# MCRO Master Filing Catalog — FINAL UNIFIED (TRIMMED)
## 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)

**Purpose:** Condensed reference catalog optimized for LLM context windows and vector-embedding retrieval. Each filing retains its metadata, narrative summary, procedural context, and forensic significance. Per-filing people/entity/date/exhibit lists have been removed — use the deduplicated appendices (A, B, C) for cross-filing reference. For full detail on any filing, refer to the unabridged Master Filing Catalog.

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## 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 | MCRO_27-CR-23-1886_Notice_of_Motion_and_Motion_2024-04-03_20240430072407.pdf |

**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.

**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.

**The Patent Dispute Narrative:** Guertin filed a provisional patent application on March 19, 2021 (No. 63/163,135).

**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.

**Key Legal Issues:** Judicial Notice (FRE 201 / MRE 9.01) • Competency Challenge • Conflict of Interest / Forensic Report Integrity • Patent Validity / Prior Art • Procedural Due Process Concerns • Alleged Corporate Patent Fraud • Alleged Government Surveillance • Google "InfiniSet" Dataset

**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.

**Key Forensic Flags:** **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. **Additional flags:** Incompetency Order Metadata • Pre-Signed Order • Index Number Inversion • Missing Index Number • Notice of Hearing Missing Timestamp • Rogstad Could Not Verify Patent Claims • Robertson Report Ambiguity • Referee Mercurio Military Background • Google "Infiniset" Dataset Naming • Duplicate Exhibit Labels • Pro Se Filing Competency Paradox • PDF Metadata Chain • Bruce Rivers Communication Issues • Coerced Waiver Allegation

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## 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 |

**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.

**Key Themes:** Competency Challenge • Defense Counsel Complaints (Bruce Rivers) • Alleged Internet Archive / Wayback Machine Fraud • Alleged Court System Corruption • Procedural Anomalies • Surveillance & Intelligence Claims • January 21, 2023 Incident Context • Connections to MOVA Contour / Steve Perlman Litigation • Contacts with Government Officials

**Key Legal Issues:** Competency to Stand Trial (Minn. R. Crim. P. 20.01) • Ineffective Assistance of Counsel • Discovery Violations (Rule 9.01, subd. 1(6)) • Fraud on the Court • Sixth Amendment — Right to Public Trial • Procedural Due Process • Right to Self-Representation • Civil Commitment Challenge

**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.

**Key Forensic Flags:** **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. **Additional flags:** Dr. Rogstad's Self-Acknowledged Limitations • Missing/Altered Discovery Materials • June 14, 2023 Hearing Irregularities • Defense Counsel Non-Responsiveness Pattern • Evidence Preservation • Email Authentication • Proton Mail Usage • Self-Representation Quality • Timeline of Escalation • Defendant's Substack Posts • Welder/CIA Connection

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## 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 |

**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.

**Key Legal Issues:** 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 • Alleged electronic surveillance and monitoring of defendant's communications • Alleged manipulation of court records (MCRO history repopulation) • Alleged manipulation of discovery materials • Due process violations in civil commitment proceedings • Conflict of interest regarding Bruce Rivers' YouTube presence and the • Right to proceed pro se • Wire fraud and criminal conspiracy allegations against third parties

**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.

**Key Forensic Flags:** **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. **Additional flags:** Attorney Conduct Flag • Selective Forwarding Flag • Discovery Manipulation Flag • Criminal History Repopulation Flag • Attorney Termination Timing Flag • LinkedIn Search Pattern Flag • PDF Metadata Note • Document Scale Flag • "Former CIA Welder" Flag

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## 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 |

**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.

**Key Legal Issues:** Defendant's Sixth and Fourteenth Amendment right to present evidence in • Minnesota Rules of Evidence 401–403 • Credibility of mental health assessments filed against the Defendant • 35 U.S.C. § 112 • 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 • Allegations of USPTO procedural failures and examiner oversight • Allegations of digitally fabricated documents submitted to the USPTO • Allegations of mislabeled/mischaracterized documents in the patent

**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.

**Key Forensic Flags:** **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. **Additional flags:** 16×16 pixel tiling artifacts in IFW documents • Missing Israeli priority document IL265092A • Dual Notices of Allowance • Mislabeled prosecution documents • Date discrepancy in Office Action • Duplicate document entries at national phase entry • Four examiner interviews • Synchronized publication date • 12-day gap between InfiniSet filing and Trojansky's duplicate application • Pattern of threshold-processed images showing artificial tiling in applicant documents • Tone and rhetoric of motion • No independent expert authentication disclosed

---

## 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 |

**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."

**Key Legal Issues:** Sixth and Fourteenth Amendment right to present a complete defense • Article I, Section 6 of the Minnesota Constitution (right to present evidence) • Minnesota Rules of Evidence 401–403 • Allegations of fabricated/backdated academic prior art • 37 CFR § 1.56 • Inequitable conduct under Therasense, Inc. v. Becton, Dickinson & Co. • Sherman Act § 2 • 18 U.S.C. § 371 • 18 U.S.C. § 1030 • 18 U.S.C. § 1962 • California Unfair Competition Law (UCL) • Tortious interference with business relationships • SEC Rule 10b-5 • Credibility challenge to Rule 20 psychiatric evaluations • Judicial notice request regarding contradictions between exhibits and

**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.

**Key Forensic Flags:** **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. **Additional flags:** No forensic metadata analysis of the 2006 papers themselves • Sole-source methodology in Exhibit F • Debevec's dual role • Claim of DTIC.mil hosting as evidence of government abuse • Pro se filing while represented by counsel • Request for judicial notice of contradictions with Rule 20 reports • Confrontational closing language • USC Cinema LinkedIn surveillance timing • Scope creep from criminal defense

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## 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 | 141__Affidavit__Attempted-Assassination-of-Matthew-Guertin__2025-04-28.pdf |

**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.

**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.

**Key Legal Issues:** Allegation of a "synthetic court ecosystem" operating within the 4th • Claim that 163 case files linked to Guertin's case are AI-generated or • Allegation of conspiracy involving multiple judges • Claim that Rule 20 evaluations were based on fabricated evidence and • Allegation that assigned defense counsel • Claim that the MCRO digital case management system was used to insert • Assertion that his mother's letter to the court was intercepted and • Claim that Judge Jay Quam • Allegation of national-security-level targeting related to his "InfiniSet • Due process violations (Fourteenth Amendment implications) • Right to effective assistance of counsel violations • Allegation of judicial fraud and obstruction of justice • Claim of fabricated psychiatric narratives constituting "psychiatric warfare"

**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).

**Key Forensic Flags:** **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. **Additional flags:** ChatGPT-Assisted Analysis • Circular Methodology Concern • VPN Usage Admission • Self-Referential Escalation Pattern • Scope of Claims vs. Evidence Presented • Timing

---

## 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 | 145__Affidavit-of-Exposure__Judicial-Simulation-and-Psychiatric-Entrapment__2025-04-28.pdf |

**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.

**Key Legal Issues:** All arguments from Filing #6, plus: • Specific due process violations • Ineffective assistance of counsel • Fabricated waiver of appearance at Index #24 • Right to be present at proceedings • Unlawful civil commitment • 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 • Violation of right to confront evidence • Cross-jurisdictional judicial overreach: Judge Klein • Circular psychiatric logic • 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

**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.

**Key Forensic Flags:** **All flags from Filing #6 apply**, plus: **Additional flags:** Vongsaphay Zip Code Discrepancy • Vongsaphay Jail/Release Contradiction • Vongsaphay Address Inconsistencies • Shared Address — Vongsaphay and Nunn • Angelic Denise Nunn Address Variations • Angelic Denise Nunn/Schaefer Name Change • Vongsaphay Docket Index Sequence • Volume of Returned Mail • USPS Postage Amounts • Filing #6 and #7 Overlap • DOB for Vongsaphay • Secret Recording • "Held Off the Record" vs. "Cancelled" • Missing Index #40 • Commitment Order Timing

---

## 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 | 128___Exhibit-A_Netflix-Whistleblower-Part-1__2025-04-10.pdf |

**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.

**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.

**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.

**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.

**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.

**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.

**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.

**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.

**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.

**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.

**The Standoff & Surrender (pp. 125–138):** Police surrounded the building.

**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.

**Key Legal Issues:** Admission of Exhibit A into official court record • Challenge to mental illness findings • Discovery fraud / evidence tampering • Judicial complicity • Patent misappropriation • Conspiracy under 42 U.S.C. § 1983 • Violation of constitutional rights • Request for sanctions • Request for comprehensive evidentiary review • Wayback Machine evidentiary reliability

**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.

**Key Forensic Flags:** **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. **Additional flags:** Satirical "review quotes" on page 3 • Market projection table • Discovery photo manipulation claims • LinkedIn search data • Temporal correlation claims • Adderall discontinuation • Sleep deprivation • Apartment as both crime scene and evidence repository • PDF metadata • Email authenticity offer • Dual nature of document • Firearm details • Multiple failed help-seeking attempts • "Former CIA" welder

---

## 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 |

**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.

**Key Legal Issues:** Ineffective assistance of counsel under the Sixth Amendment and Strickland • Failure to provide discovery materials • 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

**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.

**Key Forensic Flags:** 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.

---

## 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 |

**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.

**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.

**Key Legal Issues:** 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)

**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.

**Key Forensic Flags:** **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 **Additional flags:** Out-of-sequence index numbers • Order without corresponding motion • "Off the record" hearing • Six-month advance filing • Fabricated fee waiver • Duplicate public defender orders • Unlisted attorney of record • Simultaneous status • Rule 20 reports without examination • Chronological impossibilities in scheduling • Recusal date discrepancy • Three "Thomas" attorneys

---

## 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 |

**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).

**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.

**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.

**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.

**Key Legal Issues:** Competency under Minn. R. Crim. P. 20.01 • Challenge to March 10, 2023 forensic evaluation by Dr. Jill Rogstad • Patent infringement / intellectual property theft • Prior art and obviousness arguments against Netflix patent • Discovery fraud • Late filing justification under extraordinary circumstances • Due process violations

**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.

**Key Forensic Flags:** 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

---

## 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 |

**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."

**Key Themes:** 55 Post-Dated Signatures • 371 Timestamp Duplicates • 1,183 Duplicate Signature Images • 40 Fabricated USPS Return Scans • AI-Generated Filings • "Mother's Letter" Incident (Section VI) • 127 Cloned Incompetency Orders (Section VII) • Metadata Authors "barbj," "hernandezke," "GuzmanC," and "Nehring, Alisha" • PDF Toolchain Evidence • Embedded Font Tracking Codes (Section XVII)

**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.

**Key Legal Issues:** 42 U.S.C. § 1983 • 42 U.S.C. § 1985 • 18 U.S.C. § 1962(c) • 18 U.S.C. § 1962(d) • 18 U.S.C. §§ 1341, 1343 • 18 U.S.C. § 1512 • 18 U.S.C. § 1519 • 18 U.S.C. § 1001 • 18 U.S.C. § 505 • 18 U.S.C. § 1028 • 18 U.S.C. § 1702 • 18 U.S.C. § 371 • 18 U.S.C. § 242 • Federal Rule of Evidence 902(14) • Monell v. Department of Social Services • Judicial immunity

**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.

**Key Forensic Flags:** **Central forensic claim:** 162 of 163 criminal cases sharing the same three judicial officers appear to involve synthetic/fabricated defendants and documents **Additional flags:** Post-dated signatures • Timestamp cloning • Signature image reuse • Fabricated mail • 2-bit image filings • Mother's Letter incident • Metadata author misattribution • "barbj" centralization • "hernandezke" centralization • Nehring cross-contamination • Enterprise PDF toolchain • CFF font tracking codes • Role reversal errors • 4th Rule 20 evaluation

---

## 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 | 77__EXHIBIT-AA__Guertins-MN-OLPR-Complaint-Against-Bruce-M-Rivers.pdf |

**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.

**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).

**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.

**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).

**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.

**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.

**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.

**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."

**Key Legal Issues:** Ineffective assistance of counsel under the Sixth Amendment and Strickland • Attorney conflict of interest • Conspiracy to introduce fraudulent discovery materials into criminal case • Spoliation/manipulation of evidence • 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 • Refusal to withdraw as defense counsel despite direct requests and being • 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 • Request for change of venue • Applicability of Heck v. Humphrey, 512 U.S. 477

**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.

**Key Forensic Flags:** **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. **Additional flags:** Soft-mask layers on pages 115–117 • Two "Rule 20 Progress Report" entries in docket despite no third exam • Rivers' new phone number • Discovery chain-of-custody paradox • Judge Klein mid-hearing recusal • Entry of Default against Rivers • Rivers' dual posture in August 29, 2024 call • "No court" → incompetency stipulation pipeline • OLPR delivery signed by "A. Bertrand"

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## 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 |

**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.

**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.

**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.

**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.

**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.

**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.

**Rule 108 Four-Factor Analysis (Section VI):** 1. **Likelihood of Success on the Merits:** Guertin argues the April 29 orders flout black-letter law.

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).

**Key Themes:** Lack of Harm to State • Public Interest

**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.

**Key Legal Issues:** Fourth Rule 20.01 competency evaluation ordered without new factual basis • Content-based punishment of advocacy • Violation of Pate v. Robinson, 383 U.S. 375 (1966) • Structural Faretta violation • Chilling of First Amendment right to petition and Sixth Amendment right to • Prosecutorial perjury and Brady/Giglio violation by ACA Hamid • Confrontation Clause violations • Ineffective assistance of counsel under Strickland v. Washington, 466 U.S. 668 • Violation of Minn. R. Prof. Conduct 1.2 • "Fruit of the Poisonous Tree" doctrine • Forensic navigator appointment unlawful absent adjudication of incompetency • Navigator order's blanket records authority constitutes unreasonable • Fraud on the court doctrine • Mail interception and forgery (18 U.S.C. § 1702; Minn. Stat. § 609.625) • Brady/Napue violations regarding suppression of true provenance of • Federal Rules of Evidence 902 • Speedy trial violation (29+ months without resolution) • Involuntary medication requires prior judicial approval • Minn. R. Civ. App. P. 108 four-factor stay analysis

**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.

**Key Forensic Flags:** **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. **Additional flags:** Dual-court filing • 29+ months without trial • Competency "ping-pong" • Judge Hudleston's contradictory characterizations • ACA Hamid's contradictory statements • Defense counsel 180-degree reversal • Mother's Letter synchronized filing pattern • Nehring metadata "title bleed" • Statistical attorney-status anomaly • Scale of MCRO corpus findings • No rebuttal on record

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## 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 |

**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.

**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.

**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.

**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.

**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.

**Key Legal Issues:** 42 U.S.C. § 1983 • 42 U.S.C. § 1985(2), (3) • 18 U.S.C. § 1962(c) • 18 U.S.C. § 1962(d) • 18 U.S.C. §§ 1341, 1343 • 18 U.S.C. § 1349 • 18 U.S.C. § 1512(b), (c) • 18 U.S.C. § 1519 • 18 U.S.C. § 1001 • 18 U.S.C. § 505 • 18 U.S.C. § 1028 • 18 U.S.C. § 1702 • 18 U.S.C. § 371 • 18 U.S.C. § 241 • 18 U.S.C. § 242 • 18 U.S.C. § 1503 • 18 U.S.C. § 1505 • 18 U.S.C. § 1346 • Federal Rule of Evidence 902(14) • Federal Rule of Evidence 901, 902 • Monell v. Department of Social Services, 436 U.S. 658 (1978) • Faretta v. California, 422 U.S. 806 (1975) • Brady v. Maryland, 373 U.S. 83 (1963) • Strickland v. Washington, 466 U.S. 668 (1984) • United States v. Cronic, 466 U.S. 648 (1984) • Reves v. Ernst & Young, 507 U.S. 170 (1993) • Pate v. Robinson, 383 U.S. 375 (1966) • Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238 (1944) • Judicial immunity • Minn. R. Crim. P. 20.01 • Minn. R. Prof. Conduct 1.2(a) • Minn. Stat. § 609.48 • Minn. Stat. § 609.625

**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.

**Key Forensic Flags:** 

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## 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 |

**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.

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.

**Key Themes:** Links to Storj cloud storage directories • Links to Proton Drive • Screenshots of cloud storage file browsers • Quotations from books

**Key Legal Issues:** Fraud upon academic institutions and the public through • Criminal conspiracy involving USC, Google/YouTube, US Army/Military, • AI-generated deepfake creation of Holocaust survivor Pinchas Gutter's • Patent fraud • Prior art relevance • YouTube metadata discrepancies as evidence of content manipulation/replacement • Technology anachronism

**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.

**Key Forensic Flags:** **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. **Additional flags:** YouTube metadata discrepancies • Anachronism argument logic • Massive evidence volume with limited organization • Book quotations • Patent drawing images • "funnycatvideos.co.watch" domain • 22 GB web page collection • USC Cinema LinkedIn searches • Cross-referencing with prior filings

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## 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 |

**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.

**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.

**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.

**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)

**Key Legal Issues:** Patent fraud / inequitable conduct upon the USPTO • Fraud in establishing false prior art history • Relevance of AI-generated evidence to Guertin's competency defense • Internet Archive / Wayback Machine reliability as evidence • Ineffective assistance of counsel

**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.

**Key Forensic Flags:** **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. **Additional flags:** Visible Leading Prompt • Color Curve Methodology — Scientific Validity • Circular Reasoning in the Competency Defense • Rawner Email Cuts Both Ways • Police Report Context • Evidence Scale vs. Substance • Folder Name "04-18-2023_Its_All_Fake" • Timeline Significance • Multiple Redundant Hosting • Connection to MRMOCO/Microsoft/PhotoRobot/Dimension Studios

---

## 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 | 21__Exhibit-N__CRIMINAL-CONSPIRACY-TARGETING-GUERTINS-US-PATENT-11-577-177.pdf |

**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.

**Key Legal Issues:** Criminal conspiracy targeting Guertin's US Patent 11,577,177 by Netflix, • Patent fraud through fabrication of prior art • Fraudulent backdating of YouTube video upload dates to create false • AI-generated deepfake video production • Manipulation of Holocaust testimony footage for commercial purposes • Coordinated surveillance of Guertin through LinkedIn by • Ineffective assistance of counsel (Bruce Rivers) • Strickland v. Washington (466 U.S. 668) standard for ineffective assistance • Challenge to competency findings • Corporate fraud by Netflix through Scanline VFX and Eyeline Studios • Government/intelligence involvement • Acute stress response / duress as explanation for conduct underlying

**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.

**Key Forensic Flags:** **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. **Additional flags:** EXIF Metadata Discrepancy Claims • January 21, 2023 Coincidence • Index 05 — "Hypothetical" Framing of ChatGPT Conversation • Cross-Exhibit Consistency • Redacted Phone Numbers • Scanline VFX Seoul Office • No Independent Verification Provided

---

## 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) |

**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.

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."

**Key Themes:** Redefinition of 'Light Field' • Correlation with 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.

**Key Legal Issues:** Patent theft and intellectual property conspiracy targeting US Patent • Fraudulent attribution of MOVA Contour technology to Paul Debevec / Light • Alleged AI-generated or manipulated video evidence (SIGGRAPH 2023 presentation) • Alleged backdating of YouTube videos • Copyright, patent, and trademark infringement in the VFX industry • 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 • Alleged manipulation of the Minnesota court system to commit Guertin to a • Inequitable conduct / fraud on the patent office

**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.

**Key Forensic Flags:** **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. **Additional flags:** ChatGPT as analytical authority • Backdating allegation lacks technical substantiation • Trojansky in Debevec's "Special Thanks" • Redaction inconsistency • Self-referential evidence loop • Rearden v. Disney case used as proxy evidence • Government entity surveillance claim • "Former CIA welder" reference • Scale of conspiracy

---

## 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 |

**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.

**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.

**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)

**Key Legal Issues:** Attorney conflict of interest • Violation of Minnesota Rules of Professional Conduct • Entry of Default (Doc. 71) as to Bruce Rivers in federal case • Ineffective assistance of counsel • 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

**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.

**Key Forensic Flags:** **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. **Additional flags:** Entry of Default timing correlation • Time zone discrepancy in phone records • ChatGPT analysis as evidence • Mass judicial email campaign • Email campaign evolution • Discovery timeline contradiction • Rivers' muted responses • PDF annotation warnings

---

## 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 |

**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.

**Key Legal Issues:** Fraudulent court order • Ineffective assistance of counsel • Denial of access to critical evidence • Due process violations • Document tampering / manipulation of court records • Procedural fraud • Dismissal without prejudice of motions for continuance and production of • Denial of pro se representation while simultaneously labeling defendant • 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 • Conflict of interest • Broader conspiracy allegation connecting competency proceedings to patent

**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.

**Key Forensic Flags:** **"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. **Additional flags:** Document title vs. displayed title discrepancy • "barbj" as document author • Out-of-sequence index numbering • Non-standard e-file timestamps • Missing Index #40 • "Held Off The Record" vs. "Cancelled and Stricken" • Wrong phone number provided to Fisher • "hernandezke" as metadata author • Typo in official court order • Waiver signed under duress • Pattern of pre-business-hours filing

---

## 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 |

**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.

**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.

**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.

**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.

**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.

**Key Legal Issues:** Discovery manipulation • Chain of custody violations • Authentication of evidence under Federal Rule of Evidence 901 • Ineffective assistance of counsel • Fraudulent competency determination • Patent theft / intellectual property conspiracy • Conflict of interest • Brady violations: Withholding of exculpatory evidence by prosecution • Right to participate in one's own defense

**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.

**Key Forensic Flags:** **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. **Additional flags:** ISO file created morning of delivery • Rule 20 Evaluation Report lacks standard e-file metadata • Conservator order on discovery USB • File Access dates clustered around July 14–15 • Duplicate Appellate Court Orders • Patent valuation methodology • "CIA welder" claims • Systematic suppression of defense evidence

---

## 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 |

**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.

**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.

**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.

**Key Legal Issues:** 42 U.S.C. § 1983 • 42 U.S.C. § 1985 • 18 U.S.C. § 1341 • 18 U.S.C. § 1343 • Minn. Stat. § 609.63 • Minn. Stat. § 609.64 • Minn. Stat. § 609.43 • Minn. Stat. § 604.03 • Monell v. Department of Social Services, 436 U.S. 658 (1978) • Strickland v. Washington, 466 U.S. 668 (1984) • Heck v. Humphrey, 512 U.S. 477 (1994) • Wilkinson v. Dotson, 544 U.S. 74 (2005) • Preiser v. Rodriguez, 411 U.S. 475 (1973) • Ex parte Young • Smith v. Wade, 461 U.S. 30 (1983) • Sherman Antitrust Act, 15 U.S.C. § 1 • Thomas M. Cooley, A Treatise on the Law of Torts (1879) • Lockenour v. Sides, 57 Ind. 360 (1877)

**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.

**Key Forensic Flags:** **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. **Additional flags:** Dual Dating • Exhibit Q Designation • Defendant Overlap with Filing #12 • Address Change • Judge Quam Anomaly • Claim for Wire Fraud as Private Plaintiff • MCRO Analysis Foundation

---

## 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 |

**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.

**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.

**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.

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.

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.

**Key Legal Issues:** 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 • Whether the claim of "history of threatening to harm himself" is • Whether Guertin's factual claims about patent theft, surveillance, and • Due process implications of being declared incompetent based on a flawed • Professional conduct of forensic examiners

**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.

**Key Forensic Flags:** **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. **Additional flags:** Examiner Attentiveness • Platform as Evidence • Recording without Apparent Objection • Cross-Exhibit Labeling Discrepancy • Delusional Finding vs. Corroborated Claims • Report Metadata

---

## 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 |

**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.

**Index 02 (Pages 6–29): Light Stage 6 Fixture Position Analysis.** This is the core visual analysis section, authored by Matt Guertin.

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).

**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.

**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.

**Key Legal Issues:** Fraud / forgery • Image manipulation / evidence tampering • Patent fraud • Academic fraud • Wire fraud (18 U.S.C. § 1343) • Civil conspiracy (42 U.S.C. § 1985)

**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.

**Key Forensic Flags:** **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. **Additional flags:** Date inconsistency in archived image URL • Video hosted on obscure aggregation site • Image manipulation analysis methodology • Pipe clamp argument assumes maintenance occurred • Alternative explanation not considered — same image used in both contexts • Woman's appearance argument is subjective • Signature of "Tom" as forensic expert is misleading • Connection to broader case theory • Visual anomaly — 2018 video shows cameras among fixtures

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## 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**

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*End of MCRO Master Filing Catalog — FINAL UNIFIED (Filings #1–#25, Batches 1–18)*