In the United States District Court s20

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA

PLAINTIFF TIMOTHY CHARLES HOLMSETH’S

MOTION FOR CONTINUANCE

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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:

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MEMORANDUM IN SUPPORT

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

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

1. 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.

1. 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.

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

1. 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

1. 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.

1. 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.

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

1. 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.

1. Plaintiff then began reviewing hours of audio interviews.

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

1. 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.

1. 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).

1. 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.

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

1. 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.

1. 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

1. 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.

1. 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

1. 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.

1. 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.

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

1. 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.

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

1. 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.

1. 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.

1. 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).

1. 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.

1. 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.

1. 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:

1. 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;

1. 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.

Þ  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.

Þ  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.

Þ  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.

Þ  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:

Þ  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:

ü  Sent into the case by Rev. Richard Grund

ü  To act as the PI for Crystal Sheffield

ü  While being financed by a drug dealer from Miami

RICHARD GRUND

Þ  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.

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