default against Rivers in federal case (August 29, 2024) - Request for neutral third-party Rule 20 examiner with no Hennepin County affiliations - Request for change of venue - Applicability of Heck v. Humphrey, 512 U.S. 477 (1994) to stayed commitment status ### Factual Allegations & Key Assertions - Guertin retained Rivers in early February 2023; certificate of representation filed February 20, 2023 - Guertin and Rivers had a 25-year relationship originating from a "Pedestrian on the Freeway" ticket involving the "Fire Denny Green" snow-writing incident at the Vikings' training facility - Rivers was paid a $10,000 retainer - On November 11, 2022, Guertin called Rivers at 6:48 AM about discovering the Trojansky patent application and sent a follow-up informational packet by email - On January 13, 2023, Guertin emailed Rivers seeking referrals for investigating patent fraud - January 21, 2023: Guertin arrested after firing gun to summon police; describes acute stress reaction related to believed hacking/surveillance - Michael Biglow emailed unsolicited discovery photos (80 images in PDF titled "23-815 Guertin – photos of exterior, interior, person 1.21") on August 3, 2023 - Dr. Rogstad's March 2023 report lists 104 photographs; Robertson received same 80-photo PDF on August 1, 2023 - Guertin's forensic analysis identified 28 of 80 interior apartment photos as selectively cropped using non-uniform aspect ratios and barrel-distortion analysis - Cropping allegedly concealed patent-related items: startup books, filming/lighting equipment, workstation, and the invention itself - Photo "30-50" of laptop screen contained unique pixelation artifacts - January 5, 2024: Guertin filed first pro se motion ever — Demand for Discovery seeking 104 photos - April 4, 2024: Guertin filed Motion to Compel Discovery with forensic analysis table - July 16, 2024: Rivers provided USB flash drive with 518 discovery images; the same 28 images were missing; all laptop screen photos allegedly AI-manipulated - Rivers obtained the second fraudulent discovery set after April 4, 2024 (when cropping first became public knowledge) - May 22, 2023 at 3:13 PM: Rivers told Guertin "you have some very powerful people keeping an eye on you" and stated he did not trust the phone line's security - Rivers subsequently denied making the "powerful people" statement - June 16, 2023: Guertin emailed Rivers addressing YouTube-related conflict of interest - July 7, 2023: Rivers failed to present exculpatory evidence at competency hearing and advised Guertin not to present his own evidence - July 13, 2023: Incompetency finding entered; July 20, 2023: civil commitment petition filed — neither communicated to Guertin by Rivers - July 28, 2023: Guertin first learned of incompetency finding and civil commitment petition via letter from Biglow - August 1, 2023: Rivers failed to appear or respond for civil commitment hearing despite promising representation - January 15, 2024: Rivers told Guertin "no court"; January 16, 2024: order entered stating "all parties agree to a finding of incompetency" - Three direct written requests for Rivers to withdraw (April 3, April 18, June 6, 2024) - June 3, 2024: Motion for Substitute Counsel filed and ignored by court - July 8, 2024: Federal civil rights complaint filed naming Rivers as defendant - July 15, 2024: Rivers personally signed for federal summons via USPS Priority Mail Express - July 16, 2024: Judge Klein recused mid-hearing after discovering she was named in federal suit; Judge Koch presided remotely - August 29, 2024: Entry of Default entered against Rivers in federal case; same day Rivers called Guertin for 15 min 35 sec - Rivers oscillated between accusing Guertin of incompetence and promising charge dismissal - September 9, 2024: Exhibit Z filed containing ChatGPT analysis of Rivers' failures - September 13, 2024: Guertin's mental health case worker documented his concerns about Rivers during their monthly meeting - Guertin refused third Rule 20 exam; communicated refusal to examiner Katheryn Cranbrook beginning August 5, 2024 - Case docket shows two "Rule 20 Progress Report" entries despite no third exam participation - LinkedIn search analysis showed searches by "USC Cinema" and US Army Reserves correlated with Guertin's patent-related activities - Guertin estimates patent value at "many billions" over 20 years with military training simulation applications ### Procedural Posture This document was filed as Exhibit AA (Doc. 77) in the federal civil rights case on September 24, 2024 — the same day the physical complaint was delivered to the MN OLPR in Saint Paul. The underlying OLPR complaint was prepared and signed on September 23, 2024, with the OLPR form itself dated September 14, 2024. The exhibit contextualizes Guertin's allegations against Rivers for the federal court audience while simultaneously initiating a formal ethics investigation with the MN OLPR. The complaint was filed after Guertin's Entry of Default against Rivers (August 29, 2024) and before the scheduled October 1, 2024 review hearing. It references the entire arc of events from Rivers' retention in February 2023 through September 2024. ### Exhibit / Attachment Inventory The document is itself an exhibit (Exhibit AA) containing three indexed sub-components: - **Index 01 (pp. 1–4):** USPS Delivery Confirmation — Tracking #EI993543430US showing delivery to OLPR offices in Saint Paul, MN 55101 on September 24, 2024 at 1:57 PM, signed by "A BERTRAND." Also includes images of the USPS Express Mail label and envelope. - **Index 02 (p. 5/PDF p. 7):** Email from mattguertin@protonmail.com to OLPRComplaintDocs@courts.state.mn.us, September 24, 2024 at 3:19 PM, with 20.46 MB PDF attachment "MN-OLPR_Complaint_Bruce-M-Rivers.pdf." - **Index 03 (pp. 1–117 internal / PDF pp. 8–128):** The full OLPR complaint with 15 numbered sections, table of contents, and verification. ### Video Evidence Sources (7 items, hosted on Proton Drive and Storj): 1. Analysis of Bruce Rivers July 16, 2024 Fraudulent Discovery Materials 2. Bruce Rivers Call Logs 3. Bruce Rivers Early Texts – 01 4. Bruce Rivers Early Texts – 02 5. Bruce Rivers Retained Texts – 03 6. Bruce Rivers Retained Texts – 04 7. CIA Welder Text History ### Referenced Federal Case Exhibits: - Exhibit Y (filed September 2, 2024) — Analysis of discovery fraud "no defense" scenario - Exhibit Z (filed September 9, 2024) — ChatGPT analysis of Rivers' failures from August 7, 2024 Motion for Preliminary Injunction ### Visual Evidence Inventory This document contains 157 embedded images across its 128 pages. The vast majority are screenshots of emails, text messages, call logs, court filings, forensic image analysis tables/diagrams, USPS tracking pages, and similar evidentiary screenshots. A page-by-page summary follows: - **[Pages 1, 4, 6, 7]** Background/template images: Faint repeating page background images (20.8K each, likely decorative or watermark); standard federal court case header "CASE 0:24-cv-02646-JRT-DLM Doc. 77 Filed 09/24/24" appears on every page. - **[Pages 3–4] USPS Tracking Screenshots:** Two images — USPS tracking confirmation webpage showing tracking number EI993543430US with delivery history (Chaska → Saint Paul), and what appears to be the signed delivery confirmation. - **[Pages 5–6] USPS Express Mail Label/Envelope:** Photos of the physical USPS Express Mail envelope and label addressed to OLPR at 445 Minnesota Street, Suite 2400, Saint Paul, MN 55101-2139, with return address at Guertin's Chaska residence. Close-up of handwritten label and postage markings visible. - **[Page 7] Email Screenshot:** Proton Mail email from mattguertin@protonmail.com to OLPR, dated September 24, 2024, 3:19 PM, with attachment listed as 20.46 MB. - **[Page 8] Title Page:** Formatted title page for the OLPR complaint — "MINNESOTA OFFICE OF LAWYERS PROFESSIONAL RESPONSIBILITY COMPLAINT AGAINST BRUCE M. RIVERS SUBMITTED BY MATTHEW D. GUERTIN." - **[Pages 18–19] Text Message Screenshots (Early Texts):** Series of text message exchanges between Guertin and Rivers showing friendly/cordial communications from 2020–2022, including Guertin sharing details about his patent venture. - **[Pages 20–23] Call Log and Email Screenshots:** Phone call log showing November 11, 2022 call at 6:48 AM (11 min 48 sec duration); email screenshots of informational packet sent to Rivers about the Trojansky patent; January 13, 2023 email seeking investigation referrals. - **[Page 24] Criminal Charges Screenshot:** Appears to be Minnetonka PD or court records related to January 21, 2023 arrest. - **[Pages 25–26] Text Message Screenshots:** Additional messages from the Guertin-Rivers text history providing context about their relationship. - **[Pages 27–28] Discovery Document Screenshots:** Screenshots showing the PDF filename "23-815 Guertin – photos of exterior, interior, person 1.21" as received from Biglow; Dr. Robertson's report listing the same document title. - **[Pages 29–30] Rule 20 Email and Discovery Request:** Screenshot of January 3, 2024 email to Dr. Milz; screenshot of January 5, 2024 "Demand or Request for Discovery" filing. - **[Pages 31–35] Motion to Compel Discovery and Forensic Analysis:** Screenshots of April 4, 2024 Motion to Compel Discovery; multi-page forensic analysis tables showing aspect ratio data for all 80 images, with 28 interior photos flagged as having non-uniform ratios. - **[Pages 36–40] Barrel Distortion Analysis:** Diagrams and annotated images demonstrating the barrel distortion / wide-angle lens analysis methodology used to estimate original photo center positions before cropping. Includes side-by-side comparisons. - **[Pages 38–40] Photo "30-50" Laptop Screen Artifacts:** Screenshots highlighting pixelation artifacts uniquely present in the photograph of Guertin's laptop screen. - **[Pages 41–44] Subsequent Discovery Motions:** Screenshots of May 3, 2024 correspondence, June 3, 2024 third Motion to Compel Discovery, June 3, 2024 second follow-up correspondence, and June 6, 2024 text to Rivers about fraudulent discovery. - **[Pages 46–48] USB Discovery Analysis:** Screenshots showing the July 16, 2024 USB contents — folder structure, file listings, metadata. Updated forensic table showing cross-reference of 518 new images against 80 original images with the same 28 missing. - **[Pages 48–56] AI Manipulation Evidence and "Exhibit Y" Analysis:** Multiple pages of side-by-side image comparisons allegedly showing AI manipulation of laptop screen photos in the July 16 discovery. Screenshots from "Exhibit Y" filed September 2, 2024, presenting the argument that no defense exists for the missing 28 images. - **[Pages 59–62] Withdrawal Request Communications:** Screenshots of April 3, 2024 email requesting Rivers withdraw; April 18, 2024 text message; screenshots of Guertin's email to civil commitment attorney (Joel Fisher) and Fisher's April 23, 2024 reply. - **[Pages 65–68] Motion for Substitute Counsel:** Screenshots of the June 3, 2024 pro se Motion for Substitute Counsel (multi-page); June 6, 2024 text message with third withdrawal request. - **[Pages 69–72] Exhibit Z / ChatGPT Analysis:** Screenshots of "Exhibit Z" — a ChatGPT analysis of Rivers' failures from the August 7, 2024 Motion for Preliminary Injunction. September 13, 2024 email from mental health case worker. - **[Pages 74–78] Federal Case Service Documentation:** USPS tracking for federal summons delivery to Rivers; screenshots of Rivers personally signing for the summons on July 15, 2024; Entry of Default request and clerk's entry dated August 29, 2024. - **[Pages 79–81] August 29, 2024 Text Messages Post-Default:** Screenshots of text exchange between Guertin and Rivers following the Entry of Default and 15-minute phone call. Rivers' new phone number conversation. - **[Pages 82–84] YouTube Conflict of Interest:** Screenshots of June 16, 2023 email to Rivers addressing YouTube-related conflict of interest. - **[Pages 85–90] "Powerful People" Documentation:** Call log screenshot showing May 22, 2023 call at 3:13 PM; screenshots of May 23, 2023 text messages to friends documenting Rivers' statement; LinkedIn search analysis screenshots showing searches by USC Cinema, US Army Reserves, and other entities with chronological correlations. - **[Pages 91–95] Patent Valuation and Military Applications:** Screenshots of patent analysis documents regarding military training simulation implications; estimated 20-year patent valuation table; LinkedIn search graph image with entity cross-linking data. - **[Pages 96–100] Broken Promise — Civil Commitment:** July 28, 2023 letter from Biglow; text and email screenshots of Guertin contacting Rivers seeking guidance before August 1, 2023 hearing; screenshots documenting Rivers' non-response. - **[Pages 101–104] Exculpatory Evidence Failure:** Screenshots showing examples of exculpatory evidence Rivers failed to present, including references to Minnetonka PD Report #23-000151. - **[Pages 104–107] Misleading Statements and Discovery Refusal:** Screenshots of communications around January 15, 2024 "no court" statement; email and text screenshots documenting repeated requests for discovery and Rule 20 exam report. - **[Pages 108–111] Rivers Not Advocating:** Screenshots of additional email and text exchanges showing Guertin's repeated requests regarding discovery and defense strategy being ignored. - **[Pages 113–116] Rule 20 Refusal Documentation:** Screenshots of email exchange with Katheryn Cranbrook beginning August 5, 2024; screenshots of case docket showing two "Rule 20 Progress Report" entries despite non-participation; screenshots of Guertin's communications documenting his refusal and reasoning. - **[Pages 125–127] Additional Documentation:** Screenshots of emails regarding preferred legal strategy and additional evidence. **General Visual Notes:** All images are at 196–532 PPI, indicating high-quality scans or native screenshots. Seven images across pages 115–117 include soft-mask (transparency) layers, suggesting they may have been composited or edited from original screenshots. No images appear obviously altered at the resolution available; however, the soft-mask layers are worth forensic attention. ### Key People Referenced | Name | Role/Affiliation | Context | |---|---|---| | Matthew David Guertin* | Defendant / Pro Se Federal Plaintiff / Complainant | Author of complaint; defendant in 27-CR-23-1886; plaintiff in 24-cv-02646 | | Bruce M. Rivers* | Criminal Defense Attorney | Subject of ethics complaint; retained Feb 2023; $10,000 retainer; office at 701 Fourth Ave S., Suite 300, Minneapolis | | Michael Biglow* | Court-Appointed Attorney | Emailed first set of discovery photos August 3, 2023; sent letter July 28, 2023 re civil commitment | | Dr. Jill Rogstad* | Rule 20.01 Examiner | March 2023 Rule 20 report listing 104 photographs | | Dr. Michael Robertson* | Psychological Examiner | Conducted August 1, 2023 civil commitment Zoom interview; received same discovery PDF | | Dr. Adam Milz* | Rule 20.01 Examiner | January 3, 2024 Rule 20 exam; Guertin emailed him about discovery fraud | | Joel Fisher | Court-Appointed Civil Commitment Attorney | Guertin emailed him April 22, 2024; replied April 23, 2024 | | Katheryn Cranbrook* | Rule 20 Examiner (Third) | Emailed Guertin August 5, 2024 to schedule third exam; Guertin refused | | Judge Julia Dayton Klein* | Judge, 4th Judicial District | Recused mid-hearing July 16, 2024 after being named in federal suit | | Judge William H. Koch* | Judge, 4th Judicial District | Presided remotely July 16, 2024 after Klein's recusal | | Judge Jay Quam* | Judge, 4th Judicial District | Referenced from earlier proceedings | | Jacqueline Perez* | ACA, Hennepin County | Referenced as prosecutor | | Lea DeSouza | County Attorney | Representing the state in civil commitment proceedings; Guertin says he trusts her | | Nadia Garavito | Court staff | Met during initial civil commitment proceedings; Guertin trusts her | | Paul Debevec* | Researcher / Netflix-Eyeline Studios | Referenced in connection to YouTube videos and USC/military surveillance theory | | Stephan Trojansky* | Patent applicant | Patent application discovered November 8, 2022; alleged infringing technology | | A. Bertrand | OLPR Reception | Signed for USPS delivery at OLPR office September 24, 2024 | | Susan Humiston | MN OLPR Director | Named in OLPR complaint form as contact for ADA accommodations | `*` = previously cataloged in Entity Tracker ### Key Entities / Organizations Referenced - Minnesota Office of Lawyers Professional Responsibility (MN OLPR)* - Hennepin County Attorney's Office* - Fourth Judicial District Court, Hennepin County* - U.S. District Court, District of Minnesota* - Minnesota Court of Appeals* (A24-0780) - 8th Circuit Court of Appeals (24-2662 — new) - Minnetonka Police Department* - Plymouth Police Department* - USC Cinema / USC Institute for Creative Technologies* - US Army Reserves - Netflix* - Eyeline Studios* - InfiniSet, Inc.* - USPTO* - CourtListener.com - Proton Mail / Proton Drive (evidence hosting) - Storj (decentralized evidence hosting) - LinkedIn - ChatGPT (used for legal analysis — Exhibit Z) ### Dates & Deadlines Mentioned - ~2000: Guertin first meets Rivers (pedestrian ticket / "Fire Denny Green" incident) - 2007: Last time Guertin retained Rivers prior to 2023 - April 2020: Guertin returns to Minnesota from Los Angeles due to COVID - November 8, 2022: Guertin discovers Trojansky patent application - November 11, 2022: Guertin calls Rivers at 6:48 AM about patent discovery - January 13, 2023: Guertin emails Rivers seeking patent fraud investigation help - January 21, 2023: Guertin arrested; criminal charges originate - February 20, 2023: Rivers files certificate of representation and Demand for Discovery - March 3, 2023: Guertin's Rule 20 exam meeting with Dr. Rogstad; evidence delivered to Rivers' office - March 2023: Dr. Rogstad's Rule 20 report prepared (lists 104 photos) - May 22, 2023 at 3:13 PM: Rivers makes "powerful people" statement on phone - May 23, 2023: Guertin sends texts to friends documenting Rivers' statement - June 16, 2023: Guertin emails Rivers about YouTube conflict of interest - July 7, 2023: Competency hearing; Rivers fails to present exculpatory evidence - July 13, 2023: First incompetency finding entered - July 20, 2023: Petition for civil commitment filed - July 28, 2023: Guertin receives letter from Biglow re civil commitment - August 1, 2023: Civil commitment hearing; Rivers fails to appear - August 3, 2023: Biglow emails discovery PDF (80 photos) - January 3, 2024: Guertin emails Dr. Milz about fraud before Rule 20 exam - January 5, 2024: First pro se Demand for Discovery filed - January 15, 2024: Rivers tells Guertin "no court" - January 16, 2024: Order entered — "all parties agree to a finding of incompetency" - April 3, 2024: Email requesting Rivers withdraw - April 4, 2024: Motion to Compel Discovery filed with forensic analysis - April 18, 2024: Text requesting Rivers withdraw - April 22, 2024: Email to Joel Fisher about concerns - May 3, 2024: Pro se correspondence re discovery - June 3, 2024: Third Motion to Compel Discovery; Motion for Substitute Counsel; second correspondence - June 6, 2024: Third text request for withdrawal; text re fraudulent discovery - July 8, 2024: Federal civil rights complaint filed - July 15, 2024: Rivers signs for federal summons - July 16, 2024: Review hearing; Klein recusal; Koch remote appearance; USB discovery provided - July 18, 2024: Text exchange on Rivers' new number - July 25, 2024: Email to Rivers addressing missing images in new discovery - August 5, 2024: Cranbrook emails Guertin to schedule third Rule 20 exam - August 7, 2024: Motion for Preliminary Injunction (referenced in Exhibit Z) - August 18, 2024: Corrected Request for Entry of Default filed - August 29, 2024: Entry of Default against Rivers; Rivers calls Guertin (15 min 35 sec) - September 2, 2024: Exhibit Y filed in federal case - September 9, 2024: Exhibit Z filed in federal case - September 13, 2024: Mental health case worker meeting; case worker emails Guertin - September 14, 2024: MN OLPR complaint form date - September 23, 2024: Complaint signed and verified under penalty of perjury; USPS mailed from Chaska - September 24, 2024: Complaint delivered to OLPR (1:57 PM, signed by A. Bertrand); email copy sent (3:19 PM); Exhibit AA filed as Doc. 77 in federal case - October 1, 2024: Scheduled review hearing (continuance requested) ### Forensic Flags & Anomalies 1. **PDF Metadata — Producer chain:** The PDF metadata shows `Producer: PyPDF2; modified using iText® 7.1.6 ©2000-2019 iText Group NV (Administrative Office of the United States Courts; licensed version)` with `ModDate: D:20240924171130-05'00'` (September 24, 2024 at 5:11:30 PM CDT). The iText modification indicates the document was processed through the federal court's CM/ECF filing system after Guertin submitted it. The PyPDF2 base producer suggests Guertin assembled the exhibit using Python-based PDF tools — consistent with his claims throughout the complaint of using custom Python scripts for document preparation. 2. **Soft-mask (transparency) layers on pages 115–117:** Seven images on these pages include alpha/transparency masks. While this could simply result from screenshot compositing (e.g., combining screenshots with transparent backgrounds), it is atypical for standard phone screenshots and warrants closer examination to determine whether images were layered or edited. 3. **Two "Rule 20 Progress Report" entries in docket despite no third exam:** Guertin asserts he never participated in a third Rule 20 exam yet his criminal case docket shows two progress report entries. If accurate, this raises serious questions about what was reported to the court and by whom, and whether these entries are fabricated or based on Cranbrook's report despite non-participation. 4. **Rivers' new phone number:** Rivers changed his phone number between July 16 and July 18, 2024 — immediately after being served with the federal summons. While potentially coincidental, the timing is notable given the litigation context. 5. **Discovery chain-of-custody paradox:** Guertin's argument that the same 28 images he publicly identified as cropped on April 4, 2024 are the same 28 images missing from the July 16, 2024 discovery is logically compelling as a forensic observation: it suggests whoever assembled the July 16 set knew which images had been flagged and removed them rather than providing uncropped originals. This creates a chronological link between the two discovery sets. 6. **Judge Klein mid-hearing recusal:** Klein's recusal mid-hearing on July 16, 2024, apparently without advance notice to counsel or the defendant, is procedurally unusual. Her statement "I submitted my order of recusal yesterday" suggests the written recusal order existed the day before but was not communicated to the parties before the hearing began. 7. **Entry of Default against Rivers (August 29, 2024):** Rivers' failure to respond to the federal complaint despite personally signing for the summons on July 15, 2024 is highly unusual for a practicing attorney, suggesting either strategic choice or deliberate avoidance. 8. **Rivers' dual posture in August 29, 2024 call:** Guertin describes Rivers oscillating between accusing him of incompetence and promising charge dismissal — a posture that is internally contradictory and reflects the inherent conflict of a defense attorney who is simultaneously a defendant in his client's civil rights suit. 9. **"No court" → incompetency stipulation pipeline (January 15–16, 2024):** Rivers telling Guertin "no court" on January 15, followed by an order the next day stating "all parties agree to a finding of incompetency prior to the hearing," constitutes a serious allegation of obtaining consent through misleading statements. This sequence was also flagged in prior filings. 10. **OLPR delivery signed by "A. Bertrand":** The physical complaint was confirmed delivered and signed for, establishing a clear record that the MN OLPR received the complaint. ### Cross-References - **Filing #1** — Motion for Judicial Notice: Contains original patent fraud allegations, discovery discrepancy claims, and background on the Trojansky patent. Guertin's forensic discovery analysis was first detailed there. - **Filing #2** — Affidavit of Fact (May 6, 2024): Contains similar discovery fraud analysis and Rivers misconduct allegations. - **Filing #3** — Affidavit of Fact (Apr 9, 2024): Contains civil commitment background, WCK termination, and Robertson exam details. - **Filing #6** — Affidavit re: Attempted Assassination / Judicial Simulation: Contains Sandra Vongsaphay allegations and Katheryn Cranbrook / Kristen Otte references. - **Filing #7** — 60–90 Day Report context and Cranbrook Rule 20 background. - **Filing #8** — Netflix Whistleblower Part 1: Paul Debevec, Wayback Machine evidence, federal complaint background. - **Filing #9** — Defendant's Motion for Substitute Counsel (June 3, 2024): Directly referenced and included as exhibit within this complaint. Same Strickland v. Washington arguments. - **Filing #10** — 116-page Ethics Complaint reference: This OLPR complaint is either the same document or a related/updated version of the ethics complaint referenced in Filing #10. The September 25, 2024 date in Filing #10's reference is one day after this filing's September 24, 2024 delivery, suggesting Filing #10 may reference the filed version while the instant document is the actual complaint. - **Filing #11** — Declaration of Hao Li: Connected through the patent fraud / USC ICT / Debevec thread. - **Filing #12** — RICO Complaint: Names Rivers as defendant; overlapping allegations regarding discovery fraud, "powerful people" statement, conflicts of interest. - **Federal Case Docket Entries Referenced:** Doc. 4 (summons), Doc. 24 (complaint), Doc. 25 (TRO motion), Doc. 63 (Entry of Default request), Exhibit Y (Doc. filed 9/2/2024), Exhibit Z (Doc. filed 9/9/2024). - **State Case Docket Entries Referenced:** Index #10 (Rivers' Demand for Discovery, 2/20/2023), Index #29 (April 4, 2024 Motion to Compel), Index #30 (evidence of Rivers misconduct), Index #38 (additional evidence), Index #89 (Exhibit A in Court of Appeals). --- ## Filing #14 — Emergency Motion for Stay Pending Appeal (MN Court of Appeals A25-0882) | Field | Detail | |---|---| | Filing # | 14 | | Date Filed | June 18, 2025 (federal docket stamp); document internally dated June 4, 2025 | | Filed By | Matthew David Guertin (Petitioner, Pro Se) | | Document Type | Emergency Motion for Stay Pending Appeal under Minn. R. App. P. 108 | | Case/Court | A25-0882 / Minnesota Court of Appeals (originating: 27-CR-23-1886, Hennepin County District Court, Fourth Judicial District); also docketed as Doc. 115 in federal case 0:24-cv-02646-JRT-DLM (D. Minn.) | | Pages | 46 | | Bates / Doc ID | 115__EXHIBIT_Emergency_Motion_for_Stay_Pending_Appeal_MN_Court_of_Appeals_A25-0882__2025-06-18.pdf; PACER stamp: "CASE 0:24-cv-02646-JRT-DLM Doc. 115 Filed 06/18/25" | ### Comprehensive Summary This is a 46-page pro se emergency motion filed by Matthew David Guertin in the Minnesota Court of Appeals (case A25-0882) seeking an immediate stay of two district court orders entered April 29, 2025 by Judge Sarah Hudleston in case 27-CR-23-1886: (1) an Order for Competency to Proceed (Rule 20.01 evaluation — the fourth such order in the case), and (2) an Order Appointing Forensic Navigator. The motion was also filed as an exhibit (Doc. 115) in Guertin's federal civil rights case 0:24-cv-02646-JRT-DLM on June 18, 2025, though it is internally dated and signed June 4, 2025. Guertin seeks a stay pending appellate review, arguing that all four factors under Minn. R. Civ. App. P. 108, subd. 2 favor relief. ### Core Constitutional and Procedural Arguments (Sections I–II): Guertin contends the April 29 orders are unlawful and retaliatory. He argues the district court had no genuine, fact-based doubt about his competency under Minn. R. Crim. P. 20.01 and the Dusky v. United States standard. He asserts that Judge Hudleston ordered a fourth Rule 20 exam based solely on the content of his pro se April 16 Motion to Dismiss (Add. 232–281) — specifically characterizing his fraud allegations as "paranoia and conspiracy theories" — rather than on any clinical evidence, courtroom behavior, or medical opinion. Guertin argues this is an impermissible "content-based" competency referral that punishes advocacy and violates Due Process, the Sixth Amendment right to present a defense, and the First Amendment right to petition. Guertin cites the judge's own words from the April 29 hearing where she stated her decision was "based on what I saw that you filed in your motion to dismiss… as well as looking back into your file" (Add. 21–22), and notes a May 30, 2025 written order (Index 205) confirmed this rationale. He argues no objective evidence — no disorientation, no clinical report, no suicide attempt, no inability to interact with counsel — supported the referral. He further argues that the April 29 orders cause "structural prejudice" by (a) chilling core advocacy rights by using a defendant's legal brief as grounds to question sanity, and (b) automatically suspending proceedings and exposing him to renewed risk of civil commitment. ### Mischaracterization of Motion to Dismiss (Section II-B): Guertin alleges Judge Hudleston mischaracterized his Motion to Dismiss during the April 29 hearing in several respects: claiming the motion was "over 50 pages" (it was exactly 50); reducing it to a "big conspiracy with Netflix" when Netflix appeared only in one section (Section VI, Add. 262–267), while the remainder addressed discovery fraud, Brady violations, forged docket items, and suppressed Rule 20 reports; taking a handwritten note out of context (a note posed as an illustrative question during a 2024 civil commitment scheme); and characterizing the motion as containing "no defense to criminal liability" when the Prayer for Relief was strictly procedural (dismissal for discovery manipulation, Brady/Trombetta violations, and Rule 20 abuse). ### Prosecutorial Misconduct and Perjury (Section II-C): Guertin alleges that Assistant County Attorney Mawerdi Hamid committed prosecutorial misconduct and perjury across three hearings. He documents a specific contradiction: during the March 5, 2025 contested competency hearing, Hamid acknowledged the discovery fraud by asking "Yeah, so you said that these photos have a problem; is that correct?" (Add. 168), and then quizzed Guertin on how he would react when photos were introduced in court. But at the April 29 hearing, Hamid stated under oath: "No, Your Honor. The state is not aware of any of that information" and "the state is not aware of any manipulation of the evidence" (Add. 15). Guertin characterizes this as prima facie perjury and a Brady violation. He also documents: Hamid's attempt to invoke Rule 601 to bar anyone previously deemed incompetent from testifying (conceding she had no legal authority when challenged by Judge Koch); Hamid's refusal to call Dr. Cranbrook for cross-examination while relying on her hearsay report; and Hamid's joint effort with defense counsel to bar Guertin's pro se filings as "not properly before the Court" at the April 17 hearing. ### Defense Counsel Obstruction (Section II-D): Guertin alleges extensive ineffective assistance and adversarial conduct by court-appointed counsel Emmett Donnelly, organized into six categories: (1) abandonment of confrontation and hearsay objections by refusing to call or cross-examine Dr. Cranbrook; (2) contradictory stance on doctored photographs — initially presenting them as the defense's core position at the March 5 hearing, then urging the court not to enter those same exhibits at the close of the hearing; (3) refusal to file or litigate Guertin's Motion to Dismiss and evidentiary hearing request; (4) facilitating competency reversal by stating he didn't agree with Judge Koch's order finding Guertin competent; (5) steering toward plea negotiations against Guertin's objectives; and (6) email exchanges from January 2025 (Add. 297–320) proving Guertin competently laid out legal strategy that counsel refused to implement, forcing Guertin to act pro se, which was then used as evidence of incompetence. ### Discovery Fraud and "Fruit of the Poisonous Tree" (Section II-E): Guertin invokes Mapp v. Ohio and the "fruit of the poisonous tree" doctrine, arguing that if prior competency determinations were influenced by false evidence or manipulated discovery, those determinations cannot be relied upon. He contends all three prior Rule 20 exams are invalidated because they were based on fraudulent discovery materials. He documents four different sets of discovery materials, with "Set D" (provided February 13, 2025 by defense counsel Raissa Carpenter and Emmett Donnelly) being the key set proving fraud. He asserts the prior Rule 20 exam reports actually used his discovery fraud claims as evidence supporting a diagnosis and recommendation for forced medication, creating a circular trap. Guertin traces the discovery fraud issue to its origin: his January 5, 2024 Demand or Request for Discovery (Index 22), and documents his persistent pro se efforts across multiple courts (A24-0780 in MN Court of Appeals; 24-cv-2646 in MN Federal District Court; 24-2662 in the 8th Circuit). He claims the fraud is proven by lighting and shadow analysis of photographs that were "squished" horizontally to force them into a uniform aspect ratio, with fraudulent metadata assigned to the images in the new folder of 104 images within Set D. He states his defense counsel never replied to his February 20, 2025 email titled "My Discovery Fraud Analysis is Complete | URGENT Action is Required" (Add. 110–112). ### April 28, 2025 Evidence Dump (Section III): Guertin addresses his filing of 50 submissions (5,435 individual PDF pages) into his case docket on April 28, 2025 (Index 135–184), which he argues is being used as evidence of incompetency when it actually constitutes evidence of large-scale judicial fraud. He states he provided a "Docket Index Map" (Add. 684–686) to Judge Hudleston during the April 29 hearing, but her May 30, 2025 order (Index 205) continues to cite these filings as supporting her Rule 20 order rather than addressing their substantive content. He describes a key finding: "Exhibits L1–L5, Finding of Incompetency and Orders" (Index 143–144, 146, 149, 156) reveal that his January 17, 2024 "Finding of Incompetency and Order" (Add. 371–374) appears to be an identical clone replicated across all of the alleged synthetic cases, with only text varied to match the purported defendants. ### Digital Forensic Analysis (Section IV): This section constitutes the most technically detailed portion of the motion. Guertin describes an extensive digital forensic analysis of MCRO documents he downloaded April 29–30, 2024, which he claims has digitally proven thousands of fake MCRO case filings, dockets, and defendants. Key technical elements include: - **SHA-256 Hashing:** Guertin explains the SHA-256 algorithm and its use in digital forensics, citing Federal Rules of Evidence 902(14) (2017 amendment) on self-authentication of electronic evidence via hash values. He argues his resulting datasets — CSV tables containing thousands of rows identifying duplicate judicial timestamps (371 duplicates), judicial signatures (1,183 duplicates), and returned mail filings (40 duplicates) — "self-authenticate" based on the outputs alone, because producing them would have been impossible without properly carrying out the forensic process. - **Digital Signature Verification:** A sweep of all 3,629 PDFs shows 3,613 (99.6%) bear the original Hennepin County Courts X.509 SHA-256 digital certificate. Only 16 files lacked a signature (listed in 08_MCRO_files-with-no-signature.csv). Every signed PDF's internal signature timestamp matches the timestamp in its filename and download log, closing the chain of custody. - **May 3, 2024 Affidavit Verification:** Guertin cross-checks figures from his sworn affidavit (Add. 438–457) against the current corpus. The 163 criminal dockets and defendants matched exactly; year-stratified tallies confirmed; all filing-type counts matched one-for-one (e.g., 79 "Comp Order for Detention," 488 Rule 20 evaluation orders, 130 Findings of Incompetency). The sole discrepancy was the aggregate file count: 3,556 reported vs. 3,629 verified (73 PDFs, ~2% undercount in summation). ### Synthetic Docket Scheme Linked to Petitioner (Section V): - **Attorney-Status Anomaly (Section V-A):** Guertin presents a statistical analysis of attorneys Judith Cole and Thomas Prochazka. Cole appears in 53 dockets, marked "Active" in 52/53 — the sole "Inactive" entry is Guertin's case. Prochazka appears in 7 dockets, marked "Inactive" in 6/7 — the sole "Active" entry is again Guertin's case. The joint probability of both anomalies coinciding in case 27-CR-23-1886 is calculated at 1/371 ≈ 0.27%. Source: 04_CASE_listed-attorneys.csv. - **"Mother's Letter" Event (Section V-B):** Guertin presents what he calls "smoking gun" evidence of active obstruction. On a single day, a fake "inmate" letter was filed in synthetic case 27-CR-23-2480 (Sandra Vongsaphay) at 2:03 PM; Michelle Guertin's genuine letter was filed in Guertin's real case at 2:10 PM; Judge Julia Dayton Klein inserted an "Order Denying Petition to Proceed Pro Se" into Guertin's docket at 2:28 PM (18 minutes after the real letter, before any responses, while Guertin's case was assigned to a different judge); and Clerk Lee Cuellar issued near-identical boilerplate responses to both letters at 4:38 PM and 4:42 PM respectively. SHA-256 analysis of both response-letter PDFs shows court-header and letterhead images are byte-for-byte identical (hashes debcc04a…d764a6 and f609be80…15a1eee), not found in any other document in a 3,601-document dataset (Add. 567–568). The Vongsaphay letter reportedly displays mechanically uniform "handwriting" while the genuine Guertin letter shows natural pen-stroke variation. Guertin argues this proves mail interception and forgery violating 18 U.S.C. § 1702 and Minn. Stat. § 609.625. - **Alisha Nehring Metadata Trail (Section V-C):** Guertin documents a June 14, 2023 "Order for Continuance" (MCRO Index 16 for case 27-CR-23-1886) whose PDF metadata contains: Title = "Contested Competency for Adrian Wesley (incompetent) (doctors disagree)"; Author/Creator = "Nehring, Alisha"; Company = "MN Judicial Branch." These fields are locked inside the PDF's certified digital signature. Nehring is identified as a Minnesota Department of Health attorney with no courtroom role in Guertin's prosecution. Of Nehring's 27 filings, this is the only one with "MN Judicial Branch" as Company, and the only one signed by Judge Klein (the other 26 carry Judges Janzen, Lamas, or Browne). Three of the 27 Nehring filings belong to "Adrian Michael Wesley" (synthetic defendant), filed May 8, 2020 under three docket numbers. Guertin also identifies a 23-docket overlap between Nehring and "Amanda Burg" (described as a "Saint Peter State Hospital" liaison), which he argues indicates a single production pipeline. ### Rule 108 Four-Factor Analysis (Section VI): 1. **Likelihood of Success on the Merits:** Guertin argues the April 29 orders flout black-letter law. Judge Koch found him competent on April 3, 2025 after a full evidentiary hearing. Nothing between April 3 and April 29 provided new facts — he merely filed a motion and appeared in court, where Judge Hudleston called him "extremely intelligent" and noted "detailed legal memoranda." Re-opening competency on that record contravenes Bauer's objective-evidence requirement. He frames the order as "content-based punishment of advocacy" under Dusky. He argues the navigator order is independently unlawful because forensic navigators may only be assigned after adjudication of incompetency under Minn. Stat. § 611.361, subd. 1(a), and its blanket authority to seize medical, employment, Social Security, and educational records "notwithstanding any privacy laws" constitutes an unreasonable search under Camara v. Municipal Court. 2. **Irreparable Injury:** Forced psychiatric intrusion compels disclosure of intimate thoughts; navigator order triggers irreversible data-harvesting of medical, Social Security, employment, and educational records; risk of involuntary commitment and forced medication (citing Jarvis v. Levine, 418 N.W.2d 139); continued tolling of speedy trial and Faretta rights (29+ months without trial); no adequate legal remedy (no monetary damages available against State for constitutional injuries). 3. **Lack of Harm to State:** Status quo frozen for 29+ months; the Rule 20 reset was court-initiated (no State motion or new evidence); navigator data sweep serves no trial function; Guertin has appeared at every hearing and poses no public safety risk. 4. **Public Interest:** Halting a procedure rooted in alleged fraud preserves judicial confidence; protects integrity of Minnesota's competency-reform regime by preventing weaponization of forensic navigator resources against someone the court itself called "extremely intelligent"; encourages robust exposure of governmental misconduct; provides systemic guidance on whether content-based skepticism can trigger competency proceedings. ### Prayer for Relief (Section VII): Guertin requests: (1) immediate stay of both April 29 orders; (2) direction that no steps be taken to implement the orders (no psychiatric exams, no forensic navigator appointment, no records collection); (3) preservation of pre-April 29 status quo including existing bail conditions; (4) expedited appeal via accelerated briefing or Special Term calendar; and (5) any further relief the court deems just. ### Proposed Order (Section VIII): A proposed order granting the stay with no bond or security required. ### Certificate of Document Length (final page): Certifies the document is 11,943 words, produced in 13-point proportional type using LibreOffice Writer for Linux. ### Legal Issues & Arguments Raised - Fourth Rule 20.01 competency evaluation ordered without new factual basis — contravenes Dusky v. United States, 362 U.S. 402 (1960) - Content-based punishment of advocacy: competency referral triggered by content of pro se Motion to Dismiss rather than clinical evidence - Violation of Pate v. Robinson, 383 U.S. 375 (1966) — substantial evidence requirement for competency hearings - Structural Faretta violation: competency pretext extinguished unequivocal demand to proceed pro se (Faretta v. California, 422 U.S. 806 (1975); State v. Richards, 456 N.W.2d 260 (Minn. 1990)) - Chilling of First Amendment right to petition and Sixth Amendment right to present a defense - Prosecutorial perjury and Brady/Giglio violation by ACA Hamid (contradictory sworn statements on discovery fraud awareness) - Confrontation Clause violations (reliance on Dr. Cranbrook hearsay report without cross-examination; Bullcoming v. New Mexico, 564 U.S. 647; Melendez-Diaz v. Massachusetts, 557 U.S. 305; State v. Caulfield, 722 N.W.2d 304) - Ineffective assistance of counsel under Strickland v. Washington, 466 U.S. 668 (1984) and United States v. Cronic, 466 U.S. 648 (1984) - Violation of Minn. R. Prof. Conduct 1.2(a) and 1.3 (client controls objectives; duty of diligence) - "Fruit of the Poisonous Tree" doctrine (Mapp v. Ohio, 367 U.S. 643) applied to competency evaluations tainted by fraudulent discovery - Forensic navigator appointment unlawful absent adjudication of incompetency (Minn. Stat. § 611.361, subd. 1(a)) - Navigator order's blanket records authority constitutes unreasonable search under Camara v. Municipal Court, 387 U.S. 523 (1967) - Fraud on the court doctrine (Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238 (1944); Chambers v. NASCO, Inc., 501 U.S. 32 (1991)) - Mail interception and forgery (18 U.S.C. § 1702; Minn. Stat. § 609.625) - Brady/Napue violations regarding suppression of true provenance of ghost-written orders - Federal Rules of Evidence 902(14) self-authentication of electronic evidence via SHA-256 hashing - Speedy trial violation (29+ months without resolution) - Involuntary medication requires prior judicial approval (Jarvis v. Levine, 418 N.W.2d 139 (Minn. 1988)) - Minn. R. Civ. App. P. 108 four-factor stay analysis ### Factual Allegations & Key Assertions - Judge Hudleston ordered a fourth Rule 20 competency exam on April 29, 2025, based solely on the content of Guertin's April 16, 2025 pro se Motion to Dismiss - Judge Koch found Guertin competent to proceed on April 3, 2025 after a full evidentiary hearing - Only 26 days elapsed between the competency finding and the new Rule 20 order, with no intervening clinical evidence - Judge Hudleston described Guertin as "extremely intelligent" and noted "detailed legal memoranda" yet characterized his claims as "not rational" - Judge Hudleston's May 30, 2025 written order (Index 205) confirmed the Motion to Dismiss as the basis for the Rule 20 referral - ACA Hamid acknowledged discovery photo problems on March 5, 2025 then denied awareness on April 29, 2025 (alleged perjury) - Hamid attempted to bar Guertin from testifying under Rule 601, conceding no legal authority when challenged - Defense counsel Donnelly presented discovery fraud as core defense position then reversed at end of same hearing - Donnelly refused to file Guertin's Motion to Dismiss, stating "we do not intend to bring it up for a hearing" - Donnelly stated he disagreed with Judge Koch's competency finding - Donnelly steered toward plea negotiations against Guertin's stated objectives - January 2025 email exchanges (Add. 297–320) show Guertin competently laying out legal strategy that counsel refused to implement - Four different sets of discovery materials provided over the case; "Set D" (February 13, 2025) proved the fraud - 104 images in Set D contained fraudulent metadata; lighting and shadow analysis proves photos were horizontally compressed ("squished") to uniform aspect ratio - Guertin's February 20, 2025 email to defense counsel titled "My Discovery Fraud Analysis is Complete | URGENT Action is Required" (Add. 110–112) was never answered - Guertin filed 50 submissions (5,435 pages) into his docket on April 28, 2025 (Index 135–184) containing MCRO evidence - "Finding of Incompetency and Order" documents across synthetic cases are identical clones of Guertin's January 17, 2024 order (Add. 371–374) - Digital forensic analysis of 3,629 MCRO PDFs: 3,613 (99.6%) bear original Hennepin County digital signatures - 371 duplicate judicial timestamp SHA-256 hashes identified - 1,183 duplicate judicial signature SHA-256 hashes identified - 40 duplicate "Returned Mail" filing SHA-256 hashes identified - May 3, 2024 affidavit figures validated: 163/163 case-defendant matches; all filing-type counts exact; total file count corrected from 3,556 to 3,629 - Attorney Judith Cole: "Inactive" only in Guertin's case among 53 dockets (98.1% "Active" elsewhere) - Attorney Thomas Prochazka: "Active" only in Guertin's case among 7 dockets (85.7% "Inactive" elsewhere) - Joint probability of both anomalies in same case: 1/371 ≈ 0.27% - "Mother's Letter" event: Michelle Guertin's genuine letter and a fake "inmate" letter (Sandra Vongsaphay case 27-CR-23-2480) filed minutes apart; near-identical clerk responses 4 minutes apart; Judge Klein inserted an order into Guertin's docket between the letter and responses while case was assigned to a different judge - SHA-256 hashes of court-header images match across both response letters (debcc04a…d764a6 and f609be80…15a1eee), unique in 3,601-document dataset - June 14, 2023 "Order for Continuance" (MCRO Index 16) in Guertin's case has PDF metadata: Title referencing "Adrian Wesley (incompetent)"; Author "Nehring, Alisha"; Company "MN Judicial Branch" - Alisha Nehring identified as Minnesota Department of Health attorney with no courtroom role - Nehring authored 27 filings; 3 belong to Adrian Michael Wesley (synthetic defendant); 23-docket overlap with Amanda Burg - Guertin has been at liberty for 29+ months, appeared at every hearing, poses no public safety risk - Guertin successfully completed stayed order of civil commitment granted August 2024 - Case has been stalled by three prior Rule 20 cycles - Document prepared using LibreOffice Writer for Linux; 11,943 words ### Procedural Posture This emergency motion sits at the intersection of three proceedings: 1. **State criminal case 27-CR-23-1886** (Hennepin County District Court, Judge Hudleston): Guertin was found competent by Judge Koch on April 3, 2025. Judge Hudleston then ordered a fourth Rule 20 exam and appointed a forensic navigator on April 29, 2025. Guertin had filed an April 16 Motion to Dismiss (Add. 232–281) and an April 21 Petition to Proceed Pro Se (Add. 200–231). On May 30, 2025, Judge Hudleston entered a written order (Index 205) standing by the April 29 orders. 2. **State appellate case A25-0882** (MN Court of Appeals): Guertin filed this emergency motion seeking a stay of the April 29 orders pending appeal. He had previously filed a May 7, 2025 Emergency Motion for Stay and Vacate in the district court. 3. **Federal civil rights case 0:24-cv-02646-JRT-DLM** (D. Minn.): This motion was docketed as Doc. 115 (exhibit) on June 18, 2025. The motion responds to: (a) the April 29, 2025 competency and navigator orders; (b) Judge Hudleston's May 30, 2025 written order (Index 205); and (c) the broader 29-month procedural history of repeated Rule 20 cycles. ### Exhibit / Attachment Inventory The motion references an extensive addendum structure, though the addendum volumes themselves are not included in this PDF. Key addendum references include: - **Add. 1–3:** April 29, 2025 Order for Competency to Proceed (Rule 20.01) - **Add. 4–5:** April 29, 2025 Order Appointing Forensic Navigator - **Add. 9:** April 29 hearing transcript excerpt (Judge Hudleston's statements) - **Add. 10, 13:** April 29 hearing transcript excerpts (mischaracterization of Motion to Dismiss) - **Add. 15–16:** April 29 hearing transcript excerpts (discovery fraud acknowledgment) - **Add. 17–18, 23:** April 29 hearing transcript excerpts (Docket Index Map provided) - **Add. 20–22:** April 29 hearing transcript excerpts (competency basis stated) - **Add. 33–66:** May 7, 2025 Emergency Motion for Stay and Vacate - **Add. 34:** Doubtful question of law under Minn. R. Crim. P. 28.03 - **Add. 45:** Fruit of the poisonous tree argument - **Add. 53–58:** Discovery fraud argument sections (Sets A–D; fruit of poisonous tree; forced medication) - **Add. 99–109:** Discovery materials analysis (Set D) - **Add. 110–112:** February 20, 2025 email to defense counsel re: discovery fraud analysis - **Add. 117–177:** March 5, 2025 contested competency hearing transcript - **Add. 120–127:** Defense counsel and prosecution statements at March 5 hearing - **Add. 129–136, 151–153, 155–157, 167–172:** March 5 hearing — discovery fraud discussion - **Add. 143–159:** March 5 hearing — Guertin's testimony demonstrating competency - **Add. 178–181:** April 3, 2025 Order finding Petitioner competent to proceed - **Add. 182–199:** Motive-related materials (referenced as "extraordinary motives") - **Add. 200–231:** April 21, 2025 Petition to Proceed Pro Se - **Add. 232–281:** April 16, 2025 Motion to Dismiss (the "trigger" document) - **Add. 282–296:** April 17, 2025 hearing transcript - **Add. 297–320:** January 2025 email exchanges with defense counsel - **Add. 315:** February 13, 2025 discovery provision reference - **Add. 371–374:** January 17, 2024 Finding of Incompetency and Order - **Add. 438–457:** May 3, 2024 Affidavit and MCRO Data Analysis - **Add. 458–462:** May 15, 2024 Petition for Discretionary Review (A24-0780) - **Add. 463–466:** May 15, 2024 Supplementary Addendum Information (A24-0780) - **Add. 516–555:** Digital forensic proof of MCRO fraud - **Add. 544–555:** Judicial timestamp and signature duplicate analysis - **Add. 549–555:** "Forensic Analysis of Metadata Anomalies in Fraudulent Competency Orders" - **Add. 556–559:** "Fraudulent Incompetency Order Template Reused in Guertin's Case" - **Add. 560–572:** "Mother's Letter" document-cloning analysis - **Add. 562–566:** Mother's Letter timeline, judicial order, and forensic handwriting analysis - **Add. 567–568:** SHA-256 hash analysis of response-letter PDFs - **Add. 573–587:** Duplicate "Returned Mail" filings analysis - **Add. 684–686:** Docket Index Map (Index 141–184) - **Add. 695–700:** "Master Evidence URL Directory" - **Add. Vol VII–XV:** Referenced as containing evidence of "judicial fraud" - **Index 205:** Judge Hudleston's May 30, 2025 written order (post-filing of appellate case) ### External URLs Referenced (evidence hosted on Storj/Substack): - Index 122 (Exhibits A–E): https://matt1up.substack.com/api/v1/file/5f8e553a-60db-405b-ac5c-2c1c799b91a2.pdf - Index 123 (Exhibits F–J): https://matt1up.substack.com/api/v1/file/53f9eeec-0495-43df-9336-6cbce7d02fe4.pdf - Index 124 (Exhibits K–L): https://matt1up.substack.com/api/v1/file/8697f857-ef4a-4597-b639-d20d1ad71026.pdf - Index 22 (Jan 5, 2024 Demand for Discovery): https://matt1up.substack.com/api/v1/file/08b640d4-75e6-4fd3-b092-b0715ce143b4.pdf - Index 29 (Apr 4, 2024 Motion to Compel): https://matt1up.substack.com/api/v1/file/96a5de26-014f-459e-b77d-50eeac400400.pdf - Index 149 (Exhibit L(4)): https://matt1up.substack.com/api/v1/file/63c7c786-c43b-4797-8d01-6a95fc3040c4.pdf - Exhibit Y (24-cv-2646): https://storage.courtlistener.com/recap/gov.uscourts.mnd.216796/gov.uscourts.mnd.216796.74.0.pdf - A24-0780 petition: https://storage.courtlistener.com/recap/gov.uscourts.mnd.216796/gov.uscourts.mnd.216796.13.0.pdf - 24-cv-2646 docket: https://www.courtlistener.com/docket/68925331/guertin-v-hennepin-county/ - 24-2662 docket: https://www.courtlistener.com/docket/69060054/matthew-guertin-v-hennepin-county/ - 371 judicial timestamp duplicates CSV: https://link.storjshare.io/raw/jw7oudujbk5wn6vtfa7ijaqxwd7a/evidence/Judicial-Signatures-and-Timestamps/SHA-256_371-judicial-timestamp-duplicates.csv - 1,183 judicial signature duplicates CSV: https://link.storjshare.io/raw/jwox2hvjse4enc7sz64ezg5f3c6a/evidence/Judicial-Signatures-and-Timestamps/SHA-256_1183-judicial-officer-signature-duplicates.csv - 40 returned mail duplicates CSV: https://link.storjshare.io/raw/jxufdtgvrnu2pcl46dt7hhhqs45a/evidence/USPS-Mail-Fraud/SHA-256_returned-mail_scans_duplicate-hash.csv - Bookmarked PDF Addendum Volumes: https://link.storjshare.io/s/jxbbwkxbd6tjth3x2wfkvqg6i6bq/evidence/Add/ - MCRO evidence folder: https://link.storjshare.io/s/jxhmrcnhsa2tdo5xfusewkoadnqq/evidence/MCRO/ - Alisha Nehring evidence folder: https://link.storjshare.io/s/jvkciogrsybpscbqvmrrv426zhfa/evidence/Alisha-Nehring/ - Rule 902 reference: https://www.rulesofevidence.org/fre/article-ix/rule-902/ - SHA-256 reference: https://komodoplatform.com/en/academy/sha-256-algorithm/ - Hash functions in forensics: https://blog.daisie.com/hash-functions-in-digital-forensics-best-practices/ - 04_CASE_listed-attorneys.csv: https://link.storjshare.io/raw/jutxluotoect3hstmiq4nsrutmta/evidence/CASE/04_CASE_listed-attorneys.csv ### Visual Evidence Inventory - **[Pages 1–46] PACER/ECF Stamp:** Every page bears the footer stamp "CASE 0:24-cv-02646-JRT-DLM Doc. 115 Filed 06/18/25 Page [X] of 46" — indicates this PDF was filed into the federal docket via CM/ECF and stamped accordingly. Consistent formatting across all pages; no anomalies in page numbering or stamp placement. - **[Page 1] Caption/Header:** Dual-column format with case caption (A25-0882, MN Court of Appeals) on the right and document title on the left. Standard appellate motion format. - **[Page 30] Table:** Timeline table titled "Duplicated Timeline Proves Real-Time Court Manipulation" showing four timestamped events (2:03 PM, 2:10 PM, 2:28 PM, 4:38 PM, 4:42 PM) relating to the "Mother's Letter" event. Rendered as text within the PDF, not as an image. - **[Page 32] Metadata Table:** Four-column table displaying PDF metadata fields for the Alisha Nehring "Order for Continuance" (Title, Author/Creator, Company, File Name) with evidentiary impact column. Rendered as text. - **[Page 28] Filing Type Verification Table:** Seven-row table comparing affidavit counts versus current forensic counts for various MCRO filing types. All values match. Rendered as text. - **[Page 44] Signature Block:** Electronic signature "/s/ Matthew D. Guertin" with address at 4385 Trenton Ln. N 202, Plymouth, MN 55442; telephone 763-221-4540; email MattGuertin@protonmail.com; website www.MattGuertin.com. Same signature block repeated on page 46. - **[Page 46] Certificate of Document Length:** Second signature block identical to page 44. - **No photographs, scanned images, diagrams, screenshots, redactions, or handwritten annotations detected.** Document appears to be a native-digital PDF (not scanned). Produced with "iText-Core-7.2.3" per PDF trailer; author claims LibreOffice Writer for Linux. **Note on PDF generation:** The PDF trailer identifies the producer as "iText-Core-7.2.3," which is a Java-based PDF library. This is noteworthy because Guertin's certificate states the document was "prepared using LibreOffice Writer for Linux." This discrepancy may indicate the document was authored in LibreOffice but then processed through an iText-based pipeline (e.g., for CM/ECF filing or Substack upload), or it may warrant further investigation. ### Key People Referenced - **Matthew David Guertin*** — Petitioner/Defendant, Pro Se filer - **Sarah Hudleston*** — Judge, Fourth Judicial District (entered April 29 orders; entered May 30 written order at Index 205) - **William H. Koch*** (referenced as "Judge Koch") — Judge, Fourth Judicial District (presided over March 5 hearing; found Guertin competent April 3, 2025) - **Mawerdi Hamid*** (referenced as "Mawerdi Ahmed Hamid" in prior filings) — Assistant County Attorney, Hennepin County (alleged perjury and prosecutorial misconduct) - **Emmett Donnelly*** — Defense counsel, Hennepin County Public Defender's Office (alleged ineffective assistance and obstruction) - **Raissa Carpenter*** — Defense counsel, Hennepin County Public Defender's Office (provided Set D discovery Feb 13, 2025) - **Dr. Katheryn Cranbrook*** (referenced as "Dr. Cranbrook") — Rule 20 examiner (report relied upon via hearsay) - **Julia Dayton Klein*** — Judge, Fourth Judicial District (inserted order into Guertin's docket during Mother's Letter event; signed the Nehring "Order for Continuance") - **Jay Quam*** — Judge, Fourth Judicial District (case assigned to at time of Mother's Letter event) - **Lee Cuellar*** — Judicial Clerk (issued twin boilerplate responses in Mother's Letter event) - **Bruce Rivers*** — Former defense counsel (referenced re: prior refusal to provide discovery) - **Dr. Adam Milz*** — Author of January 3, 2024 Rule 20 report (referenced indirectly) - **Michelle Guertin** — Petitioner's mother (author of genuine letter in Mother's Letter event) - **Sandra P. Vongsaphay*** — Alleged synthetic defendant, Case 27-CR-23-2480 (fake inmate letter) - **Adrian Michael Wesley*** — Alleged synthetic defendant, 2017 cases (referenced in Nehring metadata) - **Alisha Nehring*** — Minnesota Department of Health attorney (metadata author of 27 filings including Guertin's Order for Continuance) - **Amanda Burg** — Listed as "Saint Peter State Hospital" liaison; appears as metadata author in dozens of mental-health transport orders; 23-docket overlap with Nehring - **Judith L. Cole*** — Senior ACA, Hennepin County (statistical anomaly: "Inactive" only in Guertin's case) - **Thomas Prochazka** — Attorney (statistical anomaly: "Active" only in Guertin's case) - **Kerry Meyer** — Chief Judge (listed as presider in Adrian Wesley dormant dockets; implicated via 7 duplicate signatures) - **Lisa K. Janzen*** — Judge, Fourth Judicial District (18 of 27 Nehring filings carry her signature) - **Carolina A. Lamas*** — Judge, Fourth Judicial District (5 of 27 Nehring filings carry her signature) - **Judge Browne** — Judge, Fourth Judicial District (3 of 27 Nehring filings carry her signature; referenced in prior filings) ### Key Entities / Organizations Referenced - Minnesota Court of Appeals (A25-0882)* - Hennepin County District Court, Fourth Judicial District* - U.S. District Court, District of Minnesota (0:24-cv-02646-JRT-DLM)* - U.S. Court of Appeals, Eighth Circuit (24-2662)* - Hennepin County Attorney's Office* - Hennepin County Public Defender's Office* - Minnesota Department of Health (Alisha Nehring affiliation)* - Saint Peter State Hospital (Amanda Burg affiliation) - Minnesota Judicial Branch (Company field in Nehring metadata)* - National Security Agency (NSA) — referenced as developer of SHA-256 - Hennepin County Courts — referenced as issuer of X.509 digital certificates on MCRO PDFs - MCRO (Minnesota Court Records Online)* — source of 3,629 PDFs analyzed - Storj — cloud storage platform hosting Guertin's evidence files - Substack (matt1up.substack.com)* — hosting Guertin's exhibit PDFs - CourtListener* — hosting federal docket information ### Dates & Deadlines Mentioned - **January 24, 2023** — Case 27-CR-23-1886 inception (referenced as "January of 2023") - **June 14, 2023** — Date of Nehring "Order for Continuance" (MCRO Index 16) - **January 5, 2024** — Guertin's first pro se filing: Demand or Request for Discovery (Index 22) - **January 17, 2024** — Finding of Incompetency and Order (the "clone" template, Add. 371–374) - **April 4, 2024** — Motion to Compel Discovery (Index 29) - **April 29–30, 2024** — Guertin downloaded MCRO documents - **May 3, 2024** — Sworn affidavit re: MCRO data analysis (Add. 438–457) - **May 15, 2024** — Petition for Discretionary Review (A24-0780, Add. 458–462) - **May 8, 2020** — Date of three Adrian Wesley filings by Nehring - **August 2024** — Stayed order of civil commitment granted (Guertin later completed terms) - **January 2025** — Email exchanges between Guertin and defense counsel (Add. 297–320) - **February 13, 2025** — "Set D" discovery provided by defense counsel - **February 20, 2025** — Guertin's email to counsel: "My Discovery Fraud Analysis is Complete" - **February 28, 2025** — Guertin's pro se filings with Exhibits A–L (Index 122–124) - **March 5, 2025** — Contested competency hearing before Judge Koch (Add. 117–177) - **April 3, 2025** — Order finding Guertin competent to proceed (Add. 178–181) - **April 16, 2025** — Motion to Dismiss filed (Add. 232–281) - **April 17, 2025** — Omnibus hearing before Judge Hudleston (Add. 282–296) - **April 21, 2025** — Petition to Proceed Pro Se (Add. 200–231) - **April 28, 2025** — 50 filings submitted into docket (Index 135–184; 5,435 pages) - **April 29, 2025** — Hearing; Order for Competency to Proceed and Order Appointing Forensic Navigator entered (Add. 1–5) - **May 7, 2025** — Emergency Motion for Stay and Vacate filed in district court (Add. 33–66) - **May 30, 2025** — Judge Hudleston's written order (Index 205) confirming April 29 orders - **June 4, 2025** — Date of this emergency motion (internal dating and signature) - **June 18, 2025** — Date filed in federal docket as Doc. 115 ### Forensic Flags & Anomalies 1. **iText vs. LibreOffice discrepancy:** PDF trailer identifies producer as "iText-Core-7.2.3" but Certificate of Document Length states document was "prepared using LibreOffice Writer for Linux." This may reflect CM/ECF processing or intermediate conversion. Minor flag — likely explainable but noted for completeness. 2. **Dual-court filing:** Document is an MN Court of Appeals motion (A25-0882) but was filed as an exhibit in the federal case (Doc. 115, 0:24-cv-02646-JRT-DLM). The internal date (June 4, 2025) precedes the federal filing date (June 18, 2025) by two weeks. This suggests the federal filing was done to create a parallel record. 3. **29+ months without trial:** The criminal case has been pending since January 2023 with no trial date, stalled by three (now four) Rule 20 competency cycles. This is procedurally extraordinary. 4. **Competency "ping-pong":** Judge Koch found Guertin competent on April 3, 2025; Judge Hudleston ordered a new exam 26 days later on April 29, 2025, with no new clinical evidence cited — only the content of a pro se motion. This rapid reversal between two judges is procedurally unusual. 5. **Judge Hudleston's contradictory characterizations:** She described Guertin as "extremely intelligent" and capable of "detailed legal memoranda" while simultaneously characterizing his arguments as "not rational" and evidencing "paranoia and conspiracy theories." These characterizations appear facially inconsistent. 6. **ACA Hamid's contradictory statements:** March 5 acknowledgment of photo problems vs. April 29 denial of any awareness of manipulation — presented as prima facie perjury. This is a critical forensic flag that warrants comparison of both hearing transcripts. 7. **Defense counsel 180-degree reversal:** Donnelly presented discovery fraud as the core defense position at the start of the March 5 hearing, then urged the court not to enter the same exhibits at the hearing's close. This within-hearing contradiction is highly unusual. 8. **Mother's Letter synchronized filing pattern:** Four events across two cases within a single afternoon (2:03 PM, 2:10 PM, 2:28 PM, 4:38/4:42 PM), involving a judge not assigned to Guertin's case inserting an order between receipt of a letter and clerk responses, with byte-for-byte identical header images in response PDFs. If the SHA-256 matches are accurate, this is one of the strongest pieces of circumstantial evidence in the filing. 9. **Nehring metadata "title bleed":** A live court order in Guertin's case containing metadata referencing synthetic defendant "Adrian Wesley" with authorship by a Department of Health attorney — inside a cryptographically sealed PDF — is a significant anomaly if verifiable. The fact that these metadata fields are locked by the court's digital signature means they cannot have been altered post-download. 10. **Statistical attorney-status anomaly:** The Cole/Prochazka "mirror-image" pattern (each attorney's sole atypical status falling on the same case, joint probability 0.27%) is a quantitative flag that, while not conclusive on its own, is notable when combined with the other anomalies. 11. **Scale of MCRO corpus findings:** 371 duplicate judicial timestamps, 1,183 duplicate judicial signatures, 40 duplicate returned mail filings, and 128 allegedly cloned competency orders — all within a 3,629-document corpus bearing the court's own digital signatures. If validated, the scale of these findings would represent a systemic issue far beyond a single defendant's case. 12. **No rebuttal on record:** Guertin repeatedly asserts that nobody — not the prosecutor, not defense counsel, not any judge — has ever substantively rebutted or challenged his discovery fraud claims or MCRO findings. This is noteworthy regardless of the claims' ultimate merit. ### Cross-References - **Filing #1*** (Motion for Judicial Notice) — Contains foundational case narrative, patent claims, initial MCRO fraud claims - **Filing #3*** (Affidavit of Fact, Apr 9, 2024) — Early documentation of discovery fraud and Rule 20 abuse - **Filing #6*** (Affidavit — Judicial Simulation) — Sandra Vongsaphay, Adrian Wesley, Lee Cuellar, Mother's Letter event first documented - **Filing #9*** (Motion for Substitute Counsel) — Bruce Rivers misconduct; earlier demand for discovery materials - **Filing #10*** (Judicial Notice filing) — June 14, 2023 Order for Continuance / Nehring metadata first cataloged; Judith Cole first referenced; Koch hearing context - **Filing #12*** (RICO Complaint) — Alisha Nehring, Amanda Burg, metadata analysis, "barbj"/"hernandezke" metadata authors, digital signature analysis, comprehensive MCRO fraud allegations - **Prior appellate case A24-0780*** — Guertin's May 2024 Petition for Discretionary Review - **Federal case 0:24-cv-02646-JRT-DLM*** — Civil rights complaint and RICO action - **8th Circuit case 24-2662*** — Appeal of federal case - **District court docket Index 205** — Judge Hudleston's May 30, 2025 post-filing order (NEW — not previously cataloged) - **District court docket Index 22** — January 5, 2024 Demand for Discovery (first pro se filing) - **District court docket Index 29** — April 4, 2024 Motion to Compel Discovery - **District court docket Index 135–184** — April 28, 2025 evidence submissions (50 filings, 5,435 pages) - **Add. 33–66** — May 7, 2025 Emergency Motion for Stay and Vacate (NEW — district court level predecessor to this appellate motion) - **Add. 200–231** — April 21, 2025 Petition to Proceed Pro Se (NEW — not previously cataloged as standalone filing) - **Add. 232–281** — April 16, 2025 Motion to Dismiss (NEW — the trigger document for the April 29 orders) --- ## Filing #15 — Civil Rights and RICO Complaint with Jury Demand (Full Visual-Forensic Re-Processing) | Field | Detail | |---|---| | Filing # | 15 | | Date Filed | June 25, 2025 | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Civil Rights and RICO Complaint with Jury Demand | | Case/Court | Federal: 0:24-cv-02646-JRT-DLM / U.S. District Court, District of Minnesota (Doc. 116); also references new case number 25-cv-____ (blank) | | Pages | 121 | | Bates / Doc ID | 116__EXHIBIT_CIVIL_RIGHTS_AND_RICO_COMPLAINT_WITH_JURY_DEMAND__2025-06-25.pdf | ### PDF Metadata (Extracted via pdfinfo) | Metadata Field | Value | |---|---| | Producer | PyPDF2; modified using iText® Core 7.2.3 (production version) ©2000-2022 iText Group NV, Administrative Office of the United States Courts | | ModDate | Wed Jun 25 14:31:14 2025 UTC | | Pages | 121 | | Page Size | 612 x 792 pts (US Letter) | | PDF Version | 1.6 | | Encrypted | No | | Tagged | No | | Form | None | | JavaScript | No | | Optimized | No | **Metadata Forensic Note:** The Producer field shows the document was created with PyPDF2 (a Python PDF library) and modified using iText® Core 7.2.3, with the organization listed as "Administrative Office of the United States Courts." This indicates the document passed through the federal court's CM/ECF electronic filing system, which uses iText for PDF processing upon docketing. The PyPDF2 origin suggests Guertin assembled or compiled the PDF using Python tooling before filing. No custom metadata (Author, Title, Creator, etc.) is present at the document level — only the Producer and ModDate fields survive, consistent with CM/ECF stripping custom metadata during processing. The absence of digital signatures, form fields, or JavaScript is normal for a pro se filing processed through CM/ECF. ### Comprehensive Summary This is a 121-page federal civil rights and RICO complaint filed pro se by Matthew David Guertin on June 25, 2025, docketed as Document 116 in existing federal case 0:24-cv-02646-JRT-DLM (Guertin v. Hennepin County) in the U.S. District Court for the District of Minnesota, before Judge John R. Tunheim and Magistrate Judge Douglas L. Micko. The complaint header also contains a blank new case number field ("25-cv-____"), suggesting it may have been intended as a separate new action or an amended complaint within the existing federal matter. The complaint names over 30 individual defendants in their personal and/or official capacities, plus 100 Doe defendants (John Does 1–50 and Jane Does 1–50). Claims are asserted under 42 U.S.C. §§ 1983 and 1985 (civil rights), and 18 U.S.C. §§ 1961–1968 (RICO). **Core Theory — The Synthetic Case Matrix:** Guertin alleges that a coalition of state officials, county prosecutors, judges, public defenders, mental health professionals, and court administrators orchestrated a "synthetic case matrix" — a system of fabricated court cases, falsified documents, and fictitious defendants — designed to simulate judicial process while depriving him of all meaningful due process. The ultimate purpose, Guertin alleges, was to suppress his patented technology (U.S. Patent 11,577,177 — a VR treadmill/volumetric display system he values at over $100 billion NPV), declare him mentally incompetent, and effect his indefinite psychiatric institutionalization. Guertin claims to be the only identifiable real human defendant within an otherwise entirely synthetic legal universe of 163 criminal cases, all sharing three judicial officers: Judge Julia Dayton Klein, Referee/Judge Danielle C. Mercurio, and Referee George F. Borer. **Digital Forensic Evidence Foundation (Sections IV–XVII):** The complaint's evidentiary foundation rests on a forensic analysis Guertin conducted on April 29–30, 2024, during which he downloaded 3,601 digitally signed PDF court documents across 163 criminal case files from the Minnesota Court Records Online (MCRO) system. He used custom Python automation, search-filter bypass methods, and VPN rotation to compile the dataset. The forensic findings are organized into the following categories: **Section IV — SHA-256 Authentication:** 99.6% of documents (3,585 of 3,601) bear X.509 SHA-256 digital signatures from the Hennepin County Courts. Guertin argues these signatures make the documents self-authenticating under Federal Rule of Evidence 902(14), and that the court's own cryptographic infrastructure "co-signed the proof of its own misconduct." He employed object-level hashing (using MuPDF's mutool for extraction and sha256sum for hashing) to identify duplication patterns within documents, not just across whole files. **Section V — Digital Forgery and Judicial Signature Fraud:** (A) 55 documents bear post-dated digital signatures — timestamps after their filing dates. (B) 371 instances of byte-for-byte identical timestamp blocks reused across different orders, case numbers, and judges — indicating mass document cloning. (C) 1,183 duplicate judicial signature image graphics reused across filings, sometimes with different judge names attached. (D) 40 fabricated USPS return-mail scans with identical envelope images reused across synthetic dockets, with recurring addresses at 740 E 17th Street and 1010 Curry Avenue. (E) AI-generated court filings: PDFs containing entire filings as embedded 2-bit binary images (no scan artifacts, no grayscale, no paper texture), suggesting AI/diffusion-based document fabrication rather than legitimate scanning. **Section VI — The "Mother's Letter" Incident (April 12, 2024):** Guertin presents this as a "smoking gun." A synchronized sequence across his case and a fabricated defendant's case (Sandra Phitsanoukanh Vongsaphay, 27-CR-23-2480): fake "inmate" letter filed at 2:03 PM; Guertin's mother's genuine letter at 2:10 PM; Judge Klein's preemptive "Order Denying Petition to Proceed Pro Se" at 2:28 PM; Clerk Lee Cuellar's boilerplate response to the fake letter at 4:38 PM; and the same clerk's near-identical response to the real letter at 4:42 PM. SHA-256 analysis confirmed the two clerk responses share unique header/letterhead image hashes not found in any other documents in the 3,601-file dataset. **Section VII — 127 Cloned Incompetency Orders:** 129 "Finding of Incompetency and Order" documents across 103 synthetic case numbers and 50 supposed defendants, with 127 authored by metadata entity "barbj" and cloned from a single template: Guertin's own January 17, 2024 incompetency order. Only two authentic outliers: Guertin's July 13, 2023 order (authored by Mercurio) and an Aaron Dashaun Cherry order later overwritten by a clone. **Section VIII — PDF Metadata Toolchain:** Recurring enterprise-grade metadata signatures: Adobe XMP Core 5.1.0-jc003, PScript5.dll Version 5.2.2, Acrobat Distiller 23.0/24.0, and Adobe PDF Library 22.3.34/23.1.175 — professional automated PDF generation tools not available to ordinary court personnel. **Section IX — Rule 20 Evaluation Metadata Fraud:** Two separate Rule 20 evaluations — one attributed to Dr. Adam Milz (January 11, 2024) and one to Dr. Katheryn Cranbrook (December 20, 2024) — share identical metadata: Author/Creator "Hines, Anne," identical Adobe XMP Core 5.6-c142 version string, and "Microsoft: Print To PDF" as producer. The Milz metadata was filed into the federal record on August 7, 2024 (Exhibit W), months before the Cranbrook report existed, enabling retroactive proof of fabrication. **Section X — Metadata Author "barbj":** 137 documents across 105 case numbers. 127 are "Finding of Incompetency and Order." All carry "Hennepin County" in the Company field. Seven recycled Title variants, dominated by "Commitment Order (MI, DD)" (110 instances). **Section XI — Metadata Author "hernandezke"/"HernandezKE":** 225 documents across 101 case numbers, involving only 47 unique defendants. 143 are "Notice of Remote Hearing with Instructions," 55 are "Order-Evaluation for Competency to Proceed (Rule 20.01)," 27 are "Notice of Hearing." Three documents appear in Guertin's own docket (Indexes #25, #40, #119). All carry the metadata title "Microsoft Word - Document in Unnamed." **Section XII — Defendant Profile: Alisha Nehring:** 28 court filings (July 31, 2019 – July 15, 2024) listing Nehring as Author/Creator. Authored all three "Adrian Wesley" foundational commitment filings. Authored the only "Order for Continuance" across all 3,601 files — the one in Guertin's docket (June 14, 2023), which contains the metadata title "Contested Competency for Adrian Wesley (incompetent) (doctors disagree)," a direct link to a synthetic defendant. Career history: law clerk to Judge Lamas (2014–2020), Unemployment Law Judge (2020–2022), Associate General Counsel at MN Dept. of Health (2022–present). **Section XIII — "GuzmanC" Metadata in First Rule 20:** Dr. Rogstad's March 10, 2023 Rule 20 evaluation lists metadata Author/Creator as "GuzmanC" (presumed Chela Guzman-Wiegert) with an anomalously old XMP Toolkit from November 2016, matching only 17 documents across the entire 3,601-file corpus. **Section XIV — "Odyssey Merge Batch Print Job":** The January 31, 2025 "Notice of Case Reassignment" in Guertin's docket (Index #120) carries metadata Author "HoopmanA," Title "Odyssey Merge Batch Print Job" — matching a pattern of exactly 20 such filings across the dataset, all being "Notice of Case Reassignment" types, with 3 authored by "Hoopmana" (lowercase) for synthetic defendant "Isaac Lee Kelley" and 17 by "lakee." **Section XV — Discovery Fraud Metadata:** The "Set B" discovery delivered August 3, 2023 contains Author/Creator "JSF254" with matching prefix patterns ("JS" + alphanumeric) across 26 synthetic docket entries (JSD921, JSG214, JSM332, JSU203). **Section XVI — Final Metadata Anomalies:** (1) December 30, 2024 "Objection to Competency" filed by Carpenter but authored by Andrew Reiland II. (2) January 14, 2025 "Demand or Request for Discovery" filed by Carpenter but authored by Camille A. King. (3) April 3, 2025 competency order signed by Koch but authored by "Hansen, Isabel" — produced nearly a month after the hearing, appearing the day after Guertin texted Carpenter asking about it. (4) April 29, 2025 Rule 20.01 order and forensic navigator appointment both authored by "burrowsp." (5) April 29, 2025 "Notices of Hearing" lacking standard Odyssey eFiling metadata. (6) May 30, 2025 — for the first time ever, Judge Hudleston's own name appears as metadata author on her order, after Guertin submitted extensive metadata evidence. **Section XVII — Embedded Font Tracking Codes:** Analysis of 4,400+ embedded font entries reveals 909 unique embedded fonts, of which 681 (75%) are exclusive to single defendants, suggesting per-defendant font fingerprinting. A critical hidden .cff font file (hash "427af119.....a4893f95") appears in 4 documents in Guertin's docket and 165 synthetic case documents, including fabricated filings backdated to 2017 and tied to the Adrian Wesley persona. A pair of .ttf font files (Arial and COLNXP+ArialMT) inserted in the duplicate July 13, 2023 order appears in 1,021 other documents across 160+ case numbers. Guertin argues these function as covert digital tags enabling real-time editing and synchronization of court records. **Defendant-Specific Claims (Sections XVIII–XXIII):** The complaint details individualized allegations and legal claims against each named defendant: *State Officials (Section XVIII):* - Tim Walz — Governor; sued in official capacity for failure of executive oversight, deliberate indifference, RICO acquiescence - Keith Ellison — AG; sued in official capacity for constructive knowledge of fraud, failure to investigate after notice since May 2024, tolerance of prosecutorial perjury by Mawerdi Hamid - Alisha Nehring — MDH attorney; sued individually for authoring 28 fraudulent filings, including the Adrian Wesley commitment orders and the June 14, 2023 order in Guertin's case *County Entity and Senior Officials (Section XIX):* - Hennepin County — Monell liability for policies/customs enabling fraud; institutional RICO participation; failure to secure MCRO/Odyssey systems; OneDrive discovery tampering (aspect ratio manipulation, false timestamps) - Mary Moriarty — County Attorney; supervisory liability for subordinates Cole, Hamid, and Perez; standing CJCC member; Monell policymaker - Judith L. Cole — Sr. ACA; metadata signature in 84 filings (2017–2022); 63 of 84 have signature/layout matches; listed as "active" only in Guertin's case (statistical probability <0.3%) - Chela Guzman-Wiegert — Asst. County Admin; oversees Law, Safety & Justice IT; "GuzmanC" metadata author; CJCC member - Michael Berger — Chief Public Defender; supervisory liability; CJCC member; audit shows >50% of synthetic filings generated by attorneys under his supervision *Judicial Officers (Section XX):* - Kerry W. Meyer — Chief Judge; tied to 23 synthetic dockets; 84 hearings across 15 defendants; 7 orders with duplicate signature hash "1ac840c5.....735a6ead"; linked to 2 Adrian Wesley cases - Hilary Caligiuri — Presiding Criminal Judge; 39 synthetic case files; 99 hearing records for only 8 defendants; supervisory responsibility over case authenticity - Todd Fellman — Presiding Juvenile Judge; signature/name used across adult criminal synthetic dockets despite no jurisdiction; CJCC member - Sarah Hudleston — Current trial judge; ordered 4th Rule 20 exam (April 29, 2025) based solely on legal filings; refused Faretta petition; appeared in 7 fabricated case files; first judge to author her own metadata entry (May 30, 2025) — only after Guertin exposed the metadata pattern - William H. Koch — Presided after Klein recusal; phantom docket entries (Index #102, #103); competency order authored by "Hansen, Isabel"; found Guertin competent but preserved psychiatric narrative; 13 forged signature hashes; improperly narrowed Faretta rights - Julia Dayton Klein — Central figure; 178 forged judicial signatures; 107 cloned timestamp blocks; zero metadata appearances across 112,324 records; 172 case files, 302 docket events, 308 hearings for 77 defendants; not officially assigned to any of the 163 cases; signed fraudulent June 14, 2023 order authored by Nehring; denied appellate fee waivers without basis; authored Rule 20 orders on 11/15/2023 and 5/9/2024 without motions - Danielle C. Mercurio — Authored July 13, 2023 incompetency order attributed to Borer/Browne; named on January 17, 2024 incompetency order; 219 docket events, 298 hearings in zero assigned cases; 60 signature images, 49 cloned timestamps; described as "central operator" - Michael K. Browne — 145 case files despite zero assignments; 158 cloned timestamps; 217 duplicate signature images; 165 hearings for 50 defendants; 14 warrants dominated by synthetic defendant "Gordon Eugene Sharp" - Lisa K. Janzen — 297 case files but only 3 assigned cases; 204 duplicate signatures; 441 docket events; 315 hearings for 37 defendants; zero metadata authorship - Carolina A. Lamas — 60 case files; 73 hearings for 18 defendants (15 for Adrian Wesley); connected to Nehring (former clerk); 24 cloned signature images - Shereen Askalani — Ordered 3rd Rule 20 exam (October 15, 2024) immediately after appointing Carpenter, without cause or transcript; 9 case files; 10 hearings for 7 defendants - George F. Borer — Presided over July 7, 2023 competency hearing and February 1, 2024 civil commitment hearing; zero metadata presence across entire 112,324-record corpus; 63 case files, 174 events, 232 hearings for 77 defendants; 47 signature images, 30 cloned timestamps - Lee Cuellar — Executed April 12, 2024 "Mother's Letter" cover-up; authored 11 PDFs across entire MCRO dataset; coordinated with Klein in real-time docket manipulation *Legal Counsel (Section XXI):* - Mawerdi Hamid — Current prosecutor; alleged perjury on April 29, 2025 (denied knowledge of discovery manipulation contradicting March 5, 2025 hearing transcript); uses @ag.state.mn.us address; Brady violation; appears in 3 synthetic defendant clusters - Jacqueline Perez — Original lead prosecutor; key role in July 7, 2023 competency hearing; appeared in 7 synthetic case files; went "inactive" after being named in 2024 federal suit - Emmett M. Donnelly — Current public defender; waived confrontation rights at March 5, 2025 hearing; refused to file Motion to Dismiss; abandoned discovery fraud arguments mid-hearing; urged plea negotiations against client instructions; alleged constructive abandonment per Cronic standard - Raissa Carpenter — Current public defender; appears in 16 synthetic felony cases (Lucas Patrick Kraskey cluster, Rex Allen Basswood Jr. cluster); listed simultaneously as defense and prosecution in one case; "Objection to Competency" authored by Andrew Reiland II; "Demand for Discovery" authored by Camille A. King; Guertin downloaded all synthetic dockets 6 months before meeting Carpenter - Bruce M. Rivers — Former private defense counsel; told Guertin "powerful people keeping an eye on you" (May 22, 2023); texted "No court" (January 15, 2024); withheld Milz Rule 20 report for 7+ months; delivered discovery via USB (July 16, 2024) breaking chain of custody; facilitated January 2024 "Conspiracy of Commitment"; filed 116-page MN OLPR ethics complaint (September 25, 2024) *Mental Health Professionals (Section XXII):* - Dr. Jill Rogstad — Rule 20 evaluation (March 10, 2023) metadata shows Author "GuzmanC," not Rogstad; anomalous 2016 XMP Toolkit; report misrepresented meeting content - Dr. Adam Milz — Rule 20 evaluation (January 11, 2024) metadata shows Author "Hines, Anne"; served as catalyst for February 1, 2024 commitment; withheld from Guertin 7+ months - Dr. Katheryn Cranbrook — Rule 20 evaluation (December 20, 2024) metadata shows Author "Hines, Anne" with identical toolkit to Milz; diagnosed "Unspecified Psychotic Disorder" based on legal filings rather than clinical examination; recommended forced neuroleptic treatment; ordered to conduct 4th Rule 20 exam - Dr. Kristen A. Otte — Most frequently recurring examiner in synthetic commitment cases; never involved in Guertin's case yet appears in Odyssey backend as linked provider; boilerplate diagnoses recycled across fabricated dockets; tied to foundational Adrian Wesley cluster *Doe Defendants (Section XXIII):* - John Does 1–50 and Jane Does 1–50 — believed to include court IT administrators, Odyssey system engineers, DHS contractors, military/intelligence actors, and executives from Light Field Labs, OTOY, Google/Alphabet, YouTube, the World Economic Forum, USC (ICT, Cinema, Shoah Foundation), DARPA, U.S. State Department, U.S. Army, and U.S. Air Force **RICO Claims (Section XXIV):** Alleges an enterprise under 18 U.S.C. § 1961(4) consisting of court officials, forensic examiners, public defenders, and IT operators, operating continuously from January 2023 through the present. Predicate acts under 18 U.S.C. § 1961(1) include: mail fraud (§ 1341), wire fraud (§ 1343), obstruction of justice (§§ 1503, 1512, 1519), false statements (§ 1001), witness tampering (§ 1512), and conspiracy (§ 1962(d)). The enterprise's objective: eliminating Guertin's ability to commercialize U.S. Patent 11,577,177, valued at over $100 billion NPV per addendum (Doc. 103 from 24-cv-2646). ### Relief Sought (Sections XXV–XXIX): 1. Preliminary and permanent injunction halting all state criminal proceedings 2. Declaratory judgment invalidating all synthetic psychiatric evaluations and court orders 3. Referral to DOJ/federal grand jury for criminal investigation 4. Protective order against further psychiatric examination, forced medication, or commitment 5. Expungement of synthetic/altered records 6. Compensatory, punitive, and treble damages (reserved for post-discovery) 7. Jury trial demanded on all issues (Section XXVIII) 8. Evidentiary preservation orders directed at MN Judicial Branch, Hennepin County, DHS, and Odyssey system administrators — including early Rule 45 subpoenas for internal authorship logs, identity of metadata authors, system access logs, and forensic mirror of full case files (Section XXIX) The complaint is verified under penalty of perjury and signed electronically "/s/ Matthew D. Guertin" with address at 4385 Trenton Ln. N 202, Plymouth, MN 55442, phone 763-221-4540, email MattGuertin@protonmail.com. ### Legal Issues & Arguments Raised - 42 U.S.C. § 1983 — Due process (5th, 14th Amendments), access to courts (1st Amendment), right to counsel (6th Amendment), cruel and unusual punishment (8th Amendment) - 42 U.S.C. § 1985(2), (3) — Conspiracy to deprive equal protection; conspiracy to obstruct justice - 18 U.S.C. § 1962(c) — RICO participation (conducting enterprise through pattern of racketeering activity) - 18 U.S.C. § 1962(d) — RICO conspiracy - 18 U.S.C. §§ 1341, 1343 — Mail and wire fraud (via fabricated filings) - 18 U.S.C. § 1349 — Conspiracy to commit mail or wire fraud - 18 U.S.C. § 1512(b), (c) — Witness tampering / obstruction of official proceedings - 18 U.S.C. § 1519 — Falsification of records in federal investigations or proceedings - 18 U.S.C. § 1001 — False statements within federal jurisdiction - 18 U.S.C. § 505 — Forgery of public documents - 18 U.S.C. § 1028 — Identity document fraud - 18 U.S.C. § 1702 — Obstruction of correspondence - 18 U.S.C. § 371 — Conspiracy to defraud the United States - 18 U.S.C. § 241 — Conspiracy against rights - 18 U.S.C. § 242 — Deprivation of rights under color of law - 18 U.S.C. § 1503 — Obstruction of the due administration of justice - 18 U.S.C. § 1505 — Obstruction of proceedings before departments, agencies, and committees - 18 U.S.C. § 1346 — Honest services fraud (cited re: Caligiuri) - Federal Rule of Evidence 902(14) — Self-authenticating digital evidence - Federal Rule of Evidence 901, 902 — Authentication and admissibility - Monell v. Department of Social Services, 436 U.S. 658 (1978) — Municipal entity liability - Faretta v. California, 422 U.S. 806 (1975) — Right to self-representation - Brady v. Maryland, 373 U.S. 83 (1963) — Disclosure of exculpatory evidence - Strickland v. Washington, 466 U.S. 668 (1984) — Ineffective assistance of counsel - United States v. Cronic, 466 U.S. 648 (1984) — Constructive abandonment - Reves v. Ernst & Young, 507 U.S. 170 (1993) — RICO enterprise management test - Pate v. Robinson, 383 U.S. 375 (1966) — Retaliatory use of mental health inquiry - Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238 (1944) — Fraud on the court - Judicial immunity — argued to be overcome by acts outside legitimate judicial function - Minn. R. Crim. P. 20.01 — Competency evaluation procedure - Minn. R. Prof. Conduct 1.2(a) — Client control of defense objectives - Minn. Stat. § 609.48 — Perjury - Minn. Stat. § 609.625 — Obstruction of correspondence ### Factual Allegations & Key Assertions - 3,601 PDF documents downloaded from MCRO across 163 cases on April 29–30, 2024 - 99.6% (3,585) bear X.509 SHA-256 digital signatures from Hennepin County Courts; only 16 lack signatures - Guertin is the only identifiable real person among 163 defendants - 55 documents bear post-dated digital signatures (signed after filing dates) - 371 instances of byte-for-byte timestamp reuse across orders - 1,183 duplicate judicial signature image graphics - 40 fabricated USPS return-mail filings with identical scans - Court filings rendered as 2-bit binary images (AI-generated, no scan artifacts) - 127 cloned "Finding of Incompetency and Order" documents from Guertin's January 17, 2024 order template, all authored by "barbj" - "barbj" authored 137 documents across 105 cases - "hernandezke"/"HernandezKE" authored 225 documents across 101 cases, involving only 47 defendants - Rule 20 evaluations by Milz and Cranbrook both metadata-authored by "Hines, Anne" with identical toolkit - Rule 20 evaluation attributed to Rogstad actually authored by "GuzmanC" with 2016-era toolkit - "Mother's Letter" incident (April 12, 2024): synchronized cross-docket document manipulation with unique SHA-256 header hashes - Nehring authored 28 filings including fraudulent June 14, 2023 order with metadata title referencing synthetic defendant Adrian Wesley - Nehring's career: law clerk to Lamas (2014–2020) → Unemployment Law Judge (2020–2022) → MDH Associate General Counsel (2022–present) - 20 "Odyssey Merge Batch Print Job" filings, all "Notice of Case Reassignment" type - Discovery fraud across "Sets A–D"; "Set B" metadata showing "JSF254" authorship - Enterprise PDF toolchain: Adobe XMP Core 5.1.0-jc003, PScript5.dll 5.2.2, Acrobat Distiller 23.0/24.0 - 909 unique embedded fonts; 681 (75%) exclusive to single defendants - Hidden .cff font file (hash "427af119.....a4893f95") in 4 Guertin filings and 165 synthetic case documents - Pair of .ttf font files from July 13, 2023 duplicate order appear in 1,021 additional documents across 160+ cases - Judge Klein: 178 forged signatures, 107 cloned timestamps, zero metadata appearances across 112,324 records - Mercurio: 219 docket events, 298 hearings in zero assigned cases - Browne: 217 duplicate signature images; 158 cloned timestamps - Borer: zero metadata presence across 112,324 records; 232 hearings for 77 defendants - Koch competency order (April 3, 2025) authored by "Hansen, Isabel," produced ~1 month after hearing - Hudleston first metadata-authored her own order (May 30, 2025) only after Guertin's metadata exposé - Donnelly waived confrontation rights at March 5, 2025 hearing; refused to file Motion to Dismiss - Carpenter appears in 16 synthetic felony cases; listed as both defense and prosecution in one case - Rivers told Guertin about "powerful people" (May 22, 2023); texted "No court" (January 15, 2024); withheld Milz report 7+ months - Hamid allegedly committed perjury on April 29, 2025 contradicting March 5 transcript statements - Cole: 84 filings (2017–2022); "active" only in Guertin's case out of 53 assignments - Patent theft motive: InfiniSet US 11,577,177 (provisional filed March 19, 2021) predates Netflix's Trojansky filing by 12 days - InfiniSet Inc. is Guertin's Delaware corporation - OneDrive discovery contained photographs with manipulated aspect ratios and false upload timestamps - Guertin successfully completed stayed civil commitment on November 8, 2024; Cranbrook's report 5 weeks later sought to re-entrap him in mental health narrative - Doe Defendants believed to include Google, Alphabet, YouTube, Light Field Labs, OTOY, WEF, USC, DARPA, military/intelligence actors ### Procedural Posture Filed June 25, 2025 as Doc. 116 in existing federal case 0:24-cv-02646-JRT-DLM (Guertin v. Hennepin County), before Judge John R. Tunheim with Magistrate Judge Douglas L. Micko. This is the most comprehensive federal filing to date, appearing to supersede or supplement the original 2024 complaint. It references a concurrent emergency motion for stay in state appellate case A25-0882 filed June 4, 2025, and follows a fourth Rule 20 evaluation ordered on April 29, 2025 by Judge Hudleston. The complaint's blank new case number field suggests possible dual filing. In the state criminal case (27-CR-23-1886), Guertin was found competent to proceed on April 3, 2025 by Judge Koch but with mental illness findings maintained. A fourth Rule 20 evaluation was nevertheless ordered on April 29, 2025 by Judge Hudleston, allegedly in retaliation for Guertin's legal filings. Guertin's stayed civil commitment expired November 8, 2024. ### Exhibit / Attachment Inventory No exhibits are physically attached. The complaint references numerous external resources: ### External Websites: - MnCourtFraud.com/File/Complaint.pdf — Digital bookmarked version of this complaint - MnCourtFraud.com — Extensive sub-pages per evidentiary topic - MnCourtFraud.Substack.com — Detailed analytical posts per section - CourtListener.com/docket/68925331/ — Full federal docket - MattGuertin.com and MattGuertin.Substack.com — Personal sites ### Referenced Data Files: - ZIP archives: 2017.zip through 2023.zip at MnCourtFraud.com (MCRO case files) - 08_MCRO_files-with-no-signature.xlsx - 09_MCRO_file-metadata.xlsx - ERRORS_finding-of-incompetency-and-order.xlsx - 01_CASE_details.xlsx, 02_CASE data, 03_CASE_warrants.xlsx, 04_CASE_listed-attorneys.xlsx - 06_SHA-256_ttf-font-codes.xlsx - JULY-13__guertin.csv, JULY-13__links.csv ### Referenced Hash Image Files (at MnCourtFraud.com/File/): - debcc04a.....b1d764a6.png (Mother's Letter header seal hash) - f609be80.....e15a1eee.png (Mother's Letter letterhead banner hash) - 3ff3cad7.....e30a84d9.png (Lamas signature hash) - 18d03912.....b3f87d4d.jpg (Janzen signature hash #1) - 3aeb71e9.....198e5764.png (Janzen signature hash #2) - e3e4157a.....8e9d3550.png (Browne signature hash) - 1ac840c5.....735a6ead.png (Meyer signature hash) - 427af119.....a4893f95.cff (hidden CFF font tracking file) - b50a0345.....26e17692.ttf (Arial tracking font) - 1fa67c75.....8edecef8.ttf (COLNXP+ArialMT tracking font) ### Referenced Federal Filings (24-cv-2646): - Doc. 23 — Exhibit P ("Conspiracy of Commitment") - Doc. 47 (pp. 43/167) — Exhibit W (metadata evidence from Bruce Rivers discovery) - Doc. 77 — 116-page Ethics Complaint (Bruce Rivers) - Doc. 99 — Transcript (Tr. 1-2, 8-10, Add. 15) - Doc. 102 — Transcript (Tr. 9, 12-20, Add. 168; Tr. 4-10, Add. 169) - Doc. 103 — Netflix Patent Motive & Valuation (Add. 182-199) - Doc. 115 — A25-0882 Emergency Motion for Stay ### Referenced Substack Posts (MnCourtFraud.Substack.com/p/): - 01-mcro, 02-case, 03-sha-256 - signed-after-filing-date, judicial-timestamp-duplicates, judicial-signature-duplicates - usps-mail-fraud, mothers-letter-smoking-gun, incompetency-orders - barbj, hernandezke, alisha-nehring, judith-l-cole - bruce-rivers-july-16-discovery, digital-forensic-reports - Individual defendant profiles: kerry-w-meyer, hilary-caligiuri, todd-fellman, sarah-hudleston, william-h-koch, julia-dayton-klein, danielle-c-mercurio, michael-k-browne, lisa-k-janzen, carolina-a-lamas, shereen-askalani, george-f-borer, lee-cuellar, mawerdi-hamid, jacqueline-perez, raissa-carpenter, emmett-m-donnelly, adam-milz, katheryn-cranbrook, kristen-a-otte ### Visual Evidence Inventory - **[Page 1]** [Federal Court Header]: Standard CM/ECF header stamp in blue text: "CASE 0:24-cv-02646-JRT-DLM Doc. 116 Filed 06/25/25 Page 1 of 121." Appears on every page. Native digital text, clean rendering, no anomalies. Caption page lists all named defendants with titles/roles. Blank case number field "25-cv-____" on right side, with "CIVIL RIGHTS AND RICO COMPLAINT WITH JURY DEMAND" title block. Standard federal complaint formatting. No images, stamps, or signatures on this page. - **[Pages 1–2]** [Party Listing]: Defendants listed in standard federal format across two pages. All text is native digital (not scanned). Professional formatting with bold defendant names and roles. - **[Page 18]** [Table — "Mother's Letter" Timeline]: Five-row, three-column table (Time / Event / Add.) with gray header row. Displays April 12, 2024 chronology: 2:03 PM fake letter, 2:10 PM genuine letter, 2:28 PM Klein order, 4:38 PM clerk response to fake, 4:42 PM clerk response to real. "Add." column contains addendum page references (561, 562, 563, 564, 564). Table is native digital with clear borders and shading. No anomalies. - **[Page 30]** [Table — "barbj" Defendants by Frequency]: Five-row, two-column table listing defendants with highest "barbj" file counts: Lucas Patrick Kraskey (21), Aesha Ibrahim Osman (15), Terrell Johnson (9), Gordon Eugene Sharp (7), Carmen Bendu Greaves (6). Native digital table, no anomalies. - **[Page 34]** [Table — Nehring Metadata Properties]: Four-row, three-column table showing metadata fields (Title, Author/Creator, Company, File Name) with "Value Displayed in Properties Pane" and "Evidentiary Impact" columns. Title field shows "Contested Competency for Adrian Wesley (incompetent) (doctors disagree)." Gray header row. Native digital rendering with clean borders. This table is a key evidentiary exhibit displaying the metadata fields locked inside the PDF's cryptographic signature. - **[Page 38]** [Metadata Display — GuzmanC Rule 20 Evaluation]: Formatted as label-value pairs (not a bordered table) showing: File Name (Rule 20 Evaluation Report.pdf), Author (GuzmanC), Creator (GuzmanC), Title (Guertin Report.pdf), Creator Tool (PScript5.dll Version 5.2.2), Producer (Acrobat Distiller 22.0), XMP Toolkit (Adobe XMP Core 5.6-c015 81.159809, 2016/11/11-01:42:16), Metadata Date (2023:03:10 16:38:55-06:00). Native digital text, clearly formatted. No visual anomalies. - **[Page 121]** [Signature Page]: Verification and signature block. Electronic signature "/s/ Matthew D. Guertin" with italicized formatting and underline. Address: 4385 Trenton Ln. N 202, Plymouth, MN 55442. Phone: 763-221-4540. Email: MattGuertin@protonmail.com (rendered as blue hyperlink). Website: www.MattGuertin.com (rendered as blue hyperlink). "Plaintiff Pro Se" in bold italics. Dated June 25, 2025. Large blank space below signature block to page bottom. No wet signatures, stamps, or court marks beyond the standard CM/ECF header. - **[All Pages]** [CM/ECF Header]: Every page displays consistent blue-text header "CASE 0:24-cv-02646-JRT-DLM Doc. 116 Filed 06/25/25 Page X of 121" with sequential page numbering. Headers are generated by the federal court's filing system, not by the filer. All are uniform and show no anomalies. - **[All Pages]** [Document Character]: The entire document is native digital text (not scanned). Fonts are consistent throughout. Formatting includes underlined/bold section headers (Roman numeral sections with descriptive titles), numbered paragraphs (¶¶ 1–540), bulleted lists, indented sub-sections, footnotes (numbered 1–16), and hyperlinks rendered in blue. The document uses standard word-processor formatting throughout and was clearly prepared on a computer, not handwritten or scanned. - **No photographs, screenshots, diagrams, scanned handwriting, redactions, or embedded images are present anywhere in the 121-page document.** All referenced visual evidence (signature hash images, envelope scans, etc.) is referenced by external URL to MnCourtFraud.com rather than embedded in the PDF. ### Key People Referenced *State Officials:* - **Tim Walz*** — Governor of Minnesota (Defendant, official capacity) - **Keith Ellison*** — Minnesota Attorney General (Defendant, official capacity) - **Alisha Nehring*** — MN Dept. of Health Attorney / Associate General Counsel; metadata author of 28 filings (Defendant, individual capacity) *County Officials:* - **Mary Moriarty*** — Hennepin County Attorney (Defendant, official and individual) - **Judith L. Cole*** — Sr. Assistant Hennepin County Attorney (Defendant, individual) - **Chela Guzman-Wiegert*** — Asst. County Administrator / "GuzmanC" (Defendant, individual) - **Michael Berger*** — Chief Public Defender, Hennepin County (Defendant, individual) *Judicial Officers:* - **Kerry W. Meyer*** — Chief Judge, 4th District (Defendant, individual) - **Hilary Caligiuri*** — Presiding Criminal Judge, 4th District (Defendant, individual) - **Todd Fellman*** — Presiding Juvenile Judge, 4th District (Defendant, individual) - **Sarah Hudleston*** — Judge, 4th District; current trial judge (Defendant, individual) - **William H. Koch*** — Judge, 4th District (Defendant, individual) - **Julia Dayton-Klein*** — Judge, 4th District (Defendant, individual) - **Danielle C. Mercurio*** — Judge, 4th District (Defendant, individual) - **Michael K. Browne*** — Judge, 4th District (Defendant, individual) - **Lisa K. Janzen*** — Judge, 4th District (Defendant, individual) - **Carolina A. Lamas*** — Judge, 4th District (Defendant, individual) - **Shereen Askalani*** — Judge, 4th District (Defendant, individual) - **George F. Borer*** — Referee, 4th District (Defendant, individual) - **Lee Cuellar*** — Judicial Clerk, 4th District (Defendant, individual) - **Jay Quam*** — Judge, 4th District (referenced as assigned judge during Mother's Letter incident, not named as defendant) *Legal Counsel:* - **Mawerdi Hamid*** — ACA; uses @ag.state.mn.us address (Defendant, individual) - **Jacqueline Perez*** — ACA (Defendant, individual) - **Emmett M. Donnelly*** — Public Defender (Defendant, individual) - **Raissa Carpenter*** — Public Defender (Defendant, individual) - **Bruce M. Rivers*** — Private defense counsel (Defendant, individual) *Mental Health Professionals:* - **Dr. Jill Rogstad*** — Senior Clinical Forensic Psychologist (Defendant, individual) - **Dr. Adam Milz*** — Hennepin County Psychological Services (Defendant, individual) - **Dr. Katheryn Cranbrook*** — Hennepin County Psychological Services (Defendant, individual) - **Dr. Kristen A. Otte*** — Hennepin County Psychological Services (Defendant, individual) *Metadata-Identified Individuals:* - **"barbj"*** — Metadata author of 137 documents / 105 cases (unidentified) - **"hernandezke" / "HernandezKE"*** — Metadata author of 225 documents / 101 cases - **"Hines, Anne"*** — Actual metadata author of evaluations attributed to Dr. Milz and Dr. Cranbrook - **"HoopmanA" / "Hoopmana"*** — Metadata author of case reassignment notices and synthetic filings - **"lakee"** — Metadata author of 17 of 20 "Odyssey Merge Batch Print Job" filings (NEW) - **"burrowsp"** — Metadata author of April 29, 2025 Rule 20 order and forensic navigator appointment (NEW) - **Andrew Reiland II*** — Metadata author of Carpenter's December 30, 2024 filing - **Camille A. King*** — Metadata author of Carpenter's January 14, 2025 filing - **"Hansen, Isabel"*** — Metadata author of Koch's April 3, 2025 competency order - **Amanda Burg*** — Associated with Nehring and Cole in document fabrication - **"GuzmanC"*** — Metadata author of Rogstad Rule 20 evaluation - **Virginia Kuberski** — Metadata author of Klein's fee waiver denials (NEW) - **"Rachel Pederson"** — Metadata author of Klein's April 12, 2024 pro se denial order (NEW) - **"Perry, Dolores"** — Metadata author of Klein's November 15, 2023 Rule 20 order (NEW) - **"Larison, Megan D (DHS)"** — Metadata author linked to same XMP toolkit as GuzmanC files (NEW) *Synthetic/Fabricated Defendants Referenced:* - **Sandra Phitsanoukanh Vongsaphay*** — Case 27-CR-23-2480 - **Adrian Michael Wesley*** — Foundational synthetic defendant (2017 cases) - **Lucas Patrick Kraskey** — 21 "barbj" orders; 34 Mercurio hearings; Carpenter cluster - **Aesha/AESHA Ibrahim Osman** — 15 "barbj" files; 10 orders - **Terrell Johnson** — 9 "barbj" files; 38 "hernandezke" files - **Gordon Eugene Sharp** — 7 "barbj" files; 27 Mercurio hearings; 8 Browne warrants - **Carmen Bendu Greaves** — 6 "barbj" files - **Makis D/Devell Lane** — 32 "hernandezke" files; Hudleston synthetic defendant - **Grahm Mark Fletcher** — 16 "hernandezke" files; 11 Mercurio hearings - **Rodrick Jerome Carpenter** — 12 "hernandezke" files - **Isaac Lee Kelley** — 3 "Hoopmana" synthetic files - **Aaron Dashaun Cherry** — Authentic December 6 order later overwritten by clone - **Ifrah Abdullahi Hassan** — Unique font code OLGBLK in 2 documents - **Angelic Denise Nunn/Schaefer** — Shared font suggests same individual under different names - **Juliet Kay Higgins, Rex A. Basswood Jr., Jacob J. Schech, Robert W. Balsimo** — Carpenter synthetic cases *Other:* - **Tom Arneson*** — ACA listed as defense counsel in 11 cloned filings (role reversal error) - **Thomas Prochazka*** — ACA active only in Guertin's case, inactive in all others - **Michael Biglow*** — Court-appointed attorney who delivered "Set B" discovery - **Michelle Guertin** — Plaintiff's mother, author of the genuine April 12, 2024 letter `*` = Already tracked in prior batches ### Key Entities / Organizations Referenced - U.S. District Court, District of Minnesota* - Hennepin County / Fourth Judicial District Court* - Minnesota Court Records Online (MCRO)* - Tyler Technologies / Odyssey Case Management System* - Minnesota Department of Health* - Minnesota Department of Human Services (DHS)* - Minnesota Department of Employment and Economic Development (DEED) (NEW — Nehring employment) - Hennepin County Criminal Justice Coordinating Committee (CJCC)* - Hennepin County Public Defender's Office* - Hennepin County Psychological Services* - Hennepin County Attorney's Office* - Minnesota Court of Appeals* (A24-0780, A25-0882) - U.S. Eighth Circuit Court of Appeals* - InfiniSet, Inc. (Delaware corporation)* - Netflix* - Scanline VFX / Eyeline Studios* - Light Field Labs* / OTOY* / Google LLC* / Alphabet Inc.* / YouTube* - World Economic Forum* - USC ICT / USC Cinema / USC Shoah Foundation* - DARPA / U.S. State Department / U.S. Army / Air Force* - U.S. Department of Justice* - Administrative Office of the United States Courts (NEW — PDF Producer metadata) - Adobe* (XMP Core, PDF Library, Acrobat Distiller, PScript5.dll, PDFMaker) - USPS* - MnCourtFraud.com / MnCourtFraud.Substack.com* - CourtListener.com* - MattGuertin.com / MattGuertin.Substack.com* - Minnesota Office of Lawyers Professional Responsibility (OLPR)* - Saint Peter State Security Hospital (NEW — destination for synthetic commitment scheme) - Vail Place (NEW — Guertin's civil commitment case worker organization) - Minnesota Secretary of State (NEW — InfiniSet registration) `*` = Previously referenced in prior batches ### Dates & Deadlines Mentioned - January 2023 – present — Alleged enterprise operation period - February 21, 2017 – April 19, 2024 — Span of Lamas hearings in synthetic dataset - May 27, 2021 – June 24, 2024 — Span of Caligiuri hearings in synthetic dataset - July 31, 2019 – July 15, 2024 — Span of Nehring-authored filings - January 11, 2023 – April 26, 2024 — Date range of "barbj" documents - April 4, 2023 – April 24, 2024 — Date range of "hernandezke" documents - January 1, 2023 – April 26, 2024 — MCRO search date range for case filtering - April 29–30, 2024 — Dates of MCRO document download - March 10, 2023 — Dr. Rogstad Rule 20 evaluation (metadata author: GuzmanC) - July 7, 2023 — Contested competency hearing; Perez as lead prosecutor - July 13, 2023 — First incompetency order (Borer/Browne; metadata author: Mercurio); duplicate "Order-Other" with tracking fonts - June 14, 2023 — Nehring-authored Order for Continuance in Guertin's case - January 11, 2024 — Dr. Milz Rule 20 evaluation (metadata author: Hines, Anne) - January 15, 2024 — Rivers texts "No court" - January 16, 2024 — Commitment order signed (Mercurio 8:27 AM, Klein 9:22 AM) before 1:30 PM hearing; waiver entered; "hernandezke" Notice of Remote Hearing - January 17, 2024 — Finding of Incompetency filed 7:29 AM (Index #25); master template for 127 clones - January 31, 2024 — Guertin signs stayed commitment waiver extension - February 1, 2024 — Surprise civil commitment hearing before Borer - April 3, 2024 — Motion for Judicial Notice filed (Index #28) - April 4, 2024 — Motion to Compel Discovery (Index #29); "Set B" metadata documented - April 12, 2024 — "Mother's Letter" incident - May 3, 2024 — MCRO Analysis Affidavit (Index #37) - May 9, 2024 — Klein's second Rule 20 order (metadata: HernandezKE; Index #40) - May 10, 2024 — Notice of Appeal; Petition for Discretionary Review - May 22, 2023 — Rivers "powerful people" phone call - May 24, 2024 — Klein's first fee waiver denial (metadata: Virginia Kuberski) - May 30, 2024 — Klein's second fee waiver denial (metadata: Virginia Kuberski) - July 8, 2024 — Federal civil rights lawsuit filed - July 15, 2024 — Klein recused; Order to Recuse authored by Nehring per metadata - July 16, 2024 — Rivers delivers discovery USB flash drive ("Set C") - August 7, 2024 — Exhibit W metadata filed into federal record - September 25, 2024 — 116-page ethics complaint against Rivers filed with MN OLPR - October 1, 2024 — Koch hearings; phantom docket entries at Index #102, #103 - October 15, 2024 — Askalani hearing; Carpenter appointed; 3rd Rule 20 ordered - November 8, 2024 — Stayed civil commitment expired; Vail Place positive report - November 15, 2023 — Klein orders second competency evaluation (metadata: "Perry, Dolores") - December 6, 2023 — Aaron Cherry authentic order (later overwritten by clone) - December 20, 2024 — Dr. Cranbrook Rule 20 evaluation (metadata: Hines, Anne) - December 30, 2024 — Cranbrook report received via email from Carpenter; "Objection to Competency" (metadata: Andrew Reiland II) - January 14, 2025 — "Demand or Request for Discovery" (metadata: Camille A. King) - January 30–31, 2025 — Case assigned to Hudleston; "Notice of Case Reassignment" (metadata: HoopmanA, Title: "Odyssey Merge Batch Print Job") - February 13, 2025 — Discovery "Set D" provided - February 28, 2025 — Supplemental evidence (Exhibits M–Q) filed - March 5, 2025 — Contested competency hearing; Donnelly waives confrontation; Hamid acknowledges altered photos - April 3, 2025 — Koch's competency order (metadata: Hansen, Isabel) — produced ~1 month late, appeared day after Guertin texted Carpenter - April 17, 2025 — Hearing before Hudleston; Donnelly refuses to file Motion to Dismiss; Faretta trigger - April 21, 2025 — Petition to Proceed Pro Se submitted - April 28, 2025 — Guertin files 50 evidence exhibits into docket; "Attempted Assassination" and "Judicial Simulation" affidavits - April 29, 2025 — Fourth Rule 20 evaluation ordered by Hudleston; forensic navigator appointed (metadata: burrowsp); Hamid's alleged perjury - May 30, 2025 — Hudleston "Order Other" — first ever judge-authored metadata in Guertin's docket - June 4, 2025 — Emergency Motion for Stay filed in A25-0882 - June 25, 2025 — This complaint filed (Doc. 116) ### Forensic Flags & Anomalies ### PDF-Level Metadata: - Producer field identifies "PyPDF2" as original creator and "iText® Core 7.2.3" (Administrative Office of the United States Courts) as modifier — confirming the document was Python-assembled then processed through CM/ECF. No custom metadata (Author, Title, Creator) survives. - The document is entirely native digital text — no pages are scanned, image-based, or show signs of alteration. All 121 pages are consistently formatted with uniform fonts, margins, and headers. ### Core Forensic Claims (from document content): - Central forensic claim: 162 of 163 criminal cases sharing the same three judicial officers appear to involve synthetic/fabricated defendants and documents - Post-dated signatures: 55 court documents bear digital signatures timestamped after filing dates - Timestamp cloning: 371 instances of byte-for-byte duplicate timestamps across different orders and cases - Signature image reuse: 1,183 duplicate signature graphics, sometimes mismatched to judge names - Fabricated mail: 40 identical USPS return-mail scans reused across synthetic cases - 2-bit image filings: Court documents rendered as binary images lacking scan artifacts - Mother's Letter incident: Synchronized cross-docket manipulation with matching SHA-256 hashes between response letters; unique header hashes appearing nowhere else in 3,601 files - Metadata author misattribution: Multiple Rule 20 evaluations attributed to different examiners sharing identical metadata authors (GuzmanC, Hines Anne) - "barbj" centralization: 137 documents / 105 cases; 127 of 129 incompetency orders - "hernandezke" centralization: 225 documents / 101 cases; only 47 unique defendants - Nehring cross-contamination: "Adrian Wesley" title in Guertin's Order for Continuance and Order to Recuse - Enterprise PDF toolchain: Adobe XMP Core 5.1.0-jc003, PScript5.dll, Acrobat Distiller - CFF font tracking codes: Hidden strings in 1,000+ documents; specific .cff hash links Guertin to 165 synthetic documents including "Adrian Wesley" 2017 filings - TTF font pair from July 13, 2023 duplicate order connects to 1,021 documents across 160+ cases - Role reversal: Prosecutor Arneson listed as defense counsel in 11 cloned filings - Statistical anomalies: Cole "active" only in Guertin's case out of 53 (<0.3% probability); Prochazka active only in Guertin's case - 4th Rule 20 evaluation ordered April 29, 2025 based on legal filings — alleged judicial retaliation - Hudleston's May 30, 2025 order is the first and only document in Guertin's entire docket where the named judge is also the metadata author — appearing only after metadata exposure - Koch's April 3, 2025 order appeared the day after Guertin texted Carpenter asking about it - Carpenter simultaneously listed as defense and prosecution in synthetic case 27-CR-22-24627 ### NEW metadata authors identified in this processing: - "lakee" — 17 of 20 "Odyssey Merge Batch Print Job" filings - "burrowsp" — April 29, 2025 Rule 20 order and forensic navigator appointment - Virginia Kuberski — Klein's fee waiver denials - "Rachel Pederson" — Klein's April 12, 2024 pro se denial order - "Perry, Dolores" — Klein's November 15, 2023 Rule 20 order - "Larison, Megan D (DHS)" — linked to same GuzmanC toolkit ### Cross-References - Federal case 0:24-cv-02646-JRT-DLM (Guertin v. Hennepin County) — this is Doc. 116 - State criminal case 27-CR-23-1886 - State appellate cases A24-0780, A25-0882 - Federal case 3:17-cv-04006-JST (Declaration of Hao Li — referenced indirectly through patent narrative) - Prior federal filings: Doc. 23 (Exhibit P — "Conspiracy of Commitment"), Doc. 47 (Exhibit W), Doc. 77 (ethics complaint), Doc. 99 (transcript), Doc. 102 (transcript), Doc. 103 (patent valuation), Doc. 115 (emergency motion) - Civil commitment case 27-MH-PR-23-815 - Synthetic case 27-CR-23-2480 (Vongsaphay)* - Adrian Wesley cases: 27-CR-17-1555, 27-CR-17-8342, 27-CR-17-22909* - Isaac Kelley synthetic cases: 27-CR-21-20529, 27-CR-22-5532, 27-CR-22-7953 (NEW) - Filing #1* (Motion for Judicial Notice) — Rogstad metadata first documented - Filing #2* (Affidavit of Fact, May 6) — discovery fraud; Rivers evidence - Filing #3* (Affidavit of Fact, Apr 9) — first-person narrative - Filing #6* (Attempted Assassination affidavit) - Filing #7* (Judicial Simulation affidavit) — January 2024 conspiracy timeline - Filing #8* (Netflix Whistleblower Part 1) - Filing #9* (Motion for Substitute Counsel) — Rivers allegations - Filing #10* (Judicial Notice / Docket Anomalies) — many of same anomalies expanded here - Filing #11* (Exhibits M–Q) — patent theft narrative expanded here - Filing #12* (Prior catalog entry of this same document — text-extraction only; superseded by this entry) --- ## Filing #16 — Exhibit AF: Forensic Analysis of AI-Generated Netflix Fraud (Round 2) | Field | Detail | |---|---| | Filing # | 16 | | Date Filed | September 30, 2024 | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Exhibit (AF) — Digital Forensic Analysis Reports with Evidence Compilation | | Case/Court | 0:24-cv-02646-JRT-DLM / U.S. District Court, District of Minnesota (Judge John R. Tunheim, Magistrate Judge Douglas L. Micko) | | Pages | 68 | | Bates / Doc ID | Doc. 83, CASE 0:24-cv-02646-JRT-DLM; internal pagination "Exhibit AF \| Netflix Fraud \| p. 1–66" | ### Comprehensive Summary This 68-page exhibit, designated "Exhibit AF," was filed as Document 83 in the federal civil case 0:24-cv-02646-JRT-DLM on September 30, 2024. It is subtitled "NETFLIX FRAUD (Round 2)" and contains two complete "Digital Forensic Analysis Reports" (numbered 02 and 03), followed by an extensive evidence compilation consisting of links to video files hosted on Odysee, Rumble, and Storj cloud storage, links to YouTube videos, screenshots of cloud storage file directories, and quotations from books on psychopathy/ponerology. The document's cover page (p. 2) frames the exhibit as presenting forensic proof that AI-generated videos were created for fraudulent academic research purportedly originating in 2006. It names the University of Southern California, Google/YouTube, the US Army/Military, and "MANY others" as directly involved. It also alleges that a "completely fake, AI Generated version of Holocaust Survivor 'Pinchas Gutter'" was created to further an ongoing criminal conspiracy. Two Substack URLs are cited as further references. ### Digital Forensic Analysis Report 02 — "LS6RHL Analysis: Frame Patterns and Pixel Artifacts Examination" (pp. 3–14) This report is prepared for Matthew D. Guertin by "Dr. Alex Mercer, Ph.D., chatGPT Digital Forensic Investigator" — explicitly identified as a ChatGPT-generated persona — and dated September 29, 2024. The report analyzes four image grids extracted from video footage associated with the "Light Stage 6 Relighting Human Locomotion" (LS6RHL) research project, originally attributed to USC's Institute for Creative Technologies and published at EGSR 2006 by Per Einarsson et al. The analyzed materials are: - LS6RHL1_01_20-sequential-frames.jpg (Grid 1: 20 sequential frames) - LS6RHL1_02_Segmentation-sets.jpg (Grid 2: segmentation issues) - LS6RHL2_02_30-sequential-frames.jpg (Grid 3: 30 sequential frames) - LS6RHL2_04_Digital-Region-Shifting.jpg (Grid 4: digital region shifting) The report's methodology includes visual inspection, segmentation analysis, pixel pattern investigation, and comparative frame-by-frame analysis. For each grid, the report identifies anomalies: facial feature misalignment across sequential frames (Grid 1); "blocky" segmentation artifacts where body parts appear to shift independently (Grid 2); facial feature "drift" across 30 frames (Grid 3); and abrupt digital region shifting with striping patterns (Grid 4). In each case, the report concludes these artifacts are characteristic of AI-based generation models rather than standard CGI or video editing from 2006. The report then addresses the critical temporal claim: the analyzed images are being presented as having been produced in 2006. The report argues this is "highly improbable" for several reasons: (1) GANs and deep learning-based image generation were not introduced until 2014 and thus the observed artifacts would not have been possible in 2006; (2) 2006 CGI tools (After Effects, Maya, 3ds Max) relied on keyframing and manual compositing, which would not produce these kinds of artifacts; (3) the computational power needed for AI image generation far exceeded what was available in 2006; and (4) either the date is incorrect or the visuals were manipulated using modern techniques and retroactively attributed to 2006. The report references the Eurographics Symposium on Rendering (2006) paper "Relighting Human Locomotion with Flowed Reflectance Fields" by Per Einarsson, Charles-Felix Chabert, Andrew Jones, Wan-Chun Ma, Bruce Lamond, Tim Hawkins, Mark Bolas, Sebastian Sylwan, and Paul Debevec, from USC Centers for Creative Technologies and National Taiwan University. ### Digital Forensic Analysis Report 03 — "Pinchas Gutter Analysis: Frame and Feature Shifting Forensic Review" (pp. 15–23) Also prepared by the ChatGPT-generated "Dr. Alex Mercer" for Guertin and dated September 29, 2024, this report examines four image grids extracted from video footage titled "Pinchas Analysis." The subject is Pinchas Gutter, identified as a Holocaust survivor whose likeness appears in the USC/Shoah Foundation "New Dimensions in Testimony" interactive hologram project. The analyzed materials are: - Pinchas-Grid_01_facial-shift_cc.jpg (Grid 1: facial shifting with color curves applied) - Pinchas-Grid_02_face-shift-cc.jpg (Grid 2: feature shifting with color curves) - Pinchas-Grid_03_face-feature-shift.jpg (Grid 3: face feature shifting without color curves) - Pinchas-Grid_04_Background-Shift.jpg (Grid 4: background shifting between frames) The methodology again includes visual inspection, pixel region examination, comparative analysis, and explanation of AI artifacts. The findings parallel Report 02: facial features shift unnaturally between frames; color curve analysis reveals distinct regions of shifting; background elements shift erratically while the subject remains static; and temporal inconsistency is pervasive. The report concludes the video frames were "likely generated or manipulated by an advanced AI model." A notable metadata discrepancy is flagged: A YouTube video titled "Jewish Education through Holograms" by The Jewish Week/Aaron Herman has a YouTube upload date of 2/15/2013, but its Google Inc. creation metadata shows 2023:01:10 23:51:19 — a discrepancy of nearly 10 years. A second video, "New Dimensions in Testimony Relighting Method" by USC-ICT, has a YouTube upload date of 3/15/2013 but metadata creation date of 2023:10:14 01:38:18 — also a ~10-year discrepancy. ### Evidence Compilation and Cloud Storage Directory Listings (pp. 25–68) The remainder of the exhibit (approximately 43 pages) consists of: 1. **Links to video evidence** hosted across multiple platforms (Odysee, Rumble, Storj) — including frame-scrubbing analysis videos, the original LS6RHL footage, Pinchas Gutter analysis videos, audio analysis, color banding analysis, and a 2023 SIGGRAPH presentation comparison. 2. **Links to Storj cloud storage directories** labeled "micro-sd-shared-with-police" containing folders for Netflix Fraud evidence, patent documents, academic papers, MAXQDA analysis output, InfiniSet prior art filings, and USPTO materials. 3. **Links to Proton Drive** for a LinkedIn search/count graph with PGP verification, a Plymouth MN police report dated 9/7/2023, and correspondence to Senator Amy Klobuchar dated 9/20/2023. 4. **Screenshots of cloud storage file browsers** (pp. 30–68) showing the contents of numerous directories including: brand-identity files (InfiniSet trademark materials); infiniset-pct-patent-int (PCT patent application materials in multiple groups); Trojansky-Netflix patent files; "round-1-photo-robot" full web page collections (22 GB ZIP); certified mailer images for 3rd party prior art submission; Netflix press release materials; Google-InfiniSet correspondence/screenshots; patent utility filing images (technical drawings of motorized rotatable treadmill); micro-sd-shared-with-police root directory; academic papers collected on Aug 12-13, 2023 (hundreds of PDFs spanning computer vision, 3D reconstruction, motion capture, facial reenactment, and related topics); MAXQDA output with word cloud analysis; Paul Debevec SIGGRAPH 2023 materials; USC Cinema LinkedIn search evidence; CNN and GAN AI Content Detection research; Amy Klobuchar correspondence bucket; and extensive evidence collected on Aug 14 and Aug 15, 2023. 5. **Quotations from books** interspersed between directory screenshots: Martha Stout's "The Sociopath Next Door," Daniel Jones' "Snake in the Grass," and Andrzej Łobaczewski's "Political Ponerology" — all relating to psychopathy and pathological systems of control. ### Legal Issues & Arguments Raised - Fraud upon academic institutions and the public through fabrication/backdating of research videos claimed to originate in 2006 - Criminal conspiracy involving USC, Google/YouTube, US Army/Military, Netflix, and others - AI-generated deepfake creation of Holocaust survivor Pinchas Gutter's likeness for fraudulent purposes - Patent fraud — connection between Debevec's claimed 2006 research and subsequent patent filings - Prior art relevance — Guertin's InfiniSet patent (US 11,577,177) vs. Trojansky/Netflix patent (US 11,810,254) - YouTube metadata discrepancies as evidence of content manipulation/replacement - Technology anachronism — artifacts consistent with post-2014 AI generation appearing in materials claimed to be from 2006 ### Factual Allegations & Key Assertions - Video frames from the "Light Stage 6 Relighting Human Locomotion" project exhibit pixel artifacts, feature misalignment, segmentation errors, striping patterns, and region shifting characteristic of modern AI generation models - These artifacts could not have been produced by 2006-era CGI technology (After Effects, Maya, 3ds Max), which used keyframing and manual compositing - GANs were not introduced until 2014; the observed artifacts are consistent with GAN-era or later AI generation - The computational hardware available in 2006 was insufficient for AI-based image/video generation - Video frames of Pinchas Gutter from the "New Dimensions in Testimony" project show similar AI generation artifacts - YouTube metadata for multiple videos shows Google Inc. creation dates in 2023 despite upload dates in 2013, suggesting content was replaced or recreated - Evidence was first discovered on August 8, 2023 - Evidence was shared with Plymouth, MN police on September 7, 2023 via micro-SD card - Evidence was shared with Senator Amy Klobuchar on September 20, 2023 - Paul Debevec (Netflix Eyeline Studios) presented at SF ACM SIGGRAPH 2023 and allegedly used ChatGPT to help write an academic paper - USC Cinema searched for Guertin on LinkedIn twice (per Guertin's evidence) - InfiniSet Inc. filed a 3rd party prior art claim against the Netflix/Trojansky patent - Hundreds of academic papers were collected by Guertin on August 12-13, 2023 covering 3D reconstruction, motion capture, facial reenactment, and related computer vision topics — largely authored by or citing Christian Theobalt and related researchers ### Procedural Posture Filed as Exhibit AF (Document 83) in the federal civil case 0:24-cv-02646-JRT-DLM on September 30, 2024. This exhibit is part of Guertin's ongoing federal litigation and represents the "Round 2" presentation of his Netflix fraud allegations. Round 1 was previously presented (see Filing #8, Netflix Whistleblower Part 1). The exhibit supports Guertin's broader claims of a conspiracy involving patent theft, fraudulent academic research, and cover-up by major technology companies and academic institutions. ### Exhibit / Attachment Inventory This filing is itself an exhibit (AF). Internal sub-exhibits and referenced materials include: - **Report 02** — LS6RHL Analysis: Frame Patterns and Pixel Artifacts Examination (pp. 3–14) - **Report 03** — Pinchas Gutter Analysis: Frame and Feature Shifting Forensic Review (pp. 15–23) - **LS6RHL1_01_20-sequential-frames.jpg** — Grid of 20 sequential frames from LS6RHL video - **LS6RHL1_02_Segmentation-sets.jpg** — Grid showing segmentation issues - **LS6RHL2_02_30-sequential-frames.jpg** — Grid of 30 sequential frames - **LS6RHL2_04_Digital-Region-Shifting.jpg** — Grid showing digital region shifting - **Pinchas-Grid_01_facial-shift_cc.jpg** — Facial shifting with color curves - **Pinchas-Grid_02_face-shift-cc.jpg** — Feature shifting with color curves - **Pinchas-Grid_03_face-feature-shift.jpg** — Face feature shifting without color curves - **Pinchas-Grid_04_Background-Shift.jpg** — Background shifting between frames - Multiple .mp4 video files hosted on Odysee, Rumble, and Storj (LS6RHL FrameScrubbing 1 & 2, Light Stage 6 Relighting Human Locomotion 480p, Holocaust_10_26_2023, Pinchas-Gutter-Ai-Fraud-Color-Curve-Scrub-Analysis-01, Fraudulent-Pinchas-Gutter-Audio-Analysis, Egsr2006_Rhl-Image Color Banding, EXACT Same Technology Since 2006, 2023-SIGGRAPH videos) - **Egsr2006_Rhl.pdf** — The EGSR 2006 academic paper - **Debevec-2006-Patents-vs-Claimed-2006-Research.jpg** — Comparison image - Extensive Storj cloud storage directories (micro-sd-shared-with-police, netflix-fraud, amy, infiniset-pct-patent-int, docs2, round-1-photo-robot) - Proton Drive links for Plymouth PD report and Klobuchar correspondence - **Einarsson et al., "Relighting Human Locomotion with Flowed Reflectance Fields," EGSR 2006** — Reproduced title page/credit block ### Visual Evidence Inventory - **[Page 3] Screenshot — Video player**: Shows a frame from LS6RHL__FrameScrubbing1.mp4 in what appears to be a media player (likely Adobe Premiere or similar). A male subject in a gray/green shirt is visible against a dark background with bright studio lights. Timeline visible at bottom showing timecodes from ~00:23:06 to ~00:27:14. A play button overlay is centered. The interface shows menu items: View, Select, Marker, Add, Strip, Image, and a Shuffle toggle. No obvious alterations to the screenshot itself. - **[Page 4] Screenshot — Video player**: Shows a frame from LS6RHL__FrameScrubbing2.mp4. Two side-by-side close-up views of a bald male subject's face against a dark background. Timeline at bottom shows timecodes from ~00:51:26 to ~00:58:06. Same media player interface as above. - **[Page 5] Screenshot — Video player**: Shows title card from "Light Stage 6 Relighting Human Locomotion480p.mp4." Black background with white text reading "Light Stage 6 / Postpro[cessing Co]ntrol of / Viewpo[int Illum]ination / University o[f Southern] California / Centers for Creative Technologies." Play button overlay partially obscures text. This is the original source video being analyzed. - **[Page 6] Image grid — Grid 1**: 'LS6RHL1_01_20-sequential-frames.jpg' showing 20 sequential frames (5 rows × 4 columns) of a male subject in a gray/green shirt under studio lighting. Visible artifacts include apparent misalignment of facial features across frames; pixel distortions visible in background and foreground; some frames show the subject from different angles with inconsistent rendering. Dark/black background with visible studio light fixtures. - **[Page 7] Image grid — Grid 2**: 'LS6RHL1_02_Segmentation-sets.jpg' showing approximately 20 frames (5 rows × 4 columns) of a male subject in a dark red/maroon shirt, full-body view, walking on what appears to be a treadmill. Dark background. Visible "blocky" artifacts and apparent segmentation boundaries. Some frames show the subject from different angles. - **[Page 8] Image grid — Grid 3**: 'LS6RHL2_02_30-sequential-frames.jpg' showing approximately 30 close-up frames of a bald male subject's head (6 rows × 5 columns). Red horizontal lines/markers visible across many frames at consistent positions, appearing to be analysis overlay markers. White vertical line visible in one central frame. Facial features show apparent variation across frames. - **[Page 9] Image grid — Grid 4**: 'LS6RHL2_04_Digital-Region-Shifting.jpg' showing approximately 16 close-up frames (4 rows × 4 columns) of a bald male/bearded male subject. Significant variation in background coloring (some pink/red-tinted, some gray, some dark). The last row includes what appears to be a different subject (longer hair, different lighting). Region boundaries visible between some frames. - **[Page 10] ChatGPT conversation bubble**: A gray/dark chat bubble is visible at the bottom of the page containing the text: "What would your opinion be if I told you that the images analyzed in the 'LS6RHL Analysis' are being presented as being produced in the year 2006?" — This is a screenshot of a ChatGPT conversation prompt, confirming the "Dr. Alex Mercer" analysis was generated through interactive ChatGPT prompting. - **[Page 11] YouTube screenshot**: Shows the video "The Full Spectrum of Virtual Production - SF ACM SIGGRAPH 2023" from the ACMSIGGRAPH YouTube channel. The thumbnail shows Paul Debevec (identified by name overlay "Paul Debevec, Netflix Eyeline Studios") with a smaller picture-in-picture window showing another individual labeled "Henry LaBretz" (partially visible). The video shows 3,649 views, uploaded May 22, 2023, with 60 likes. Subscription count shows 61.1K. Description states Paul Debevec presented to the San Francisco Chapter of ACM SIGGRAPH on May 17, 2023. The URL points to timestamp 59 minutes. - **[Page 12] Two images side by side**: Left image shows a still from the Einarsson et al. "Relighting Human Locomotion" EGSR 2006 video — a Light Stage setup with a subject surrounded by an array of lights, with a small picture-in-picture of a bearded man in the lower right (labeled "Paul Debevec"). Right side is the same SIGGRAPH video PiP. Caption reads "Einarsson et al. Relighting Human Locomotion. EGSR 2006." - **[Page 13] Two images**: Top image shows the Contributors credit screen from the Einarsson et al. EGSR 2006 video, listing: Per Einarsson, Charles-Felix Chabert, Wan-Chun Ma, Andrew Jones, Bruce Lamond, Tim Hawkins (left column); Sebastian Sylwan, Aimee Dozois, Brian Miller, Katsunori Ishikawa, Tomas Pereira, Paul Debevec (right column). Special Thanks section lists numerous individuals and organizations. Copyright line reads "© 2006 University of Southern California." A small PiP in lower right shows Paul Debevec. Caption: "Einarsson et al. Relighting Human Locomotion. EGSR 2006." - **[Page 14] Academic paper header**: Reproduces the title page of the EGSR 2006 paper: "Eurographics Symposium on Rendering (2006) / Tomas Akenine-Möller and Wolfgang Heidrich (Editors) / Relighting Human Locomotion with Flowed Reflectance Fields" with authors and institutional affiliations (USC CCT, National Taiwan University, USC School of Cinema-Television). - **[Page 15] Screenshot — Video player**: Shows Pinchas-Gutter-Ai-Fraud-Color-Curve-Scrub-Analysis-01.mp4. Split screen: left half shows an elderly bald man (Pinchas Gutter) in a dark jacket against a dark background; right half shows the same face processed with color curve manipulation revealing a vivid multi-colored heat-map-like overlay (cyan, magenta, green). Timeline at bottom shows timecodes from ~05:24:02 to ~05:31+. - **[Page 16] Screenshot — Video player**: Shows Fraudulent-Pinchas-Gutter-Audio-Analysis.mp4. Split screen: left shows two views of an elderly man (Pinchas Gutter) at different ages/settings — one in a dark suit, one in lighter clothing; right shows a timeline/waveform editor with colored audio blocks. An audience is visible in the lower portion of the left frame. Timeline markers and audio strip names visible. - **[Page 18] Image grid — Pinchas Grid 1**: 'Pinchas-Grid_01_facial-shift_cc.jpg' showing approximately 20 frames (5 rows × 4 columns) of Pinchas Gutter's face processed with color curve manipulation. The images appear in cyan/magenta/gray tones against a dark background. Facial features show apparent shifting and misalignment between frames. - **[Page 19] Image grid — Pinchas Grid 2**: 'Pinchas-Grid_02_face-shift-cc.jpg' showing approximately 15 frames (5 rows × 3 columns) processed with different color curves (yellow/magenta/green dominant tones). The face appears distorted with vivid false-color mapping against a green background. - **[Page 20] Image grid — Pinchas Grid 3**: 'Pinchas-Grid_03_face-feature-shift.jpg' showing approximately 20 frames (5 rows × 4 columns) alternating between color-curve-processed views and standard views of the elderly subject. Some frames show vivid magenta/green false-color; others show standard video frames. Mix of close-up and slightly wider shots. - **[Page 21] Image grid — Pinchas Grid 4**: 'Pinchas-Grid_04_Background-Shift.jpg' showing approximately 20 frames (5 rows × 4 columns) with color curve analysis applied. Vivid green background dominates most frames with magenta/pink tones on the subject. The subject appears seated. A patterned background is visible with flower-like repeating motifs. The last row shows dramatically different framing/lighting. - **[Page 22] YouTube embed screenshot**: "Jewish Education through Holograms" from The Jewish Week channel. Shows a dark image with what appears to be a bearded man and some kind of projected/holographic display. "Watch on YouTube" button visible. Notable metadata discrepancy highlighted in text: YouTube upload date 2/15/2013 vs. Google Inc. creation date 2023:01:10 23:51:19 (bolded). - **[Page 23] Screenshot — Video player**: Holocaust_10_26_2023.mp4 showing what appears to be a classroom or laboratory setting with several people, including a woman with blonde/red hair and others near electronic equipment/displays. - **[Page 24] Two YouTube embed screenshots**: Top: "New Dimensions in Testimony Relighting Method" from USC-ICT channel showing Pinchas Gutter seated (left: green-tinted 3D scan view; right: relighted final version with "Surface Orientation" and "Gloss" labels). Bottom: "New Dimensions in Testimony - USC ICT and SFI - Classroom Concept" from ICT Graphics Lab channel showing students in a classroom setting with Gutter's projected image. YouTube overlay shows "The Holocaust - The Holocaust was the genocide of European Jews during World..." information card. - **[Page 25] Two YouTube embed screenshots**: Top: "How USC's Automultiscopic 3D Display Works" from Adam Savage's Tested channel showing a person near a large display setup with green lighting. Upload date 9/5/2016, metadata 2016:09:06 03:50:02 (dates consistent). Bottom: "New Dimensions in Testimony preserves Holocaust survivors stories as holograms" from Digital Trends channel showing "Speaking with Holograms" text overlay with an elderly man's projected image and audience. Upload 6/6/2017, metadata 2017:05:26 19:49:45 (dates approximately consistent). - **[Page 26] Two YouTube embed screenshots**: Top: "New Dimensions in Testimony - USC ICT - Relighting Method" from ICT Graphics Lab showing "Relighting results: Grace Cathedral" text overlay with Gutter's relighted image. Upload 2/8/2013. Bottom: "From the 60 Minutes archive: Letting future generations speak with Holocaust survivors" from CBS 60 Minutes channel showing Gutter with a female interviewer. Upload 4/5/2023. - **[Pages 32–68] Cloud storage directory screenshots** (approximately 37 pages): All appear to be screenshots of a dark-themed web file browser (likely Storj DCS or similar cloud storage interface). Each screenshot shows: - File/folder names, types, sizes, and dates - Navigation breadcrumbs showing directory paths - "Upload," "New Folder," and settings buttons - Gallery/List view toggle - The interface theme is consistently dark (dark navy/black background, colored text for filenames) Specific directories shown include: - [Page 32] docs2 > brand-identity: 11 InfiniSet trademark/branding files, dated Sep 18, 2023 - [Page 32] infiniset-pct-patent-int > Group_1: 8 items including PCT patent application files - [Page 33] Group_1 > Attachments-PCT Patent Application (6 items dated Sep 14, 2023) - [Page 33] infiniset-pct-patent-int > Group_2: 7 items including patent application docs - [Page 34] amy > InfiniSet_Inc_USPTO_share > Trojansky-Netflix-Patent-Granted: 4 PDFs dated Oct 10, 2023 - [Page 34] round-1-photo-robot > full web pages downloaded: 1 item "FULL WEB PAGE COLLECTIONS.zip" at 22 GB, Oct 6, 2023 - [Page 34] Video player screenshot of "The Psychology of Psychopaths Predators who Walk Among Us.mp4" (36.06 MB) with Martha Stout quote from "The Sociopath Next Door" - [Page 35] amy > 3rdPartySubmission > Certified Mailer Images: 11 image files of certified mailer screenshots (BryonyGagan, Eyeline Registered Agent, GregPeters, NetflixAmyReinhard, NetflixDavidHyman, NetflixSpencerWang, RobertHulse, ScanlineTrojansky, ScottMiller, TedSarandos, TrojanskyEyeline), all 1 MB, Oct 10, 2023 - [Page 35] Trojansky_Netflix - Press Release > Original PDFs and Images for PRESS: 8 items including Acquisition_Press.pdf, Eyeline_Studios.pdf, Netflix_2022Q1_Shareholders_Letter.pdf, Netflix_Lawfirm_and_Attorney.pdf, Scanline_VFX.pdf - [Page 36] docs2 > Google-Infiniset: 20 items including timestamped screenshots (2023-03 through 2023-06) and GOOGLE_InfiniSet PDFs - [Pages 37–38] infiniset-pct-patent-int > Group_1 > Patent Utility Filing Images: ~24 technical drawings of what appears to be a motorized rotatable treadmill system (FIG 1 through FIG 27), all dated Sep 14, 2023 - [Pages 39–40] Group_1 > Attachments-Draft Non-Provisional Patent Application > Images: ~16 patent drawing pages plus proximity sensor detail images - [Page 40] Second video player screenshot with Daniel Jones "Snake in the Grass" quote - [Page 41] Understanding The Very Clear Patent Issue... directory: articles about patent law duties of disclosure, first-to-file rules, and related legal topics - [Page 41] micro-sd-shared-with-police root: folders for CNN and GAN AI Content Detection, Microsoft Fraud, Netflix Fraud, Other Reports, and the psychopaths video - [Page 42] Paul Debevec - SIGGRAPH 2023: Adobe After Effects Auto-Save folder, discovery folders, screencaps PDF, and SIGGRAPH video (476 MB) - [Page 42] USC Cinema - Searched Me Twice on LinkedIn: LinkedIn search PDFs from Dec 2022 and Feb 2023, raw email data, screencaps - [Page 43] Original_Downloads_Upon_Discovery subfolder with SIGGRAPH video files - [Page 43] CNN and GAN AI Content Detection: ~19 items including academic papers on AI artifact detection, synthetic face detection, frequency analysis for deep-fakes - [Page 44] Netflix Fraud root folder: ~22 subfolders covering academic papers, AI analysis, build files, email sequences, evidence collections, InfiniSet filings, MAXQDA output, Paul Debevec materials, Trojansky/Netflix materials, USC Cinema LinkedIn evidence, Word Cloud Analysis, plus standalone images and a 778 MB TimeSequence_All.pdf - [Page 45] SIGGRAPH_2023_Debevec_images: ~22 images named SIGGRAPH_2023_0 through _17 - [Page 46] amy root bucket: InfiniSet_Inc_USPTO_share folder, Email To Amy Klobuchar.pdf (Sep 19, 2023), FraudLinks documents in multiple formats - [Page 46] USC Cinema LinkedIn Search Screencaps From Phone subfolder with phone screencap PDFs from May 15, 2023 - [Pages 47–56] Academic Papers Collected On Aug[12-13]2023 - Original ALL: Spanning 6+ pages of screenshots, showing approximately 150+ academic papers. These are predominantly computer vision, 3D reconstruction, motion capture, facial reenactment, and CGI research papers. Many are authored by or affiliated with Christian Theobalt (denoted "THEOBALT_" prefix). Papers span from approximately 2001 to 2023 and cover topics including: multi-view reconstruction, facial performance capture, GAN-based synthesis, neural rendering, body tracking, deformable models, and light field analysis. This collection appears to represent Guertin's research into the state of the art in computer-generated human imagery. - [Page 57] HIGHLIGHTED PAPERS subfolder: ~20 selected papers from the larger collection - [Page 57] MAXQDA Output: folders for copied data, Netflix-InfiniSet comparison context, Reports, Word Clouds, plus individual word cloud analysis images and an XLSX comparison file - [Page 58] Word Cloud Analysis: ~18 items including MAXQDA_Analysis.pdf, word cloud PNGs comparing Guertin InfiniSet, Trojansky Netflix, and Debevec patent/paper language - [Page 58] Second Łobaczewski "Political Ponerology" quote on pathocracy - [Pages 59–62] Evidence Collected On Aug[14]2023: ~75+ items including ADA481779_MIL_PDF.pdf (military document), videos of Light Stage technology, academic papers, screencaptures from various websites about Paul Debevec and LightStage technology, funnycatvideos.co.watch screencaptures (apparently related to LightStage content hosted on unexpected domains), wiki pages in multiple languages about LightStage - [Page 62] Third Łobaczewski quote on pathocracy - [Pages 63–68] Evidence Collected On Aug[15]2023: ~100+ items including DBLP bibliography pages for Paul Debevec, multiple LightStage-related web page captures, Wikipedia entries in various languages, Stanford course materials, interviews with Debevec, sensor papers, Google research blog captures, and various video alignment files ### Key People Referenced - **Matthew David Guertin*** — Plaintiff/Defendant, Pro Se (client commissioning reports) - **"Dr. Alex Mercer, Ph.D."** — Explicitly identified as a ChatGPT-generated forensic investigator persona; author of Reports 02 and 03 - **Paul Debevec*** — USC ICT researcher / Netflix Eyeline Studios; central figure in alleged fraud; presenter at SIGGRAPH 2023; named on patents and academic papers - **Pinchas Gutter** — Holocaust survivor; subject of alleged AI-generated deepfake in "New Dimensions in Testimony" project - **Per Einarsson** — Lead author of EGSR 2006 "Relighting Human Locomotion" paper - **Charles-Felix Chabert** — Co-author, EGSR 2006 paper - **Andrew Jones** — Co-author, EGSR 2006 paper - **Wan-Chun Ma** — Co-author, EGSR 2006 paper (National Taiwan University) - **Bruce Lamond** — Co-author, EGSR 2006 paper - **Tim Hawkins** — Co-author, EGSR 2006 paper - **Mark Bolas** — Co-author, EGSR 2006 paper - **Sebastian Sylwan** — Co-author, EGSR 2006 paper - **Aimee Dozois** — Contributor, EGSR 2006 video credits - **Brian Miller** — Contributor, EGSR 2006 video credits - **Katsunori Ishikawa** — Contributor, EGSR 2006 video credits - **Tomas Pereira** — Contributor, EGSR 2006 video credits - **Tomas Akenine-Möller** — Editor, Eurographics Symposium on Rendering 2006 - **Wolfgang Heidrich** — Editor, Eurographics Symposium on Rendering 2006 - **Aaron Herman** — Reporter, The Jewish Week (YouTube video on Jewish education through holograms) - **Henry LaBretz** — Visible in SIGGRAPH 2023 video PiP - **Ted Sarandos** — Referenced via certified mailer image filename (Netflix executive) - **Greg Peters** — Referenced via certified mailer image filename (Netflix executive) - **Amy Reinhard** — Referenced via certified mailer image filename (Netflix executive) - **David Hyman** — Referenced via certified mailer image filename (Netflix executive) - **Spencer Wang** — Referenced via certified mailer image filename (Netflix executive) - **Scott Miller** — Referenced via certified mailer image filename - **Robert Hulse** — Referenced via certified mailer image filename - **Bryony Gagan** — Referenced via certified mailer image filename - **Trojansky** (first name not specified on this document; previously identified as "Scanline Trojansky")* — Referenced via certified mailer images and patent documents - **Amy Klobuchar*** — U.S. Senator; recipient of evidence package dated 9/20/2023 - **Martha Stout** — Author, "The Sociopath Next Door" (quoted) - **Daniel Jones** — Author, "Snake in the Grass" (quoted) - **Andrzej Łobaczewski** — Author, "Political Ponerology" (quoted) - **Christian Theobalt** — Researcher; extensively represented in collected academic papers (dozens of papers prefixed "THEOBALT_") - **Adam Savage** — Host, "Tested" YouTube channel (USC display video) ### Key Entities / Organizations Referenced - **University of Southern California (USC)** — Institute for Creative Technologies (ICT), Vision and Graphics Lab, Centers for Creative Technologies, School of Cinema-Television - **Netflix / Netflix Eyeline Studios*** — Named as central party in alleged fraud; patent holder - **Google / YouTube*** — Content hosting platform; metadata discrepancies flagged; Google Inc. creation dates on YouTube videos - **US Army / US Military** — Named as "directly involved"; ADA481779_MIL_PDF.pdf in evidence files - **Shoah Foundation / USC Shoah Foundation** — "New Dimensions in Testimony" project - **Scanline VFX** — Referenced in press release materials - **InfiniSet Inc.*** — Guertin's company; patent holder (US 11,577,177) - **United States Patent and Trademark Office (USPTO)*** — Patent filings and 3rd party submissions - **Plymouth, MN Police Department*** — Police report #23033797 referenced - **ACM SIGGRAPH** — Conference where Debevec presented - **Eurographics Symposium on Rendering (EGSR)** — Published the 2006 paper - **CBS 60 Minutes** — Featured New Dimensions in Testimony - **Digital Trends** — YouTube coverage of hologram project - **Adam Savage's Tested** — YouTube coverage of USC display - **The Jewish Week** — YouTube video on hologram education - **National Taiwan University** — Co-affiliated institution on EGSR 2006 paper - **WIPO*** — Trademark filing referenced - **Proton Drive** — Evidence hosting platform - **Storj** — Decentralized cloud storage hosting evidence - **Odysee** — Video hosting platform - **Rumble** — Video hosting platform - **MAXQDA** — Qualitative data analysis software used for word cloud/text analysis - **Forcepoint** — Referenced in prior filing context - **DTIC (Defense Technical Information Center)** — Implied via military PDF ### Dates & Deadlines Mentioned - **2006** — Claimed year of production for LS6RHL video and EGSR paper; central to the temporal fraud allegation - **2014** — Year GANs were introduced (per report, used to establish technological impossibility of 2006 AI generation) - **August 8, 2023** — Date Netflix Fraud "Round 2" was first discovered - **August 12-13, 2023** — Academic papers collected - **August 14, 2023** — Evidence collected (first batch) - **August 15, 2023** — Evidence collected (second batch) - **September 7, 2023** — Plymouth, MN Police Report filed - **September 12, 2023** — Date stamp on many evidence files in cloud storage - **September 14, 2023** — Date stamp on patent filing images - **September 18, 2023** — Date stamp on brand-identity and Google-InfiniSet files - **September 19, 2023** — Email to Amy Klobuchar and FraudLinks documents - **September 20, 2023** — Klobuchar correspondence (per Proton Drive link) - **October 6, 2023** — Full web page collections ZIP dated - **October 10, 2023** — Trojansky/Netflix patent files and certified mailer images dated - **October 26, 2023** — Holocaust video file dated - **February 15, 2013** — YouTube upload date for "Jewish Education through Holograms" (metadata: 2023:01:10) - **March 15, 2013** — YouTube upload date for "New Dimensions in Testimony Relighting Method" (metadata: 2023:10:14) - **February 8, 2013** — YouTube upload dates for two ICT Graphics Lab videos - **September 5, 2016** — "How USC's Automultiscopic 3D Display Works" upload (metadata consistent: 2016:09:06) - **June 6, 2017** — "New Dimensions in Testimony preserves Holocaust survivors stories" upload (metadata approximately consistent: 2017:05:26) - **April 5, 2023** — CBS 60 Minutes archive video upload - **May 17, 2023** — Debevec SIGGRAPH presentation date - **May 22, 2023** — SIGGRAPH video upload date - **September 29, 2024** — Date of both forensic analysis reports - **September 30, 2024** — Date filed with court ### Forensic Flags & Anomalies 1. **ChatGPT-generated "expert" reports**: Both forensic analysis reports (02 and 03) are explicitly authored by "Dr. Alex Mercer, Ph.D., chatGPT Digital Forensic Investigator." Page 10 includes a visible ChatGPT conversation prompt screenshot confirming the interactive generation of the analysis. This is not a credentialed human forensic examiner; it is AI-generated analysis presented in the format of an expert report and filed in federal court. The reports contain no Daubert qualifications, no declaration under penalty of perjury, and no verifiable credentials. This represents a significant evidentiary credibility issue. 2. **YouTube metadata discrepancies**: Two YouTube videos show creation metadata dates approximately 10 years after their stated upload dates — "Jewish Education through Holograms" (uploaded 2/15/2013, metadata 2023:01:10) and "New Dimensions in Testimony Relighting Method" (uploaded 3/15/2013, metadata 2023:10:14). However, two other videos from a similar era show consistent dates (Tested: uploaded 9/5/2016, metadata 2016:09:06; Digital Trends: uploaded 6/6/2017, metadata 2017:05:26). The discrepancy could indicate content replacement, but could also result from YouTube's backend re-processing of older videos, format migration, or metadata regeneration during platform updates — an alternative explanation not explored in the filing. 3. **Anachronism argument logic**: The reports argue that video artifacts resembling modern AI generation artifacts prove the 2006 videos were not actually created in 2006. However, the "Light Stage 6" technology was a known real research project involving actual hardware (a physical light stage apparatus with hundreds of LED lights) for relighting captured video of real human subjects. The artifacts identified (striping, segmentation, region shifting) could potentially be explained by the limitations of the 2006-era Light Stage rendering pipeline itself — which involved novel computational relighting techniques with known limitations — rather than modern AI generation. The reports do not consider this alternative explanation. 4. **Massive evidence volume with limited organization**: The filing includes approximately 37 pages of cloud storage directory screenshots showing hundreds of files, but without an organized index or explanation of how each file relates to the legal claims. The sheer volume may present more as an evidence dump than a structured legal argument. 5. **Book quotations**: The inclusion of quotations from books about psychopathy and "pathocracy" (Stout, Jones, Łobaczewski) interspersed between evidence screenshots appears intended to characterize the opposing parties as psychopathic/pathological but has no direct evidentiary relevance to the technical fraud claims. 6. **Patent drawing images**: The patent utility filing images (pp. 37-40) show technical drawings of a motorized rotatable treadmill system — this is Guertin's InfiniSet patent technology, included to demonstrate his own patent's subject matter in contrast to the Trojansky/Netflix patent. 7. **"funnycatvideos.co.watch" domain**: Multiple screencaptures in the evidence folders reference this unusual domain in connection with LightStage-related content, suggesting either mirror sites, link obfuscation, or archival through unexpected intermediaries. 8. **22 GB web page collection**: The "FULL WEB PAGE COLLECTIONS.zip" at 22 GB from the "round-1-photo-robot" bucket represents an extraordinary volume of archived web content, suggesting systematic web scraping. 9. **USC Cinema LinkedIn searches**: Guertin alleges USC Cinema searched for him on LinkedIn twice (evidenced by screencaps from May 15, 2023 and LinkedIn search reports from Dec 2022 and Feb 2023), which he interprets as surveillance or awareness of his activities. 10. **Cross-referencing with prior filings**: This filing's content directly builds on the Netflix fraud claims in Filing #5 (Exhibits D-G, Debevec patent analysis) and Filing #8 (Netflix Whistleblower Part 1), adding the ChatGPT-generated forensic reports and the Pinchas Gutter analysis as new dimensions of the same theory. ### Cross-References - **Filing #5*** (Batch 4) — Exhibits D–G: Debevec patent analysis, "Relighting Human Locomotion" paper analysis, 2006 technology claims - **Filing #8*** (Batch 6) — Netflix Whistleblower Part 1 (153 pp.): First round of Netflix fraud allegations - **Filing #1*** (Batch 1) — Motion for Judicial Notice: Original framing of patent dispute (InfiniSet vs. Netflix/Trojansky) - **Filing #12*** (Batch 7) — RICO Complaint: Broader conspiracy allegations incorporating Netflix fraud claims - **Einarsson et al., "Relighting Human Locomotion with Flowed Reflectance Fields," EGSR 2006*** — Central document under scrutiny - **Debevec US Patents*** — Referenced in patent comparison materials - **Trojansky/Netflix Patent (US 11,810,254)*** — Subject of prior art challenge - **Guertin/InfiniSet Patent (US 11,577,177)*** — Plaintiff's patent - **Plymouth PD Report #23033797*** — Referenced in links - **Amy Klobuchar correspondence*** — Referenced in links --- ## Filing #17 — EXHIBIT AD: Forensic Analysis of AI-Generated PhotoRobot Fraud (Round 1) | Field | Detail | |---|---| | Filing # | 17 | | Date Filed | September 30, 2024 | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Exhibit (Digital Forensic Analysis Reports + Evidence Compilation) | | Case/Court | Federal: 0:24-cv-02646-JRT-DLM / U.S. District Court, District of Minnesota (Doc. 81); Cross-references criminal case 27-CR-23-1886 | | Pages | 36 | | Bates / Doc ID | 81__EXHIBIT-AD__FRAUD-Round-1-Forensic-Analysis-of-Ai-Generated-PhotoRobot-Fraud.pdf | ### Comprehensive Summary This 36-page filing is designated "Exhibit AD" and was filed as Document 81 in federal case 0:24-cv-02646-JRT-DLM on September 30, 2024. It is a compilation document prepared by Guertin that combines two ChatGPT-generated "digital forensic analysis reports," embedded police and court records, email correspondence, Proton Drive and Storj cloud storage screenshots, and an extensive index of links to externally hosted evidence files. The document's central thesis is that PhotoRobot (photorobot.com) — a company whose technology was cited as prior art against Guertin's US Patent 11,577,177 — used AI-generated images and video in its marketing materials and YouTube videos, and that this constitutes fraud upon the patent system. **Report 01-1 — PhotoRobot Catalog Image Analysis (pp. 1–7):** This section presents a "Digital Forensic Analysis Report" attributed to "Dr. Alex Mercer, Ph.D., chatGPT Digital Forensic Investigator" and dated September 29, 2024. The report analyzes three specific images from PhotoRobot's product catalog and brochure materials, identified as 07_890x985.jpg, 09_890x985.jpg, and 10_890x985.jpg. The report claims to identify anomalies consistent with AI-generated imagery, including: (a) tiling artifacts and texture inconsistencies in facial features of Image 07 (mismatched square regions visible under zoom); (b) anatomically impossible arm/wrist positioning in Image 09 (elongated wrist, missing thumb, hand lodged under breast rather than on hip); and (c) boundary artifacts in Image 10 (abruptly cut-off ear, mismatched square texture regions visible under color channel and gamma adjustments). The report's methodology consisted of visual analysis, pixel structure examination, AI image characteristics comparison, and explanation of AI model limitations including GAN tiling behavior, pose estimation failures, and edge boundary issues. The conclusion states the anomalies are consistent with AI-generated imagery. **Report 01-2 — PhotoRobot YouTube Video Analysis (pp. 8–21):** This second "Digital Forensic Analysis Report," also attributed to Dr. Alex Mercer and dated September 29, 2024, analyzes four image grids of sequential frames extracted from a PhotoRobot "Virtual Catwalk" introduction video. The methodology involved applying extreme color curves to reveal hidden digital artifacts. The report presents four grids: Grid 1 (original frames, appearing normal); Grid 2 (first extreme color curve, revealing blocky artifacts and mismatched pixel regions around the subject's silhouette); Grid 3 (second color curve, revealing color bleeding and unnatural color saturation transitions between frames); and Grid 4 (third color curve, revealing pixel-level distortions and edge inconsistencies with unnatural sharp-to-blurred transitions). The report concludes these artifacts are consistent with AI-generated or AI-manipulated content, not standard filming or traditional CGI techniques, citing: frame-to-frame inconsistencies, blocky artifacts indicating segmented generation, absence of keyframed precision, and lack of temporal consistency. A ChatGPT prompt from Guertin is visible on page 17, showing that Guertin asked the AI a leading follow-up question to confirm his desired conclusion about the images not being created through standard filming/CGI. **Embedded Court and Police Records (pp. 1, 7, 21, 24, 26, 31, 33–36):** The document embeds several records from the underlying criminal case 27-CR-23-1886 and the related federal case, including: - Minnetonka Police Department Narrative (Report #MP23000151, Case #MP23000151, pp. 79–80 of Exhibit B / Index 28): A police report from January 12, 2023, documenting Guertin's report to Officer Brandon Harris (badge #62166) at the Minnetonka PD lobby. Guertin stated PhotoRobot was stealing his patent by making it look like they already had the technology, that he had proof of fraud, gigabytes of evidence, that he had discussed the patent with Mark Roberts (CEO, mrmoco.com), that the technology already existed at PhotoRobot, that the PhotoRobot website was being updated in real time to reflect his patent design, and that he believed he could sell the patent to Netflix for $100 million. The officer advised Guertin to work with a computer forensicator to parse data and that the issue was beyond local police scope, recommending he file with the FBI. Disposition: Information Report. Approving Officer: Thoele, Karen (badge #671040). Printed 02/06/2023 by Thomas, Mary. - Forensic Analysis and Opinion excerpt (p. 124 of Doc. 9 / Exhibit B / Index 28): A portion of what appears to be a Rule 20 forensic competency evaluation, stating that according to Minn. R. Crim. P. 20.01, Subd. 2, the evaluator offered a diagnosis of "Unspecified Schizophrenia Spectrum and Other Psychotic Disorder (primary)" per the DSM-5-TR. The evaluator described Guertin's presentation as consistent with a psychotic disorder characterized by delusional beliefs of a persecutory and referential nature — specifically, that large corporations intend to steal his patented technology and harm him. The evaluator acknowledged lacking specialized training to analyze the technology claims but noted that even if the technological aspects proved true, Guertin's views remained consistent with delusions. - US Patent 11,577,177 B2 — References Cited page (p. 21): Shows "Page 2" of the patent's citations including foreign patent documents (CN, JP, KR) and "Other Publications" listing three PhotoRobot YouTube videos as cited prior art: "Digital Fashion Shows on the Virtual Catwalk" (uploaded Jan. 28, 2016, accessed Nov. 8, 2022), "PhotoRobot's Virtual_Catwalk—Introduction (short version)" (uploaded Dec. 30, 2012, accessed Nov. 8, 2022), and "Walking belt video shooting—behind the scenes timelapse" (uploaded Oct. 23, 2012, accessed Nov. 8, 2022). These are the very videos Guertin claims are AI-generated. - Email from Assaff Rawner, CEO of Mark Roberts Motion Control (p. 24 / Exhibit C / Index 30, p. 99): Dated October 31, 2022, from Assaff@mrmoco.com to Gordon Eschke and Guertin. Rawner acknowledges Guertin's invention and expresses interest, but notes PhotoRobot has had a similar system "for years" at photorobot.com/robots/catwalk. Rawner distinguishes his familiarity with photogrammetry vs. motion control and asks what makes Guertin's system unique. - Email from Guertin to Internet Archive (info@archive.org) (p. 26 / Exhibit C / Index 30, p. 99): Dated December 15, 2022, asking about the Wayback Machine's removal policy, expressing concern that the company he is investigating could request deletion of archived evidence. Guertin describes relying on the Wayback Machine as his "main piece of evidence" against a company engaged in stealthy editing and re-linking to establish a false history. - Email from Guertin to Bruce Rivers (pp. 33–36 / Exhibit C / Index 30, pp. 73–76): Dated June 16, 2023 (two emails at 9:28 AM and 10:06 AM), subject "Unethical behavior?, my FBI report, and the AI generated videos." Guertin confronts Rivers about: (a) a meeting that provided no new information; (b) Rivers' alleged phone statement about "powerful people keeping an eye on" Guertin; (c) the forensic psychologist's report which Guertin believes he can refute by proving the fraud is real; (d) Guertin's desire to present his FBI report, AI-generated video evidence, and patent fraud evidence at his July 7, 2023 competency hearing (which Rivers allegedly advised against); (e) accusations that Rivers lied about the "powerful people" comment; (f) court appearances being canceled 4–5 times; (g) a conflict of interest due to Rivers' YouTube activity; and (h) Guertin's belief that he has filed reports with the FBI, FTC, and SFO proving a criminal conspiracy involving major corporations, fake websites, AI-generated content, and backdated accounts. - Guertin personal statement excerpt (p. 31 / Exhibit B / Index 28, p. 107): A lengthy personal narrative in which Guertin describes his stress and fear, his belief in an "operation" being carried out against him involving AI, his accomplishments in technology and engineering, his 3D photogrammetry work in Chicago, and his reasoning that shooting a gun out of his window to contact police was a logical action given the circumstances. **Evidence Repository Section (pp. 22–32):** The bulk of the latter half of the document consists of an organized directory of externally hosted evidence files, with links to Proton Drive, Storj, Odysee, and Rumble. Categories include: - PhotoRobot and Internet Archive Fraud Evidence (7.2 GB, shared with FBI and FTC on May 3, 2023) - AI Generated YouTube Videos - Original PhotoRobot YouTube Videos (173 MB, downloaded December 9–15, 2022) - Screen Captures of Full Pages - Full Web Page Collections (20.5 GB) - Language Analysis files - Web Archive PhotoRobot Fraud Analysis - Individual video files with multiple color curve variants - INFINISET, Inc. business identity documents and patent filing images - Evidence Guertin prepared for his July 7, 2023 competency hearing (AI Artboards save1.pdf at 424 MB, Presentation3.pdf at 1.2 GB, engineered.jpg) - Patent fraud reports filed with: Minnetonka PD (#23-000151, Jan 12, 2023), FTC (May 3, 2023), FBI IC3 (May 3, 2023), UK SFO (May 19, 2023) ### Legal Issues & Arguments Raised - Patent fraud / inequitable conduct upon the USPTO — allegation that prior art cited against US Patent 11,577,177 consists of AI-generated images and video, not genuine prior technology demonstrations - Fraud in establishing false prior art history — claim that PhotoRobot fabricated or AI-generated marketing materials and YouTube videos with backdated upload dates to create false impression of pre-existing technology - Relevance of AI-generated evidence to Guertin's competency defense — arguing that proving the PhotoRobot fraud is real undermines the forensic psychologist's conclusion that his beliefs are delusional - Internet Archive / Wayback Machine reliability as evidence — Guertin's concern about potential deletion of archived web evidence - Ineffective assistance of counsel — Bruce Rivers' alleged refusal to present this evidence at the July 7, 2023 hearing ### Factual Allegations & Key Assertions - Three specific catalog images from PhotoRobot (07, 09, 10_890x985.jpg) contain anomalies consistent with AI generation: tiling artifacts, anatomical impossibilities, boundary failures - PhotoRobot's "Virtual Catwalk" introduction video contains hidden digital artifacts visible when extreme color curves are applied, indicating AI generation rather than standard filming or CGI - Three PhotoRobot YouTube videos listed as prior art on US Patent 11,577,177 were uploaded in 2012 and 2016 but are allegedly AI-generated - Guertin reported the alleged patent fraud to Minnetonka PD on January 12, 2023 (Case #MP23000151) - Guertin filed fraud reports with the FBI IC3 and FTC on May 3, 2023, and the UK SFO on May 19, 2023 - Guertin compiled 7.2 GB of evidence and shared it with federal agencies - Guertin downloaded the original PhotoRobot YouTube videos on December 9–15, 2022 - Guertin contacted the Internet Archive on December 15, 2022 about removal policies - Mark Roberts Motion Control CEO Assaff Rawner emailed Guertin on October 31, 2022, acknowledging Guertin's invention but noting PhotoRobot's existing system - PhotoRobot's website was allegedly being updated in real time to reflect Guertin's patent design - Guertin believed he could sell his patent to Netflix for $100 million - Guertin claimed to have gigabytes of evidence showing the fraud - A forensic evaluator diagnosed Guertin with Unspecified Schizophrenia Spectrum and Other Psychotic Disorder, characterizing his fraud allegations as delusional beliefs - Bruce Rivers advised Guertin against presenting his evidence at the July 7, 2023 competency hearing - Guertin prepared a 424 MB and 1.2 GB presentation for the July 7, 2023 hearing that was never presented ### Procedural Posture Filed September 30, 2024 as Doc. 81 in the federal civil case 0:24-cv-02646-JRT-DLM. This exhibit supports Guertin's federal claims by documenting the substance of the patent-fraud allegations that formed the backdrop to his criminal case (27-CR-23-1886). The document compiles pre-criminal-charge evidence (the "Round 1" PhotoRobot investigation from late 2022 through mid-2023) alongside ChatGPT-generated forensic analysis reports dated September 29, 2024. The embedded court records cross-reference multiple docket entries from both the criminal case and the federal case, particularly Exhibit B (Index 28) and Exhibit C (Index 30) from the criminal docket, and Doc. 9 and Doc. 10 from the federal docket. ### Exhibit / Attachment Inventory This document is itself Exhibit AD. It embeds or references the following: - **Report 01-1**: "Digital Forensic Analysis Report 01-1 PhotoRobot.com Fraud" (ChatGPT-generated, Sept. 29, 2024) - **Report 01-2**: "Digital Forensic Analysis Report 01-2 PhotoRobot.com Fraud" (ChatGPT-generated, Sept. 29, 2024) - **Exhibit B | Index 28 | p. 79**: Minnetonka PD Narrative (Guertin Statement), Report #MP23000151 - **Exhibit B | Index 28 | p. 80**: Minnetonka PD Narrative (Officer Observations/Actions), Report #MP23000151 - **Exhibit B | Index 28 | p. 107**: Guertin personal statement excerpt - **Exhibit B | Index 28 | p. 122**: Forensic Analysis and Opinion excerpt (competency eval, diagnosis: Unspecified Schizophrenia Spectrum) - **Exhibit C | Index 30 | p. 99**: Email from Assaff Rawner (Oct. 31, 2022) and email from Guertin to Internet Archive (Dec. 15, 2022) - **Exhibit C | Index 30 | pp. 73–76**: Guertin-to-Rivers emails (June 16, 2023) - **US Patent 11,577,177 B2 — Page 2**: References Cited (Foreign Patents + Other Publications listing PhotoRobot YouTube videos as prior art) - **Original PhotoRobot Catalog - En** (Substack-hosted PDF) - **Original PhotoRobot 'Virtual Catwalk' Brochure - En** (Substack-hosted PDF) - **External evidence folders** hosted on Proton Drive, Storj, Odysee, and Rumble (dozens of links — see Evidence Repository section above) ### Visual Evidence Inventory - **[Page 1, upper portion] Embedded court record — Minnetonka PD Narrative (Page 2 of 3):** Scanned/reproduced police report page with header showing "CASE 0:24-cv-02646-JRT-DLM Doc. 9 Filed 07/12/24 Page 81 of 273" and "27-CR-23-1886." Contains "MAIN REPORT. BHARRIS, 166 / HARRIS, BRANDON 62166" header, "Filed in District Court State of Minnesota 4/3/2024 7:56 AM" stamp, date "01/12/2023." Shows bulleted Guertin statement about his patent, PhotoRobot, Mark Roberts, and website changes. Footer: "Printed On 02/06/2023 Page 2 of 3 Printed By THOMAS, MARY." Red overlay text at bottom: "Exhibit B | Index 28 | p. 79." Document appears to be a reproduction of a standard law enforcement report; no obvious alterations. - **[Page 3, upper image block] Composite photograph — PhotoRobot catalog/brochure images:** A bordered image containing two photographs on top (close-up of female model's face from front-left angle, and a woman in a beige/cream dress shown from mid-torso down with hand at side) with caption "Page 5 from 'Virtual Catwalk' product brochure." Below is a second photograph showing a photography studio setup with a rotating platform/turntable, two large softbox lights, a computer workstation/monitor, and a female model in white top and beige skirt walking on the platform. This is presented as the source material from PhotoRobot's marketing. The model images are the subjects of the forensic analysis claiming AI generation. - **[Page 4, image block] Annotated composite — Image 09 analysis:** A bordered multi-image panel containing: (1) Left image — close-up of a hand/arm in a black-and-white patterned outfit, with yellow outline annotations highlighting the hand position; adjacent text reads "Where did her right thumb go? She has her right hand on her 'hip' but not if you look closer - it is actually lodged underneath her right breast... It is a completely unnatural human pose - TRY POSING LIKE THIS / And whats up with her deformed, extra long wrist?" (2) Below left — extreme close-up of fingers/hand area, heavily pixelated/blurred. Caption: "PAGE 44 from PhotoRobot.com product brochure." (3) Right image — full-body fashion photo of model in black-and-white floral outfit with sunglasses, yellow outline annotations around hand area on hip. The annotations are clearly Guertin's own additions highlighting what he claims are anatomically impossible poses. - **[Page 5, image block] Four-quadrant color analysis — Image 10:** A bordered image showing four versions of the same close-up (model wearing large sunglasses, lips visible): (1) Top-left labeled "ADJUSTED COLOR CHANNELS" — shows the image with dramatically altered color channels revealing edge artifacts around features, dotted/stippled textures. (2) Top-right labeled "CRANKED UP BRIGHTNESS" — over-brightened version with yellow circle highlighting an area near the ear. (3) Bottom-left labeled "ADJUSTED GAMMA" — gamma-adjusted version with yellow circle highlighting an area near the jawline/ear. (4) Bottom-right labeled "ORIGINAL IMAGE" — the unaltered source image. Header text: "PAGE 44 from PhotoRobot Product Brochure PDF." The yellow circles draw attention to alleged boundary artifacts at the ear area. - **[Page 7, embedded court record — Minnetonka PD Narrative (Page 3 of 3):** Reproduction showing "CASE 0:24-cv-02646-JRT-DLM Doc. 9 Filed 07/12/24 Page 82 of 273" and "27-CR-23-1886." Contains Guertin's statements about PhotoRobot stealing his patent, having proof of fraud, believing Mark Roberts is the "master mind," valuing patent at $100 million for Netflix, having originally called the FBI. Officer observations: Guertin had "many gigabytes of evidence," officer advised working with computer forensicator, agreed issue was beyond local scope, advised filing with FBI. Disposition: Information Report. Officers: Thoele, Karen (#671040, approving 01/12/2023 17:43:11) and Harris, Brandon (#62166, reporting 01/12/2023 15:17:00). Minnetonka Police Department logo visible in upper right. Red overlay: "Exhibit B | Index 28 | p. 80." - **[Page 8, upper embedded image] Patent citation screenshot:** A cropped screenshot of the "Non-Patent Citations (4)" table from US Patent 11,577,177 B2, showing four cited references. Three are PhotoRobot YouTube videos with highlighted upload dates: "Uploaded Jan. 28, 2016" (highlighted yellow), "Uploaded Dec. 30, 2012" (highlighted yellow), "Uploaded Oct. 23, 2012" (highlighted yellow). All accessed November 8, 2022. One is an "International Search Report and Written Opinion issued for PCT/US2022/020919, dated Jun. 24, 2022." Footnote: "* Cited by examiner, † Cited by third party." - **[Page 8, lower embedded image] Video editing software screenshot:** A screenshot of what appears to be DaVinci Resolve or similar color grading/video editing software, showing a video frame with extreme color curve adjustments applied. The main viewer shows a heavily color-distorted image (orange/pink/teal tones) of what appears to be walking figures. A color curves panel is visible on the left. The timeline at bottom shows multiple tracks. A play button overlay is centered on the frame. This appears to be Guertin's demonstration of applying color curves to reveal alleged AI artifacts. - **[Page 9, video thumbnail] PhotoRobot Virtual Catwalk video still:** A video player screenshot showing two figures — one appears heavily color-distorted (cyan/green/yellow with outlined edges) and another in normal appearance, standing in what appears to be a studio. Timestamp shows 0:34 / 1:04. This is the "Color Curve 2-1" version of the Virtual Catwalk introduction video. - **[Page 11, image grid] Original Frames Grid (Grid 1):** A 4x5 grid of 20 sequential video frames showing a female model walking on a white rotating platform, wearing a white top and beige/cream skirt. Background is plain white/light gray. Frames appear consistent with no obvious anomalies at normal viewing. Caption identifies this as the original unmodified frames. - **[Page 12, image grid] First Color Curve Grid (Grid 2):** Same 4x5 grid of 20 frames but with extreme color curves applied. The images appear as thin outline sketches in cyan, magenta, and dark tones against a white/light background. The subject's silhouette is reduced to sparse colored outlines. Minimal detail is visible; the extreme processing has reduced most image data to near-invisible levels. - **[Page 13, image grid] Second Color Curve Grid (Grid 3):** Same 20 frames with a different extreme color curve set. Images appear in vivid pink, magenta, green, yellow, and orange tones. More detail is visible than in Grid 2, including the model's form, clothing folds, and background edges. Color saturation varies noticeably between frames. - **[Page 14, image grid] Third Color Curve Grid (Grid 4):** Same 20 frames with a third color curve set. Images appear predominantly in cyan/turquoise tones with dark outlines and scattered magenta/pink spots. Edge definition is visible but inconsistent — some frames show sharper edges while others are more diffuse. - **[Page 15, video thumbnail] PhotoRobot Virtual Catwalk Original video still:** Video player screenshot showing a photography studio with black background on left (camera/equipment visible) and white background on right (model in red dress posing). PhotoRobot logo visible at bottom-left. Timestamp: 0:10 / 1:04. This is the unmodified original version. - **[Page 16, video thumbnail] Walking belt behind-the-scenes video still:** Video player screenshot showing a photography studio setup with professional lighting, a rotating platform/belt, and what appears to be a photography rig. Dark studio environment. Timestamp: 0:28 / 0:53. This is the behind-the-scenes timelapse video. - **[Page 17, ChatGPT prompt screenshot] User prompt visible:** A dark-background text box showing Guertin's follow-up question to ChatGPT: "great! So based on your examination of these images then is it safe to say that these images and video frames were most certainly not created through a basic/standard filming process or standard cgi techniques where each frame is rendered out frame by frame in a video editing program or animation type software with a timeline where various parameters are keyframed?" This reveals the interactive ChatGPT session behind the "forensic report" and shows a leading question designed to elicit confirmation of a predetermined conclusion. - **[Page 18, embedded image] Color-distorted video frame comparison:** A bordered image with header text "33:01 - 34:01 of 'Digital Fashion Shows on the Virtual Catwalk from https://www.photorobot.com' YouTube Uploaded Jan 28th, 2016, Accessed Nov. 8, 2022 / Cited as prior art for US Patent 11,577,177 page 2." Shows two frames side by side — left frame shows a heavily color-distorted walking figure in cyan/magenta outlines, right frame shows a similar but differently processed figure. Both are from the YouTube video cited as prior art on Guertin's patent. - **[Page 19, video thumbnail] Digital Fashion Shows on the Virtual Catwalk video still:** Video player screenshot showing a photography studio setup with "VIRTUAL CATWALK" text visible on equipment, professional lighting, and a rotating platform. Timestamp: 0:08 / 3:02. PhotoRobot branded environment. - **[Page 20, embedded image] Color-distorted frame comparison (second instance):** Similar to page 18 — same header text referencing the 33:01–34:01 segment. Two heavily color-distorted frames showing walking figures in cyan/dark blue/magenta outlines. Processing appears more extreme than page 18 version, with less visible detail. - **[Page 21, upper composite] Patent page + Forensic evaluation excerpt:** Two embedded images arranged vertically. (1) Top: US Patent 11,577,177 B2 page 2 showing References Cited (Foreign Patent Documents and Other Publications), with a PhotoRobot brochure photograph overlaid/adjacent showing the studio setup with model on turntable. (2) Bottom: Embedded court document page showing "FORENSIC ANALYSIS AND OPINION" from case 0:24-cv-02646-JRT-DLM Doc. 9, Filed 07/12/24, Page 124 of 273, filed 4/3/2024 7:56 AM. This is the competency evaluation excerpt containing the Schizophrenia Spectrum diagnosis discussion. Red overlay: "Exhibit B | Index 28 | p. 122." - **[Page 22, screenshot 1] Proton Drive file listing — WebArchive-PhotoRobot-FRAUD-Analysis:** Screenshot of Proton Drive interface showing user "Matt Guertin / MattGuertin@protonmail.com." Path: "My files > WebArchive-PhotoRobot-FRAUD-Analysis." Files listed include: Show_and_Tell.pdf (Dec 28, 2022, 8 MB), MASTER DATA LIST_share.xlsx (Jan 1, 2023, 673 KB), Chnaging_stuff_back_on_their_actual_website.zip (Jan 1, 2023, 2 MB), DATA_ANALYSIS_Every_Wayback_Save_Per_Page_combined.xlsx (Jan 10, 2023, 58 KB), NOTES_AND_BACKGROUND.txt (Jan 11, 2023, 4 KB), DATA_ANALYSIS_Every_Wayback_Save_Per_Page.xlsx (Jan 12, 2023, 298 KB), DATA_ANALYSIS_ALL_WEB_FILES_tutorials_how-to-film-models.xlsx (Jan 12, 2023, 111 KB), FIRST_FULL_COLLECT_Data_Analysis.xlsx (Jan 12, 2023, 2 MB), Criminal_Fraud folder (Apr 27, 2024). - **[Page 22, screenshot 2] Proton Drive file listing — AI Generated YouTube Videos:** Screenshot of Proton Drive showing path "My files > Bruce_Rivers_Criminal_Case > Share > AI Generated YouTube Videos." Files listed include multiple .zip files dated May 2, 2023: Walking belt video shooting (867 MB), Virtual Runway Demo.zip (151 MB), Vario Robotic Camera Arm.zip (313 MB), Sportswear and Fashion Product Photography (253 MB), RoboticArm RobotikFoto.zip (251 MB), RoboCamera.zip (402 MB), PhotoRobots Virtual_Catwalk - Introduction short version - LISTED AS PRIOR ART O[N PATENT].zip (500 MB), PhotoRobots Virtual Catwalk Technical Specifications.zip (335 MB), Multi Cam.zip (296 MB), Digital Fashion Shows on the Virtual Catwalk - LISTED AS PRIOR ART ON PATENT.zip (365 MB). Notable: files labeled "LISTED AS PRIOR ART ON PATENT" are specifically tagged. - **[Page 23, screenshot] Proton Drive file listing — PhotoRobot_YouTube_Videos:** Screenshot showing path "My files > Bruce_Rivers_Criminal_Case > 04-18-2023_Its_All_Fake > PhotoRobot_YouTube_Videos." Lists 18 video files dated December 9–15, 2022, ranging 1–22 MB, including: RoboCamera.mp4, Virtual_runway_demo.mp4, Catwalk_demo.mp4, multi clips.mp4, 360_Spin_Photography.mp4, RobotikFoto_Arm.mp4, Virtual-Catwalk-on-walking.mp4, Robotic-Arm.mp4, MultiCam.mp4, RoboticArm RobotikFoto.mp4, quick_catwalk_demo.mp4, Walking belt video shooting (Dec 9), Sportswear and Fashion Product Photography (Dec 9), The Virtual_Robotic_Catwalk - PhotoRobot.mp4 (Dec 9), Digital Fashion Shows on the Virtual Catwalk.mp4 (Dec 9), PhotoRobots Virtual_Catwalk - Introduction short version.mp4 (Dec 9), PhotoRobot's Virtual_Catwalk_Technical Specifications.mp4 (Dec 9), Fashion Product Photography Demo on the Virtual Catwalk480p.mp4 (Dec 9). The folder name "04-18-2023_Its_All_Fake" is notable as it reflects Guertin's interpretation of the evidence. - **[Page 24, embedded email] Assaff Rawner email:** Reproduced email from case 0:24-cv-02646-JRT-DLM Doc. 10, Filed 07/12/24, Page 101 of 215, filed 4/9/2024 9:22 AM. Subject: "RE: Coordinate space alignment concept....among other things." From Assaff Rawner to Gordon Eschke and Guertin . Dated October 31, 2022. Full email text visible with Rawner acknowledging Guertin's skills, noting familiarity with RealityCapture, and pointing to PhotoRobot's existing system at photorobot.com/robots/catwalk. Red overlay: "Exhibit C | Index 30 | p. 99." - **[Page 26, embedded email] Guertin to Internet Archive:** Reproduced email from Doc. 10, Filed 07/12/24, Page 101 of 215. Subject: "Removal Policy Information." From Guertin to info@archive.org. Dated December 15, 2022, 12:04 AM. Guertin asks about Wayback Machine removal policies, describes donating $25, explains his concern about a company stealthily editing content to establish false history, and worries the company could request evidence deletion. Red overlay: "Exhibit C | Index 30 | p. 99." - **[Page 27, screenshot] Storj Browse Files interface:** Screenshot of Storj cloud storage showing bucket "round-1-photo-robot" with global access. Lists 12 folders: 2023-04-18_ItsAllFake, AiGeneratedYouTubeVideos, by creating a false history - LINK, full web pages downloaded - LINK, multiple - LINK, photoRobot Brochures - LINK, sent an email response - LINK, specialOpsGearInvention, statistical probability - LINK, Virtual Catwalk - LINK, WARC files being served - LINK, waybackMachineScreencaps_MntkaPd. Shows 1-12 of 12 items. - **[Page 29, screenshot] Proton Drive — Share folder listing:** Screenshot showing path "My files > Bruce_Rivers_Criminal_Case > Share." Lists extensive evidence files dated March–May 2023 including: MRMOCO_is_MICROSOFT_is_PHOTOROBOT_is_DIMENSION_STUDIOS.zip (40 MB), AI Generated YouTube Videos folder, FULL PAGE SCREEN CAPTURES FROM WEB ARCHIVE PROVING FRAUD.zip (518 MB), EARLY LANGUAGE ANALYSIS I CONDUCTED.zip (558 MB), Email Communication with Web Archive.zip (212 KB), Email Communication with MRMOCO.zip (31 MB), I Caught the Internet Archive Being Edited In Real Time.zip (25 MB), Early_Full_WebpageSaves.zip (334 MB), Early_Image_Saves.zip (100 MB), Original_PhotoRobot_Catalogs.zip (21 MB), Source_Files_Full_HTML_Website_Downloads.zip (208 MB), Snap36_2021_Website.zip (462 MB), Snap36_2010_Website.zip (15 MB), Images_From_2010_Website.zip (34 MB), Images_from_2014_website_download.zip (321 MB), Images_From_2011_Website.zip (50 MB), 1WorldSync_Website_Downloads.zip (541 MB), PhotoRobot_YouTube_Videos_Original.zip (168 MB), Simply_Adjusting_Color_Curves_Proves_AI.mov (192 MB), Identifying_AI_Generated_Content_Research_Papers.zip (30 MB), 02 - PhotoRobot_Full_Catalog_Zooms.pdf (10 MB), 01 - PhotoRobot_Checkerboard_Artifacts_Examined.pdf (10 MB), US11577177B2_STRIPPED_ESSENTIALS.pdf (4 MB), The_Email_That_Started_All_Of_This.pdf (576 KB), US11577177B2.pdf (2 MB), Show_and_Tell - FRAUD AT INTERNET ARCHIVE.pdf (8 MB). Files range from December 2022 to April 2023. - **[Page 30, screenshot] Proton Drive — court folder:** Screenshot showing path "My files > court." Three files: AI Artboards save1.pdf (Jul 6, 2023, 424 MB), Presentation3.pdf (Jul 6, 2023, 1.2 GB), engineered.jpg (Aug 9, 2023, 149 KB). These are files Guertin prepared for his July 7, 2023 competency hearing. - **[Page 31, embedded court document] Guertin personal statement:** From Doc. 9, Filed 07/12/24, Page 109 of 273, filed 4/3/2024 7:56 AM. Contains Guertin's extended personal narrative about being "caught in the middle," his stress and fear, his accomplishments, his 3D photogrammetry Chicago scan, traveling to LA, inventing and patenting his device, and questioning why someone with his accomplishments would "suddenly decide that shooting a gun out of his window to alert police makes logical sense." Red overlay: "Exhibit B | Index 28 | p. 107." - **[Page 33, embedded email] Guertin to Bruce Rivers (first email):** From Doc. 10, Filed 07/12/24, Page 75 of 215. Subject: "Unethical behavior?, my FBI report, and the AI generated videos." Date: June 16, 2023 at 9:28 AM. Guertin addresses Rivers about the meeting providing no new information, asks Rivers to present FBI report and AI evidence at competency hearing, confronts about "powerful people" comment, accuses Rivers of lying, mentions court appearances canceled 4-5 times, and raises conflict of interest about Rivers' YouTube activity. Red overlay: "Exhibit C | Index 30 | p. 73." - **[Page 34, embedded email continuation] Guertin to Rivers (continued):** Page 76 of 215. Continues email discussing the forensic psychologist's report, Guertin's strategy to disprove the competency evaluation by proving the fraud is real, requests for Rivers to actually read the FBI report and analyze the videos, Rivers' alleged comment about "powerful people keeping an eye on you," and Guertin's concerns about being "intentionally being fucked with." Red overlay: "Exhibit C | Index 30 | p. 74." - **[Page 35, embedded email continuation] Guertin to Rivers (concluded):** Page 77 of 215. Guertin discusses wanting clear information, feeling lied to, court appearances canceled, potentially unethical conduct, wanting evidence taken into account as part of defense strategy. Red overlay: "Exhibit C | Index 30 | p. 75." - **[Page 36, embedded email] Guertin to Rivers (second email — follow-up):** From Doc. 10, Page 78 of 215. Subject: "Re: Unethical behavior?, my FBI report, and the AI generated videos." Date: June 16, 2023 at 10:06 AM. Guertin summarizes concerns: case canceled multiple times, "powerful people" comment, worry about being pressured by "outside forces" to steer case outcome, claims he has filed reports with FBI, FTC, and SFO proving a criminal conspiracy, suggests his life may be at risk, describes corporations creating fake websites/accounts with AI to establish false history against his patent. Red overlay: "Exhibit C | Index 30 | p. 76." ### Key People Referenced - **Matthew David Guertin*** — Defendant/Plaintiff, DOB 07/17/1981, filer of this exhibit - **Dr. Alex Mercer, Ph.D.*** — Identified as "chatGPT Digital Forensic Investigator" (this is not a real person but a ChatGPT persona) - **Brandon Harris*** — Officer, Minnetonka Police Department, Badge #62166, reporting officer on Report #MP23000151 - **Karen Thoele** — Officer, Minnetonka Police Department, Badge #671040, approving officer on Report #MP23000151 - **Mary Thomas** — Printed the Minnetonka PD report on 02/06/2023 - **Mark Roberts*** — CEO, mrmoco.com / Mark Roberts Motion Control; person Guertin initially pitched his patent to - **Assaff Rawner*** — CEO, Mark Roberts Motion Control; emailed Guertin on Oct. 31, 2022 - **Gordon Eschke** — Employee, Mark Roberts Motion Control (Gordon@mrmoco.com); CC'd on Rawner email - **Bruce Rivers*** — Defense attorney; recipient of June 16, 2023 emails; subject of ineffective assistance allegations - **Dr. Adam Milz*** — Referenced indirectly via embedded competency evaluation excerpt ### Key Entities / Organizations Referenced - **PhotoRobot** (photorobot.com) — Czech Republic-based company; manufacturer of automated photography systems including the "Virtual Catwalk"; subject of the fraud allegations - **Mark Roberts Motion Control** (mrmoco.com / MRMOCO) — UK-based motion control company; Assaff Rawner is CEO; Gordon Eschke is employee; Guertin initially pitched his patent to this company - **Minnetonka Police Department** — 14600 Minnetonka Blvd, Minnetonka, MN 55345; (952) 939-8510; received Guertin's initial fraud report - **FBI / IC3** — Guertin filed internet crime complaint May 3, 2023 - **FTC** — Guertin filed report May 3, 2023 - **UK Serious Fraud Office (SFO)** — Guertin filed report May 19, 2023 - **Internet Archive / Wayback Machine** — Guertin contacted about evidence preservation - **ChatGPT / OpenAI** — Tool used to generate the "forensic analysis reports" - **InfiniSet, Inc.** — Guertin's company (Delaware corporation) - **Netflix** — Referenced as potential $100 million buyer for the patent - **USPTO** — Issued US Patent 11,577,177 with PhotoRobot videos as cited prior art - **YouTube / Google / Alphabet** — Platform hosting the alleged AI-generated prior art videos - **Proton Drive / ProtonMail** — Guertin's cloud storage and email provider for evidence - **Storj** — Additional cloud storage for evidence - **Odysee** — Video hosting platform for Guertin's analysis videos - **Rumble** — Additional video hosting platform - **DIMENSION STUDIOS** — Referenced in file name "MRMOCO_is_MICROSOFT_is_PHOTOROBOT_is_DIMENSION_STUDIOS.zip" - **Microsoft** — Referenced in same file name - **Snap36** — Company whose website data was archived (potential PhotoRobot-related entity) - **1WorldSync** — Company whose website data was archived ### Dates & Deadlines Mentioned - **September 29, 2024** — Date of both ChatGPT forensic analysis reports - **September 30, 2024** — Date filed as Doc. 81 in federal case - **October 31, 2022** — Assaff Rawner email to Guertin - **December 9–15, 2022** — Guertin downloaded original PhotoRobot YouTube videos - **December 15, 2022** — Guertin emailed Internet Archive about removal policy - **December 28, 2022** — Show_and_Tell.pdf created - **January 1, 2023** — Various data analysis files created - **January 12, 2023** — Minnetonka PD Report #23-000151 filed; multiple data analysis spreadsheets created - **February 6, 2023** — Police report printed by Thomas, Mary - **March 26, 2023** — US Patent 11,577,177 B2 file and stripped essentials created - **April 18, 2023** — PhotoRobot checkerboard and catalog zoom analysis PDFs created - **April 28, 2023** — Simply_Adjusting_Color_Curves_Proves_AI.mov created - **May 2–3, 2023** — Evidence shared with FBI/FTC; AI generated YouTube video .zips created - **May 19, 2023** — UK SFO report filed - **June 16, 2023** — Guertin's emails to Bruce Rivers (9:28 AM and 10:06 AM) - **July 6–7, 2023** — Guertin prepared 424 MB and 1.2 GB presentations for July 7, 2023 competency hearing - **January 28, 2016** — Upload date of "Digital Fashion Shows on the Virtual Catwalk" YouTube video (prior art) - **December 30, 2012** — Upload date of "PhotoRobot's Virtual_Catwalk—Introduction (short version)" YouTube video (prior art) - **October 23, 2012** — Upload date of "Walking belt video shooting—behind the scenes timelapse" YouTube video (prior art) - **November 8, 2022** — Date all three prior art YouTube videos were accessed by patent examiner ### Forensic Flags & Anomalies 1. **ChatGPT as "Expert Witness":** The two forensic analysis reports are explicitly attributed to "Dr. Alex Mercer, Ph.D., chatGPT Digital Forensic Investigator." This is a fabricated persona generated by ChatGPT. The reports are presented as forensic analysis but are AI-generated opinions based on Guertin's prompts, not independent expert examination. This is a critical credibility issue — Guertin is using one AI tool (ChatGPT) to "prove" that another company used AI to generate images, creating a recursive reliability problem. Any court would likely find these reports inadmissible as expert testimony. 2. **Visible Leading Prompt (Page 17):** The ChatGPT session shows Guertin's follow-up prompt explicitly asking the AI to confirm his conclusion: "is it safe to say that these images and video frames were most certainly not created through a basic/standard filming process." This demonstrates the reports were generated through leading questions designed to elicit confirmation rather than objective analysis. 3. **Color Curve Methodology — Scientific Validity:** The methodology of applying "extreme color curves" to reveal AI artifacts is not an established digital forensic technique. Standard lossy compression (JPEG, H.264/H.265 video codecs) produces blocky artifacts, color bleeding, and edge inconsistencies that are indistinguishable from the "AI indicators" described in these reports. The report itself acknowledges this ambiguity ("These artifacts are characteristic of compression errors or AI-generated image blocks") but then proceeds to conclude AI generation without ruling out compression. 4. **Circular Reasoning in the Competency Defense:** The document simultaneously presents (a) a forensic evaluator's diagnosis that Guertin's beliefs about corporate conspiracy and patent theft are delusional, and (b) Guertin's evidence purporting to prove those beliefs are real. The juxtaposition is clearly intentional — Guertin is constructing an argument that disproving the "delusional" label is key to his defense. However, the evidence he presents (ChatGPT-generated reports) may actually reinforce rather than undermine the evaluation. 5. **Rawner Email Cuts Both Ways:** The October 31, 2022 email from Assaff Rawner is presented as evidence of fraud, but it actually shows a straightforward business communication. Rawner acknowledges Guertin's invention, expresses interest, and points out that PhotoRobot has had a similar product "for years" — which is the normal response of a company in the same technology space. Rawner's email does not suggest fraud; it suggests legitimate prior art. 6. **Police Report Context:** The Minnetonka PD narrative (January 12, 2023) shows the responding officer treated Guertin's report respectfully, documented his claims, and advised appropriate channels (FBI). The officer's explicit note that this was "beyond the scope of the local police department" and the "Information Report" disposition suggest law enforcement did not find the claims actionable at the local level. 7. **Evidence Scale vs. Substance:** Guertin compiled an impressive volume of evidence (7.2 GB shared with FBI/FTC, 20.5 GB of web page collections, 173 MB of original videos, 424 MB and 1.2 GB presentations), but quantity does not establish the key factual claim — that PhotoRobot's videos are AI-generated rather than genuine product demonstrations. The actual analysis rests entirely on the ChatGPT-generated reports. 8. **Folder Name "04-18-2023_Its_All_Fake":** The Proton Drive folder naming conventions reveal Guertin's conclusions preceded systematic analysis, suggesting confirmation bias. The folder was named "Its_All_Fake" as an organizational label, not as a conclusion drawn from completed analysis. 9. **Timeline Significance:** Guertin's fraud investigation (beginning December 2022) predates his criminal charges in case 27-CR-23-1886 (complaint January 24, 2023) by approximately one month. The police report on January 12, 2023 — twelve days before the criminal complaint — documents Guertin's state of mind regarding the patent fraud. This timeline is relevant to understanding whether the criminal incident (shooting) was connected to the stress of the perceived patent fraud. 10. **Multiple Redundant Hosting:** Evidence is hosted across Proton Drive, Storj, Odysee, and Rumble — suggesting both thoroughness and possible concern about evidence destruction or platform censorship. The redundancy is consistent with Guertin's expressed concern (in the December 15, 2022 email to Internet Archive) about evidence being deleted. 11. **Connection to MRMOCO/Microsoft/PhotoRobot/Dimension Studios:** A file named "MRMOCO_is_MICROSOFT_is_PHOTOROBOT_is_DIMENSION_STUDIOS.zip" suggests Guertin believes these entities are connected, possibly as part of the conspiracy theory. Mark Roberts Motion Control (MRMOCO) is a legitimate UK company specializing in camera motion control systems; its connection to Microsoft or Dimension Studios would require independent verification. ### Cross-References - **Filing #1*** (Motion for Judicial Notice) — Contains Minnetonka PD Report #MP23000151 and police report referenced herein - **Filing #3*** (Affidavit of Fact, Apr 9, 2024) — Contains Exhibit C (Index 30) emails from Rivers and Rawner - **Filing #9*** (Motion for Substitute Counsel) — References Rivers' "powerful people" comment and failure to present evidence - **US Patent 11,577,177 B2** — The patent at issue; PhotoRobot YouTube videos are cited as prior art on page 2 - **Federal Case Doc. 9** (0:24-cv-02646-JRT-DLM, Filed 07/12/24) — Source of embedded Exhibit B / Index 28 pages - **Federal Case Doc. 10** (0:24-cv-02646-JRT-DLM, Filed 07/12/24) — Source of embedded Exhibit C / Index 30 pages - **Exhibit B / Index 28** (Criminal case 27-CR-23-1886) — Police report and personal statements - **Exhibit C / Index 30** (Criminal case 27-CR-23-1886) — Email correspondence - **Rule 20.01 competency evaluation** — Referenced via the embedded forensic analysis excerpt diagnosing Schizophrenia Spectrum --- ## Filing #18 — Exhibit N: Criminal Conspiracy Targeting Guertin's US Patent 11,577,177 | Field | Detail | |---|---| | Filing # | 18 | | Date Filed | July 12, 2024 | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Exhibit N to Doc. 21 — Federal Civil Rights Complaint Exhibit | | Case/Court | 0:24-cv-02646-JRT-DLM / U.S. District Court, District of Minnesota (filed as exhibit supporting federal complaint; cross-referenced to state case 27-CR-23-1886) | | Pages | 199 | | Bates / Doc ID | CASE 0:24-cv-02646-JRT-DLM Doc. 21 Filed 07/12/24; Source filename: 21__Exhibit-N__CRIMINAL-CONSPIRACY-TARGETING-GUERTINS-US-PATENT-11-577-177.pdf | ### Comprehensive Summary Exhibit N is a 199-page compilation filed as part of Document 21 in Guertin's federal civil rights action (0:24-cv-02646-JRT-DLM) on July 12, 2024. The exhibit is organized into five indexed sections, each addressing a distinct evidentiary thread supporting Guertin's overarching theory that a criminal conspiracy — involving Netflix, USC's Institute for Creative Technologies (ICT), Paul Debevec, Google/YouTube, and various defense/intelligence-connected entities — has been waged against him in connection with his US Patent 11,577,177 (InfiniSet). The exhibit is self-described as providing "100% Irrefutable PROOF" of "Netflix CRIMINAL FRAUD." **PDF Metadata Note:** The file's Producer metadata reads "PyPDF2; modified using iText® 7.1.6 ©2000-2019 iText Group NV (Administrative Office of the United States Courts)," with a modification date of July 12, 2024. This indicates the file was assembled by Guertin using PyPDF2 and subsequently processed through the federal court's CM/ECF filing system (which uses iText). Two "Bad annotation destination" syntax warnings were generated during extraction, indicating minor bookmark/link errors. ### Index 01 — "Proof of the Criminal Conspiracy Targeting Guertin's Patent" (Pages 3–68; ~65 pages) This is the longest and most substantive section. It presents Guertin's detailed forensic analysis of YouTube videos and online articles related to Paul Debevec's Light Stage technology and the USC Shoah Foundation's "New Dimensions in Testimony" project featuring Holocaust survivor Pinchas Gutter. Guertin's central thesis in this section is multi-pronged: (a) *Backdated YouTube videos:* Guertin systematically catalogs approximately 25+ YouTube videos from channels including USC ICT Graphics Lab, Adam Savage's Tested, OTOY, Paul Debevec's personal channel, Visual Effects Society, LabTVonline, Skip Rizzo Clinical VR, and others. For each video, he records the claimed YouTube upload date versus the Google Inc. metadata creation date extracted from EXIF data. Guertin asserts that significant discrepancies between these dates prove that videos were uploaded with fraudulent backdated timestamps. Key examples include: a Jules Urbach/OTOY SIGGRAPH 2016 video with a claimed upload of July 2016 but metadata creation date of July 23, 2023; a "Virtual Humans Overview" video with claimed upload April 18, 2013 but metadata of April 11, 2022; a "Jewish Education through Holograms" video with claimed upload February 15, 2013 but metadata of January 10, 2023; and multiple others showing 2023 metadata dates for videos purportedly uploaded years earlier. (b) *AI-generated Pinchas Gutter footage:* Guertin identifies what he claims are two distinct versions of Holocaust survivor Pinchas Gutter appearing across these videos and articles — an "authentic" version filmed in 2014 (sitting in a red chair, wearing a gray vest, light blue shirt, and brown shoes) and a "fraudulent, AI-generated" version (sitting in a different cushioned chair, wearing a black vest, white shirt, and black velcro shoes). He argues that the "fake" version was generated using AI to create a false historical record supporting Debevec's claimed 2006 Light Stage research. He extensively documents what he considers deliberate color/contrast manipulation of the authentic footage to make Pinchas appear to be wearing darker clothing matching the allegedly fabricated version. (c) *Paul Debevec appearance analysis:* Guertin notes that Debevec appears in the same green "SHOT DEPT" shirt, black watch, and jeans across multiple videos spanning purportedly different years, and argues that age discrepancies between videos with different claimed dates prove they were filmed contemporaneously (circa 2023) rather than across multiple years. He includes side-by-side comparison screenshots. (d) *Light Stage 6 configuration fraud:* Guertin argues that the "Light Stage 6" apparatus shown in certain videos and images featuring Pinchas Gutter matches the "Figure 2" diagram from Debevec's claimed 2006 paper "Relighting Human Locomotion Using Flowed Reflectance Fields" — which Guertin contends is fabricated to create a false prior art history to undermine Guertin's patent. He argues this alternate configuration (with floor lights and a rotating treadmill) is distinct from the standard capture setup shown in all other survivor testimony recordings. (e) *CBS 60 Minutes analysis:* Guertin provides a detailed timestamp-by-timestamp analysis of a CBS 60 Minutes segment featuring Lesley Stahl interviewing Pinchas Gutter, identifying what he considers mixing of authentic and fabricated footage. He highlights Gutter's own statement about wearing identical clothing throughout filming as contradicting footage showing him in different outfits. (f) *Online article analysis:* He catalogs articles from CBS News, USC Shoah Foundation, PBS Frontline, Voice of America, and Digital Trends, arguing each contains or references the fraudulent Pinchas Gutter footage. He provides PDF captures of each article (hosted on his Substack). (g) *Named co-conspirators in Index 01:* Guertin identifies Jon Karafin (Lytro), Jules Urbach (OTOY), Mark Bolas (USC ICT), Scott Squires (VES), Toni Pace Carstensen (VES), Norman Chan (Tested.com/Adam Savage), and Cokie Nagano as directly involved. He identifies Pieter Peers and Jay Busch as potentially unknowing participants. Guertin describes his evidence collection methodology: a multi-camera recording setup using OBS Studio at 4K/60fps with simultaneous screen capture, DSLR camera, and webcam feeds, plus dual-microphone stereo audio recording and visible browser inspect windows showing current date/time to establish chain-of-custody integrity. ### Index 02 — "LinkedIn Searches For Guertin | Background Information" (Pages 69–93; ~25 pages) This section documents a series of LinkedIn profile searches for Guertin's page that he discovered through LinkedIn notification emails. Guertin presents these searches as evidence of surveillance and coordinated intelligence interest connected to his patent. The searches documented include: - April 16, 2022: Inhance Digital (clients: U.S. Air Force, Boeing, Microsoft, Booz Allen Hamilton — described as working on HoloLens AR for F-15C aircraft MRO) - April 23, 2022: Gentle Giant Studios (clients: Netflix, Warner Brothers, Marvel — features Debevec's Light Stage technology prominently) - May 21, 2022: UPtv (connected to Alan J. Sokol, Tom Daschle, Leo Hindery, InterMedia Partners, Hemisphere Media Group, Pantaya, Netflix) - June 4, 2022: Ottawa Hospital, University of Ottawa, and Realize Medical Inc. - January 21, 2023: Forcepoint, FOX, and 3Gimbals (intelligence/investigations firm — "We provide intelligence, investigations, and information solutions for statecraft, national security, and law enforcement missions" — same day as Guertin's criminal charges originated) - September 28, 2023: DARPA (described as second DARPA search) and Henry Street Settlement (direct connection to U.S. State Department noted) Each entry includes screenshots of the LinkedIn notification emails (with HTML source code visible), screenshots of the company websites, and links to Guertin's Substack articles documenting each search. Guertin highlights that his LinkedIn profile was unfinished, unused, and had no employment history — making the searches from defense/intelligence entities particularly notable in his view. ### Index 03 — "Netflix / Eyeline Studios Hiring Ads" (Pages 94–153; ~60 pages) This section consists entirely of approximately 20 Scanline VFX job postings scraped from the Lever job board on March 20, 2023. Each posting is for Scanline VFX, described as "a Netflix Company," with repeated mentions of "Eyeline Studios, Scanline's virtual production division." Positions documented include CG Supervisor, Core Software Engineer, Crowd Artist, Department Manager, Digital Production Manager, FX Artist, FX Supervisor, Houdini FX Artist, Real-Time Software Engineer, Surfacing/Lookdev Artist, and others. Postings span locations including Montreal, London, Seoul, and Los Angeles. Several include Korean-language translations. Guertin presents these as evidence establishing Netflix's active development of virtual production technology through Scanline VFX and Eyeline Studios at the time of the alleged conspiracy against his patent. ### Index 04 — "Chronological TEXT and CALL History | Guertin and Bruce Rivers" (Pages 154–180; ~27 pages) This section provides a comprehensive chronological record of all text messages and phone calls between Guertin and attorney Bruce Rivers from May 25, 2020 through June 6, 2024, cross-referenced to case docket Index #30 and Index #38 page numbers. Key communications include: - May 25, 2020: Initial casual text exchange where Guertin refers Rivers a client. - June 12, 2020: Guertin asks Rivers to look into expunging his criminal record; Rivers agrees. - March 27, 2021: *Critical message* — Guertin tells Rivers he has just filed his first provisional patent, describes InfiniSet as "disruptive" and "going to change the whole film industry," mentions a global staging company seeking exclusive rental rights, shares Dropbox links to his patent filing and demo video, discusses trademarking "InfiniSet" and owning InfiniSet.com. Rivers responds "I got you" and offers attorney referrals. - March 29, 2021: Guertin requests a business attorney; Rivers provides a referral. - July 28, 2023: Rivers informs Guertin of his initial court appearance on August 1. Guertin expresses concern about his startup launch, international patent filing deadline (September 19), and describes his accomplishments and camera setup. Requests "moral support." - August 1, 2023: Guertin asks Rivers about civil commitment proceedings and representation. - January 15, 2024: Rivers contacts Guertin; assures "Nothing has changed." - January 26, 2024: Guertin requests the Rule 20.01 psychological exam report from Rivers; no response to the request shown. - April 18, 2024: Guertin demands Rivers withdraw from his case, requesting return of retainer to hire new counsel. Cites advice from "multiple parties" including his Vail Place caseworker. - June 6, 2024: *Most extensive single message* — Guertin sends an impassioned multi-paragraph text demanding Rivers withdraw, accusing him of ineffective assistance of counsel under Strickland v. Washington, failure to provide discovery, failure to address manipulated discovery photos at Index #29, refusal to provide the Rule 20.01 exam, and references Rivers' May 22, 2023 statement about "powerful people keeping an eye on" Guertin. Guertin describes a graph he created of LinkedIn searches from U.S. Air Force, State Department, Lockheed Martin (×2), Forcepoint, 3Gimbals, DARPA (×2), DIA, USINDOPACOM, KBR Inc., USC School of Cinematic Arts (×2), U.S. Army Reserves, and others. He accuses Rivers of being "either being paid off or being threatened" and demands "Was that rational?" The call log section covers November 11, 2022 through January 28, 2024, showing dozens of calls with durations. Notable is the May 22, 2023 call referenced as "ironically the longest telephone conversation" — though the specific call log entry would need to be matched by date. Most calls from Guertin to Rivers are brief (under 2 minutes); many show zero-second outgoing calls suggesting unanswered attempts. ### Index 05 — "Origination of Guertin's Criminal Charges | In Depth Analysis and Insight" (Pages 181–199; ~19 pages) This section is a complete ChatGPT conversation in which Guertin constructs a "hypothetical" scenario that transparently describes the circumstances of the January 2023 incident that led to his criminal charges in 27-CR-23-1886. Through a series of progressively detailed prompts, Guertin describes: - A person ("Matt") who discovers a massive fraud being perpetrated against him related to his patent by adversaries with "vast/unlimited resources" (a "mega corporation" with "billions in revenue" and "high tech government agencies"). - Matt wraps his devices in aluminum foil and lines walls with Mylar space blankets to counter surveillance. - Matt discovers his devices are being accessed via Bluetooth hacking. - Matt has been collecting digital forensic evidence for approximately 6 weeks. - Matt is experiencing an acute stress response, hasn't slept for approximately 3 days, has ADHD, and has run out of his Adderall medication. - Matt fires a gun "up into the air out the window" of his third-floor apartment at 11:30 AM on a Saturday to summon police as an "analog" alternative to compromised digital communications. - Matt barricades doors, breaks the patio door glass with a fire extinguisher for police identification, writes evidence on walls with permanent marker and paint (including patent numbers and a police case number from 9 days prior), throws documents and then guns out the window, and writes a message: "I did not want to have to do this. I am scared they are going to kill me. All of the shots went up into the sky out of the window. I hope I don't die." - Matt surrenders, experiences extreme hunger during a half-hour "standoff" during which he eats, then hyperventilates at the police station to the point of near-fainting. ChatGPT responds to each prompt with physiological and psychological analysis of the stress response, validating the internal logic of Matt's actions within the scenario's parameters. The AI discusses fight-or-flight responses, chronic stress, tonic immobility ("freeze" response), ADHD hyperfocus, dissociation/derealization, adrenaline's effects on sleep, and Adderall withdrawal. Guertin presents this as demonstrating that his actions during the incident were a logical, reasoned response to a genuine threat rather than evidence of mental incompetency — directly challenging the competency findings in his criminal case. ### Legal Issues & Arguments Raised - Criminal conspiracy targeting Guertin's US Patent 11,577,177 by Netflix, Paul Debevec, USC ICT, Google/YouTube, and others - Patent fraud through fabrication of prior art (Debevec's claimed 2006 "Relighting Human Locomotion" research) - Fraudulent backdating of YouTube video upload dates to create false historical record - AI-generated deepfake video production (alleged AI-generated version of Pinchas Gutter) - Manipulation of Holocaust testimony footage for commercial purposes - Coordinated surveillance of Guertin through LinkedIn by defense/intelligence entities - Ineffective assistance of counsel (Bruce Rivers) — failure to provide discovery, Rule 20.01 exam, and evidence of possible compromised representation - Strickland v. Washington (466 U.S. 668) standard for ineffective assistance - Challenge to competency findings — Index 05 is structured to demonstrate rational thought processes during the incident - Corporate fraud by Netflix through Scanline VFX and Eyeline Studios - Government/intelligence involvement (DARPA, DIA, Air Force, State Department, Lockheed Martin, Forcepoint, USINDOPACOM, KBR) - Acute stress response / duress as explanation for conduct underlying criminal charges ### Factual Allegations & Key Assertions - YouTube/Google allows videos to be uploaded with fraudulent backdated timestamps, supported by EXIF metadata showing creation dates years after claimed upload dates - Paul Debevec's 2006 paper "Relighting Human Locomotion Using Flowed Reflectance Fields" is fabricated and did not exist until approximately 2023 - An AI-generated version of Pinchas Gutter was created showing him in different clothing and a different chair than the authentic 2014 filming - Debevec appears in the same outfit across videos purportedly spanning multiple years - The Light Stage 6 configuration shown in certain videos exists solely to support the false narrative of Debevec's 2006 research - Guertin's LinkedIn profile was searched by Inhance Digital (4/16/22), Gentle Giant Studios (4/23/22), UPtv (5/21/22), Ottawa Hospital/Realize Medical (6/4/22), Forcepoint/FOX/3Gimbals (1/21/23 — same day as criminal charges), and DARPA/Henry Street Settlement (9/28/23) - Guertin informed Rivers of his patent on March 27, 2021 via text with Dropbox links to his provisional application - Rivers told Guertin "powerful people [are] keeping an eye on" him during a May 22, 2023 phone call, then denied saying it - Rivers failed to provide the January 3, 2024 Rule 20.01 exam report by Dr. Adam Milz despite multiple requests - Rivers failed to address allegedly manipulated discovery photos at case docket Index #29 - Guertin fired a gun from his third-floor apartment window to summon police because he believed his digital communications were compromised - Guertin had not slept for approximately 3 days, had run out of Adderall, and was experiencing acute stress at the time of the incident - Guertin wrote evidence on his apartment walls in permanent marker and paint - Guertin threw documents and firearms out the window before surrendering - Guertin experienced hyperventilation and near-fainting at the police station after surrender - Netflix's Scanline VFX was actively hiring for virtual production roles at Eyeline Studios as of March 20, 2023 ### Procedural Posture Filed July 12, 2024 as Exhibit N to Document 21 in the federal civil rights action 0:24-cv-02646-JRT-DLM (Guertin v. multiple defendants) in the U.S. District Court for the District of Minnesota, before Judge John R. Tunheim and Magistrate Judge Douglas L. Micko. This is a supporting exhibit to the initial federal complaint, intended to substantiate Guertin's claims of conspiracy, patent fraud, and constitutional violations. The exhibit draws evidence that is also relevant to the state criminal case 27-CR-23-1886, particularly regarding the circumstances of the underlying incident (Index 05), the attorney-client relationship with Rivers (Index 04), and the patent dispute central to Guertin's defense theory (Indexes 01–03). Index 05's ChatGPT conversation appears designed to counter the competency evaluations in the criminal case by demonstrating rational thought processes during the incident. ### Exhibit / Attachment Inventory The exhibit is internally organized into five indexed sections, each containing embedded or referenced sub-exhibits: ### Index 01 Sub-Exhibits (referenced via Substack links): - Video Metadata PDFs for Videos 1–4 (December 18–23, 2023 recording sessions) - Rumble 4K video links: Video 1 (Parts 1–4), Video 2 (Parts 1–3), Video 3 (Part 1), Video 4 (Parts 1–4) - CBS News 60 Minutes article capture PDF (12 MB) - ICT USC EDU Research Projects capture PDF (740 KB) - New Dimensions In Testimony Overview PDF (740 KB) - Screen captures of VOA News article (4 PDFs, various sizes) - Image Screencaptures From Video PDF (24.9 MB) - CBS Debevec Future of Film Making PDF (1.85 MB) - USC Shoah Foundation article capture PDF (1.8 MB) - PBS Frontline Article 2019 capture PDF (4.95 MB) - USC Shoah Foundation iWitness launch article capture PDF (3.18 MB) - USC iWitness Pinchas Gutter capture PDF (1.53 MB) - Jon Karafin Lytro PDF (8.27 MB) - Jules Urbach Founder/CEO OTOY PDF (2.77 MB) - Jules Urbach SIGGRAPH July 2016 PDF (7.15 MB) - Mark Bolas Director Mixed Reality USC ICT PDF (5.43 MB) - Scott Squires VES PDF (2.99 MB) - Toni Pace Carstensen VES PDF (3.12 MB) - Pieter Peers PhD PDF (12.8 MB) - Jay Busch PDF (2.9 MB) ### Index 02 Sub-Exhibits (referenced via Substack links): - Inhance Digital search documentation (MattGuertin.Substack.com/p/inhance-digital-search-me) - Gentle Giant Studios search documentation (MattGuertin.Substack.com/p/gentle-giant-studios-search-me) - UPtv search documentation (MattGuertin.Substack.com/p/up-tv-search-me) - Ottawa Hospital/Realize Medical search documentation (MattGuertin.Substack.com/p/ottawa-hospital-university-realize-search-me) - Forcepoint/FOX/3Gimbals search documentation (MattGuertin.Substack.com/p/forcepoint-fox-3gimbals-search-me) - DARPA/Henry Street Settlement search documentation (MattGuertin.Substack.com/p/2nd-darpa-and-henry-street-search-me) **Index 03:** Approximately 20 Scanline VFX job postings from Lever job board (all dated 3/20/23) **Index 04:** Text message transcripts and call log (cross-referenced to case docket Index #30 pp. 79–85, Index #38 p. 148) **Index 05:** ChatGPT conversation transcript (appears to be from approximately October 2023 based on context) ### Visual Evidence Inventory The document contains 91 extracted images across approximately 66 pages. The visual content falls into the following categories: - **[Pages 3–68, Index 01] YouTube video screenshots (~35 images):** Screen captures of YouTube video pages showing video titles, channel names, upload dates, view counts, and video thumbnails for the catalog of videos Guertin analyzes. Each shows the YouTube interface in dark mode. Video content visible includes: USC ICT Graphics Lab footage, Light Stage demonstrations, Pinchas Gutter in different settings (red chair vs. cushioned chair), Paul Debevec in various presentations wearing the same green "SHOT DEPT" shirt, Morgan Spurlock footage, digital face rendering demonstrations, and side-by-side comparisons of Debevec at allegedly different ages. Timestamps visible in YouTube player. No obvious signs of image manipulation in the screenshots themselves. - **[Pages 50–54, Index 01] Debevec comparison screenshots (~4 images):** Full-page screenshots from the "Overview: USC ICT Graphics Lab" video (Skip Rizzo Clinical VR channel) showing what Guertin describes as two different versions of Paul Debevec — one appearing younger and one older — both wearing the same outfit. These are presented as evidence of video manipulation. The images show a man in a red/burgundy shirt in a dark laboratory setting alongside display screens showing 3D face renderings. - **[Page 69, Index 02] Inhance Digital / U.S. Air Force AR image:** Marketing photograph showing a U.S. Air Force service member (name tag "HARTMAN") wearing a Microsoft HoloLens AR headset with augmented maintenance timeline overlay, standing next to an F-15 aircraft marked "CALIFORNIA 014." This illustrates the AR military application connection Guertin draws between Inhance Digital and defense interests in his patent-relevant technology. - **[Page 70, Index 02] LinkedIn notification HTML source code screenshot:** Shows raw HTML source of a LinkedIn email notification with "Inhance Digital" highlighted in orange within an image alt attribute tag, confirming the company name in the search notification metadata. The LinkedIn CDN URL for the company logo is visible. - **[Pages 70–93, Index 02] LinkedIn search documentation screenshots (~20 images):** Mix of LinkedIn notification email screenshots and company website screenshots. Company website captures include: Inhance Digital case study pages, Gentle Giant Studios "About/History/Services" pages (showing 3D scanning and Light Stage-related work), UPtv-related content, Alan Sokol Schwab Network appearance capture, Realize Medical website, Forcepoint homepage, 3Gimbals website ("About" and "OMEN" product pages describing intelligence and investigations solutions), and Henry Street Settlement staff leadership page. Several LinkedIn notification screenshots show HTML source code with company names highlighted. The Substack article links for detailed documentation are visible as text. - **[Pages 179–180] LinkedIn graph/chart images (~8 images):** These pages contain the most concentrated visual evidence — images that appear to be part of Guertin's compiled graph/chart of LinkedIn searches showing the pattern of defense/intelligence entity searches. The images are small and appear to be thumbnails or cropped portions of larger documents. - **[Throughout Index 03, Pages 94–153] Scanline VFX job posting screenshots:** These pages contain rendered web content from the Lever job board showing Scanline VFX hiring pages, with the Scanline VFX logo visible. The URL "jobs.lever.co/scanlinevfx/" is shown in browser address bars. Content is primarily text-based job descriptions with minimal visual elements beyond company branding. **No anomalies in image integrity were detected**, though the low resolution of some images (particularly the LinkedIn HTML screenshots) makes fine detail difficult to verify. All screenshots appear to be authentic browser captures consistent with the platforms depicted. The document pages themselves show consistent PACER/CM/ECF headers ("CASE 0:24-cv-02646-JRT-DLM Doc. 21 Filed 07/12/24 Page X of 199") confirming federal court filing. ### Key People Referenced - **Matthew David Guertin*** — Defendant (state case), Plaintiff (federal case), patent holder (US 11,577,177), pro se filer - **Paul Debevec*** — USC ICT / Netflix / Eyeline Studios; alleged principal architect of patent fraud conspiracy; Light Stage inventor; 2022 Engineering Emmy recipient - **Bruce Rivers*** — Defense attorney, subject of ineffective assistance allegations; recipient of text/call communications documented in Index 04 - **Pinchas Gutter** — Holocaust survivor, subject of USC Shoah Foundation's "New Dimensions in Testimony" project; Guertin alleges AI-generated footage of him was fabricated - **Stephan Trojansky*** — Netflix patent holder (US 11,810,254); alleged co-conspirator through patent overlap - **Jules Urbach** — Founder/CEO of OTOY; alleged participant in fraudulent video conspiracy; SIGGRAPH presenter; described as Tim Hawkins' collaborator - **Jon Karafin** — Head of Light Field Video at Lytro; identified as directly involved - **Mark Bolas** — Director of Mixed Reality Research, USC ICT; identified as directly involved - **Cokie Nagano** — USC ICT researcher; appears in allegedly fraudulent videos; Guertin notes age discrepancies - **Norman Chan** — Interviewer for Adam Savage's Tested.com; conducted Light Stage interview with Debevec - **Pieter Peers, PhD** — Computer Graphics Scientist; discussed Light Stage 6 in videos; identified as possibly unknowingly involved - **Jay Busch** — USC ICT researcher; discussed "Digital Emily Project"; identified as possibly unknowingly involved - **Scott Squires** — VES Visual Effects Supervisor; identified as directly involved - **Toni Pace Carstensen** — VES Chair, VES Vision Committee; identified as directly involved - **Aaron Herman** — Associated with The Jewish Week; appears in video with Debevec - **Morgan Spurlock** — CNN host; subject of "Inside Man" Light Stage segment; Guertin argues age discrepancy proves fraud - **Lesley Stahl** — CBS 60 Minutes correspondent; conducted Pinchas Gutter interview - **Adam Savage** — Host, Tested.com; publisher of Debevec Light Stage videos - **Skip Rizzo** — USC ICT researcher; YouTube channel host of "Overview: USC ICT Graphics Lab" video - **Alan J. Sokol** — CEO, Hemisphere Media; connected to UPtv LinkedIn search - **Tom Daschle*** — Political figure; connected to InterMedia Partners / UPtv search - **Leo Hindery** — Media executive; connected to InterMedia Partners - **Tim Hawkins** — OTOY collaborator; author listed on claimed 2006 research papers (Note: likely refers to Tim Hawkins who runs OTOY — may be confused with Jules Urbach in text) - **Dr. Adam Milz*** — Author of January 3, 2024 Rule 20.01 exam report (referenced in Index 04 texts) ### Key Entities / Organizations Referenced - **Netflix, Inc.*** — Alleged co-conspirator; parent company of Scanline VFX; employer of Debevec and Trojansky - **Scanline VFX** — Netflix subsidiary; VFX studio with 7 global locations; employer described in ~20 job postings - **Eyeline Studios*** — Scanline VFX's virtual production division; central to Guertin's patent infringement theory - **USC Institute for Creative Technologies (ICT)*** — Research institution; Light Stage location; alleged fraud base - **USC Shoah Foundation** — "New Dimensions in Testimony" project; Pinchas Gutter recordings - **Google / YouTube*** — Alleged complicit in backdating video upload timestamps - **OTOY** — Company run by Jules Urbach; collaborator with Debevec; connected to fraudulent SIGGRAPH content - **DARPA** — Searched for Guertin on LinkedIn (×2); defense research agency - **U.S. Air Force / Air Force Research Labs (AFRL)** — LinkedIn search; MRO AR connection through Inhance - **U.S. Army Reserves** — LinkedIn search; connected to USC Cinema search - **Defense Intelligence Agency (DIA)** — Referenced in Guertin's LinkedIn search pattern - **USINDOPACOM** — Referenced in LinkedIn search pattern - **U.S. State Department** — Connected through Henry Street Settlement LinkedIn search - **Lockheed Martin** — Referenced in LinkedIn search pattern (×2) - **KBR Inc.** — Referenced in LinkedIn search pattern - **Forcepoint** — Intelligence/investigations firm; LinkedIn search on same day as criminal charges (1/21/23) - **3Gimbals** — Intelligence solutions firm; LinkedIn search on same day as criminal charges - **Inhance Digital** — AR/VR company; clients include USAF, Boeing, Microsoft, Booz Allen; first documented LinkedIn search - **Gentle Giant Studios** — 3D scanning studio; clients include Netflix, Warner Brothers, Marvel; features Light Stage technology - **UPtv** — Television network; connected to InterMedia Partners / Tom Daschle - **Realize Medical Inc.** — Ottawa-based medical VR company - **Henry Street Settlement** — NYC nonprofit; connection to U.S. State Department - **CBS News / 60 Minutes** — Broadcast segments featuring Pinchas Gutter footage - **CNN** — Morgan Spurlock "Inside Man" segment - **Visual Effects Society (VES)*** — Published "Light Field Imaging" video series - **Adam Savage's Tested / Tested.com** — Published Light Stage videos - **Digital Trends** — Published "New Dimensions in Testimony" article - **PBS / Frontline** — Published Holocaust technology article - **Voice of America (VOA)** — Published Pinchas Gutter technology article - **Rumble** — Video hosting platform where Guertin uploaded evidence videos - **Substack (MattGuertin.Substack.com)** — Guertin's publication platform for evidence documentation - **Internet Archive / WebArchive*** — Alleged complicit in supporting fraudulent historical record - **USC School of Cinematic Arts** — Referenced in LinkedIn search pattern (×2) - **Pacific Domes** — Company Guertin identifies as Light Stage 6 dome constructor - **Vail Place** — Community mental health organization; Guertin's caseworker referenced - **USPTO*** — Patent office; granted both Guertin's and Trojansky's patents ### Dates & Deadlines Mentioned - **2006 (claimed):** Publication date of Debevec's "Relighting Human Locomotion Using Flowed Reflectance Fields" paper (Guertin alleges fabricated) - **2012 (claimed):** "Prototype/proof of concept" filming of Pinchas Gutter (Guertin alleges fabricated) - **March 2014:** Authenticated filming of Pinchas Gutter (camera LCD dates visible: March 19 and March 20, 2014) - **April 16, 2022:** Inhance Digital LinkedIn search - **April 23, 2022:** Gentle Giant Studios LinkedIn search - **May 21, 2022:** UPtv LinkedIn search - **June 4, 2022:** Ottawa Hospital/Realize Medical LinkedIn search - **November 11, 2022:** First documented phone calls between Guertin and Rivers - **January 21, 2023:** Forcepoint/FOX/3Gimbals LinkedIn search — Guertin states this is the same day his criminal charges originated - **March 20, 2023:** Date of all Scanline VFX job posting screenshots - **March 27, 2021:** Guertin's text to Rivers announcing his provisional patent filing - **May 22, 2023:** Longest phone call between Guertin and Rivers; Rivers' alleged "powerful people" statement - **July 28, 2023:** Rivers informs Guertin of August 1 initial court appearance - **August 1, 2023:** Guertin's initial court appearance; texts Rivers about civil commitment - **September 19, 2023:** International patent filing deadline referenced by Guertin - **September 28, 2023:** DARPA/Henry Street Settlement LinkedIn search - **December 18–23, 2023:** Guertin's multi-camera evidence recording sessions (Videos 1–4) - **January 3, 2024 / January 11, 2024:** Dr. Milz Rule 20.01 exam (referenced in requests) - **January 15–29, 2024:** Text exchanges where Guertin requests Rule 20 report from Rivers - **April 18, 2024:** Guertin demands Rivers withdraw from case - **June 6, 2024:** Guertin's lengthy text message accusing Rivers of ineffective assistance - **July 12, 2024:** Date of federal filing (Exhibit N as part of Doc. 21) ### Forensic Flags & Anomalies 1. **PDF Metadata Provenance:** The Producer field shows "PyPDF2; modified using iText® 7.1.6 ©2000-2019 iText Group NV (Administrative Office of the United States Courts)." This confirms the document was assembled using Python's PyPDF2 library (consistent with Guertin's documented technical capabilities) and subsequently processed through the federal court's CM/ECF electronic filing system. The modification date (July 12, 2024) matches the filing date. Two "Bad annotation destination" warnings indicate minor PDF structural issues with bookmarks or internal links, consistent with complex multi-source PDF assembly. 2. **EXIF Metadata Discrepancy Claims:** Guertin's central evidentiary theory in Index 01 rests on discrepancies between YouTube upload dates and Google metadata creation dates. If verified, some discrepancies would be significant (e.g., 2013 upload dates with 2023 metadata). However, EXIF metadata can reflect video re-encoding, format conversion, or platform-side processing rather than original creation. This distinction is not addressed in the exhibit. 3. **January 21, 2023 Coincidence:** Guertin asserts that LinkedIn searches by Forcepoint, FOX, and 3Gimbals occurred on the same day his criminal charges originated. If the date correlation is accurate, this warrants investigation. However, no documentary proof of the charge origination date is provided within this exhibit (though it is documented in other filings). 4. **Index 05 — "Hypothetical" Framing of ChatGPT Conversation:** The conversation is transparently autobiographical despite the "hypothetical" framing. It provides Guertin's most detailed first-person account of the incident underlying the criminal charges, including: the 2–3 day isolation period, wrapping devices in aluminum foil, Mylar on walls, duct-taping door locks, firing a gun through the window at 11:30 AM on a Saturday, writing on walls, throwing documents and guns out the window, the surrender, extreme hunger, and hyperventilation at the police station. This constitutes a detailed admission of the physical acts while asserting justification through perceived threat. The ChatGPT responses validate the internal logic of Guertin's reasoning while noting the actions "carry inherent risks" and could "be seen as reckless." 5. **Cross-Exhibit Consistency:** The text messages in Index 04 from March 27, 2021, where Guertin tells Rivers about his patent filing and shares Dropbox links, establish a documented timeline of Rivers' knowledge of the patent. This is consistent with and supports Guertin's allegations in other filings that Rivers was aware of the patent's significance when retained for the criminal case. 6. **Redacted Phone Numbers:** Several phone numbers in Index 04 are partially redacted with "X" characters, though Guertin's own number (763-221-4540) and some other details remain visible. The redactions appear to have been made by Guertin before filing. 7. **Scanline VFX Seoul Office:** The job postings in Index 03 include a Seoul, South Korea location with Korean-language content, which connects to the Korea Trade-Investment Promotion Agency (KOTRA) references in prior filings regarding Netflix's international operations. 8. **No Independent Verification Provided:** While Guertin provides extensive screenshots and metadata claims, no third-party verification (forensic expert report, affidavit, or independent analysis) of the EXIF metadata claims is included in this exhibit. ### Cross-References - **Filing #1* (Motion for Judicial Notice):** Establishes Guertin's patent (US 11,577,177), Trojansky/Netflix patent (US 11,810,254), Debevec's Light Stage patents, and the Rearden LLC v. Disney case. Index 01 of this exhibit provides supporting evidence for claims made in Filing #1. - **Filing #8* (Netflix Whistleblower Part 1):** Contains overlapping evidence regarding Debevec's claimed 2006 research, Wayback Machine evidence, and the broader Netflix fraud theory. Index 01 expands on these themes significantly. - **Filing #9* (Motion for Substitute Counsel):** Index 04's text messages provide the underlying communications supporting the ineffective assistance claims formalized in Filing #9, including the May 22, 2023 "powerful people" statement and discovery request failures. - **Filing #12* (RICO Complaint):** This exhibit was filed contemporaneously as a supporting exhibit to the federal complaint cataloged in Filing #12. The LinkedIn searches (Index 02) and Scanline VFX job postings (Index 03) support the RICO complaint's allegations of enterprise activity. - **Case Docket Index #29:** Referenced in Index 04 as containing manipulated discovery photos that Rivers failed to address. - **Case Docket Index #30:** Extensively cross-referenced throughout Index 04 (text messages cite specific page numbers pp. 79–85). - **Case Docket Index #38:** Cross-referenced in Index 04 (p. 148 for April 18, 2024 text exchange). - **Filing #5* (Affidavit re: Attempted Assassination):** Index 05's "hypothetical" ChatGPT scenario describes the same incident detailed in Filing #5 (the January 2023 "standoff"), providing additional narrative context. - **Filing #4* (Exhibits B–C, Brodsky Patent Analysis):** The USC ICT and Light Stage technology analysis in Index 01 connects to the patent prior art analysis in Filing #4. - **Federal Case 0:24-cv-02646-JRT-DLM:** This exhibit is Doc. 21 in this case, filed before Judge Tunheim and Magistrate Micko. --- ## Filing #19 — Exhibit M: Guertin's Patent Theft Investigation | Field | Detail | |---|---| | Filing # | 19 | | Date Filed | July 12, 2024 | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Exhibit (Exhibit M) to Federal Civil Complaint — Investigative Compilation | | Case/Court | 0:24-cv-02646-JRT-DLM / U.S. District Court, District of Minnesota (Judge John R. Tunheim, Magistrate Judge Douglas L. Micko) | | Pages | 89 | | Bates / Doc ID | Doc. 20 (CASE 0:24-cv-02646-JRT-DLM); Exhibit M | ### Comprehensive Summary Exhibit M is a self-compiled 89-page investigative dossier assembled by Matthew David Guertin and filed as part of the federal civil action (0:24-cv-02646-JRT-DLM). The document is described on its cover page as containing "a significant amount of documents resulting from Guertin's own investigation and research into the theft of his intellectual property," which Guertin claims present "rather compelling evidence to support the massive criminal conspiracy being carried out against Mr. Guertin." The exhibit is organized into five indexed sections, each addressing a distinct facet of Guertin's allegations that his patented "InfiniSet" rotating treadmill technology (US Patent #11,577,177) was stolen, suppressed, or targeted for invalidation through fraudulent means by individuals and entities connected to Netflix, USC's Institute for Creative Technologies (ICT), Google, and the broader visual effects (VFX) industry. ### Index 01 (Pages 3–12): "The Paul Debevec 2023 SIGGRAPH Video Is Discovered" This section narrates how Guertin discovered what he alleges is a fraudulent SIGGRAPH presentation by Dr. Paul Debevec on August 8, 2023. Guertin recounts that his unnamed business partner flew to SIGGRAPH 2023 in Los Angeles, prompting Guertin to search YouTube for "SIGGRAPH." The first result he found was a video referencing Netflix and Eyeline Studios. Guertin presents a chain of redacted emails (subject line: "Re: Your InfiniSet, Inc Signed Documents") dated August 8, 2023, sent from "matt[redacted]" at 4:57 PM, 5:00 PM, and 5:38 PM, showing the rapid progression from asking about "InfiniSet duplicates" at SIGGRAPH to discovering the Debevec video (YouTube link: https://www.youtube.com/watch?v=tMpg29Vc0bU) and reacting with alarm. Guertin's commentary asserts that Debevec, identified as working at Eyeline Studios (a company Guertin claims was formed around Stephan Trojansky's patent), was fraudulently presenting a "rotating treadmill from 2006" and claiming credit for volumetric capture research involving a rotating treadmill — technology Guertin considers derivative of or identical to his InfiniSet patent. Guertin claims Debevec's use of the word "volumetric" when referencing 2006 research is anachronistic and deceitful, as that term was allegedly never used in the actual 2006 papers. Guertin presents screenshots from the SIGGRAPH video showing: (1) the title slide "The Full Spectrum of Virtual Production" identifying Debevec as Chief Research Officer of Netflix Eyeline Studios and Adjunct Research Professor at USC ICT, dated May 17, 2023; (2) a video frame referencing "Einarsson et al. Relighting Human Locomotion. EGSR 2006" showing a person on what appears to be a rotating treadmill surrounded by lights; (3) a 2019 segment referencing "Guo et al. The Relightables. SIGGRAPH Asia 2019" showing a standard (non-rotating) treadmill setup; (4) a Debevec biography slide listing extensive film credits and affiliations; (5) a "THANK YOU" credits slide listing collaborators, thanks, research sponsors, and notably a "Special Thanks" section including Stephan Trojansky. Guertin then presents what he claims is video forensic analysis conducted in Blender (visible interface metadata: Resolution 1920x1080, 24fps, Frame Range 1–250, file named "SIGGRAPH_2023_Paul_Debev...") asserting the video was "generated using AI." He presents extreme color curve analysis screenshots showing distorted, highly saturated versions of the video frames, claiming these reveal "structured patterns" in the pixel data around Debevec's picture-in-picture window — specifically multi-colored pixel groupings of consistent heights (one pixel, one pixel, two pixels, etc.) that he interprets as either an encoding system or evidence of synthetic generation. He acknowledges he has not investigated this further but asserts it is "definitely structured" and not compression artifacts. Guertin also notes that Debevec's SIGGRAPH affiliations were "not disclosed at all" in the video and that Debevec "candidly admits to writing a research paper with ChatGPT." He directs viewers to custom video edits at MattGuertin.Substack.com/p/netflix-fraud-is-discovered. The section concludes with a ChatGPT transcript in which Guertin asks the AI about USC ICT's Light Stage technology, Google's "Relightables" research, and whether his own patent (US Patent #11,577,177 — "Motorized Rotatable Treadmill and System for Creating the Illusion of Movement") could complement these technologies. The ChatGPT responses affirm potential synergies between Guertin's patent and both the Light Stage system and Google's Relightables project. ### Index 02 (Pages 16–40): "Paul Debevec Takes Credit For MOVA Contour Technology" This section presents Guertin's research into the origins of the 3D facial scanning technology that Debevec is credited with, arguing that the actual technology was MOVA Contour, invented by Steve Perlman of Rearden Companies. Guertin asserts Debevec is falsely "portraying himself as having created" the 3D face scanning technology. The section contains extensive supporting documentation: - A Vimeo screenshot of "MOVA® Contour® Reality Capture Overview" by Rearden Companies (URL: https://vimeo.com/424337703), showing the MOVA Contour logo and branding. - A VentureBeat article excerpt describing how Digital Domain used Debevec's work for Benjamin Button, with Debevec quoted describing his Light Stage approach. Guertin highlights that Debevec currently works as "chief researcher at Netflix's Eyeline Studios." - Promotional quotes from Ed Ulbrich (Digital Domain) and David Fincher praising Contour technology — displayed as graphical banners from MOVA's website. - A list of MOVA's past clients: Digital Domain, Electronic Arts, Industrial Light & Magic, Marvel Studios, Twentieth Century Fox, Warner Brothers — accompanied by a screenshot of a performer being captured by an array of cameras. - A Hollywood Reporter article dated August 3, 2007 by Carolyn Giardina titled "Advances sure to capture attention at Siggraph," discussing performance capture technology including MOVA Contour and Paul Debevec's SIGGRAPH involvement. Multiple passages are yellow-highlighted. - A MOVA/Gentle Giant Studios press release (August 6, 2007) about a "First-Ever Moving 3-D Sculpture of Live-Action Performance" at SIGGRAPH 2007, with extensive yellow-highlighted passages about the Contour Reality Capture System. - A MOVA press release about the Disney film "John Carter" (March 9, 2012), detailing how MOVA Contour was used for facial capture, with highlighted passages noting MOVA's use in Benjamin Button, Harry Potter, Pirates of the Caribbean, Transformers, and other films. The "About MOVA" section identifies it as "a wholly-owned subsidiary of cloud gaming pioneer OnLive" and an "Academy Award-nominated company." - An Animation World Network article about "Percy Jackson" VFX, with a highlighted passage about MPC using MOVA Contour for Hades' facial capture. - A San Francisco Business Times article (March 1, 2009) titled "Bay Area inventor is the face behind the face behind 'Button'" about Steve Perlman's motion capture technology winning an Academy Award for Benjamin Button. Multiple names are highlighted: Brad Pitt, F. Scott Fitzgerald, Steve Perlman, Ed Ulbrich, David Fincher. - Google Patents screenshots for patent US7548272B2 — "System and method for performing motion capture using phosphor application techniques" — showing Debevec's 2002 publication "The Light Stage: Photorealistically Integrating Real Actors into Virtual Environments" as related prior art. The similar documents table is visible. A separate page shows the full patent face for US7,548,272 B2 (Perlman et al.), filed June 7, 2006, granted June 16, 2009, assigned to OnLive, Inc. - A Wired article (October 23, 2007) titled "Beowulf F/X Masters Put a New Spin on 3-D" with highlighted passages about Gentle Giant Studios partnering with MOVA, Steve Perlman as founder, and the aspiration toward full-body capture. Photographs show the physical 3D Zoetrope apparatus and a mannequin head model. - A Hollywood Reporter article (September 26, 2006) titled "emotion motion" about MOVA Contour technology, with highlighted passages about phosphorescent makeup, David Fincher's plans for Benjamin Button, and Steve Perlman's role. - An NPR article (February 17, 2009) "Building The Curious Faces Of 'Benjamin Button'" with highlighted passages about Light Stage Six at USC ICT and Paul Debevec — including a headshot photograph of Debevec and a photo of the Light Stage apparatus with a person inside. - A photograph (page 33) showing a woman standing before the MOVA Contour capture rig — a large cylindrical metal framework with cameras, with a monitor showing a 3D rendered face. Blue lighting visible in background. - Quotes from Steve Perlman about Contour's capabilities regarding photorealism and crossing the "Uncanny Valley." - A Hollywood Reporter "Contour mapping intricate detail" article (July 31, 2006) showing the full-page layout with technical diagrams of the Contour capture process. - A Boston Globe blog post (July 31, 2006) "Crossing the Uncanny Valley" with highlighted passages about Perlman demonstrating Contour at SIGGRAPH 2006. - A Computer Graphics World article "Heavy-Handed" about The Incredible Hulk (July 2008) detailing how MOVA data was used for Edward Norton's facial capture to create Hulk's expressions, with highlighted passages about MOVA's facial-capture sessions with Tim Roth for Abomination. ### Index 03 (Pages 41–69): "Federal Court Case 3:17-cv-04006 | Theft of MOVA Contour Technology" This section reproduces selected pages from the federal complaint in Rearden LLC, Rearden Mova LLC v. The Walt Disney Company et al. (Case 3:17-cv-04006, N.D. Cal., San Francisco Division, filed July 17, 2017). The complaint was filed by Hagens Berman Sobol Shapiro LLP on behalf of Rearden LLC and Rearden Mova LLC, alleging copyright, patent, and trademark infringement against Walt Disney Company, Walt Disney Motion Pictures Group, Buena Vista Home Entertainment, Marvel Studios, and Mandeville Films. Key reproduced pages include: - The complaint cover page (Page 1 of 307) showing the caption and "DEMAND FOR JURY TRIAL." - Paragraphs 23–25 (Pages 11–12 of 307) describing MOVA Contour's introduction at SIGGRAPH on July 31, 2006, with photographs from The Hollywood Reporter and New York Times showing the phosphor-based makeup application process. - Paragraph 44 (Page 24 of 307) quoting Ed Ulbrich's TED Talk describing MOVA Contour as the "breakthrough" that made Benjamin Button possible, with highlighted passages about the technology being "beyond the technology of the day." - Paragraphs 50–53 (Pages 27–29 of 307) showing Contour Program output files including Makeup Pattern, Captured Surface, and Tracking Mesh outputs of Brad Pitt's face, with images of the green phosphorescent makeup captures and the resulting 3D models. - Paragraph 54 (Page 30 of 307) describing photorealistic reverse-aging from MOVA Contour data, noting Disney hired MOVA for TRON: Legacy (2008). - Paragraph 57 (Page 35 of 307) describing a Digital Domain photograph showing the "stolen MOVA Contour rig" with red circles highlighting a Rearden Inc. Asset Tag (#10393, Basler 102f Camera, Serial #20606024) that the "thieves neglected to remove." - Paragraphs 64–73 (Pages 38–40 of 307) describing the MOVA Assets, their classification as trade secrets under California's Uniform Trade Secrets Act and federal law, and listing 15 major motion pictures that used MOVA Contour (collectively grossing ~$9.5 billion globally), the transfer of assets from Rearden to OnLive to OL2 to Rearden Mova, and the Academy of Motion Picture Arts and Sciences awarding the Scientific and Technical Award to MOVA Contour on February 9, 2015. - Paragraphs 95–97 (Page 46 of 307) alleging that neither Rearden nor Rearden Mova authorized use of MOVA Contour by DD3, Marvel, or Disney in Guardians of the Galaxy (grossing $333M US/$773M globally). Guertin also includes YouTube video thumbnails and links for: (1) "Why Everyone Is Fighting To Get This VFX Tool | MOVA" and (2) "Oscar SciTech Award 2015 for Mova Contour." He includes a link to OTOY's GTC 2013 video "The Convergence of Cinema and Games: From Performance Capture to Final Render," noting that the thumbnail shows images of Brad Pitt that he says should be compared to those in the federal complaint, and asserting this video shows MOVA Contour technology being "re-assigned" to Debevec's "Light Stage 6." A grid of nine screenshots (page 50) shows the MOVA Contour capture rig from various angles, real-time rendered faces, and the Contour branding — labeled as stills from various MOVA demonstration videos. The section includes a Hollywood Reporter article by Scott Johnson about Digital Domain's legal setback, reporting that a federal judge in San Francisco (Judge John S. Tigar) issued a preliminary injunction on June 17, 2017, freezing MOVA technology after finding that Virtual Global Holdings and Shenzhen Haitiecheng Science and Technology had behaved "fraudulently" in transferring MOVA technology through various Chinese firms after a 2013 acquisition from Greg LaSalle for $25,000. The article describes FBI involvement, reporting to the House Permanent Committee on Intelligence, export prohibition concerns, and Steve Perlman's conflict with his former employee LaSalle over the 2014 SciTech Academy Award. Highlighted passages discuss Digital Domain's admission that the ban "could be disastrous," the judge finding "badges of fraud," and the FBI's interest in potential economic espionage. The section concludes with six pages of hyperlinks (pages 63–69) to dozens of source documents hosted on Guertin's Substack pages and original source URLs, covering articles from Hollywood Reporter, Daily Mail, The Wrap, Disney Dining, Courthouse News, Wired, NPR, Computer Graphics World, VentureBeat, Bloomberg, and court filings. ### Index 04 (Pages 70–87): "Visual Effects Society | 4 Part Conference is Backdated FRAUD" This section presents Guertin's analysis — largely generated with assistance from ChatGPT — alleging that a four-part Visual Effects Society (VES) conference video series titled "Light Field Imaging: The Future of VR-AR-MR" (purportedly from 2015) was actually "backdated" by YouTube/Google/Alphabet to create fraudulent prior art targeting Guertin's InfiniSet patent. The section opens with a screenshot of the conference panel video and a link to a Rumble video (https://rumble.com/v449oyx-video-1-part-1-of-1.html) described as "BACKDATED CRIMINAL FRAUD PROOF." The analysis — presented as structured ChatGPT output with bullet points — argues: 1. **Indicators of Advanced Knowledge Beyond 2015**: The discussions about light field technology for high-resolution VR/AR applications, real-time rendering, and complex cinematography techniques suggest knowledge unavailable until several years after 2015. VR was "mostly limited to gaming and basic simulations" in 2015, and AR was "in its nascent stage." 2. **Redefinition of 'Light Field'**: The conference speakers allegedly expanded the definition of "Light Field" to encompass synthetic rendering, virtual lenses, and depth information — a breadth not typical of 2015 understanding — interpreted as an attempt to retroactively establish more advanced knowledge. 3. **Correlation with InfiniSet Patent**: The analysis maps the conference content to specific InfiniSet patent features, including: the motorized rotatable treadmill, control of treadmill/turntable speed, vibration sources for haptic feedback, camera-treadmill synchronization, and use in virtual environments. The conference's emphasis on "walking" and movement in VR is highlighted as directly correlating with the InfiniSet patent. Four detailed analyses follow, one for each conference video: - **Video 1**: Paul Debevec — "Light Field Imaging: The Future of VR-AR-MR- Part 1" (YouTube: https://www.youtube.com/watch?v=Raw-VVmaXbg). Screenshot shows a presentation slide with an 18x7 fisheye camera array and a person wearing a VR headset, labeled "from Stanford SCIEN Workshop on Light Field Imaging, 2/12/2015." Analysis focuses on light fields, photogrammetry, depth mapping, Light Stage technology, and real-time graphics. - **Video 2**: Mark Bolas — Part 2 (YouTube: https://www.youtube.com/watch?v=ftZd6h-RaHE). Screenshot shows lab equipment with caption "Time-lapse used just for this capture video, all CG video is real-time." Analysis emphasizes facial nuances in VR, walking/movement importance, and "Near Field VR." - **Video 3**: Jules Urbach — Part 3 (YouTube: https://www.youtube.com/watch?v=0LLHMpbIJNA). Screenshot shows a photorealistic rendered interior scene. Analysis covers photogrammetry, dynamic rendering, position tracking, and technological convergence. - **Video 4**: Jon Karafin — Part 4 (YouTube: https://www.youtube.com/watch?v=_PVok9nUxME). Screenshot shows a person in motion-capture suit with a "DEPTH SCREEN" label. Analysis addresses light field surface interaction, dynamic range, high frame rate challenges, and data management. Each analysis concludes with an assertion that the video's content "targets" or "complements" the InfiniSet patent's core technology. ### Index 05 (Pages 88–89): "You Will Own Nothing and be Happy Includes All of Your Intellectual Property" This final section is a personal narrative by Guertin expressing frustration and despair at his situation. Key assertions include: - He has "always been willing to outright sell" his intellectual property, and the entities involved "could've just approached me and paid me what would've amounted to pocket change for them." - He alleges they are "continuing to manipulate the court system in Hennepin County to literally try to have me locked away in a mental institution after they scared the living shit out of me." - He references a "'former CIA' welder" he was connected with who allegedly had knowledge of his working prototype. - He lists multiple government and military entities he claims have been searching for his LinkedIn profile: US Army, US Air Force, State Department, DARPA, Defense Intelligence Agency, US Indo Pacific Command, USC, Lockheed Martin, KBR Inc, Forcepoint, 3Gimbals. - He has filed fraud reports with the FTC, FBI, and SFO (UK Serious Fraud Office), two police reports, and contacted the US Secret Service. - He states Amy Klobuchar "knows what is going on." - He describes the period from conceiving InfiniSet in February 2021 to his "life intentionally being derailed in late 2022" as "one of the most exciting adventures in my life." - He concludes with contact information: www.MattGuertin.com and Rumble.com/user/MattGuertin. ### Legal Issues & Arguments Raised - Patent theft and intellectual property conspiracy targeting US Patent #11,577,177 (InfiniSet) - Fraudulent attribution of MOVA Contour technology to Paul Debevec / Light Stage system - Alleged AI-generated or manipulated video evidence (SIGGRAPH 2023 presentation) - Alleged backdating of YouTube videos (VES 2015 conference) to create fraudulent prior art - Copyright, patent, and trademark infringement in the VFX industry (via Rearden v. Disney case) - Theft of trade secrets (MOVA Assets) under California UTSA and federal DTSA - Economic espionage involving Chinese entities (SHST, VGH) and FBI investigation - Conspiracy involving government agencies (DARPA, DIA, US Army, Air Force, State Dept.) - Alleged manipulation of the Minnesota court system to commit Guertin to a mental institution - Inequitable conduct / fraud on the patent office (implied re: Trojansky/Debevec patents) ### Factual Allegations & Key Assertions - On August 8, 2023, Guertin discovered the Debevec SIGGRAPH video within three minutes of asking his business partner about SIGGRAPH - Paul Debevec's 2023 SIGGRAPH presentation at Netflix Eyeline Studios featured a "rotating treadmill from 2006" that Guertin claims is AI-generated fraud - Debevec's SIGGRAPH "Thank You" slide includes Stephan Trojansky in "Special Thanks" — Trojansky is the inventor on the competing Netflix patent (US 11,810,254) - Blender-based video analysis at 1920x1080, 24fps reveals alleged "structured patterns" in pixel data around Debevec's PIP window - Debevec allegedly admitted to writing a research paper with ChatGPT - The MOVA Contour facial capture technology was actually invented by Steve Perlman (Rearden Companies), not Debevec - MOVA Contour was used in 15+ major motion pictures grossing collectively ~$9.5 billion - US Patent 7,548,272 B2 (Perlman et al., filed 2006, granted 2009) covers MOVA's phosphor-based motion capture system - Rearden LLC filed suit against Disney et al. (3:17-cv-04006) on July 17, 2017 for unauthorized use of MOVA technology - Judge Tigar found "badges of fraud" in the Chinese firms' handling of MOVA assets and issued a preliminary injunction June 17, 2017 - Digital Domain's stolen MOVA rig photograph showed an unremovedRearden Asset Tag (#10393) - The FBI investigated potential economic espionage related to MOVA source code export - Perlman reported to the House Permanent Committee on Intelligence - Greg LaSalle sold MOVA technology to SHST for $25,000 in 2013 - A four-part VES conference (purportedly 2015) was allegedly backdated by YouTube/Google to create prior art against InfiniSet - ChatGPT analysis affirms InfiniSet patent's potential synergies with Light Stage and Relightables technologies - Multiple government/military entities (US Army, DARPA, DIA, etc.) allegedly searched for Guertin's LinkedIn - Guertin conceived InfiniSet in February 2021; his life was "derailed" in late 2022 - Guertin encountered a "'former CIA' welder" who knew about his working prototype ### Procedural Posture Filed as Exhibit M to Doc. 20 in the federal civil action 0:24-cv-02646-JRT-DLM (Guertin v. various defendants) on July 12, 2024. This exhibit is part of a larger set of exhibits (A through at least Q) supporting Guertin's federal claims. The federal case was assigned to Judge John R. Tunheim with Magistrate Judge Douglas L. Micko. This exhibit compiles Guertin's independent research and investigation into alleged patent theft and constitutes his evidentiary basis for claims of a large-scale conspiracy involving technology companies, government entities, and the VFX industry. ### Exhibit / Attachment Inventory This exhibit is itself an attachment to the federal complaint. It contains embedded/referenced sub-documents: | Sub-Index | Title | Pages (within Exhibit M) | |---|---|---| | Index 01 | The Paul Debevec 2023 SIGGRAPH Video Is Discovered | pp. 1–12 (PDF pp. 3–12) | | Index 02 | Paul Debevec Takes Credit For MOVA Contour Technology | pp. 1–25 (PDF pp. 16–40) | | Index 03 | Federal Court Case 3:17-cv-04006 — Theft of MOVA Contour Technology | pp. 1–29 (PDF pp. 41–69) | | Index 04 | Visual Effects Society — 4 Part Conference is Backdated FRAUD | pp. 1–18 (PDF pp. 70–87) | | Index 05 | You Will Own Nothing and be Happy Includes All of Your IP | pp. 1–2 (PDF pp. 88–89) | ### Referenced external documents (extensive list): - Rearden v. Disney complaint (3:17-cv-04006, 307 pages) - US Patent 7,548,272 B2 (Perlman et al.) - US Patent 11,577,177 (Guertin — InfiniSet) - Dozens of articles from Hollywood Reporter, Wired, NPR, Boston Globe, VentureBeat, Animation World Network, Computer Graphics World, Daily Mail, The Wrap, Courthouse News, etc. - MOVA press releases (multiple) - Google Patents records - YouTube videos (SIGGRAPH 2023, VES 2015 Parts 1–4, OTOY GTC 2013, MOVA documentary, Oscar SciTech 2015) - Vimeo video (MOVA Contour Reality Capture Overview) - Rumble video (Guertin's backdating analysis) - Multiple Substack-hosted PDF archives (MattGuertin.Substack.com and Matt1Up.Substack.com) ### Visual Evidence Inventory - **[Page 3] Email screenshot (1 of 3):** Redacted email in "Re: Your InfiniSet, Inc Signed Documents" thread. From: matt[redacted]. To/CC: redacted (black bars). Date: Tuesday, August 8th, 2023 at 4:57 PM. Body: "You haven't seen any InfiniSet duplicates yet at SIGGRAPH have you [redacted]?" Standard email formatting, no anomalies in layout. Redaction bars are solid black rectangles covering full email addresses. - **[Page 3] Email screenshot (2 of 3):** Same thread. From: matt[redacted]. Date: Tuesday, August 8th, 2023 at 5:00 PM. Body: "NETFLIX / EYELINE STUDIOS - around 3:00 mark" with YouTube link (https://www.youtube.com/watch?v=tMpg29Vc0bU). Three-minute gap between emails consistent with claimed discovery timeline. - **[Page 4] Email screenshot (3 of 3):** Same thread. From: matt[redacted]. Date: Tuesday, August 8th, 2023 at 5:38 PM. Body contains YouTube link and timestamp "58:53" followed by profane commentary about Eyeline Studios and Stephan Trojansky. 38-minute gap from prior email. - **[Page 5] Video screenshots (2 images):** Top: SFACM SIGGRAPH video conference screenshot showing Paul Debevec at a desk with architectural imagery behind him; title "The Full Spectrum of Virtual Production"; PIP window shows "Henry LaBounta" label. Bottom: Presentation title slide showing "Dr. Paul Debevec, Chief Research Officer, Netflix Eyeline Studios, Adjunct Research Professor, USC ICT"; dated "May 17, 2023"; logos for California IBL IRL (dmv.ca.gov), USC ICT, Eyeline Studios, and Netflix (N). PIP shows "Paul Debevec" label. Multiple thumbnail images of virtual production environments visible. - **[Page 6] Video screenshot:** Frame from SIGGRAPH presentation showing a person (bald, wearing dark clothing) on what appears to be a rotating treadmill surrounded by an array of lights in a circular configuration. Caption reads "Einarsson et al. Relighting Human Locomotion. EGSR 2006." PIP shows "Paul Debevec" label. Play button visible center-frame. The figure appears to be a CGI or motion-captured person, not clearly photographic — Guertin alleges this person "isn't even real." - **[Page 7] Video screenshot:** Frame showing "The Relightables: Time Multiplexed Color Gradient Illumination, SIGGRAPH Asia 2019." Multiple figures visible in a camera array with lighting apparatus. Small images at left show a person holding a basketball with color gradient circles. Caption: "Guo et al. The Relightables. SIGGRAPH Asia 2019." Note: "~100x 12MP cameras @ 60Hz" visible. PIP shows "Paul Debevec." This shows a standard (non-rotating) treadmill, contrasting with the 2006 segment. - **[Page 8] Video screenshot (top):** Debevec's SIGGRAPH biography slide showing "The Full Spectrum of Virtual Production" with multiple production stills. Dense biographical text references Light Stage 3, USC ICT, films including The Matrix, Spider-Man 2, Benjamin Button, Avatar, Gravity, Furious 7, Blade Runner: 2049, Gemini Man, Free Guy. Lists Academy Awards, SMPTE Progress Medal, Lifetime Achievement Emmy. PIP shows "Henry LaBounta." - **[Page 8] Video screenshot (bottom):** Blender video editor interface showing a dark frame of the Debevec video. Right panel shows Scene/Format settings: Resolution X: 1920 px, Y: 1080 px, 100%, Aspect 1.000/1.000, Frame Rate: 24 fps, Frame Range 1–250, File Format: FFmpeg Video, Color: RGB. Bottom timeline shows markers at 01:00:14+16 through 01:00:22+16 with current frame at 01:00:18+21. Tab at bottom reads "SIGGRAPH_2023_Paul_Debev..." This is Guertin's claimed forensic analysis workspace. File naming and interface consistent with Blender 2.8+ video sequence editor. - **[Page 9] Video screenshot (top):** Close-up frame of Debevec speaking, with artwork visible in background. PIP label "Paul Debevec." Below text: "Candidly admits to writing a research paper with chatGPT..." - **[Page 9] Video screenshot (bottom):** SIGGRAPH presentation "THANK YOU" slide. Lists Collaborators (30+ names including Chloe LeGendre, Xueming Yu, Dima Smirnov, Graham Fyffe, etc.); Thanks (Randall Hill, Joe Letteri, Stephen Rosenbaum, Chris DeFaria, Tim Webber, Darren Hendler, Kathleen Haase, Image Metrics, Sony Pictures Imageworks, Digital Domain, Weta Digital, ILM, Activision, Warner Brothers, PULSE Entertainment, SOOVII); Research Sponsors (ARL, USC Office of the Provost, Google Daydream, Google Research, Netflix Data & Insights, Eyeline Studios); **Special Thanks: Henry LaBounta, Cassidy Curtis, Lianette Alnaber, Connie Siu, Stephan Trojansky**. Contact: vgl.ict.usc.edu, www.debevec.org, debevec@gmail.com. PIP shows "Paul Debevec." - **[Page 10] Color-curve-manipulated screenshots (2 images):** Top: Extreme color curve analysis of the "Einarsson et al. 2006" rotating treadmill frame, showing highly distorted colors with magenta/cyan/yellow artifacts. The circular camera array structure visible but heavily distorted. PIP of Debevec also color-distorted. Bottom: Same treatment applied to the presentation overview, showing heavily distorted pinks and magentas with small rectangles of color visible. PIP shows "Henry LaBounta" with color distortion. Text annotation states these reveal "structured information in the pixel data." - **[Page 11] Color-curve-manipulated screenshots (2 images):** Top: Color-distorted frame labeled "virtual viewpoint control" / "Einarsson et al. Relighting Human Locomotion. EGSR 2006." Shows a person standing in the distorted lighting array with extreme pixel artifacts. Structured colored rectangles visible at edges of PIP window. Bottom: Another distorted frame labeled "compositing with matched viewpoint and lighting" showing side-by-side interior/exterior composited scene with a running figure. PIP shows "Paul Debevec" with edge artifacts. - **[Page 12] Color-curve-manipulated screenshots (2 images):** Top and bottom: "The Relightables: Time Multiplexed Color Gradient Illumination, SIGGRAPH Asia 2019" frames with extreme color manipulation. Person holding basketball visible at left. Red dashed lines visible at bottom of each frame. PIP windows show Debevec with structured pixel groupings at edges. - **[Page 14] Patent summary graphic:** Full page showing patent title "MOTORIZED ROTATABLE TREADMILL AND SYSTEM FOR CREATING THE ILLUSION OF MOVEMENT" with "US Patent # 11,577,177" and quoted patent claims in bold text. This appears to be a custom-formatted summary document, not the actual patent face page. Key bolded phrases highlight camera synchronization, LED virtual film set usage, and audio/visual/tactile cue sources. - **[Page 16] Vimeo screenshot:** "MOVA® Contour® Reality Capture Overview" video by Rearden Companies. Shows MOVA Contour logo (blue "mova" with orange character, "contour" text, "REALITY CAPTURE" subtitle). Duration 04:56. Standard Vimeo interface. - **[Page 17] Promotional graphic (top):** Black background with orange text quote: "'Contour is a breakthrough technology for digital effects production.' —Ed Ulbrich, Senior Vice President and Executive Producer, Digital Domain." - **[Page 17] Promotional graphic (bottom):** Black background with orange text quote: "'Contour...opens up so many possibilities for both two- and three-dimensional image makers and storytellers.' —David Fincher, Director of Panic Room, Fight Club, The Game, Se7en, Alien³ and Zodiac." - **[Page 18] Video screenshot:** Frame from MOVA promotional video showing a performer being captured in front of an array of cameras and equipment. Blue lighting visible. Caption: "Performers are captured in front of an array of cameras." - **[Page 19] Newspaper article scan:** The Hollywood Reporter, Friday, August 3, 2007. Full-page article titled "Advances sure to capture attention at Siggraph" by Carolyn Giardina. Standard newspaper column layout. Multiple passages highlighted in yellow. Contains references to SIGGRAPH, Paul Debevec, MOVA, Steve Perlman, Gentle Giant Studios, Beowulf, and various VFX technologies. Published with permission notation at bottom. - **[Page 20] Press release:** MOVA/Gentle Giant Studios joint press release with both company logos. Dated "Aug. 6, 2007 – SAN DIEGO -- SIGGRAPH." Multiple passages highlighted in yellow. "Gentle Giant Studios" logo shows a figure. "MOVA contour" logo visible. - **[Page 21] Press release page 2:** Continuation of MOVA/Gentle Giant release. "3-D ZOETROPE DEBUTS AT SIGGRAPH/Page 2." Extensive yellow-highlighted passages describing the Contour Reality Capture System's technical specifications. - **[Page 22] Press release:** MOVA press release titled "MOVA Motion Capture Technology Delivers New Levels of Realism to Highly Anticipated John Carter Movie" dated March 9, 2012. Extensive yellow highlighting throughout. "About MOVA" section identifies it as subsidiary of OnLive and lists clients. - **[Page 23] Webpage screenshot:** Animation World Network article page about Percy Jackson VFX. Shows article text with sidebar including job listings and comments. A still image shows a CGI creature (Hydra) with caption "MPC used Mova's Contour for Hades and higher resolution fire sim." Timestamp: "3/17/24, 21:52." - **[Page 24] Webpage screenshot:** San Francisco Business Times article. Title: "Bay Area inventor is the face behind the face behind 'Button'" by Jim Gardner, dated March 1, 2009. "IN THIS ARTICLE" sidebar lists Brad Pitt, F. Scott Fitzgerald, Steve Perlman, Ed Ulbrich, David Fincher — all highlighted in yellow. Body text heavily highlighted describing Perlman's motion capture technology winning Academy Award for Benjamin Button. Timestamp: "3/17/24, 21:53." - **[Page 25] Google Patents screenshot:** Scholar page for Debevec 2002 — "The Light Stage: Photorealistically Integrating Real Actors into Virtual Environments." Searched query "7548272." Shows publication year 2002, venue: Svenska Föreningen för Grafisk Databehandling. Similar Documents table visible listing patents from 2002–2024. Highlighted entries include US7548272B2, Debevec 2002, and Debevec 2003. Timestamp: "3/17/24, 11:35 PM." - **[Page 26] Webpage screenshot:** Wired article dated October 23, 2007 by James Lee: "Beowulf F/X Masters Put a New Spin on 3-D." Shows photograph of the physical 3-D Zoetrope apparatus — a large mechanical device with circular array on top. Photo credit: Sian Kennedy. Yellow highlights on "Gentle Giant Studios," "Angelina Jolie," "The company partnered with Mova, a pioneer," and the quote about full-body version of Angelina. - **[Page 27] Webpage screenshot continued:** Rest of Wired article. Photo of mannequin head (Thomas Heinser photo). Another photo credited Sian Kennedy. Yellow highlights on capture process description, "Mova passes the gigavoxels of camera data (voxels are three-dimensional pixels) to Gentle Giant." - **[Page 28] Newspaper article scan:** The Hollywood Reporter, Tuesday, September 26, 2006. Full-page article titled "emotion motion — Contour shapes a new level of digital performance" by Carolyn Giardina. Standard newspaper layout. Yellow highlights on key passages about Steve Perlman, phosphorescent makeup, David Fincher's plans for Benjamin Button. - **[Page 29] Webpage screenshot:** NPR article page "Building The Curious Faces Of 'Benjamin Button'" dated February 17, 2009 by Laura Sydell. Shows NPR branding, "The 81st Annual Academy Awards" header. Large photograph of elderly Benjamin Button character from the film. Timestamp: "3/17/24, 21:49." Yellow highlights on title elements. - **[Page 30] Webpage screenshot continued:** NPR article continued. Shows photograph of USC ICT Light Stage Six — a large spherical dome of lights with a person standing inside on a circular platform. Caption highlighted: "Light Stage Six at the University of Southern California's Institute for Creative Technologies helps FX wizards create realistic lighting effects." Credit: USC Institute for Creative Technologies. - **[Page 31] Photograph:** Large headshot of Paul Debevec, captioned (highlighted): "Paul Debevec — who worked on the digital technology used in Benjamin Button — lit his head shot using one of the institute's lighting stages." Below: "Clips from 'Simone'" and reference to "The Curious Case of Benjamin Button." - **[Page 32] Webpage screenshot continued:** NPR article text with yellow highlights on passages about Digital Domain, the "Uncanny Valley," Debevec helping develop "some" of the technology, and his quote about future film projects refining the technologies. - **[Page 33] Full-page photograph:** Large high-resolution photograph of a woman (blonde, ponytail, black tank top, jeans) standing with her back to the camera, facing the MOVA Contour capture rig — a large cylindrical metal framework with multiple cameras, monitors, and blue-lit cables. A monitor at center shows a 3D thermal/color map of a face. The rig is industrial-grade with aluminum framing. - **[Page 35] Newspaper article scan:** The Hollywood Reporter, Monday, July 31, 2006. Full-page article titled "Contour mapping intricate detail — Mova revolutionizing motion-capture process with new system" by Chris Marlowe. Contains a sidebar graphic labeled "Photo finish" showing 5 stages of the Contour capture process (live performance, phosphorescence, surface geometry, textured geometry, vertex tracking). Yellow highlights throughout. - **[Page 36] Webpage screenshot:** Wayback Machine capture of Boston Globe "OnSite" blog, dated Monday, July 31, 2006. Title: "Crossing the Uncanny Valley." Yellow highlights on passages about Steve Perlman, Contour technology at SIGGRAPH, phosphorescent makeup process, and working with Hollywood. Wayback Machine URL bar visible. Timestamp: "3/17/24, 10:15 PM." - **[Page 37] Webpage screenshot:** Computer Graphics World article "Heavy-Handed" about The Incredible Hulk. Banner image of Hulk transformation. Yellow highlights on passages about MOVA facial-capture sessions, Edward Norton's face data, and using Mova data for Hulk's expressions. Timestamp: "3/17/24, 22:29." - **[Page 38] Webpage screenshot continued:** CGW article continued. Image of CGI Abomination character. Yellow highlights on passages about returning to Mova for Tim Roth facial capture for Abomination. - **[Page 39] Google Patents screenshot:** Full web page for US7548272B2 — "System and method for performing motion capture using phosphor application techniques." Shows patent details panel: Inventors: Stephen G. Perlman, John Speck, Roger van der Laan, Kenneth A. Pearce, Lisa Jo Cohen, Kelly Leigh Tunstall. Current Assignee: Rearden Mova for Benefit of Rearden LLC, Virtue Global Holdings Ltd, Insolvency Services Group Inc, Rearden Mova LLC. Filed 2006, Granted 2009, Active, expires 2027-08-30. Claims section partially visible. Patent drawings showing camera/light setup diagrams visible at bottom. Timestamp: "3/17/24, 7:47 PM." - **[Page 40] Patent face page:** Full image of US 7,548,272 B2 patent document first page. Title: "SYSTEM AND METHOD FOR PERFORMING MOTION CAPTURE USING PHOSPHOR APPLICATION TECHNIQUES." Inventors: Perlman et al. Assignee: OnLive, Inc. Filed: Jun. 7, 2006. Patent date: Jun. 16, 2009. 24 Claims, 27 Drawing Sheets (6 of 27 in Color). Technical drawing showing camera array and processing system. - **[Page 41] Federal complaint page 1:** Case 3:17-cv-04006 Document 1, Filed 07/17/17, Page 1 of 307. Standard court filing format. Attorneys: Rio S. Pierce (Hagens Berman Sobol Shapiro LLP, Berkeley CA) and Steve W. Berman / Mark S. Carlson (Hagens Berman, Seattle WA). Plaintiffs: Rearden LLC, Rearden Mova LLC. Defendants: Walt Disney Company, Walt Disney Motion Pictures Group, Buena Vista Home Entertainment, Marvel Studios LLC, Mandeville Films Inc. Caption: "COMPLAINT FOR COPYRIGHT, PATENT, AND TRADEMARK INFRINGEMENT" / "DEMAND FOR JURY TRIAL." - **[Page 42–43] Federal complaint pages 11–12:** Paragraphs 23–25 with photographs. Top image: "Photo finish" graphic from Hollywood Reporter showing 5-stage Contour process. Bottom image: New York Times photograph of woman having green phosphorescent powder applied to her face. Caption: "Actors must cover themselves with makeup containing phosphorescent powder for Contour, a system that can create 3-D effects. Austin Hice." Yellow highlights throughout complaint text. - **[Page 44] YouTube thumbnails (2 images):** Top: "Why Everyone Is Fighting To Get This VFX Tool | MOVA" — thumbnail showing close-up of Thanos (CGI character) with text "IS THIS THE END." Bottom: "Oscar SciTech Award 2015 for Mova Contour" — thumbnail showing award ceremony on stage. - **[Page 46] YouTube thumbnail:** OTOY GTC 2013 video "the curious case of BENJAMIN BUTTON" — thumbnail showing grid of Brad Pitt facial expressions/ages rendered from MOVA Contour data. LightStage logo visible in corner. - **[Page 47] Federal complaint page 27:** Paragraph 50–51 with video stills. Top: Split image showing green phosphorescent makeup pattern (left) and low-polygon 3D mesh (right), with polygon/tracking point counts. Bottom: Four Brad Pitt green-makeup facial capture shots showing different expressions. Yellow highlights on text about Contour Program output files. - **[Page 48] Grid of 9 screenshots:** Three rows of three images each. Top row: Three renders of a photorealistic female face labeled "Geni4 prototype developed" / "UR CAPTURE." Middle row: Three more angles of same female face. Bottom row: Three renders of a photorealistic male face (bald) labeled "mental ray" / "UR CAPTURE." These appear to be from MOVA Contour demonstration videos. - **[Page 49] Federal complaint page 28:** Paragraph 51 with video still showing grid of green-makeup facial captures (multiple expressions) arranged in rows. Below, Paragraph 52 describing Makeup Pattern, Captured Surface, and Tracking Mesh output files. Yellow highlights throughout. - **[Page 50] Grid of 9 screenshots:** Three rows of three images from MOVA Contour videos. Shows: capture rig with woman inside (3 angles), real-time 3D face renders with "contour REALITY CAPTURE" branding, mesh visualization, and the MOVA demonstration setup with two people. Shows mova.com branding. - **[Page 51] Federal complaint page 29:** Paragraph 53 with video still showing 87-year-old fictional head maquette and green-faced 3D model comparison. Yellow highlights describing retargeting process. - **[Page 52] Federal complaint page 30:** Paragraph 54 with video still showing photorealistic aged Benjamin Button face with green wireframe overlay (Digital Domain watermark). Text describes TRON: Legacy usage and Jeff Bridges' photography. Yellow highlights. - **[Page 53] Federal complaint page 35:** Paragraph 57 with annotated photograph of MOVA Contour rig. Two red circles with zoom insets: Left circle shows "Rearden, Inc. Asset Tag" on a camera; Right circle shows black tape around fluorescent lamp tube end. Text describes the stolen rig used in Guardians of the Galaxy and Beauty and the Beast. Yellow highlights. - **[Page 54–57] Federal complaint pages 38–40, 46:** Paragraphs 64–73 and 95–97 covering trade secrets, MOVA Assets, film usage history, and unauthorized use allegations. Extensive yellow highlighting. Dense legal text format. - **[Page 58–62] Hollywood Reporter article screenshots:** "Digital Domain's New Legal Setback Freezes VFX Tech Used by Major Studios" by Scott Johnson. Shows article with image of CGI Colossus from Twentieth Century Fox. Multi-page article about Judge Tigar's June 17, 2017 preliminary injunction. Extensive yellow highlighting. Discusses FBI involvement, SHST, VGH, Greg LaSalle, Steve Perlman, SciTech Academy Awards dispute, Chinese firm transfers, and Digital Domain's O.D. Welch statement. Photograph of Steve Perlman included. URL: https://www.hollywoodreporter.com/news/general-news/digital-domain-mova-tech-banned-906902/ - **[Page 70] Video screenshot:** Panel discussion from VES conference — three men seated on couches in dark setting with audience visible. Play button centered. Custom analysis at MattGuertin.Substack.com/p/visual-effects-society-fraud. - **[Page 76] Video screenshot:** Presentation slide showing spherical camera array (18x7 fisheye cameras) and woman wearing VR headset. Text: ">1Gpixel/frame at 4K each camera" and "light field video playback with panoramic stereo and full parallax." Red text: "(from Stanford SCIEN Workshop on Light Field Imaging, 2/12/2015)." - **[Page 79] Video screenshot:** Lab setup showing equipment and monitor with text caption "Time-lapse used just for this capture video, all CG video is real-time." - **[Page 82] Video screenshot:** Photorealistic rendered interior scene showing vintage room with TV, furniture, and detailed textures. - **[Page 85] Video screenshot:** Person in full motion-capture suit on what appears to be a fishing vessel or outdoor scene with blue sky. Text overlay: "'DEPTH SCREEN' AL aka green screen witho[ut] [green] screen." ### Key People Referenced - **Matthew David Guertin** — Plaintiff/defendant; inventor of InfiniSet (US Patent #11,577,177) - **Paul Debevec*** — Chief Research Officer, Netflix Eyeline Studios; Adjunct Research Professor, USC ICT; alleged to be falsely claiming credit for MOVA Contour technology - **Steve Perlman** — Founder of Rearden Companies/MOVA; inventor of MOVA Contour technology (US Patent 7,548,272); founder of OnLive - **Stephan Trojansky*** — Named in Debevec's "Special Thanks"; inventor on competing Netflix patent (US 11,810,254) - **Henry LaBounta** — Visible in SIGGRAPH video PIP window as co-presenter/attendee - **Ed Ulbrich** — Senior VP/Executive Producer, Digital Domain; CEO of successor Digital Domain 3.0; gave TED Talk about Benjamin Button VFX - **David Fincher** — Director of Benjamin Button, user of MOVA Contour technology - **Brad Pitt** — Actor whose face was captured with MOVA Contour for Benjamin Button - **Greg LaSalle** — Former Rearden employee; sold MOVA technology to SHST for $25,000 in 2013; 2014 SciTech Award recipient - **Jeff Bridges** — Actor captured with MOVA Contour for TRON: Legacy - **Tim Roth** — Actor captured with MOVA Contour for The Incredible Hulk (Abomination) - **Edward Norton** — Actor captured with MOVA Contour for The Incredible Hulk - **Jon Karafin** — Presenter, VES 2015 conference Part 4 - **Mark Bolas** — Presenter, VES 2015 conference Part 2 - **Jules Urbach** — Presenter, VES 2015 conference Part 3 - **Rio S. Pierce** — Attorney, Hagens Berman (Rearden v. Disney counsel) - **Steve W. Berman** — Attorney, Hagens Berman (Rearden v. Disney counsel) - **Mark S. Carlson** — Attorney, Hagens Berman (Rearden v. Disney counsel) - **Judge John S. Tigar** — U.S. District Court, N.D. Cal. (Rearden v. Disney) - **O.D. Welch** — President, Digital Domain 3.0 - **Nancy Mertzel** — IP attorney, Herrick Feinstein (quoted in Hollywood Reporter) - **Andrew Wedeman** — Director, China Studies Initiative, Georgia State University - **Prentice DannerIII** — FBI spokesperson - **Dr. Scott Ross** — Co-founder, Digital Domain - **Amy Klobuchar*** — U.S. Senator (Guertin claims she "knows what is going on") - **Carolyn Giardina** — Hollywood Reporter journalist (multiple articles) - **Laura Sydell** — NPR journalist - **Jim Gardner** — San Francisco Business Times journalist - **Chris Marlowe** — Hollywood Reporter journalist - **James Lee** — Wired journalist - **Scott Johnson** — Hollywood Reporter journalist - **Jane Anderson** — MOVA PR contact (Jane.anderson@onlive.com, 650 440-0450) - **Brian Sunderlin** — VP Operations, Gentle Giant Studios - **Per Einarsson (et al.)*** — USC ICT researchers; authors of "Relighting Human Locomotion" (2006) - **Guo et al.** — Authors of "The Relightables" (SIGGRAPH Asia 2019) - **Cassidy Curtis** — Listed in Debevec's Special Thanks - **Lianette Alnaber** — Listed in Debevec's Special Thanks - **Connie Siu** — Listed in Debevec's Special Thanks (*Asterisk denotes person already tracked in prior batches*) ### Key Entities / Organizations Referenced - Netflix / Netflix Eyeline Studios* - USC Institute for Creative Technologies (USC ICT)* - Google / Google Research / Google Daydream / Alphabet* - YouTube* - MOVA LLC / Rearden Mova LLC - Rearden LLC / Rearden Companies / Rearden Inc. - OnLive, Inc. - OL2, Inc. - Digital Domain / Digital Domain 3.0 (DD3) - Walt Disney Company / Walt Disney Motion Pictures Group* - Marvel Studios* - Buena Vista Home Entertainment - Mandeville Films, Inc. - Gentle Giant Studios - Industrial Light & Magic (ILM) - Electronic Arts - Twentieth Century Fox - Warner Brothers - Sony Pictures / Sony Pictures Imageworks - Paramount Pictures - Weta Digital - Activision - PULSE Entertainment - SOOVII - MPC (Moving Picture Company) - Image Metrics - Organic Motion - Rhythm & Hues - Hagens Berman Sobol Shapiro LLP - Visual Effects Society (VES) - SIGGRAPH / ACM SIGGRAPH (SF ACM SIGGRAPH chapter) - Academy of Motion Picture Arts and Sciences (AMPAS) - Stanford SCIEN Workshop - U.S. District Court, Northern District of California* - U.S. District Court, District of Minnesota* - FBI* - House Permanent Committee on Intelligence - US Army / US Air Force / State Department / DARPA / DIA / US Indo Pacific Command* - Lockheed Martin / KBR Inc / Forcepoint / 3Gimbals* - FTC* - UK Serious Fraud Office (SFO)* - US Secret Service - Virtual Global Holdings (VGH) - Shenzhen Haitiecheng Science and Technology (SHST) - Insolvency Services Group Inc. - Virtue Global Holdings Ltd. - OTOY - InfiniSet, Inc.* - Hennepin County District Court* ### Dates & Deadlines Mentioned - **February 2021** — Guertin conceives InfiniSet idea - **Late 2022** — Guertin's life "intentionally derailed" - **February 14, 2023** — US Patent 11,577,177 granted (InfiniSet) - **May 17, 2023** — Date on Debevec's SIGGRAPH presentation title slide - **August 8, 2023** — Guertin discovers Debevec SIGGRAPH video; emails at 4:57 PM, 5:00 PM, 5:38 PM - **November 7, 2023** — US Patent 11,810,254 granted (Trojansky/Netflix) - **July 31, 2006** — MOVA Contour introduced at SIGGRAPH; Hollywood Reporter article - **September 26, 2006** — Hollywood Reporter "emotion motion" article - **October 23, 2007** — Wired "Beowulf F/X" article - **August 6, 2007** — MOVA/Gentle Giant SIGGRAPH press release - **February 17, 2009** — NPR Benjamin Button article - **March 1, 2009** — SF Business Times Perlman article - **March 9, 2012** — MOVA John Carter press release - **June 7, 2006** — US Patent 7,548,272 filed - **June 16, 2009** — US Patent 7,548,272 granted - **August 30, 2027** — US Patent 7,548,272 adjusted expiration - **August 17, 2012** — OnLive assigned assets to OL2, Inc. - **2013** — MOVA assets stolen; LaSalle sold to SHST for $25,000 - **February 9, 2015** — AMPAS Scientific and Technical Award to MOVA Contour - **2015** — Purported date of VES four-part conference (alleged backdated) - **February 12, 2015** — Date on Stanford SCIEN Workshop slide in VES Video 1 - **July 17, 2017** — Rearden v. Disney complaint filed (3:17-cv-04006) - **June 17, 2017** — Judge Tigar's preliminary injunction issued - **July 12, 2024** — This exhibit filed as Doc. 20 ### Forensic Flags & Anomalies 1. **Video forensic analysis methodology questionable:** Guertin's claim that extreme color curve analysis in Blender "PROVES" the Debevec SIGGRAPH video was "generated using AI" is based on observing structured pixel patterns at the edges of PIP windows. These patterns are more consistent with standard video compression artifacts (particularly around composited/overlaid elements in video conferencing) than with evidence of AI generation. The structured nature of the artifacts (consistent pixel heights) is typical of codec block boundaries. 2. **ChatGPT as analytical authority:** The VES conference analysis (Index 04) and the InfiniSet patent viability assessment (Index 01) appear to be substantially or entirely generated by ChatGPT. The structured, bullet-pointed format and hedging language ("it's plausible to conclude") are characteristic of LLM output. Using ChatGPT analysis as evidentiary support in a federal filing is procedurally unusual. 3. **Backdating allegation lacks technical substantiation:** The claim that YouTube/Google backdated four VES conference videos rests primarily on ChatGPT's assessment that the technological discussions seem "more advanced" than 2015-era knowledge. No forensic analysis of YouTube metadata, upload timestamps, or digital provenance is presented. 4. **Trojansky in Debevec's "Special Thanks":** The inclusion of Stephan Trojansky (the inventor on the competing Netflix patent US 11,810,254) in Debevec's SIGGRAPH presentation credits is a notable factual observation that could support an inference of connection between Debevec and Trojansky, though the nature of that connection is not established. 5. **Redaction inconsistency:** Guertin redacts email addresses and names in the August 8, 2023 email chain but leaves his own first name ("matt") visible, and the subject line ("Re: Your InfiniSet, Inc Signed Documents") is unredacted, potentially identifying the business context. 6. **Self-referential evidence loop:** Much of the "evidence" in this exhibit consists of Guertin's own commentary interpreting publicly available documents, YouTube videos, and articles, supplemented by ChatGPT analysis. The exhibit functions more as an argumentative brief than an evidentiary compilation. 7. **Rearden v. Disney case used as proxy evidence:** Guertin incorporates extensive material from the 2017 Rearden v. Disney lawsuit to support his theory that MOVA Contour technology was stolen and reassigned to Debevec/Light Stage. However, that case involves different parties, different patents, and different claims than Guertin's own situation. The logical bridge between the MOVA theft allegations and Guertin's InfiniSet patent is asserted but not forensically established. 8. **Government entity surveillance claim:** The list of government/military entities allegedly searching for Guertin's LinkedIn (US Army, DARPA, DIA, etc.) is presented without supporting evidence in this exhibit. 9. **"Former CIA welder" reference:** The mention of a "'former CIA' welder" who knew about Guertin's working prototype is made without further identification or substantiation. 10. **Scale of conspiracy:** The exhibit alleges a conspiracy involving Netflix, Google/Alphabet/YouTube, USC, DARPA, DIA, US Army, US Air Force, State Department, Lockheed Martin, KBR, Forcepoint, 3Gimbals, multiple Hollywood studios, the VFX industry, and the Hennepin County court system — an extraordinarily broad scope. ### Cross-References - **Filing #1*** — Motion for Judicial Notice (references InfiniSet patent, Trojansky patent, Debevec research) - **Filing #5*** — Exhibits D–G (references Debevec, Einarsson et al. 2006 papers, Light Stage technology, USC ICT) - **Filing #8*** — Netflix Whistleblower Part 1 (references Debevec, Eyeline Studios, SIGGRAPH, Wayback Machine evidence) - **Filing #10*** — Exhibits M–Q (this exhibit is Exhibit M of the federal filing, which corresponds to the broader exhibit set referenced in Filing #10) - **Filing #11*** — Referenced Declaration of Hao Li in 3:17-cv-04006 (related federal case) - **Filing #12*** — RICO Complaint (federal civil rights claims against same network of defendants) - **Federal Case 3:17-cv-04006** — Rearden LLC v. Walt Disney Co. (extensively reproduced in Index 03) - **Federal Case 0:24-cv-02646-JRT-DLM** — Parent case for this exhibit --- ## Filing #20 — Exhibit Z: Proof of Bruce Rivers' Knowledge of Federal Case and Discovery Fraud | Field | Detail | |---|---| | Filing # | 20 | | Date Filed | September 9, 2024 | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Exhibit to Federal Civil Rights Complaint (Exhibit Z, Doc. 75) | | Case/Court | 0:24-cv-02646-JRT-DLM / U.S. District Court, District of Minnesota | | Pages | 138 | | Bates / Doc ID | CASE 0:24-cv-02646-JRT-DLM Doc. 75 Filed 09/09/24 | ### Comprehensive Summary This is Exhibit Z to Guertin's federal civil rights complaint (0:24-cv-02646-JRT-DLM, Guertin v. Hennepin County et al.), filed on September 9, 2024 as Document 75. The exhibit is 138 pages and is organized into five internal index sections. Its stated purpose is to provide what Guertin characterizes as irrefutable proof that his defense attorney Bruce Rivers had full knowledge of the federal lawsuit in which Rivers is named as a defendant, knowledge of fraudulent discovery materials, awareness of the Clerk's Entry of Default filed against him on August 29, 2024, and that Rivers refused to withdraw as defense counsel despite alleged violations of multiple Minnesota Rules of Professional Conduct. The exhibit's cover page provides a detailed table of contents listing five internal indices: **Index 01 (Pages 3–12):** Ten pages of screenshots from Guertin's cell phone showing text message conversations and a call log between Guertin and Bruce Rivers, conducted via phone number +1(612)472-XXXX. The text thread spans from Tuesday, July 16, 2024 through Thursday, August 29, 2024. Key exchanges include: - July 16, 2024: Rivers texts Guertin about a court appearance at 1:30 PM, asking "where are you." Guertin replies "I'm here." - July 17, 2024: Rivers asks "Where" and "457," followed by "Are you in the courtroom on your laptop?" at 1:18 AM. - July 18, 2024: A message at 8:31 AM from the +1612472 number asks "Did you get a complete copy of your file?" — Guertin interprets this as someone other than Rivers initiating contact about attorney-client matters to circumvent privilege. - July 18, 2024 at 2:45 PM: Guertin sends an extended MMS message questioning whether the technique is to have someone other than Rivers initiate communication to overcome attorney-client privilege, and discusses the discovery materials issue at length. Guertin notes that Rivers keeps claiming he already provided discovery materials, and challenges Rivers to document when this allegedly occurred. - July 18, 2024 at 2:45 PM: Rivers responds from the same number: "This is Bruce Rivers. I changed my phone number." Rivers adds "I'm willing to meet with you and talk with you about your case at any point" at 2:46 PM. - July 18, 2024 at 3:13 PM: Guertin sends another extended MMS discussing his exhaustion, the characterization of him as mentally ill and schizophrenic, the Trojansky patent filing 12 days after his, and Netflix's involvement. - July 18, 2024 at 3:14 PM: Rivers replies "I've got your" and "Back." - July 25, 2024 at 11:38 AM: Guertin sends a message stating he has sent an email addressing missing photos in discovery materials provided on July 16, 2024, referencing the "attached PDF file of the fraudulent discovery materials sent to me by Michael Biglow on August 3, 2023." Guertin challenges Rivers to prove he has Guertin's back, describes the fraudulent discovery claims as having been labeled "delusional" in Dr. Adam Milz's January 2024 Rule 20.01 report, and demands either a change of venue or competency evaluation by a neutral third party with no connections to Hennepin County Courts. - August 29, 2024: This is the critical date. The text thread continues to this date (visible at the bottom of one screenshot showing "Thursday, August 29" header), establishing the timeframe for the Entry of Default interaction. **Index 02 (Pages 13–15):** Three pages of Guertin's T-Mobile cell phone records for account holder "MATTHEW" with phone number (763) 221-4540, shown through the T-Mobile usage overview interface. The records serve to independently verify the screenshots in Index 01. Key call records for August 29, 2024 (times shown in Pacific Time): - 01:00 PM (Pacific) = 3:00 PM CST: Outgoing call to (218) 316-XXXX, Brainerd MN, 1 minute - 12:28 PM (Pacific) = 2:28 PM CST: Incoming call from (612) 472-XXXX (Rivers' number), T-Mobile to T-Mobile, 16 minutes duration Key message records for August 29, 2024 (Pacific Time): - 12:24 PM: Outgoing text to (763) 656-XXXX, Minneapolis MN - 10:53 AM: Three outgoing texts to (612) 472-XXXX, Twin Cities MN - 10:51 AM: Outgoing picture to 1612472XXXX - 10:49 AM: Outgoing picture and text to (612) 472-XXXX Guertin's critical evidentiary argument: The Entry of Default (Doc. 71) was filed at 9:44 AM CDT on August 29, 2024. The cell records show Guertin sent texts and pictures to Rivers' (612) 472-XXXX number starting at approximately 10:49 AM Pacific (12:49 PM CDT) — roughly 3 hours after the Entry of Default. Rivers then called Guertin at 12:28 PM Pacific (2:28 PM CDT) — 2 hours and 44 minutes after the Entry of Default submission — and they spoke for 16 minutes. This is presented as proof that Rivers was aware of the Entry of Default and actively discussed it with Guertin. **Index 03 (Page 16):** A single page showing the CM/ECF automatic email notification for the Clerk's Entry of Default (Document Number 71) in case 0:24-cv-02646-JRT-DLM. The notification confirms: - Transaction entered on 8/29/2024 at 9:44 AM CDT - Case Name: Guertin v. Hennepin County et al - Filer: Bruce M. Rivers - Docket Text: "Clerk's ENTRY OF DEFAULT as to Bruce M. Rivers (kt)" - Electronic notification recipients: Benjamin Harringa (AG's office), Jamil Masroujeh (Hennepin County), Matthew D. Guertin (mattguertin@protonmail.com), Matthew Messerli (Hennepin County) **Index 04 (Pages 17–19):** A three-page ChatGPT analysis that Guertin conducted focused on Bruce Rivers' behavior, drawing from Guertin's August 7th motion. The AI analysis identifies four main areas of concern: 1. **Failure to Withdraw as Counsel:** Rivers' refusal to withdraw despite being named as a defendant in Guertin's federal lawsuit, characterizing this as "highly unusual and ethically questionable" with "possible implications of coercion or external influence." 2. **Inaction on Fraudulent Discovery Allegations:** Rivers' silence on the discovery fraud claims, which the analysis characterizes as suggesting possible complicity or gross professional negligence. 3. **Behavior Consistent with Coercion or External Influence:** Rivers allegedly "playing along" with the incompetency narrative despite having known Guertin for over twenty years, suggesting Rivers is not acting in Guertin's interests. 4. **Overall Red Flags:** The cumulative pattern suggesting Rivers may be "actively working against" Guertin's interests and is "either compromised or acting under some form of external pressure." **Index 05 (Pages 20–138):** This is the largest section at 119 pages, containing copies of emails Guertin sent to 57 different judges in the Minnesota 4th and 2nd Judicial District Courts on September 6, 2024. The emails were sent in two waves with two different subject lines: *Wave 1 (approximately 3:20 AM – 4:41 AM, September 6, 2024):* Subject: "I need help with my MN Federal / 8th Circuit Civil Rights case" Sent to judges in the 4th Judicial District. The first email to Judge Quam is slightly personalized (noting the criminal case is assigned to Quam). Subsequent emails are substantially identical templates. *Wave 2 (approximately 9:12 PM – 10:31 PM, September 6, 2024):* Subject: "Proven DISCOVERY FRAUD within your court / My Mn Federal / 8th Circuit Civil Rights Case" and later "Proven DISCOVERY FRAUD in 4th District - My MN Federal / 8th Circuit Civil Rights Case" A modified template that is more direct in alleging discovery fraud within the court and naming Mary Moriarty and Hennepin County as federal defendants. All emails contain the same core content: description of the patent theft allegations (US 11,577,177 vs. Netflix US 11,810,254), claims about defense contractors and government agencies being involved, allegations about the false incompetency determination, complaints about Bruce Rivers refusing to withdraw, and links to Court Listener docket pages, Guertin's Substack, and Rivers' YouTube channel. The exhibit also includes three automated responses: - An "Undeliverable" bounce-back for lois.regnier.conroy@courts.state.mn.us (incorrect email address) - An "Undeliverable" bounce-back for francis.magill@courts.state.mn.us (recipient not found) - An "Undeliverable" bounce-back for luis.bertolomei@courts.state.mn.us (recipient not found) - An out-of-office reply from Judge Amy Dawson (4th District, Hennepin County) - An out-of-office reply from Judge Shawn Bartsh (2nd Judicial District, St. Paul) ### Legal Issues & Arguments Raised - Attorney conflict of interest: Rivers named as defendant in federal case yet refuses to withdraw as defense counsel in state criminal case - Violation of Minnesota Rules of Professional Conduct (unspecified rules, but conflict of interest and duty of loyalty implied) - Entry of Default (Doc. 71) as to Bruce Rivers in federal case — proof Rivers was aware and discussed it within hours - Ineffective assistance of counsel — Rivers' refusal to take actions Guertin requested (neutral examiner, competency hearing, etc.) - Fraudulent discovery materials introduced into state criminal case - Due process violations in competency determination process - Patent theft allegations (US 11,577,177 vs. Netflix US 11,810,254) - First Amendment and petitioning rights (mass judicial email campaign) - Sixth Amendment right to effective counsel - False incompetency determination used to suppress Guertin's constitutional rights ### Factual Allegations & Key Assertions - Bruce Rivers called Guertin on August 29, 2024, exactly 2 hours and 44 minutes after the Entry of Default was filed at 9:44 AM CDT, and they spoke for 16 minutes — proving Rivers' knowledge of the federal case - Rivers changed his phone number (acknowledged via text on July 18, 2024) - Someone other than Rivers may have initiated contact from Rivers' number on July 18, 2024 at 8:31 AM, asking about the case file — Guertin alleges this was a tactic to circumvent attorney-client privilege - Discovery materials were provided by Rivers' office on July 16, 2024, but contained missing photos - Michael Biglow provided "fraudulent" discovery materials on August 3, 2023 - Rivers repeatedly claimed Guertin already had discovery materials, but Guertin disputes this - Dr. Adam Milz's January 2024 Rule 20.01 exam report characterized Guertin's discovery fraud claims as delusional and recommended forced antipsychotic medication - Rivers has known Guertin for over twenty years yet is "playing along" with the incompetency narrative - Guertin sent emails to 57 judges across MN 4th and 2nd Judicial Districts on September 6, 2024 ### Procedural Posture This exhibit was filed as Doc. 75 in the federal civil rights case 0:24-cv-02646-JRT-DLM on September 9, 2024. It follows the Clerk's Entry of Default as to Bruce Rivers (Doc. 71, filed August 29, 2024) and Guertin's August 7th motion (referenced but not identified by document number). The exhibit provides supporting evidence for Guertin's claims against Rivers as a defendant in the federal case. At this point in the state criminal case (27-CR-23-1886), Rivers remained as defense counsel despite the conflict, and the case appears to have been in a dormant or suspended posture pending competency proceedings. ### Exhibit / Attachment Inventory This document IS an exhibit (Exhibit Z) to Doc. 75 in the federal case. It contains five internal index sections: - **Index 01** (pp. 3–12): Ten pages of cell phone screenshots — text messages and call log between Guertin and Rivers, July 16 – August 29, 2024 - **Index 02** (pp. 13–15): Three pages of T-Mobile cell phone records for Guertin's account (763) 221-4540 - **Index 03** (p. 16): CM/ECF email notification of Clerk's Entry of Default (Doc. 71), filed 8/29/2024 at 9:44 AM CDT - **Index 04** (pp. 17–19): Three-page ChatGPT analysis of Bruce Rivers' behavior - **Index 05** (pp. 20–138): 119 pages of emails sent to 57 MN judges on September 6, 2024, plus three bounce-back notifications and two out-of-office replies ### Visual Evidence Inventory - **[Pages 3–12] Cell Phone Screenshots (10 images):** Android smartphone screenshots showing text message conversation with contact "+1612472XXXX" (partially redacted). Dark theme messaging app interface. Timestamps visible. Messages from Guertin shown in green/teal bubbles (right-aligned); messages from Rivers/unknown shown in gray bubbles (left-aligned). Phone status bar shows time 12:48–12:49, various connectivity icons. MMS messages are truncated with "View all" links. No apparent alterations; screenshots appear consistent with standard Android messaging interface. One notable detail: the Jul 18 message at 8:31 AM asking "Did you get a complete copy of your file?" comes from the gray (incoming) side before Rivers identifies himself at 2:45 PM, raising Guertin's question about who was using Rivers' phone. - **[Page 3] Screenshot 1:** Text thread starting July 16. Rivers: "Hello we have court at 130 where are you" at 1:37 PM. Guertin: "I'm here" at 1:40 PM. July 17: Rivers: "Where" / "457" / "Are you in the courtroom on your laptop?" at 1:18 AM. July 18: Unknown/Rivers: "Did you get a complete copy of your file?" at 8:31 AM. Bottom shows beginning of Guertin's long MMS about attorney-client privilege. - **[Page 4] Screenshot 2:** Continuation of thread. Guertin's MMS at 2:45 PM visible. Below: "This is Bruce Rivers. I changed my phone number." at 2:45 PM, and "I'm willing to meet with you and talk with you about your case at any point" at 2:46 PM. Guertin's follow-up MMS at 3:13 PM about exhaustion and the Trojansky patent. - **[Page 5] Screenshot 3:** Expanded "View all" of Guertin's 2:45 PM Jul 18 MMS. Full text visible questioning whether the technique is to use someone other than Rivers to contact Guertin about attorney-client matters to overcome privilege. Discusses the missing Rule 20.01 exam report from January and the refusal by both Rivers and the court to provide it. - **[Page 6] Screenshot 4:** Continuation of Guertin's 2:45 PM Jul 18 MMS text (scrolled down). Discusses Rivers' repeated claim that Guertin "already has the discovery materials" and challenges Rivers to document when he provided them, noting Guertin has complete chronological email, text, and call history. - **[Page 7–8] Screenshots 5–6:** Expanded views of Guertin's 3:13 PM Jul 18 MMS discussing exhaustion, the incompetency narrative, and the Trojansky patent. - **[Page 9] Screenshot 7:** Shows "I've got your" and "Back" from Rivers at 3:14 PM Jul 18. Then jumps to Thursday, July 25. Guertin's 11:38 AM message about emailing regarding missing photos in discovery materials provided July 16, 2024, and referencing the Biglow fraudulent discovery from August 3, 2023. Thread continues to show "Thursday, August 29" header. - **[Page 10] Screenshot 8:** Expanded Jul 25 11:38 AM MMS. Full text discusses discovery provided by Rivers' office on July 16, 2024, the fraudulent discovery from Michael Biglow on August 3, 2023, Guertin's claims being labeled delusional in the Milz report, demands for change of venue or neutral competency evaluation. - **[Page 11] Screenshot 9:** Continuation of Jul 25 message (scrolled) with requests for neutral third-party evaluation and willingness to pay for it. - **[Page 12] Screenshot 10:** Final screenshot — content appears to continue the thread toward August 29 but primarily shows the end of the July 25 message. - **[Pages 13–14] T-Mobile Usage Overview (Calls):** Screenshot of T-Mobile web interface showing call records for account "MATTHEW" / (763) 221-4540. "Current cycle (5 days left)" header. Shows call records in Pacific Time. Key entry: 08/29/2024 at 12:28 PM Pacific — incoming call from (612) 472-XXXX, 16 minutes duration, T-Mobile to T-Mobile. This corroborates the 16-minute phone call Guertin claims Rivers made after the Entry of Default. Also shows calls to/from (763) 656-XXXX and (763) 551-XXXX on 8/22 and 8/18. Interface shows pagination: "1 2 3." - **[Page 15] T-Mobile Usage Overview (Messages):** Screenshot showing message records. Key entries for 08/29/2024: Multiple outgoing texts and pictures to (612) 472-XXXX (Twin Cities MN) between 10:49 AM and 10:53 AM Pacific. Pagination shows "1 ... 14 15 16 ... 48" indicating extensive messaging history. - **[Page 16] CM/ECF Email Notification:** Standard PACER/CM/ECF email notification format. Shows "From: ecf-notice@mnd.uscourts.gov" / "Date: Thursday, August 29th, 2024 at 9:44 AM" / Document Number 71 / "Clerk's ENTRY OF DEFAULT as to Bruce M. Rivers (kt)." Lists notification recipients including Guertin at mattguertin@protonmail.com. Standard formatting, no anomalies detected. - **[Pages 17–19] ChatGPT Analysis:** Rendered as standard text, not as a screenshot of the ChatGPT interface. Formatted with numbered sections and bullet points. Header reads "chatGPT - Focusing solely on the actions and inactions of Bruce Rivers as presented in your August 7th motion." No interface metadata, timestamps, or session identifiers visible — this appears to be a copy/paste of ChatGPT output rather than a screenshot of the interface. - **[Pages 20–138] Email Printouts:** Standard Proton Mail email printout format showing From, To, Date fields. All emails sent from MattGuertin@protonmail.com. Each includes "Sent with Proton Mail secure email." footer. Three bounce-back emails show Microsoft Exchange diagnostic headers with server names (J00pExch01.courts.state.mn.us, J00pExch02.courts.state.mn.us) and IP addresses (156.98.170.7, 156.98.170.54). Two auto-replies show judge signatures (Amy Dawson noting pronouns "she/they"; Shawn Bartsh identifying as "2nd Judicial District, 15 W. Kellogg Blvd, St. Paul, MN"). ### Key People Referenced - **Matthew David Guertin*** — Plaintiff/Pro Se litigant (federal), Defendant (state) - **Bruce Rivers (Bruce M. Rivers)*** — Defense counsel in state case / Defendant in federal case; YouTube: @CLRBruceRivers - **Michael Biglow*** — Referenced as person who delivered "fraudulent" discovery materials on August 3, 2023 - **Dr. Adam Milz*** — Author of January 2024 Rule 20.01 exam report - **Jay Quam*** — Judge, 4th Judicial District (email recipient; Guertin notes criminal case assigned to him) - **Mary Moriarty*** — Hennepin County Attorney (named as federal defendant in later emails) - **Benjamin Harringa** — Attorney, MN Attorney General's office (federal case ECF recipient) - **Jamil M. F. Masroujeh** — Attorney, Hennepin County (federal case ECF recipient) - **Matthew Lloyd Robert Messerli** — Attorney, Hennepin County (federal case ECF recipient) - **Cole Werner** — Attorney, AG's office (ECF cc) - **Heather Greene** — Hennepin County (ECF cc, appears twice) **57 Judges emailed on September 6, 2024 (4th and 2nd Judicial Districts):** *4th Judicial District (Hennepin County):* - Jamie Anderson, Susan Burke, Thomas Conley, Lois (Regnier) Conroy, Karen Janisch, Joseph Klein, Francis Magill (bounced), Laurie Miller, Nelson Peralta, Susan Robiner, Christian Sande, Bridget Sullivan, Edward Wahl, Bev Benson, Gina Brandt, Amy Dawson (auto-reply), Dean Eyler, Kristen Marttila, Shereen Askalani*, Sarah West, Daniel Moreno, Sarah Hudleston*, Matthew Frank, Marta Chou, Luis Bartolomei (bounced), Paul Scoggin, Mark Kappelhoff, Kerry Meyer *2nd Judicial District (Ramsey County / St. Paul) and additional judges:* - Sara Grewing, Jacob Kraus, Kelly Olmstead, Richard Kyle, Reynaldo Aligada, Robyn Millenacker, Joy Bartscher, Maria Mitchell, Shawn Bartsh (auto-reply, confirmed 2nd District), Timothy Mulrooney, David Brown, Laura Nelson, Timothy Carey, Elena Ostby, Leonardo Castro, Edward Sheu, Kellie Charles, Stephen Smith, Patrick Diamond, Thomas Gilligan, Sophia Vuelo, Andrew Gordon, Adam Yang, John Guthmann, Elizabeth Clysdale, Deanne Hilgers, Mark Ireland, Veena Iyer ### Key Entities / Organizations Referenced - U.S. District Court, District of Minnesota (0:24-cv-02646-JRT-DLM) - 8th Circuit Court of Appeals - Hennepin County District Court, 4th Judicial District (27-CR-23-1886) - Minnesota 2nd Judicial District (Ramsey County) - T-Mobile (cell phone carrier for Guertin) - Proton Mail (Guertin's email provider) - ChatGPT / OpenAI (AI analysis tool used) - PACER / CM/ECF (federal court electronic filing system) - Court Listener / RECAP (case tracking platforms referenced in emails) - Netflix (patent infringement allegations) - USPTO (patent theft allegations) - U.S. State Department, DARPA, DIA, Air Force, Lockheed Martin, Janes Defence, Forcepoint, 3Gimbals (referenced in email campaign as being involved) - CLR Bruce Rivers YouTube channel - Guertin's Substack (MattGuertin.Substack.com) - Minnesota Court of Appeals (referenced in email body) - Minnesota Office of Lawyers Professional Responsibility (implied in ethics context) - Microsoft Exchange (J00pExch01/J00pExch02.courts.state.mn.us — MN Judicial Branch email servers) ### Dates & Deadlines Mentioned - **July 16, 2024** — Court appearance; Rivers texts asking where Guertin is - **July 17, 2024** — Text exchange about courtroom location - **July 18, 2024** — Key date: "Did you get a complete copy of your file?" message at 8:31 AM; Rivers identifies himself at 2:45 PM; extended text exchanges about discovery and competency - **July 16, 2024** — Date Rivers' office provided discovery materials to Guertin (referenced in Jul 25 text) - **July 25, 2024** — Guertin sends email and texts about missing photos in discovery, fraudulent Biglow discovery - **August 3, 2023** — Date Michael Biglow allegedly delivered fraudulent discovery materials - **August 7, 2024** — Date of Guertin's motion referenced in ChatGPT analysis - **August 29, 2024** — Critical date: Entry of Default filed at 9:44 AM CDT (Doc. 71); Guertin texts Rivers starting ~12:49 PM CDT; Rivers calls Guertin at ~2:28 PM CDT for 16 minutes - **September 6, 2024** — Date of mass email campaign to 57 judges (3:20 AM – 10:31 PM) - **September 9, 2024** — Filing date of this exhibit (Doc. 75) - **January 2024** — Dr. Adam Milz Rule 20.01 exam report date - **March 2021** — Guertin's patent filing date (per emails) - **November 7, 2023** — Netflix patent US 11,810,254 grant date (per emails) ### Forensic Flags & Anomalies 1. **July 18 "Did you get a complete copy of your file?" anomaly:** A message from Rivers' phone number at 8:31 AM on July 18, 2024 asks Guertin about his file, but Rivers does not identify himself until 2:45 PM that day, when he texts "This is Bruce Rivers. I changed my phone number." Guertin interprets this as evidence that someone other than Rivers was using the phone to contact him about attorney-client matters, potentially to circumvent privilege protections. This is forensically significant — it suggests either (a) a different person used Rivers' new number to contact Guertin, or (b) Rivers was evasive about his identity for nearly 6 hours. 2. **Entry of Default timing correlation:** The precise timing sequence — Entry of Default at 9:44 AM CDT, Guertin's texts to Rivers at ~12:49 PM CDT, Rivers' 16-minute call to Guertin at ~2:28 PM CDT — does corroborate that Rivers was in communication with Guertin on the same day the Entry of Default was filed against him. Whether Rivers discussed the Entry of Default during the 16-minute call is asserted by Guertin but cannot be verified from the phone records alone. 3. **Time zone discrepancy in phone records:** T-Mobile records are displayed in Pacific Time, while the ECF notification is in CDT. The conversion is straightforward (Pacific + 2 hours = CDT), but the presentation without explicit conversion could be confusing. Guertin's characterization of the call as "two hours and forty-four minutes after" the Entry of Default requires the conversion from Pacific 12:28 PM to CDT 2:28 PM, which checks out mathematically (9:44 AM to 2:28 PM = 4 hours 44 minutes, not 2:44 minutes — there may be a discrepancy in Guertin's stated timeline vs. actual calculation, or the reference point is different). 4. **ChatGPT analysis as evidence:** The inclusion of AI-generated legal analysis as a federal court exhibit is highly unusual. The analysis is not presented as a screenshot of the ChatGPT interface but as formatted text, making it impossible to verify it was actually generated by ChatGPT or to confirm the prompt/date. No session ID, URL, or metadata is included. 5. **Mass judicial email campaign:** Guertin sent substantively identical emails to 57 judges across two judicial districts in a single day. This is procedurally extraordinary — ex parte communications with judges not assigned to a case are generally prohibited under judicial ethics rules. Three emails bounced (Conroy, Magill, Bartolomei), suggesting some email addresses were guessed or outdated. Two judges responded with auto-replies. The emails contained case-specific allegations, links to case documents, and requests for judicial intervention, which goes beyond normal communication channels. 6. **Email campaign evolution:** The emails show progressive refinement between the two waves. The first wave (3:20–4:41 AM) uses a general "I need help" subject line. The second wave (9:12–10:31 PM) uses a more aggressive "Proven DISCOVERY FRAUD" subject line and adds language specifically accusing "someone within your very court" of being involved in fraudulent discovery. 7. **Discovery timeline contradiction:** Guertin's July 25 text states Rivers' office provided discovery materials on July 16, 2024, yet simultaneously claims Rivers has been refusing to provide discovery materials. This suggests a new set was finally provided but Guertin contends it was incomplete or itself fraudulent. 8. **Rivers' muted responses:** Throughout the text thread, Rivers' responses are notably brief and non-committal ("I've got your" / "Back"), especially compared to Guertin's lengthy multi-page MMS messages. Rivers does not engage substantively with any of the allegations about fraudulent discovery, the federal lawsuit, or the incompetency proceedings. 9. **PDF annotation warnings:** The PDF extraction generated "Syntax Warning: Bad annotation destination" errors (2 instances), suggesting some bookmarks or hyperlinks in the PDF may be malformed, though the document content extracted cleanly. ### Cross-References - **Federal Case 0:24-cv-02646-JRT-DLM** — Parent case for this exhibit; previously cataloged in Filing #8 (Netflix Whistleblower) and Filing #12 (RICO Complaint)* - **Doc. 71 (Entry of Default as to Bruce Rivers)** — Filed 8/29/2024, core subject of this exhibit - **Doc. 74 (referenced in emails as "very last filing")** — Guertin's most recent filing at time of emails; link provided: gov.uscourts.mnd.216796.74.0.pdf - **State Case 27-CR-23-1886*** — Referenced throughout emails and texts - **Index #29 (state case docket)** — Guertin's pro se filing about discovery fraud, referenced in later emails - **August 7, 2024 Motion** — Referenced as basis for ChatGPT analysis - **Milz Rule 20.01 Report (January 2024)*** — Referenced re: claims being labeled delusional - **Michael Biglow discovery (August 3, 2023)*** — Referenced re: fraudulent discovery materials - **Filing #9 (Motion for Substitute Counsel)*** — Prior filing about Rivers' refusal to withdraw - **MN Court of Appeals Case A24-0780*** — Referenced indirectly - **8th Circuit Court of Appeals case** — Referenced in emails (courtlistener.com/docket/69060054) - **116-page Ethics Complaint (Bruce Rivers)*** — Contextually related, filed 9/25/2024 - **CLR Bruce Rivers YouTube Channel** — https://www.youtube.com/@CLRBruceRivers (referenced in all emails) - **Guertin Substack** — https://MattGuertin.Substack.com (referenced in all emails) - **Guertin personal website** — https://www.MattGuertin.com (referenced in all emails) --- ## Filing #21 — Exhibit P: Conspiracy of Commitment | Field | Detail | |---|---| | Filing # | 21 | | Date Filed | July 16, 2024 | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Exhibit (Exhibit P) — Narrative chronological compilation with supporting evidence | | Case/Court | 0:24-cv-02646-JRT-DLM / U.S. District Court, District of Minnesota (filed as Doc. 23); underlying state cases: 27-CR-23-1886 (criminal) and 27-MH-PR-23-815 (civil commitment) | | Pages | 39 (37 numbered exhibit pages plus cover page and PACER header page) | | Bates / Doc ID | 23__EXHIBIT-P__CONSPIRACY-OF-COMMITMENT.pdf | ### Comprehensive Summary Exhibit P is a 37-page narrative exhibit filed as Doc. 23 in Guertin's federal civil rights case on July 16, 2024 — the same day as his scheduled 1:30 PM "Review Hearing" in the state criminal case. The document is titled "Conspiracy of Commitment" and presents a detailed, chronologically ordered account of what Guertin alleges was a coordinated conspiracy between his defense attorney Bruce Rivers and the Hennepin County Courts to deceive him into a surprise civil commitment proceeding that would result in his involuntary detention in a mental health facility. The core narrative begins on January 15, 2024, when Bruce Rivers told Guertin via text message at 6:26 PM that there was "No court" for his scheduled January 16, 2024, 1:30 PM hearing. Guertin alleges that the very next morning, at 8:26–8:27 AM on January 16, a court order titled "Findings of Fact, Conclusions of Law and Order Regarding Competency" was created and signed by Referee Danielle C. Mercurio, then countersigned by Judge Julia Dayton Klein at 9:22 AM. This order stated that "prior to the hearing, the parties agreed to a finding of incompetency entered administratively" — a statement Guertin vehemently denies, asserting he never agreed to any such finding and was told there was no hearing taking place. Guertin supports his allegations with extensive PDF metadata analysis using ExifTool, which revealed that the court order file was internally titled "Commitment Order (MI, DD)" (interpreted as "Mentally Ill, Developmentally Disabled"), had a Create Date of 2024:01:16 08:26:48 (one minute before Mercurio's 8:27 AM signature), was authored by "barbj," and had a Metadata Date of 2024:01:17 07:29:42, suggesting the document was withheld for a day before being filed into the record on January 17 at 7:29 AM. Guertin flags that the document was placed at Index #25, out of sequential order (after Index #26), and that the e-file timestamp was non-standard — center-positioned, left-justified, with a non-standard date format ("Jan 17, 2024 7:29 am" rather than the usual "1/17/2024 7:29 AM") and a visibly misaligned bottom row of text, all of which Guertin contends are indicative of manual post-hoc insertion. Simultaneously, on January 16 at 4:19 PM, a "Notice of Remote Zoom Hearing" for July 16, 2024 (six months away) was filed at Index #26. Guertin used ExifTool to determine this filing time, noting the e-file timestamp on the document itself was missing the time component. The metadata showed the document was created by "hernandezke." Guertin argues this notice was filed concurrently with the withheld order to create the false impression — had Guertin checked his case files that day — that nothing urgent was occurring and the next event was six months away. On January 17, all further court actions shifted to Guertin's civil case (27-MH-PR-23-815), where between January 17 and January 25, multiple entries appeared at Indices #27–#35. On January 22, an Affidavit of Service was filed (Index #31) along with an Order and Notice of Hearing (Index #30), scheduling a February 1 civil commitment hearing — just 10 days away. Guertin discovered the surprise hearing on Friday, January 26, while reviewing his case files online. He immediately tried to contact Bruce Rivers by phone (12:49 PM) and text (12:51 PM) to obtain the Rule 20.01 exam report prepared by Dr. Adam Milz following a January 3, 2024 evaluation, which he had never been provided. Rivers responded via text: "I'll look for it in my email. Ttyl." The report was never provided. Guertin also located contact information for his newly court-appointed civil commitment attorney, Joel Fisher, through the E-File and Serve service contacts, and emailed him at 1:38 PM. At 4:38 PM, Guertin emailed Rivers again requesting the exam report. Fisher replied on January 27 stating he was "hoping to see if there is some sort of an offer from the county." Guertin replied on January 28: "An 'offer' for what exactly? I have no idea what is going on." On January 29, Fisher attempted to call Guertin but revealed that the court had provided him with a completely wrong phone number (763-245-0896), which Guertin states bore no resemblance to his actual number, suggesting deliberate provision of an incorrect number to prevent attorney-client contact before the hearing. On January 30 at 6:37 AM and 6:43 AM, Guertin filed two pro se motions into his civil case: a Motion for Continuance (Index #36) and a Motion for Production of Medical Records (Index #37). The Motion for Continuance cited his recent discovery of the hearing date, non-receipt of the exam report despite repeated requests, lack of effective communication with his court-appointed attorney due to the wrong phone number, and the need for additional preparation time. The Motion for Production of Medical Records specifically requested the complete psychological evaluation report conducted by Dr. Adam Milz on January 3, 2024, all related notes and observations, and any other relevant medical or psychological records. On January 31, Guertin signed a Waiver (Index #38) agreeing to extend his Stay of Commitment by an additional nine months to avoid appearing in-person at the February 1 hearing, where he feared being detained. The Waiver, filed in case 27-MH-PR-23-815, states Guertin consented to the extension for a period of nine months without the hearing provided by Minn. Stat. §253B.05 subd.3, 08, and .09. It includes Guertin's handwritten date of 1/31/2024 and his signature. Judicial Referee George Borer then filed a "Taken Under Advisement" notice at Index #39. On February 1, 2024, an Order for Continued Stayed Commitment was filed at Index #41 (not #40, which Guertin notes is missing/deleted). The order, recommended by Referee Borer and signed by Judge Klein, extended the Stayed Order of Commitment until November 8, 2024, and dismissed Guertin's Motion for Continuance and Motion for Production of Medical Records "without prejudice." The order stated the February 1 hearing at 9:00 AM was "cancelled and shall be stricken from the court's calendar," yet Guertin's civil case timeline shows the hearing listed as "Held Off The Record." The exhibit then chronicles Guertin's continued attempts to obtain the exam report and resolve the representation issue. On April 3, 2024, Guertin emailed Rivers requesting he file a Withdrawal of Representation, attaching a Petition to Proceed as Pro Se Counsel. On April 4, Guertin filed a pro se Motion to Compel Production of Medical Records (Index #43) in his civil case, which he states was ignored. On April 18, Guertin sent another text to Rivers requesting withdrawal, citing advice from multiple trusted parties. Rivers refused. On May 3, 2024, Guertin filed a Follow-Up Correspondence (Index #36 of the criminal case) addressed to Judge Julia Dayton Klein and the Clerk of Court, following up on unacknowledged motions including a Motion for Judicial Notice, Motion to Compel Discovery, and Motion to Compel Production of Medical Records. He cited specific Minnesota Rules of Criminal Procedure (Rule 9.01 subd.1(3)(b), 1(4)(a), 1(6), 1a(1), 2(1)) and Special Rules of Procedure Governing Proceedings Under the Minnesota Commitment and Treatment Acts (Rule 13(a)). The correspondence noted that only fraudulently altered discovery materials had ever been provided, and that the court continued to withhold the exam report four months and two motions later. On June 3, 2024, Guertin filed three additional pro se documents in his criminal case: a second Motion to Compel Discovery (Index #90), a Motion for Substitute Counsel (Index #91), and a second Follow-Up Correspondence (Index #92). The Motion to Compel Discovery was addressed to Judges Quam and Klein, ACA Jacqueline Perez, the Clerk of Court, and the Hennepin County Attorney's Office. It cited Minnesota Rule of Criminal Procedure 9.01 (subd. 1(3)(b), 1(6), 1a(1), 2(1)) and Federal Rule of Evidence 901(b)(1). It specifically requested all Brady material, squad video, audio tapes, and all 104 police photographs taken by Minnetonka PD on January 21, 2023. The Motion for Substitute Counsel cited Strickland v. Washington, 466 U.S. 668 (1984) and detailed instances of ineffective assistance including failure to provide discovery, failure to present exculpatory evidence at the July 7, 2023 hearing, conflict of interest, and broken promises regarding civil commitment representation. On June 6, 2024, Guertin sent extensive text messages to Rivers demanding withdrawal, including detailed accusations regarding ineffective assistance, fraudulent discovery materials, and the "powerful people" comment. Rivers continued to refuse to withdraw. The exhibit concludes with Guertin's statement that as of July 16, 2024 (the day of filing), he expects to be detained at court, and that every one of his constitutional rights, access to a fair trial, and due process protections have been disregarded. ### Legal Issues & Arguments Raised - Fraudulent court order: Allegation that the January 16–17, 2024 "Findings of Fact, Conclusions of Law and Order Regarding Competency" was fabricated, claiming Guertin agreed to a finding of incompetency when he was told there was "no court" - Ineffective assistance of counsel (Sixth Amendment / Strickland v. Washington): Bruce Rivers allegedly colluded with the court by telling Guertin there was "no court" and then acting on his behalf without knowledge or consent - Denial of access to critical evidence: Rule 20.01 exam report by Dr. Adam Milz from January 3, 2024 withheld from Guertin despite repeated formal and informal requests over six+ months - Due process violations: Surprise civil commitment hearing with less than one week's notice; incorrect phone number provided to court-appointed attorney to prevent contact - Document tampering / manipulation of court records: Non-standard e-file timestamps, out-of-sequence index numbering, missing Index #40, metadata title discrepancy ("Commitment Order (MI, DD)" vs. displayed title) - Procedural fraud: February 1 hearing listed as "Held Off The Record" despite the court order stating it was "cancelled and stricken from the court's calendar" - Dismissal without prejudice of motions for continuance and production of medical records - Denial of pro se representation while simultaneously labeling defendant incompetent - Right to effective legal representation under Sixth Amendment - Minnesota Rules of Criminal Procedure Rule 9.01 (multiple subdivisions) - Rule 13(a), Special Rules of Procedure Governing Proceedings Under the Minnesota Commitment and Treatment Acts - Conflict of interest: Rivers allegedly compromised by "powerful people" and refused to withdraw despite multiple requests - Broader conspiracy allegation connecting competency proceedings to patent fraud involving US Patent 11,577,177 and Netflix ### Factual Allegations & Key Assertions - January 15, 2024 at 6:26 PM: Bruce Rivers told Guertin via text "No court" for the next day's scheduled 1:30 PM hearing - January 16, 2024: No contact between Guertin and Rivers; Waiver of Appearance entered at Index #24; "Found Incompetent" notation entered with no Index number and no corresponding PDF - January 16, 2024 at 8:26 AM: PDF metadata Create Date for the competency order (one minute before Mercurio's 8:27 AM signature) - January 16, 2024 at 8:27 AM: Referee Mercurio signs "Findings of Fact, Conclusions of Law and Order Regarding Competency" - January 16, 2024 at 9:22 AM: Judge Klein countersigns the order - January 16, 2024 at 4:19 PM: Notice of Remote Zoom Hearing for July 16, 2024 filed at Index #26 - January 16, 2024 at 1:30 PM: Originally scheduled hearing marked "Cancelled; Other" - January 17, 2024 at 7:29 AM: The January 16 court order officially filed into the criminal case record, becoming the "January 17 Court Order" at Index #25 (out of sequence) - PDF metadata for competency order: Author "barbj"; Title "Commitment Order (MI, DD)"; Creator Tool "Microsoft Word for Microsoft 365"; iText Group NV (Minnesota Judicial Branch) processing - PDF metadata for Notice of Remote Hearing: Author "hernandezke"; missing time in e-file stamp; Create Date 2024:01:16 16:19:59 - E-file timestamp anomalies: Non-standard placement (center vs. right), left-justified text, non-standard date format, missing time on one document - January 22, 2024: Affidavit of Service filed (sheriff serving order to appear) - January 25, 2024: Four separate actions in civil case (Indices #32–#35) - January 26, 2024: Guertin discovers surprise February 1 hearing; contacts Rivers by phone (12:49 PM) and text (12:51 PM); contacts Joel Fisher by email (1:38 PM); emails Rivers again (4:38 PM) - Court provided Joel Fisher with wrong phone number (763-245-0896) bearing no resemblance to Guertin's actual number - January 30, 2024: Pro se Motion for Continuance filed at 6:37 AM (Index #36); Pro se Motion for Production of Medical Records filed at 6:43 AM (Index #37) - January 31, 2024: Guertin signs Waiver extending Stay of Commitment by 9 months; DOB listed as 7/17/1981 - February 1, 2024: Order for Continued Stayed Commitment filed at Index #41; Index #40 missing/deleted; order extends commitment until November 8, 2024; motions dismissed without prejudice - February 1 hearing listed as "Held Off The Record" despite order stating it was cancelled and stricken - Dr. Adam Milz, PhD, LP, ABPP, Psychological Services of Hennepin County District Court, conducted the Rule 20.01 evaluation; the evaluation was ordered November 15, 2023 by Judge Klein - Milz opined defendant lacks ability to rationally consult with counsel or understand proceedings due to mental illness or cognitive impairment; opinion described as "uncontested by either party" — Guertin disputes this - Court order provisions included: defendant ordered to cooperate with civil commitment process; if found dangerous by Probate/Mental Health Division, defendant may be committed to "safe and secure facility"; treatment facility head to submit reports every six months; criminal conditions of release remain until "placement at an appropriate facility"; next review July 16, 2024 - Reports to be e-served to: 4thCriminalRule20 email list; Bruce Rivers (riverslawyers@aol.com); Jacqueline Perez (jacqueline.perez@hennepin.us); Hennepin County Attorney's Office – Adult Services Division (if commitment ordered); Commitment Defense Panel attorney appointed by Fourth Judicial District Court – Probate/Mental Health Division - April 3, 2024: Guertin emails Rivers requesting withdrawal, attaches Petition to Proceed as Pro Se Counsel - April 4, 2024: Pro se Motion to Compel Production of Medical Records filed (Index #43, civil case); Petitioner listed as Hennepin County Attorney's Office; Lead Attorney for Petitioner: De Souza, Lea Marie - April 18, 2024: Guertin texts Rivers second request to withdraw; mentions advice from "multiple parties" including Vail Place case worker - May 3, 2024: Follow-Up Correspondence filed in criminal case; Guertin cites Rules 1.0–1.18 of MN Rules of Professional Conduct regarding Rivers' failures; mentions active MnCare/HealthPartners health plan and upcoming therapist appointment - June 3, 2024: Second Motion to Compel Discovery (Index #90), Motion for Substitute Counsel (Index #91), Second Follow-Up Correspondence (Index #92) filed; all follow completion of MN Court of Appeals case A24-0780 on May 31, 2024 - June 6, 2024: Third demand to Rivers via text to withdraw; Rivers asks "What did I do to you?" and "Where do I send your file?"; Guertin sends four groups of detailed text messages - Guertin's address listed as 4385 Trenton Lane North, Apt 202, Plymouth, MN 55442 (on Notice of Remote Hearing); later address 1075 Traditions Ct, Chaska, MN 55318 (on later filings) - Lea De Souza identified as Assistant Hennepin County Attorney representing the petitioner in commitment proceedings - Joel Fisher identified as court-appointed attorney representing Guertin in civil commitment proceedings ### Procedural Posture Filed on July 16, 2024, as Doc. 23 in the federal civil rights action (0:24-cv-02646-JRT-DLM), on the same day as Guertin's scheduled Review Hearing in the criminal case. The exhibit serves as supporting evidence for Guertin's federal civil rights claims, documenting what he characterizes as a conspiracy to effect a fraudulent civil commitment. The exhibit references events from January 15, 2024 through June 6, 2024, and sits within the context of the broader federal case that was initially filed on July 8, 2024. ### Exhibit / Attachment Inventory This exhibit is itself a compilation that references but does not separately attach the following sub-exhibits: - Exh. A, Index 00 — 27-CR-23-1886 Case Timeline (pp. 7, 9) - Exh. A, Index 25 — January 16/17, 2024 Court Order / Finding of Incompetency and Order (pp. 1–4) - Exh. A, Index 26 — Notice of Remote Zoom Hearing with Instructions (pp. 1–2) - Exh. A, Index 36 — May 3, 2024 Follow-Up Correspondence (pp. 1–3) - Exh. A, Index 90 — June 3, 2024 Second Motion to Compel Discovery (pp. 1–5) - Exh. A, Index 91 — June 3, 2024 Motion for Substitute Counsel (pp. 1–4) - Exh. A, Index 92 — June 3, 2024 Second Follow-Up Correspondence (p. 1) - Exh. C, Index 30 — Text/call evidence compilation (pp. 22, 35–38, 83–85) - Exh. D, Index 38 — Email evidence compilation (pp. 141–144, 148) - Exh. F, Index 01 — Court of Appeals petition - Exh. K, Index 00 — 27-MH-PR-23-815 Civil Case Timeline (pp. 1–2, 4) - Exh. K, Index 36 — Guertin-Fisher email correspondence (pp. 1–2, 7, 9–12) - Exh. K, Index 37 — Motion for Production of Medical Records (pp. 1–2) - Exh. K, Index 38 — Waiver (p. 1) - Exh. K, Index 41 — February 1, 2024 Order for Continued Stayed Commitment (pp. 1–2) - Exh. K, Index 43 — Motion to Compel Production of Medical Records (pp. 1–2) - Exh. N, Index 04 — June 6, 2024 text messages to Rivers (pp. 26–27) - Exh. Q — Federal complaint (referenced for "powerful people" comment) - Exh. S, Index 09 — Patent attorney correspondence ### Visual Evidence Inventory - **[Page 1]** Cover page: White page reading "Exhibit P" with PACER header "CASE 0:24-cv-02646-JRT-DLM Doc. 23 Filed 07/16/24 Page 1 of 39." Standard federal e-filing stamp. - **[Page 3]** Annotated chronological timeline chart: Large composite image showing dual-column layout of Guertin's criminal case (27-CR-23-1886, left) and civil case (27-MH-PR-23-815, right) timelines from 01/16/2024 through 02/16/2024. Contains case information headers with case numbers, status, judicial officers (Quam, Jay for criminal; Borer, George for civil), and defendant/respondent identification. Each row shows a dated docket entry (e.g., "Waiver of Appearance, Index #24"; "Found Incompetent, Judicial Officer: Mercurio, Danielle"). Extensive hand-annotated red and yellow highlighted commentary appears alongside each entry. Notable annotations flag: Index #25 appearing "out of sequence"; Index #40 "missing/deleted"; the statement about Guertin being told "No court." Red highlighting marks key entries. Footer reads "Exhibit P | Commitment Conspiracy | p. 1." This appears to be a screenshot of the MCRO court records system reformatted with annotations. - **[Page 4]** Two email screenshots (Exh. D, Index 38, pp. 141–142): Emails between Guertin (MattGuertin@protonmail.com) and Bruce Rivers (riverslawyers@aol.com) dated January 14 at 12:00 PM and January 15 at 3:02 PM. Subject line "Re: Matt Guertin / LinkedIn Search Graph." Content: Guertin asks "Can my court date on Tuesday be over Zoom then?" and follows up with "YO." Standard email formatting, no anomalies. - **[Page 4]** Two phone call log screenshots labeled "Bruce-Rivers-Calls-04" and "Bruce-Rivers-Calls-05": Dark-themed mobile phone interface showing call history. Calls-04 shows May 31, 2023 outgoing call at 7:35 PM (0 mins 8 sec) and incoming call at 7:41 PM (0 mins 35 sec). Calls-05 shows incoming call at 9:41 PM (2 mins 0 sec) and January 15 outgoing call at 4:17 PM (0 mins 9 sec). Standard Android/iOS call log interface. - **[Page 4]** Three text message screenshots labeled "Bruce-Rivers-Texts-25," "Bruce-Rivers-Texts-26," and "Bruce-Rivers-Texts-27": Dark-themed messaging interface, contact name "Bruce Rivers Cel." Texts-25 shows messages about wanting to meet with "a neutral Doctor" and concerns about representation. Texts-26 shows a message sent August 1 at 6:14 AM about leaving a message through Rivers' office and concerns about freedom being taken away. **Texts-27 (critical)**: Shows Monday, January 15 exchange — Guertin asks "Can I call you later?" at 4:17 PM; Rivers responds "Sure. If I don't answer for some reason try 763..." at 4:18 PM; Guertin asks "Can I do zoom tomorrow? I kind of have to know what's going on..." at 6:25 PM; **Rivers responds "No court" at 6:26 PM**, followed by "I'll call you in the morning" and "Nothing has changed" at 6:27 PM. Guertin's reply appears at 6:27 PM. The "No court" message is clearly visible and legible. - **[Page 5]** Two text message screenshots labeled "Bruce-Rivers-Texts-28" and "Bruce-Rivers-Texts-29": Texts-28 shows Tuesday, January 16 exchange with Guertin sending "Xok" at 7:32 PM. Also shows Rivers saying "Otherwise if I try calling you... around lunch time? Between 12 and 1?" at 6:28 PM prior, and "Have a good night" at 6:30 PM. **Texts-29** shows Sunday, January 28 exchange: a protonmail.com reference; Guertin asking about "The one that claims I'm 'incompetent'..." at 12:51 PM; Rivers responding "I'll look for it in my email. Ttyl" at 12:53 PM; then "Bruuuuuce" at 4:34 PM on Sunday, January 28; and Monday, January 29 "Matthew?" at 8:45 AM from Rivers with "Yes" and "Tis me" responses from Guertin at 8:47 AM. - **[Page 5]** Court records screenshot: Three rows from 27-CR-23-1886 case timeline showing entries dated 01/16/2024 (Found Incompetent, Judicial Officer: Mercurio, Danielle — notably with no Index number); 01/16/2024 (Waiver of Appearance, Index #24); 01/11/2024 (Rule 20 Evaluation Report, Index #23). This confirms the "Found Incompetent" entry has no corresponding index or PDF. - **[Page 5]** Court order header screenshot: Shows "STATE OF MINNESOTA / COUNTY OF HENNEPIN" District Court header with case number 27-CR-23-1886, title "FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER REGARDING COMPETENCY." Contains two signatures: left side "Order Recommended By:" with signature of "Mercurio, Danielle" dated "Jan 16 2024 8:27 AM" as Referee of District Court; right side "BY THE COURT:" with signature of "Dayton Klein, Julia" dated "Jan 16 2024 9:22 AM" as Judge of District Court. Both signatures appear as electronic/digital signatures with printed names and timestamps below. A faint watermark or background text is visible behind the document. - **[Page 6]** ExifTool metadata output screenshot: Terminal-style black background with green/white text showing metadata for file "25__Finding-of-Incompetency-and-Order__2024-01-17.pdf." Key fields: Author: barbj; Create Date: 2024:01:16 08:26:48-06:00; iText 7.1.16 (Minnesota Judicial Branch); Creator Tool: Microsoft Word for Microsoft 365; Metadata Date: 2024:01:17 07:29:42-06:00; Title: Commitment Order (MI, DD); Creator: barbj. The "Title" field ("Commitment Order (MI, DD)") and "barbj" author are highlighted as significant. - **[Page 6]** Court order text excerpts (highlighted): Two boxed sections from Exh. A, Index 25. First box shows the opening paragraph stating the matter was scheduled before the undersigned Referee on January 16, 2024, Tom Arneson as ACA, defendant represented by Bruce Rivers, and the critical sentence "Prior to the hearing, the parties agreed to a finding of incompetency entered administratively" — with "agreed to a finding of incompetency entered administratively" highlighted in yellow. Second box shows Findings of Fact #2–4: #2 notes November 15, 2023 order by Judge Klein for competency evaluation per Minn.R.Crim.P. 20.01; #3 identifies Dr. Adam A. Milz, PhD, LP, ABPP as the examiner; #4 states Milz opined defendant lacks ability to consult with counsel or understand proceedings, with "This opinion was uncontested by either party" highlighted in yellow. - **[Page 7]** Court order text (continued): Paragraphs 9–11 and 12–13 from the competency order with yellow highlighting on key phrases: "Defendant may be committed directly to an appropriate safe and secure facility"; "at least every six months"; "if the defendant is civilly committed"; "until placement at an appropriate facility can occur"; "is July 16, 2024"; "if a commitment is ordered"; "The Commitment Defense Panel attorney appointed to represent Defendant." - **[Page 7]** Hearings section screenshot: Shows "Previous Hearings" entry for 01/16/2024 at 01:30 PM — "Review Hearing, Judicial Officer: Mercurio, Danielle, Location: GC-C556" with red-highlighted status "Cancelled; Other." - **[Page 8]** Notice of Remote Zoom Hearing screenshot: Full-page image of the notice. Shows "Filed in District Court State of Minnesota 1/16/2024" stamp (notably missing the time). Addressed to Matthew David Guertin, 4385 Trenton Lane North, Apt 202, Plymouth MN 55442. Hearing Information table shows "July 16, 2024 / Review Hearing / 1:30 PM" highlighted in yellow. Contains standard language about Zoom hearing and warning about failure to appear. The e-file stamp anomaly (missing time, left-justified) is visible. - **[Page 9]** ExifTool metadata output for Notice of Remote Hearing: Shows file "26__Notice-of-Remote-Hearing-with-Instructions__2024-01-16.pdf." Key fields: Author: hernandezke; Create Date: 2024:01:16 16:19:59-06:00; Modify Date: 2024:04:28 02:24:24-05:00; Creator Tool: PScript5.dll Version 5.2.2; Producer: Acrobat Distiller 23.0 (Windows) modified using iText (MN Judicial Branch); Title: Microsoft Word - Document in Unnamed; Creator: hernandezke; Page Count: 2. - **[Page 9]** Court order header (filed version): Shows the competency order as filed with "Filed in District Court State of Minnesota Jan 17, 2024 7:29 am" stamp at top center. Guertin annotates that this timestamp is non-standard in placement, format, and justification. - **[Page 10]** Case timeline screenshot: Four rows from 27-CR-23-1886 showing 04/03/2024 (Petition to Proceed as ProSe Counsel, Index #27, 8 pages); 01/17/2024 (Finding of Incompetency and Order, Judicial Officer: Mercurio, Danielle, Index #25, highlighted in red, 4 pages); 01/16/2024 (Notice of Remote Hearing with Instructions, Index #26, 2 pages); 01/16/2024 (Found Incompetent, Judicial Officer: Mercurio, Danielle — no index number). The out-of-sequence ordering (#25 appearing after #26) is visually apparent. - **[Page 10]** Second ExifTool metadata output (duplicate with first): Shows same file with Create Date 2024:01:16 08:26:48-06:00 and Title "Commitment Order (MI, DD)." - **[Page 10]** Court order text excerpt: Paragraph 4 quoted with highlighting on "This opinion was uncontested by either party." - **[Page 11]** Close-up of court order header e-file stamp: Zoomed view showing "Filed in District Court State of Minnesota Jan 17, 2024 7:29 am" stamp with annotation pointing out the non-standard placement (top-center instead of upper-right), left-justified text, and non-standard date format. - **[Page 11]** Civil case timeline screenshot (27-MH-PR-23-815): Shows entries from 01/17/2024 through 01/25/2024 at Indices #27–#35, including: Notice of Motion and Motion (#27), Other Document (#28), Correspondence (#29) on 01/17/2024; Order and Notice of Hearing (#30), Affidavit of Service (#31) on 01/22/2024; Motion for Production of Medical Records (#32), Proposed Order or Document (#33), Correspondence (#34), Order for Production of Medical Records (#35) on 01/25/2024. - **[Page 12]** Phone call logs (Bruce-Rivers-Calls-04 and 05): Shows January 26 outgoing call at 12:49 PM (0 mins 6 sec) and January 28 outgoing call at 4:31 PM (0 mins 7 sec). - **[Page 12]** Text message screenshots (Bruce-Rivers-Texts-28 and 29): Shows Friday, January 26 messages requesting the psychological exam report, Rivers' response, and subsequent exchanges through Monday, January 29. - **[Page 13]** Email screenshot (Guertin to Joel Fisher, January 26, 1:38 PM): Subject "Matthew Guertin - Hello." Guertin writes noting his incompetency status, finding Fisher's contact info through E-File and Serve, attempting to call without answer, and asking about Zoom proceedings. - **[Page 13]** Email screenshot (Guertin to Bruce Rivers, January 26, 4:38 PM): Subject "Re: Matt Guertin / LinkedIn Search Graph." Brief message: "Can you please email me my psychological evaluation report?" with "evaluation report" highlighted in red. - **[Page 14]** Email screenshot (Fisher to Guertin, January 27, 2:13 PM): Subject "Re: Matthew Guertin - Hello." Fisher writes he received Guertin's email and is "hoping to see if there is some sort of an offer from the county" — highlighted in yellow. - **[Page 14]** Email screenshot (Guertin to Fisher, January 28, 9:51 PM): Guertin responds "An 'offer' for what exactly? I have no idea what is going on.." — highlighted in red. - **[Page 15]** Email screenshot (Fisher to Guertin, January 29, 5:46 AM): "I'll try to call you this AM." — highlighted in yellow. - **[Page 15]** Email screenshot (Fisher to Guertin, January 29, 11:14 AM): Subject "Phone." Fisher asks "What's the best # to reach you. I must have an old # 763-245-0896" — the wrong number highlighted in red with annotation noting it bears no resemblance to Guertin's actual number. - **[Page 16]** Pro se Motion for Continuance screenshot: Full page of Guertin's January 30, 2024 motion filed in 27-MH-PR-23-815. Shows four numbered grounds: (1) recent discovery of hearing date with less than one week to prepare; (2) non-receipt of crucial medical records including Dr. Milz's evaluation; (3) lack of effective communication with court-appointed attorney including wrong phone number; (4) requirement for clarity and fairness in proceedings. - **[Page 17]** Motion for Continuance (page 2) and Motion for Production of Medical Records (page 1): Continuation of the continuance motion requesting 30-day postponement, and beginning of the medical records motion requesting Dr. Milz's evaluation conducted January 3, 2024. - **[Page 18]** Motion for Production of Medical Records (page 2) and Waiver: Shows conclusion of medical records motion. Below, the Waiver form: "STATE OF MINNESOTA / COUNTY of HENNEPIN / FOURTH JUDICIAL DISTRICT / MENTAL HEALTH DIVISION / Court File: 27-MH-PR-23-815." Lists Matthew Guertin, DOB 07/17/1981. Waiver text states consent to extending Stay of Commitment for 9 months without hearing per Minn. Stat. §253B.05 subd.3, 08 and .09. Handwritten date "1/31/2024" and Guertin's handwritten signature "Matthew David Guertin." - **[Page 19]** Civil case timeline excerpt showing Index #39 (01/31/2024, Taken Under Advisement, Judicial Officer: Borer, George) and Index #38 (01/31/2024, Waiver). - **[Page 20]** Order for Continued Stayed Commitment (page 1): Filed 2/1/2024 at 8:39 AM in 27-MH-PR-23-815. Identifies Lea De Souza as ACA representing petitioner, Joel Fisher representing respondent. Notes Guertin's waiver and continuation of Stayed Commitment for 9 months. Contains a typo: "STAYED OMMITMENT" (missing 'C'). Yellow highlighting on key provisions including November 8, 2024 expiration date and dismissal of motions. - **[Page 21]** Order for Continued Stayed Commitment (page 2): Shows paragraph 3 stating hearing "is cancelled and shall be stricken from the court's calendar" — highlighted in yellow. Signatures: "Order Recommended by" George Borer (Referee, Feb 1 2024 8:10 AM) and "BY THE COURT" Julia Dayton Klein (Judge, Feb 1 2024 8:35 AM). - **[Page 21]** Hearings section screenshot: Shows 02/01/2024 at 09:00 AM — "Motion Hearing, Judicial Officer: Borer, George, Location: GC-C456" with result "Held Off The Record" — contradicting the order's statement that the hearing was cancelled. - **[Page 21]** Civil case timeline showing Index #41 (02/01/2024, Order for Continued Commitment, Borer), Index #39 (01/31/2024, Taken Under Advisement, Borer), Index #38 (01/31/2024, Waiver). Gap between #39 and #41 confirms missing Index #40 — highlighted in yellow. - **[Page 22]** Order excerpt showing dismissal of motions "without prejudice" highlighted in yellow. Email screenshot of April 3, 2024 Guertin-to-Rivers email: "NOTICE OF DISMISSAL AS DEFENSE COUNSEL / Matthew Guertin / 27-CR-23-1886." Attachment: "27-CR-23-1886_Pro-Se-Motion_2024-04-03.pdf" (300.35 KB). - **[Page 23]** Motion to Compel Production of Medical Records (civil case, April 4, 2024): Two-page document showing case header (27-MH-PR-23-815), Petitioner as Hennepin County Attorney's Office, Lead Attorney De Souza, Lea Marie. Filed 4/4/2024 at 7:30 AM. Requests production of Dr. Milz's January 3, 2024 exam report "within a reasonable timeframe" — highlighted in yellow. - **[Page 24]** Text message screenshots (Guertin to Rivers, April 18): Two screenshots showing Guertin demanding Rivers withdraw, citing advice from multiple parties including his Vail Place case worker, mentioning "external influences," and noting Rivers' failure to represent him as promised. - **[Pages 25–27]** May 3, 2024 Follow-Up Correspondence: Three pages addressed to Judge Julia Dayton Klein and Clerk of Court. References pending Motion for Judicial Notice, Motion to Compel Discovery, and Motion to Compel Production of Medical Records (filed April 3–4, 2024). Cites Rules 9.01 subd.1(3)(b), 1(4)(a), 1(6), 1a(1), 2(1) of MN Rules of Criminal Procedure and Rule 13(a) of Special Rules. Discusses denial of Pro Se Counsel petition, ongoing discovery withholding, MnCare/HealthPartners enrollment, and planned therapist visits. Signed by Matthew David Guertin. - **[Pages 28–32]** June 3, 2024 Second Motion to Compel Discovery: Five pages filed in 27-CR-23-1886 at 7:37 AM. Addressed to Judges Quam and Klein, ACA Perez, Clerk of Court. Details chronological history of discovery requests from January 5, 2024 forward. Cites MN Rule of Criminal Procedure 9.01 (multiple subdivisions) and Federal Rule of Evidence 901(b)(1). Requests provision of all missing discovery, investigation of discrepancies, and direct delivery to Guertin at MattGuertin@Protonmail.com. Signed "/s/ Matthew Guertin." - **[Pages 33–36]** June 3, 2024 Motion for Substitute Counsel: Four pages filed at 7:33 AM. Details Strickland v. Washington standard, conflict of interest, constitutional rights, procedural failures, and requests appointment of public defender. Signed "/s/ Matthew Guertin." - **[Page 37]** June 3, 2024 Second Follow-Up Correspondence: One page filed at 7:41 AM. Addressed to Judges Quam and Klein and Clerk of Court. References pending motions and requests prompt action. Signed by Matthew David Guertin. - **[Pages 38–39]** June 6, 2024 text messages to Bruce Rivers: Four groups of screenshots. First group shows morning messages at 6:56 AM: "I DO NOT WANT TO BE REPRESENTED BY YOU ANYMORE. / I DON'T TRUST YOU. / PLEASE WITHDRAWAL FROM MY CASE. / I want a public defender. / I want discovery. / I still want my Rule 20 exam from last January. / I'm not calling you." Rivers responds at 7:51 AM "What did I do to you?" and 7:53 AM "Where do I send your file?" Second through fourth groups show extensive 4:20 PM text messages discussing ineffective assistance under Strickland, fraudulent discovery at Index #29, broken promise of civil commitment representation, LinkedIn searches by entities connected to Netflix (US Air Force, Lockheed Martin, Forcepoint, 3Gimbals, DARPA, Defense Intelligence Agency, USINDOPACOM, KBR Inc., USC School of Cinematic Arts, US Army Reserves), the "powerful people" comment from May 22, 2023, and his patent for "the 'holy grail' of virtual reality/film production" with "VAST implications for use in military training simulations." Final messages: "You are either being paid off or being threatened, etc. Regardless it is now blatantly obvious that you are 'compromised'" and "To sit here and pretend I'm 'incompetent' is an insult to my Intelligence and yours... and you fucking know it." ### Key People Referenced - **Matthew David Guertin*** — Defendant/Respondent/Plaintiff (DOB: 07/17/1981) - **Bruce Rivers*** — Defense counsel (criminal case); riverslawyers@aol.com; known by Guertin for 20+ years - **Danielle C. Mercurio*** — Referee, Fourth Judicial District; signed competency order at 8:27 AM on 1/16/2024 - **Julia Dayton Klein*** — Judge, Fourth Judicial District; countersigned competency and commitment orders - **George Borer*** — Referee, Fourth Judicial District; oversaw civil commitment proceedings; recommended February 1 order - **Joel Fisher** — Court-appointed attorney for Guertin in civil commitment case (27-MH-PR-23-815) - **Dr. Adam A. Milz*** — PhD, LP, ABPP; Psychological Services, Hennepin County District Court; conducted January 3, 2024 Rule 20.01 evaluation - **Tom Arneson** — Assistant Hennepin County Attorney; represented the plaintiff in the January 16 competency hearing - **Lea De Souza** — Assistant Hennepin County Attorney; represented petitioner in civil commitment proceedings - **Jacqueline Perez*** — Assistant Hennepin County Attorney (criminal case) - **Jay Quam*** — Judge, Fourth Judicial District (criminal case, addressed in June 3 motions) - **"barbj"*** — PDF metadata author/creator of the competency order - **"hernandezke"*** — PDF metadata author/creator of the Notice of Remote Zoom Hearing - **Stephan Trojansky*** — Referenced as filer of duplicate patent application 12 days after Guertin - **Dr. Michael Robertson*** — Referenced as conducting second mental health exam based on allegedly fraudulent discovery - **Dr. Jill Rogstad*** — Referenced as author of initial Rule 20.01 exam report (March 10, 2023) ### Key Entities / Organizations Referenced - Hennepin County District Court, Fourth Judicial District - Hennepin County Attorney's Office (including Adult Services Division) - Fourth Judicial District Court — Probate/Mental Health Division - Commitment Defense Panel - Psychological Services of Hennepin County District Court - Department of Human Services Forensic Evaluation Department - Minnesota Court of Appeals (case A24-0780) - U.S. District Court, District of Minnesota (0:24-cv-02646-JRT-DLM) - Netflix, Inc. - U.S. Patent Office - Vail Place (case worker referenced) - MnCare/HealthPartners - MCRO electronic records system (referenced by name) ### Dates & Deadlines Mentioned - November 15, 2023 — Judge Klein ordered competency evaluation under Minn.R.Crim.P. 20.01 - January 3, 2024 — Dr. Milz conducts Rule 20.01 evaluation of Guertin - January 11, 2024 — Rule 20 Evaluation Report filed at Index #23 - January 14, 2024 — Guertin emails Rivers re: Zoom court date - January 15, 2024, 6:26 PM — Rivers texts "No court" - January 16, 2024, 8:26–8:27 AM — Competency order created/signed by Mercurio - January 16, 2024, 9:22 AM — Klein countersigns - January 16, 2024, 4:19 PM — Notice of Remote Hearing filed - January 17, 2024, 7:29 AM — Competency order filed into record - January 22, 2024 — Affidavit of Service and Order/Notice of Hearing - January 25, 2024 — Four actions in civil case - January 26, 2024 — Guertin discovers surprise hearing; contacts Rivers and Fisher - January 29, 2024 — Fisher reveals wrong phone number - January 30, 2024, 6:37 AM — Motion for Continuance filed; 6:43 AM — Motion for Production of Medical Records filed - January 31, 2024 — Waiver signed - February 1, 2024 — Order for Continued Stayed Commitment; hearing cancelled/stricken but listed as "Held Off The Record" - April 3, 2024 — Guertin requests Rivers' withdrawal - April 4, 2024 — Motion to Compel Production of Medical Records (civil case) - April 18, 2024 — Second request for Rivers' withdrawal - May 3, 2024 — Follow-Up Correspondence filed - May 31, 2024 — Completion of MN Court of Appeals case A24-0780 - June 3, 2024 — Three filings: Motion to Compel Discovery, Motion for Substitute Counsel, Follow-Up Correspondence - June 6, 2024 — Third demand for Rivers' withdrawal - July 16, 2024, 1:30 PM — Review Hearing (date of this exhibit's filing) - November 8, 2024 — Expiration date of extended Stayed Commitment ### Forensic Flags & Anomalies 1. **"No court" deception followed by 8:26 AM court order creation**: The one-minute gap between the PDF Create Date (8:26:48 AM) and Mercurio's signature timestamp (8:27 AM) on January 16 — the morning after Rivers told Guertin there was "no court" — suggests a pre-planned administrative action taken without the defendant's knowledge or consent. 2. **Document title vs. displayed title discrepancy**: The PDF metadata title "Commitment Order (MI, DD)" does not match the displayed document title "Findings of Fact, Conclusions of Law and Order Regarding Competency," suggesting the template used was originally for a commitment order for a mentally ill/developmentally disabled person. 3. **"barbj" as document author**: The same metadata author ("barbj") identified in previous catalog entries as prolific across 137 documents / 105 cases. 4. **Out-of-sequence index numbering**: Index #25 (filed 1/17) appears after Index #26 (filed 1/16) in the case timeline, inconsistent with sequential filing. 5. **Non-standard e-file timestamps**: Multiple anomalies — center positioning instead of upper-right corner; left-justified instead of right; "Jan 17, 2024 7:29 am" format instead of standard "1/17/2024 7:29 AM"; missing time on the Notice of Remote Hearing timestamp; misaligned bottom text row. These are characterized as indicative of manual post-hoc insertion. 6. **Missing Index #40**: Civil case timeline jumps from Index #39 (01/31/2024) to Index #41 (02/01/2024). No explanation provided for the missing entry. 7. **"Held Off The Record" vs. "Cancelled and Stricken"**: The February 1 hearing is documented in the court order as cancelled and stricken, yet the case timeline reflects it as "Held Off The Record" — a direct contradiction. 8. **Wrong phone number provided to Fisher**: Joel Fisher was given phone number 763-245-0896, which Guertin states bore no resemblance to his actual number, potentially preventing attorney-client contact before the surprise hearing. 9. **"hernandezke" as metadata author**: Same person previously identified in prior catalog entries as prolific metadata author across 225 documents / 101 cases. 10. **Typo in official court order**: "STAYED OMMITMENT" (missing 'C') in the February 1 order header suggests possible hasty preparation. 11. **Waiver signed under duress**: Guertin asserts the Waiver was signed to avoid detention because the exam report had been withheld, effectively coercing the 9-month extension without informed decision-making. 12. **Pattern of pre-business-hours filing**: Multiple filings and actions occurred at 7:29 AM, 8:26 AM, 8:27 AM, and 8:39 AM — before standard court operating hours. ### Cross-References - Filing #9* — Motion for Substitute Counsel (June 3, 2024) — same document reproduced in part within this exhibit - Filing #12* — RICO Complaint — references the same commitment conspiracy narrative - Filing #1* — Motion for Judicial Notice — original presentation of commitment timeline - Filing #2* — Affidavit of Fact (May 6, 2024) — Exh. D, Index 38 evidence referenced here - Filing #3* — Affidavit of Fact (April 9, 2024) — Exh. C, Index 30 evidence referenced here - "barbj" and "hernandezke" metadata author patterns documented in Filing #12 --- ## Filing #22 — Exhibit W: Estimated Value of Guertin's US 11,577,177 Over 20 Years (with Discovery Materials Analysis and Supporting Documentation) | Field | Detail | |---|---| | Filing # | 22 | | Date Filed | August 7, 2024 | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Exhibit (Exhibit W) — Multi-section evidentiary compilation with metadata analysis, patent valuation, communications, and biographical documentation | | Case/Court | 0:24-cv-02646-JRT-DLM / U.S. District Court, District of Minnesota (filed as Doc. 47) | | Pages | 167 | | Bates / Doc ID | 47__EXHIBIT-W__ESTIMATED-VALUE-OF-GUERTINS-US-11-577-177-OVER-20-YEARS.pdf | ### Comprehensive Summary Exhibit W is a 167-page multi-section evidentiary exhibit filed as Doc. 47 in Guertin's federal civil rights case on August 7, 2024. Despite its title focusing on patent valuation, the exhibit is organized into eight distinct indices covering a wide range of subjects, from forensic metadata analysis of discovery materials to communications with a self-described former CIA-affiliated individual to a detailed chronology of Guertin's professional accomplishments. **Index 01 (pp. 1–43): File, Directory, and Metadata Details of the July 16, 2024 Discovery Materials.** This section provides an exhaustive forensic analysis of the discovery materials that Bruce Rivers finally provided to Guertin via USB drive following the July 16, 2024 court appearance. Guertin presents a complete file tree showing 49 files in two directories, followed by ExifTool metadata output for every file on the drive. The key forensic finding is that many files show File Access Date/Time entries of July 14 and July 15, 2024 — just days before delivery — and the ISO file containing police photographs (Guertin - HCSO CLU - Photos #23-0098.iso) was created the morning of July 16, 2024 itself, mere hours before being handed to Guertin. This contradicts Rivers' claim that Guertin "already had" the materials. The section also notes that the "Rule 20 Evaluation Report.pdf" (the Milz report) has metadata showing: Author/Creator: "Hines, Anne"; Title: "Guertin, Matthew 20.01 1-11-24.pdf"; Producer: "Microsoft: Print To PDF"; and critically, it lacks the standard iText 7.1.16 e-file metadata present on all other court-processed documents, suggesting it may not have gone through the standard court filing system. Another notable metadata entry is for "Order-Other (3).pdf" which shows Author: "Danielle C. Mercurio"; Title: "Conservator (All Powers; Unlimited Duration)" — a title inconsistent with any document in Guertin's case. Multiple files show being created by various court personnel metadata authors including "Kuberski, Virginia" (for fee waiver orders), "Olson, Julie" (for appellate orders), and the recurring iText/Minnesota Judicial Branch processing signatures. Section C includes screen-capture images of the discovery folder structure. **Index 02 (pp. 1–5): Estimated Value of Guertin's US Patent 11,577,177 Over 20 Years.** This section presents a market-based economic valuation of Guertin's patent covering a motorized, rotatable treadmill designed to create the illusion of user movement while remaining stationary. The analysis identifies four market segments: VR/AR Gaming (projected $50 billion by 2030, 2% adoption = $1 billion/year), Film/Virtual Production ($10 billion by 2030, 1% adoption = $100 million/year), Military/Training Simulations ($20 billion by 2030, 5% adoption = $1 billion/year), and Metaverse ($800 billion by 2030, 1% adoption = $8 billion/year). The combined annual revenue estimate is $10.1 billion/year, yielding $202 billion over the 20-year patent life, with a "conservative ballpark figure" of $150 billion. This valuation is presented to establish the magnitude of what Guertin alleges has been stolen through patent fraud. **Index 03 (pp. 1–4): Bruce Rivers' Comment to Guertin About "Powerful People."** This section provides a comprehensive chronological documentation of the "powerful people keeping an eye on you" comment allegedly made by Bruce Rivers to Guertin over the phone on May 22, 2023 at 3:13 PM. Guertin supports the claim with personal call log records, T-Mobile billing records, text messages sent to friends beginning May 23, 2023, and multiple emails to his patent attorney (May 27, May 30, May 31, June 10, 2023) expressing fear for his safety. The section documents Guertin's escalating concerns, including statements such as "I'm afraid I'm going to be disappeared or killed" (May 30 email) and "I'm currently scared to leave my house" (May 31 email). It also notes that Rivers allegedly denied making the comment in person at his office weeks later. The section traces the "powerful people" thread through Guertin's June 16, 2023 email to Rivers, August 2023 LinkedIn search analysis, May 10, 2024 Court of Appeals petition (case A24-0780), and July 8, 2024 federal complaint. **Index 04 (pp. 1–11): Text Messages Between Guertin and His Self-Professed Former CIA Welder.** This section reproduces text message exchanges between Guertin and an unnamed individual identified as a welder who fabricated parts for Guertin's prototype, and who Guertin describes as self-professing CIA and military affiliations. The exchanges span December 5, 2022 through February 26, 2023 (with the welder's name redacted). The December 5, 2022 exchange is notable: the welder opens with "Have they got to you yet?" and Guertin provides an extended analysis of the patent situation vis-à-vis Netflix, demonstrating sophisticated strategic thinking about leverage, intellectual property, and business negotiation. The welder validates Guertin's analysis as "Pretty spot on." Guertin shares images of his prototype with LED light bars, discusses his programming work, patent law self-education, and MAXQDA data analysis. On January 14, 2023, Guertin sends a link to a compiled "Data_Analysis_Fraud.zip" file and asks the welder to share it with a "trusted contact at FBI," discussing allegations involving the Internet Archive, Assaff Rawner, and PhotoRobot in the Czech Republic. The welder sends a link to openai.com. Later exchanges reference Guertin's ongoing investigation activities. **Index 05 (pp. 1–11): Guertin's Repeated Attempts to Defend Himself Are Always Thwarted.** This section provides a chronological compilation of Guertin's efforts to actively participate in his defense, all of which he alleges were ignored or undermined by his counsel. Key items include: a January 30, 2023 email to Detective Samantha Johnson (Minnetonka PD) with Rivers CC'd discussing Personal Area Network intrusion, wire fraud conspiracy involving the Wayback Machine/Internet Archive/PhotoRobot/1WorldSync, and Guertin's collection of 780 archived web pages as evidence; a February 7, 2023 email to Rivers about the welder's CIA background and "special ops gear" photographed on Guertin's prototype; an April 26, 2023 email to Dr. Jill Rogstad (with Rivers CC'd) containing online publication credits proving Guertin's professional accomplishments (XiteLabs, PLSN Magazine, Derivative.ca, BlackTrax), directly rebutting Rogstad's characterization of his claims as "delusions"; a second April 26 email to Rogstad with certified mailer images proving patent dealings with Netflix; a January 10, 2024 email to Rivers describing Forcepoint/3Gimbals LinkedIn searches, Paul Debevec's SIGGRAPH 2023 presentation of the same technology on behalf of Netflix/Eyeline Studios, the Internal corruption at Hennepin County Courts regarding altered discovery with 24 missing photographs, and the demand for original discovery under Rule 9.01 subd. 1(6); an August 1, 2023 email to court-appointed attorney Michael Biglow with 16 attached documents including publication credits and a 2019 W-2 showing $218,385 gross income, of which only the April 7, 2023 letter from Dr. Martin Schuster was forwarded; and Dr. Schuster's letter itself, which states he has treated Guertin since September 15, 2016, diagnosed him with ADHD (Hyperactive and Inattentive), never observed psychosis, schizophrenia, or bipolar disorder, describes Guertin as "very decided, extremely focused, very hard worker," and attests to the "revolutionary" nature of his patented technology. **Index 06 (pp. 1–4): Guertin Sets Aside $5,000 for Digital Forensic Analysis of Drives and Data.** This section documents Guertin's attempts to have his computer hard drives professionally analyzed to prove his claims of being hacked. It includes: January 6, 2023 email from his patent attorney Amanda Prose recommending he file an FBI IC3 complaint; the January 12, 2023 Minnetonka Police Report #23-000151 filed with Officer Brandon Harris documenting Guertin's patent, the website manipulation claims, and Harris's advice to get a "computer forensicator"; a May 24, 2023 email from Prose confirming receipt of payment to be reserved for forensic analysis; subsequent email exchanges about engaging Mark Lanterman at Computer Forensics through Prose's firm, with discussions about preserving work product privilege. Guertin's patent attorney indicated the firm's board needed to review the engagement. **Index 07 (pp. 1–14+): Chronological Continuity of Competence, Understanding, and Rationality.** This extensive section presents a chronological record of Guertin's communications, filings, and activities that demonstrate sustained competence, rationality, and coherent legal reasoning throughout the period during which the court found him incompetent. It includes professional accomplishments from 2018–2023, detailed legal filings, and correspondence showing sophisticated understanding of legal procedures and intellectual property matters. **Index 08 (pp. 1–10): Guertin's Accomplishments Since Being Prescribed Adderall in 2016.** This section presents a comprehensive chronological portfolio of Guertin's professional work from 2018 through mid-2024, documented through website references (MattGuertin.com, XiteLabs.com), video links (Vimeo), and external press coverage. Key accomplishments include: programming a custom media server for the LA Philharmonic's 100th Anniversary Concert at the Hollywood Bowl (September 2018, featuring Katy Perry and John Williams); designing, engineering, and overseeing fabrication of Bad Bunny's mainstage set piece for Coachella 2019 (covered by ET Online, Buzzfeed, Billboard); designing and engineering a 50-foot wide falcon for the UNESCO World Heritage Site inauguration of Diriyah in Saudi Arabia, tracked via 53 infrared beacons and projection-mapped with 8×40k laser projectors; conducting 3D scanning projects using a Faro S-150 scanner (Nestle headquarters, Como Park, Grant Park/Lollapalooza, resulting in a RealityCapture "Scan of the Month Award"); designing and building the InfiniSet prototype (concept February 3, 2021, through working prototype by mid-2023); receiving US Patent 11,577,177 on February 14, 2023; producing professional investor promotional videos (mid-February 2024); and multiple Vimeo videos documenting engineering milestones with timestamps from 2022–2023 including servo motor calibration, multi-camera recording system, and Unreal Engine integration. Entries include direct links to web publications, portfolio pages, and video documentation, all presented as evidence contradicting the incompetency determination. ### Legal Issues & Arguments Raised - Discovery manipulation: Metadata evidence that discovery materials were accessed/modified July 14–16, 2024, contradicting Rivers' claim materials were previously provided - Chain of custody violations: ISO file for police photographs created morning of delivery, suggesting materials were assembled rather than simply provided - Authentication of evidence under Federal Rule of Evidence 901(b)(1): Discrepancies between metadata and claimed provenance - Ineffective assistance of counsel: Rivers' failure to present exculpatory evidence, failure to provide discovery, failure to present Guertin's defense materials - Fraudulent competency determination: Extensive evidence of rational, coherent behavior and professional accomplishment contradicting incompetency finding - Patent theft / intellectual property conspiracy: $150 billion estimated patent value establishing motive for conspiracy - Conflict of interest: "Powerful people" comment and Rivers' subsequent denial and non-cooperation - Brady violations: Withholding of exculpatory evidence by prosecution - Right to participate in one's own defense: Pattern of Guertin's defense efforts being ignored or suppressed ### Factual Allegations & Key Assertions - July 16, 2024: Rivers provided discovery materials via USB after telling Guertin he "already had" them - Multiple files show access dates of July 14–15, 2024; ISO file created morning of July 16, 2024 - Rule 20 Evaluation Report metadata shows Author "Hines, Anne" and lacks standard iText e-file metadata, suggesting non-standard filing path - "Order-Other (3).pdf" authored by Mercurio has Title "Conservator (All Powers; Unlimited Duration)" — unrelated to Guertin's case - Patent 11,577,177 covers a motorized rotatable treadmill for VR/film/military applications - Conservative patent value estimated at $150 billion over 20-year life - May 22, 2023 at 3:13 PM: Rivers told Guertin "powerful people keeping an eye on you" - Guertin expressed fear for his life in multiple emails following the comment - December 5, 2022: Unnamed "CIA welder" asked Guertin "Have they got to you yet?" - Guertin conducted sophisticated data analysis using MAXQDA software - Guertin provided extensive exculpatory evidence to Rivers, Biglow, and Rogstad, none of which was presented in court - Dr. Schuster (Guertin's psychiatrist since 2016) diagnosed ADHD only, no psychosis or schizophrenia - Guertin's 2019 W-2 income: $218,385 - Guertin's patent attorney retained payment for Computer Forensics digital analysis through Mark Lanterman - January 12, 2023: Minnetonka PD Report #23-000151 documents Guertin's claims about website fraud - Professional portfolio includes Hollywood Bowl, Coachella (Bad Bunny), Diriyah Saudi Arabia (UNESCO), 3D scanning awards, prototype engineering ### Procedural Posture Filed as Doc. 47 on August 7, 2024, approximately one month after the initial federal complaint (Doc. 1, July 8, 2024) and three weeks after Exhibit P (Doc. 23, July 16, 2024). This exhibit expands the evidentiary foundation for Guertin's federal claims by providing forensic metadata analysis of the discovery materials finally provided on July 16, establishing the economic magnitude of the patent at issue, and documenting the extensive pattern of Guertin's rational behavior and professional competence throughout the relevant period. ### Exhibit / Attachment Inventory The exhibit itself is organized into eight sub-indices: - Index 01 — File tree, metadata analysis of July 16, 2024 USB discovery materials (43 pages) - Index 02 — Patent valuation analysis (5 pages) - Index 03 — "Powerful people" comment chronology (4 pages) - Index 04 — Text messages with unnamed "CIA welder" (11 pages) - Index 05 — Defense participation efforts chronology (11 pages) - Index 06 — Digital forensic analysis efforts (4 pages) - Index 07 — Chronological continuity of competence (14+ pages) - Index 08 — Professional accomplishments timeline (10 pages) Cross-references within the exhibit to other exhibits: Exh. B (Index 28), Exh. C (Index 30), Exh. D (Index 38), Exh. F (Indices 01, 16, 26, 31), Exh. K (Index 36), Exh. N (Index 04), Exh. Q (federal complaint), Exh. S (Index 07, 09). ### Visual Evidence Inventory - **[Pages 3–44]** Approximately 43 pages of ExifTool metadata terminal output (text-based): Formatted as monospace terminal output showing complete metadata for all 49 files on the discovery USB. Not image-based but presented in a code-block visual format. - **[Page 45]** Screen-capture images of discovery materials folder structure: Described as showing the Windows Explorer directory listing of the USB contents. (Images embedded in PDF; specific details from the scanned visual context.) - **[Index 02]** Text-based economic analysis with bullet-point formatting: No charts or graphs; the valuation is presented entirely in narrative text with bulleted market segment breakdowns. - **[Index 03]** References to call log screenshots, T-Mobile billing records, and email screenshots from other exhibits (Exh. C, Index 30, pp. 84, 132–133; Exh. S, Index 09, pp. 2–4; Exh. D, Index 38, pp. 126–128) — these are referenced by citation rather than reproduced. - **[Index 04]** Transcribed text message exchanges: Content appears to be transcribed from screenshots rather than shown as images, with citation references to Exh. C, Index 30 specific page/screenshot numbers (welder-01 through welder-29). One reference to "(Image of prototype with LED light bars turned on)" and "(Image of prototype with LED light bars turned off)" indicating two photographs were shared in the text exchange. - **[Index 05]** Email content transcribed with extensive inline quotation: References screenshots and attached documents from Exh. D, Index 38 (pp. 94–120, 130–136) and Exh. C, Index 30 (pp. 26, 107–115). References to three attachments from the April 26 Rogstad email (special ops gear images, Facebook Messenger screenshot showing "it should revolutionize the industry" comment), certified mailer images, USPTO filing confirmation screenshot, and Guertin's 2019 W-2 transcript image. - **[Index 06]** Referenced Minnetonka Police Report excerpts and email content transcribed. - **[Index 07–08]** Professional accomplishments documented through URL references to MattGuertin.com, XiteLabs.com, Vimeo videos, and external press (ET Online, Buzzfeed, Billboard, PLSN Magazine, Derivative.ca, BlackTrax). Multiple Vimeo video links with specific timestamps for engineering milestones. ### Key People Referenced - **Matthew David Guertin*** — Plaintiff/Defendant/inventor - **Bruce Rivers*** — Defense counsel; alleged to have made "powerful people" comment and manipulated discovery provision - **Danielle C. Mercurio*** — Referee; metadata author of "Conservator (All Powers; Unlimited Duration)" document on discovery USB - **"Hines, Anne"*** — Metadata author of Rule 20 Evaluation Report - **"barbj"*** — Referenced in metadata context - **"hernandezke" / "HernandezKE"*** — Referenced in metadata context - **Kuberski, Virginia** — Metadata author of Order Denying Fee Waiver documents; Company: Minnesota Judicial Branch - **Olson, Julie** — Metadata author of Appellate Court Order documents - **Dr. Adam Milz*** — Author of the Rule 20 evaluation provided on the discovery USB - **Dr. Jill Rogstad*** — Rule 20.01 examiner; recipient of rebuttal evidence from Guertin - **Dr. Martin Schuster*** — Guertin's California psychiatrist since September 2016; wrote April 7, 2023 rebuttal letter - **Amanda Prose** — Guertin's patent attorney; handled forensic analysis payment - **Mark Lanterman** — Computer Forensics professional (discussed engagement) - **Michael Biglow*** — Court-appointed attorney who forwarded only one of 16+ documents - **Detective Samantha Johnson** — Minnetonka Police Department - **Officer Brandon Harris** — Minnetonka PD; took the January 12, 2023 report (#23-000151) - **Paul Debevec*** — Referenced as presenting Guertin's technology at SIGGRAPH 2023 for Netflix/Eyeline Studios - **Assaff Rawner** — CEO of UK company; alleged mastermind of fraud conspiracy - **Unnamed "CIA welder"** — Fabricated parts for prototype; self-professed CIA/military background - **Stephan Trojansky*** — Netflix patent applicant - **Joel Fisher*** — Referenced in context of discovery timeline ### Key Entities / Organizations Referenced - Netflix, Inc.* - Eyeline Studios - InfiniSet, Inc.* (Guertin's company) - XiteLabs* - U.S. Patent and Trademark Office (USPTO)* - Minnetonka Police Department* - Internet Archive / Wayback Machine* - PhotoRobot (Czech Republic)* - 1WorldSync - Computer Forensics (Mark Lanterman's firm) - T-Mobile (Guertin's carrier) - Forcepoint* - 3Gimbals* - DARPA* - Defense Intelligence Agency - USINDOPACOM - KBR Inc. - USC School of Cinematic Arts / USC ICT* - US Army / US Air Force* - Lockheed Martin - US Army Reserves - ACM-SIGGRAPH* - Faro (3D scanner manufacturer) - RealityCapture (software company) - MnCare/HealthPartners - Vail Place* - Hennepin County District Court* - Minnesota Court of Appeals* - FBI / IC3* - Secret Service - PLSN Magazine - LA Philharmonic Orchestra - Bad Bunny (artist — Coachella 2019) - UNESCO (Diriyah event) - Derivative (TouchDesigner software) - BlackTrax (tracking system) - Proton Mail ### Dates & Deadlines Mentioned - September 15, 2016 — Dr. Schuster first sees Guertin - September 30, 2018 — LA Philharmonic 100th Anniversary Concert - April 2019 — Bad Bunny Coachella mainstage - 2019 — Guertin's W-2 showing $218,385 income - February 3, 2021 — InfiniSet concept conceived - March 19, 2021 — Provisional patent filing - December 5, 2022 — Text exchange with "CIA welder" - January 6, 2023 — Patent attorney recommends FBI IC3 complaint - January 12, 2023 — Minnetonka PD Report #23-000151 filed - January 14, 2023 — Guertin sends Data_Analysis_Fraud.zip to welder - January 30, 2023 — Email to Detective Johnson - February 7, 2023 — Email to Rivers re: "special ops gear" - February 14, 2023 — US Patent 11,577,177 granted - March 10, 2023 — Rogstad Rule 20.01 report - April 7, 2023 — Dr. Schuster letter - April 26, 2023 — Emails to Dr. Rogstad with rebuttal evidence - May 22, 2023 at 3:13 PM — "Powerful people" comment by Rivers - May 24, 2023 — Patent attorney confirms forensic analysis payment - June 1, 2023 — Patent attorney discusses Computer Forensics engagement - August 1, 2023 — Emails to Biglow with 16 defense exhibits - January 3, 2024 — Dr. Milz evaluation of Guertin - January 10–12, 2024 — Emails to Rivers with new evidence (Debevec/SIGGRAPH, LinkedIn searches, altered discovery) - July 11, 2024 — File Modification dates on many discovery USB files - July 14–15, 2024 — File Access dates on discovery USB files - July 16, 2024 — ISO file creation date; discovery materials provided; 1:30 PM court appearance - August 7, 2024 — Filing date of this exhibit ### Forensic Flags & Anomalies 1. **Discovery USB metadata timestamps**: Extensive evidence that files were accessed/modified July 11–16, 2024, shortly before delivery to Guertin, contradicting Rivers' claim they had been previously provided. 2. **ISO file created morning of delivery**: The police photographs ISO was created the morning of July 16, 2024 — hours before being handed to Guertin at court. 3. **Rule 20 Evaluation Report lacks standard e-file metadata**: Unlike all other court-processed documents which show iText 7.1.16 processing signatures, the Milz report was produced via "Microsoft: Print To PDF" by "Hines, Anne" — suggesting it may not have been filed through the standard court e-filing system. 4. **Conservator order on discovery USB**: "Order-Other (3).pdf" authored by Mercurio has the internal title "Conservator (All Powers; Unlimited Duration)" — a document type unrelated to Guertin's criminal or commitment cases, raising questions about why it was on his discovery USB. 5. **File Access dates clustered around July 14–15**: A large number of files show access dates of July 15, 2024 specifically, suggesting systematic review/preparation of the materials shortly before delivery. 6. **Duplicate Appellate Court Orders**: Two copies of the same appellate order from July 2, 2024 appear on the USB with different file modification dates (July 11 vs. July 12), suggesting the USB contents were assembled over multiple days. 7. **Patent valuation methodology**: While presented as "conservative," the $150 billion figure relies on market size projections and adoption rate assumptions that are not independently validated. 8. **"CIA welder" claims**: The text messages reference an individual who self-professes CIA/military affiliations and whose first message to Guertin was "Have they got to you yet?" — suggesting pre-knowledge of events affecting Guertin. 9. **Systematic suppression of defense evidence**: Multiple instances documented where defense materials submitted by Guertin to Rivers, Biglow, and Rogstad were not presented, forwarded, or considered. ### Cross-References - Filing #21 (this batch) — Exhibit P: references the same January 2024 commitment conspiracy events and July 16, 2024 hearing - Filing #1* — Motion for Judicial Notice — original presentation of patent fraud narrative - Filing #2* — Affidavit of Fact (May 6, 2024) — Exh. D, Index 38 evidence - Filing #3* — Affidavit of Fact (April 9, 2024) — Exh. C, Index 30 evidence - Filing #6* — Netflix Whistleblower Part 1 — SIGGRAPH/Debevec evidence - Filing #9* — Motion for Substitute Counsel — same Strickland arguments - Filing #12* — RICO Complaint — incorporates patent valuation and conspiracy narrative - "Hines, Anne" metadata author pattern documented in Filing #12 - Minnetonka PD Report #23-000151 referenced in Filings #1, #3 - Dr. Schuster letter referenced in Filings #1, #3 --- ## Filing #23 — Original Federal Civil Rights Complaint (Digital Version / Exhibit Q) | Field | Detail | |---|---| | Filing # | 23 | | Date Filed | July 16, 2024 (digital version filed as Exhibit Q); original complaint dated July 8, 2024 | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Federal Civil Rights Complaint with Jury Demand (digital duplicate of original paper filing) | | Case/Court | Federal: 0:24-cv-02646-JRT-DLM / U.S. District Court, District of Minnesota (Doc. 24); references state criminal case 27-CR-23-1886 and civil commitment case 27-MH-PR-23-815 | | Pages | 110 | | Bates / Doc ID | 01__ORIGINAL-COMPLAINT__DIGITAL.pdf | ### Comprehensive Summary This is a 110-page federal civil rights complaint filed by Matthew David Guertin pro se, docketed as Document 24 in case 0:24-cv-02646-JRT-DLM. The document is identified on its face as "Exhibit Q" — a fully digital, hyperlinked, and bookmarked duplicate of the original paper complaint Guertin filed on July 8, 2024. The original had to be submitted in paper form to initiate the case and was scanned by the court, losing all hyperlinks and bookmarks. This digital version was filed on July 16, 2024 to restore navigability. The complaint names eleven defendants: Hennepin County (as a municipal entity), Keith Ellison (MN Attorney General, official capacity for injunctive relief under Ex parte Young), Mary Moriarty (Hennepin County Attorney, official capacity), Chela Guzman-Weigart (Assistant County Administrator, official capacity), Julia Dayton-Klein (Judge, individual capacity), George F. Borer (Judicial Referee, individual capacity), Danielle C. Mercurio (Judicial Referee, individual capacity), Dr. Jill Rogstad (Senior Clinical Forensic Psychologist, official capacity), Dr. Adam Milz (Hennepin County Mental Health, official capacity), Jacqueline Perez (Assistant County Attorney, official capacity), and Bruce M. Rivers (defense counsel, individual capacity). **Core Narrative (Sections I–V):** Guertin alleges that his invention of VR treadmill technology (US Patent 11,577,177, filed March 18, 2022, granted February 14, 2023) placed him in the crosshairs of powerful military, corporate, and governmental interests. He contends that Stephan Trojansky filed a patent application for essentially identical technology just 12 days after Guertin's own filing, and that Netflix acquired the Trojansky technology (through its purchase of ScanlineVFX/Eyeline Studios) for approximately $100 million. Guertin's name and patent appear at the top of the resulting Netflix patent (US 11,810,254, published November 7, 2023) because Guertin filed a third-party prior art submission with the USPTO on February 17, 2023. Guertin describes events leading to his January 21, 2023 arrest: he had been collecting digital forensic evidence of patent theft and surveillance since December 2022, including evidence of his computers being covertly accessed, phone calls being rerouted, and involvement of entities like Forcepoint, 3Gimbals, and FOX, who searched his LinkedIn profile on the same day he was charged. He states he fired a gun into the air to summon police because he feared for his life and did not trust his phone calls were reaching actual police. He had no prior violent criminal history. The complaint details an extensive chronological timeline (Section V, paragraphs 84–457) spanning from April 2, 2014 through mid-2024, documenting Guertin's professional career in interactive media and entertainment (Hollywood Bowl for LA Philharmonic, Bad Bunny at Coachella, 50-foot falcon for Saudi Arabia's Diriyah inauguration), the genesis and development of his InfiniSet patent, the discovery of the parallel Netflix patent, his arrest, the criminal proceedings in Hennepin County, two Rule 20.01 competency evaluations (Rogstad on March 10, 2023, and Milz on January 3, 2024), civil commitment proceedings, the alleged manipulation of discovery materials, and extensive LinkedIn search evidence purportedly showing surveillance by military/intelligence entities (DARPA, DIA, US Indo-Pacific Command, Air Force, State Department, Lockheed Martin, Morgan Stanley, Moody's Analytics, etc.). **MCRO Fraud Allegations (Section VI):** Guertin describes a data analysis he conducted of Minnesota Court Records Online, downloading 3,556 case files across 163 unique case IDs. He identified irregularities including defendants with similar/varied names, a disproportionate number of competency evaluations, repeated judicial assignments among three officers (Klein, Mercurio, Borer), and records he believes may be fraudulently produced. **Heck v. Humphrey Preemption (Section VII):** Guertin preemptively addresses potential Heck v. Humphrey barriers, arguing that: he has not been convicted or sentenced; his civil commitment order is stayed; his claims concern procedural due process violations (not conviction validity); and the case is distinguishable under Wilkinson v. Dotson and Preiser v. Rodriguez. ### Fifteen Counts (Section VIII): 1. Count I: Procedural Due Process violation (42 U.S.C. § 1983) 2. Count II: Fraud & Forgery (18 U.S.C. §§ 1341, 1343; Minn. Stat. § 609.63) 3. Count III: Ineffective Assistance of Counsel (Sixth Amendment) 4. Count IV: Equal Protection violation (42 U.S.C. § 1983) 5. Count V: Denial of Right of Access to Courts (42 U.S.C. § 1983) 6. Count VI: Civil Conspiracy (42 U.S.C. § 1985) 7. Count VII: Gross Negligence (Minn. Stat. § 604.03) 8. Count VIII: Judicial Misconduct (42 U.S.C. § 1983) 9. Count IX: Monell Claim (42 U.S.C. § 1983) 10. Count X: Negligent Infliction of Emotional Distress (Minn. Stat. § 604.03) 11. Count XI: Retaliation (42 U.S.C. § 1983) 12. Count XII: Federal Wire Fraud (18 U.S.C. § 1343) 13. Count XIII: Fraud on the Court (42 U.S.C. § 1983) 14. Count XIV: Misconduct of Public Officer/Employee (Minn. Stat. § 609.43) 15. Count XV: Recording/Filing of Forged Instrument (Minn. Stat. § 609.64) **Key Specific Allegations per Count:** Count II targets Guzman-Weigart as the true author ("GuzmanC") of Dr. Rogstad's Rule 20.01 evaluation and alleges the resulting report is a forged document. Count III details Rivers' failures including withholding discovery, not presenting exculpatory evidence at the July 7, 2023 hearing, and the "powerful people" comment. Count V addresses denial of access to the Milz Rule 20.01 exam report. Count VIII targets Klein for issuing rulings on motions not directed at her court and referencing non-existent affidavits. Count XV alleges that Borer's competency order was actually authored by Mercurio based on metadata analysis. **Prayer for Relief (Section IX):** Guertin seeks: (A) emergency TRO/preliminary injunction halting state proceedings and postponing July 16, 2024 review hearing; (B) declaratory judgment of constitutional violations; (C) permanent injunction against surveillance, record manipulation, and retaliation; (D) mandated policy changes at Hennepin County; (E) $5M+ compensatory damages for emotional distress; (F) $10M+ compensatory damages for financial/career losses as CEO of InfiniSet, Inc.; (G) punitive damages per Smith v. Wade; (H) attorney fees under 42 U.S.C. § 1988; (I) pre/post-judgment interest; (J) further equitable relief. Jury demand under FRCP Rule 38. ### Legal Issues & Arguments Raised - 42 U.S.C. § 1983 — Due process (14th Amendment), access to courts (1st Amendment), right to counsel (6th Amendment), cruel and unusual punishment (8th Amendment), retaliation, judicial misconduct, fraud on the court - 42 U.S.C. § 1985 — Civil conspiracy to deprive equal protection - 18 U.S.C. § 1341 — Mail fraud - 18 U.S.C. § 1343 — Wire fraud - Minn. Stat. § 609.63 — Forgery - Minn. Stat. § 609.64 — Recording/filing of forged instrument - Minn. Stat. § 609.43 — Misconduct of public officer or employee - Minn. Stat. § 604.03 — Gross negligence; negligent infliction of emotional distress - Monell v. Department of Social Services, 436 U.S. 658 (1978) — Municipal liability - Strickland v. Washington, 466 U.S. 668 (1984) — Ineffective assistance standard - Heck v. Humphrey, 512 U.S. 477 (1994) — Preemptive rebuttal of favorable-termination bar - Wilkinson v. Dotson, 544 U.S. 74 (2005) — Procedural claims not barred by Heck - Preiser v. Rodriguez, 411 U.S. 475 (1973) — § 1983 vs. habeas distinction - Ex parte Young — Basis for suing AG Ellison for injunctive relief - Smith v. Wade, 461 U.S. 30 (1983) — Punitive damages standard - Sherman Antitrust Act, 15 U.S.C. § 1 — Referenced re: corporate/government entanglement - Thomas M. Cooley, A Treatise on the Law of Torts (1879) — Malicious prosecution for incompetency proceedings - Lockenour v. Sides, 57 Ind. 360 (1877) — Liability for false competency proceedings ### Factual Allegations & Key Assertions - Guertin conceived InfiniSet VR treadmill concept on February 3, 2021; filed provisional patent March 19, 2021; filed patent application 17/698,420 on March 18, 2022; granted US Patent 11,577,177 on February 14, 2023 - Stephan Trojansky filed a provisional patent for the same technology on March 31, 2021 — 12 days after Guertin's provisional filing - Netflix acquired ScanlineVFX and Eyeline Studios (announced November 22, 2021) for approximately $100M, which included the Trojansky technology - Netflix patent US 11,810,254 published November 7, 2023, lists Guertin's patent at the top due to his third-party prior art submission of February 17, 2023 - ChatGPT analysis of both patents concluded they describe essentially the same technology - Guertin's LinkedIn profile was searched by US Air Force Academy (November 28, 2021), US Air Force (January 16, 2022), Forcepoint, 3Gimbals, and FOX (coinciding with January 21, 2023 arrest date), DARPA, DIA, US Indo-Pacific Command, State Department, Lockheed Martin, Morgan Stanley, and Moody's Analytics (during commitment proceedings period) - On January 21, 2023, Guertin fired a gun into the air to summon police, fearing for his safety; charged with multiple felonies - Guertin had no prior violent criminal history — only two petty misdemeanor parking tickets - Bruce Rivers told Guertin on May 22, 2023 at 3:13 PM: "You have some very powerful people keeping an eye on you" — then denied making the statement - Rivers failed to provide discovery materials and the Milz Rule 20.01 exam report - Rivers failed to present exculpatory evidence at the July 7, 2023 hearing - Rogstad Rule 20.01 evaluation (March 10, 2023) was authored by "GuzmanC" per metadata analysis - Milz Rule 20.01 evaluation (January 3, 2024) found Guertin incompetent; report never provided to Guertin - Judge Klein issued rulings on motions not directed at her court, referenced non-existent affidavits - Borer's competency order was authored by Mercurio per metadata analysis - April 12, 2024 "Mother's Letter" incident: Guertin's mother wrote to Judge Quam; response came from Klein's clerk (Cuellar) at 4:42 PM, after Klein had already denied Guertin's pro se petition at 2:28 PM - Judge Quam has been assigned judge throughout but never involved in any decision - Discovery photographs provided to Rogstad were fraudulent/manipulated - Google named its Bard AI dataset "Infiniset" (matching Guertin's trademark) on January 20, 2022 - Guertin downloaded 3,556 MCRO case files across 163 case IDs; identified pattern of Klein/Mercurio/Borer "circular handling" - YouTube/Google directly involved in patent theft conspiracy per Guertin's analysis - Guertin's professional background includes work for LA Philharmonic 100th Anniversary at Hollywood Bowl, Bad Bunny at Coachella, Saudi Arabia Diriyah inauguration, and other high-profile entertainment productions - InfiniSet, Inc. registered with Delaware and Minnesota Secretaries of State - WIPO Trademark Certificate #1,739,675 for InfiniSet obtained June 1, 2023 ### Procedural Posture This is the original complaint initiating the federal civil rights action, filed July 8, 2024 in paper form and docketed as the initial filing. The digital version (this document) was filed as "Exhibit Q" on July 16, 2024 as Doc. 24 to preserve hyperlinks and bookmarks. The complaint was filed while Guertin's state criminal case (27-CR-23-1886) remained pending, with no conviction entered. His civil commitment (27-MH-PR-23-815) was under a stayed order. The complaint sought an emergency TRO ahead of a July 16, 2024 review hearing in state court. This is the predecessor to the more expansive RICO complaint filed as Filing #12 (Doc. 116) on June 25, 2025. ### Exhibit / Attachment Inventory The complaint itself contains no attached exhibits within the PDF, but extensively references exhibits filed separately in the federal case: - Exh. A (Index 00, 01, 16, 19, 22, 27, 29, 31, 33, 34, 36, 37, 90–92) — Criminal case docket materials - Exh. B (Index 28) — Motion for Judicial Notice (271 pages, 78 exhibits) - Exh. C (Index 30) — Affidavit of Fact (April 9, 2024, 213 pages) - Exh. D (Index 38) — Additional evidence and correspondence - Exh. E (Index 39) — Prototype development materials - Exh. F (Index 00, 01, 18, 20, 21, 24, 25, 27, 33) — Civil commitment case materials - Exh. G (Index 04, 05) — Additional evidence - Exh. K (Index 22, 36–37, 43) — Stayed commitment order materials - Exh. M (Index 03) — MOVA Contour facial capture technology materials - Exh. N (Index 01, 02, 05) — LinkedIn search evidence - References Rearden LLC v. Walt Disney Co., 3:17-cv-04006 (N.D. Cal.) — MOVA IP theft case - Numerous MattGuertin.Substack.com and Matt1Up.Substack.com article URLs - Guertin's personal portfolio website MattGuertin.com - LinkedIn profile: linkedin.com/comm/in/mattguertin612 - YouTube channel: YouTube.com/@CLRBruceRivers (Bruce Rivers) - MCRO case files share link at Proton Drive - Vimeo.com/MattGuertin ### Visual Evidence Inventory - [Page 1] Court filing header: "CASE 0:24-cv-02646-JRT-DLM Doc. 24 Filed 07/16/24 Page 1 of 110" — standard federal court electronic filing stamp. Below it, "Exhibit Q" label in standalone text. No anomalies in header formatting. - [Page 2] Introductory note explaining this is a digital duplicate of the paper-filed original complaint; includes footnote "Make use of the bookmarks for easy navigation of this exhibit." Red footer text: "Exhibit Q | Complaint | p. [N]" appears on all content pages — this footer is Guertin's own pagination, not the court's. - [Pages 3–110] Standard text-based federal complaint format with numbered paragraphs. No embedded photographs, screenshots, or diagrams within the PDF text. Document is natively digital (not scanned). Extensive footnotes throughout with hyperlinks to external sources (Substack, Rumble, Vimeo, LinkedIn, patent databases, court filings, etc.). - [Page 109] Electronic signature block: "/s/ Matthew D. Guertin" with address at 1075 Traditions Ct., Chaska, MN 55318, phone 763-221-4540, email MattGuertin@protonmail.com, website www.MattGuertin.com. - [Page 110] Verification under penalty of perjury with identical signature block. - **PDF Metadata Note:** Producer field shows "PyPDF2; modified using iText® 7.1.6 ©2000-2019 iText Group NV (Administrative Office of the United States Courts; licensed version)." ModDate is July 16, 2024 08:50:15 UTC. PDF version 1.3. The document generated 200+ "Bad annotation destination" warnings during text extraction, suggesting hyperlink targets that could not be resolved — consistent with bookmarks referencing external exhibits not contained within this PDF. No custom metadata. Not tagged or optimized. ### Key People Referenced - **Matthew David Guertin*** — Plaintiff, Pro Se; inventor of US Patent 11,577,177; CEO of InfiniSet, Inc. - **Keith Ellison*** — Minnesota Attorney General (defendant, official capacity for injunctive relief) - **Mary Moriarty*** — Hennepin County Attorney (defendant, official capacity) - **Chela Guzman-Weigart*** — Asst. County Administrator for Law, Safety, and Justice; metadata author "GuzmanC" (defendant, official capacity) - **Julia Dayton-Klein*** — Judge, 4th Judicial District (defendant, individual capacity) - **George F. Borer*** — Judicial Referee, 4th Judicial District (defendant, individual capacity) - **Danielle C. Mercurio*** — Judicial Referee, 4th Judicial District (defendant, individual capacity) - **Dr. Jill Rogstad*** — Senior Clinical Forensic Psychologist (defendant, official capacity) - **Dr. Adam Milz*** — Hennepin County Mental Health (defendant, official capacity) - **Jacqueline Perez*** — Asst. Hennepin County Attorney (defendant, official capacity) - **Bruce M. Rivers*** — Defense counsel (defendant, individual capacity); YouTube channel @CLRBruceRivers - **Jay Quam** — Judge assigned to criminal case but never involved in any decisions - **Lee Cuellar*** — Judicial Clerk to Judge Klein - **Michael Biglow*** — Referenced as source of discovery materials - **Michael Robertson** — Examiner, referenced re: image count discrepancies in evaluation - **Stephan Trojansky** — Named as inventor on the Netflix patent application filed 12 days after Guertin's - **Paul Debevec** — Accused of fraudulent attribution of MOVA Contour facial capture technology - **Steve Perlman** — Identified as true inventor of MOVA Contour technology - **Katy Perry** — Performer at Hollywood Bowl event Guertin worked on - **John Williams** — Conductor at Hollywood Bowl event - **Bad Bunny** — Artist whose Coachella stage Guertin designed/fabricated - **King Salman bin Abdulaziz** — Attended Diriyah inauguration where Guertin's falcon was featured - **Prince Mohammed bin Salman** — Attended same event ### Key Entities / Organizations Referenced - Hennepin County (defendant entity) - Fourth Judicial District Court, Hennepin County - Minnesota Court of Appeals (case A24-0780) - U.S. District Court, District of Minnesota - InfiniSet, Inc. (Guertin's Delaware corporation) - Netflix, Inc. / ScanlineVFX / Eyeline Studios - USPTO (United States Patent and Trademark Office) - WIPO (World Intellectual Property Organization) - Google / Alphabet / YouTube - Forcepoint - 3Gimbals - FOX / FOX Entertainment / FOX Corporation - DARPA - Defense Intelligence Agency (DIA) - US Indo-Pacific Command - US Air Force / US Air Force Academy - US State Department - Lockheed Martin - Morgan Stanley - Moody's Analytics - Minnetonka Police Department - Plymouth Police Department - FBI / FBI IC3 - FTC - US Secret Service - Derivative (TouchDesigner blog) - Xite Labs (entertainment production company) - Digital Domain - Rearden LLC (plaintiff in 3:17-cv-04006) - Walt Disney Company / Mandeville Films / Marvel Studios (defendants in 3:17-cv-04006) - USC (University of Southern California) - Delaware Secretary of State / Minnesota Secretary of State - Hennepin County Attorney's Office - Minnesota Department of Health ### Dates & Deadlines Mentioned - February 3, 2021 — Guertin conceives InfiniSet idea - March 19, 2021 — Provisional patent filed - March 31, 2021 — Trojansky provisional patent filed (12 days later) - March 18, 2022 — Guertin files patent application 17/698,420 - January 20, 2022 — Google names Bard AI dataset "Infiniset" - January 21, 2023 — Guertin arrested (gun-firing incident) - February 14, 2023 — US Patent 11,577,177 granted to Guertin - February 17, 2023 — Third-party prior art submission filed against Netflix application - March 10, 2023 — Rogstad Rule 20.01 evaluation - May 22, 2023 — Rivers "powerful people" phone call at 3:13 PM - June 16, 2023 — Email to Rivers re: YouTube/Google conflict of interest - July 7, 2023 — Court hearing where exculpatory evidence allegedly not presented - July 17, 2017 — Rearden v. Disney (3:17-cv-04006) filed - November 7, 2023 — Netflix patent US 11,810,254 published - January 3, 2024 — Milz Rule 20.01 evaluation (Zoom meeting) - April 3, 2024 — Pro se petition to proceed as own counsel; email to Rivers re: dismissal - April 3, 2024 — Motion for Judicial Notice filed (78 exhibits, 271 pages) - April 4, 2024 — Motion to Compel Discovery filed (40 pages) - April 9, 2024 — Affidavit of Fact filed (213 pages) - April 12, 2024 — "Mother's Letter" incident (letters at 2:10 PM, Klein order at 2:28 PM, response at 4:42 PM) - May 3, 2024 — MCRO analysis affidavit filed (3,556 case files analyzed) - July 8, 2024 — Original paper complaint filed - July 16, 2024 — Digital version (this document) filed as Exhibit Q / Doc. 24; review hearing scheduled same day ### Forensic Flags & Anomalies - **PDF Metadata:** Producer is "PyPDF2; modified using iText® 7.1.6" from the Administrative Office of the US Courts — this is the standard federal court CM/ECF processing toolchain, not anomalous for a federal filing. However, the 200+ "Bad annotation destination" warnings suggest the document's internal bookmarks may have been partially corrupted during CM/ECF processing, which is consistent with Guertin's explanation that the original was paper-filed and this digital version was subsequently uploaded. - **Dual Dating:** The complaint body is dated July 8, 2024, but the CM/ECF filing stamp shows July 16, 2024 — consistent with the stated purpose of filing a digital duplicate after the paper original was already docketed. - **Exhibit Q Designation:** The document labels itself "Exhibit Q" — meaning it was filed as an exhibit to something else (likely a motion or other filing), not as the original complaint docket entry. This is a supplementary filing providing a navigable version. - **Defendant Overlap with Filing #12:** This complaint names 11 defendants; the later RICO complaint (Filing #12, Doc. 116, June 25, 2025) expanded to 30+ named defendants plus 100 Does. All 11 original defendants carry over, suggesting this filing is the foundation for the expanded action. - **Address Change:** Guertin's address here is 1075 Traditions Ct., Chaska, MN 55318. In Filing #12, his address is listed as 4385 Trenton Ln. N 202, Plymouth, MN 55442 — indicating a move between July 2024 and June 2025. - **Judge Quam Anomaly:** Guertin notes that Judge Jay Quam has been the assigned judge throughout the criminal case but has never been involved in any decision. All substantive decisions were made by Klein, Mercurio, and Borer. This is a recurring theme across multiple filings. - **Claim for Wire Fraud (18 U.S.C. § 1343) as Private Plaintiff:** The complaint includes a count for federal wire fraud, which is typically a criminal statute without a private right of action. This may represent a legal error or an attempt to invoke supplemental jurisdiction on the theory that the fraud constitutes the underlying conduct for the § 1983 claims. - **MCRO Analysis Foundation:** The 3,556 downloaded case files referenced here (from the May 3, 2024 affidavit) form the precursor dataset to the expanded 3,601-file analysis described in Filing #12's RICO complaint. The scope grew from 163 case IDs to the same 163, but with additional analytical layers (SHA-256 signatures, metadata authors, cloned orders). ### Cross-References - Filing #1* — Motion for Judicial Notice (271 pp.) — referenced as Exh. B, Index 28 - Filing #2* — Affidavit of Fact (May 6, 2024, 148 pp.) — referenced as Exh. D, Index 38 - Filing #3* — Affidavit of Fact (April 9, 2024, 213 pp.) — referenced as Exh. C, Index 30 - Filing #9* — Motion for Substitute Counsel — related to ineffective assistance claims against Rivers - Filing #12* — RICO Complaint (Doc. 116) — supersedes/expands this complaint - Filing #24 (this batch) — Exhibit AB, which contains video evidence of the January 3, 2024 Milz Rule 20.01 exam referenced extensively in this complaint - MN Court of Appeals case A24-0780 — Petition for Discretionary Review (denied) - Rearden LLC v. Walt Disney Co., 3:17-cv-04006 (N.D. Cal.) — MOVA technology theft case - State criminal case 27-CR-23-1886 - Civil commitment case 27-MH-PR-23-815 --- ## Filing #24 — Exhibit AB: Video Evidence of Guertin's January 3, 2024 Rule 20.01 Exam (Zoom Meeting with Dr. Adam Milz) | Field | Detail | |---|---| | Filing # | 24 | | Date Filed | September 26, 2024 | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Exhibit (video evidence compilation with screenshots, AI analysis, and excerpts from Rule 20.01 exam report) | | Case/Court | Federal: 0:24-cv-02646-JRT-DLM / U.S. District Court, District of Minnesota (Doc. 78) | | Pages | 15 | | Bates / Doc ID | 78__EXHIBIT-AB__VIDEO-Guertins-Jan-3-2024-Rule-20-01-Exam-Report.pdf | ### Comprehensive Summary This is a 15-page exhibit filed as Document 78 in the federal case, designated "Exhibit AB." It is organized into three indexed sections and serves as a visual evidence package challenging the validity and accuracy of Dr. Adam Milz's January 3, 2024 Rule 20.01 competency examination of Guertin. The exhibit is structured around video recordings Guertin made of the Zoom meeting, supplemented by AI-assisted image analysis and excerpts from the resulting exam report. **Page 1 (Cover):** Identifies the document as "Exhibit AB" filed in case 0:24-cv-02646-JRT-DLM, Doc. 78, on September 26, 2024. **Page 2 (Introduction):** Guertin provides an introductory statement asserting that the Rule 20.01 exam meeting lasted approximately two hours and was conducted over Zoom. He claims the resulting exam report contains false statements and fabricated narratives. He specifically challenges Milz's statement that Guertin has "a history of threatening to harm himself, which elevates his long-term risk of similar behavior," asserting categorically that he has zero history of self-harm, has never been suicidal, has never thought about suicide, and has never attempted suicide. He describes the report as containing "blatant lies." The introduction identifies Milz's credentials (PhD, LP, ABPP; Supervising Forensic Psychologist; Fourth Judicial District Psychological Services; Board Certified in Forensic Psychology; American Board of Professional Psychology). A table of contents lists three indexes plus a note to use bookmarks for navigation. **Index 01 (Pages 3–7): Full Zoom Meeting Video — 5 pages of screenshots.** This section provides viewing, download, and hosting links for the full recording of the January 3, 2024 Zoom meeting, along with 15 screenshots taken at various points during the session. The screenshots show the "Zoom for Government" interface in gallery view with two participants: "Dr. Adam Milz" (left panel, wearing headphones, seated in a beige/tan room) and "matt1up" (right panel — Guertin, wearing headphones and a backwards cap, seated in front of a green screen with visible microphone equipment). The video timestamp visible on page 3 shows "1:15:50 / 1:59:32" — confirming approximately a 2-hour meeting. A bottom toolbar shows standard Zoom controls (Mute, Stop Video, Participants, Chat, Share Screen, Record, Reactions, Whiteboard, Leave). The screenshots capture a range of expressions and moments from both participants throughout the meeting. **Index 02 (Pages 8–12): "Adam Milz Incoming Text Edition" — 5 pages focusing on Milz's distraction.** This section provides a separate video cut/edit with different viewing and download links, focusing specifically on Dr. Milz's behavior during the examination. It includes an AI chatbot conversation (appears to be ChatGPT based on visible interface elements) in which Guertin submitted sequential still frames of Milz and asked the AI to analyze what the examiner appeared to be doing. The AI analysis concluded that Milz appeared to be "preoccupied with something other than the person he is supposed to be assessing," showing "distraction, contemplation, and perhaps surprise or confusion," and was likely "focusing on some form of text that is off to the side, potentially on another screen or a printed document." Guertin provided additional context that this behavior persisted for approximately 20–25 minutes total during the meeting. The AI responded that this sustained side-reading behavior during a mental health assessment "would raise concerns about his attentiveness to the patient" and "could impact the quality and accuracy of the assessment." Pages 10–12 contain extensive grids of sequential still frames of Dr. Milz — approximately 40 per page in a 4-column grid on pages 11–12 — showing his face from slightly different angles and moments, with his gaze frequently directed off-screen to the side rather than at the camera/Guertin. These frames appear designed to document the sustained pattern of side-looking behavior. **Index 03 (Pages 13–15): Excerpts from Dr. Milz's Rule 20.01 Exam Report — 3 pages.** This section reproduces excerpted pages from the actual Rule 20.01 exam report that Milz produced. The excerpts are presented as images/scans of the original report pages, with certain passages highlighted in yellow, blue, green, and red to draw attention to specific claims. The report header shows it was filed as Doc. 43 in the federal case on August 7, 2024, at pages 130–132 of 196. The filing stamp shows "27-CR-23-1886" (the criminal case number) with "Filed in District Court State of Minnesota 1/11/2024 2:05 PM." A cross-reference footer on page 13 reads "Exhibit S | Index 10 | p. 4" suggesting this excerpt was also used in another exhibit. Key content from the Milz report excerpts: *Diagnostic Formulation:* Milz diagnosed "unspecified schizophrenia spectrum and other psychotic disorder" per DSM-5-TR. He reported that Guertin has "a history of psychosis characterized by prominent delusional thinking as well as impaired thought processes." Highlighted passages indicate Milz found it unclear whether Guertin was receiving treatment to address psychotic symptoms. Milz stated Guertin "demonstrated these symptoms during the current interview, which compromised his abilities to rationally engage in the evaluation and effectively communicate." He also noted a history of symptoms consistent with mania and a history of consuming illicit and mood-altering substances. *Competency Assessment:* Milz assessed multiple domains including understanding of charges/penalties, factual and rational understanding of legal proceedings, ability to apply legal understanding to his own case, motivation, and ability to consult with counsel. Milz reported Guertin's competency-related knowledge was "compromised by his delusional beliefs and impaired thought processes." He noted Guertin identified his attorney as "Bruce Rivers" but also stated he was representing himself because Rivers is a "big YouTube star" presenting a conflict of interest. Milz noted Guertin "cryptically confirmed" that Rivers told him his phone calls were being monitored during a prior consultation. Milz characterized Guertin's statements about being hacked, stalked via AI and Bluetooth, monitored by ex-military/ex-CIA personnel, being surveilled by companies, and possessing proof that Netflix committed fraud as evidence of "delusional thinking" and strategies "based on his delusional thinking." *Summary and Opinion:* Milz concluded Guertin remains incompetent due to "delusional thinking (including paranoid beliefs about the evidence in this matter case and potential outcomes of his case)" and impaired thought processes. He opined that Guertin lacks the ability to rationally consult with counsel, understand proceedings, or participate in his defense, and that accommodations could not be reasonably implemented. *Prognosis:* Described as "poor" for psychotic symptoms remitting on their own. Milz recommended treatment adjustments and psychiatric stabilization, projecting recovery of competency-related abilities within approximately six months with appropriate treatment. *Imminent Risk/Emergency Intervention:* Contains the statement Guertin challenges — that Guertin "has a history of threatening to harm himself, which elevates his long-term risk of similar behavior." However, the same section states: "No recent indication of self-harm was noted and he reported no specific thoughts, plans, or intent to harm himself or commit suicide during the current interview." Milz concluded Guertin does not present imminent risk and does not require emergency intervention. *Additional Considerations:* Notes Guertin was under a stayed order of civil commitment as MI (mental illness) until February 10, 2024. Milz opined Guertin "requires psychiatric treatment in order to stabilize his mental status" but does not need immediate hospitalization. *Signature:* Handwritten signature reading "PhD, LP, ABPP" with typed signature block for Adam A. Milz, PhD, LP, ABPP, Supervising Forensic Psychologist, Fourth Judicial District Psychological Services. ### Legal Issues & Arguments Raised - Competency to stand trial under Minnesota Rule 20.01, Subd. 2 - Accuracy and integrity of court-ordered forensic psychological evaluations - Right to a fair and attentive competency examination - Whether Milz's inattention during the Zoom exam undermines the reliability of his findings - Whether the claim of "history of threatening to harm himself" is fabricated or unsupported - Whether Guertin's factual claims about patent theft, surveillance, and court fraud constitute "delusions" or evidence-based assertions - Due process implications of being declared incompetent based on a flawed evaluation process - Professional conduct of forensic examiners ### Factual Allegations & Key Assertions - The January 3, 2024 Rule 20.01 exam was conducted over Zoom and lasted approximately 2 hours (video shows 1:59:32 total runtime) - The platform used was "Zoom for Government" (visible in interface header) - Guertin recorded the entire session and has made it publicly available on multiple platforms - Dr. Milz spent an estimated 20–25 minutes during the exam looking to the side, apparently reading text on another screen or document rather than attending to Guertin - AI analysis of sequential still frames confirms Milz appeared distracted and preoccupied during the assessment - The Milz report states Guertin has "a history of threatening to harm himself" — Guertin categorically denies this, stating he has zero history of self-harm, has never been suicidal, and has never contemplated suicide - Milz diagnosed "unspecified schizophrenia spectrum and other psychotic disorder" - Milz characterized Guertin's claims about hacking, surveillance, Netflix fraud, ex-CIA welder, AI monitoring, and Bluetooth tracking as evidence of "delusional thinking" and "paranoid beliefs" - Milz found Guertin incompetent to stand trial, lacking ability to rationally consult with counsel or participate in defense - Milz acknowledged Guertin correctly identified his charges and maximum sentences - Milz noted Guertin identified his attorney as Bruce Rivers but said he was representing himself due to Rivers' YouTube conflict of interest - The report was officially filed in district court on January 11, 2024 at 2:05 PM - The report excerpts also appear in "Exhibit S | Index 10" — indicating they were cross-filed in another exhibit within the federal case ### Procedural Posture Filed September 26, 2024 as Doc. 78 in the federal civil rights case. This exhibit post-dates the original complaint (Doc. 24, July 16, 2024) and represents supplemental evidence supporting the claims against Dr. Milz. The Rule 20.01 exam took place on January 3, 2024; the resulting report was filed January 11, 2024. Guertin's inability to obtain this report was a central grievance in the original complaint. By the time of this exhibit filing, Guertin had apparently obtained the report (possibly through the federal case proceedings or Doc. 43 filing on August 7, 2024). The exhibit is part of the ongoing federal case in which Guertin was building his evidentiary record. ### Exhibit / Attachment Inventory The document itself is a compilation exhibit containing three indexed sections: - **Index 01:** Full Zoom meeting video — provided via external links (Rumble, Odysee, Storj, Proton Drive, Substack) - **Index 02:** "Adam Milz Incoming Text Edition" video — separate edit focusing on Milz's distraction behavior, with external links (Rumble, Odysee, Storj, Proton Drive, Substack) - **Index 03:** Excerpted pages from the Milz Rule 20.01 exam report (pages 130–132 of Doc. 43 in the federal case) - Cross-reference to Exhibit S, Index 10 (pages 4–6) — same report excerpts appear in another exhibit External video hosting links provided: - Rumble: rumble.com/v5g369h (full meeting); rumble.com/v5g37e5 (incoming text edition) - Odysee: ody.sh/QSmwuASLVs; ody.sh/SaV7LzhjNj - Storj: link.storjshare.io (two separate video files) - Proton Drive: drive.proton.me (two separate share links) - Substack: Matt1Up.Substack.com/p/january-rule-20-exam ### Visual Evidence Inventory - **[Page 1]** Court filing header: "CASE 0:24-cv-02646-JRT-DLM Doc. 78 Filed 09/26/24 Page 1 of 15" — standard federal CM/ECF header. Below it, "Exhibit AB" label in standalone text. No anomalies. - **[Page 3] [Screenshot — Zoom meeting]:** Large screenshot of "Zoom for Government" interface in gallery view. Left panel shows "Dr. Adam Milz" name label — a middle-aged man with short light/gray hair wearing over-ear headphones and a dark blue sweater/fleece, seated in a room with beige/tan walls. Right panel shows "matt1up" label — a younger man (Guertin) wearing a backwards baseball cap, headphones, and a dark t-shirt, seated in front of a bright green screen with visible microphone boom equipment. Both participants' cameras are on. Play button overlay is centered on the video frame. Timeline bar at bottom shows "1:15:50 / 1:59:32." A small green dot and "GCH" text appear in the upper-left corner of the Zoom window. The "View" button is visible in the upper-right. Below the video: Zoom toolbar with Mute, Stop Video, Participants, Chat, Share Screen (highlighted blue/green), Record, Reactions, Whiteboard buttons, and a red "Leave" button. No visible anomalies in the interface. - **[Page 4] [Three Zoom screenshots]:** Three sequential screenshots from different moments in the meeting. All show the same Zoom for Government interface with "Dr. Adam Milz" and "matt1up" panels. Screenshots capture various conversational expressions — Milz appears engaged with slightly different postures (leaning on hand, sitting upright, leaning forward). Guertin displays animated expressions including smiling and gesturing. Green screen visible behind Guertin in all frames. All three show the same Zoom toolbar at bottom. - **[Page 5] [Three Zoom screenshots]:** Similar to page 4. Milz appears to be speaking in the top screenshot (mouth open). Middle screenshot shows Milz looking slightly to the side. Bottom screenshot shows both participants appearing to be mid-conversation. Guertin is variously smiling and gesturing with hands visible. No anomalies in interface or participant appearance. - **[Page 6] [Three Zoom screenshots]:** Top screenshot: Milz's mouth is slightly open as if speaking; Guertin looking attentive with hand on chin. Middle: Milz appears to be looking somewhat to the side with a slight smile; Guertin smiling and gesturing. Bottom: Milz speaking; Guertin laughing/smiling broadly. These frames appear to capture moments of lighter conversation. - **[Page 7] [Three Zoom screenshots]:** Top: Milz appears with a more serious/concerned expression; Guertin gestures with arm raised. Middle: Milz looking to the side with mouth open (speaking or reacting); Guertin smiling. Bottom: Milz speaking; Guertin making a fist-pump or animated gesture while smiling. These screenshots present Guertin as engaged, animated, and emotionally responsive — potentially offered to counter the characterization of psychosis or impaired communication. - **[Page 8] [Screenshot — Zoom meeting, "Incoming Text Edition"]:** A single large screenshot showing only Dr. Milz in a close-up Zoom view, filling most of the frame. He is wearing headphones, looking slightly to the right of camera. The video timeline shows "5:49 / [total not visible]." This frame appears to be from the separately edited video focusing on Milz's behavior. The "Zoom for Government" header is visible. Below: same external video hosting links as the full meeting but for the alternative edit. - **[Page 9] [AI chatbot conversation with sequential frames]:** At the top, three small grids of sequential still frames of Dr. Milz (approximately 12–16 frames per grid), showing him in the same close-up Zoom view from slightly different moments. Below the top grids: a text block in a rounded-corner gray bubble (appears to be a user prompt in a chatbot interface) asking the AI to analyze the photographs and guess what the man is likely "so interested in" given that the images are from a Zoom meeting during a "professional mental health assessment." Below: a green-bubbled AI response stating the man appears "preoccupied with something other than the person he is supposed to be assessing." Below that: three more close-up still frames of Milz shown at larger size. Below those: another gray user prompt providing more detail — noting the man "appears to be reading as his eyes can very clearly be seen moving back and forth" and that this occurred throughout the meeting for an estimated 20–25 minutes total. - **[Page 10] [AI chatbot continuation + frame grid]:** Continuation of the AI chatbot conversation. The AI response (green bubble) states that if the man was reading and not typing, "it strongly suggests that he is focusing on some form of text that is off to the side, potentially on another screen or a printed document." The AI further states that given the 20–25 minute duration, this suggests "sustained engagement with the material he is reading." The AI concludes: "If this took place during a mental health assessment, such behavior would raise concerns about his attentiveness to the patient." Interface elements at the bottom of the chat (speaker icon, copy, thumbs up/down, refresh icons) are visible, consistent with a ChatGPT-like interface. Below the chat: a 4×3 grid of 12 sequential still frames of Milz showing various moments of his gaze directed to the side, with slight expression changes. - **[Pages 11–12] [Large frame grids of Milz]:** Two full pages of sequential still frames arranged in a 4×10 grid (approximately 40 frames per page, ~80 total). Each frame shows Milz's face in the same webcam view at slightly different moments. Across these 80 frames, Milz's gaze frequently shifts to the left or right of the camera, his expression varies between neutral contemplation and mild engagement, and in several frames his chin rests on his hand. The frames appear to be extracted at regular intervals from the video, designed to document the persistent pattern of side-looking behavior. No obvious signs of digital manipulation or frame duplication — each frame shows subtly different positioning and expression consistent with sequential video capture. - **[Page 13] [Scanned document excerpt — Milz report p. 130/196]:** Image of a court document page with header "27-CR-23-1886" and "CASE 0:24-cv-02646-JRT-DLM Doc. 43 Filed 08/07/24 Page 130 of 196" plus "Filed in District Court State of Minnesota 1/11/2024 2:05 PM." Contains "DIAGNOSTIC FORMULATION" section. Several passages highlighted in yellow: "the defendant has a history of psychosis characterized by prominent delusional thinking as well as impaired thought processes"; "it is unclear if he is receiving treatment designed to specifically address psychotic symptoms (e.g., antipsychotic medications)"; "He demonstrated these symptoms during the current interview." These highlights appear to have been added by Guertin to draw attention to contested findings. Footer in red: "Exhibit S | Index 10 | p. 4" — cross-referencing another exhibit. - **[Page 14] [Scanned document excerpt — Milz report p. 131/196]:** "Competency Assessment" and "Summary and Opinion" sections. Multiple highlighted passages in yellow, blue, and green. Yellow highlights cover: statements about Guertin representing himself because Rivers is a "big YouTube star"; Rivers "cryptically confirmed" phone monitoring; delusional-based trial strategies involving hacking, AI/Bluetooth monitoring, ex-military/CIA agents. Green highlight: "He also stated Mr. Rivers cryptically confirmed to him during a prior consultation that his phone calls were being monitored." Blue highlighting appears on the passage about evidence he would present including Netflix fraud proof. Red/pink highlight on the final opinion: "He exhibited delusional thinking (including paranoid beliefs about the evidence in this matter case and potential outcomes of his case)" and "These impairments are directly related to his psychotic disorder and suggest an inability to rationally assist defense counsel during defense-planning and legal proceedings, make informed and rational legal decisions, provide relevant testimony, and manage the demands of legal proceedings and the trial process." Footer: "Exhibit S | Index 10 | p. 5." - **[Page 15] [Scanned document excerpt — Milz report p. 132/196]:** "PROGNOSIS REGARDING COMPETENCY," "IMMINENT RISK/NEED FOR EMERGENCY INTERVENTION," and "ADDITIONAL CONSIDERATIONS" sections, plus signature block. Yellow highlight on: "Although psychotic disorders are typically chronic and relapsing conditions that require long-term treatment, such disorders often respond positively to psychiatric medications"; "The prognosis for his psychotic symptoms remitting on their own is poor." Blue highlight on: "Mr. Guertin has a history of threatening to harm himself, which elevates his long-term risk of similar behavior" — this is the specific claim Guertin contests as fabricated. Green highlight on: "It is my opinion he requires psychiatric treatment in order to stabilize his mental status." Handwritten signature visible at bottom: a stylized cursive initial/mark followed by "PhD, LP, ABPP" in handwriting. Typed signature block: "Adam A. Milz, PhD, LP, ABPP / Supervising Forensic Psychologist / Fourth Judicial District Psychological Services / Board Certified in Forensic Psychology / American Board of Professional Psychology." Footer: "Exhibit S | Index 10 | p. 6." - **Anomaly Flag — Signature:** The handwritten signature on page 15 is a brief stylized mark (appears to be an initial or abbreviated signature) rather than a full name signature. This is not necessarily anomalous for a professional report but is notably informal compared to the typed credentials block. ### Key People Referenced - **Matthew David Guertin*** — Defendant (criminal) / Plaintiff (federal); exam subject - **Adam A. Milz, PhD, LP, ABPP*** — Supervising Forensic Psychologist, Fourth Judicial District Psychological Services; examiner; Board Certified in Forensic Psychology (ABPP) - **Bruce Rivers*** — Defense attorney referenced in the Milz report; identified as having a YouTube channel creating a conflict of interest - **Netflix** — Referenced in Milz report as entity Guertin claims committed fraud ### Key Entities / Organizations Referenced - Fourth Judicial District Psychological Services - American Board of Professional Psychology (ABPP) - Zoom for Government (video conferencing platform used for exam) - U.S. District Court, District of Minnesota (filing court) - Hennepin County District Court (report filing court) - Rumble (video hosting) - Odysee (video hosting) - Storj (cloud storage / video hosting) - Proton Drive (cloud storage) - Substack / Matt1Up.Substack.com (Guertin's publication platform) ### Dates & Deadlines Mentioned - January 3, 2024 — Date of Rule 20.01 exam Zoom meeting - January 11, 2024 at 2:05 PM — Filing date/time of Milz report in district court - August 7, 2024 — Date Milz report filed as Doc. 43 in the federal case (pages 130–132 of 196) - September 26, 2024 — Filing date of Exhibit AB (this document) as Doc. 78 - February 10, 2024 — Expiration of stayed order of civil commitment referenced in Milz report ### Forensic Flags & Anomalies - **Self-Harm History Claim:** Milz's report states Guertin "has a history of threatening to harm himself" but the same report acknowledges "No recent indication of self-harm was noted and he reported no specific thoughts, plans, or intent to harm himself or commit suicide." Guertin categorically denies any history of self-harm. The source of Milz's claim about self-harm history is not identified within the excerpted pages — it may derive from collateral records (police reports from January 2023 incident, commitment records) not shown in this exhibit. The disconnect between the claim and Guertin's denial is a central forensic flag. - **Examiner Attentiveness:** The video evidence and AI-assisted frame analysis suggest Milz may have been reading something off-screen for approximately 20–25 minutes during the 2-hour exam. If substantiated by the full video, this raises questions about the thoroughness and reliability of the evaluation. However, the AI analysis was conducted by Guertin himself as a party to the case, which limits its independent evidentiary weight. - **Platform as Evidence:** The Zoom interface clearly displays "Zoom for Government" — a specific government-contracted version of Zoom. This confirms the exam was conducted through official government channels. The participant names visible ("Dr. Adam Milz" and "matt1up") confirm the identities of both parties. - **Recording without Apparent Objection:** Guertin appears to have recorded the entire 2-hour session and subsequently published it publicly on multiple platforms. Whether Milz consented to recording or was aware of it is not addressed in this exhibit. - **Cross-Exhibit Labeling Discrepancy:** The excerpted report pages carry a footer reading "Exhibit S | Index 10 | p. 4/5/6" while the current exhibit is labeled "Exhibit AB." This indicates the same report pages were used in at least two different exhibits within the federal case — first in Exhibit S (filed earlier) and now in Exhibit AB. This is not anomalous per se (evidence reuse is common) but should be tracked for consistency. - **Delusional Finding vs. Corroborated Claims:** Milz characterized as "delusional" Guertin's claims about computer hacking, phone monitoring, Netflix fraud, ex-CIA agents, and corporate surveillance. However, other filings in this case (particularly Filings #1, #3, #8, and #12) present detailed digital forensic evidence purporting to support several of these claims — including LinkedIn search records, patent comparisons, and MCRO document analysis. The tension between the clinical characterization and the documentary evidence is a central issue across the case. - **Report Metadata:** The report header shows it was filed in state district court on January 11, 2024 and later filed in the federal case as Doc. 43 on August 7, 2024 at pages 130–132 of a 196-page filing. Previously cataloged entries note that the metadata author of the Milz report is "Hines, Anne" — not Adam Milz — per Filing #12's digital forensic analysis. This exhibit does not address the metadata authorship question directly. ### Cross-References - Filing #9* — Motion for Substitute Counsel — references Milz report denial and Rivers' failures - Filing #12* — RICO Complaint — identifies "Hines, Anne" as metadata author of Milz report; expanded forensic claims - Filing #23 (this batch) — Original Complaint — extensively references the January 3, 2024 exam and Milz as a defendant - Filing #7* — 60–90 Day Report — referenced positive compliance during stayed commitment - Milz Rule 20 Report* (January 11, 2024) — the report excerpted in Index 03 of this exhibit - Exhibit S (Doc. 78 cross-reference) — same report excerpts appear at Index 10, pp. 4–6 - Doc. 43 in federal case (filed August 7, 2024) — full filing containing the Milz report at pages 130–132 of 196 --- ## Filing #25 — Exhibit L: Light Stage 6 at USC — Image Fraud Analysis | Field | Detail | |---|---| | Filing # | 25 | | Date Filed | July 12, 2024 | | Filed By | Matthew David Guertin (Plaintiff, Pro Se) | | Document Type | Exhibit (image forensic analysis with supporting source materials) | | Case/Court | Federal: 0:24-cv-02646-JRT-DLM / U.S. District Court, District of Minnesota (Doc. 19, Pages 1–40 of 40) | | Pages | 40 | | Bates / Doc ID | 19__Exhibit-L__LIGHT-STAGE-6-AT-USC-ANALYSIS__FRAUD_Index_01-02.pdf + 19__Exhibit-L__LIGHT-STAGE-6-AT-USC-ANALYSIS__FRAUD_Index_03-05.pdf | ### Comprehensive Summary Exhibit L is a 40-page image-centric forensic analysis document filed as part of Doc. 19 in the federal civil rights case. The exhibit is organized into five indexed sections and focuses entirely on what Guertin alleges is a fraudulent portrayal of the "Light Stage 6" technology at USC's Institute for Creative Technologies (ICT), associated with Paul Debevec. The central thesis is that images from a purported 2006 academic research paper ("Virtual Cinematography: Relighting Through Computation") and a 2018 online video ("The Light Stage With Paul Debevc – 360 Video") show lighting fixtures in identical rotational positions despite a 12-year gap — a result Guertin argues is physically impossible given that the fixtures are attached with standard pipe clamps, which inherently introduce variability upon any removal, maintenance, or reattachment. The exhibit's argument proceeds in five sections: **Index 01 (Pages 3–5): ChatGPT Digital Forensic Analysis Report.** This section consists of two formal-style "Digital Forensic Analysis Reports" attributed to an analyst identified only as "Tom," bearing case number 2024-DF-002 and dated June 8, 2024. The first report analyzes the technical likelihood that the Light Stage 6 fixtures could remain in identical positions from 2006 to 2018 without maintenance, cleaning, or reconfiguration. It concludes that exact positioning over 12 years is "highly improbable" given the use of standard pipe clamps, which are not designed for precision placement. The second report extends the analysis to assess implications of fraud, concluding that the consistency in fixture positions suggests the images may have been staged or manipulated, constituting deliberate deception. Both reports are signed by "Tom, Highly Accredited Digital Forensic Expert." The reports' provenance as ChatGPT-generated analysis is disclosed in the Index 01 title on the table of contents page. **Index 02 (Pages 6–29): Light Stage 6 Fixture Position Analysis.** This is the core visual analysis section, authored by Matt Guertin. It spans 24 pages and is overwhelmingly image-based, containing approximately 40+ images including annotated photographs, vector-traced overlays, brightness-adjusted versions, color-masked analyses, and composite comparison images. Guertin describes using vector imaging software to trace three distinct layers across three source images: (1) individual lighting fixture positions and rotational orientations, (2) the physical metal dome structural members (color-coded by structural grouping), and (3) controller unit positions (small rectangular boxes used to control different fixtures). The three source images are: (a) an image saved from Debevec's purported 2006 paper, (b) a screen capture from a 2018 video titled "The Light Stage With Paul Debevc – 360 Video," and (c) an image from Archive.today (archived January 18, 2013, purported URL http://www.blogcdn.com/www.joystiq.com/media/2008/08/ls6-usc_ict-inside.jpg) showing a woman on a rotating treadmill. Guertin's analysis proceeds through multiple visual steps: tracing individual fixtures on the 2006 image; tracing the dome's structural members with color-coded groupings; adding a controller unit layer; then performing the identical tracing on the 2018 video screencapture and the Archive.today image. When the traced layers are compared across the 2006, 2013/Archive, and 2018 images, Guertin asserts that virtually every lighting fixture maintains the identical rotational position across all three time periods. Additionally, Guertin performs image manipulation analysis on the 2006 paper image, adjusting brightness/levels to reveal what he describes as evidence of editing in the black space between lighting fixtures — showing "blocky, inorganic edit shapes" that he interprets as evidence of image manipulation to conceal cameras used for the USC Shoah Foundation's "New Dimensions in Testimony" project. He performs the same levels-adjustment analysis on the Archive.today image and reaches similar conclusions about editing artifacts. Guertin also argues that the woman and treadmill in the Archive.today image may have been digitally inserted based on his assessment of color level inconsistencies. The section includes additional screencaptures from a purported 2006 video showing Paul Debevec and the Light Stage 6 setup from various angles, close-ups showing pipe clamp attachments, PCBs on the back of light units with what appears to be an ethernet jack and two separate cables per fixture, views of controller units, and images branded with "USC SHOAH FOUNDATION" and "Shoah Foundation" watermarks. Guertin identifies the 2006 video as the same one shared in a 2023 SIGGRAPH presentation where Debevec represented Netflix and Eyeline Studios. Guertin claims the technology visible in the images — including individually-addressed LED fixtures with separate ethernet data and power connections per unit — represents capabilities far more advanced than what was standard for LED lighting technology in 2006, supporting his theory that the research papers and their claimed dates are fraudulent. The section also references the red chair visible in the 2018 video screencaptures, which Guertin identifies as the chair used to record Holocaust survivors for the USC Shoah Foundation's "New Dimensions in Testimony" project. He identifies video cameras visible among the lighting fixtures in the 2018 footage. The "JAUNT" watermark is visible at the bottom of the 2018 video screencaptures, indicating the video was associated with Jaunt, a VR content company. **Index 03 (Pages 30–38): Debevec 2006 Paper — "Virtual Cinematography: Relighting Through Computation."** This section reproduces the full 9-page IEEE Computer Society cover feature article by Paul Debevec, published August 2006 (0018-9162/06/$20.00 © 2006 IEEE). The paper discusses the plenoptic function, digital imaging dimensions, light field photography, and Debevec's work on performance relighting using Light Stage apparatuses. Key content includes: descriptions of Light Stage 5 (156 white LED light sources in a 2-meter sphere) and Light Stage 6 (an 8-meter dome with 901 controllable LED light sources using LumiLEDs Luxeon V LEDs in 18cm hexagonal arrangements, with Fraen "single wide" optics, controlled by 75 Microchip PIC 18F8627 microcontroller boards at 40MHz). The paper includes Figure 6, which shows (a) the Light Stage 6 with a running subject on a treadmill — the same image Guertin analyzes throughout Index 02, and (b) a composite rendering of multiple runner instances in a Doge's Palace courtyard setting. The paper describes relighting applications for filmmaking, mentions use of the technique for Spider-Man 2, King Kong, and Superman Returns digital stunt doubles, and discusses relighting the Parthenon using captured illumination data. The paper lists numerous collaborators and acknowledges sponsorship by USA RDECOM, USC Office of the Provost, and TOPPAN Printing Co., Ltd. **Index 04 (Page 39): 2018 Video Source Screenshot.** A full-page screenshot of a webpage on "Funny Cat Videos" (a video hosting site) showing the video titled "'The Light Stage With Paul Debevec' - 360 Video" published by "Jaunt" on January 18, 2018 at 04:01 am. The video had 13,627 views, 87 likes, and 0 dislikes at the time of capture. The video description states Debevec has been developing technologies to digitize humans for more than a decade, used in visual effects for Hollywood blockbusters. The page shows 0 comments and includes a Facebook Comments Plugin section. Below the video area is unrelated "Funny Cat Videos Motive" text. The page has a copyright notice of 2014-2020. **Index 05 (Page 40): Archive.today Source Screenshot.** A full-page screenshot of an Archive.today webpage showing the archived image of the woman on the treadmill inside Light Stage 6. The archive metadata shows: saved from "http://www.blogcdn.com/www.joystiq.com/media/2008/08/ls6-usc_ict-inside.jpg," archive date of January 18, 2013, 20:34:54 UTC. The page indicates it was "Linked from ru.wikipedia.org > LightStage." Navigation options include "Webpage" and "Screenshot" tabs, plus share, download .zip, report abuse, and "Buy me a coffee" links. ### Legal Issues & Arguments Raised - Fraud / forgery — Central allegation that images in Debevec's 2006 academic research papers are fabricated or manipulated to support a false timeline of technology development - Image manipulation / evidence tampering — Claim that 2006 paper images were edited to conceal cameras and other equipment, constituting misrepresentation of the technology's actual purpose and configuration - Patent fraud — Overarching theory that the Light Stage 6 technology's fraudulent 2006 dating supports a broader scheme to backdate technology that competes with or was derived from Guertin's InfiniSet VR treadmill patent - Academic fraud — Implicit allegation that peer-reviewed IEEE publications contain manipulated images - Wire fraud (18 U.S.C. § 1343) — Part of broader fraud allegations against Netflix, Debevec, and others - Civil conspiracy (42 U.S.C. § 1985) — Part of broader conspiracy allegations connecting corporate, academic, and government actors ### Factual Allegations & Key Assertions - Light Stage 6 lighting fixtures are attached using standard pipe clamps, which do not allow for precision repositioning - Comparison of 2006 paper images, a 2013 archived image, and 2018 video screencaptures shows lighting fixtures in identical rotational positions across 12 years - Standard maintenance, cleaning, LED replacement, or reconfiguration over 12 years would have required removing and reattaching fixtures, making identical repositioning physically improbable - The 2006 paper images show evidence of digital editing when brightness levels are adjusted — blocky, inorganic shapes in the black space between fixtures - The Archive.today image (purportedly from 2006/2008) shows similar editing artifacts when levels are adjusted - The woman in the Archive.today image is a "PERFECT match" to images appearing in multiple papers purported to be from 2006 - The 2006 images were edited to hide cameras used for the USC Shoah Foundation's "New Dimensions in Testimony" project - Light Stage 6 originally existed for the Shoah Foundation project and was later "re-purposed" for what Guertin calls the fraud operation - The 2018 video shows the identical controller units in the same positions as 2006 - A bright red chair visible in the 2018 video is identified as the chair used to record Holocaust survivors - Video cameras are visible along the second/third row of fixtures in the 2018 video - Each lighting fixture appears to have two cables (ethernet/data and power), with PCBs and ethernet jacks visible on the backs of units - The dual-cable, individually-addressable LED technology visible in the images is claimed to be far more advanced than 2006-era LED technology - The 2006 video screencaptures are from the same video shared in Debevec's 2023 SIGGRAPH presentation representing Netflix and Eyeline Studios - Guertin personally downloaded the 2018 video evidence on August 14, 2023 as part of his initial investigation - Guertin's investigation began after encountering the 2023 SIGGRAPH video featuring Paul Debevec ### Procedural Posture This exhibit was filed as Exhibit L within Doc. 19, a set of exhibits supporting Guertin's federal civil rights complaint (0:24-cv-02646-JRT-DLM). Doc. 19 was filed on July 12, 2024. The exhibit provides image-based forensic evidence supporting Guertin's broader allegations that Paul Debevec, Netflix, Eyeline Studios, and others are engaged in a fraud scheme involving backdated technology claims, which Guertin ties to the theft of his InfiniSet VR treadmill patent technology. This exhibit directly supports claims in the original complaint (Filing #23) regarding Debevec's alleged fraud. ### Exhibit / Attachment Inventory | Label | Description | |---|---| | Index 01 | ChatGPT Digital Forensic Analysis of Light Stage 6 Fixture Positions (2 formal reports by "Tom," Case No. 2024-DF-002, dated June 8, 2024) | | Index 02 | Light Stage 6 Fixture Position Analysis (authored by Matt Guertin; 24 pages of annotated images, vector traces, and comparative analysis) | | Index 03 | Full reprint of Paul Debevec's 2006 IEEE Computer article "Virtual Cinematography: Relighting through Computation" (9 pages) | | Index 04 | Screenshot of 2018 video source page — "The Light Stage With Paul Debevec" - 360 Video on Funny Cat Videos / Jaunt (1 page) | | Index 05 | Screenshot of Archive.today page preserving the "Woman on Treadmill" original image source (1 page) | ### Visual Evidence Inventory **[Page 1] Cover Page:** White page with blue ECF header "CASE 0:24-cv-02646-JRT-DLM Doc. 19 Filed 07/12/24 Page 1 of 40" and centered bold text "Exhibit L." No anomalies. **[Page 2] Table of Contents:** Text-based page describing the exhibit's purpose and listing all five index sections. Footnote references bookmarks for navigation. Blue ECF header present. **[Page 3] Index 01, p. 1 — ChatGPT Report #1:** Formatted as a formal forensic report with bold headers, bullet points. Case Number 2024-DF-002. Red text footer "Exhibit L | Index 01 | p. 1." No images on this page. **[Page 4] Index 01, p. 2 — ChatGPT Report #1 Conclusion + Report #2 Beginning:** Contains the conclusion and signature block of the first report ("Signed: Tom, Highly Accredited Digital Forensic Expert") followed immediately by a second report on fraudulent portrayal. Red footer. No images. **[Page 5] Index 01, p. 3 — ChatGPT Report #2 Conclusion:** Conclusion of second report asserting evidence of deliberate deception. Signature block for "Tom." Red footer. No images. **[Page 6] Index 02, p. 1 — Guertin Narrative Introduction:** Bold title "Light Stage 6 | EXACT Same Technology Since 2006..." with "Matt Guertin" byline. Text-only page laying out the core argument about fixture positions, pipe clamps, hidden cameras, Shoah Foundation, and fraud. No images. **[Page 7] Index 02, p. 2 — Two Composite Comparison Images:** - **[Top image]** Split-composition: bottom-left quadrant shows an original photograph from the 2006 paper (man standing on platform inside Light Stage 6, dark dome with hundreds of white LED fixtures visible as dot patterns, vertical equipment rack on left side, gray backdrop). The upper-right portion of the image shows a black background with color-coded vector trace overlays: small hexagonal/circular shapes representing individually-traced lighting fixtures in white/cyan outlines, plus colored structural lines (green, yellow, pink/magenta, cyan, orange) connecting structural node points. Red rectangular shapes mark controller unit positions. The traces map the fixture positions and rotational alignments from the 2006 source image. - **[Bottom image]** Same split-composition format but sourced from the 2018 video. Bottom-left shows a 360-degree video screencapture with bright green backdrop/screen, two figures standing (identified as Debevec on left), green floor covering, and the JAUNT watermark at bottom. Upper-right shows the same style of vector trace overlays on black background. The captions state the traces correspond to and can be compared with the 2006 image. Red footer. **[Page 8] Index 02, p. 3 — Two Versions of 2006 Paper Image:** - **[Top image]** Original image saved from the Debevec 2006 paper PDF: man in green/olive t-shirt and shorts standing on circular platform inside Light Stage 6. Dome visible with hundreds of white LED fixtures as dot/flower patterns against black interior. Vertical equipment stack on left. Gray/white backdrop behind subject. Image appears dark with high contrast. - **[Bottom image]** Same image with brightness/levels dramatically increased. Background shifts to green/teal tones. The lighting fixtures now appear as distinct white flower-shaped clusters. Large irregular patches of slightly different green tones are visible in the spaces between fixtures — these are what Guertin identifies as evidence of digital editing (blocky, inorganic shapes). The subject figure appears overexposed/washed out to white silhouette. Caption states this demonstrates editing in the "black space" between fixtures. **[Page 9] Index 02, p. 4 — Color Selection Mask Analysis of 2006 Image:** - **[Top image]** The 2006 image with a color selection mask applied: areas matching a specific color value are filled with bright magenta/pink. Large irregular pink blocks appear throughout the space between lighting fixtures, particularly prominent in the upper dome area and around the backdrop edges. The fixtures themselves remain visible as white/green flower shapes. Guertin interprets the blocky, angular pink shapes as confirmation of digital editing, as they represent uniform-color regions with inorganic geometric boundaries inconsistent with natural photographic content. - **[Bottom image]** The pink mask areas from the top image composited/overlaid onto the brightened version of the original (from page 8 bottom), showing the edited regions in context with the original image content. The man in the original (normal exposure) is visible. Pink blocks surround the dome fixtures. Red footer. **[Page 10] Index 02, p. 5 — Fixture Tracing Steps on 2006 Image:** - **[Top image]** The 2006 paper image (man on platform) with individual lighting fixtures traced as small white hexagonal/pentagonal outlines overlaid on the original dark photo. Only fixtures also visible in the 2018 video are traced. Caption notes that fixtures to the right of the person are not traced because they are hidden by the green cloth backdrop in the 2018 video. - **[Bottom image]** Same 2006 image with color-coded structural member traces added. The dome's metal framework is outlined in multiple colors: green (large structural triangles on left), cyan, yellow, orange, pink/magenta (various structural groupings across the dome). Caption explains each color corresponds to a structural grouping, matched to colors used in the 2018 analysis for comparison. **[Page 11] Index 02, p. 6 — Combined Layers on 2006 Image:** - **[Top image]** Both the fixture position traces and structural grouping traces visible together overlaid on the 2006 paper image. Fixture outlines sit atop the colored structural lines. - **[Bottom image]** All three layers visible: fixture traces, structural traces, plus the addition of controller unit positions marked as small red rectangles at various points among the fixtures and structure. Caption identifies controllers as "small, rectangular 'boxes' that are used to control different fixtures." **[Page 12] Index 02, p. 7 — Final Traced Result on 2006 Image + Black Background Version:** - **[Top image]** Final composite: all three trace layers (fixtures, structure, controllers) overlaid on the original 2006 paper image, providing the complete "map" of the Light Stage 6 configuration as it appears in the 2006 source. - **[Bottom image]** Same three trace layers with the original photograph removed, replaced by a black background. The lower-left corner retains a small thumbnail of the original image for reference. The isolated traces show the full geometric pattern of the dome: fixture positions as small outlined shapes, colored structural lines forming the geodesic framework, and red controller rectangles. This serves as the reference "map" to be compared against the 2018 traces. **[Page 13] Index 02, p. 8 — 2018 Video Screencaptures (Panoramic):** - **[Top image]** Wide panoramic 360-degree screencapture from the 2018 Jaunt video. Interior of Light Stage 6 is dramatically lit with green: a large green screen/backdrop dominates the center, green fabric/covering on the floor. Two figures stand near a bright red/pink chair at center (Guertin identifies the person on the left as Paul Debevec). Hundreds of LED fixtures visible on the dome surrounding the interior. The JAUNT logo/watermark and a gray decorative border strip are visible at the bottom of the image. - **[Bottom image]** Similar panoramic view at a slightly different angle/moment. Debevec and another person visible, red/pink chair prominent. The lighting fixtures are clearly visible across the dome interior. Video cameras appear to be visible among the fixture rows along the left and right sides. JAUNT watermark at bottom. **[Page 14] Index 02, p. 9 — Structural and Fixture Traces on 2018 Video:** - **[Top image]** 2018 panoramic screencapture with structural member traces overlaid. Color-coded structural groupings match those used on the 2006 image (orange, cyan, yellow, magenta, etc.). Caption notes the corresponding colors match perfectly with the 2006 paper analysis, and references a woman "purportedly from 2009" whose clothing and appearance is "a PERFECT match" to 2006 paper images. - **[Bottom image]** 2018 screencapture with both structural traces and individual fixture position traces overlaid. The fixture outlines appear as small circles/hexagons mapped across the visible portions of the dome. **[Page 15] Index 02, p. 10 — Full Layers on 2018 Video + Isolated Traces:** - **[Top image]** 2018 screencapture with all three layers: structural traces, fixture traces, and controller unit layer (red rectangles). Complete mapping of the 2018 configuration. - **[Bottom image]** All three trace layers isolated on black background (original 2018 video screencapture removed). Shows the geometric dome pattern from the 2018 source in isolation, enabling direct visual comparison with the similarly isolated 2006 traces from page 12. **[Page 16] Index 02, p. 11 — Archive.today Image Comparison with 2018:** - **[Top image]** Composite showing the Archive.today image of the woman on the treadmill (lower-left quadrant) with all three trace layers mapped onto the dome portion. The upper-right shows traces on black background. The viewpoint in this image is different from the 2006 paper image (more centered, looking upward into the dome), providing a third independent source for fixture position comparison. - **[Bottom image]** Corresponding version of the 2018 video screencapture edited to match the Archive.today image's perspective/framing. All three trace layers overlaid. Caption states that virtually every lighting fixture maintains the exact same rotational position between the two images, which is the critical finding given the pipe clamp attachment method. **[Page 17] Index 02, p. 12 — Original and Enhanced Archive.today Image:** - **[Top image]** Original Archive.today image at normal exposure: woman in turquoise/teal top and khaki pants walking on a circular platform inside Light Stage 6. Dome is dark with hundreds of white LED flower-pattern fixtures visible. Vertical equipment rack on left side. What appears to be an easel or stand visible on the right. Red indicator lights visible along certain rows of fixtures. - **[Bottom image]** Same image with brightness/levels increased. Reveals more detail in the dark areas: additional fixtures, structural members, floor equipment, and the surrounding lab environment become more visible. Red indicator lights on certain fixtures become more prominent. **[Page 18] Index 02, p. 13 — Enhanced Archive.today Images (Two Levels):** - **[Top image]** Archive.today image with levels adjusted to highlight the woman, treadmill, and backdrop. The subject and the gray/white backdrop become more distinct. Caption states that based on Guertin's digital media background, the treadmill and backdrop appear to be digitally inserted rather than physically present — i.e., they look composited. - **[Bottom image]** Archive.today image with levels adjusted further/differently. Background noise pattern shifts to aqua/teal/cyan tones. Blocky, inorganic regions become visible between lighting fixtures, similar to those identified in the 2006 paper image analysis on page 9. Caption draws the parallel to the 2006 image editing evidence. **[Page 19] Index 02, p. 14 — Fixture and Structural Traces on Archive.today Image:** - **[Top image]** Archive.today image with lighting fixture layer overlaid — small hexagonal/circular traced outlines mapped to each visible fixture's position and rotation. - **[Bottom image]** Archive.today image with dome structural tracing layer: color-coded structural groupings (cyan, yellow, orange, magenta, green) matching the scheme used in the 2006 and 2018 analyses. **[Page 20] Index 02, p. 15 — Combined Layers on Archive.today Image:** - **[Top image]** Fixture layer plus structural layer together on the Archive.today image. - **[Bottom image]** All three layers (fixture, structural, controller) on the Archive.today image, completing the full tri-source comparison dataset. **[Page 21] Index 02, p. 16 — Technical Diagram and Paper Excerpt:** - **[Top image]** "Figure 2" from Paul Debevec's purported 2006 "Relighting Human Locomotion" paper. This is a technical cross-section diagram of the Light Stage 6 setup showing: the dome structure ("lighting apparatus") in profile as the upper two-thirds of an 8m geodesic sphere; labels for "lights," "ring light," "camera array," "matte backing," "matte lights," "working volume," "equator," "virtual floor," "floor lights," "foam," "treadmill," and "turntable." A silhouette of a running person is shown at center. The diagram is labeled as the "core element supporting the fraud." - **[Bottom image]** A text excerpt box from the same paper describing the technical specifications: 8m 6th-frequency geodesic sphere, 901 controllable light sources, six LumiLEDs Luxeon V LEDs per fixture in 18cm hexagonal arrangement, Fraen "single wide" optics, 100 lux at 4m, 75 Microchip PIC 18F8627 microcontroller boards at 40MHz, 990fps acquisition at f/2.8 aperture. **[Page 22] Index 02, p. 17 — Close-up of Fixture Rear / Pipe Clamp:** - **[Image]** Photograph (screencapture from video) showing the rear/exterior view of Light Stage 6 fixtures. Multiple hexagonal LED fixture units are visible attached to structural metal tubes via standard pipe clamps (clearly visible as metal clamp hardware gripping the tubes). Wiring is visible. The image shows a busy, industrial setup with many cables. Caption emphasizes that the pipe clamps prove the fixtures are not precision-mounted and draws the conclusion about rotational alignment impossibility. Also notes what appears to be an ethernet jack and corresponding cable visible on the PCB at the back of a fixture unit. **[Page 23] Index 02, p. 18 — Two Screencaptures (Shoah Foundation / VOA + Rear View):** - **[Top image]** Video screencapture showing the back of an elderly person (white/grey hair) looking toward the Light Stage 6 interior. A screen/monitor shows a face (appearing to be recorded testimony). Text overlay reads "USC SHOAH FOUNDATION" in upper left. A VOA (Voice of America) logo watermark is visible in the lower right. Green PCBs, wiring, and lighting fixtures are visible in the foreground. This image connects the Light Stage 6 directly to the USC Shoah Foundation's Holocaust survivor recording project. - **[Bottom image]** Another video screencapture showing a younger person (sandy/brown hair) from behind/side, looking at the Light Stage 6 setup. A monitor with what appears to be a blue sky/clouds wallpaper (or environment map) is visible among the equipment. Dense arrays of fixtures, PCBs, wiring, and controller units are visible. **[Page 24] Index 02, p. 19 — Two Screencaptures (Debevec in Lab + Close-up):** - **[Top image]** Video screencapture of a young man (identified in context as Paul Debevec based on other images) standing inside or near the Light Stage 6, speaking/gesturing. LED fixtures visible as illuminated flower patterns behind him. Metal structural framework and pipe clamps visible in foreground. - **[Bottom image]** Close-up screencapture from the purported 2006 video showing the interior detail of Light Stage 6: individual LED fixture units, red/orange controller components, structural metalwork, and dense cabling. Black bars (letterboxing) at top and bottom suggest video source. **[Page 25] Index 02, p. 20 — Two Wider View Screencaptures:** - **[Top image]** Wide interior shot from the purported 2006 video: three people standing on the circular platform inside Light Stage 6. LED fixtures illuminated as white flower patterns across the dome. Equipment, cables, and structural members visible in foreground (green-colored objects visible that may be equipment or cable management). - **[Bottom image]** Exterior/control-room view of Light Stage 6: the dome structure is visible from outside at an angle, showing the geodesic framework with illuminated LED fixtures. A person sits at a workstation with multiple monitors in the foreground right. Racks of equipment visible. A white figure/statue appears to be positioned inside the dome at center. **[Page 26] Index 02, p. 21 — Structural Close-up + Person with Light Probe:** - **[Top image]** Close-up of the Light Stage 6 structural framework from inside, looking through the metal tubes outward. Individual LED fixture units visible as hexagonal clusters attached via pipe clamps. Two separate cables running to each fixture are clearly visible. A person is visible in the background through the framework. Caption notes the dual cables likely represent separate ethernet/data and power connections per fixture, described as "far more advanced than what was standard in 2006." - **[Bottom image]** Close-up of a young person (appears to be Debevec based on other images) holding a chrome/mirrored spherical object (a light probe device) while standing among the illuminated LED fixtures. The fixtures appear as bright star/flower shapes surrounding the subject. Another person partially visible at right edge. **[Page 27] Index 02, p. 22 — Two More Screencaptures from Purported 2006 Video:** - **[Top image]** Interior view of Light Stage 6 from the purported 2006 video with black letterboxing: a bald/grey-haired man walking near the right side of the frame. Dense array of fixtures, controller units (red/orange), structural metalwork, and cabling fills the left side. LED flower patterns visible in background. Caption notes this is from the same video shared in the 2023 SIGGRAPH presentation. - **[Bottom image]** Close-up of the top/exterior of the dome showing fixtures, wiring, and structural joints from above. A single green-lit LED fixture is visible at center. Dense cable routing and PCBs visible. **[Page 28] Index 02, p. 23 — Exterior Dome + Person with Light Probe (Different Angle):** - **[Top image]** Wider exterior/control-area view of the Light Stage 6 dome from the purported 2006 video. The dome's geodesic framework is prominent. A person sits at a desk with monitors in front of the dome. Equipment racks and storage shelving visible on the right. Blue-tinted lighting. - **[Bottom image]** A person (appears to be Debevec) holding or examining a mirrored spherical light probe object, with LED fixtures visible behind as bright white star patterns. The image appears close-up and the person is speaking/gesturing. **[Page 29] Index 02, p. 24 — Two Final Screencaptures (Shoah Foundation + Dome View):** - **[Top image]** Video screencapture showing "Shoah Foundation" text overlay in upper left. An elderly person seated in a chair (visible through the structural framework) inside the Light Stage 6. Green screen/backdrop visible on left. LED fixtures and pipe clamp attachments clearly visible in the foreground structural members. - **[Bottom image]** Interior wide-angle view from the purported 2006 video showing the full dome structure from inside, looking up and across. A person visible at center on the platform. Dense array of fixtures, structural members, and equipment visible. The image appears slightly desaturated/grey. **[Page 30–38] Index 03, pp. 1–9 — Debevec 2006 IEEE Paper Reproduction:** - Full reproduction of the published academic paper with IEEE Computer Society formatting (two-column layout, red-brown header banner with "COVER FEATURE" label). Contains multiple figures: - **Figure 1 (p. 30/Index 03 p. 1):** Reproduction of the first photograph by Joseph Nicéphore Niépce, 1826 — a sepia/brownish historical photograph showing buildings/rooftops. - **Figure 2 (p. 31/Index 03 p. 2):** Technical diagram showing the geometry of the plenoptic function and reflectance field — vectors showing incident and emitted light rays with mathematical notation. - **Figure 3 (p. 33/Index 03 p. 4):** Three-part figure showing the Light Stage 5 setup: (a) actress inside spherical apparatus with LED lights, (b) grid of 156 facial images under different lighting directions, (c) same actress rendered under three different virtual lighting environments. - **Figure 4 (p. 34/Index 03 p. 5):** Grid of 9 images showing actor Chris Carmack rendered under nine different virtual lighting configurations. Directed by Randal Kleiser. - **Figure 5 (p. 35/Index 03 p. 6):** Four-part figure showing spatially varying illumination: (a) structured illumination pattern projected onto actress, (b) geometric model, (c) virtual Venetian blind lighting, (d) virtual stained glass lighting. - **Figure 6 (p. 36/Index 03 p. 7):** Two-part figure — **(a)** The key image: man in green t-shirt on treadmill inside the 8-meter Light Stage 6 dome (this is the same image Guertin analyzes throughout Index 02). **(b)** Composite rendering: multiple instances of a running figure placed in the courtyard of the Doge's Palace, Venice, with virtual lighting matching the environment. - **Figure 7 (p. 36/Index 03 p. 7):** Two-part figure showing Parthenon work: (a) light probe device in use near the temple base, (b) 3D laser-scanned surface model of the Parthenon. - **Figure 8 (p. 37/Index 03 p. 8):** Two images of the virtually reilluminated Parthenon: (a) rendered under dramatic natural sky (with HDR inset), (b) rendered with nighttime spotlight design. **[Page 39] Index 04, p. 1 — 2018 Video Source Webpage Screenshot:** Full-page screenshot of a website ("Funny Cat Videos" domain, funnycatvideos.co or similar). Shows a video player with a still frame from the 360-degree video — interior of Light Stage 6 with a figure visible. "YTAPI" text visible in upper right of video frame. Below the player: title "'The Light Stage With Paul Debevec' - 360 Video," publisher "Jaunt" (with Jaunt logo), 13,627 views, 87 likes / 0 dislikes, Share/Report Video/Embed options. Published date: "January 18, 2018 at 04:01 am." Video description text about Debevec developing technologies to digitize humans. Facebook Comments Plugin with 0 comments. Unrelated "Funny Cat Videos Motive" content below. Copyright 2014-2020. Login/Signup buttons visible. **Anomaly noted:** The video is hosted on what appears to be a video aggregation/scraping site rather than an official platform (Jaunt's own platform or YouTube), which may affect provenance reliability. **[Page 40] Index 05, p. 1 — Archive.today Webpage Screenshot:** Full-page screenshot of an Archive.today capture. Header shows Archive.today branding with metadata: "Saved from http://www.blogcdn.com/www.joystiq.com/media/2008/08/ls6-usc_ict-inside.jpg" with a search button. "18 Jan 2013 20:34:54 UTC" timestamp. "All snapshots from host www.blogcdn.com" link. "Linked from ru.wikipedia.org > LightStage." Tabs for "Webpage" and "Screenshot" (Screenshot is highlighted in red/active). Options: share, download .zip, report/bug or abuse, "Buy me a coffee." The main content area displays the image of the woman on the treadmill inside Light Stage 6 at a large scale, with vertical percentage markers (25%, 50%, 75%, 100%) along the left edge. The image itself matches the "original Archive.today image" shown on page 17. **Anomaly noted:** The URL path includes "2008/08/" suggesting the original image may have been from August 2008, not 2006 as Guertin asserts. Guertin acknowledges this discrepancy but argues the image "MUST be from 2006" based on the woman's appearance matching 2006 papers. ### Key People Referenced | Name | Role / Affiliation | Context | |---|---|---| | Matthew David Guertin (Matt Guertin)* | Plaintiff / Author of Index 02 analysis | Conducted the vector tracing analysis, filed the exhibit, collected 2018 video evidence on August 14, 2023 | | Paul Debevec* | USC ICT researcher / Netflix / Eyeline Studios | Author of the 2006 IEEE paper; appears in 2006 and 2018 video screencaptures; presented at 2023 SIGGRAPH on behalf of Netflix/Eyeline Studios; central figure in fraud allegations | | "Tom" | "Highly Accredited Digital Forensic Expert" / ChatGPT | Author of the two forensic analysis reports in Index 01 (disclosed as ChatGPT-generated) | | Chris Carmack | Actor | Subject of Figure 4 in the 2006 Debevec paper — performance relighting demonstration | | Randal Kleiser | Director | Directed the Chris Carmack performance shown in Figure 4 of the 2006 paper | | Joseph Nicéphore Niépce | Historical figure | Creator of the first photograph (1826), referenced in Debevec paper introduction | | E.H. Adelson | MIT researcher | Co-author of the plenoptic function concept (1991), cited in Debevec paper | | J.R. Bergen | Researcher | Co-author with Adelson of plenoptic function description | ### Key Entities / Organizations Referenced | Entity | Context | |---|---| | USC Institute for Creative Technologies (ICT)* | Location of Light Stage 6; Debevec's institutional affiliation | | USC Shoah Foundation* | Identified as operating the "New Dimensions in Testimony" project using Light Stage 6 to record Holocaust survivor testimonies; cameras allegedly hidden in 2006 images | | Netflix* | Alleged to be party to the fraud scheme; acquired Eyeline Studios/ScanlineVFX; Debevec represented Netflix at 2023 SIGGRAPH | | Eyeline Studios* | Debevec represented Eyeline Studios at 2023 SIGGRAPH | | IEEE Computer Society | Publisher of the 2006 Debevec paper (Index 03) | | Jaunt (Jaunt VR) | Publisher/host of the 2018 360-degree video; watermark visible on screencaptures | | SIGGRAPH* | 2023 conference where Debevec presented on behalf of Netflix/Eyeline Studios | | Archive.today | Web archiving service; source of the "woman on treadmill" image (archived Jan 18, 2013) | | Joystiq (via blogcdn.com) | Original host URL of the archived Light Stage 6 image | | Russian Wikipedia (ru.wikipedia.org) | Source that linked to the archived image (per Archive.today metadata) | | Voice of America (VOA) | Logo watermark visible on USC Shoah Foundation video screencapture | | Fakespace Labs | Manufacturer of the high-speed video projector mentioned in Debevec paper | | LumiLEDs | Manufacturer of Luxeon V LEDs used in Light Stage 6 per the 2006 paper | | Microchip (PIC 18F8627) | Manufacturer of microcontroller boards controlling Light Stage 6 per the 2006 paper | | Fraen | Manufacturer of "single wide" optics used in Light Stage 6 fixtures | | USA RDECOM | Sponsor of Debevec's research per paper acknowledgments | | TOPPAN Printing Co., Ltd. | Sponsor of Debevec's research per paper acknowledgments | | Funny Cat Videos (funnycatvideos.co) | Video aggregation website hosting the 2018 video at time of Guertin's capture | ### Dates & Deadlines Mentioned | Date | Event | |---|---| | 2006 (general) | Purported date of Debevec's "Virtual Cinematography" paper and Light Stage 6 research; Guertin disputes authenticity of this date | | August 2006 | Publication date of the IEEE Computer article (Index 03) | | 2008 (August) | Date in the URL path of the archived image (blogcdn.com/...2008/08/...) | | 2009 | Purported date of the "woman on treadmill" image per some attributions (Guertin disputes) | | January 18, 2013 | Archive.today capture date for the woman-on-treadmill image | | Late 2005 / Early 2006 | Purported original installation timeframe for Light Stage 6 technology | | January 18, 2018 | Publication date of the Jaunt 360 video on Funny Cat Videos site | | August 14, 2023 | Date Guertin personally downloaded the 2018 video as evidence | | 2023 (unspecified) | SIGGRAPH conference where Debevec presented for Netflix/Eyeline Studios; triggered Guertin's investigation | | June 8, 2024 | Date of the two ChatGPT forensic analysis reports (Index 01) | | July 12, 2024 | Filing date of Doc. 19 containing this exhibit | ### Forensic Flags & Anomalies 1. **ChatGPT as forensic expert:** Index 01 presents two reports authored by "Tom, Highly Accredited Digital Forensic Expert," but the Index title on page 2 identifies these as "ChatGPT Digital Forensic Analysis." The reports mimic formal forensic report formatting (case numbers, signatures, formal conclusions) but are AI-generated. This is a significant credibility issue — the reports are formatted to appear as independent expert analysis but are acknowledged (in the index) to be ChatGPT outputs. A court may view this as misleading or give the analysis no evidentiary weight. 2. **Date inconsistency in archived image URL:** The Archive.today URL contains "2008/08/" in the path (http://www.blogcdn.com/www.joystiq.com/media/2008/08/ls6-usc_ict-inside.jpg), suggesting the image may have been uploaded or published in August 2008. Guertin asserts the image "MUST be from 2006" based on the woman's appearance matching 2006 papers. The archive date is January 18, 2013. There is a gap between the URL's 2008 date, the 2006 paper date, and the 2013 archive date that is not fully reconciled. 3. **Video hosted on obscure aggregation site:** The 2018 Jaunt video evidence (Index 04) is sourced from "Funny Cat Videos" rather than an official platform. This raises chain-of-custody questions about the video's authenticity and whether it has been modified from the original Jaunt publication. 4. **Image manipulation analysis methodology:** Guertin's technique of adjusting brightness/levels to reveal "editing artifacts" is a common image analysis approach, but JPEG compression artifacts and other digital imaging phenomena can produce similar blocky patterns in dark regions without indicating manipulation. The "inorganic block shapes" identified could be compression artifacts, particularly in images extracted from PDF files (which often recompress embedded images). This alternative explanation is not addressed in the exhibit. 5. **Pipe clamp argument assumes maintenance occurred:** The central argument — that fixtures could not maintain identical rotational positions over 12 years — depends on the assumption that the fixtures were removed and reinstalled at some point during that period. If the apparatus was simply left in place without significant maintenance, fixtures remaining in position would not be anomalous. The ChatGPT reports assume maintenance "would typically" occur but do not establish that it did occur. 6. **Alternative explanation not considered — same image used in both contexts:** If the 2018 video shows the same physical setup that was never substantially modified (which is possible for a research apparatus), the consistent positions would be expected, not anomalous. Alternatively, if the images attributed to different dates are actually from the same session, this would also explain consistency but would indicate a different type of misrepresentation than what Guertin alleges. 7. **Woman's appearance argument is subjective:** Guertin's assertion that the woman "MUST be from 2006" because her clothing/appearance matches 2006 papers is circular reasoning if the same images were reused across multiple publications. 8. **Signature of "Tom" as forensic expert is misleading:** Even though the ChatGPT origin is disclosed in the table of contents, the reports themselves contain formal signature blocks ("Signed: Tom, Highly Accredited Digital Forensic Expert") without any disclosure of AI generation within the body of the reports. A reader viewing only Index 01 without the table of contents would not know these are AI-generated. 9. **Connection to broader case theory:** This exhibit is part of Guertin's overarching fraud theory connecting Debevec's USC research to Netflix's acquisition of Eyeline Studios/ScanlineVFX and the alleged theft of his InfiniSet patent technology. The exhibit does not directly address the patent issue but attempts to undermine the credibility of Debevec's research timeline. 10. **Visual anomaly — 2018 video shows cameras among fixtures:** Guertin identifies video cameras visible among the lighting fixtures in the 2018 video, which he connects to the Shoah Foundation recording project. If cameras were present in the 2006 images but were edited out (as Guertin alleges), this would support the image manipulation claim but would raise the question of why the cameras were hidden in still images but left visible in the 2018 video. ### Cross-References - **Filing #23** (Original Federal Complaint / Exhibit Q, Doc. 24) — This exhibit directly supports the fraud and conspiracy allegations in the complaint, particularly regarding Paul Debevec, Netflix, and Eyeline Studios - **Filing #8** (Netflix Whistleblower Part 1, Batch 6) — Related Netflix/Debevec fraud allegations - **Filing #23, Section VI** — MCRO analysis connecting court record irregularities to broader fraud theory - **Exhibit Q referenced in Filing #23** — The 2023 SIGGRAPH video featuring Debevec that triggered Guertin's investigation - **2006 Debevec Paper "Relighting Human Locomotion"** (referenced in Index 02, p. 16) — Separate paper containing "Figure 2" technical diagram and specifications; not included in this exhibit but referenced as a key supporting document --- --- ## APPENDIX A: FINAL Unified Chronological Timeline (All Filings #1–#25) | Date | Event | Filing # | |---|---|---| | 1826 | First photograph by Joseph Nicéphore Niépce (referenced in Debevec paper context) | #25 | | ~2000 | Guertin first meets Rivers (pedestrian ticket / "Fire Denny Green" incident) | #13 | | Late 2005 / Early 2006 | Purported installation of Light Stage 6 technology at USC ICT | #25 | | 2006 | Einarsson et al. "Relighting Human Locomotion" published at EGSR; LS6RHL video produced (per USC attribution) | #16 | | June 7, 2006 | US Patent 7,548,272 (Perlman/MOVA) application filed | #19 | | July 31, 2006 | MOVA Contour introduced at SIGGRAPH; Hollywood Reporter coverage | #19 | | August 2006 | Publication of Debevec "Virtual Cinematography" paper in IEEE Computer | #25 | | September 26, 2006 | Hollywood Reporter "emotion motion" article on MOVA Contour | #19 | | 2007 | Last Rivers retention before 2023 | #13 | | August 6, 2007 | MOVA/Gentle Giant SIGGRAPH 2007 press release | #19 | | October 23, 2007 | Wired "Beowulf F/X" article covering MOVA | #19 | | August 2008 (approx.) | Date suggested by URL path of archived woman-on-treadmill image | #25 | | February 17, 2009 | NPR article on Benjamin Button VFX featuring Light Stage Six | #19 | | March 1, 2009 | SF Business Times article on Perlman/Benjamin Button Academy Award | #19 | | June 16, 2009 | US Patent 7,548,272 granted | #19 | | March 9, 2012 | MOVA press release re John Carter facial capture | #19 | | August 17, 2012 | OnLive assigns assets to OL2, Inc. | #19 | | Oct. 23, 2012 | PhotoRobot "Walking belt video shooting" uploaded to YouTube (alleged prior art) | #17 | | Dec. 30, 2012 | PhotoRobot "Virtual_Catwalk—Introduction (short version)" uploaded to YouTube (alleged prior art) | #17 | | 2013 | MOVA assets stolen; LaSalle sells to SHST for $25,000 | #19 | | January 18, 2013 | Archive.today captures the woman-on-treadmill Light Stage 6 image | #25 | | 2/8/2013 | Two ICT Graphics Lab "New Dimensions in Testimony" videos uploaded to YouTube | #16 | | 2/15/2013 | "Jewish Education through Holograms" uploaded to YouTube (metadata: 2023:01:10) | #16 | | 3/15/2013 | "New Dimensions in Testimony Relighting Method" uploaded to YouTube (metadata: 2023:10:14) | #16 | | 4/2/2014 | Guertin recognized on Derivative.ca for TouchDesigner project | #1 | | 2015 (alleged) | VES "Light Field Imaging" 4-part conference (Guertin claims backdated) | #19 | | February 9, 2015 | AMPAS Scientific and Technical Award to MOVA Contour | #19 | | Jan. 28, 2016 | PhotoRobot "Digital Fashion Shows on the Virtual Catwalk" uploaded to YouTube (alleged prior art) | #17 | | 6/28/2016 | Digital Domain MOVA tech ban; VFX/DOD interest articles | #1 | | 9/5/2016 | "How USC's Automultiscopic 3D Display Works" uploaded (metadata consistent) | #16 | | 6/6/2017 | "New Dimensions in Testimony preserves Holocaust survivors stories" uploaded (metadata approx. consistent) | #16 | | June 17, 2017 | Judge Tigar issues preliminary injunction freezing MOVA technology | #19 | | 7/17/2017 | Rearden v. Disney complaint filed (MOVA tech) | #1 | | July 17, 2017 | Rearden v. Disney complaint filed (3:17-cv-04006) | #19 | | January 18, 2018 | Jaunt publishes "The Light Stage With Paul Debevec - 360 Video" | #25 | | 9/30/2018 | LA Phil 100th Anniversary — Guertin credited as chief technical artist | #1 | | April 2019 | Bad Bunny Coachella — Guertin designed/fabricated LED eye set piece | #1 | | July 31, 2019 | Earliest Nehring-authored filing (Order-Other, signed by Lamas) | #15 | | Aug–Nov 2019 | 50-foot Falcon — Guertin engineered carbon fiber structure | #1 | | October 9, 2019 | Four Nehring-authored filings signed by Lamas | #15 | | Apr 2020 | Guertin returns to MN from LA; reconnects with Rivers | #13 | | May 8, 2020 – Dec 9, 2022 | Span of Nehring-authored filings signed by Janzen (18 filings) | #15 | | May 25, 2020 | First documented text exchange between Guertin and Rivers | #18 | | June 12, 2020 | Guertin asks Rivers to look into expungement | #18 | | Nov 2020 | Portfolio development — Vimeo, MattGuertin.com; LED volume stage visit | #1, #8 | | February 2021 | Guertin conceives InfiniSet idea | #19 | | ~Feb 3, 2021 | InfiniSet concept conceived | #3, #8 | | 2/13/2021 | infiniset.com domain registered | #1 | | 3/19/2021 | Guertin provisional patent 63/163,135 filed | #1–#8, #11 | | March 27, 2021 | Guertin texts Rivers about provisional patent filing for InfiniSet; shares Dropbox links | #18 | | March 29, 2021 | Guertin requests business attorney referral from Rivers | #18 | | 3/31/2021 | Trojansky provisional patent 63/168,558 filed (12 days later) | #1–#5, #8, #11 | | 4/1/2021 | INFINISET trademark application filed (USPTO Serial #90618638) | #1 | | 6/30/2021 | Eyeline Studios registered in California | #1, #2 | | 11/22/2021 | Netflix acquires Scanline VFX / Eyeline Studios (~$100M) | #1, #4 | | 11/28/2021 | First LinkedIn search: US Air Force Academy | #3, #8 | | 1/20–2/10/2022 | Google LaMDA papers — "Infiniset" dataset | #1 | | ~11/5–6/2022 | Guertin discovers Netflix/Trojansky patent application | #2, #8 | | 1/16/2022 | LinkedIn: US Air Force search | #3 | | 1/31/2022 | Prototype welding completed | #3 | | 3/18/2022 | Guertin files US patent app 17/698,420 | #1 | | 3/30–31/2022 | Trojansky/Netflix files US and PCT applications | #1 | | April 16, 2022 | Inhance Digital searches Guertin's LinkedIn | #18 | | 4/19/2022 | Netflix Q1 2022 letter: $125M for Scanline acquisition | #1 | | April 23, 2022 | Gentle Giant Studios searches Guertin's LinkedIn | #18 | | 5/20/2022 | Netflix $100M South Korea VFX investment announcement | #4 | | May 21, 2022 | UPtv searches Guertin's LinkedIn | #18 | | June 4, 2022 | Ottawa Hospital/Realize Medical searches Guertin's LinkedIn | #18 | | 6/8/2022 | Brodsky continuation filing (patent 11,383,062) | #4 | | 6/24/2022 | KIPO completes PCT search on InfiniSet's application | #4 | | 7/12/2022 | US Patent 11,383,062 issued (Brodsky) | #1, #4 | | 7/18/2022 | InfiniSet Inc. registered in Delaware | #1 | | 9/22/2022 | Multiple patent publications (Guertin, Brodsky, Trojansky) | #1, #4 | | 10/31/2022 | MRMC CEO Assaff Rawner emails Guertin with PhotoRobot link | #2, #3, #8 | | Oct. 31, 2022 | Assaff Rawner (CEO, MRMOCO) emails Guertin acknowledging invention, noting PhotoRobot's existing system | #17 | | 11/8/2022 | Amanda Prose confirms patent similarities | #2 | | Nov 8, 2022 | Guertin discovers Trojansky patent application | #13 | | Nov. 8, 2022 | Patent examiner accesses three PhotoRobot YouTube videos as prior art | #17 | | 11/11/2022 | Guertin emails Bruce Rivers with 288MB evidence packet | #2 | | Nov 11, 2022 | Guertin calls Rivers at 6:48 AM re patent; sends info packet | #13 | | November 11, 2022 | First documented phone calls between Guertin and Rivers regarding legal representation | #18 | | 11/13/2022 | InfiniSet Inc. registered with MN SOS | #1 | | 12/5/2022 | Welder texts "Have they got to you yet?" | #3, #8 | | 12/5/2022 | Text exchange between Guertin and "CIA welder" — "Have they got to you yet?" | #22 | | 12/9/2022 | PatentlyFalse Wayback Machine account created | #2, #3, #8 | | 12/15/2022 | Guertin contacts Internet Archive about removal policy | #3, #8 | | Dec. 15, 2022 | Guertin emails Internet Archive about removal policies | #17 | | Dec. 9–15, 2022 | Guertin downloads original PhotoRobot YouTube videos (18 files) | #17 | | Dec. 28, 2022 | Guertin creates "Show_and_Tell - FRAUD AT INTERNET ARCHIVE.pdf" | #17 | | 12/29/2022 | Mark Graham (Internet Archive) responds | #8 | | 2023 (unspecified) | Debevec presents at SIGGRAPH representing Netflix and Eyeline Studios | #25 | | Jan. 1, 2023 | Guertin creates initial data analysis spreadsheets and website change evidence | #17 | | 1/2/2023 | BSOD event; alleged hacking begins | #8 | | 1/5/2023 | JavaScript timestamp anomalies discovered | #8 | | 1/12/2023 | Guertin visits FBI (Brooklyn Center); Minnetonka PD Report #23-000151 filed | #1, #2, #3, #8 | | 1/12/2023 | Minnetonka PD Report #23-000151 filed with Officer Harris | #22 | | Jan. 12, 2023 | Guertin reports patent fraud to Minnetonka PD (Report #MP23000151, Officer Harris) | #17 | | 1/13/2023 | "Smoking gun" spreadsheets sent to attorneys | #2, #8 | | Jan 13, 2023 | Guertin emails Rivers seeking patent fraud investigation help | #13 | | 1/14/2023 | Guertin sends Data_Analysis_Fraud.zip to welder for FBI contact | #22 | | 1/15/2023 | Secret Service call (22 min); welder call immediately after | #3 | | 1/17–18/2023 | AI deepfake discovery; evidence sent to attorney | #8 | | 1/19/2023 | Bluetooth PAN discovery; psychological break begins | #8 | | **1/21/2023** | **Guertin fires AR-15 from apartment; SWAT response; arrest** | **#1, #2, #3, #8** | | January 21, 2023 | Forcepoint/FOX/3Gimbals search Guertin's LinkedIn (same day criminal charges allegedly originated) | #18 | | 1/24/2023 | Criminal complaint filed; bail set at $50,000 | #1 | | 1/25/2023 | Probable cause found; Rule 20 evaluation ordered | #1 | | 1/30/2023 | Guertin email to Det. Samantha Johnson | #2 | | 1/30/2023 | Guertin emails Det. Johnson with wire fraud evidence (Rivers CC'd) | #22 | | 2/7/2023 | Guertin emails Rivers re: "special ops gear" on prototype | #22 | | 2/9/2023 | Dr. Rogstad scheduling letter | #2 | | 2/14/2023 | US Patent 11,577,177 granted to Guertin | #1, #11 | | 2/17/2023 | Third-party prior art filed against Netflix | #1 | | 3/1/2023 | Rule 20.01 exam meeting with Dr. Rogstad | #1, #2, #8 | | Mar 3, 2023 | Rule 20 exam with Rogstad; evidence envelope delivered to Rivers' office | #13 | | 3/7/2023 | USPTO Examiner Merouan approves Guertin's prior art submission | #1 | | 3/10/2023 | Dr. Rogstad's evaluation report filed (metadata author: "GuzmanC") | #1, #2, #3, #11, #12 | | March 20, 2023 | Date of Scanline VFX/Eyeline Studios job posting screenshots | #18 | | 4/5/2023 | CBS 60 Minutes archive video on Holocaust holograms uploaded | #16 | | 4/7/2023 | Dr. Schuster letter rebutting Rogstad | #3 | | 4/7/2023 | Dr. Schuster letter challenging Rogstad report | #22 | | Apr. 18, 2023 | Guertin creates PhotoRobot checkerboard artifact and catalog zoom analysis PDFs | #17 | | 4/26/2023 | Guertin emails Rogstad with evidence | #2 | | 4/26/2023 | Guertin emails Dr. Rogstad with rebuttal evidence (Rivers CC'd) | #22 | | Apr. 28, 2023 | Guertin creates "Simply_Adjusting_Color_Curves_Proves_AI.mov" | #17 | | May 2–3, 2023 | Guertin shares 7.2 GB evidence with FBI (IC3) and FTC | #17 | | 5/3/2023 | FBI IC3 and FTC fraud reports filed | #1, #3 | | May 17, 2023 | Date on Debevec's SIGGRAPH presentation slide | #19 | | 5/19/2023 | UK Serious Fraud Office report filed | #3 | | May 19, 2023 | Guertin files report with UK Serious Fraud Office | #17 | | 5/22/2023 | Rivers tells Guertin about "powerful people" (phone call) | #2, #3, #9 | | 5/22/2023 | SIGGRAPH 2023 video uploaded showing Debevec presentation | #16 | | 5/22/2023 | Bruce Rivers tells Guertin "powerful people keeping an eye on you" at 3:13 PM | #22 | | May 22, 2023 | Rivers allegedly tells Guertin about "powerful people keeping an eye on" him (longest call) | #18 | | 5/24/2023 | Patent attorney confirms payment for forensic analysis | #22 | | 6/1/2023 | International trademark filings (WIPO) | #1 | | 6/14/2023 | Hearing cancelled; order for continuance on non-existent motion; held "off the record" | #2, #7, #10, #12 | | Jun. 16, 2023 | Guertin emails Bruce Rivers about FBI report, AI videos, "powerful people" comment, competency hearing | #17 | | 7/7/2023 | Omnibus/competency hearing; Rivers presents only patent | #1, #2, #9, #10 | | Jul. 6–7, 2023 | Guertin prepares 424 MB + 1.2 GB presentations for competency hearing (never presented per Rivers' advice) | #17 | | 7/13/2023 | First incompetency order (Referee Borer / Judge Browne) | #1 | | 7/20/2023 | Civil commitment order filed (27-MH-PR-23-815); 25 LinkedIn searches | #3, #6, #7, #8 | | July 28, 2023 | Rivers informs Guertin of August 1 initial court appearance; Guertin describes startup status | #18 | | 8/1/2023 | Civil commitment hearing (Zoom); Biglow forwards only 1 of 16 docs | #3, #7 | | 8/1/2023 | Guertin sends 16 defense documents to Biglow; only Schuster letter forwarded | #22 | | August 1, 2023 | Guertin texts Rivers about civil commitment proceedings | #18 | | 2023-08-03 | Michael Biglow delivers allegedly fraudulent discovery materials to Guertin | #20 (Index 01/05 texts) | | 8/3–4/2023 | Stayed Order of Commitment | #3, #7 | | Aug 3, 2023 | Biglow emails discovery PDF (80 photos) to Guertin | #13 | | 8/8/2023 | Debevec SIGGRAPH 2023 video discovered | #3, #5 | | 8/8/2023 | Netflix Fraud "Round 2" first discovered by Guertin | #16 | | August 8, 2023 | Guertin discovers Debevec SIGGRAPH video | #19 | | 8/10/2023 | Guertin emails WCK about SIGGRAPH discovery; dropped as client | #3, #5 | | 8/12-13/2023 | Academic papers collected (150+ computer vision/CGI papers) | #16 | | 8/14/2023 | Evidence collection batch 1 (LightStage materials, military docs, web captures) | #16 | | August 14, 2023 | Guertin downloads 2018 video as evidence during initial investigation | #25 | | 8/15/2023 | Evidence collection batch 2 (Debevec bibliography, wiki pages, interviews) | #16 | | 8/21/2023 | Patent attorney (WCK) withdraws | #1, #3 | | 9/7/2023 | Plymouth PD Report #23033797 | #1 | | 9/7/2023 | Plymouth PD police report filed; micro-SD evidence shared with police | #16 | | 9/12/2023 | Multiple evidence files dated in cloud storage | #16 | | 9/19/2023 | Email to Amy Klobuchar; FraudLinks documents created | #16 | | 9/20/2023 | Guertin contacts Sen. Klobuchar's office | #1 | | 9/20/2023 | Klobuchar correspondence package sent | #16 | | September 28, 2023 | DARPA and Henry Street Settlement search Guertin's LinkedIn (2nd DARPA search) | #18 | | ~October 2023 | Guertin conducts ChatGPT conversation analyzing incident (Index 05) | #18 | | 10/10/2023 | Netflix/Trojansky patent files and certified mailer images dated | #16 | | 10/30/2023 | Positive 60–90 Day Report filed | #7 | | 11/7/2023 | Netflix patent US 11,810,254 published (cites Guertin as prior art) | #1, #4, #11 | | 11/15/2023 | Judge Klein orders new competency evaluation (no basis per Guertin) | #7, #12 | | November 15, 2023 | Klein orders 2nd competency evaluation; metadata author "Perry, Dolores" | #15 | | December 6, 2023 | Aaron Cherry authentic incompetency order (later overwritten by Dec 11 clone) | #15 | | December 18–23, 2023 | Guertin records multi-camera evidence documentation sessions (Videos 1–4) | #18 | | 1/3/2024 | Second Rule 20 exam with Dr. Milz (Zoom); secretly recorded by Guertin | #2, #7 | | 1/3/2024 | Dr. Milz conducts Rule 20.01 evaluation | #21 | | Jan 3, 2024 | Guertin emails Dr. Milz re discovery fraud before Rule 20 exam | #13 | | January 3, 2024 | Rule 20.01 competency exam conducted via Zoom for Government between Dr. Adam Milz and Matthew Guertin; approximately 2-hour session | #24 | | Jan 5, 2024 | Guertin files first pro se motion — Demand for Discovery | #13 | | 1/10/2024 | Guertin emails Rivers with new evidence (Debevec/SIGGRAPH, LinkedIn, altered discovery) | #22 | | 1/11/2024 | Dr. Milz Rule 20 report authored (metadata: "Hines, Anne"); sealed 7 months | #7, #12 | | January 11, 2024 | Milz Rule 20.01 exam report filed in Hennepin County District Court at 2:05 PM; diagnosis of unspecified schizophrenia spectrum disorder; finding of incompetency | #24 | | 1/15/2024 | Bruce Rivers texts "No court" and "Nothing has changed" | #3, #7 | | 1/15/2024 | Rivers texts Guertin "No court" at 6:26 PM | #21 | | Jan 15, 2024 | Rivers tells Guertin "no court" | #13 | | January 15–29, 2024 | Text exchanges: Guertin requests Rule 20 exam report from Rivers | #18 | | **1/16/2024** | **Commitment Order signed (Mercurio 8:27 AM, Klein 9:22 AM) before 1:30 PM hearing** | **#1, #3, #7, #10, #12** | | 1/16/2024 | Competency order created (8:26 AM), signed by Mercurio (8:27 AM) and Klein (9:22 AM); Notice of Remote Hearing filed (4:19 PM); hearing "Cancelled; Other" | #21 | | Jan 16, 2024 | Order entered: "all parties agree to a finding of incompetency" | #13 | | 1/17/2024 | Finding of Incompetency filed at 7:29 AM (Index #25) | #1, #7, #10 | | 1/17/2024 | Competency order filed into record at 7:29 AM; court actions shift to civil case | #21 | | 1/22/2024 | Sheriff dispatched to serve civil commitment appearance order | #7 | | 1/22/2024 | Affidavit of Service and Order/Notice of Hearing for Feb 1 hearing | #21 | | 1/26/2024 | Guertin discovers surprise Feb 1 hearing | #7 | | 1/26/2024 | Guertin discovers surprise hearing; contacts Rivers, Fisher, requests exam report | #21 | | 1/29/2024 | Fisher reveals wrong phone number for Guertin | #21 | | 1/30/2024 | Pro se motions for continuance and medical records filed | #1, #7 | | 1/30/2024 | Pro se Motion for Continuance and Motion for Production of Medical Records filed | #21 | | 1/31/2024 | Guertin signs waiver extending stayed commitment 9 months | #1, #7 | | 1/31/2024 | Guertin signs Waiver extending commitment 9 months | #21 | | 2/1/2024 | Hearing "cancelled and stricken" yet marked "Held Off the Record"; Index #40 missing | #7 | | 2/1/2024 | Order for Continued Stayed Commitment; motions dismissed; Index #40 missing | #21 | | 3/13/2024 | MCRO criminal history repopulated back to 2002 | #3 | | **4/3/2024** | **Filing #1: Motion for Judicial Notice (271 pp.) filed** | **#1** | | 4/3/2024 | Guertin requests Rivers' withdrawal; attaches Pro Se Motion | #21 | | Apr 3, 2024 | Email requesting Rivers withdraw | #13 | | 4/4/2024 | Motion to Compel Discovery and Affidavit filed | #2, #3 | | 4/4/2024 | Pro se Motion to Compel Production of Medical Records filed (civil case) | #21 | | **4/9/2024** | **Filing #3: Affidavit of Fact (213 pp.) filed** | **#3** | | 4/12/2024 | "Mother's Letter" incident — cross-docket manipulation alleged | #6, #7, #12 | | 4/18/2024 | Second request for Rivers' withdrawal via text | #21 | | Apr 18, 2024 | Text requesting Rivers withdraw | #13 | | April 18, 2024 | Guertin demands Rivers withdraw from case | #18 | | Apr 22, 2024 | Email to Joel Fisher re concerns about Rivers | #13 | | 4/29–30/2024 | Guertin downloads 3,601 PDFs from MCRO (163 cases) | #6, #7, #12 | | **5/3/2024** | **MCRO Analysis Affidavit filed (Index #37)** | **#7, #10** | | 5/3/2024 | Follow-Up Correspondence filed re: unacknowledged motions | #21 | | **5/6/2024** | **Filing #2: Affidavit of Fact (148 pp.) filed** | **#2** | | 5/10/2024 | Notice of Appeal filed (Index #53) | #10 | | 5/23/2024 | Alleged fee waiver affidavit at Index #77 (denied by Guertin) | #10 | | May 24, 2024 | Klein's first fee waiver denial (metadata author: Virginia Kuberski) | #15 | | May 30, 2024 | Klein's second fee waiver denial (metadata author: Virginia Kuberski) | #15 | | **6/3/2024** | **Filing #9: Motion for Substitute Counsel filed** | **#9** | | 6/3/2024 | Three filings: Motion to Compel Discovery, Motion for Substitute Counsel, Follow-Up Correspondence | #21 | | 6/6/2024 | Third demand for Rivers' withdrawal with extensive text messages | #21 | | Jun 6, 2024 | Third text request for Rivers' withdrawal; text re fraudulent discovery | #13 | | June 6, 2024 | Guertin sends detailed text accusing Rivers of ineffective assistance | #18 | | June 8, 2024 | ChatGPT forensic analysis reports dated (Index 01) | #25 | | 7/8/2024 | Federal civil rights lawsuit filed (Guertin v. Hennepin County) | #8, #10 | | July 8, 2024 | Original federal civil rights complaint filed in paper form by Guertin initiating case 0:24-cv-02646-JRT-DLM; 15 counts against 11 defendants; seeks TRO, $15M+ damages, jury trial | #23 | | July 12, 2024 | Exhibit N filed as part of Doc. 21 in federal case 0:24-cv-02646-JRT-DLM | #18 | | July 12, 2024 | Exhibit M filed as Doc. 20 in federal case | #19 | | July 12, 2024 | Doc. 19 filed in federal case, containing Exhibit L | #25 | | 7/15/2024 | Judge Klein recused (named in federal case) | #10, #12 | | Jul 15, 2024 | Rivers personally signs for federal summons | #13 | | 2024-07-16 | Court appearance; Rivers texts Guertin; Rivers' office provides discovery materials | #20 (Index 01 screenshots) | | 7/16/2024 | Review Hearing; Rivers provides discovery USB; Exhibit P filed | #21, #22 | | Jul 16, 2024 | Review hearing: Klein recusal; Koch remote; Rivers provides USB discovery | #13 | | July 16, 2024 | Digital version of complaint filed as Exhibit Q / Doc. 24 to preserve hyperlinks and bookmarks | #23 | | 2024-07-17 | Rivers texts about courtroom location ("457") | #20 (Index 01 screenshots) | | 2024-07-18 | "Did you get a complete copy of your file?" message from Rivers' number at 8:31 AM; Rivers identifies himself at 2:45 PM; extended text exchanges | #20 (Index 01 screenshots) | | Jul 18, 2024 | Text exchange on Rivers' new number | #13 | | 2024-07-25 | Guertin sends email about missing photos in discovery; texts Rivers about fraudulent discovery comparison | #20 (Index 01 screenshots) | | Jul 25, 2024 | Guertin emails Rivers about 28 missing images in new discovery | #13 | | Aug 5, 2024 | Cranbrook emails Guertin to schedule 3rd Rule 20 exam | #13 | | 2024-08-07 | Guertin's motion (basis for ChatGPT analysis) | #20 (Index 04) | | 8/7/2024 | Exhibit W filed as Doc. 47 | #22 | | August 7, 2024 | Milz report filed in federal case as Doc. 43 (pages 130–132 of 196) | #24 | | Aug 18, 2024 | Corrected Request for Entry of Default filed vs. Rivers | #13 | | 2024-08-29 | Clerk's Entry of Default filed at 9:44 AM CDT as to Bruce Rivers (Doc. 71); Guertin texts Rivers ~12:49 PM CDT; Rivers calls Guertin at ~2:28 PM CDT (16-minute call) | #20 (Index 02/03) | | Aug 29, 2024 | Entry of Default against Rivers; Rivers calls Guertin (15:35) | #13 | | Sep 2, 2024 | Exhibit Y filed in federal case (discovery fraud analysis) | #13 | | 2024-09-06 | Guertin sends mass emails to 57 MN judges (3:20 AM – 10:31 PM) | #20 (Index 05) | | 2024-09-09 | Exhibit Z filed as Doc. 75 in federal case | #20 (cover page) | | Sep 9, 2024 | Exhibit Z filed in federal case (ChatGPT analysis of Rivers) | #13 | | Sep 13, 2024 | Case worker meeting; case worker emails Guertin re Rivers concerns | #13 | | Sep 14, 2024 | OLPR complaint form date | #13 | | Sep 23, 2024 | OLPR complaint signed under penalty of perjury; mailed from Chaska | #13 | | Sep 24, 2024 | Complaint delivered to OLPR (1:57 PM); email copy sent (3:19 PM); Exhibit AA filed as Doc. 77 | #13 | | September 26, 2024 | Exhibit AB filed as Doc. 78 in federal case; contains video evidence and screenshots of the Milz Zoom exam plus report excerpts | #24 | | 9/29/2024 | Digital Forensic Analysis Reports 02 and 03 generated via ChatGPT | #16 | | Sep. 29, 2024 | Two ChatGPT "forensic analysis reports" generated (Reports 01-1 and 01-2) | #17 | | 9/30/2024 | Exhibit AF filed as Doc. 83 in federal case 0:24-cv-02646-JRT-DLM | #16 | | Sep. 30, 2024 | Exhibit AD filed as Doc. 81 in federal case 0:24-cv-02646-JRT-DLM | #17 | | 10/1/2024 | Hearing before Judge Koch | #10 | | 10/15/2024 | Hearing before Judge Askalani; competency evaluation ordered | #10 | | November 8, 2024 | Guertin's stayed civil commitment expires; Vail Place positive report | #15 | | 12/20/2024 | Rule 20 Evaluation Report (Dr. Cranbrook; metadata: "Hines, Anne") | #10, #12 | | **12/27/2024** | **Filing #10: Motion for Judicial Notice / Docket Anomalies filed** | **#10** | | **2/28/2025** | **Filing #11: Supplemental Evidence (Exhibits M–Q) filed** | **#11** | | 3/5/2025 | Competency order: competent to proceed, mental illness findings maintained | #8 | | April 3, 2025 | Judge Koch enters order finding Guertin competent to proceed | #14 | Add. 178–181 | | **4/10/2025** | **Filing #8: "Netflix Whistleblower Part 1" (153 pp.) filed** | **#8** | | **4/14/2025** | **Filings #4–#5: Exhibits B–G filed (Brodsky/Debevec fraud analyses)** | **#4, #5** | | April 16, 2025 | Guertin files pro se Motion to Dismiss | #14 | Add. 232–281; 50 pages; trigger for April 29 orders | | 4/17/2025 | Hearing before Judge Hudleston | #6 | | April 17, 2025 | Omnibus hearing before Judge Hudleston | #14 | Add. 282–296; first meeting between Guertin and Hudleston | | April 21, 2025 | Guertin files Petition to Proceed Pro Se | #14 | Add. 200–231 | | April 21, 2025 | Petition to Proceed Pro Se submitted | #15 | | **4/28/2025** | **Filings #6–#7: "Attempted Assassination" and "Judicial Simulation" affidavits filed** | **#6, #7** | | April 28, 2025 | Guertin files 50 submissions (5,435 pages) into docket | #14 | Index 135–184; MCRO evidence | | 4/29/2025 | Fourth Rule 20 evaluation ordered | #12 | | April 29, 2025 | Hearing; Judge Hudleston enters Order for Competency (Rule 20) and Order Appointing Forensic Navigator | #14 | Add. 1–5; fourth Rule 20 order | | April 29, 2025 | Hamid's alleged perjury before Judge Hudleston | #15 | | May 7, 2025 | Guertin files Emergency Motion for Stay and Vacate in district court | #14 | Add. 33–66 | | May 30, 2025 | Judge Hudleston enters written order (Index 205) confirming April 29 orders | #14 | Post-filing of appellate case | | May 30, 2025 | Hudleston's order — first judge-authored metadata entry in Guertin's docket | #15 | | 6/4/2025 | Emergency Motion for Stay filed (A25-0882) | #12 | | June 4, 2025 | Guertin signs Emergency Motion for Stay Pending Appeal | #14 | This document | | June 18, 2025 | Motion filed as Doc. 115 in federal case 0:24-cv-02646-JRT-DLM | #14 | PACER stamp date | | **6/25/2025** | **Filing #12: RICO Complaint filed (121 pp., Doc. 116)** | **#12** | --- ## APPENDIX B: FINAL Unified Entity Tracker (People — All Filings #1–#25, Deduplicated) | Name | Role | Affiliation | First Seen | |---|---|---|---| | "barbj" | Metadata author (unknown) | 137 docs / 105 cases | #12 | | "burrowsp" | Metadata author | Unknown / Hennepin County | #15 | | "Dr. Alex Mercer, Ph.D." | ChatGPT-generated forensic analyst persona | ChatGPT / OpenAI | #16 | | "Former CIA welder" (Jeffrey) | Welding contractor / associate | Name redacted | #3 | | "Hansen, Isabel" | MN Judicial Branch | Metadata author of Koch's order | #12 | | "hernandezke" / "HernandezKE" | Metadata author (unknown) | 225 docs / 101 cases | #12 | | "hernandezke" | PDF metadata author | Unknown / MN Judicial Branch | #21 | | "Hines, Anne" | Metadata author (unknown) | Author of Milz and Cranbrook evals | #12 | | "lakee" | Metadata author | Unknown / Hennepin County | #15 | | "Larison, Megan D (DHS)" | Metadata author | MN DHS | #15 | | "Perry, Dolores" | Metadata author | Unknown / 4th Judicial District | #15 | | "Rachel Pederson" | Metadata author | Unknown / 4th Judicial District | #15 | | "Tom" (ChatGPT) | AI-generated forensic analyst persona | ChatGPT | #25 | | A. Bertrand | Reception / signing party | MN OLPR | #13 | | Aaron Dashaun Cherry | Authentic defendant (outlier order) | N/A | #15 | | Aaron Herman | Reporter | The Jewish Week | #16 | | Abderrahim Merouan | Patent Examiner | USPTO | #1 | | Adam A. Milz, Ph.D. | Psychologist | Hennepin County Psych Services | #1 | | Adam Savage | YouTube host | Tested | #16 | | Adam Yang | Judge | 2nd Judicial District | #20 | | Adrian Michael Wesley | Alleged synthetic defendant | 2017 cases | #6 | | Aesha/AESHA Ibrahim Osman | Synthetic defendant | N/A | #15 | | Ahn Duk-geun | Trade Minister | South Korea | #4 | | Aimee Dozois | Contributor, EGSR 2006 video | USC CCT | #16 | | Alan J. Sokol | CEO | Hemisphere Media / UPtv | #4 | | Alan Sokol | Executive | UPtv / InterMedia | #4 | | Alexander Shapiro | Co-inventor/applicant | Brodsky PCT | #4 | | Alisha Nehring | MDH Attorney | MN Dept. of Health | #12 | | Amanda Burg | Liaison / metadata author | Saint Peter State Hospital | #14 | | Amanda M. Prose | Patent Attorney | Westman Champlin & Koehler | #1 | | Amanda Prose | Patent attorney | Not specified | #22 | | Amy Dawson | Judge | 4th Judicial District (Hennepin) | #20 | | Amy Klobuchar | US Senator | Minnesota | #1 | | Amy Reinhard | VP Studio Operations | Netflix, Inc. | #1 | | Andrew Gordon | Judge | 2nd Judicial District | #20 | | Andrew Jones | Co-author, EGSR 2006 paper | USC CCT | #16 | | Andrew Reiland II | Public Defender's Office | Metadata author of Carpenter filing | #12 | | Andrew Wedeman | Academic / China Studies | Georgia State University | #19 | | Andrzej Łobaczewski | Author (quoted) | "Political Ponerology" | #16 | | Angela Tinwell | Author, "Uncanny Valley" | Academic | #5 | | Angelic Denise Nunn/Schaefer | Synthetic defendant (dual names, shared font) | N/A | #15 | | Anna Cousin | Law clerk | Clerk to Judge Bartsh, 2nd District | #20 | | Assaff Rawner | CEO | Mark Roberts Motion Control | #1 | | Bad Bunny | Artist | Coachella stage project | #23 | | Benjamin Harringa | Attorney | MN Attorney General's Office | #20 | | Bev Benson | Judge | 4th Judicial District | #20 | | Brad Pitt | Actor (MOVA capture subject) | Film | #19 | | Brandon Harris | Officer | Minnetonka PD | #1 | | Brian Miller | Contributor, EGSR 2006 video | USC CCT | #16 | | Brian O'Hara | Police Chief | Minneapolis PD | #1 | | Brian Sunderlin | VP Operations | Gentle Giant Studios | #19 | | Bridget Sullivan | Judge | 4th Judicial District | #20 | | Bruce Lamond | Co-author, EGSR 2006 paper | USC CCT | #16 | | Bruce M. Rivers | Defense counsel (defendant) | Private attorney / YouTube personality | #23, #24 | | Bruce Rivers (Bruce M. Rivers) | Defense counsel / Federal defendant | Private attorney | #1 | | Bruce Rivers | Defense Attorney (later dismissed) | Private practice ("CLR Bruce Rivers") | #1 | | Camille A. King | Unknown affiliation | Metadata author of Carpenter filing | #12 | | Carlos Fueyo | VAD Art Director | Eyeline Studios | #2 | | Carmen Bendu Greaves | Synthetic defendant | N/A | #15 | | Carolina A. Lamas | Judge | 4th Judicial District | #12 | | Carolyn Giardina | Journalist | The Hollywood Reporter | #19 | | Casey Boland, Ph.D. | Postdoctoral Fellow | Psych Services | #1 | | Cassidy Curtis | VFX professional | Debevec collaborator (Special Thanks) | #19 | | Charles-Felix Chabert | Co-author, EGSR 2006 paper | USC CCT | #16 | | Chela Guzman-Weigart | Asst. County Admin / "GuzmanC" (defendant) | Hennepin County | #23 | | Chela Guzman-Wiegert ("GuzmanC") | Asst. County Admin; CJCC member | Hennepin County | #1 | | Chris Carmack | Actor (performance relighting demo) | N/A | #25 | | Christian Sande | Judge | 4th Judicial District | #20 | | Christian Theobalt | Researcher (extensively cited in collected papers) | Max Planck / Academic | #16 | | Cokie Nagano | Researcher | USC ICT | #18 | | Cole Werner | Attorney | MN Attorney General's Office | #20 | | Connie Siu | Unknown | Debevec collaborator (Special Thanks) | #19 | | Daniel Jones | Author (quoted) | "Snake in the Grass" | #16 | | Daniel Moreno | Judge | 4th Judicial District | #20 | | Danielle C. Mercurio | Referee/Judge | 4th Judicial District | #1 | | David Brown | Judge | 2nd Judicial District | #20 | | David Fincher | Director | Film (Benjamin Button, etc.) | #19 | | Dawanna Witt | Sheriff | Hennepin County | #1 | | Dean Eyler | Judge | 4th Judicial District | #20 | | Deanne Hilgers | Judge | 2nd Judicial District | #20 | | Det. Samantha Johnson | Detective | Minnetonka PD | #2 | | Detective Samantha Johnson | Detective | Minnetonka Police Dept. | #22 | | Dr. Adam A. Milz | Evaluator (PhD, LP, ABPP) | Hennepin County Psych Services | #21, #22 | | Dr. Adam Milz | Rule 20 examiner | Hennepin County | #1 | | Dr. Alex Mercer, Ph.D. | ChatGPT-generated persona | "chatGPT Digital Forensic Investigator" (not a real person) | #17 | | Dr. Jill Rogstad | Rule 20.01 examiner | Hennepin County | #21, #22 | | Dr. Katheryn Cranbrook | Rule 20 examiner | Hennepin County Psych Services | #7 | | Dr. Martin Schuster | Psychiatrist | California (private practice) | #22 | | Dr. Michael Robertson | Examiner | Independent | #21 | | Dr. Schuster (Martin) | Psychiatrist (treating) | California (telehealth) | #1 | | Dr. Scott Ross | Co-founder | Digital Domain | #19 | | E.H. Adelson | MIT researcher (plenoptic function) | MIT | #25 | | Ed Ulbrich | Sr. VP / Executive Producer / CEO | Digital Domain / Digital Domain 3.0 | #19 | | Edward Norton | Actor (MOVA capture subject) | Film (Incredible Hulk) | #19 | | Edward Sheu | Judge | 2nd Judicial District | #20 | | Edward Thomas Wahl | Judge | 4th Judicial District | #1 | | Edward Wahl | Judge | 4th Judicial District | #20 | | Elena Ostby | Judge | 2nd Judicial District | #20 | | Elizabeth Clysdale | Judge | 2nd Judicial District | #20 | | Elizabeth Dorene Murphy | ACA | Hennepin County Attorney | #10 | | Emmett Donnelly | Defense attorney | Hennepin County | #6 | | Erin Goltz | Prosecuting Attorney | Hennepin County Attorney | #1 | | Examiner Moore | USPTO Patent Examiner | USPTO | #4 | | Francis Magill | Judge (email bounced) | 4th Judicial District | #20 | | George Borer | Referee | 4th Judicial District | #1 | | George F. Borer | Judicial Referee (defendant, individual capacity) | 4th Judicial District | #23 | | Gina Brandt | Judge | 4th Judicial District | #15 | | Gordon Eschke | Employee | Mark Roberts Motion Control | #3 | | Gordon Eugene Sharp | Synthetic defendant | N/A | #15 | | Grahm Mark Fletcher | Synthetic defendant | N/A | #15 | | Greg Hermanovick | Creator | TouchDesigner / SideFX | #2 | | Greg LaSalle | Former Rearden employee / MOVA seller | Rearden Inc. (former) | #19 | | Greg Lunt | Attorney | Greenberg Traurig LLP | #1 | | Hanna Welch | Constituent Advocate | Office of Sen. Klobuchar | #1 | | Hao Li | Director, USC ICT Vision Lab | USC ICT / Declarant in 3:17-cv-04006 | #11 | | Heather Greene | Staff | Hennepin County | #20 | | Henry LaBounta | Conference co-presenter/attendee | Unknown (visible in SIGGRAPH video) | #19 | | Henry LaBretz | Visible in SIGGRAPH PiP | Unknown | #16 | | Hilary Caligiuri | Presiding Judge, Criminal | 4th Judicial District | #1 | | Ian Milham | VP Supervisor | ILM | #2 | | Ifrah Abdullahi Hassan | Synthetic defendant (font tracking) | N/A | #15 | | Isaac Lee Kelley | Synthetic defendant (Hoopmana cluster) | N/A | #15 | | J.R. Bergen | Researcher (plenoptic function) | N/A | #25 | | Jacob Frey | Mayor | City of Minneapolis | #1 | | Jacob Kraus | Judge | 2nd Judicial District | #20 | | Jacqueline Perez | ACA — Prosecutor | Hennepin County Attorney | #1 | | Jamie Anderson | Judge | 4th Judicial District | #20 | | Jamil M. F. Masroujeh | Attorney | Hennepin County | #20 | | Jane Anderson | PR Contact | OnLive/MOVA | #19 | | Jason Nelson | Representative | Hennepin Police Chiefs Assoc. | #1 | | Jay Busch | Researcher | USC ICT | #18 | | Jay Quam | Judicial Officer | 4th Judicial District | #1 | | Jeff Bridges | Actor (MOVA capture subject) | Film (TRON: Legacy) | #19 | | Jeremy Reiss | Executive VP | Henry Street Settlement | #8 | | Jill E. Rogstad, Ph.D. | Sr. Clinical Forensic Psychologist | 4th Judicial District Psych Services | #1 | | Joel Fisher | Civil commitment attorney | Private practice | #1 | | John Guthmann | Judge | 2nd Judicial District | #20 | | John Williams | Conductor | Hollywood Bowl event | #23 | | Jon Karafin | Head of Light Field Video | Lytro | #18 | | Joseph Klein | Judge | 4th Judicial District | #20 | | Joseph Nicéphore Niépce | Historical figure (first photograph) | N/A | #25 | | Joy Bartscher | Judge | 2nd Judicial District | #20 | | Judge John S. Tigar | Federal Judge | U.S. District Court, N.D. Cal. | #19 | | Judith L. Cole | Sr. ACA | Hennepin County Attorney | #10 | | Jules Urbach | Founder/CEO | OTOY | #18 | | Julia Dayton Klein | Judge | 4th Judicial District | #1 | | Julia Dayton-Klein | Judge (defendant, individual capacity) | 4th Judicial District | #23 | | Karen Janisch | Judge | 4th Judicial District | #20 | | Karen Thoele | Approving Officer (Badge #671040) | Minnetonka Police Department | #17 | | Katheryn Cranbrook | Rule 20 examiner | Hennepin County Psych Services | #7 | | Katsunori Ishikawa | Contributor, EGSR 2006 video | USC CCT | #16 | | Katy Perry | Performer | Hollywood Bowl event | #23 | | Keith Ellison | Attorney General | State of Minnesota | #12 | | Keith Moore, RN | Nurse | Hennepin County | #1 | | Kellie Charles | Judge | 2nd Judicial District | #20 | | Kelly Olmstead | Judge | 2nd Judicial District | #20 | | Kerry Meyer | Chief Judge | 4th Judicial District | #1 | | King Salman bin Abdulaziz | Saudi monarch | Diriyah inauguration | #23 | | Kristen Marttila | Judge | 4th Judicial District | #20 | | Kristen Otte | Listed evaluator (Odyssey) | Hennepin County Psych Services | #6 | | Krystal Beauchane | Officer | Plymouth PD | #1 | | Kuberski, Virginia | PDF metadata author | MN Judicial Branch | #22 | | Laura Nelson | Judge | 2nd Judicial District | #20 | | Laura Sydell | Journalist | NPR | #19 | | Laurie Miller | Judge | 4th Judicial District | #20 | | Lea De Souza | Assistant County Attorney | Hennepin County Attorney's Office | #21 | | Lea DeSouza | ACA (civil) | Hennepin County Attorney | #1 | | Lee Cuellar | Judicial Clerk | Clerk to Judge Klein | #6 | | Leo Hindery | Media executive | InterMedia Partners | #18 | | Leonardo Castro | Judge | 2nd Judicial District | #20 | | Lesley Stahl | Correspondent | CBS 60 Minutes | #18 | | Lianette Alnaber | Unknown | Debevec collaborator (Special Thanks) | #19 | | Lisa K. Janzen | Judge | 4th Judicial District | #12 | | Lois (Regnier) Conroy | Judge | 4th Judicial District | #20 | | Lucas Patrick Kraskey | Synthetic defendant (most frequent) | N/A | #15 | | Luis Bartolomei | Judge (email bounced) | 4th Judicial District | #20 | | Lyonel Norris | Referee | 4th Judicial District | #1 | | Maj. Gen. Joe Brendler | U.S. Army (Ret.) | Forcepoint endorser | #8 | | Makis D/Devell Lane | Synthetic defendant | N/A | #15 | | Maria Mitchell | Judge | 2nd Judicial District | #20 | | Mark Bolas | Co-author, EGSR 2006 paper | USC CCT | #16 | | Mark Graham | Director, Wayback Machine | Internet Archive | #8 | | Mark Ireland | Judge | 2nd Judicial District | #20 | | Mark Kappelhoff | Judge | 4th Judicial District | #20 | | Mark Lanterman | Computer forensics professional | Computer Forensics | #22 | | Mark M. Friedman, Dr. | Attorney | Brodsky patent applicant | #4 | | Mark Roberts | CEO | mrmoco.com / Mark Roberts Motion Control | #1 | | Mark S. Carlson | Attorney | Hagens Berman Sobol Shapiro LLP | #19 | | Marta Chou | Judge | 4th Judicial District | #20 | | Martha Stout | Author (quoted) | "The Sociopath Next Door" | #16 | | Mary F. Moriarty | County Attorney | Hennepin County | #4 | | Mary Moriarty | County Attorney (defendant) | Hennepin County | #23 | | Mary Thomas | Report printer | Minnetonka Police Department | #17 | | Matthew David Guertin (Matt Guertin) | Plaintiff / Author of analysis | InfiniSet, Inc. / Pro Se | #25 | | Matthew David Guertin | Defendant / Pro Se / CEO-Inventor | InfiniSet, Inc. | #1 | | Matthew Frank | Judge | 4th Judicial District | #20 | | Matthew Lloyd Robert Messerli | Attorney | Hennepin County | #20 | | Mawerdi Ahmed Hamid | ACA | Hennepin County Attorney | #4 | | Mawerdi Hamid | ACA | Hennepin County Attorney | #4 | | Max Igan | Interviewer/media | BitChute/Rumble | #10 | | Megan Neumann | Patent Attorney / Paralegal | Westman Champlin & Koehler | #2 | | Michael Berger | Chief Public Defender | Hennepin County | #12 | | Michael Biglow | Court-appointed attorney | Biglow Law Offices | #3 | | Michael Browne | Judge | 4th Judicial District | #1 | | Michael Robertson | Examiner (image count discrepancies) | Not specified | #23 | | Michael Robertson, Psy.D. | Independent Examiner | Private practice | #1 | | Michelle Guertin | Petitioner's mother | N/A | #14 | | Mordechai Americus | Attorney | Brodsky patent applicant | #4 | | Morgan Spurlock | CNN host | CNN "Inside Man" | #18 | | Nadia Garavito | Court staff | Hennepin County (initial commitment proceedings) | #13 | | Nancy Mertzel | IP Attorney | Herrick Feinstein (NYC) | #19 | | Nelson Peralta | Judge | 4th Judicial District | #20 | | Nigel Denton-Howes | VP | Eyeline Studios | #2 | | Norman Chan | Interviewer/journalist | Tested.com / Adam Savage | #18 | | O.D. Welch | President | Digital Domain 3.0 | #19 | | Officer Brandon Harris | Officer | Minnetonka Police Dept. | #22 | | Olson, Julie | PDF metadata author | Unknown (appellate court) | #22 | | Patrick Diamond | Judge | 2nd Judicial District | #20 | | Paul Debevec | Professor/Researcher / VP SIGGRAPH (2008–2011) | USC ICT / Netflix-Eyeline | #1 | | Paul Scoggin | Judge | 4th Judicial District | #20 | | Per Einarsson (et al.) | USC ICT researchers | USC | #5 | | Per Einarsson | Lead author, EGSR 2006 paper | USC CCT | #16 | | Peter Plantec | Animation author/expert | Independent | #5 | | Philip Dutré | Researcher (wavelet noise reflectance) | Referenced in Debevec paper | #25 | | Pieter Peers | Researcher (wavelet noise reflectance) | Referenced in Debevec paper | #25 | | Pieter Peers, PhD | Computer Graphics Scientist | Academic | #18 | | Pinchas Gutter | Holocaust survivor / subject of alleged deepfake | USC Shoah Foundation NDT project | #16 | | Pradeep Sen | Researcher (dual photography) | Referenced in Debevec paper | #25 | | Prentice DannerIII | FBI Spokesperson | FBI | #19 | | Prince Mohammed bin Salman | Saudi Crown Prince | Diriyah inauguration | #23 | | Raissa Carpenter | Public Defender | Hennepin County | #6 | | Randal Kleiser | Director (performance relighting demo) | N/A | #25 | | Reg Thompson | Officer (corporate) | Eyeline Studios, Inc. (NV) | #2 | | Reynaldo Aligada | Judge | 2nd Judicial District | #20 | | Richard Kyle | Judge | 2nd Judicial District | #20 | | Rio S. Pierce | Attorney | Hagens Berman Sobol Shapiro LLP | #19 | | Robert Sorensen | Private attorney | Not specified | #6 | | Robyn Millenacker | Judge | 2nd Judicial District | #20 | | Rodrick Jerome Carpenter | Synthetic defendant | N/A | #15 | | Sandra P. Vongsaphay | Alleged synthetic defendant | Case 27-CR-23-2480 | #6 | | Sara Gonsalves | Court Administrator | 4th Judicial District | #1 | | Sara Grewing | Judge | 2nd Judicial District | #20 | | Sarah Hudleston | Judge | 4th Judicial District (current trial judge) | #4 | | Sarah West | Judge | 4th Judicial District | #20 | | Scott Miller | COO | Eyeline Studios | #1 | | Scott Squires | VES Visual Effects Supervisor | Visual Effects Society | #18 | | Sebastian Sylwan | Co-author, EGSR 2006 paper | USC CCT | #16 | | Shawn Bartsh | Judge | 2nd Judicial District (confirmed) | #20 | | Shereen Askalani | Judge | 4th Judicial District | #10 | | Skip Rizzo | Researcher | USC ICT | #18 | | Sophia Vuelo | Judge | 2nd Judicial District | #20 | | Stephan Trojansky | Inventor / CEO | Scanline VFX / Eyeline Studios | #1 | | Stephen Smith | Judge | 2nd Judicial District | #20 | | Stephen Zager | Officer (corporate) | Eyeline Studios, Inc. (NV) | #2 | | Steve Jelley | Co-founder / Joint MD | Dimension Studios | #2 | | Steve Perlman | Inventor (MOVA Contour) | Rearden LLC | #2 | | Steve W. Berman | Attorney | Hagens Berman Sobol Shapiro LLP | #19 | | Steven M. Koehler | Shareholder | WCK Law Firm | #3 | | Susan Burke | Judge | 4th Judicial District | #20 | | Susan Herlofsky | Public Defender | Hennepin County | #6 | | Susan Humiston | Director, OLPR | Minnesota Office of Lawyers Professional Responsibility | #13 | | Susan Robiner | Judge | 4th Judicial District | #20 | | Ted Sarandos | Executive (certified mailer reference) | Netflix | #16 | | Terrell Johnson | Synthetic defendant | N/A | #15 | | Thomas Conley | Judge | 4th Judicial District | #20 | | Thomas Franklin Manewitz | ACA (Lead) | Hennepin County Attorney | #10 | | Thomas Gilligan | Judge | 2nd Judicial District | #20 | | Thomas Prochazka | Attorney | Unknown affiliation | #14 | | Tim Hawkins | Co-author, EGSR 2006 paper | USC CCT | #16 | | Tim Roth | Actor (MOVA capture subject) | Film (Incredible Hulk) | #19 | | Tim Walz | Governor | State of Minnesota | #12 | | Timothy Carey | Judge | 2nd Judicial District | #20 | | Timothy Mulrooney | Judge | 2nd Judicial District | #20 | | Todd Fellman | Presiding Juvenile Judge | 4th Judicial District | #12 | | Toddrick Barnette | Judge | 4th Judicial District | #1 | | Tom Arneson | ACA | Hennepin County Attorney | #1 | | Tom Daschle | Political figure | InterMedia Advisors | #4 | | Tom Prochazka | ACA | Hennepin County Attorney | #1 | | Tomas Akenine-Möller | Editor, EGSR 2006 | Academic | #16 | | Tomas Pereira | Contributor, EGSR 2006 video | USC CCT | #16 | | Toni Pace Carstensen | VES Chair, Vision Committee | Visual Effects Society | #18 | | Trojansky | Patent applicant (certified mailer reference) | Netflix / Scanline VFX | #16 | | Unnamed "CIA welder" | Welder/associate | Self-professed CIA/military | #22 | | Veena Iyer | Judge | 2nd Judicial District | #20 | | Virginia Kuberski | Metadata author | Unknown / 4th Judicial District | #15 | | Wan-Chun Ma | Co-author, EGSR 2006 paper | National Taiwan University | #16 | | Warsame Ali | Private attorney | Not specified | #6 | | William H. Koch | Judge | 4th Judicial District | #10 | | Wolfgang Heidrich | Editor, EGSR 2006 | Academic | #16 | | Yoav Schechner | Researcher (multiplexed illumination) | Referenced in Debevec paper | #25 | | Yu Jeong-yeol | KOTRA President | Korea Trade-Investment Promotion Agency | #4 | | Yuval Brodsky | Patent applicant / Inventor | Newton VR Ltd., Tel Aviv | #1 | | Z. Peter Sawicki | Attorney | WCK Law Firm | #3 | --- ## APPENDIX C: FINAL Unified Key Documents Referenced (All Filings #1–#25, Deduplicated) | Document | Date | Type | First Seen | |---|---|---|---| | "23-815 Guertin – photos of exterior, interior, person 1.21" (80-photo PDF from Biglow) | 8/3/2023 | Discovery photographs | #13 | | "Oscar SciTech Award 2015 for Mova Contour" (Av9bPvUyjkE) | 2015 | YouTube video | #19 | | "Relighting Character Motion" (2006) | Mid-2006 | Purported academic paper / DTIC tech report | #5 | | "Relighting Human Locomotion Using Flowed Reflectance Fields" (Debevec, claimed 2006) | Claimed 2006 | Academic paper (alleged fabrication) | #5 | | "Relighting Human Locomotion with Flowed Reflectance Fields" (EGSR 2006) | 2006 | Academic paper | #16 | | "Relighting Human Locomotion" (2006) | Mid-2006 | Purported academic paper | #5 | | "The Light Stage With Paul Debevec - 360 Video" (Jaunt) | January 18, 2018 | Online video (screencaptures used as evidence) | #25 | | "Virtual Cinematography" (IEEE, 2006) | Mid-2006 | IEEE Computer magazine article | #5 | | "Why Everyone Is Fighting To Get This VFX Tool" (ryL-G9lbanY) | N/A | YouTube video | #19 | | 04_CASE_listed-attorneys.csv | N/A | Forensic dataset | #14 | | 06_MCRO_2024-05-03-affidavit-figures.csv | N/A | Verification dataset | #14 | | 07_MCRO_digital-signature-report.csv | N/A | Forensic dataset | #14 | | 08_MCRO_files-with-no-signature.csv | N/A | Forensic dataset (16 unsigned files) | #14 | | 09_MCRO_file-metadata.csv | N/A | Master metadata table | #14 | | 116-page Ethics Complaint (Bruce Rivers) | 9/25/2024 | Filed with MN OLPR | #10 | | 60–90 Day Report | 10/30/2023 | Positive compliance report | #7 | | Aaron Cherry December 11, 2023 clone | 12/11/2023 | Fraudulent clone overwriting authentic order | #15 | | Aaron Cherry December 6, 2023 authentic order | 12/6/2023 | Original incompetency order (author: Apker, MB) | #15 | | ADA481779_MIL_PDF.pdf | N/A | Military document | #16 | | Affidavit of Fact (Exh. C, 213 pp.) | 4/9/2024 | Pro se affidavit | #23 | | AI Artboards save1.pdf (424 MB) | Jul. 6, 2023 | Competency hearing presentation (never presented) | #17 | | AI_CHECKERBOARD_ARTIFACTS__ATSIP_2019_2.pdf | 2019 | Academic paper on AI artifact detection | #16 | | Alisha-Nehring_Amanda-Burg__CASE-OVERLAP.csv | N/A | Forensic dataset (23-docket overlap) | #14 | | Application 16/329,231 (Brodsky) | 2/28/2019 | USPTO application | #4 | | April 12, 2024 — Klein's "Order Denying Petition to Proceed Pro Se" | 4/12/2024 | Order (metadata: Rachel Pederson) | #15 | | April 16, 2025 Motion to Dismiss | 4/16/2025 | Pro se motion (Guertin) | #14 | | April 21, 2025 Petition to Proceed Pro Se | 4/21/2025 | Pro se petition (Guertin) | #14 | | April 28, 2025 Evidence Submissions (Index 135–184) | 4/28/2025 | 50 pro se filings, 5,435 pages | #14 | | April 29, 2025 Order Appointing Forensic Navigator | 4/29/2025 | Court order (Hudleston) | #14 | | April 29, 2025 Order for Competency to Proceed (Rule 20.01) | 4/29/2025 | Court order (Hudleston) | #14 | | April 3, 2025 Order Finding Competent to Proceed | 4/3/2025 | Court order (Koch) | #14 | | Archive.today capture of ls6-usc_ict-inside.jpg | January 18, 2013 | Archived web image | #25 | | August 7, 2024 Motion | 8/7/2024 | Federal motion (basis for ChatGPT analysis) | #20 | | AWN "Arming Percy Jackson" article | N/A | News article | #19 | | Boston Globe "Crossing the Uncanny Valley" blog post | Jul. 31, 2006 | Blog post (Wayback archived) | #19 | | Bruce Rivers Federal Summons (24-cv-02646, Doc. 4) | 7/8/2024 | Federal summons | #13 | | Carpenter's synthetic case assignments | Various | 16 synthetic felony dockets | #15 | | CBS 60 Minutes Pinchas Gutter segment | 4/5/2023 | Broadcast / YouTube | #18 | | CBS News Article: "Is 'digital cloning' the future..." | Claimed 6/2/2014 | News article | #18 | | CGW "Heavy-Handed" (Incredible Hulk VFX) | Jul. 2008 | Trade publication article | #19 | | ChatGPT Analysis of Bruce Rivers | ~8–9/2024 | AI-generated analysis | #20 | | ChatGPT Conversation Transcript (Index 05) | ~October 2023 | AI chat log re: incident analysis | #18 | | ChatGPT Digital Forensic Analysis Reports (Case 2024-DF-002) | June 8, 2024 | AI-generated analysis reports | #25 | | ChatGPT Forensic Report 01-1 (PhotoRobot Catalog Image Analysis) | Sep. 29, 2024 | AI-generated analysis | #17 | | ChatGPT Forensic Report 01-2 (PhotoRobot YouTube Video Analysis) | Sep. 29, 2024 | AI-generated analysis | #17 | | Clerk's Entry of Default (Doc. 71, 0:24-cv-02646) | 8/29/2024 | Federal default entry as to Bruce Rivers | #20 | | Court Order — Competency (Mar 5, 2025) | 3/5/2025 | Competent but mental illness maintained | #8 | | Cranbrook Rule 20 Report | 12/20/2024 | Competency eval (metadata: "Hines, Anne") | #12 | | Criminal Complaint 27-CR-23-1886 | 1/24/2023 | Charging document | #1 | | Data_Analysis_Fraud.zip | 1/14/2023 | Compiled fraud evidence | #22 | | Debevec 2002 — "The Light Stage" (Google Scholar) | 2002 | Academic paper | #19 | | Debevec 2003 — "Computer Graphics with Real Light" (Google Scholar) | 2003 | Academic paper | #19 | | Debevec et al., "Relighting Human Locomotion with Flowed Reflectance Fields," Eurographics 2006 | 2006 | Academic paper (referenced, Figure 2 reproduced in Index 02 p. 16) | #25 | | Debevec, "Virtual Cinematography: Relighting through Computation," IEEE Computer, Aug. 2006 | August 2006 | Academic paper (reproduced in full as Index 03) | #25 | | Debevec-2006-Patents-vs-Claimed-2006-Research.jpg | N/A | Comparison image | #16 | | Declaration of Hao Li (3:17-cv-04006, Doc. 139.7) | N/A | Federal declaration (defense research) | #11 | | Demand or Request for Discovery (Jan 5, 2024) | 1/5/2024 | Pro se motion | #13 | | Detection_of_AI_generated_Synthetic_Faces__2022.pdf | 2022 | Academic paper | #16 | | Digital Complaint / Exhibit Q (Doc. 24) | 7/16/2024 | Digital duplicate of complaint | #23 | | Digital Forensic Analysis Report 02 — LS6RHL Analysis | 9/29/2024 | ChatGPT-generated forensic report | #16 | | Digital Forensic Analysis Report 03 — Pinchas Gutter Analysis | 9/29/2024 | ChatGPT-generated forensic report | #16 | | Doc. 19 (federal case, Exhibit L, 40 pages, filed 7/12/2024) | July 12, 2024 | Federal filing containing this exhibit | #25 | | Doc. 43 (federal case, 196 pages, filed 8/7/2024) | 8/7/2024 | Federal filing containing Milz report | #24 | | Doc. 74 (0:24-cv-02646) | ~8/2024 | Federal filing (referenced as "last filing") | #20 | | Dr. Schuster Letter | 4/7/2023 | Clinical letter (rebuttal to Rogstad) | #1 | | Edge Online "Codeshop: The Faceplanters" | 2008 (archived) | Trade publication article | #19 | | Egsr2006_Rhl.pdf | 2006 | Academic paper (source of analyzed frames) | #16 | | Entry of Default against Bruce Rivers (24-cv-02646) | 8/29/2024 | Clerk's entry | #13 | | Exhibit AB (Doc. 78) | 9/26/2024 | Video/screenshot exhibit | #24 | | Exhibit S (referenced in Doc. 78 footers) | Unknown | Cross-referenced exhibit | #24 | | Exhibit Y (24-cv-02646) — Discovery fraud "no defense" analysis | 9/2/2024 | Federal exhibit | #13 | | Exhibit Z (24-cv-02646) — ChatGPT analysis of Rivers failures | 9/9/2024 | Federal exhibit | #13 | | Exhibit Z (Doc. 75, 0:24-cv-02646) | 9/9/2024 | Federal exhibit (138 pp.) | #20 | | FBI IC3 Complaint | 5/3/2023 | Federal report | #1 | | Feb 20, 2025 Email: "Discovery Fraud Analysis Complete" | 2/20/2025 | Email to counsel (Add. 110–112) | #14 | | Federal Complaint (0:24-cv-02646-JRT-DLM) | 7/8/2024 | Civil rights complaint | #8 | | Federal Complaint (0:24-cv-02646-JRT-DLM, Doc. 21) | 7/12/2024 | Federal complaint with exhibits | #8 | | Findings of Fact, Conclusions of Law and Order Regarding Competency (Index #25) | 1/16–17/2024 | Court order (metadata: "barbj") | #21 | | Follow-Up Correspondence (Index #36, criminal case) | 5/3/2024 | Pro se correspondence | #21 | | Fraudulent-Pinchas-Gutter-Audio-Analysis.mp4 | N/A | Audio analysis video | #16 | | FTC Report #159606444 | 5/3/2023 | Federal report | #1 | | FTC Report | May 3, 2023 | Federal report | #1 | | Google LaMDA Paper (arXiv:2201.08239) | 1/20–2/10/2022 | Academic paper ("Infiniset" dataset) | #1 | | Guertin - HCSO CLU - Photos #23-0098.iso | 7/16/2024 | ISO file (police photographs) | #22 | | Guertin 2019 W-2 (Wage and Income Transcript) | 2019 | Tax document ($218,385) | #22 | | Guertin Provisional Patent Application (Dropbox link) | ~March 27, 2021 | Provisional patent filing (17 pages) | #18 | | Guertin T-Mobile cell phone records | 8/2024 | Carrier records (usage overview) | #20 | | Guertin-to-Internet Archive email (Removal Policy Information) | Dec. 15, 2022 | Email correspondence | #17 | | Guertin-to-Rivers emails (Unethical behavior?, my FBI report) | Jun. 16, 2023 | Email correspondence (2 emails) | #17 | | Guertin/InfiniSet Patent (US 11,577,177) | 2/14/2023 | Granted patent | #16 | | Hollywood Reporter "Advances sure to capture attention at Siggraph" | Aug. 3, 2007 | News article | #19 | | Hollywood Reporter "Contour mapping intricate detail" | Jul. 31, 2006 | News article | #19 | | Hollywood Reporter "Digital Domain Mova Tech Banned" | 2017 | News article | #19 | | Hollywood Reporter "emotion motion" article | Sep. 26, 2006 | News article | #19 | | Holocaust_10_26_2023.mp4 | 10/26/2023 | Evidence video | #16 | | IL265092A (Israeli priority — missing) | Referenced | Priority document (not locatable) | #4 | | Incompetency Order (1st — Borer/Browne) | 7/13/2023 | Court order | #1 | | Incompetency Order (2nd — Mercurio/Klein) | 1/17/2024 | Court order (metadata: "barbj") | #1 | | InfiniSet Demo Video (Dropbox link) | ~March 2021 | Technology demonstration | #18 | | InfiniSet Patent Summary (custom formatted) | N/A | Guertin-created summary | #19 | | InfiniSet Patent US 11,577,177 | 2/14/2023 | Granted patent | #23 | | Interlocutory Appeal (8th Cir. 24-2662) | 2024 | Appeal | #13 | | January 2025 Email Exchanges w/ Defense Counsel | 1/2025 | Email correspondence (Add. 297–320) | #14 | | July 16, 2024 Discovery USB Materials | 7/16/2024 | USB drive with 49 files | #22 | | June 14, 2023 Order for Continuance (Index #16) | 6/14/2023 | Order w/o corresponding motion (metadata: "Nehring, Alisha"; title: "Adrian Wesley") | #10, #12 | | Klein's fee waiver denials (May 24 & 30, 2024) | 5/24–30/2024 | Order denying fee waiver (metadata: Virginia Kuberski) | #15 | | Klein's November 15, 2023 Rule 20 order | 11/15/2023 | Rule 20 evaluation order (metadata: Perry, Dolores) | #15 | | Light Stage 6 Relighting Human Locomotion480p.mp4 | N/A | Original source video | #16 | | LinkedIn Search Notification Emails (6 entities) | 4/16/2022–9/28/2023 | Email/HTML screenshots | #18 | | LS6RHL1_01_20-sequential-frames.jpg | N/A | Image grid analysis exhibit | #16 | | LS6RHL1_02_Segmentation-sets.jpg | N/A | Image grid analysis exhibit | #16 | | LS6RHL2_02_30-sequential-frames.jpg | N/A | Image grid analysis exhibit | #16 | | LS6RHL2_04_Digital-Region-Shifting.jpg | N/A | Image grid analysis exhibit | #16 | | LS6RHL__FrameScrubbing1.mp4 | N/A | Video analysis source | #16 | | LS6RHL__FrameScrubbing2.mp4 | N/A | Video analysis source | #16 | | Mass judicial email campaign (57 emails) | 9/6/2024 | Emails to MN 4th & 2nd District judges | #20 | | MAXQDA_Analysis.pdf | N/A | Qualitative analysis output | #16 | | May 30, 2025 Written Order (Index 205) | 5/30/2025 | Court order (Hudleston) | #14 | | May 7, 2025 Emergency Motion for Stay and Vacate | 5/7/2025 | Pro se motion (Guertin) | #14 | | MCRO Analysis Affidavit (Index #37) | 5/3/2024 | 31-page pro se analysis | #10 | | MCRO Analysis Affidavit (Index 37) | 5/3/2024 | Pro se analysis | #23 | | Milz Rule 20 Report | 1/11/2024 | Competency eval (metadata: "Hines, Anne") | #9 | | Milz Rule 20.01 Exam Report | 1/11/2024 | Competency evaluation | #23, #24 | | Minnetonka PD Report #23-000151 (MP23000151) | Jan. 12, 2023 | Police report | #1 | | Minnetonka PD Report #23-000151 | 1/12/2023 | Police report | #1 | | MN Court of Appeals Case A24-0780 | 5/10–31/2024 | Appellate petition/filings | #21, #22 | | MN OLPR Complaint Against Bruce M. Rivers (Exhibit AA, Doc. 77) | 9/24/2024 | Ethics complaint / Federal exhibit | #13 | | Motion for Continuance (Index #36, civil case) | 1/30/2024 | Pro se motion | #21 | | Motion for Judicial Notice (Exh. B, 271 pp.) | 4/3/2024 | Pro se motion | #23 | | Motion for Preliminary Injunction (24-cv-02646) | 8/7/2024 | Federal motion | #13 | | Motion for Production of Medical Records (Index #37, civil case) | 1/30/2024 | Pro se motion | #21 | | Motion for Substitute Counsel (Index #91) | 6/3/2024 | Pro se motion | #21 | | Motion for Substitute Counsel (Jun 3, 2024) | 6/3/2024 | Pro se motion | #9, #13 | | Motion to Compel Discovery (Apr 4, 2024) | 4/4/2024 | Pro se motion w/ forensic analysis | #13 | | Motion to Compel Discovery (Exh. A, 40 pp.) | 4/4/2024 | Pro se motion | #23 | | Motion to Compel Production of Medical Records (Index #43, civil case) | 4/4/2024 | Pro se motion | #21 | | MOVA Contour Reality Capture Overview (Vimeo 424337703) | N/A | Vimeo video | #19 | | MOVA John Carter Press Release | Mar. 9, 2012 | Press release | #19 | | MOVA/Gentle Giant SIGGRAPH 2007 Press Release | Aug. 6, 2007 | Press release | #19 | | Netflix Patent US 11,810,254 | 11/7/2023 | Granted patent | #23 | | Netflix Q1 2022 Shareholders Letter | 4/19/2022 | Corporate filing | #1 | | Notice of Remote Zoom Hearing (Index #26) | 1/16/2024 | Court notice (metadata: "hernandezke") | #21 | | NPR "Building The Curious Faces" article | Feb. 17, 2009 | News article | #19 | | Order for Continued Stayed Commitment (Index #41) | 2/1/2024 | Court order (Borer/Klein) | #21 | | Order of Civil Commitment | 7/20/2023 | Court order (27-MH-PR-23-815) | #3 | | Order-Other (3).pdf (Mercurio, "Conservator") | 7/13/2023 | Court order — wrong case type on USB | #22 | | Original Federal Complaint (paper, Doc. 1 or initial docket entry) | 7/8/2024 | Federal complaint (paper original) | #23 | | Original PhotoRobot 'Virtual Catwalk' Brochure - En (Substack-hosted PDF) | Undated | Product brochure | #17 | | Original PhotoRobot Catalog - En (Substack-hosted PDF) | Undated | Product catalog | #17 | | OTOY GTC 2013 — "Convergence of Cinema and Games" (etoS6daj20c) | 2013 | YouTube video | #19 | | PBS Frontline Article: "How Technology Helps Preserve..." | Claimed 2019 | News article | #18 | | PCT WO2018/042442 (Brodsky/Newton VR) | 3/8/2018 | International application | #4 | | Phone Call Log (Guertin–Rivers, 2022–2024) | 11/11/2022–1/28/2024 | Communications record | #18 | | PhotoRobot "Digital Fashion Shows on the Virtual Catwalk" (YouTube) | Uploaded Jan. 28, 2016 | Video (cited as prior art on patent) | #17 | | PhotoRobot "Virtual_Catwalk—Introduction (short version)" (YouTube) | Uploaded Dec. 30, 2012 | Video (cited as prior art on patent) | #17 | | PhotoRobot "Walking belt video shooting—behind the scenes timelapse" (YouTube) | Uploaded Oct. 23, 2012 | Video (cited as prior art on patent) | #17 | | Pinchas-Grid_01 through _04 (.jpg series) | N/A | Image grid analysis exhibits | #16 | | Pinchas-Gutter-Ai-Fraud-Color-Curve-Scrub-Analysis-01.mp4 | N/A | Video analysis | #16 | | Plymouth PD Report #23033797 | 9/7/2023 | Police report | #1 | | Presentation3.pdf (1.2 GB) | Jul. 6, 2023 | Competency hearing presentation (never presented) | #17 | | Rawner-to-Guertin email (RE: Coordinate space alignment concept) | Oct. 31, 2022 | Email correspondence | #17 | | Rearden LLC v. Disney (3:17-cv-04006) | Jul. 17, 2017 | Federal case (previously referenced) | #1 (expanded #19) | | Rearden LLC v. Walt Disney Co. (3:17-cv-04006) | 7/17/2017 | Federal complaint | #1 | | Rearden v. Disney Complaint (3:17-cv-04006) | Jul. 17, 2017 | Federal complaint (307 pp.) | #19 | | Request for Entry of Default (corrected) against Rivers | 8/18/2024 | Federal filing | #13 | | RICO Complaint (Doc. 116, 0:24-cv-02646) | 6/25/2025 | Federal RICO complaint (121 pp.) | #12 | | Rivers Certificate of Representation (Index #10) | 2/20/2023 | Certificate | #13 | | Robertson Examiner's Report (27-MH-PR-23-815) | 8/4/2023 | Independent exam | #1 | | Rogstad Forensic Evaluation Report | 3/10/2023 | Rule 20.01 report (metadata: "GuzmanC") | #1 | | Rogstad Rule 20.01 Exam Report | 3/10/2023 | Competency evaluation | #23 | | Rule 20 Evaluation Report.pdf (Milz, via Hines) | 1/11/2024 | Evaluation report (metadata: "Hines, Anne") | #22 | | Rumble backdating analysis video (v449oyx) | N/A | Rumble video | #19 | | Scanline VFX Job Postings (~20 positions) | 3/20/2023 | Lever job board screenshots | #18 | | Second Follow-Up Correspondence (Index #92) | 6/3/2024 | Pro se correspondence | #21 | | Second Motion to Compel Discovery (Index #90) | 6/3/2024 | Pro se motion | #21 | | SF Business Times "Bay Area inventor" article | Mar. 1, 2009 | News article | #19 | | Show_and_Tell - FRAUD AT INTERNET ARCHIVE.pdf | Dec. 28, 2022 | Evidence presentation | #17 | | SIGGRAPH 2023 Video — Debevec "Full Spectrum of Virtual Production" | May 17, 2023 | YouTube video (tMpg29Vc0bU) | #19 | | Simply_Adjusting_Color_Curves_Proves_AI.mov | Apr. 28, 2023 | Video analysis file | #17 | | State v. Vagle, 999 N.W.2d 909 (Minn. Ct. App. 2023) | 2023 | Case law (constitutional vagueness of § 609.667(3)) | #13 | | Stayed Order of Commitment | 8/4/2023 | Court order | #3 | | Text Message Log (Guertin–Rivers, 2020–2024) | 5/25/2020–6/6/2024 | Communications record | #18 | | Text message thread (Guertin–Rivers) | 7/16–8/29/2024 | Cell phone screenshots | #20 | | Therasense v. Becton Dickinson (Fed. Cir. 2011) | 2011 | Case law (inequitable conduct) | #5 | | TimeSequence_All.pdf | N/A | 778 MB analysis document | #16 | | Trojansky/Netflix Patent (US 11,810,254) | 11/7/2023 | Granted patent | #16 | | UK SFO Report | 5/19/2023 | Fraud complaint | #3 | | US Patent 11,383,062 (Brodsky/Newton VR) | 7/12/2022 | Granted patent | #1 | | US Patent 11,577,177 (Guertin/InfiniSet) | 2/14/2023 | Granted patent | #1 | | US Patent 11,577,177 B2 | Feb. 14, 2023 | Granted patent | #1 | | US Patent 11,810,254 (Trojansky/Netflix) | 11/7/2023 | Granted patent | #1 | | US Patent 7,548,272 B2 (Perlman et al. — MOVA phosphor capture) | Jun. 16, 2009 | Granted patent | #19 | | US Patent 8,988,599 (Debevec, 2015) | 2015 | Granted patent (alleged post-2021 insertion) | #5 | | US Patent App 17/709,126 (Trojansky) | 3/30/2022 | Patent application | #1 | | US Patent App 18/108,858 (Guertin continuation) | 2/13/2023 | Patent application | #1 | | USB Flash Drive Discovery (518 images from Rivers' office) | 7/16/2024 | Discovery materials | #13 | | USC Shoah Foundation iWitness Launch Article | 4/2021 | Institutional announcement | #18 | | Using_Frequency_Analysis_to_identify_Deep-Fake_Images__2023.pdf | 2023 | Academic paper | #16 | | Vail Place compliance letter (27-MH-PR-23-815) | ~Oct/Nov 2024 | Positive completion report | #15 | | VES 2015 Conference — Part 1: Paul Debevec (Raw-VVmaXbg) | 2015 (alleged) | YouTube video | #19 | | VES 2015 Conference — Part 2: Mark Bolas (ftZd6h-RaHE) | 2015 (alleged) | YouTube video | #19 | | VES 2015 Conference — Part 3: Jules Urbach (0LLHMpbIJNA) | 2015 (alleged) | YouTube video | #19 | | VES 2015 Conference — Part 4: Jon Karafin (_PVok9nUxME) | 2015 (alleged) | YouTube video | #19 | | Videos 1–4 (Guertin multi-camera evidence recordings) | 12/18–12/23/2023 | Self-recorded evidence sessions (4K/60fps) | #18 | | VOA Article: "Tech Enables Holocaust Survivors..." | Published date disputed | News article | #18 | | Waiver (Index #38, civil case) | 1/31/2024 | Waiver form | #21 | | Waiver (stayed commitment extension) | 1/31/2024 | Waiver form | #1 | | WCK Termination Letter (Koehler) | 8/16/2023 | Attorney withdrawal | #3 | | Weinhoffer v. Davie Shoring (5th Cir. 2022) | 2022 | Case law (Wayback Machine reliability) | #8 | | WIPO Trademark Certificate #1,739,675 | 6/1/2023 | International trademark | #1 | | Wired "Beowulf F/X Masters" article | Oct. 23, 2007 | News article | #19 | | Zoom recording — "Milz Incoming Text Edition" | 1/3/2024 | Edited video evidence | #24 | | Zoom recording — Jan. 3, 2024 Rule 20.01 exam (full) | 1/3/2024 | Video evidence | #24 | --- ## CONSOLIDATED BATCH LOG | Batch | Processing Date | New Filings | Range | Source PDF(s) | Cumulative | |---|---|---|---|---|---| | 1 | 2026-03-06 | 1 | #1 | Motion for Judicial Notice (271 pp.) | 1 | | 2 | 2026-03-06 | 1 | #2 | Affidavit of Fact — May 6, 2024 (148 pp.) | 2 | | 3 | 2026-03-06 | 1 | #3 | Affidavit of Fact — Apr 9, 2024 (213 pp.) | 3 | | 4 | 2026-03-06 | 2 | #4–#5 | Exhibits B–C and D–G (46 pp. + 36 pp.) | 5 | | 5 | 2026-03-06 | 2 | #6–#7 | Affidavits — Attempted Assassination / Judicial Simulation (21 pp. + 37 pp.) | 7 | | 6 | 2026-03-06 | 1 | #8 | Netflix Whistleblower Part 1 (153 pp.) | 8 | | 7 | 2026-03-06 | 4 | #9–#12 | Motion for Sub. Counsel + Judicial Notice + Exhibits M–Q + RICO Complaint (4 + 19 + 23 + 121 pp.) | 12 | | 8 | 2026-03-06 | 1 | #13 | Exhibit AA — MN OLPR Complaint Against Bruce M. Rivers (128 pp.) | 13 | | 9 | 2026-03-07 | 1 | #14 | Emergency Motion for Stay Pending Appeal, MN COA A25-0882 (46 pp.) | 14 | | 10 | 2026-03-06 | 1 | #15 | RICO Complaint — Full Visual-Forensic Re-Processing (121 pp.) | 15 | | 11 | 2026-03-06 | 1 | #16 | Exhibit AF — Forensic Analysis of AI-Generated Netflix Fraud, Round 2 (68 pp.) | 16 | | 12 | 2026-03-06 | 1 | #17 | Exhibit AD — PhotoRobot Fraud Round 1 Forensic Analysis (36 pp.) | 17 | | 13 | 2026-03-07 | 1 | #18 | Exhibit N — Criminal Conspiracy Targeting Guertin's US Patent 11,577,177 (199 pp.) | 18 | | 14 | 2026-03-06 | 1 | #19 | Exhibit M — Guertin's Patent Theft Investigation (89 pp.) | 19 | | 15 | 2026-03-06 | 1 | #20 | Exhibit Z — Proof of Bruce Rivers' Knowledge (138 pp.) | 20 | | 16 | 2026-03-07 | 2 | #21–#22 | Exhibit P — Conspiracy of Commitment (39 pp.) + Exhibit W — Patent Value Estimate (167 pp.) | 22 | | 17 | 2026-03-07 | 2 | #23–#24 | Original Complaint Digital (110 pp.) + Exhibit AB — Video/Milz Report (15 pp.) | 24 | | 18 | 2026-03-06 | 1 | #25 | Exhibit L — Light Stage 6 at USC Fraud Analysis (40 pp.) | 25 | **Total Filings Cataloged: 25 | Batches 1–18 | All batches merged | Compiled: 2026-03-06** --- *End of MCRO Master Filing Catalog — FINAL UNIFIED (Filings #1–#25, Batches 1–18)*