King Lincoln Bronzeville Neighborhood Association et al v. J. Kenneth Blackwell et al

Filing 96

Supplemental Memorandum Opposing re 92 MOTION to Quash Plaintiffs' Subpoenas filed by Plaintiffs Willis Brown, Miles Curtiss, Paul Gregory, King Lincoln Bronzeville Neighborhood Association, League of Young Voters/Columbus, Ohio Voter Rights Alliance for Democracy, Matthew Segal & Harvey Wasserman. (Attachments: # 1 Appendix OEC Complaint & Exhibits, # 2 Appendix OEC 11-1 Hearing Transcript, # 3 Appendix OEC Hearing Exhibits 1-5, # 4 Exhibit 1 Cit for Strg OH contributions, # 5 Exhibit 2 Ptr for OH's Future contibutors, # 6 Exhibit 3 Arnebeck to Smith Doc Hold Ltr, # 7 Exhibit 4 Rove on Face the Nation, # 8 Exhibit 5 Tobacco Coup of 1994, # 9 Exhibit 6 Coalition for Legal Reform, # 10 Exhibit 7 Analysis of Ltr to FBI on Connell death, # 11 Exhibit 8 Analysis of Connell crash site, # 12 Exhibit 9 Cyber Map of 2004 OH election, # 13 Exhibit 10 Cyber Map of 2006 OH election, # 14 Exhibit 11 Smartech targets Obama) (Arnebeck, Clifford)

M ON D AY , J AN U ARY 04, 2010
Special Report. From National Security Letters to National Security Targets: Green light
for domestic assassinations exposed
WMR has obtained a letter and an after-action report sent by an anonymous source,
who used the alias "Mark Felt," the FBI official who was allegedly the source "Deep
Throat" during the Watergate scandal, to the FBI's supervisory special agent in
Cleveland that explicitly states that Mike Connell, the Republican Party's information
technology guru who helped engineer the delivery of Ohio's 20 electoral votes to the
Bush-Cheney column in 2004, was targeted for assassination by a team that was tasked
to eliminate an "NST" -- intelligence-speak for a "national security target." The afteraction report, which is heavily redacted, states that an order was given by a party
[redacted] to "neutralize" Connell as an NST. According to the accompanying letter, the
author writes that the after-action report "is not supposed to exist." In addition to the
FBI in Cleveland, the document was sent to five other parties.
As WMR reported on December 20, 2008, "Connell's Piper Saratoga single-engine plane
crashed during the evening of December 19 in Uniontown, Ohio as it was preparing to
land at Akron-Canton airport. There were no other passengers and Connell was killed in
the crash. Connell had flown to College Park, Maryland the previous day." Connell was
returning from College Park airport. The after-action report states that at 2:30 am on
December 19, 2008, [redacted] was directed to KGCS (College Park airport) to
"neutralize" NST (Connell) in DC FRZ (Metropolitan Washington Flight Restricted
Zone). Specifically, the after-action report states that targeted was Connell's Piper
Saratoga, tail number N9299N. The DC FRZ includes three Maryland airports at which
operations are severely limited by the Transportation Security Administration (TSA). In
the wake of 9/11, all pilots using College Park, Washington Executive/Hyde Field, and
Potomac Airfield are required to have background checks and be issued a personal
identification number.
At least three individuals were involved in sabotaging Connell's aircraft. The report
states that [redacted] arrived northeast of the airport at 0426, approached on foot north
from Indian Creek Park. The report further states that [redacted] covered the theater
from the park side and [redacted] and [redacted] proceeded to target the area across the
runway (runway 33). Another individual covered a redacted entity with a report of with
"no surveillance detected." The after-action report stated that the area was "sanitized"
and the team exited College Park airport via Indian Creek Park at 0557. The team was
reported to be OOA (Out of Area) at 0642.

Sabotage team approached Connell's plane, across runway 33, from the tree line in the far distance.

Sabotage of Connell's Piper Saratoga occurred under the noses of the Prince George's
County Police Department's Special Operations Division Aviation Section.

CCTV cameras at the Operations Building and surrounding area, including PG County
Police unit, may have detected sabotage team that installed special equipment on
Connell's airplane.

Were Blackwater CIA assassins involved in the sabotage of Connell's airplane?

View of College Park airport from neighboring Indian Creek Park.

Sabotage team entered airport from Indian Creek Park from north side of runway (in
photo from right to left).
The covered target may be the Prince George's County Special Operations Division
Aircraft Section, which maintains a facility at College Park airport, as well as two
helicopters. There is also an airport Operations Building that doubles as a museum,
since College Park airport is the oldest military airport in the United States. Surveillance
cameras operated by the Prince George's County Police, the airport Operations Building,
or the nearby College Park Metro station, may have captured the perpetrators of the
early-morning sabotage of Connell's aircraft.
According to the after-action report, one of the saboteurs opened the Piper Saratoga's
cowling, unlocked the door, and installed an AMD on the static port system. The author
of the accompanying letter, dated August 31, 2009, to the FBI and the five other
recipients wrote that "the AMD is designed to mimic existing aircraft components in
order to thwart investigations." The author informs the FBI that "you may be able to

find evidence of it (AMD) in the static port system." The author, in his letter, also
specifically states that "Connell was not NST" (national security target). The fake return
address on the letter's envelope, postmarked Washington, DC, also yields a few potential
clues as to its source. The phony street address is "4007 Kohtraktop Rd." The street
name may be a cipher for "contract op" with 4007 possibly meaning "for 007," a
reference to a James Bond-style intelligence operation. The return address town is
"McClean [sic], Virginia, a reference to the CIA's headquarters town, McLean, Virginia.
The zip code is 20661. which is Mount Victoria in southern Maryland, which is across
the Potomac River from the Naval Surface Warfare Center at Dahlgren, Virginia where
one of the tenant activities is the Joint Warfare Analysis Center (JWAC), which helps
develop electronic warfare weapons, including Meaconing, Intrusions, Jamming,
Interference (MIJI) systems designed to confuse pilots.
The date of the letter to the FBI is also potentially significant. On August 20, The
Washington Post reported that the CIA hired Blackwater, now Xe Services, to assemble
assassins to target "Al Qaeda" leaders. The report followed by a day a similar report
in The New York Times. The program was not revealed to Congressional intelligence
and military oversight committees on orders from Vice President Dick Cheney. Was the
author of the letter convinced that the top secret CIA program using Blackwater
assassins would be exposed and reveal details of a program that not only targeted "Al
Qaeda" leaders for assassination but also political operatives who could pose a threat as
potential witnesses against Cheney, CIA director Michael Hayden, and Homeland
Security Secretary Michael Chertoff on murder one charges? Did the Department of
Defense's Asymmetric Warfare Group involve the use of aircraft tampering technology
developed at Dahlgren, Virginia? Did Blackwater's strong ties to the Republican Party
make it a natural fit to take out Connell who posed a threat to the party's hierarchy,
including Rove, over the 2004 Ohio electoral vote theft?
Did the mysterious "Mark Felt," who sent the after-action report to the FBI office in
Cleveland, know about the former Blackwater employee known as "John Doe #2"
who filed an affidavit in federal court in Washington on behalf of Iraqis who filed suit in
Washington over the firm's security guards' massacre of Iraqi civilians in Baghdad?
John Doe #2, a former Blackwater employee, stated in his affidavit: "Based on
information provided to me by former colleagues, it appears that Mr. [Erik] Prince
[then-Blackwater's CEO] and his employees murdered, or had murdered, one or more
persons who have provided information, or who were planning to provide information,
to the federal authorities about the ongoing criminal conduct." The affidavit was dated

July 29, 2009, a month before the Felt letter arrived at the FBI office in Cleveland.
Could "Mark Felt" and "John Doe #2" even be the same person?
WMR's December 20, 2008 report also revealed: "Connell's name surfaced as a key
player in Rove's election fraud conspiracy after this year's July 17 Columbus news
conference hosted by Cliff Arnebeck, the Ohio attorney who has been representing
plaintiffs in the federal civil suit against former Republican Secretay of State Kenneth
Blackwell. On the phone at the conference was John McCain campaign adviser and
computer security specialist Stephen Spoonamore who identified Connell as a key
player, as well as potential trial witness, in the GOP's conspiracy to flip Ohio votes in the
2004 election. Spoonamore and Connell had reportedly worked together on foreign
elections in programs sponsored by the International Republican Institute (ISI) and the
National Endowment for Democracy (NED). Both had traveled abroad together on
special election projects to ensure 'fair voting' procedures."
Our December 20, 2008, report continued: "After Connell was identified as a potential
witness in the civil case against Blackwell and a possible criminal Ohio RICO case
against Rove, Blackwell, and perhaps others, the plaintiff attorneys received a tip from a
high-level source in the McCain presidential campaign that Rove had issued a threat
against Connell. Connell had worked for the 2008 McCain presidential campaign on the
development of its web pages.
WMR has learned from our Ohio sources that five threats against Connell were
conveyed to the election fraud plaintiff attorneys with the last tip being 'Connell is in
danger.' One of the threats reportedly made by Rove to Connell was that Connell could
forget about a pardon from President George W. Bush if he did not 'take the fall' in the
event criminal charges were brought and that his wife Heather, who was used as a
majority stockholder for one of Connell's web design companies, GovTech Solutions,
would be prosecuted for illegal lobbying. Connell's other company is New Media
Communications, Inc."
The story about Connell's planned testimony and his threat to the Republican machine
led by Rove was even murkier as WMR reported on December 20, 2008, "Connell's
firms received contracts to place its servers behind the House of Representatives firewall
courtesy of then-House Administration Committee Chairman Bob Ney (R-OH), later
jailed for his role in the Jack Abramoff lobbying-influence peddling scandal. Connell
also designed and ran the web sites for the House Permanent Select Committee on
Intelligence and the House Judiciary Committee. WMR has learned that through

effective GOP control of these web sites, the Bush White House was able to monitor all
committee e-mails and documents, including planning documents for House Judiciary
Committee impeachment hearings against Bush and Vice President Dick Cheney. We
have also learned that Connell's IT firm did classified web site development work for the
CIA. Based on the threats against Connell, the federal judge in Cleveland hearing the
civil suit King Lincoln v. Blackwell conveyed to Connell that the court would protect
him if he came forward. On October 17, 2008, Connell's attorneys attempted to quash
an October 8, 2008, plaintiff subpoena for his court appearance. On October 31, U.S.
Judge Solomon Oliver denied the motion to quash the subpoena and ordered Connell's
deposition to proceed on November 3, the day before Election Day.
WMR has learned that on Friday, October 31, Connell was nervous and 'beet red' during
the hearing to quash the subpoena. On Monday, November 3, Connell was composed
and it is believed that his top shelf law firm had been selected by Rove to represent
Connell for the deposition. Rove's intent was to ensure that there would be no
deposition from Connell before the November 4 election. WMR has also learned that
Connell was prepared to testify before the House Judiciary Committee about the
election fraud in Ohio and other states but that the offer of testimony was not acted
upon by senior staffers for House Judiciary Committee Rep. John Conyers (D-MI). A
source in Columbus told us that some of Conyers' senior staffers on his committee and
in is office are not to be trusted on issues related to election fraud. In addition, Rove and
the Bush White House attempted to forestall testimony by election officials in Mahoning
County and Youngstown, Ohio on election fraud in 2004 by promising to have former
Rep. James Traficant (D-OH), who is currently imprisoned after being convicted of
corruption, released early in return for their silence. Traficant is not scheduled for
release from federal prison until Sept, 2, 2009."
On December 22, 2008, WMR reported on an e-mail letter sent by Arnebeck to Attorney
General Michael Mukasey on July 24, 2008 warning of a threat against Connell. The
letter stated: "We have been confidentially informed by a source we believe to be
credible that Karl Rove has threatened Michael Connell, a principal witness we have
identified in our King Lincoln case in federal court in Columbus, Ohio, that if he does
not agree to 'take the fall' for election fraud in Ohio, his wife Heather will be prosecuted
for supposed lobby law violations. This appears to be in response to our designation of
Rove as the principal perpetrator in the Ohio Corrupt Practices Act/RICO claim with
respect to which we issued document hold notices last Thursday to you and to the US
Chamber of Commerce Institute for Legal Reform."

On December 22, 2008, WMR also reported: "WMR has learned from knowledegable
Republican Party sources that Mike Connell, the GOP's information technology maestro
who was killed in a suspicious plane crash last Friday night while flying from the
Washington, DC area back to Akron, Ohio, was involved in a high-tech operation
targeting Democratic presidential candidate Al Gore in 2000. Although Connell, whose
Richfield, Ohio-based GovTech Solutions LLC is accused of helping to steer Ohio's 20
electoral votes to the George W. Bush column in 2004, is identified with alleged vote
fraud in 2000 and was reportedly prepared to testify about it before being threatened by
former Bush aide Karl Rove, our sources have claimed Connell's network goes back to
2000 and is linked to malfeasance directed against Gore.
GovTech Solutions and Connell's other firm New Media Communications were closely
linked to the Ohio election fraud. GovTech Solutions was hired by then-GOP Ohio
Secretary of State Kenneth Blackwell as a consultant to the Secretary of State for the
election. New Media Communications set up hundreds of Republican web sites,
including gwb43.com, which was used by Bush White House staffers to send politicallyconnected emails in violation of government policies on mixing official duties with
political work. Blackwell also contracted out backup servers to Smartech of
Chattanooga, Tennessee. Stephen Spoonamore, a computer security expert and IT
adviser to the Bush 2004 and John McCain 2008 presidential campaigns, revealed that
Smartech was able to intercept 2004 Ohio election returns before they were made
available on the Ohio Secretary of State's website.
Connell's colleague Jeff Averbeck was reportedly brought by the GOP to Chattanooga
from Texas to head up the efforts targeting Gore in Gore's home state. SmarTech'
servers were placed in the basement of the old Pioneer Bank Building in downtown
Chattanooga. The parent company for SmartTech is Airnet, also headed by Averbeck.
Averbeck was, according to our sources, the actual technical brains behind the entire
SmartTech-GovTech Solutions-Media Communications operation that resulted in the
election tampering in 2004. There are also questionable ties between SmarTech and
former Chattanooga Mayor and now U.S. Senator Bob Corker that point to
Chattanooga's city government under Corker providing a cover for a major GOP political
dirty tricks operation in the city. Corker successfully ran for Mayor of Chattanooga in
2000. In February 2007, Corker, Rove, and Bush were spotted together at Porker's BBQ
restaurant in Chattanooga. There were reports of a connection between SmarTech's
predecessor firm ST3, another web service provider called Coptix, and
Corker. According to our sources, Averbeck's SmarTech was tasked with high-tech

spying on Al Gore's Nashville presidential campaign headquarters. A three hour drive
from Nashville, Chattanooga was considered by Karl Rove to be an excellent and
friendly spot to keep a high-tech eye on the Gore campaign from within his home state.
Two years later, SmarTech had reportedly become involved in Alabama politics and may
have, according to our sources, been involved in the computer glitch in Magnolia
Springs, Alabama that gave Republican gubernatorial candidate Bob Riley and razorthin win over incumbent Democratic Governor Don Siegelman. SmarTech reportedly
received a lucrative Alabama state contract from Governor Riley to support Alabama's
criminal justice information system. There are, according to our sources, close links
between Averbeck and former Republican National Committee official Bill Canary,
whose wife Leura was one of the U.S. Attorneys used in Alabama to prosecute Siegelman
in a politically-manufactured corruption probe. Connell also, according to our sources,
received contract work from the Riley administration to perform IT services for
Alabama's criminal justice system. Connell also did IT work for the Alabama Republican
Party. In 1998, Averbeck's IT firm, Executive Consulting Services of Chattanooga, won
Microsoft's 'Best Solutions for Small Business' grand prize. Averbeck's firm developed a
software package that tracks bankruptcy and collection cases, enables electronic court
filings, schedules and manages dockets, calculates payments with or without interest,
and manages attorneys' billing time. Interestingly, the software mirrors some of the
same functions provided by the Prosecutors Management Information System
(PROMIS) that remains a controversial subject as a result of charges that the Justice
Department purloined the software in the early 1980s from Inslaw and made it available
to various intelligence agencies.
Averbeck is also considered a technical expert on Internet live stream technology. WMR
previously reported that Connell had contracts for web site development for the CIA and
House Permanent Select Committee on Intelligence. We have now learned that Connell
and Averbeck may have been behind the installation of live streaming black boxes in the
White House and the Eisenhower Old Executive Office Building used to stream live
video of torture sessions in Guantanamo, Cuba and Abu Ghraib to the Old Executive
Office Building office of Vice President Dick Cheney's Chief Counsel David Addington
and into the White House, itself. Media reports of torture sessions being taped may have
been planted by the White House to deter investigators away from looking at live
streaming capabilities in the offices of Cheney and President Bush.

The fire that broke out in an 'electrical closet' in the Old Executive Office Building on
December 19, 2007, near Cheney's ceremonial office likely contained the live streaming
boxes used to stream torture sessions from Guantanamo and Abu Ghraib, according to
our sources who added that SmartTech and Airnet have been in the live streaming video
business since 2002. SmarTech also had the contract to provide video streaming
services at the GOP conventions in New York in 2004 and St. Paul in 2008. On
September 5, 2008, WMR reported: "WMR has learned from a reliable source that the
GOP convention organizers in St. Paul installed special microphones and cameras in
the Xcel Energy Center in order to monitor who delegates were chatting with and
listen in on their conversations. Similar technology, WMR is told, was used by the
Republicans at the 2004 national convention in New York at Madison Square
Garden. The eavesdropping on state delegations involved the use of powerful pan,
zoom, and tilt camera technology and noise-canceling shotgun microphones, similar to
those used sporting events by broadcasters. The cover for the eavesdropping
equipment was that it was part of Internet coverage for the convention. Yesterday, The
Washington Times reported on the presence of 'Black Hat' squads on the convention
floor in St. Paul that tracked Ron Paul supporters and other potential disruptors.
Wearing black ball caps with white stars, the squads were authorized to yank
delegates' credentials and remove them from the convention floor.
The high-tech Big Brother system kept track of conversations held within state
delegations, especially those of non-McCain delegates who originally were pledged to
Paul and Mitt Romney. Paul received 15 votes from the floor, although the Oklahoma
delegation's microphone was cut off before Senator Jim Inhofe could announce two
votes for Paul. The GOP's Big Brother surveillance of the Oklahoma delegation likely
picked up the conversations about Oklahoma's vote beforehand, prompting the
silencing of the microphone. WMR has been told that the same group of GOP high-tech
spies are involved in yet another operation to engineer the 2008 presidential election
for the Republican ticket using connections to private companies' election tallying
computers and voting machines around the United States. The operation is primarily
based in Chattanooga, Tennessee and Enterprise, Alabama, the same locations that
served as headquarters for the election engineering carried out in 2004. The group of
high-tech experts was responsible for the flipping of votes in Ohio, New Mexico,
Nevada, Iowa, Florida and other states in 2004, as well as statewide elections in
Alabama and Georgia in 2002. WMR has been told by our sources that the company
that ran the video surveillance at the conventions was SmarTech."

Posted by Macu at 1/04/2010 04:55:00 PM
Labels: assassination, GOP corruption, Karl Rove

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