IN THE UNITED STATES DISTRICT COURT



IN THE UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA

|TIMOTHY CHARLES HOLMSETH |Case No. 14-CV-2970 (DWF/LIB) |

| | |

|Plaintiff, | |

| | |

|v. | |

| | |

|CITY OF EAST GRAND FORKS, a municipal entity in the state of | |

|Minnesota; RONALD GALSTAD, city attorney for City of East Grand | |

|Forks, in his official and individual capacity; BARB ERDMAN, |MOTION |

|Sheriff of Polk County, Minnesota, in her official and individual|FOR |

|capacity; JAMES RICHTER, director of Economic Development and |CONTINUANCE |

|Housing Authority (retired), in his official and individual | |

|capacity; MICHAEL HEDLUND, chief of police for City of East Grand| |

|Forks, in his official and individual capacity; DAVID MURPHY, | |

|administrator for the City of East Grand Forks, in his official | |

|and individual capacity; RODNEY HAJICEK, lieutenant detective at | |

|East Grand Forks Police Department, in his official and | |

|individual capacity; AEISSO SCHRAGE, police officer at East Grand| |

|Forks Police Department, in his official and individual capacity;| |

|MICHAEL LACOURSIERE, public defender for MINNESOTA PUBLIC | |

|DEFENDER’S OFFICE, in his official and individual capacity; JOHN | |

|DOE, in his/her official and individual capacity; JEANETTE | |

|RINGUETTE, administrative assistant at the Grand Forks National | |

|Weather Service Office, in her official and individual capacity; | |

|MICHAEL NORLAND, deputy at the Polk County Sheriff’s Office, in | |

|his official and individual capacity; | |

| | |

|Defendant. | |

PLAINTIFF TIMOTHY CHARLES HOLMSETH’S

MOTION FOR CONTINUANCE

* * * * *

COMES NOW Plaintiff, Timothy Charles Holmseth, and respectfully moves the Court for a continuance of the pre-trial hearing, which is set for December 17, 2014.

Plaintiff’s has acquired new information and evidence that dramatically affects the entire case.

Plaintiff requests all Motions to Dismiss be continued until Plaintiff has ample time to review new evidence.

As grounds for this Motion, counsel submits the following Memorandum in Support:

* * * * *

MEMORANDUM IN SUPPORT

1. Plaintiff is a reporter, journalist, author, and publisher.

2. In July, 2014, Plaintiff filed this Deprivation of Rights action against law enforcement officers and public officials that targeted Plaintiff’s Constitutional rights.

3. Plaintiff became the target of Defendant(s) beginning in 2009, after Plaintiff began conducting interviews regarding the national profile cases of the kidnapped child HaLeigh Ann-Marie Cummings, and slain toddler Caylee Marie Anthony.

4. In December, 2012, Defendant City seized Plaintiff’s hard-drive, which contained his entire work product on the aforementioned cases; took the hard-drive to an unknown location; secretly searched it without an applicable warrant; and then permanently disabled the hard-drive before returning it.

5. Defendant John Doe also damaged Plaintiff’s computer processor whereby he/she un-hooked wires and caused internal plastic clips to snap.

6. The malicious and illegal actions taken against Plaintiff by Defendants, which afforded them access to Plaintiff’s computer and hard-drive, were executed under the pretext of a fraudulent divorce court scheme that Plaintiff was a perpetrator of ‘domestic violence’ against an REDACTED from Florida named REDACTED REDACTED (whom he had never met).

NEW INFORMATION AND EVIDENCE OF A CRIME

7. In November, 2014, Plaintiff discovered new information contained in audio interviews Plaintiff conducted with kidnapping suspects between 2009 and 2012. The audio interviews were the same interviews contained on the hard-drive seized by Defendants.

8. Plaintiff located the interviews in November of 2014 by using an old computer processor that was given to Plaintiff by his parents. Plaintiff obtained the old computer processor while visiting Southern Minnesota for a wedding in September, 2014, and brought the old processor back to Northern Minnesota.

9. The acquisition of the old processor was not planned, rather, a spontaneous offer by Plaintiff’s father.

10. After returning to Northern Minnesota, Plaintiff searched two old hard-drives but did not locate the sought files. On November 16, 2014, while again sifting through files on a hard-drive, Plaintiff happened upon the ‘mother’ file of his HaLeigh Cummings/Caylee Anthony project, which was buried deep in the drive.

11. Plaintiff then began reviewing hours of audio interviews.

12. Plaintiff needs several months to effectively review all the audio interviews that may potentially have a bearing on this case.

13. As is set forth in Plaintiff’s First Amended Complaint, Plaintiff conducted hundreds of hours of recorded interviews with key figures in the national profile cases, which included family members, suspects, persons of interest, law enforcement officers, attorneys, advocates, and witnesses.

14. Plaintiff also obtained highly sensitive information in the form of emails and other recordings. Some of the recordings were mailed to Plaintiff that captured various suspects committing felonies (including REDACTED REDACTED).

15. Plaintiff obtained information regarding a (1) murder (2) kidnapping (3) drug trafficking, (4) child pornography (5) international human trafficking operation (6) fraud (7) money laundering (8) public corruption (9) police corruption.

16. REDACTED REDACTED, an REDACTED from REDACTED, Florida, was involved in all of the aforementioned criminal activity.

17. REDACTED REDACTED admitted to Plaintiff during an interview that REDACTED and a staff member were suspects of law enforcement in transporting the missing child HaLeigh Cummings across state lines.

18. In November, 2014, Plaintiff discovered information, that demonstrates Plaintiff’s hard-drive, which was seized, searched, and destroyed by Defendants, contains e-mail evidence that implicates REDACTED REDACTED for REDACTED criminal involvement regarding the:

o Kidnapping of HaLeigh Ann-Marie Cummings

o Cover-up of the murder of Caylee Marie Anthony

o Felony false imprisonment of Daniel Everett Snodgrass

o REDACTED Misconduct

19. On November 16, 2014, Plaintiff listened to an interview conducted in 2010 with Wayanne Kruger. During the interview, Wayanne Kruger and Plaintiff discussed the contents of an e-mail thread dated March 23, 2009 that Kruger had forwarded to Plaintiff. Both Kruger and Plaintiff have the e-mail up in front of them on their computer monitors as they discuss the contents.

20. The contents of the e-mail, in sum and substance, is the smoking gun that REDACTED REDACTED sought to keep hidden.

THE SECRET TRUTH ABOUT REDACTED REDACTED

EVIDENCE OF CRIMINAL ACTIVITY DESTROYED BY DEFENDANT CITY

21. The newly discovered evidence of an e-mail reveals the previously unknown fact that in March of 2009, REDACTED REDACTED was the REDACTED for William Eugene Staubs, Case Closed Inc.

22. William Staubs (a.k.a. Cobra) is a bail bondsman and licensed private investigator from Broward County, Florida. In 2009, William (Cobra) Staubs interjected himself into the HaLeigh Cummings kidnapping investigation and performed a high-media ‘search’ for the missing child.

23. In sum and substance, REDACTED REDACTED, a REDACTED, was using REDACTED REDACTED license and status as an REDACTED, to act as an ‘agent’ and/or ‘operative’ in a criminal operation involving the kidnapping of one child, to cover-up the murder of another child.

24. William Staubs originally claimed he was the private investigator working for Crystal Sheffield, HaLeigh’s Cummings’ mother.

25. In March of 2009, REDACTED REDACTED became the REDACTED REDACTED REDACTED REDACTED Crystal Sheffield. REDACTED appeared on national television in this capacity. REDACTED claimed to have a team of investigators working for REDACTED.

26. REDACTED REDACTED was strategically brought into the HaLeigh Cummings case by William Staubs (to officially REDACTED Staubs’ PI client Crystal Sheffield).

27. William Staubs told Plaintiff he brought REDACTED REDACTED into the case so he would have REDACTED subpoena power over any witness he wanted to lean on.

28. REDACTED REDACTED told Plaintiff REDACTED was privy to sensitive investigative information regarding the kidnapped child because REDACTED was the REDACTED for the missing child’s mother. REDACTED told Plaintiff REDACTED was “coordinating leads” with “Captain Dominic Piscitello” and “Detective Peggy Cone” at the Putnam County Sheriff’s Office.

29. The newly discovered proof of an email reveals REDACTED REDACTED was REDACTED BOTH William Staubs and Crystal Sheffield at the same time (but keeping the William Staubs REDACTED/REDACTED relationship secret).

30. The newly discovered proof of an email reveals that while REDACTED REDACTED was openly, publicly, and officially acting as the REDACTED for Crystal Sheffield, REDACTED (REDACTED REDACTED) was receiving REDACTED instruction and directives from REDACTED CLIENT/CO-CONSPIRATOR William Staubs.

31. In May of 2009 William Staubs was arrested by the Putnam County Sheriff’s Office on charges of felony false imprisonment stemming from illegal actions he took.

32. The newly discovered information shows William Staubs acted under REDACTED direction and criminal conspiracy with REDACTED REDACTED REDACTED.

CONSPIRACY TO CREATE REASONABLE DOUBT

THE TRUTH ABOUT THE DEATH OF CAYLEE MARIE ANTHONY AND THE STAGED KIDNAPPING OF HALEIGH ANN-MARIE CUMMINGS

INTRODUCTION

1) Caylee Marie Anthony, Orlando, Florida, was reported missing on July 15, 2008, by her grandmother who had not seen the child for a month. Caylee’s skeletal remains were found on December 11, 2008, in a wooded area near the family home.

2) HaLeigh Ann-Marie Cummings, 5, was reported missing from her Satsuma, Florida home on February 10, 2009. An Amber Alert was issued for HaLeigh and she has never been found.

3) Crystal Sheffield is the mother of the missing child HaLeigh Ann-Marie Cummings.

4) William Staubs, Case Closed Inc., Weston, Florida, was the licensed private investigator working for Crystal Sheffield in regards to the case of her missing daughter. Staubs is also a licensed bail bondsman for a company called Lighting Strike Force.

5) REDACTED REDACTED REDACTED, REDACTED REDACTED Office, REDACTED, Florida, was the REDACTED working REDACTED Crystal Sheffield.

6) REDACTED REDACTED, convicted felon/bankrupt/fraudster, REDACTED, Florida, is the REDACTED of REDACTED REDACTED.

7) Wayanne Kruger, author/sex victims advocate, Avondale, Arizona, was the official advocate and media coach for Crystal Sheffield.

8) Rev. Richard Grund, Supernatural Response Team, Windermere, Florida, was on the tentative Witness list in the Casey Anthony murder trial, and subsequently interjected himself into the HaLeigh Cummings kidnapping case through his relationship with William Staubs and Wayanne Kruger.

9) Art Harris, tabloid blogger, is a former CNN correspondent and reporter for the Nancy Grace Show.

10) Jeremiah Regan, drifter, interjected himself into the HaLeigh Cummings kidnapping case to set up a money-making facility called the HaLeigh Bug Center.

11) John Regan, father of Jeremiah Regan, is a clergy impersonator, sexual predator/pedophile that interjected himself into the HaLeigh Cummings case and claimed to be an agent of the FBI and CIA.

CRIMINAL CONSPIRACY TO CONCEAL TRUE FACTS AND CIRCUMSTANCES SURROUNDING THE MURDER OF CAYLEE MARIE ANTHONY

12) Plaintiff’s journalistic investigation and interviews resulted in Plaintiff assimilating statements, admissions, confessions, dates, times, and circumstances into a fact-pattern that revealed the true facts and circumstances surrounding the unsolved death/murder of Caylee Marie Anthony, and unsolved kidnapping of HaLeigh Ann-Marie Cummings.

13) Prima Facie evidence exists that shows multiple actors including REDACTED REDACTED REDACTED, REDACTED REDACTED, William Staubs, Rev. Richard Grund, Wayanne Kruger, John Regan, Jeremiah Regan, and Art Harris conspired to:

A. Create reasonable doubt regarding the identity of the person(s) responsible for the death/murder of Caylee Marie Anthony, 2, Orlando, Florida, by way of;

B. Staging the kidnapping of HaLeigh Ann-Marie Cummings, 5, Satsuma, Florida, and creating the false appearance the child was abducted and murdered by a local child molester roving the area.

FACT PATTERN

14) Caylee Marie Anthony’s remains were discovered on December 11, 2008.

15) HaLeigh Ann-Marie Cummings was reported missing from her home in Satsuma, Florida on February 10, 2009.

16) During interviews between Plaintiff and REDACTED REDACTED REDACTED, conducted in May of 2009, REDACTED REDACTED discussed a meeting between himself, REDACTED REDACTED REDACTED (REDACTED wife), and William Staubs, which revealed the following:

o The aforementioned meeting occurred on a date that fell AFTER William Staubs had returned from Satsuma, Florida, but Staubs was ‘going back up there’

o REDACTED REDACTED REDACTED would now be assisting William Staubs in his ventures involving the missing child HaLeigh Cummings

o William Staubs would provide REDACTED REDACTED rough numbers of how much money he would need REDACTED REDACTED to secure to fund the venture

CHILI’S RESTAURANT MEETING

CONSPIRACY TO CREATE REASONABLE DOUBT

HALEIGH ‘MIRRORS’ CAYLEE

17) On a date before March 20, 2009 (believed to be March 19, 2009) William Staubs, REDACTED REDACTED, Art Harris, Donald Knop, Crystal Sheffield, Jeremiah Regan, Matthew Staubs, Donna Wagoner, and Jerri Greene met at the Chili’s restaurant in Palatka, Florida.

← See Exhibitive Photo A

18) At the Chili’s meeting, the group discussed their illegal plan for William Staubs (a licensed bail bondsman) to travel to the home of Daniel Everett Snodgrass, Satsuma, Florida, an accused child molester that was free on bond, and revoke his bond.

← REDACTED REDACTED REDACTED discussed the Chili’s meeting with Plaintiff during recorded journalistic interviews. REDACTED openly stated that during the Chili’s meeting REDACTED provided William Staubs legal advice and information regarding the tentative bond revocation of Daniel Snodgrass.

← REDACTED REDACTED told Plaintiff REDACTED met with William Staubs immediately after the bond revocation of Daniel Snodgrass. REDACTED gleefully stated she sat in William Staubs’ vehicle with him and viewed footage of the violent event on a lap-top computer and congratulated him.

← Plaintiff has in his possession, multiple documents regarding Daniel Snodgrass, which were originally faxed to William Staubs by the REDACTED REDACTED of REDACTED REDACTED.

THE FIRST COAST NEWS INTERVIEW

19) On a date between March 11, 2009, and March 20, 2009, William Staubs was interviewed by news reporter Jessica Clark, First Coast News, Florida. William Staubs was wearing a ‘wire’ during his conversations with Jessica Clark. William Staubs subsequently sent copies of the recordings to Plaintiff. During William Staubs’ interview with Jessica Clark the following was said/established:

← William Staubs told Jessica Clark he had been sent to Satsuma, Florida, to search for HaLeigh Cummings at the request of a pastor from Orlando named Richard Grund.

o William Staubs told Jessica Clark his bills were being paid by a reformed drug dealer from Miami.

o William Staubs asserted he was:

✓ Sent into the case by Rev. Richard Grund

✓ To act as the PI for Crystal Sheffield

✓ While being financed by a drug dealer from Miami

RICHARD GRUND

← Rev. Richard Grund is the father of Jesse Grund. Jesse Grund is the former fiancé of Casey Anthony. In March, 2009, Casey Anthony was in the custody of the State of Florida facing first degree murder charges of her two year-old daughter, Caylee Marie Anthony.

← Plaintiff interviewed and communicated with Richard Grund multiple times beginning in 2009. Richard Grund told Plaintiff:

o There was a plot to frame his son Jesse Grund for the murder of Caylee Anthony

o Casey Anthony unsuccessfully attempted to lure his son Jesse Grund into a shower to obtain pubic hair and/or semen to plant on the dead body of Caylee Anthony

o Casey Anthony attempted to lure his son Jesse Grund to the location of her vehicle and trick him into touching the trunk (where the lifeless body of Caylee Anthony is believed to have been for a period of time)

o The Anthony family hacked Richard Grund’s computer and stole photographs, etc.

o There was an ongoing conspiracy and multiple continued attempts being made to obtain DNA to plant on Caylee Anthony’s body that would implicate Grund

o Caylee Anthony was the biological child of Casey Anthony’s brother, Lee Anthony

o Richard Grund operates a paranormal service called the Supernatural Response Team, which specializes in casting out demons through exorcisms, etc.

o The Anthony family home was possessed by demons

o On one occasion, when Richard Grund was in the home of the Anthony’s, items began to fly off the shelf on their own. He said the demons were letting him know the power they had in that house

o Richard Grund was once a worshipper of Satan

o Richard Grund once had an encounter with a fallen Watcher

o Casey Anthony’s body was possessed by an ancient god called “Moloch” that demanded the sacrifice of babies

o Casey Anthony’s body was/is taking on the physical form of “Moloch” (literally he said)

o Cindy Anthony was the most evil person Richard Grund ever met

o Casey Anthony was deadly afraid that Caylee Anthony would become like Casey’s mother, Cindy Anthony

o Caylee Anthony, 2, was overtly sexual (according to Richard Grund) because she ‘flirted’ with men (had five pair of sunglasses and was ‘becoming’ Casey Anthony and Cindy Anthony)

20) During the First Coast News interview William Staubs told Jessica Clark:

o Daniel Snodgrass was a person of interest in HaLeigh Cummings’ kidnapping because he was charged with sexual battery against a child under twelve

o Daniel Snodgrass’ ankle bracelet monitor didn’t always work; so the fact that he had been cleared by law enforcement couldn’t be trusted

o Daniel Snodgrass was believed to have been crossing the county line [emphasis added]

o William Staubs was investigating Daniel Snodgrass

FELONY FALSE IMPRISONMENT

THE BOND REVOCATION OF DANIEL EVERETT SNODGRASS

‘MIRRORING’ THE CAYLEE ANTHONY DISAPPEARANCE WITH A STAGED KIDNAPPING OF HALEIGH CUMMINGS

21) On March 20, 2009, William Staubs revoked the bond of Daniel Snodgrass in Satsuma, Florida. In doing so, he violently slammed the handcuffed man down onto the ground face first. Art Harris, tabloid blogger (formerly of CNN) accompanied Staubs and filmed the entire event. Harris subsequently published it on You Tube.

22) Information obtained during Plaintiff’s journalistic investigation shows the Daniel Snodgrass bond revocation was a strategically planned media event intended to create the false appearance for the American public that Daniel Snodgrass was the pedophile/murderer that kidnapped HaLeigh Ann-Marie Cummings.

23) The expanded intent of the Daniel Snodgrass bond revocation media stunt hoax was to create the false appearance that Daniel Snodgrass might have also murdered Caylee Marie Anthony, whose body had been discovered in December of 2008, 75 miles south in Orlando.

24) The staged kidnapping of HaLeigh Cummings was carefully planned and executed to create REASONABLE DOUBT for any possible criminal charges that may be brought against those responsible (e.g. Rev. Richard Grund) for the death of Caylee Anthony – 75 miles south in Orlando.

➢ Evidence shows Caylee Marie Anthony likely died during an exorcism and/or satanic ritual based upon:

✓ The expressed suspicions of Cindy Anthony contained in the files of the Orange County Prosecutor’s Office, as reported by the National Enquirer in 2009

✓ Statements by Wayanne Kruger to Plaintiff that Rev. Richard Grund told her HaLeigh Cummings was born “without a soul” because she has Turner’s syndrome and no reproductive ability

✓ Statements by Wayanne Kruger to Plaintiff that she feared Rev. Grund may have killed HaLeigh Cummings in one of his “frickin exorcisms”

✓ Rev. Grund’s consistent expressions of fear that his family’s DNA (pubic hair, semen) was going to be ‘planted’ on Caylee Anthony’s body

✓ Rev. Grund’s assertion the slain child’s mother was physically taking on the form of the ancient satanic god “Moloch” which demanded the sacrifice of babies

← After the bond revocation and physical assault on Daniel Snodgrass by William Staubs, Snodgrass went to the Putnam County Sheriff’s Office and demanded criminal charges be filed against Staubs

← On dates following William Staubs’ arrest, REDACTED REDACTED REDACTED made a flurry of telephone calls to authorities on behalf of Staubs, including telephone calls to State’s Attorney Joseph Boatwright, officers at the Putnam County Sheriff’s Office, and newspapers

▪ The newly discovered information by Plaintiff now shows that REDACTED REDACTED made these calls as William Staubs’ REDACTED

← REDACTED REDACTED advised William Staubs that REDACTED had spoken to authorities, and that if he left Putnam County he would not be arrested

← William Staubs refused to leave Putnam County and remained active in the HaLeigh Cummings case

← On May 20, 2009, William Staubs was arrested by the Putnam County Sheriff’s Office and charged with felony false imprisonment based upon his actions regarding Daniel Snodgrass on March 20, 2009

THE NEWLY DISCOVERED EVIDENCE OF AN E-MAIL IN THE POSSESSION OF

TIMOTHY CHARLES HOLMSETH

25) In November, 2014, Plaintiff discovered back-up files he saved on a hard-drive. While reviewing audio interviews, Plaintiff discovered key information about REDACTED REDACTED, William Staubs, Richard Grund, and Wayanne Kruger that had been lost in the malicious illegal destruction of Plaintiff’s hard-drive by Defendant City.

THE E-MAIL

26) On March 20, 2009, William Staubs executed the Daniel Snodgrass bond revocation media hoax after the Chili’s meeting with REDACTED REDACTED, Art Harris, and others.

27) On March 23, 2009, Richard Grund emailed REDACTED REDACTED REDACTED and told REDACTED he had a following of supporters on the Web because of his family’s involvement with the Casey Anthony murder case. He told REDACTED REDACTED he believed he could encourage donations from his followers to help support William Staubs and keep him going.

28) In his email, Richard Grund told REDACTED REDACTED he had been threatened by the Anthony family and it would not be a good idea to accept donations directly through his ministry. He asked REDACTED REDACTED if REDACTED could set up a “client account” [emphasis added] for the funds. He asked REDACTED to think about it and advised he would call REDACTED the next day to discuss it.

29) After receiving the aforementioned email from Richard Grund, REDACTED REDACTED then forwarded the email to William Staubs and said, “Bill, is this your guy? Give me authority to talk to him and tell me what you want me to do with him”.

30) William Staubs replied to REDACTED REDACTED and said, “Yes he is REDACTED – he got us this gig”.

31) The fact that REDACTED REDACTED asked William Staubs to give REDACTED “authority” to speak to Richard Grund regarding a “client account” demonstrates REDACTED REDACTED was Williams Staubs’ REDACTED.

32) REDACTED REDACTED is a REDACTED REDACTED and only licensed to practice REDACTED REDACTED. REDACTED REDACTED REDACTED Kathy Staubs, the ex-wife of William Staubs during the Staubs’ REDACTED, which creates further conflict of interest issues.

33) The fact pattern and timeline shows that REDACTED REDACTED was the REDACTED for BOTH William Staubs and Crystal Sheffield at the same time.

34) The e-mail shows that in March, 2009, REDACTED REDACTED was receiving instructions and directives from William Staubs.

35) REDACTED REDACTED was William Staubs’ REDACTED BEFORE REDACTED was Crystal Sheffield’s REDACTED, and strategically proceeded covertly as an agent of William Staubs, amidst William Staubs’ felonious activity, for which he was arrested, while presenting REDACTED to the American public as the REDACTED for the mother of a missing child.

36) Defendant City attempted to destroy this evidence.

Respectfully submitted,

|November 21, 2014 |Timothy Charles Holmseth |

| |320 17th Street N.W. |

| |Unit # 17 |

| |East Grand Forks, MN |

| |56721 |

| |218.773.1299 |

| |218.230.1597 (cell) |

| |tholmseth@ |

| | |

| |PRO SE |

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