“It appears that the government itself is the author of the most incriminating and damning document in this case, which was mysteriously sent at government request to Proud Boy leader Enrique Tarrio immediately prior to January 6 in order to frame or implicate Tarrio in a government- created scheme to storm buildings around the Capitol. As such, Exhibit 528-1 and the government’s efforts to frame or smear defendants with it, constitutes outrageous government conduct. This is either entrapment or outrageous government conduct, or both. Equally improper, it is a Brady violation because the Department of Justice must surely have known these revelations before putting Special Agent Dubrowski on the stand on February 9 to introduce this evidence.”
