Law 1: Charlie Kirk Investigation - DoJ/FBI Forced Disclosure Act

AUTHOR: Bryan Starbuck (BryanStarbuck@gmail.com)

Short Title

This Act may be cited as the "Charlie Kirk Files Forced Disclosure Act — Law Enforcement."

Title

The Charlie Kirk Files Forced Disclosure Act - Law Enforcement

Purpose

To require the Department of Justice, the Federal Bureau of Investigation, and all federal, state, and local law enforcement agencies to fully and immediately disclose all files, records, communications, and information in their possession related to the investigation of the death of Charlie Kirk, including but not limited to the 227 specific disclosure items enumerated in Schedule A of this Act.

Disclaimer: This document does not assert as fact that any individual, organization, or government entity has committed any criminal, illegal, or immoral act. All references to persons and entities are made solely for proposed legislative and legal discovery purposes — to identify what information should be disclosed and investigated through lawful processes. The items listed here are questions for investigation, not conclusions. No statement in this document should be understood as an accusation, allegation, or assertion of wrongdoing against any party. This document exists solely to support public transparency through lawful legislative and judicial processes.

Section 1: Congressional Findings

The Congress finds the following:

(a) Constitutional Authority. The Congress has authority to enact this legislation pursuant to Article I legislative and oversight powers, the Spending Clause (Article I, Section 11, Clause 1) with respect to state and local cooperation, and the Commerce Clause (Article I, Section 11, Clause 3) with respect to financial records and interstate communications.

(b) Inadequacy of Existing Investigations. The investigation into the death of Charlie Kirk on September 10, 2025, at Utah Valley University in Orem, Utah, has been marked by significant deficiencies including: allegations of evidence destruction, crime scene alteration, witness intimidation, blocked FOIA requests, and failure to investigate credible leads regarding foreign intelligence activity, including approximately 12 foreign-registered cell phones detected at the shooting site, foreign military aircraft delivering personnel with Defense Attache badges to Provo Municipal Airport, and a HADES surveillance aircraft circling 35 minutes before the shooting.

(c) Prior Disclosure Law Failures. The JFK Assassination Records Collection Act of 1992 (Public Law 102-526) failed to achieve full disclosure because successive Presidents exercised override authority to withhold records for over 30 years. The Epstein Files Transparency Act (Public Law 119-38), while passing 427-1 in the House and by unanimous consent in the Senate, suffered compliance failures when the Department of Justice released only approximately 12,285 documents out of potentially 6+ million pages by the statutory deadline, with no Special Master mechanism to compel compliance. This Act is designed to remedy these structural deficiencies.

(d) Public Interest in Transparency. The public has a compelling interest in full disclosure of all records related to the death of Charlie Kirk, a prominent public figure killed in a public venue, where substantial evidence suggests involvement beyond a single individual. The integrity of public institutions depends upon transparency and accountability.

Section 2: Broad Mandatory Disclosure

(a) Catch-All Requirement. Within 30 days of enactment, all covered agencies shall produce and make publicly available in a searchable and downloadable format ALL records, documents, communications, and investigative materials in their possession that relate in any way to the investigation of the death of Charlie Kirk, the prosecution of Tyler Robinson, or any matter that could help establish the full truth about the circumstances of Charlie Kirk's death. This requirement is not limited to the specific items enumerated in Schedule A but extends to any and all records that could assist in understanding the investigation.

(b) No covered agency may claim any privilege, classification, or exemption to withhold covered records, except as narrowly provided in Section 6.

(c) Each covered agency shall designate a senior official, at the level of Deputy Director or above, responsible for compliance with this Act. Such official shall certify under penalty of perjury that all responsive records have been identified and produced.

(d) Each covered agency shall conduct a comprehensive search of all file systems, databases, email archives, internal communication platforms, and storage media to identify covered records, and shall submit to Congress a declaration describing the scope and methodology of the search. The search shall encompass every database, file system, email archive, communication platform, classified storage system, and backup system across every division, field office, and component of the agency — not solely the primary case file. Each covered agency shall certify that it searched every system, not merely the systems deemed "logically" responsive. The review board shall have authority to direct agencies to search specific additional systems the board identifies. No covered agency may define its own compliance — the review board makes that determination. The FBI shall specifically search and produce records from: (1) the primary case file, (2) all counterintelligence files, (3) all FISA files, (4) all headquarters supervisory files, (5) all internal affairs and Office of Professional Responsibility files, (6) all field offices (not solely Salt Lake City), (7) the Director's office files, (8) all email archives including personal email accounts of agents who worked the case, and (9) all classified and compartmented information systems. The review board shall specify the systems to be searched; FBI discretion over search scope is not permitted.

(e) Compulsory Process for Private Entity Records. Within 15 days of enactment, each covered agency shall issue subpoenas, National Security Letters, or other compulsory process for all records described in Schedule A that are held by private entities — including but not limited to TPUSA, Mosaic Pro Events, rental car companies, hotels, Accurate Energetic Systems (AES), banks, telecommunications providers, and any other entity in possession of relevant records — regardless of whether the agency previously sought such records. The review board established under Section 11 shall have independent subpoena power over private entities for any records described in Schedule A. Any private entity that destroys, alters, or conceals records after receiving notice under this subsection shall be subject to the same criminal penalties as government agencies under Section 10. Private Entity Compliance Deadline. Any private entity served with a subpoena or compulsory process under this subsection shall comply within 30 days of service. Any private entity that fails to comply within 30 days shall be subject to a civil penalty of $100,000 per day of non-compliance, enforceable by the review board or any federal district court. The review board may seek expedited contempt proceedings against non-compliant private entities, and courts shall hear such motions within 7 days of filing. The review board may appoint a Special Master with authority to conduct on-site inspections of private entity records and systems. The Special Master shall have authority to direct forensic imaging of private entity systems within 15 days of enactment for TPUSA and Mosaic Pro Events. Small Entity Extension. Private entities with fewer than 50 employees may petition the review board for a single 30-day extension of the compliance deadline upon a showing of good faith compliance efforts, including documentation of steps taken to locate and produce responsive records. The review board shall rule on such petitions within 7 days of filing. This extension is not available to any entity that has destroyed, altered, or concealed records after receiving notice under this subsection.

(f) Negative Certification for Non-Existent Records. Each covered agency shall file a sworn declaration, signed by the senior official designated under subsection (c), listing every category in Schedule A and stating, for each category: (1) what records the agency found responsive to that category; (2) the volume and nature of records produced; and (3) for any category where the agency claims no responsive records exist, a detailed explanation of why such records should not be expected to exist given the agency's mission, jurisdiction, and involvement in the investigation. A bare assertion that "no responsive records were found" without explanation shall be treated as non-compliance. The review board may challenge any negative certification and require the agency to demonstrate, under oath, the search methodology used and the basis for claiming non-existence.

Section 3: Rolling 72-Hour Law Enforcement Production

(a) Continuing Disclosure Obligation. Beginning on the date of enactment and continuing indefinitely, each covered agency shall collect and produce to the review board and make publicly available any newly generated record, report, communication, forensic result, investigative lead, interview report, or any other information that relates to any Schedule A item or to the death of Charlie Kirk within 72 hours of its creation, receipt, or discovery by the agency.

(b) This rolling production obligation applies to:

1. Any new record, report, or investigative product created by the agency after enactment that relates to any Schedule A subject
2. Any record received from a foreign government, foreign law enforcement partner, or international organization after enactment that relates to any Schedule A subject
3. Any previously existing record discovered after the initial 30-day production deadline
4. Any record, lead, or evidence identified by investigation teams established under the Charlie Kirk Mandatory Investigation Act (Law 3) or the Charlie Kirk Trusted Investigators Act (Law 4) that relates to records in the possession of a covered agency under this Act
5. Any record that a Designated Trusted Investigator, an investigation team under Law 3, or the external independent monitor under Law 3 identifies as responsive and requests from a covered agency — such requests shall be treated as mandatory production orders with the same 72-hour deadline
6. Any information generated in response to or as a result of investigations conducted under the Charlie Kirk Mandatory Investigation Act (Law 3) or the Charlie Kirk Trusted Investigators Act (Law 4)
7. Any communication between covered agencies regarding Schedule A subjects, including internal memoranda, emails, and verbal communications (which must be memorialized in writing within 24 hours)

(c) Each covered agency shall designate a compliance officer responsible for monitoring all new law enforcement production for Schedule A relevance and ensuring 72-hour disclosure. The identity of the compliance officer shall be reported to the review board within 7 days of enactment.

(c-1) Each compliance officer shall maintain a log of all investigative and records-production activities related to Schedule A subjects and provide it to the review board weekly.

(d) Failure to produce a newly generated or newly discovered record within 72 hours constitutes obstruction under Section 10(a). The 72-hour deadline may not be extended by legal review, privilege review, or any other internal process.

(e) The review board shall maintain a public log of all rolling disclosures, including the originating agency, date of creation, date of disclosure, and Schedule A item(s) addressed.

(f) Investigation-Triggered Disclosure. When any investigation team established under the Charlie Kirk Mandatory Investigation Act (Law 3) or the Charlie Kirk Trusted Investigators Act (Law 4) discovers evidence suggesting the existence of additional records held by a covered agency under this Act, the covered agency shall: (1) conduct a targeted search for such records within 48 hours of notification; (2) produce all responsive records within 72 hours of identification; and (3) certify under penalty of perjury the completeness of its response. The investigation teams under Laws 3 and 4 may issue binding production requests directly to any covered agency under this Act, and such requests carry the same legal force as a subpoena.

Section 4: Specific Mandatory Disclosures (Schedule A)

(a) In addition to the broad catch-all requirement of Section 2, the following categories of records are specifically and individually mandated for disclosure, as more fully described in Schedule A attached hereto:

FBI Investigation Files (Items #58-#67):

1. All FBI Form 302 interview reports from the inception of the investigation to the present
2. All FBI 302s documenting any request by FBI agents to witnesses to delete evidence, including identification of agents involved
3. All FBI counterintelligence division reports regarding foreign intelligence investigation related to the case
4. All FBI agent notes, memoranda, rough notes, and investigative working papers
5. All FBI case opening documentation, investigative plans, and scope documents
6. All FBI counterintelligence reports on foreign intelligence services operating in Utah (January 2023 to present)
7. All FBI threat assessments for Charlie Kirk regarding foreign intelligence targeting
8. All FBI liaison reports with CIA, NSA, and DHS regarding foreign nationals connected to the case
9. All FBI counterintelligence surveillance logs tracking suspected foreign intelligence officers in Utah
10. All FISA applications and materials related to foreign nationals in Utah connected to the case

Cell Phone and Digital Data (Items #68-#74):

1. Cell tower dumps for UVU campus (September 10, 2025, 8AM-6PM)
2. Cell tower dumps for Tyler Robinson's residence (September 1-15, 2025)
3. Cell tower dumps for Provo Airport (August 25 - September 15, 2025)
4. Geofence warrant applications and returns for UVU
5. Cell site location information for phones with international roaming (Egyptian, French, Israeli carriers)
6. FBI analytical reports identifying foreign phones
7. Subscriber information for all unidentified foreign phones

Customs and Border Protection Records (Items #75-#81):

1. CBP entry/exit records for Egyptian, French, and Israeli nationals (July-November 2025)
2. TSA PreCheck and Known Traveler records for foreign nationals with expedited clearance
3. CBP special clearance records for military contractors
4. Passenger manifests for international flights to SLC/Provo (September 3-17, 2025)
5. CBP biometric data for foreign arrivals during the relevant period

Aircraft Records (Items #82-#87 and related):

1. All flight records, passenger manifests, and crew lists for Egyptian aircraft SU-BTT, SU-BND, SU-BTU, SU-BTV, and SU-BGM
2. All records for surveillance aircraft N1098L (HADES spy plane), N59906 (MARC Inc. Piper), N888KG, N560TW, N40JD, N872RA, N102DZ, N55906, and N582MM (TPUSA-linked aircraft)
3. All records for U.S. Air Force VIP transport jet 99-0404 (SAM callsign) and US Gov flight SAM-000 and foreign military aircraft T7ELL and EJM36
4. CBP inspection records, cargo manifests, and security clearance records for all listed aircraft
5. Who contracted, paid for, and received data from any surveillance aircraft

Financial Records (Items #99-#105):

1. International wire transfers to Utah (August-September 2025) from Egyptian, French, or Israeli sources
2. All Suspicious Activity Reports (SARs) for Utah during the relevant period
3. All Currency Transaction Reports over $10,000 involving foreign nationals
4. All payment records (credit card, PayPal, Venmo, Zelle) for rental cars, hotels, and any payments to persons present at UVU
5. All wire transfers or payments to Tyler Robinson or Lance Twiggs, including any transfers through DSA-linked accounts
6. FBI financial crimes investigation files related to the case
7. All records relating to DOD contracts awarded to Bilt Inc. in June 2025, including approximately $8 million from the U.S. Air Force, all invoices, payment authorization chains, ownership records, and all financial flows into and out of Bilt Inc. from March 2025 through the present (Items #223-#227)

Chain of Custody and Physical Evidence (Items #106-#113):

1. Complete chain of custody for the Mauser Model 98 rifle, including all custody documentation with timestamps
2. All body camera footage from initial search, K-9 search, and re-search
3. K-9 unit deployment records and reports
4. Names, reports, and records of FBI agents who directed the re-search that located the weapon
5. All communications between FBI and local law enforcement regarding the rifle search
6. DNA analysis and fingerprint analysis from all rifle surfaces, trigger, scope, towel, and cartridges
7. FBI internal investigation records regarding gun planting allegations

Surveillance and Video Evidence (Items #119-#124):

1. All UVU campus security camera footage (September 9-11, 2025)
2. Traffic camera footage on routes between airports and UVU
3. Airport surveillance footage (Provo and SLC)
4. Hotel surveillance footage within 20 miles of UVU
5. License plate reader data for rental vehicles
6. All video footage of witnesses that FBI agents requested be deleted

Ballistics and Forensics (Items #142-#149):

1. Complete ATF trace for the Mauser Model 98
2. All manufacturing, import, and serial number documentation
3. Metallurgical analysis of rifle components
4. Analysis of cartridge engravings
5. All ballistics analysis regarding the bullet path, caliber determination, and wound characteristics
6. Any analysis regarding whether a caliber other than .30-06 was fired

Autopsy and Medical Evidence (Items #167-#172):

1. Complete autopsy report with wound measurements, trajectories, and photographs
2. All evidence from the body regarding the lavalier microphone
3. Toxicology results and any unusual findings
4. Wound trajectory analysis
5. Explosive residue testing on body, clothing, and crime scene materials

Additional Specific Items (#1-#57 Intelligence-Related):

1. All records relating to planes listed in Schedule A, including location, passengers, cargo, and any connection to the investigation (Items #1, #15, #50)
2. All records regarding threats, plans, or actions by any foreign intelligence service toward Charlie Kirk (Item #2)
3. All records relating to distraction persons present at UVU, decisions not to charge them, and blocked FOIA requests related to them (Items #20-#22)
4. All records relating to electronic jamming of cell/internet signals at UVU (Item #11)
5. All records relating to drone activity, video feeds, and surveillance operations at UVU (Items #8, #9, #12, #15)
6. All records relating to evidence of FBI requesting witness video deletion or videos being remotely deleted from witness devices (Items #48-#49)
7. All records relating to meetings at Fort Huachuca AZ and One Rodney Square, Wilmington DE (September 1-11, 2025) related to Charlie Kirk (Items #28-#31)
8. All records relating to Charlie Kirk's communications expressing fear for his life (Item #14)
9. All records relating to rental cars used by foreign operatives (Items #43, #125-#130)
10. All records relating to psychological operations or manipulation of Tyler Robinson or Lance Twiggs (Item #39)
11. All records relating to foreigners in TPUSA or TPUSA donor communications with foreign intelligence (Items #3-#4, #161-#167)
12. All records relating to the Hampton meeting (August 3-6, 2025) (Item #51)
13. All records relating to the DoD contract N0016425PJ538 for miniaturized anti-personnel charges delivered August 25, 2025
14. All records relating to the AES factory explosion (October 10, 2025) and its connection to the investigation
15. All records relating to crime scene alteration, including who authorized paving over the crime scene
16. All records related to Tyler Robinson's family statements and his claim of knowledge of other perpetrators (Items #177-#180)
17. All records of witness intimidation including fake therapy sessions and witness suppression (Items #180-#182)
18. All records related to Brian Harpole (member of Kirk's security detail with foreign security service background) (Item #183)
19. All records related to hospital routing decisions and FBI blocking a surgeon (Items #183-#186)
20. All TPUSA financial records including shell company payments and post-assassination board actions (Items #186-#188)
21. All records from Mosaic Pro Events, the Rode Wireless PRO microphone audio, and Mikey McCoy's mic-up video (Items #188-#191)
22. All records related to Butch Hibbs at UVU and the Heber City to Nashville flight on AES delivery day (Items #191-#193)
23. All records of the FBI RAV4 near Robinson and FBI direction of the re-search that located the weapon (Items #193-#195)
24. All records of the Fort Huachuca pre-assassination meeting (Item #196)
25. All records of live stream interruptions at UVU (Item #197)
26. All of Kirk's pre-death warnings, records on his parents' legal representation decisions, and his girlfriend (Items #197-#200)
27. Full forensic analysis of bullet casing engravings and planted evidence indicators (Item #201)
28. All records related to UVU crime scene paving (Item #202)
29. All records of the AES factory explosion investigation and its connection to DoD contract N0016425PJ538 (Item #203)
30. Tyler Robinson's complete travel path before and after the shooting, all prior visits to UVU campus, all evidence regarding Robinson's exact position at the moment of the shot, and all video footage and analysis of whether the rooftop suspect was running or stationary when the shot was fired (Items #203-#207)
31. All records related to the registration of domain vancekirk2028.com two days after Kirk's death, including the true registrant identity behind GoDaddy's Domains By Proxy privacy service, payment records, and all evidence of foreknowledge (Item #222)

(b) Schedule A shall be the document titled "Charlie Kirk 227 Critical Disclosure Items" as maintained in the public repository at https://github.com/BryanStarbuck/Charlie_Kirk_175_Critical_To_Expose, as of the date of enactment, incorporated by reference and attached as an appendix to this Act.

(c) The enumeration of specific items in this Section and in Schedule A shall not be construed to limit the scope of the broad disclosure mandate in Section 2. Both the broad mandate and the specific enumeration apply concurrently.

(d) Schedule A Count Discrepancy Resolution. In the event of any discrepancy between the Schedule A item count referenced in this Act and the Schedule A item count in any companion Act (the Charlie Kirk Intelligence Services Disclosure Act, the Charlie Kirk Mandatory Investigation Act, or the Charlie Kirk Trusted Investigators Act), the higher count controls, and the most comprehensive version of each individual item across all four Acts shall be deemed incorporated.

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Schedule A: 227 Critical Disclosure Items

Application Notes:

(a) For purposes of this Schedule, references to the FBI and the Department of Justice include the intelligence and counterintelligence divisions of such agencies. Records held by these divisions are subject to the same disclosure requirements as records held by any other division of the agency.

"People Listed" (PEOPLE_LISTED): are the set of people information must be disclosed on. It is listed in Schedule B. A summary: P1) TPUSA organization, P2) TPUSA security team, P3) Sound/AV/equipment crew, P4) All persons present at UVU 9/10/2025, P5) FBI personnel, P6) DOJ and federal prosecutors, P7) Utah state and local law enforcement, P8) Judges and court personnel, P9) Defense attorneys, P10) US intelligence community personnel, P11) Foreign intelligence operatives and foreign nationals, P12) Military personnel and contractors, P13) Aircraft personnel, P14) Drone and surveillance operators, P15) Distraction persons and persons of interest, P16) Airport and transportation personnel, P17) TPUSA donors and persons who met with Kirk, P18) Kirk's close associates and confidants, P19) Erika Kirk and Kirk family, P20) Medical and hospital personnel, P21) Crime scene alteration personnel, P22) Witnesses and civilian videographers, P23) Life insurance and financial persons, P24) Tyler Robinson's associates, P25) Political figures and government officials, P26) Lobbyists and political organizations, P27) Media and journalists with inside knowledge, P28) AES personnel, P29) Rental car and lodging personnel, P30) Digital platform and telecom personnel, P31) UVU administration and staff, P32) Persons on listed aircraft, P33) Persons connected to Scott Lazerson, P34) Religious leaders, P35) Any other person with relevant information.

A Table of Contents

• Intelligence Service Discovery (#1–#57)
• FBI 302 Reports (#58–#62)
• FBI Counterintelligence (#63–#67)
• Cell Phone Data (#68–#74)
• Airport / CBP Records (#75–#81)
• Egyptian Planes (#82–#87)
• Israeli Cell Phones (#88–#92)
• Provo Airport (#93–#98)
• Financial Records (#99–#105)
• Chain of Custody (#106–#113)
• Threat Assessments (#114–#118)
• Surveillance Footage (#119–#124)
• Rental Car Records (#125–#130)
• Hotel Records (#132–#136)
• Digital Forensics (#137–#142)
• Ballistics (#143–#149)
• Distraction People (#150–#156)
• Drones (#157–#161)
• TPUSA Intel (#162–#167)
• Autopsy / Medical (#168–#172)
• International Liaison (#173–#177)
• Tyler Robinson Defense & Family (#178–#180)
• Witness Intimidation (#181–#182)
• Security Detail & Foreign Connections (#183)
• Medical & Hospital Records (#184–#186)
• TPUSA Financial Fraud (#187–#188)
• TPUSA Employee and Contractor Unusual Payments (#189)
• Mosaic Pro Events / AV Equipment (#190–#192)
• Butch Hibbs & Exploding Microphone (#193–#194)
• FBI Conduct at Scene (#195–#196)
• Fort Huachuca Meeting (#197)
• Event Live Streams (#198)
• Kirk's Personal Statements & Relationships (#199–#201)
• Bullet Engravings & Planted Evidence (#202)
• Crime Scene Paving (#203)
• AES Factory Explosion (#204)
• Tyler Robinson Movement & Identity (#205–#208)
• Venue Access & Non-Traditional Weapons (#209–#210)
• Israeli IP Surveillance Targeting (#211)
• Autopsy Failure (#212)
• Corner-Shot Weapon Analysis (#213)
• State Official Communications (#214)
• Hospital Compromise (#215)
• Hospital Bomb Threat and Diversion (#216)
• Carbyne 911 System Data (#217)
• Independent Ballistics and Forensic Testing Authority (#218)
• TPUSA Insider Aircraft N582MM (#220)
• Egyptian Aircraft Return to Provo (#221)
• VanceKirk2028.com Domain Registration (#222)
• Bilt Inc. DOD Contracts (#223–#227)

Each item in Schedule A is individually mandated for complete disclosure. Partial compliance with Schedule A does not constitute compliance with this Act.

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Intelligence Service Discovery (#1–#57)

• #1: Aircraft Records for Listed Planes: Each covered agency shall produce all records relating to the following aircraft: SU-BTT, SU-BND, SU-BTU, SU-BTV, SU-BGM, N1098L, N888KG, N59906, N560TW, N102DZ, N40JD, N872RA, 99-0404, T7ELL, EJM36, N55906, and N582MM—including location, passengers, crew, cargo, and anyone who flew on them within 2 weeks before or on the day of the assassination. Each covered agency shall also produce all records related to investigating the assassination or anything peripheral, or any connection to anyone in the Charlie Kirk investigation involving these aircraft.

• #2: Foreign Threats Against Charlie Kirk: Each covered agency shall produce all records relating to threats, plans, or actions by any foreign intelligence service or country toward assassination of Charlie Kirk, including consideration of such actions, or hiring contractors to carry them out. Each covered agency shall also produce all records relating to any foreign government or entity that discussed, planned, or considered harm to Charlie Kirk in any capacity.

• #3: Foreigners Employed by TPUSA: Each covered agency shall produce all records relating to whether TPUSA employed or engaged any foreigners or anyone holding citizenship other than solely U.S. citizenship. Each covered agency shall also produce all records relating to any non-U.S. nationals who had access to TPUSA operations, events, finances, or personnel in any capacity.

• #4: TPUSA Donor Foreign Intel Contact: Each covered agency shall produce all records relating to whether any TPUSA donors had communication, interaction, or meetings with any foreign intelligence service within the 3 months before the assassination, including any FBI, DoJ, or U.S. intelligence documents, investigation information, cell data, or any other data showing these connections or communications. Each covered agency shall also produce all records relating to any TPUSA donor interactions with foreign governments, officials, or intelligence-linked entities.

• #5: Tyler Robinson Clothing & Biometric Evidence: Each covered agency shall produce all records relating to clothing of Tyler Robinson and what other possible perpetrators the investigation shows this may be. Each covered agency shall produce all FBI or law enforcement analysis on whether the person observed in the stairways of the Losee Center is the same individual as Tyler Robinson — including height, build, gait, clothing, face comparison, and any video or photographic evidence from stairway cameras or adjacent angles. All biometric analysis performed on FBI-released surveillance images estimating Tyler Robinson's age — including facial metrics such as angular jaw definition, skin texture, build proportions, and any other age-estimation methodology — and whether this analysis is consistent with Robinson's stated age or suggests the individual is aged 20–24 or any other range. Each covered agency shall also produce all records relating to any discrepancies between witness descriptions, surveillance footage, and official identification of suspects, and any analysis concluding the stairway individual is or is not Tyler Robinson.

• #6: FBI Ballistics Analysis: Each covered agency shall produce all ballistics evidence the FBI or any law enforcement agency has related to the Charlie Kirk shooting, including the total number of shots fired, the origin point of each shot, the caliber of each round, and whether shots originated from different locations or weapons. Each covered agency shall produce all records establishing whether gunpowder residue was found in the barrel of the Mauser Model 98, whether the barrel showed signs of recent firing, and whether residue analysis is consistent with the rifle having been the weapon actually fired on September 10, 2025. Each covered agency shall also produce all records relating to any ballistic tests, comparisons, or analyses performed by any agency or laboratory.

• #7: Forensic Acoustic Analysis: Each covered agency shall produce all forensic acoustic analysis the FBI or any law enforcement agency has related to the shooting, including whether acoustic or other investigative means were able to determine the source location and origin point of any bullet that entered Charlie Kirk's body. Each covered agency shall also produce all records relating to any sound recordings, audio analysis, or gunshot detection data from the incident.

• #8: Military Drone Activity at UVU: Each covered agency shall produce all records relating to whether any military drones were flying at or near UVU on September 10, 2025. Each covered agency shall also produce all records relating to any military aerial surveillance or unmanned aircraft operations within 50 miles of UVU on that date.

• #9: Civilian Drone Activity at UVU: Each covered agency shall produce all records relating to whether any civilian drones were flying at or near UVU on September 10, 2025. Each covered agency shall also produce all records relating to any civilian aerial surveillance, hobbyist drones, or commercial drone operations within 10 miles of UVU on that date.

• #10: Security Planning Failures at UVU: Each covered agency shall produce all records relating to the PERSON_10_REDACTED security firm's planning for the Charlie Kirk event on September 10, 2025, including the planning window for the last 30 university events with 300+ people, earliest communications with local police or campus, and internal planning timelines. Each covered agency shall also produce all records relating to any security lapses, protocol deviations, or unusual changes to standard security procedures for the UVU event.

• #11: Electronic Signal Jamming at UVU: Each covered agency shall produce all records relating to whether electronic means were used to cut internet access (cell-based or otherwise) in the seconds before, during, and after the shooting at UVU. Each covered agency shall also produce all records relating to any disruption, degradation, or interference with communications signals within 2 miles of UVU on September 10, 2025.

• #12: Drone Video Feed Recipients: Each covered agency shall produce all records relating to any drones having video feeds sent back to anyone, including who received the feeds and which drones transmitted them. Each covered agency shall also produce all records relating to any aerial surveillance data collection, transmission, or storage related to UVU on September 10, 2025.

• #13: FBI Internal Withholding Discussions: Each covered agency shall produce all communications, meetings, or discussions within the FBI or U.S. intelligence where anything was communicated about not wanting information to reach the defense team or be presented at trial, including intelligence service factors related to the case. Each covered agency shall also produce all records relating to any deliberate decisions to withhold, suppress, or delay disclosure of any evidence or information.

• #14: Charlie Kirk Death Threat Communications: Each covered agency shall produce all communications (written or non-written) by Charlie Kirk about feeling threatened, his life ending early, thinking he would likely be killed, or anything related—including who received these communications, when, the exact content, and any preceding communications. Each covered agency shall produce all FBI file interviews with recipients such as PERSON_4_REDACTED, PERSON_2_REDACTED, PERSON_3_REDACTED, PERSON_20_REDACTED, and Andrew. Each covered agency shall also produce all records relating to any person who received or heard about Kirk expressing fear for his safety in any context.

• #15: ISR Drone and Surveillance Aircraft Links: Each covered agency shall produce all records linking the Charlie Kirk event on September 10, 2025, to any U.S. Army ISR drone, plane N1098L, tech traded to any country or individual (Egypt, Israel, PERSON_60_REDACTED), approval by plane SU-BTT, or technology installed on any plane staying in a Utah airport for over a month. Each covered agency shall also produce all records relating to any military or intelligence surveillance technology deployed in connection with the event.

• #16: FBI Instructions to Airport Employees: Each covered agency shall produce all records relating to whether the FBI or anyone instructed any employee or person at the local airport to lie or provide false information. Each covered agency shall also produce all records relating to any pressure, coercion, or direction given to airport personnel regarding statements about the investigation.

• #17: Bullet Trajectory and Caliber Analysis: Each covered agency shall produce all records relating to the analysis or investigation into the bullet traveling through Charlie Kirk—why it didn't exit, what path it took, what evidence suggests it likely wasn't a .30-06 caliber or was another caliber, whether part of the microphone hit Kirk's neck, and the bullet path analysis. Each covered agency shall also produce all records relating to any wound characteristics, projectile behavior, or forensic evidence inconsistent with the official narrative.

• #18: Tyler Robinson Financial Transfers: Each covered agency shall produce all records relating to any money transfer to Tyler Robinson, including but not limited to any $50,000 in wire transfers through DSA-linked accounts in the months leading to the killing, and any knowledge of what funds were used for—logistics, travel, weapon acquisition, or otherwise. Each covered agency shall also produce all records relating to any financial transactions, gifts, payments, or funding of any kind received by Tyler Robinson from any source.

• #19: Lance Twiggs Financial Transfers: Each covered agency shall produce all records relating to any money transfer to Lance Twiggs, including but not limited to any $20,000 transfer or multiple transfers. Each covered agency shall also produce all records relating to any financial transactions, gifts, payments, or funding of any kind received by Lance Twiggs from any source during 2024–2025.

• #20: Distraction People Identification and Intel: Each covered agency shall produce all records relating to possible "distraction people" present on September 10, 2025, including: PERSON_179_REDACTED ("Fake Doctor w/Gun"), the pellet gun man at Joe Vera's Mexican Restaurant (201 W Center St, Provo), George Zinn, PERSON_53_REDACTED, curly hair "David" (PERSON_139_REDACTED / @RtothepowerofX), persons police were called on at Urban Pioneer Cafe or Sorenson Molecular Biotechnology Building, PERSON_42_REDACTED, and any others — including the person captured on video asking questions to Charlie Kirk who was also recorded beforehand practicing the same shocked facial expression, and who later appeared on CBS with Erika Kirk. Each covered agency shall produce all communications they had with any individual, government, or intelligence service — including U.S. intelligence or foreign intelligence — all claims they made, and any payments or coordination, including whether any distraction person communicated with, coordinated with, or worked with anybody before the shooting or for the shooting. Each covered agency shall produce all records establishing whether any distraction person was ever offered money or received money from any source, and all financial payments they received. Each covered agency shall produce all records of the question-asker's communications and coordination with any person before and after the event. Each covered agency shall also produce all records relating to any person who appeared at or near UVU that day in a manner suggesting coordination or operational purpose.

• #21: Decisions Not to Charge Distraction People: Each covered agency shall produce all communications, actions, or information about decisions not to charge the distraction people, by whom these decisions were made, and any communications inside FBI, DoJ, U.S. intelligence, or local law enforcement about not charging them. Each covered agency shall also produce all records relating to any instructions from any agency or official directing that these individuals not be charged, investigated, or questioned.

• #22: Blocked FOIAs About Distraction People: Each covered agency shall produce all records relating to decisions to reject or block FOIA, GRAMA, and equivalent requests regarding the distraction people, by whom, and any communications inside FBI, DoJ, U.S. intelligence, or local law enforcement about blocking them. Each covered agency shall also produce all records relating to any instructions from any source to deny, delay, or obstruct public records requests related to these individuals.

• #23: NCC Reasons for Intel Investigation: Each covered agency shall produce all records relating to why PERSON_15_REDACTED from the National Counterterrorism Center and others at NCC desired to have U.S. intelligence investigate the Charlie Kirk assassination, including the factors they found. Each covered agency shall also produce all records relating to any NCC assessment, analysis, or recommendation regarding the case.

• #24: NCC Review of FBI Files: Each covered agency shall produce all documents reviewed by PERSON_15_REDACTED (NCC) from FBI files or anything related to the Charlie Kirk investigation. Each covered agency shall also produce all records relating to any NCC interactions with FBI regarding the case, including requests made and responses received.

• #25: Suspect Clothing Discrepancies: Each covered agency shall produce all records from the FBI or DoJ about clothing on any possible suspects, including the reported difference between rooftop suspect clothing and Tyler Robinson's clothing, times seen, proposed clothing changes, and any video evidence. Each covered agency shall produce all FBI or law enforcement analysis comparing the person observed in the stairways to Tyler Robinson — whether they are the same person based on clothing, physical build, timing, and any biometric or facial recognition analysis. Each covered agency shall also produce all records relating to any inconsistency between witness descriptions and official suspect identification, and whether the investigation considered that the stairway individual and the rooftop individual may be different people.

• #26: Israeli Cellphones at UVU: Each covered agency shall produce all records relating to approximately 12 Israeli-registered cellphones at the shooting site, including who these people were, connections to U.S. or foreign intelligence, photos of them, what they did at UVU, how long they were in Utah, and whether they visited any investigation-linked locations (airport, Tyler's apartment, rental cars, listed planes). Each covered agency shall also produce all records relating to any Israeli nationals or Israeli-linked communications present in the Provo/Orem area during August–September 2025.

• #27: Sorenson Building Person of Interest: Each covered agency shall produce all records relating to the person of interest at or near the Sorenson Molecular Biotechnology Building / Urban Pioneer Cafe (35 S Wasatch Dr, Salt Lake City) on September 10, 2025, on whom police were called and reportedly told "The FBI wants you to stand by there with him" and "As per SBI and FBI, we've been given clear direction NOT to interview." All photos, files, and investigation information. Each covered agency shall also produce all records relating to any person at that location on that date who was subject to law enforcement attention or FBI direction.

• #28: Wilmington DE Meetings (Sept 1–11): Each covered agency shall produce all records relating to who attended and what was discussed at any meeting at the One Rodney Square building (920 North King St, Wilmington, DE) from September 1–11, 2025, including anything about Charlie Kirk, UVU, or someone being killed, whether in Suite 404 or elsewhere. Each covered agency shall also produce all records relating to any meeting at that location during that period involving any person connected to the investigation.

• #29: Fort Huachuca Meetings (Sept 1–11): Each covered agency shall produce all records relating to who attended and what was discussed at any meeting at Fort Huachuca, AZ, from September 1–11, 2025 (especially September 9), including anything about Charlie Kirk, UVU, or someone being killed. Each covered agency shall also produce all records relating to any intelligence or military meeting at Fort Huachuca during that period related to domestic targets or operations. Each covered agency shall specifically produce all records relating to aircraft N582MM — a plane frequently used by TPUSA insiders — including its October 4–5, 2025 presence at Fort Huachuca followed by an immediate flight to Kalispell, Montana coinciding with a TPUSA security team gathering in the same area, and all records of who was aboard this aircraft for any flight to or from Fort Huachuca at any time.

• #30: Fort Huachuca Attendee Identification: Each covered agency shall produce all records relating to whether PERSON_10_REDACTED or PERSON_7_REDACTED attended any meeting at Fort Huachuca, AZ, from September 1–11, 2025, especially September 9. Each covered agency shall also produce all records relating to any person connected to Charlie Kirk or TPUSA who was present at Fort Huachuca during that period.

• #31: SAM-Designated VIP Aircraft and Fort Huachuca Meetings: Each covered agency shall produce all records relating to any U.S. government aircraft operating under Special Air Mission callsigns SAM 702, SAM 000, 99-0404 SAM callsign, and any other SAM-designated callsign during the period September 7 through September 10, 2025, inclusive. For each such flight, the disclosure shall include: (i) the complete passenger manifest identifying all persons aboard by name, title, and agency or organizational affiliation; (ii) the complete itinerary, including point of origin, each intermediate stop, final destination, and the date and time of each departure and arrival; (iii) all transponder data, including any periods during which the aircraft's transponder was deactivated, operated in a reduced mode, or otherwise rendered non-visible to public flight-tracking systems, and the authority under which any such deactivation occurred; and (iv) whether any passenger deplaned at or traveled to Fort Huachuca, Arizona, or any installation in the Sierra Vista, Arizona area, Davis-Monthan Air Force Base, Peterson Space Force Base, Fort Bliss, or Joint Base Andrews. For any passenger who entered Fort Huachuca or any other military installation during the disclosure period, each covered agency shall further produce all records identifying: (a) every meeting attended by such passenger, including the date, time, location, and purpose of each meeting; (b) every person present at each such meeting; (c) every building or facility entered by such passenger, and every person present in each such building or facility during the passenger's presence. The foregoing disclosures shall specifically include, but not be limited to, any records concerning the presence or travel of senior U.S. government officials, Members of Congress, Erika Kirk, and any person who was at any time an employee, contractor, consultant, volunteer, donor, or affiliate of Turning Point USA or any TPUSA-affiliated entity. Each covered agency shall also produce all records relating to any other military VIP flight to or from Arizona, Utah, or Colorado during September 7–10, 2025, connected to any person identified in this Act.

• #32: SAM-Designated VIP Aircraft and AES Tennessee Operations: Each covered agency shall produce all records relating to any U.S. government aircraft operating under Special Air Mission callsign SAM 702, SAM 000, tail number 99-0404, or any other SAM-designated callsign — where a flight matching any one or more of these identifiers satisfies this requirement, and no agency shall withhold records on the basis that an aircraft did not match all listed identifiers — that at any time during the period October 9 through October 11, 2025, inclusive, flew into, flew over, landed in, took off from, or transited the airspace of the State of Tennessee. For each such flight, the disclosure shall include: (i) the complete passenger manifest identifying all persons aboard by name, title, and agency or organizational affiliation, without exception for any person regardless of rank, classification level, intelligence community affiliation, military grade, diplomatic status, or foreign nationality; (ii) the complete itinerary, including point of origin, each intermediate stop, final destination, and the date and time of each departure and arrival; (iii) all transponder data, including any periods during which the aircraft's transponder was deactivated, operated in a reduced mode, or otherwise rendered non-visible to public flight-tracking systems, and the authority under which any such deactivation occurred; (iv) the stated and actual purpose of each flight and each stop, including the reason each passenger was aboard and the purpose of their travel to or through Tennessee; and (v) whether any passenger deplaned at any location in Tennessee, including but not limited to any airport, airfield, military installation, or private landing facility. For any passenger who deplaned or was present in Tennessee during the disclosure period, each covered agency shall further produce all records identifying: (a) every meeting attended by such passenger, including the date, time, location, purpose of each meeting, and every person present; (b) every facility, building, or location visited by such passenger, including the Accurate Energetic Systems (AES) facility in Camden, Tennessee, or any AES-affiliated location, and every person present at each such location during the passenger's presence; (c) all communications by such passenger during the disclosure period relating to AES, the Charlie Kirk investigation, or any subject matter referenced in this Act. No covered agency shall limit its production to records that relate solely to a particular subset of the foregoing categories; the obligation is to produce all records responsive to any element of this item. The classification level, intelligence community affiliation, military rank, diplomatic status, or foreign nationality of any person aboard such aircraft or present at any meeting or facility shall not constitute grounds for withholding, redacting, or delaying disclosure of any record required by this item. Each covered agency shall also produce all records relating to any connection between SAM-designated flights to or through Tennessee during October 2025 and the Accurate Energetic Systems factory explosion on October 10, 2025, which killed 16 AES employees and may have destroyed evidence relevant to this investigation.

• #33: Alternative Shooter Location Analysis: Each covered agency shall produce all records, files, and investigation data relating to whether a shot was fired from a drone in the air, anywhere behind or to the side of Charlie Kirk, or from any location other than the rooftop. Each covered agency shall produce all records establishing whether a second sniper was positioned on any rooftop at or near UVU, including all rooftop access logs, surveillance footage of rooftops, and law enforcement sweeps of rooftops before, during, and after the shooting. Each covered agency shall produce all records establishing whether the person observed on the roof was running at the moment the shot was fired, and all video footage, witness statements, or analysis addressing the rooftop suspect's movement and posture at the time of the shot. The total number of shots fired from all locations and the direction each shot originated from. Each covered agency shall produce all evidence supporting or refuting a coordinated cell operation with multiple actors — including a shooter, a spotter for logistics, and an exfiltration handler — potentially under quasi-governmental or private military contractor auspices, and the FBI's admission of possible multiple accomplices. Each covered agency shall also produce all records relating to any analysis of alternative shooting positions, trajectories, or multiple shooter scenarios.

• #34: Foreigners in UVU Security Zone: Each covered agency shall produce all records relating to whether anyone with citizenship other than solely U.S. citizenship was in the security zone at UVU between 11 AM and 12:23 PM MT on September 10, 2025, which was controlled by Charlie Kirk's contract security team. Each covered agency shall also produce all records relating to any non-U.S. citizen who had access to restricted areas at the UVU event.

• #35: PERSON_45_REDACTED Intelligence Contact: Each covered agency shall produce all records relating to PERSON_45_REDACTED having any communication, coordination, or interaction with any U.S. or foreign intelligence service during April 1, 2025, through November 1, 2026. Each covered agency shall also produce all records relating to any intelligence service interest in or contact with PERSON_45_REDACTED at any time.

• #36: Investigation-Related Google Searches: Each covered agency shall produce all records relating to Google searches during October 2024 through September 11, 2025, for any terms unique to this investigation—people, planes, addresses, companies, or anything else—where any government entity has information related to the case. Each covered agency shall also produce all records relating to any digital search activity, browser history, or internet research by any person of interest related to the investigation.

• #37: Foreign Visitors to Lance Twiggs Home: Each covered agency shall produce all records relating to any foreigners or intelligence service personnel visiting the apartment or townhome of Lance Twiggs during March 1, 2025, through September 11, 2025. Each covered agency shall also produce all records relating to any surveillance, monitoring, or tracking of visitors to Lance Twiggs's residence during that period.

• #38: Electronic Equipment at Twiggs Residence: Each covered agency shall produce all records relating to any electronic equipment installed or operated by foreigners in, directed at, or near the apartment or townhome of Lance Twiggs during March 1, 2025, through September 10, 2025. Each covered agency shall also produce all records relating to any surveillance devices, monitoring equipment, or electronic operations targeting or near Twiggs's residence.

• #39: Psyops on Robinson or Twiggs: Each covered agency shall produce all records relating to any psychological operations or psychological manipulation carried out on either Tyler Robinson or Lance Twiggs by any government or non-government actor. Each covered agency shall also produce all records relating to any behavioral influence, radicalization efforts, grooming, or manipulation directed at Robinson or Twiggs by any person or entity.

• #40: Lance Twiggs Intelligence Interactions: Each covered agency shall produce all records relating to any interactions (meetings, communication, coordination) between Lance Twiggs and any FBI, U.S., or foreign intelligence during April 1, 2025, through September 10, 2025. Each covered agency shall also produce all records relating to any intelligence service contact with or interest in Lance Twiggs at any time.

• #41: Robinson/Twiggs Digital Communications: Each covered agency shall produce all records relating to any interactions between Lance Twiggs or Tyler Robinson and any FBI, U.S., or foreign intelligence via Discord, Steam, in-game voice chat, or text message during August 1, 2024, through September 10, 2025. All odd, suspicious, or unusual instant messages, in-game communications, Discord exchanges, or text messages potentially related to assassination planning, threats, or coordination. Each covered agency shall also produce all records relating to any digital or electronic communication between Robinson or Twiggs and any government agent or intelligence operative on any platform.

• #42: PERSON_27 and PERSON_28 Intel Contact: Each covered agency shall produce all records relating to any interactions between PERSON_27_REDACTED or PERSON_28_REDACTED and FBI, U.S., or foreign intelligence during August 1, 2024, through September 10, 2025. Each covered agency shall also produce all records relating to any intelligence service contact with or interest in these individuals at any time.

• #43: Investigation-Linked Rental Cars: Each covered agency shall produce all records relating to the people who rented or traveled in the following cars during August 1, 2025, through September 10, 2025: Silver 2025 Toyota RAV4 (Utah plate T092ZS), White 2025 Toyota Camry (Arizona plate CWN9872), 2023 Toyota RAV4 (Utah plate T912KM), 2025 Toyota 4Runner (Utah plate Z923DA), Grey/Silver 2025 Toyota 4Runner (plate Z349AA), including links to Duncan Aviation, "PERSON_132_REDACTED Consulting," or "Eng. PERSON_133_REDACTED." Each covered agency shall also produce all records relating to any rental vehicle used by any person of interest in the investigation.

• #44: MARC Inc. Surveillance Plane Contract: Each covered agency shall produce all records relating to who rented or contracted MARC Inc.'s Piper N59906 for the flight on September 10, 2025—who paid, who interacted with the company, how information was delivered to the customer (real-time or otherwise), and the identity of the customer organization and individuals. Each covered agency shall also produce all records relating to any aerial surveillance contracted by any party for any date near September 10, 2025, in the Utah area.

• #45: Airport Foreign Military Personnel: Each covered agency shall produce all records relating to persons at Provo Municipal Airport (PVU) or Salt Lake City International Airport (SLC) during August 1, 2025, through September 11, 2025, who: had "U.S. Department of Defense Liaison" badges, had Egyptian passports boarding private planes, tested Counter-UAS gear (especially September 4–10), used "no-scan priority clearance" via federal override, or prompted tower insiders to remark on suspicious activity. Each covered agency shall also produce all records relating to any unusual military, diplomatic, or intelligence activity at either airport during that period.

• #46: Non-.30-06 Caliber Gunfire at UVU: Each covered agency shall produce all records relating to whether any caliber of gunfire besides .30-06 was fired on September 10, 2025, between 12:20 and 12:30 PM MT at UVU, including witness testimony describing the shot sound as resembling a 9mm or a "cherry bomb" rather than a deep rifle report (specifically witness Eric's testimony), which may indicate a different weapon type or caliber. Each covered agency shall also produce all records relating to any ballistic evidence, projectile analysis, or weapon discharge data suggesting additional or alternative weapons were fired.

• #47: Laser Targeting and Electronic Targeting at UVU: Each covered agency shall produce all records relating to laser targeting that occurred on September 10, 2025, at UVU anywhere within 2,000 feet of Charlie Kirk. Each covered agency shall produce all records relating to any electronic device, system, or technology — whether ground-based, drone-mounted, or otherwise — that performed any function related to tracking, targeting, range-finding, shot timing, shot coordination, gunshot detection, or any other function connected to the shooting or the movements of Charlie Kirk, the shooter, or any person of interest. Each covered agency shall also produce all records relating to any targeting, range-finding, or laser-related equipment detected or deployed at or near UVU on that date, and whether any drone was performing active tracking of Charlie Kirk or any other person at the time of the shooting.

• #48: FBI Requests to Delete Witness Videos: Each covered agency shall produce all records relating to FBI employees calling witnesses who had videos and asking them to delete the video, including the list of FBI employees who did this, the witnesses, the dates, and how many calls. Each covered agency shall produce all records establishing whether the FBI ever asked any witnesses or anyone to delete video from September 10, 2025, in Utah, from any device. Each covered agency shall also produce all records relating to any law enforcement requests to any person to delete, destroy, or surrender photographic or video evidence from the UVU event.

• #49: Remotely Deleted Witness Videos: Each covered agency shall produce all records relating to witnesses who reported that videos they took at UVU on September 10, 2025, were deleted from their phones or devices without their permission, including how the deletions occurred, who performed them, what tools were used, and all details of each occurrence. Each covered agency shall produce all records relating to any videos that were deleted from mobile phones of witnesses or people at UVU on September 10, 2025, that were deleted at any later date, whether by the owner, remotely, or by any other means. Each covered agency shall also produce all records relating to any unauthorized access to, deletion of, or tampering with any person's digital media from the UVU event.

• #50: Listed Planes Transponder-Off Flights: Each covered agency shall produce all records relating to whether any of the listed planes flew into Egypt from another country with the transponder off, and which country they flew from. Each covered agency shall produce all records providing clarification from investigators on whether any suspicious plane's transponder was deliberately turned off versus showing gaps due to incomplete ADS-B data coverage in rural areas. Each covered agency shall also produce all records relating to any transponder deactivation, route concealment, or flight path obfuscation by any aircraft connected to the investigation.

• #51: Hampton Meeting Intel Presence: Each covered agency shall produce all records relating to any military or U.S. or foreign intelligence personnel present at the August 3–6, 2025, meeting at the Hamptons, including names and who they worked for. Each covered agency shall also produce all records relating to any intelligence service involvement with, monitoring of, or interest in any TPUSA donor or leadership meeting during 2025.

• #52: Business Deal Threat to Kirk: Each covered agency shall produce all records relating to any business opportunity discussed with Charlie Kirk from September 1–10, 2025, including allegations that PERSON_3_REDACTED lost $2M when Charlie turned down a deal, the identity of the deal and who offered it, factors Kirk found problematic, and whether Kirk said "they will kill me tomorrow" in connection with the call. Each covered agency shall also produce all records relating to any financial pressure, inducement, or threat connected to business dealings with Kirk in 2025.

• #53: TPUSA Financial Audit by Kirk: Each covered agency shall produce all records relating to Charlie Kirk's request for a DOGE-equivalent audit inside TPUSA, as found in FBI investigation files, and what financial irregularities were found. Each covered agency shall also produce all records relating to any financial misconduct, mismanagement, or irregular transactions at TPUSA discovered during any investigation.

• #54: TPUSA Leadership Foreign Intel Contact: Each covered agency shall produce all records relating to any communication or meetings between TPUSA managers, executives, or board members with U.S. or foreign intelligence within 12 months before September 11, 2025. Each covered agency shall also produce all records relating to any intelligence service contact with or interest in any TPUSA leadership figure at any time.

• #55: All-Black Suspect at UVU Construction: Each covered agency shall produce all records matching or similar to: one or more eyewitnesses describing a man dressed in all black (trench coat, cargo pants, black mask, sunglasses, long greasy black hair, small backpack) who walked through a UVU construction site immediately after the shooting, spoke with an excavator operator, admitted someone had been shot before sirens started, was tracked by K-9 units, and whose photo shown by sheriffs did not match the FBI's publicly released image. Each covered agency shall also produce all records relating to any unidentified suspect or person of interest at or near UVU on September 10, 2025, who does not match Tyler Robinson's description.

• #56: Threats Against Charlie Kirk from Any Source: Each covered agency shall produce all records from U.S. intelligence about any individuals, governments, or government organizations that wanted Charlie Kirk's life ended, discussed getting him killed, or threatened him. Each covered agency shall also produce all records relating to any threat assessment, warning, or intelligence report regarding danger to Charlie Kirk from any source.

• #57: Threats Against Similar Public Figures: Each covered agency shall produce all records from U.S. intelligence, FBI, or DoJ about threats or communication about harm, plans, or consideration toward: Marjorie Taylor Greene (including threats to murder her son), Matt Gaetz, Andrew Breitbart, Candace Owens, Tucker Carlson, and Thomas Massie. Each covered agency shall also produce all records relating to any threat pattern or coordinated targeting of public figures with similar political profiles.

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FBI 302 Reports (#58–#62)

• #58: All FBI 302 Interview Reports: Each covered agency shall produce all FBI Form 302 interview reports from September 10, 2025, to the present from the FBI Salt Lake City Field Office, covering all witness interviews, including the FBI's admission of possible multiple accomplices, investigations into Discord chats, text messages, and bullet trajectories, and the questioning of over 20 people. Each covered agency shall also produce all supplemental reports, attachments, and any 302s from other field offices related to the investigation.

• #59: FBI 302s on Evidence Deletion Requests: Each covered agency shall produce all FBI 302s documenting instances where agents asked witnesses to delete photos or videos, identifying the agents involved. Each covered agency shall also produce all records relating to any FBI communication with witnesses regarding evidence preservation or destruction.

• #60: Counterintelligence Division 302s: Each covered agency shall produce all FBI 302s from the Counterintelligence Division regarding foreign intelligence investigation related to the case. Each covered agency shall also produce all records relating to any counterintelligence assessment or report touching on the Charlie Kirk investigation.

• #61: FBI Agent Notes and Memoranda: Each covered agency shall produce all investigative notes, rough notes, and memoranda from FBI Salt Lake City Field Office agents. Each covered agency shall also produce all records relating to any handwritten notes, personal files, or informal records kept by any agent working the case.

• #62: FBI Case Opening Documentation: Each covered agency shall produce all case opening forms, investigative plans, and scope documents from the FBI Records Division. Each covered agency shall also produce all records relating to any modification, expansion, or restriction of the investigation's scope after opening.

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FBI Counterintelligence (#63–#67)

• #63: FBI Foreign Intel Reports on Utah: Each covered agency shall produce all FBI counterintelligence reports on Egyptian GID, French DGSE, Israeli Mossad, and other foreign intelligence operations in Utah from January 2023 to present. Each covered agency shall also produce all records relating to any foreign intelligence service activity in the state of Utah during that period.

• #64: FBI Threat Assessments for Kirk: Each covered agency shall produce all FBI Protective Intelligence threat assessments regarding foreign intelligence targeting of Charlie Kirk. Each covered agency shall also produce all records relating to any FBI awareness of foreign threats to Kirk before the assassination.

• #65: FBI Liaison Reports with CIA/NSA/DHS: Each covered agency shall produce all cable traffic and intelligence sharing from the FBI Salt Lake City Field Office with CIA, NSA, and DHS regarding foreign nationals connected to the case. Each covered agency shall also produce all records relating to any inter-agency communication about the investigation.

• #66: FBI Counterintel Surveillance Logs: Each covered agency shall produce all FBI Counterintelligence Division surveillance logs tracking suspected foreign intelligence officers in Utah. Each covered agency shall also produce all records relating to any FBI monitoring of foreign intelligence personnel in the western United States during 2025.

• #67: FISA Applications and Materials: Each covered agency shall produce all FISA surveillance applications and materials from the DOJ National Security Division related to foreign nationals in Utah connected to the case. Each covered agency shall also produce all records relating to any electronic surveillance authorized by any court related to the investigation.

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Cell Phone Data (#68–#74)

• #68: UVU Campus Cell Tower Dumps: Each covered agency shall produce all cell tower dump records for UVU campus on September 10, 2025, from 8 AM to 6 PM, identifying all phones that connected to towers serving UVU. Each covered agency shall also produce all records relating to any device that connected to, attempted to connect to, or was detected by any cell infrastructure serving the UVU area that day.

• #69: Tyler Robinson Residence Tower Dumps: Each covered agency shall produce all cell tower dump records for Tyler Robinson's residence from September 1–15, 2025, identifying all phones connecting to nearby towers. Each covered agency shall also produce all records relating to any device activity near Tyler Robinson's residence during August–September 2025.

• #70: Provo Airport Cell Tower Dumps: Each covered agency shall produce all cell tower dump records for Provo Airport from August 25 through September 15, 2025, identifying all phones at the airport. Each covered agency shall also produce all records relating to any device activity at or near Provo Municipal Airport during that period.

• #71: Geofence Warrant Data for UVU: Each covered agency shall produce all geofence warrant applications and returns for UVU from FBI, Google, and Apple, identifying all devices within 500 meters of the shooting location. Each covered agency shall also produce all records relating to any location-based data request or return related to the UVU campus on September 10, 2025.

• #72: Foreign Roaming Phone Data: Each covered agency shall produce all cell site location information for all phones with international roaming from Egyptian, French, or Israeli carriers in Utah during the relevant period. Each covered agency shall also produce all records relating to any phone with non-U.S. carrier roaming detected at any investigation-related location.

• #73: FBI Foreign Phone Analysis Reports: Each covered agency shall produce all FBI Cellular Analysis Survey Team reports and link analysis connecting foreign phones to people and locations. Each covered agency shall also produce all records relating to any FBI analytical work product identifying foreign devices in connection with the case.

• #74: Foreign Phone Subscriber Information: Each covered agency shall produce all subscriber information for all unidentified foreign phones, including names, passport numbers, and billing addresses. Each covered agency shall also produce all records relating to any effort to identify owners of foreign-registered devices detected at investigation-related locations.

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Airport / CBP Records (#75–#81)

• #75: CBP Israeli National Entry/Exit Records: Each covered agency shall produce all CBP entry/exit records, I-94 records, passport scans, and biometric data for Israeli nationals from July through November 2025. Each covered agency shall also produce all records relating to any Israeli national entering or exiting the United States through any port during that period who traveled to or through Utah.

• #76: CBP Egyptian National Entry/Exit Records: Each covered agency shall produce all CBP entry/exit records, I-94 records, passport scans, and biometric data for Egyptian nationals from July through November 2025. Each covered agency shall also produce all records relating to any Egyptian national entering or exiting the United States through any port during that period who traveled to or through Utah.

• #77: CBP French National Entry/Exit Records: Each covered agency shall produce all CBP entry/exit records, I-94 records, passport scans, and biometric data for French nationals from July through November 2025. Each covered agency shall also produce all records relating to any French national entering or exiting the United States through any port during that period who traveled to or through Utah.

• #78: TSA PreCheck Foreign National Records: Each covered agency shall produce all TSA PreCheck and Known Traveler records for foreign nationals with expedited clearance connected to the investigation. Each covered agency shall also produce all records relating to any foreign national who received expedited security screening at any U.S. airport during the relevant period.

• #79: CBP Military Contractor Clearances: Each covered agency shall produce all CBP special clearance records for military contractors, including diplomatic and military personnel bypassing standard security. Each covered agency shall also produce all records relating to any federal override, diplomatic waiver, or special access authorization for foreign personnel at U.S. airports during the relevant period.

• #80: International Flight Passenger Manifests: Each covered agency shall produce complete passenger manifests for all international flights to Salt Lake City or Provo from September 3–17, 2025. Each covered agency shall also produce all records relating to any passenger on any flight arriving in Utah from a foreign origin during August–October 2025 who is connected to the investigation.

• #81: CBP Biometric Data for Foreign Arrivals: Each covered agency shall produce all biometric captures (fingerprints, facial recognition) from the DHS Biometric Identity Management System for foreign arrivals during the relevant period. Each covered agency shall also produce all records relating to any biometric data collected from any foreign national entering Utah during 2025.

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Egyptian Planes (#82–#87)

• #82: Egyptian Plane SU-BTT Flight Records: Each covered agency shall produce all flight records for Egyptian plane SU-BTT, including flight plans and arrival records for the September 4, 2025, Provo arrival. Each covered agency shall also produce all records relating to any flight by this aircraft to or within the United States during 2025 and 2026. Each covered agency shall specifically produce all records relating to the return of Egyptian-registered aircraft to Provo, Utah in March 2026, including passenger manifests, cargo, purpose of travel, and any connection to the timing of French President Macron's wife Brigitte Macron's concurrent visit to Washington D.C., and all records establishing whether a pattern exists between Egyptian aircraft movements and French diplomatic travel.

• #83: Egyptian Plane SU-BND Flight Records: Each covered agency shall produce all flight records for Egyptian plane SU-BND, including transponder activation records around September 15, 2025. Each covered agency shall also produce all records relating to any flight by this aircraft to or within the United States during 2025.

• #84: SU-BTT Passenger and Crew Manifests: Each covered agency shall produce all passenger manifests and crew lists for SU-BTT, including names of all 4–6 military contractors who deplaned. Each covered agency shall also produce all records relating to any person who was aboard this aircraft for any flight to or within the United States during 2025.

• #85: CBP Inspection of Egyptian Aircraft: Each covered agency shall produce all CBP inspection reports and cargo manifests for Egyptian aircraft. Each covered agency shall also produce all records relating to any customs inspection, security screening, or cargo declaration for any Egyptian-registered aircraft arriving at any U.S. airport during 2025.

• #86: Egyptian Contractor Security Clearances: Each covered agency shall produce all State Department and DoD records of Defense Attaché badges issued to Egyptian military contractors. Each covered agency shall also produce all records relating to any U.S. government authorization, credential, or clearance provided to Egyptian nationals during 2025.

• #87: Egyptian Contractor Ground Transportation: Each covered agency shall produce all rental car and hotel records showing where Egyptian contractors went after arriving. Each covered agency shall also produce all records relating to any ground transportation, lodging, or movement by Egyptian nationals who arrived on the listed aircraft.

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Israeli Cell Phones (#88–#92)

• #88: Israeli Phone Location History: Each covered agency shall produce complete cell site location information for all 12 Israeli phones (Cellcom, Partner, Pelephone carriers) from September 1–15, 2025, showing presence at UVU, Tyler Robinson's home, airports, and other locations. Each covered agency shall also produce all records relating to any Israeli-carrier phone detected at any investigation-related location during August–October 2025.

• #89: Israeli Phone Subscriber Identification: Each covered agency shall produce all subscriber information for the 12 Israeli phones obtained via FBI MLAT with Israeli carriers, including names, passport numbers, and addresses. Each covered agency shall also produce all records relating to the identity of any person using an Israeli-registered phone in Utah during the relevant period.

• #90: Israeli Phone Call Detail Records: Each covered agency shall produce all call detail records for the Israeli phones, showing all calls and texts to and from Utah numbers. Each covered agency shall also produce all records relating to any communication between Israeli-registered phones and any U.S. number or device during the relevant period.

• #91: Israeli Phone International Roaming Records: Each covered agency shall produce all international roaming activation and usage patterns from Israeli and U.S. carriers for the identified phones. Each covered agency shall also produce all records confirming the physical presence of Israeli-registered devices in Utah.

• #92: FBI Communications with Israel on Case: Each covered agency shall produce all communications between FBI Legal Attaché Tel Aviv and Israeli authorities regarding the Israeli phones and the investigation. Each covered agency shall also produce all records relating to any FBI request to or response from Israeli government entities about the case.

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Provo Airport (#93–#98)

• #93: Airport Badge Access Logs: Each covered agency shall produce all badge access logs from Provo Municipal Airport, including the September 11, 2025, badge system update, and all badge access records and modifications. Each covered agency shall also produce all records relating to any changes to airport access systems or records during September 2025.

• #94: Airport Surveillance Camera Footage: Each covered agency shall produce all surveillance camera footage from all Provo Municipal Airport locations from September 3–17, 2025, showing Egyptian plane arrival and contractors deplaning. Each covered agency shall also produce all airport video from any camera at PVU during August–October 2025 showing any person or aircraft connected to the investigation.

• #95: Counter-UAS Testing Records: Each covered agency shall produce all drone countermeasure testing documentation from the FAA and airport authority for September 4–10, 2025. Each covered agency shall also produce all records relating to any Counter-UAS activity, drone detection, or unmanned aircraft operations at Provo Airport during 2025.

• #96: Airport Flight Arrival/Departure Records: Each covered agency shall produce all FAA and Provo Airport records of private and commercial flight arrivals and departures during the relevant period. Each covered agency shall also produce all records relating to any flight movement at PVU during August–October 2025.

• #97: Aircraft Fueling Records: Each covered agency shall produce all fuel purchase records from FBO operators at Provo Airport for foreign and private aircraft. Each covered agency shall also produce all records relating to any aircraft servicing, maintenance, or fueling at PVU during the relevant period.

• #98: Foreign Personnel Security Waivers: Each covered agency shall produce all records from the airport authority and TSA of personnel bypassing security, including waivers for foreign military personnel. Each covered agency shall also produce all records relating to any non-standard security screening or access granted to any person at PVU during 2025.

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Financial Records (#99–#105)

• #99: International Wire Transfers to Utah: Each covered agency shall produce all international wire transfers to Utah from August–September 2025 from Egyptian, French, or Israeli sources, as reported by FinCEN and major banks. Each covered agency shall also produce all records relating to any foreign-origin financial transfer to any Utah account or entity during that period.

• #100: Utah Suspicious Activity Reports: Each covered agency shall produce all Suspicious Activity Reports (SARs) filed by Utah banks during the relevant period, as maintained by FinCEN. Each covered agency shall also produce all records relating to any unusual financial activity in Utah flagged by any financial institution during 2025.

• #101: Large Cash Transaction Reports: Each covered agency shall produce all Currency Transaction Reports over $10,000 involving foreign nationals filed with FinCEN. Each covered agency shall also produce all records relating to any large cash transaction in Utah involving any person connected to the investigation.

• #102: Rental Car Foreign Payment Records: Each covered agency shall produce all payment records from Enterprise, Hertz, Avis, Budget, and other rental companies for payments from foreign credit cards or accounts. Each covered agency shall also produce all records relating to any rental car transaction in Utah paid by foreign funds during August–September 2025.

• #103: Hotel Foreign Payment Records: Each covered agency shall produce all payment records from hotels within 20 miles of UVU for foreign national lodging payments. Each covered agency shall also produce all records relating to any hotel transaction in the Provo/Orem area paid by foreign funds during August–October 2025.

• #104: Digital Payments to Distraction People: Each covered agency shall produce all PayPal, Venmo, Zelle, and other digital payment platform records of transfers to individuals present at UVU on September 10, 2025. Each covered agency shall also produce all records relating to any electronic payment to any person of interest from any source during 2025.

• #105: FBI Financial Crimes Investigation Files: Each covered agency shall produce all financial analysis work products from FBI Salt Lake City related to the case. Each covered agency shall also produce all records relating to any FBI financial investigation, FinCEN query, or bank subpoena related to the Charlie Kirk investigation.

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Chain of Custody (#106–#113)

• #106: Mauser Rifle Chain of Custody: Each covered agency shall produce the complete chain of custody for the Mauser Model 98 rifle with all custody documentation and timestamps from the FBI Evidence Response Team. Each covered agency shall produce all records relating to how the rifle entered the UVU campus — the complete path of the weapon from its last known prior location to the campus, including how it was transported, by whom, through which entry points, and at what times. Each covered agency shall produce all records relating to how the rifle left the campus after the shooting or after its discovery, including which agency took possession, how it was transported, and to which facility. Each covered agency shall also produce all records relating to any person who handled, transported, or had access to the rifle from the time of its alleged discovery through the present.

• #107: Body Camera Footage of All Searches: Each covered agency shall produce all body camera footage from the Utah County Sheriff and FBI of the initial search, K-9 search, and re-search of the area where the rifle was found. Each covered agency shall also produce all records relating to any video or audio recording of any search conducted at UVU on September 10–11, 2025.

• #108: K-9 Unit Deployment Records: Each covered agency shall produce all K-9 unit deployment records and reports from the Utah County Sheriff showing search results. Each covered agency shall also produce all records relating to any dog search conducted at UVU, including handler reports, search patterns, and findings.

• #109: FBI Agents Who Directed Re-Search: The names and reports of the FBI agents who directed the re-search that located the weapon. Each covered agency shall also produce all records relating to any FBI personnel who participated in, directed, or were present during any search at UVU.

• #110: FBI–Local Law Enforcement Communications: Each covered agency shall produce all communications between FBI and Utah County Sheriff regarding the rifle search. Each covered agency shall also produce all records relating to any coordination between federal and local law enforcement regarding evidence collection at UVU.

• #111: Rifle DNA Analysis: Each covered agency shall produce the full DNA profile from all rifle surfaces as analyzed by the FBI Laboratory. Each covered agency shall also produce all records relating to any biological evidence collected from the rifle, towel, cartridges, or scope, and any DNA profiles identified.

• #112: Rifle Fingerprint Analysis: Each covered agency shall produce all latent fingerprint analysis from the rifle, trigger, scope, towel, and cartridges by the FBI Laboratory. Each covered agency shall also produce all records relating to any fingerprint evidence collected from any item of physical evidence in the case.

• #113: FBI Gun Planting Investigation: Each covered agency shall produce all FBI Office of Professional Responsibility investigation files regarding gun planting allegations. Each covered agency shall also produce all records relating to any internal review, complaint, or investigation regarding the handling of physical evidence in this case.

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Threat Assessments (#114–#118)

• #114: Tucker Carlson Post-Assassination Threats: Each covered agency shall produce all FBI Protective Intelligence threat assessments for Tucker Carlson made after Charlie Kirk's death. Each covered agency shall also produce all records relating to any threat to Tucker Carlson that references or is connected to the Charlie Kirk assassination.

• #115: PERSON_184_REDACTED Post-Assassination Threats: Each covered agency shall produce all FBI Protective Intelligence threat assessments for PERSON_184_REDACTED made after the assassination. Each covered agency shall also produce all records relating to any threat to PERSON_184_REDACTED that references or is connected to the Charlie Kirk assassination.

• #116: Candace Owens Post-Assassination Threats: Each covered agency shall produce all FBI Protective Intelligence threat assessments for Candace Owens made after the assassination. Each covered agency shall also produce all records relating to any threat to Candace Owens that references or is connected to the Charlie Kirk assassination.

• #117: Pattern Analysis Against Commentators: Each covered agency shall produce all FBI Counterterrorism and Counterintelligence analysis of threat patterns against anti-Israel commentators or similar public figures. Each covered agency shall also produce all records relating to any coordinated threat campaign targeting public figures with similar political profiles.

• #118: FBI 302s from Carlson/Owens Interviews: Each covered agency shall produce all FBI 302s from interviews with Tucker Carlson, PERSON_184_REDACTED, and Candace Owens about threats they received. Each covered agency shall also produce all records relating to any FBI interview with any public figure about threats connected to the Charlie Kirk case.

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Surveillance Footage (#119–#124)

• #119: UVU Campus Security Camera Footage: Each covered agency shall produce all UVU campus security camera footage from September 9–11, 2025, from all campus cameras. Each covered agency shall also produce all records relating to any video recording from any camera at UVU during that period, including cameras that were disabled or repositioned.

• #120: Traffic Camera Footage Airport-to-UVU Routes: Each covered agency shall produce all traffic camera footage from UDOT and local municipalities along travel routes between airports and UVU. Each covered agency shall also produce all records relating to any traffic camera footage in Utah County during September 2025 showing vehicles connected to the investigation.

• #121: Airport Surveillance Footage: Each covered agency shall produce all terminal, parking, and rental car area surveillance footage from Provo and Salt Lake City airports. Each covered agency shall also produce all records relating to any airport surveillance video showing persons or vehicles connected to the investigation.

• #122: Hotel Surveillance Footage Near UVU: Each covered agency shall produce all lobby, parking, and elevator camera footage from hotels within 20 miles of UVU. Each covered agency shall also produce all records relating to any hotel surveillance video showing persons connected to the investigation during August–October 2025.

• #123: ATM Camera Footage in Utah County: Each covered agency shall produce all ATM camera footage from banks in Utah County from August 25 through September 15, 2025. Each covered agency shall also produce all records relating to any ATM or bank camera footage showing persons connected to the investigation.

• #124: License Plate Reader Data: Each covered agency shall produce all license plate reader hits from law enforcement agencies for rental vehicles connected to the investigation. Each covered agency shall also produce all records relating to any LPR data in Utah showing vehicles connected to the investigation during August–October 2025.

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Rental Car Records (#125–#130)

• #125: Foreign License Rental Agreements: Each covered agency shall produce all rental agreements from all Utah rental companies for renters using foreign driver's licenses from August–September 2025. Each covered agency shall also produce all records relating to any rental vehicle agreement involving a foreign national in Utah during that period.

• #126: Rental Vehicle GPS/Telematics Data: Each covered agency shall produce all GPS and telematics vehicle location tracking data from Enterprise, Hertz, Avis, Budget, and other companies for vehicles connected to the investigation. Each covered agency shall also produce all records relating to any rental vehicle tracking data showing travel to UVU, Tyler Robinson's home, airports, or other investigation-related locations.

• #127: Rental Vehicle Mileage and Fuel Records: Each covered agency shall produce all mileage records and fuel receipts for rental vehicles connected to the investigation. Each covered agency shall also produce all records relating to any usage documentation for rental vehicles used by persons of interest.

• #128: Rental Facility Surveillance Footage: Each covered agency shall produce all counter and lot camera footage from rental car facilities. Each covered agency shall also produce all records relating to any surveillance video from any rental car location in Utah showing persons connected to the investigation.

• #129: Dark Tinted Window Rental Records: Each covered agency shall produce all records of rentals with abnormally dark tinted windows or special vehicle modification requests. Each covered agency shall also produce all records relating to any unusual vehicle requests or modifications by renters connected to the investigation.

• #130: Unusual Vehicle Return Reports: Each covered agency shall produce all damage reports and unusual vehicle return inspection reports from rental companies. Each covered agency shall also produce all records relating to any rental vehicle returned with evidence of operational or surveillance use.

• #131: All Other Rental Vehicles Connected to the Investigation: Each covered agency shall produce all rental car agreements, GPS/telematics data, mileage records, fuel receipts, surveillance footage, and return reports for any rental vehicle used by FBI agents, FBI informants, DOJ personnel, any person identifying themselves as or claiming to be FBI or federal law enforcement, any federal or state law enforcement officer, any intelligence community personnel, or any other person possibly connected to the investigation—whether or not that person has been formally identified as a subject, witness, or person of interest. Each covered agency shall also produce records for any rental vehicle present in or traveling through the Provo, Orem, Salt Lake City, or broader Utah County area between August 1 and October 31, 2025, that was rented by, assigned to, or used by any of the above persons. Each covered agency shall also produce all rental car company internal records, employee notes, and communications referencing any renter who presented a government credential, badge, or claimed law enforcement affiliation.

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Hotel Records (#132–#136)

• #132: Foreign National Hotel Registration: Each covered agency shall produce all guest registration cards and passport copies for foreign nationals at hotels within 20 miles of UVU. Each covered agency shall also produce all records relating to any foreign national lodging in the Provo/Orem/Salt Lake area during August–October 2025.

• #133: Hotel Key Card Access Logs: Each covered agency shall produce all room entry and exit key card logs from hotels where foreign nationals stayed. Each covered agency shall also produce all records relating to any hotel access records showing movement patterns of persons connected to the investigation.

• #134: Hotel Wi-Fi Connection Logs: Each covered agency shall produce all Wi-Fi connection logs showing device MAC addresses from hotels where persons of interest stayed. Each covered agency shall also produce all records relating to any device network activity at hotels in the area during the relevant period.

• #135: Hotel Room Service and Minibar Records: Each covered agency shall produce all in-room charges from hotels where persons of interest stayed to establish duration and nature of stays. Each covered agency shall also produce all records relating to any hotel billing records for persons connected to the investigation.

• #136: Hotel Business Center Usage Logs: Each covered agency shall produce all computer and printer usage logs from hotel business centers. Each covered agency shall also produce all records relating to any hotel facility usage by persons connected to the investigation that could indicate operational planning or communications.

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Digital Forensics (#137–#142)

• #137: Foreign Domain Email Communications: Each covered agency shall produce all email traffic to and from foreign domains obtained from ISPs and email providers. Each covered agency shall also produce all records relating to any electronic communication between persons of interest and foreign entities.

• #138: VPN Foreign Connection Logs: Each covered agency shall produce all VPN connection records to foreign countries obtained from ISPs. Each covered agency shall also produce all records relating to any attempt by persons of interest to conceal communications through encrypted tunnels or anonymization services.

• #139: Encrypted Messaging App Records: Each covered agency shall produce all Signal, Telegram, and WhatsApp account data and metadata from app providers for persons of interest. Each covered agency shall also produce all records relating to any encrypted or secure communication by persons connected to the investigation.

• #140: Social Media Direct Messages: Each covered agency shall produce all Facebook, Instagram, and Twitter/X direct message records for persons of interest. Each covered agency shall also produce all records relating to any social media communication related to coordination, recruitment, or planning connected to the investigation.

• #141: Deleted File Recovery Analysis: Each covered agency shall produce all recovered deleted communications and files from the FBI Digital Evidence Laboratory. Each covered agency shall also produce all records relating to any deleted, encrypted, or hidden digital evidence recovered from any device connected to the investigation.

• #142: UVU Network Traffic During Incident: Each covered agency shall produce all network logs from the UVU IT Department for September 10, 2025, showing devices communicating during the assassination. Each covered agency shall also produce all records relating to any network activity, device connections, or data transmissions at UVU during the incident.

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Ballistics (#143–#149)

• #143: ATF Trace for Mauser Model 98: Each covered agency shall produce the complete ATF National Tracing Center trace showing full ownership and transfer history of the Mauser Model 98. Each covered agency shall also produce all records relating to any prior owner, transfer, or possession of the rifle.

• #144: Rifle Manufacturing and Serial Records: Each covered agency shall produce all manufacturing records, serial number documentation, and production records from ATF and the manufacturer. Each covered agency shall also produce all records relating to the origin, production date, and distribution history of the rifle.

• #145: Rifle Import Records: Each covered agency shall produce all ATF and CBP import documentation if the weapon came from abroad. Each covered agency shall also produce all records relating to any foreign origin, international transfer, or importation of the rifle or its components.

• #146: Rifle Metallurgical Analysis: Each covered agency shall produce all FBI Laboratory metal composition analysis of rifle components. Each covered agency shall also produce all records relating to any material analysis suggesting foreign manufacture, modification, or non-standard components.

• #147: Cartridge Engraving Analysis: Each covered agency shall produce all FBI Laboratory linguistic and cultural analysis of cartridge engravings including "Bella Ciao" and other inscriptions. Each covered agency shall also produce all records relating to the cultural, operational, or intelligence significance of any markings on ammunition.

• #148: Engraving Tool Mark Analysis: Each covered agency shall produce all FBI Laboratory tool identification and tool mark analysis of engraving equipment used on cartridges. Each covered agency shall also produce all records relating to what equipment was used, where it was obtained, and who had access to it.

• #149: Foreign Intel Weapon Signature Comparison: Each covered agency shall produce all FBI and CIA pattern analysis comparing the weapon and methods with known foreign intelligence tradecraft signatures. Each covered agency shall also produce all records relating to any similarity between evidence in this case and methods used by any foreign intelligence service.

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Distraction People (#150–#156)

• #150: All Individuals at UVU During Shooting: Each covered agency shall produce the complete FBI and UVU Police list of all individuals identified at UVU during the shooting. Each covered agency shall also produce all records relating to any person present at or near UVU on September 10, 2025, between 10 AM and 2 PM.

• #151: Background Checks on Unidentified Individuals: Each covered agency shall produce all FBI criminal and intelligence background checks on unidentified individuals at UVU. Each covered agency shall also produce all records relating to any person at UVU whose identity was not immediately established or who had connections to intelligence services.

• #152: Foreign National Immigration Status: Each covered agency shall produce all CBP and USCIS visa and immigration status records for foreign nationals present at UVU. Each covered agency shall also produce all records relating to the immigration status, visa type, and entry circumstances of any non-U.S. citizen at UVU on September 10, 2025.

• #153: Financial Records for UVU Attendees: Each covered agency shall produce all FinCEN and bank records of payments received by individuals at UVU before the incident, including whether any distraction persons or persons of interest received money, were offered money, or received any financial payments from any source — and full investigation of any financial payments they did receive. Each covered agency shall also produce all records relating to any financial transaction suggesting payment or compensation to any person present at UVU.

• #154: Phone Records for Unidentified Attendees: Each covered agency shall produce all FBI call detail records and cell site location information for unidentified attendees at UVU. Each covered agency shall also produce all records relating to any phone activity by persons of interest at UVU on September 10, 2025.

• #155: UVU Attendee Travel Records: Each covered agency shall produce all airline and CBP records of recent international travel by UVU attendees. Each covered agency shall also produce all records relating to any foreign travel by persons present at UVU that could indicate recruitment or coordination.

• #156: Social Media Analysis of UVU Attendees: Each covered agency shall produce all FBI analysis of social media accounts and connections of UVU attendees. Each covered agency shall also produce all records relating to any social media activity by persons at UVU suggesting foreign intelligence contact or operational coordination.

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Drones (#157–#161)

• #157: Military Drones at Provo Airport: Each covered agency shall produce all FAA and DoD drone registration and flight records for military drones at Provo Airport from September 4–10, 2025. Each covered agency shall also produce all records relating to any military unmanned aircraft operations at or near PVU during August–October 2025.

• #158: Counter-UAS Testing Documentation: Each covered agency shall produce all FAA and airport authority testing records and authorizations for Counter-UAS operations. Each covered agency shall also produce all records relating to any drone countermeasure testing, deployment, or capability demonstration at Provo Airport during 2025.

• #159: Drone Flight Logs During UVU Event: Each covered agency shall produce all FAA drone flight logs for September 10, 2025, from 8 AM to 2 PM in the UVU area. Each covered agency shall also produce all records relating to any unmanned aircraft in the air within 20 miles of UVU during the event.

• #160: Surveillance Plane N1098L Records: Each covered agency shall produce all FAA flight plans, crew information, and rental records for plane N1098L (HADES spy plane), which circled 35 minutes before the shooting. Each covered agency shall also produce all records relating to any surveillance aircraft operating in the Provo/Orem area during September 2025.

• #161: Surveillance Aircraft Customer Identity: Each covered agency shall produce all charter company and FAA records identifying who requested, rented, and paid for surveillance aircraft over UVU. Each covered agency shall also produce all records relating to any person or entity that contracted aerial surveillance in the Utah County area during September 2025.

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TPUSA Intel (#162–#167)

• #162: FBI Reports on Foreign Intel in TPUSA: Each covered agency shall produce all FBI Counterintelligence reports on foreign intelligence recruitment within TPUSA from September 2023 through September 2025. Each covered agency shall also produce all records relating to any foreign intelligence service targeting, approaching, or recruiting TPUSA members or affiliates.

• #163: FBI TPUSA Member Foreign Contact Interviews: Each covered agency shall produce all FBI Form 302s from interviews with TPUSA members regarding foreign contact. Each covered agency shall also produce all records relating to any FBI interview with any TPUSA-affiliated person about foreign intelligence approaches or relationships.

• #164: TPUSA Member Foreign Travel Reports: Each covered agency shall produce all FBI reports on TPUSA member travel to Egypt, France, Israel, or other countries of interest. Each covered agency shall also produce all records relating to any foreign travel by TPUSA leadership or staff that involved contact with foreign government officials or intelligence personnel.

• #165: Foreign Payments to TPUSA: Each covered agency shall produce all FBI and FinCEN records of wire transfers and payments from foreign sources to TPUSA. Each covered agency shall also produce all records relating to any foreign funding, donation, or financial support to TPUSA from any foreign entity or individual.

• #166: Kirk Security Chief Foreign Intel Links: Each covered agency shall produce all FBI investigation records of Charlie Kirk's head of security regarding foreign intelligence connections. Each covered agency shall also produce all records relating to any person in Kirk's security detail who had contact with or ties to any foreign intelligence service.

• #167: Hampton Meeting Foreign Intel Activity: Each covered agency shall produce all FBI reports on communications, threats, or money from Egyptian, French, or Israeli sources — including any involvement by Benjamin Netanyahu or Emmanuel Macron or their intermediaries — at the Hampton meeting of August 4–6, 2025. Each covered agency shall also produce all records relating to any foreign intelligence activity, influence, or presence at any TPUSA donor or leadership meeting during 2025.

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Autopsy / Medical (#168–#172)

• #168: Complete Charlie Kirk Autopsy Report: Each covered agency shall produce the full autopsy documentation from the Utah Office of Medical Examiner, including wound measurements, trajectories, and photographs. Each covered agency shall produce all records explaining whether an autopsy on Charlie Kirk was declined or limited in scope, by whom, on what authority, and all communications related to that decision. Each covered agency shall also produce all records relating to any supplemental autopsy findings, second opinions, or additional medical examiner analysis.

• #169: Lapel Microphone Evidence from Body: Each covered agency shall produce all evidence from the medical examiner and FBI regarding the lapel microphone found on or near the body. Each covered agency shall also produce all records relating to any fragments, residue, or material from the microphone recovered from the body, clothing, or immediate area.

• #170: Unusual Autopsy Findings: Each covered agency shall produce all medical examiner toxicology reports, anomaly reports, and any unusual findings from the Utah Office of Medical Examiner. Each covered agency shall produce all records establishing whether Charlie Kirk's heart stopped before his neck wound occurred. Each covered agency shall produce all records establishing whether Charlie Kirk had brain damage or other damage that could be noticed or detected before the bullet or neck and tree wound occurred. Each covered agency shall produce all records establishing whether there was any cause of death or cause of injury that was different from a bullet — or different from a .386-caliber bullet — that hurt Charlie Kirk or caused his death, including any evidence of explosion, blast effect, or non-ballistic trauma. Each covered agency shall also produce all records relating to any unexpected cause-of-death factors, foreign substances, or unexplained medical findings.

• #171: Wound Trajectory Analysis: Each covered agency shall produce the complete wound trajectory documentation from the medical examiner, showing direction of the shot, and whether more than one bullet entered Charlie Kirk's body. Each covered agency shall also produce all records relating to any ballistic wound analysis, trajectory reconstruction, or determination of shooting position.

• #172: Time of Death Determination: Each covered agency shall produce the precise time-of-death analysis from the medical examiner. Each covered agency shall also produce all records relating to any analysis establishing the exact timeline of the fatal event and Kirk's death.

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International Liaison (#173–#177)

• #173: FBI Legat Israel Communications: Each covered agency shall produce all cable traffic from FBI Legal Attaché Tel Aviv to and from Israeli authorities — including any communications involving Prime Minister Benjamin Netanyahu or his office — regarding the case. Each covered agency shall also produce all records relating to any U.S.–Israel intelligence sharing, liaison activity, or diplomatic communication about the Charlie Kirk investigation.

• #174: FBI Legat Egypt and France Communications: Each covered agency shall produce all communications from FBI Legal Attaché Cairo regarding Egyptian planes and personnel connected to the case, and all communications from FBI Legal Attaché Paris regarding French intelligence (DGSE), French legionnaires, or any activity directed by or connected to President Emmanuel Macron or his office. Each covered agency shall also produce all records relating to any U.S.–Egypt or U.S.–France intelligence sharing or diplomatic communication about the investigation.

• #175: Interpol Communications on Case: Each covered agency shall produce all FBI and Interpol international law enforcement sharing regarding the case. Each covered agency shall also produce all records relating to any international law enforcement cooperation, notice, or request related to the investigation.

• #176: MLAT Requests and Responses: Each covered agency shall produce all formal Mutual Legal Assistance Treaty requests and responses from the DOJ Office of International Affairs. Each covered agency shall also produce all records relating to any international legal cooperation request made or received in connection with the investigation.

• #177: Diplomatic Communications on Case: Each covered agency shall produce all State Department diplomatic cables about the assassination, including any communications with or involving Egyptian President El-Sisi, French President Emmanuel Macron, Israeli Prime Minister Benjamin Netanyahu, or their offices. Each covered agency shall also produce all records relating to any diplomatic communication, protest, inquiry, or notification by any foreign government regarding the Charlie Kirk investigation.

Tyler Robinson Defense & Family (#178–#180)

• #178: Tyler Robinson Family Statements: Each covered agency shall produce all statements by Tyler Robinson's family members — made in person, in court, or to investigators — asserting that Tyler Robinson did not commit the assassination or that he stated he "didn't do it but knows who did but won't say because it would endanger the family." All records regarding the rapid family cooperation in turning Tyler in, whether his roommate was placed under protection, all confessions made by Tyler Robinson, and all records regarding early FBI/ATF bulletins on "trans ideology bullets" that were subsequently and subsequently retracted — including who authored those bulletins, who authorized the retraction, and why. Each covered agency shall also produce all records of family members' claims at the January 16th hearing and any other proceedings, and all evidence regarding whether a Mormon preacher and a retired sheriff turned him in rather than his parents.

• #179: Mormon Preacher and Retired Sheriff: Each covered agency shall produce full identification and all records, communications, and interviews related to the Mormon preacher and retired sheriff who reportedly turned Tyler Robinson in. Each covered agency shall also produce all records relating to how they obtained information about Robinson, who directed them to contact law enforcement, and whether any federal agency or intelligence service coordinated or incentivized their actions.

• #180: Tyler Robinson's Claim of Knowledge: Each covered agency shall produce all FBI 302 reports, interview transcripts, jail recordings, and communications in which Tyler Robinson indicated knowledge of who was responsible for the assassination. Each covered agency shall also produce all offers of cooperation, plea discussions, or debriefings in which Robinson provided or attempted to provide information about other participants.

Witness Intimidation (#181–#182)

• #181: Fake Therapy Witness Intimidation: Each covered agency shall produce all records related to "free trauma counseling" sessions offered to UVU witnesses of the assassination, specifically the identity of the therapist who locked a UVU student witness in a room, told him "You're the next target," admitted to carrying a gun, and refused to let him leave until his own supervisor ordered the door opened. Each covered agency shall also produce the identity of the agency or organization that arranged and funded these sessions, whether any federal agency coordinated or directed them, and all communications between the therapy provider and any government agency.

• #182: Witness Suppression After Shooting: Each covered agency shall produce all records of efforts to discourage, intimidate, or silence civilian witnesses at UVU on September 10, 2025 and afterward. Each covered agency shall also produce any directives from FBI or other agencies to local law enforcement to prevent witnesses from speaking publicly, and all records explaining why no verifiable UVU student witnesses have come forward publicly despite hundreds being present.

Security Detail & Foreign Connections (#183)

• #183: Brian Harpole — Foreign Security Background on Kirk Detail: Each covered agency shall produce all records, contracts, and communications related to Brian Harpole, a former police officer/mercenary embedded in Charlie Kirk's security detail on September 10, 2025, who has photographic evidence (from 2017) placing him on a foreign head-of-state security detail. Each covered agency shall also produce his full employment history with any foreign government or foreign security service, who placed him on Kirk's detail, his communications in the 30 days before and after the assassination, and whether any foreign government entity coordinated his assignment.

Medical & Hospital Records (#184–#186)

• #184: Hospital Routing Decision: Each covered agency shall produce all records explaining why Charlie Kirk was transported to Timpanogos Regional Hospital instead of Utah Valley Hospital (a Level II trauma center and the designated facility for life-threatening gunshot wounds in Utah County). Each covered agency shall also produce all protocols, communications, and decisions made by paramedics, dispatchers, or any other personnel regarding hospital selection, and any records showing why Kirk had a pre-existing medical file at Utah Medical Center.

• #185: Surgeon Blocked by FBI: Each covered agency shall produce all records related to the FBI physically preventing a surgeon from re-entering the room where Charlie Kirk was being treated. Each covered agency shall also produce the identity of the FBI agents involved, the authority cited, and all communications between FBI and hospital medical staff regarding access to Kirk.

• #186: Glass or Plastic Fragments in Transport: Each covered agency shall produce all forensic reports and evidence collection records related to glass or plastic fragments found on the ground near or in the car used to transport Charlie Kirk to the hospital. Each covered agency shall also produce origin analysis of these fragments and whether they are consistent with an exploding device.

TPUSA Financial Fraud (#187–#188)

• #187: TPUSA Shell Company Payments: Each covered agency shall produce all financial records, contracts, and communications related to payments by TPUSA to Resource One (DBA for Moore DM Group, a $700M political direct mail conglomerate) — approximately $9M+ paid while TPUSA reported only $1.35M for printing — and Clocktower LLC (dissolved 2022) — $999K for a "research project" with no public deliverables. Each covered agency shall also produce all records of connections to Jake Hoffman, 1Ten LLC, and fake elector schemes, and all records of Erika Kirk's mother's appointment to and service on the TPUSA board.

• #188: TPUSA Board Actions Post-Assassination: Each covered agency shall produce all records of TPUSA board meetings, votes, communications, and negotiations between September 10, 2025 (Kirk's death) and September 18, 2025 (Erika Kirk's announcement as CEO). Each covered agency shall produce all records and video documenting the demeanor and conduct of Charlie Kirk's close associates, including Erika Kirk, immediately after the event. Each covered agency shall also produce all records relating to the 8-day gap before Erika's TPUSA CEO announcement, all negotiations with donors, board members, and foreign interests during that period, and all records related to Erika Kirk's speech referencing "evil Do-ERs" (plural) approximately 55 hours after Charlie Kirk's death.

TPUSA Employee and Contractor Unusual Payments (#189)

• #189: TPUSA Employee and Contractor Payment Audit: Each covered agency shall produce all financial records — including bank records, wire transfers, checks, digital payments, trust distributions, insurance payouts, real estate transactions, gifts, and any other transfer of value — received by any employee, contractor, consultant, board member, or officer of TPUSA (including but not limited to Erika Kirk) during the period from May 10, 2025 (four months before the assassination) through January 10, 2026 (four months after the assassination). This production shall specifically identify any single payment or series of related payments exceeding $100,000 from any source. Excluded from this disclosure requirement are: (1) regular W-2 salary payments from TPUSA at the recipient's established pay rate; and (2) distributions from companies in which the recipient holds an ownership interest that are consistent with the company's historical distribution pattern. All other payments exceeding $100,000 — including but not limited to consulting fees, bonuses, life insurance proceeds, severance, trust distributions from trusts in which the recipient is a beneficiary but not the grantor, real estate sale proceeds, gifts, loans, and any payment routed through intermediary entities — shall be disclosed with full documentation of the source, amount, date, stated purpose, and the identity of the payor. Each covered agency shall also produce all FinCEN records, Suspicious Activity Reports, and Currency Transaction Reports related to any TPUSA-connected individual during this period.

Mosaic Pro Events / AV Equipment (#190–#192)

• #190: Mosaic Pro Events Staff Scheduling Anomaly: Each covered agency shall produce all scheduling records from Mosaic Pro Events for the TPUSA campus tour, specifically explaining why no Mosaic night staff was scheduled for the UVU event (the first tour stop) while all subsequent stops had night events scheduled. Each covered agency shall also produce all contracts, work orders, and communications between Mosaic Pro Events and TPUSA regarding the UVU event.

• #191: Rode Wireless PRO Microphone Audio: Each covered agency shall produce all audio captured by the Rode Wireless PRO microphone Charlie Kirk was wearing, which records internally at 32-bit audio and cannot be turned off by the wearer — only remotely — from the moment it was removed from its case through the end of the event. Each covered agency shall also produce the current location and chain of custody of this microphone, all records of its destruction if destroyed, and all audio from any Rode devices present at the event including backup recordings stored on TPUSA or Mosaic servers.

• #192: Mikey McCoy's Mic-Up Video: The close-up video filmed by Mikey McCoy showing Charlie Kirk being mic'd up before the event. Each covered agency shall also produce the current location of this video, whether it was deleted or requested to be deleted by any agency, and all communications between McCoy and any government agency regarding this footage.

Butch Hibbs & Exploding Microphone (#193–#194)

• #193: Butch Hibbs at UVU Event: Each covered agency shall produce all records, photographs, video, and communications related to Butch Hibbs (brother of Calvary Chapel pastor Jack Hibbs) at the UVU event on September 10, 2025, specifically the square object in his front right pocket matching the dimensions of a Rode Wireless GO II receiver (approximately 2x2 inches), his proximity to the sound crew, photographs showing his pocket empty after Kirk was killed, and his movements throughout the event. Each covered agency shall produce all evidence of any kind of explosion that happened within an hour before or an hour and a half after Charlie Kirk died, at or near UVU or any related location. Each covered agency shall also produce all of Butch Hibbs's communications in the 60 days before and 30 days after the assassination.

• #194: Heber City to Nashville Flight (Aug 25, 2025): Each covered agency shall produce all records related to the private aircraft flight from Heber City, Utah to John Tune Airport, Nashville, Tennessee on August 25, 2025 — the same day AES delivered the "MINIATURIZED-XS DEMOLITION CHARGES, ANTI PERSONNEL-XS" under DoD contract N0016425PJ538. Each covered agency shall also produce the passenger manifest, aircraft registration, who chartered or owned the aircraft, and any connection to Butch Hibbs or any person associated with TPUSA, Calvary Chapel, or the Charlie Kirk investigation.

FBI Conduct at Scene (#195–#196)

• #195: FBI RAV4 Near Robinson Post-Shooting: Each covered agency shall produce all records related to the FBI agent(s) in an unmarked RAV4 who drove past Tyler Robinson immediately after the shooting and subsequently flashed an FBI badge when pulled over by local law enforcement. Each covered agency shall also produce the identity of these agents, their assignment, why they were in the area, and all communications and GPS/vehicle tracking data for this vehicle on September 10, 2025.

• #196: FBI Direction of Re-Search Finding Weapon: Each covered agency shall produce detailed records of the sequence of searches for the weapon: (1) the initial arm-to-arm local law enforcement search that found nothing, (2) the K-9 search that found nothing, (3) the arrival of three federal agents who directed three junior local law enforcement officers to re-search the area, after which the weapon was "found." Each covered agency shall also produce the identity of the three federal agents, their chain of command, how they knew to direct a re-search of that specific area, and whether the weapon was planted.

Fort Huachuca Meeting (#197)

• #197: Fort Huachuca Pre-Assassination Meeting: Each covered agency shall produce all records related to a meeting at Fort Huachuca (U.S. Army intelligence installation) referenced as involving "JTF" (Joint Task Force), including the identity of all participants — the woman with striking blue eyes who "dressed down" (reportedly the top administration visitor, possibly Karoline Leavitt), a Hispanic female Secret Service agent, a GSA representative, and Congressman Mark E. Amodei (R-NV). Each covered agency shall also produce all records of what was discussed, why they "cared very much about the next 24 hours," and the timeline of this meeting relative to the assassination.

Event Live Streams (#198)

• #198: Live Stream Interruptions at UVU: Each covered agency shall produce all records explaining whether live streams of the UVU event were cut or interrupted during or immediately after the shooting, which streams continued and which were stopped, who had the authority and ability to cut streams. Each covered agency shall also produce all communications between TPUSA, Mosaic Pro Events, streaming platforms, and any government agency regarding live stream management on September 10, 2025.

Kirk's Personal Statements & Relationships (#199–#201)

• #199: Kirk's Pre-Death Warnings — Full Record: Each covered agency shall produce all communications by Charlie Kirk in the 90 days before his death expressing fear for his life, identifying specific threats or threateners, or describing confrontations — beyond the known texts saying "THEY ARE GOING TO KILL ME." Each covered agency shall also produce all records from the Hamptons meeting where he was confronted by pro-Israel figures, including the donor who asked "What would happen to TPUSA if you DIED?" approximately 40 days before the assassination (confirmed by Erika Kirk in an interview with Megyn Kelly).

• #200: Kirk's Parents and Legal Representation: Each covered agency shall produce all communications and records explaining why Charlie Kirk's parents reportedly did not want high-end attorneys involved in the case. Each covered agency shall also produce records establishing whether any person, agency, or organization pressured or advised Kirk's family regarding legal representation, and all communications between Kirk's family and any government agency or TPUSA regarding the investigation.

• #201: Kirk's Girlfriend: Each covered agency shall produce all records, communications, and interview transcripts related to Charlie Kirk's girlfriend, her presence or absence at the UVU event, her communications with Kirk in the days before the assassination, and any contact between her and federal investigators.

Bullet Engravings & Planted Evidence (#202)

• #202: Bullet Casing Engravings Analysis: Each covered agency shall produce full forensic analysis of the engraved cartridge casings, including tools used for engraving, timeline of when engravings were made (before or after firing), whether the engravings are consistent with Tyler Robinson's handwriting and known tools, and whether the engravings appear staged or planted. Each covered agency shall produce all analysis of whether the apparent motive indicators — including the cartridge inscriptions ("Notices Bulge OWO what's this?", "hey fascist! CATCH!", "O Bella ciao, Bella ciao, Bella ciao, Ciao, ciao!", "If you read This, you are GAY Lmao") — are consistent with genuine radicalization or suggest an externally constructed narrative, and all FBI investigation into the authenticity and origin of the motive evidence. Each covered agency shall also produce all chain-of-custody records for these casings from discovery through current storage.

Crime Scene Paving (#203)

• #203: UVU Crime Scene Paving & Alteration: Each covered agency shall produce all records, communications, contracts, and authorizations related to the paving over of the crime scene at Utah Valley University, including who authorized the paving, when it occurred relative to the completion of forensic examination, whether all evidence had been collected before destruction, and whether any federal or state agency objected to or approved the destruction. Each covered agency shall produce all records of the crime scene being rapidly scrubbed, altered, or cleaned up post-incident — including who ordered and performed the cleanup, what was removed, and whether any evidence was lost as a result. Each covered agency shall also produce all communications between UVU administration and any government agency regarding the crime scene.

AES Factory Explosion (#204)

• #204: AES Factory Explosion Investigation: Each covered agency shall produce all federal investigation records (ATF, OSHA, FBI, DOD) related to the explosion at the Accurate Energetic Systems facility in McEwen, Tennessee on October 10, 2025, which killed 16 employees — the deadliest above-ground industrial accident in the US in 34 years. Each covered agency shall also produce records establishing whether any investigation examined the connection between this explosion and the DoD contract N0016425PJ538 for miniaturized anti-personnel charges, all records of which employees had knowledge of or involvement in the N0016425PJ538 contract and whether any of those specific employees were among the 16 killed, and all records of whether the explosion destroyed evidence, blueprints, production records, or test data related to the miniaturized devices.

Tyler Robinson Movement & Identity (#205–#208)

• #205: Tyler Robinson Complete Travel Path: Each covered agency shall produce all FBI, law enforcement, and intelligence information on Tyler Robinson's complete travel path and movements in the 72 hours before and 24 hours after the shooting on September 10, 2025 — including every location visited, mode of transportation used, timestamps, surveillance footage, cell phone location data, GPS data, witness sightings, and any stops along the way. Each covered agency shall also produce records of his route to UVU, how he entered the campus, what path he took through the campus, what buildings he entered, how he accessed the rooftop, what path he took after the shooting, and how he departed the campus. Each covered agency shall produce all records of visitors to Tyler Robinson's home in the lead-up to the event, including dates, identities, surveillance footage, and any connection between those visitors and any intelligence service or other organization. Each covered agency shall also produce all records relating to Tyler Robinson's movements for the 30 days prior to the shooting.

• #206: Tyler Robinson Prior Visits to UVU: Each covered agency shall produce all FBI, law enforcement, and intelligence information on whether Tyler Robinson had ever visited the Utah Valley University campus prior to September 10, 2025. Each covered agency shall also produce any surveillance footage, cell phone location data, campus access records, witness statements, or any other evidence showing Robinson at or near UVU on any date before the shooting. Each covered agency shall also produce records of any investigation into whether Robinson conducted reconnaissance or scouting visits to the campus, and whether any other person accompanied him on any prior visit.

• #207: Tyler Robinson Position at Time of Shooting: Each covered agency shall produce all FBI and law enforcement analysis, video footage, witness statements, cell phone data, and any other evidence addressing whether Tyler Robinson was on the rooftop, in the stairways, or at any other location at the exact moment the fatal shot was fired. Each covered agency shall produce all timeline reconstruction showing Robinson's second-by-second position, and whether the investigation found or considered the possibility that Robinson was already descending or off the roof when the shot occurred. Each covered agency shall also produce all records relating to whether any person other than Robinson was on the rooftop at the time of the shot.

• #208: Rooftop Suspect Movement at Moment of Shot: Each covered agency shall produce all video footage, witness statements, and FBI analysis showing whether the person on the rooftop was stationary (in a firing position) or running/moving at the exact moment the shot was fired. Each covered agency shall produce all surveillance camera angles, drone footage, aerial footage, and any other visual evidence capturing the rooftop at the time of the shooting. Each covered agency shall produce all records establishing whether the movement pattern observed is consistent with a person who just fired a rifle versus a person who was not the shooter. Each covered agency shall also produce all records relating to whether any shots were fired from drones, from any other elevated position, or from any location other than the Losee Center rooftop, and the total number of shots fired from each identified origin point.

Venue Access & Non-Traditional Weapons (#209–#210)

• #209: Hatch Beneath Charlie Kirk's Seat: Each covered agency shall produce all records, blueprints, building plans, photographs, and video related to the presence of a hatch, access panel, or below-stage access point beneath or near Charlie Kirk's seat at the UVU event venue on September 10, 2025. Each covered agency shall produce all records relating to who had knowledge of this access point, whether it was used before, during, or after the event, who had access to it, and whether any person, equipment, or weapon was staged, concealed, or moved through it.

• #210: Non-Traditional Weapon or "Camera Gun" Theory: Each covered agency shall produce all FBI and law enforcement investigation into the theory that a non-traditional weapon — including but not limited to a "camera gun" or other weapon disguised as event equipment (camera, microphone, lighting, AV gear) — was used in the assassination. Each covered agency shall produce all forensic analysis of any event equipment that could have been modified to conceal or function as a weapon, all records of any unusual or unregistered equipment brought to the UVU event, and all investigation into whether any device other than the Mauser Model 98 rifle was used to fire a projectile on September 10, 2025.

Israeli IP Surveillance Targeting (#211)

• #211: Israeli IP Surveillance of Key Persons: All records from NSA, FBI, or any agency documenting foreign government digital surveillance, IP tracking, or electronic monitoring directed at any Schedule B person at any time, including but not limited to Israeli IP addresses targeting Timpanogos Hospital surgeons, medical examiner, defense counsel, crime scene contractors, and hospital CEO. Each covered agency shall also produce all records relating to any foreign government electronic surveillance, network intrusion, or digital monitoring of any person connected to the investigation, medical treatment, prosecution, or defense in the Charlie Kirk case.

Autopsy Failure (#212)

• #212: Failure to Perform Required Autopsy: All records explaining why no autopsy was performed on Charlie Kirk despite Utah Code 26B-8-205 requiring it, including who made the decision not to perform an autopsy, who authorized the body's removal from the jurisdiction, and whether any government agency, intelligence service, or other entity influenced the decision. Each covered agency shall also produce all communications between any medical examiner, coroner, law enforcement agency, or government official regarding the autopsy decision, and all records of any pressure, direction, or interference with the medical examiner's independent judgment.

Corner-Shot Weapon Analysis (#213)

• #213: Corner-Shot and Non-Standard Weapon Analysis: All ballistic analyses, comparisons, or assessments involving non-standard weapons including Israeli Corner-Shot weapons, 9mm Israeli-manufactured ammunition, and concealed-position weapons, and any intelligence reports on such weapons in the possession of persons present at or near UVU on September 10, 2025. Each covered agency shall also produce all records relating to the importation, sale, or transfer of Corner-Shot weapons or similar concealed-firing-position weapons to any person or entity in the United States, and all assessments of whether such a weapon could have been used in the shooting.

State Official Communications (#214)

• #214: Utah State Official Federal Communications: All communications between Utah state officials — including Governor Spencer Cox, the Utah Attorney General, the Utah judiciary, and any state agency head — and any federal agency regarding the Charlie Kirk investigation, prosecution strategy, evidence handling, judicial orders (including gag orders), or any other matter related to the case. Each covered agency shall also produce all records of federal agencies directing, advising, or influencing Utah state officials in the handling of the investigation or prosecution, and all records of coordination between federal and state officials regarding public statements, media strategy, or information control related to the case.

Hospital Compromise (#215)

• #215: Hospital Pre-Selection and Intelligence Influence: All records relating to whether Timpanogos Regional Hospital, its medical personnel, or CEO Andrew Zenger was subject to pre-selection, direction, intelligence service influence, or pre-planned placement of personnel in connection with the Charlie Kirk case. Each covered agency shall also produce all records of any contact between any intelligence service or government agency and hospital personnel before, during, or after the shooting, all records of any direction given to hospital staff regarding treatment decisions, and all records relating to whether the routing of Charlie Kirk to Timpanogos Regional Hospital rather than another facility was influenced by any government agency or intelligence service.

Hospital Bomb Threat and Diversion (#216)

• #216: Hospital Bomb Threat and Planned Diversion: All records related to any bomb threat, bomb scare, or security incident at any hospital within 20 miles of Utah Valley University on September 10, 2025, including but not limited to Intermountain Health Utah Valley Regional Medical Center. Each covered agency shall produce all 911 call records, caller identification data, call timing and duration, law enforcement dispatch records, hospital security logs, and all non-disclosure agreements (NDAs) signed by hospital staff in connection with any such bomb threat. Each covered agency shall further produce all records relating to whether the bomb threat was coordinated with the assassination to divert Charlie Kirk away from the closer hospital to a controlled facility, and all communications between any government agency, intelligence service, or private entity regarding hospital security incidents on September 10, 2025.

Carbyne 911 System Data (#217)

• #217: Carbyne 911 System Intelligence Access: All records related to the Carbyne 911 system — an Israeli intelligence-linked 911 technology platform co-founded by Ehud Barak with Epstein-connected funding — deployed across Utah, including all Carbyne system data for the Provo/Orem area on September 10, 2025. Each covered agency shall produce all 911 calls processed through the Carbyne system, all location pings, audio recordings, metadata, and data transmissions to any domestic or foreign server. Each covered agency shall further produce all records identifying any foreign entity, foreign government, or foreign intelligence service with access to Carbyne 911 data, all contracts between Utah governmental entities and Carbyne Ltd., and all assessments of whether the Carbyne system provided real-time intelligence access to any foreign service during the events of September 10, 2025.

Independent Ballistics and Forensic Testing Authority (#218)

• #218: Independent Ballistics and Forensic Testing: The review board established under Section 11 is hereby granted explicit authority to commission independent ballistics testing, acoustic analysis, explosive residue testing, metallurgical examination, and any other forensic testing it deems necessary, using experts selected by the review board and not by any covered agency. Each covered agency shall produce all existing ballistics analyses, acoustic analyses, explosive residue tests, and metallurgical examinations. The review board may conduct independent testing to verify, supplement, or challenge any existing agency analysis, including but not limited to: (1) independent determination of whether a 9mm weapon was fired; (2) independent analysis of whether the microphone or other equipment contained explosive material; (3) acoustic analysis of gunshot origin and trajectory; and (4) metallurgical analysis of all fragments recovered from the scene or from Charlie Kirk's body. No covered agency may obstruct, delay, or interfere with independent testing authorized under this item.

TPUSA Insider Aircraft N582MM (#220)

• #220: TPUSA Insider Aircraft N582MM Flight Records: Each covered agency shall produce all flight records, passenger manifests, crew lists, fuel purchase records, and FBO service records for aircraft N582MM from January 1, 2025, through the present, including but not limited to: (1) the September 10, 2025 flight from Chicago to Provo on the day of Charlie Kirk's assassination — who was aboard, who arranged the flight, and the purpose of travel; (2) the October 4–5, 2025 flights to and from Fort Huachuca, AZ, including who was aboard, the purpose of the visit, and the immediate subsequent flight to Kalispell, Montana; (3) any connection between the Kalispell flight and the TPUSA security team gathering in the same area; (4) all flights to or from any location referenced in Schedule A; (5) the complete flight history showing all destinations and passengers; and (6) the identity of all persons who chartered, paid for, or arranged flights on this aircraft. Each covered agency shall also produce all records relating to any TPUSA-affiliated person who traveled on any private aircraft to Provo, Utah on September 10, 2025, and the purpose of their travel.

Egyptian Aircraft Return to Provo (#221)

• #221: Egyptian Aircraft Return to Provo in 2026: Each covered agency shall produce all records relating to the return of Egyptian-registered aircraft (SU-BTT, SU-BND, SU-BTU, SU-BTV, SU-BGM, and any other Egyptian-registered aircraft) to Provo, Utah, or any Utah airport in 2026, including but not limited to: (1) all flight records, passenger manifests, crew lists, and cargo manifests; (2) the purpose of travel and all ground activities of passengers after arrival; (3) any correlation between the timing of Egyptian aircraft arrivals in Utah and French diplomatic visits to the United States, including Brigitte Macron's March 2026 visit to Washington D.C.; (4) all records establishing a pattern of coordinated movement between Egyptian aircraft and French diplomatic travel; and (5) all intelligence assessments of the operational significance of repeated Egyptian military aircraft visits to Provo. Each covered agency shall also produce all records relating to any Egyptian-registered aircraft visiting any U.S. airport within 48 hours before or after any diplomatic visit by any French official during 2025–2026.

VanceKirk2028.com Domain Registration (#222)

• #222: VanceKirk2028.com Domain Registration and Foreknowledge: Each covered agency shall produce all records relating to the internet domain vancekirk2028.com, which was registered on September 12, 2025 — two days after Charlie Kirk's assassination — through GoDaddy.com (Registrar IANA ID 146) with the registrant identity concealed behind Domains By Proxy, LLC (100 S. Mill Ave, Suite 1600, Tempe, AZ 85281). Each covered agency shall subpoena and produce: (1) the true identity, address, phone number, email address, and payment information of the person or entity that registered the domain, including all records held by GoDaddy.com and Domains By Proxy, LLC; (2) the payment method used to purchase the domain, including credit card number, bank account, PayPal account, cryptocurrency wallet, or any other payment instrument, and the identity of the account holder; (3) the IP address from which the domain was registered and all subsequent login sessions to the registrar account; (4) all DNS records, hosting records, and the identity of any person or entity that configured hosting on AWS Global Accelerator (IP addresses 13.248.243.5 and 76.223.105.230) or any other hosting provider; (5) all website content ever published at vancekirk2028.com, including archived versions, and the identity of whoever uploaded or authored that content; (6) all communications between the registrant and any domain registrar, hosting provider, or web developer regarding this domain; and (7) all records establishing whether the registration of a domain anticipating a "Vance/Kirk 2028" presidential ticket within 48 hours of Kirk's death reflects foreknowledge of the assassination or coordination with any person, organization, intelligence service, or political operation. Each covered agency shall also produce all records relating to any other internet domain registered between September 10-17, 2025 that references Charlie Kirk, TPUSA leadership succession, or any political ticket involving JD Vance paired with a replacement for Charlie Kirk.

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Bilt Inc. DOD Contracts (#223–#227)

• #223: Bilt Inc. DOD Contract Details and Authorization: Each covered agency shall produce all records relating to Department of Defense contracts awarded to Bilt Inc. in June 2025, totaling approximately $8 million from the U.S. Air Force, including but not limited to: (1) the full text of each contract, task order, modification, and amendment; (2) the contracting officer and all government officials who authorized, approved, or reviewed the award; (3) the stated purpose, scope of work, and deliverables for each contract; (4) all invoices submitted by Bilt Inc. and all payments made, with dates, amounts, and approving officials; (5) the justification for the unprecedented increase in contract value compared to Bilt Inc.'s historical contract amounts; and (6) all communications between DOD personnel and Bilt Inc. regarding these contracts. Each covered agency shall also produce all records relating to any DOD contract, grant, or payment to Bilt Inc. from January 2020 through the date of enactment.

• #224: Bilt Inc. Ownership and Personnel: Each covered agency shall produce all records identifying every person behind Bilt Inc., including but not limited to: (1) all current and former owners, shareholders, members, partners, officers, directors, and registered agents; (2) all employees, contractors, subcontractors, and consultants; (3) all beneficial owners as reported to FinCEN under the Corporate Transparency Act; (4) all corporate formation documents, amendments, and annual filings; (5) all affiliated entities, subsidiaries, parent companies, and related parties; and (6) all security clearances held by any person associated with Bilt Inc. Each covered agency shall also produce all records relating to any connection between Bilt Inc. personnel and any person listed in Schedule B or any foreign intelligence service.

• #225: Bilt Inc. Financial Flow Investigation: Each covered agency shall produce all records of money flows into and out of Bilt Inc. from March 2025 (six months before September 2025) through the date of enactment, including but not limited to: (1) all bank account statements, wire transfers, ACH transactions, checks, and digital payments; (2) all payments to subcontractors, vendors, employees, or any other recipients of Bilt Inc. funds; (3) all sources of revenue beyond DOD contracts; (4) all Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) filed by any financial institution involving Bilt Inc.; (5) all tax filings, including 1099s issued and received; and (6) any transfers to or from foreign accounts, shell companies, or intermediary entities. Each covered agency shall also produce all FinCEN records and bank subpoena responses relating to Bilt Inc. and its principals.

• #226: Bilt Inc. Invoice and Deliverable Audit: Each covered agency shall produce all records establishing the legitimate basis — if any — for the approximately $8 million in DOD payments to Bilt Inc. in June 2025, including but not limited to: (1) all invoices with line-item detail of goods or services provided; (2) all delivery receipts, acceptance documentation, and quality assurance records; (3) all progress reports and status updates; (4) all physical or digital deliverables produced under the contracts; (5) whether any goods or services were actually delivered or whether the contracts were used as a financial pass-through; and (6) all inspector general, audit, or oversight records relating to Bilt Inc. contracts. Each covered agency shall also produce all records of any DOD Inspector General inquiry, GAO review, or congressional inquiry into Bilt Inc. contracts.

• #227: Bilt Inc. Connection to Charlie Kirk Investigation: Each covered agency shall investigate and produce all records establishing any connection between Bilt Inc., its personnel, its subcontractors, or the recipients of its DOD funds and: (1) any person listed in Schedule B; (2) any event, location, or entity referenced in Schedule A; (3) any foreign intelligence service or foreign government; (4) the Charlie Kirk assassination or any aspect of the investigation; (5) TPUSA, Accurate Energetic Systems (AES), or any other entity referenced in this Act; and (6) any other DOD contractor that received unusually large or unprecedented contract awards in the period March–September 2025. Each covered agency shall also produce all intelligence assessments regarding Bilt Inc. and its potential role as a funding conduit or operational cover.

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Schedule B: List of People

"People Listed" (PEOPLE_LISTED): are the set of people information must be disclosed on. This definition includes the following:

• P1) All TPUSA employees, executives, board members, officers, contractors, consultants, and interns — current as of September 10, 2025 and for the 12 months prior. All TPUSA donors who contributed $5 million or more in any single year or $10 million cumulatively. All TPUSA event organizers, logistics personnel, and anyone involved in planning or executing the UVU event on September 10, 2025. Includes Erika Kirk and any person who assumed a leadership role at TPUSA within 30 days of Charlie Kirk's death.

• P2) All members of the TPUSA security detail, including head of security Dan Flood, external security contractors, private security firms hired for the UVU event, and any person who provided security services to Charlie Kirk at any event in the 12 months prior to September 10, 2025. Includes anyone on any security advance team that conducted or should have conducted site assessments at UVU. Includes any security personnel with prior employment by any foreign government, foreign leader, or foreign security service.

• P3) All audio engineers, sound crew, AV technicians, and equipment handlers at the UVU event on September 10, 2025. Includes whoever provided, handled, or attached the lavalier microphone to Charlie Kirk. Includes Michael Olbert and Terryl Farnsworth. Includes any person who had physical access to the microphone, audio equipment, or stage setup in the 48 hours before the event. Includes any person who removed equipment, SD cards, or recordings from the event.

• P4) All persons physically present on the Utah Valley University campus on September 10, 2025, whose identity is known to any law enforcement or intelligence agency. Includes attendees, students, faculty, staff, campus police, visitors, contractors performing work on campus, and any person captured on UVU surveillance cameras that day.

• P5) All FBI agents, analysts, supervisors, and support staff assigned to, participating in, consulted on, or possessing knowledge of the Charlie Kirk investigation from September 10, 2025 to present. Includes FBI agents who were physically present at UVU on or after September 10, 2025. Includes FBI agents who contacted witnesses and requested deletion of evidence. Includes the FBI Special Agent in Charge (SAIC) of the Salt Lake City field office (including Mehtab Syed and any successor). Includes any FBI personnel who directed the re-search that located the weapon. Includes any FBI Counterintelligence Division personnel involved in assessing foreign intelligence connections.

• P6) All Department of Justice officials, federal prosecutors, and DOJ staff with knowledge of or involvement in the investigation or prosecution. Includes any DOJ official involved in decisions about what information to share with or withhold from defense counsel, the court, or the public.

• P7) All Utah state, county, and local law enforcement officers involved in the response, investigation, or prosecution, including Utah County Sheriff's Office, Orem Police Department, UVU campus police, Provo Police Department, and any other responding agency. Includes all officers who participated in the initial search, K-9 search, and re-search for the weapon. Includes Utah County Attorney Jeffrey S. Gray, Deputy Attorneys Chad E. Grunander, Ryan McBride, Lauren Hunt, David Sturgill, and Christopher D. Ballard.

• P8) All judges assigned to State of Utah v. Tyler Alexander Robinson (Case No. 251403576), including Judge Tony F. Graf Jr. and any predecessor or successor judges. Includes Judge Robert Lunnen, whose retirement created the vacancy filled by Graf. Includes any judge or judicial officer involved in issuing warrants, gag orders, or other orders related to the investigation. Includes any person involved in the appointment or selection of judges for this case.

• P9) All attorneys representing Tyler Robinson, including Kathryn Nester, Richard Novak, Michael N. Burt, and Staci Visser, and any other counsel of record or consulting attorneys.

• P10) All employees, officers, contractors, and agents of any US intelligence agency — including CIA, NSA, DIA, NRO, NCTC, ODNI — who have any knowledge of, involvement in, or have produced any report, analysis, or communication related to the Charlie Kirk investigation, the UVU event, foreign intelligence activity connected to it, or the blocking of any investigation related to it. Includes Joe Kent (NCTC Director), Tulsi Gabbard (DNI), Kash Patel (FBI Director), and any intelligence official who participated in decisions to limit, block, or control the scope of investigation. Includes any person involved in the HADES spy plane program or drone operations on September 10, 2025.

• P11) All foreign intelligence officers, agents, contractors, military personnel, diplomats, or foreign nationals identified by any US agency as present in Utah between July 1, 2025 and November 30, 2025, whose presence may be connected to the Charlie Kirk investigation. Includes persons associated with Egyptian intelligence (GIS/Mukhabarat), French intelligence (DGSE/DGSI), Israeli intelligence (Mossad, Shin Bet), or any other foreign intelligence service. Includes all persons carrying Israeli-registered cell phones detected at or near UVU on September 10, 2025 (the 12 phones identified by NSA). Includes any foreign national who entered the US through Provo or Salt Lake City airports in the relevant period.

• P12) All US military personnel, defense contractors, and Department of Defense civilians involved in any military activity connected to the investigation. Includes crew and mission personnel of aircraft N1098L (HADES spy plane), including pilots, co-pilots, mission engineers, and observers from LASAI Aviation II LLC and Leidos Aviation Services. Includes any military personnel stationed at or visiting Fort Huachuca, AZ between September 1-11, 2025 who had any connection to matters related to Charlie Kirk. Includes personnel involved in DoD contract N0016425PJ538 for miniaturized anti-personnel charges at NSWC Crane and Accurate Energetic Systems (AES). Includes any person aboard US Air Force VIP transport jet 99-0404 (SAM callsign). Includes French legionnaires present in the US August 2-25, 2025.

• P13) All pilots, crew, passengers, and ground handlers associated with Egyptian-registered aircraft SU-BTT, SU-BND, SU-BTU, SU-BTV, SU-BGM, T7ELL, and EJM36 during any flights to or within the United States between May 1, 2025 and November 30, 2025. Includes any "military contractors" who deplaned these aircraft and remained in the US. Includes any person who held "US Department of Defense Liaison" badges. Includes any person involved in Counter-UAS testing at Provo airport September 4-10, 2025. Includes Walid Mahmoud and any other identified passengers.

• P14) All persons who operated, contracted for, received data from, or had knowledge of any drone — military or civilian — operating at or near UVU on September 10, 2025. Includes operators of the HADES spy plane N1098L and any drones launched or recovered from it. Includes operators of surveillance aircraft N59906 (MARC Inc.). Includes any person who received real-time surveillance feeds from any aerial platform that day.

• P15) All persons who were identified as persons of interest, detained, questioned, or arrested at or near UVU on September 10, 2025, other than Tyler Robinson. Specifically includes: Russell Kennington ("Fake Doctor w/Gun"), the pellet gun individual at Joe Vera's Mexican Restaurant, George Zinn ("Mr. Shoot Me"), Zachariah Ahmed Qureshi, the person known as "David" (owner of X account @RtothepowerofX), any person police were called about at Urban Pioneer Cafe or Sorenson Molecular Biotechnology Building that day, the individual known as "Rick Cutler" (arm puller/sunglasses man), and any other person whose presence or behavior was flagged by law enforcement. Includes any person who was considered as an alternate suspect, a possible second shooter, or a distraction operative.

• P16) All airport staff, TSA agents, CBP officers, FBO employees, ground handlers, and air traffic controllers at Provo Municipal Airport (PVU) and Salt Lake City International Airport (SLC) who handled, interacted with, or had knowledge of Egyptian military aircraft, surveillance aircraft, or any aircraft listed in Schedule A. Includes anyone who granted "no-scan priority clearance" or special security exemptions. Includes anyone who modified badge access lists at Provo airport on or around September 11, 2025.

• P17) All persons who attended meetings, calls, or confrontations with Charlie Kirk between July 1, 2025 and September 10, 2025, regarding Israel policy, donor pressure, or TPUSA direction. Specifically includes participants in the Hamptons meeting (August 3-6, 2025), including but not limited to Rabbi Pesach Wolicki, Josh Hammer, Seth Dillon, Bill Ackman, and Natasha Hausdorff. Includes any person who participated in the described "intervention" where Charlie Kirk was confronted by pro-Israel figures. Includes Benjamin Netanyahu, Yair Netanyahu, Emmanuel Macron, and any intermediaries who communicated offers or pressure to Charlie Kirk. Includes participants in the July 31, 2025 White House meeting organized by the Faith & Freedom Coalition, Latino Coalition for Israel, and Philos Project, including Ralph Reed, Luke Moon, Apostle Mario Bramnick, and Yehuda Kaploun.

• P18) All persons to whom Charlie Kirk communicated fears for his life or threats against him. Specifically includes Andrew Kolvet, Frank Turek, Dan Flood, Harrison Smith, and Candace Owens. Includes any person who received texts, Signal messages, Telegram messages, or any other communications from Charlie Kirk expressing concern about being killed or threatened. Includes Blake Neff, Mikey McCoy, Rob McCoy, and any other person in Kirk's inner circle who was present at or communicated about the UVU event.

• P19) Erika Kirk (Charlie Kirk's wife), Charlie Kirk's parents, and any immediate family member who had knowledge of threats, life insurance policies, communications, or who took actions related to Charlie Kirk's death, his estate, or the succession of TPUSA leadership. Includes any person who communicated with Erika Kirk about TPUSA leadership succession in the 30 days following the death.

• P20) All physicians, surgeons, nurses, paramedics, EMTs, hospital staff, and medical examiners who treated, examined, transported, or handled the body of Charlie Kirk from the moment of shooting through burial. Includes the surgeon who was reportedly blocked by FBI from re-entering Charlie Kirk's room. Includes whoever signed the death certificate. Includes anyone involved in the decision regarding whether to perform an autopsy (as required by Utah law 268-8-205 for gun violence deaths).

• P21) All persons involved in the decision to pave over the UVU crime scene and all persons who performed the work. Specifically includes employees and owners of Hardscape Specialties LLC (Michael Powell — Utah AG special agent, and Burton Romrell — former UVU operations staff) and Hardscape Utah/Daniel Merrell. Includes any UVU administrator or state official who authorized or ordered the alteration. Includes any person from "Crew GC" or other construction firms involved. Includes the "men who work for the state of Utah" who contacted the contractor.

• P22) All persons who witnessed the shooting, recorded video or audio, or were interviewed by law enforcement. Includes any person whose video or recordings were requested to be deleted by FBI agents. Includes any witness who was contacted by FBI and told not to speak publicly or to other law enforcement. Includes witness Dylan Hope (electrician working at adjacent property). Includes Phil Lyman (whose car was parked near the scene). Includes any person subject to or affected by the court gag order.

• P23) All persons involved in the creation, management, beneficiary designation, or payout of any life insurance policy on Charlie Kirk. Includes all persons associated with GGLF 2023 LLC. Includes any insurance company executives or agents who processed claims. Includes any person involved in the $350,000 TPUSA loan related to insurance premiums. Includes any financial advisor, accountant, or banker who handled Charlie Kirk's or TPUSA's finances related to insurance or the estimated $20-50 million payout.

• P24) Tyler Robinson, Lance Twiggs (Robinson's girlfriend/live-in partner), Robinson's parents, Robinson's family members, and any person who communicated with, met with, housed, employed, educated, trained, or provided financial support to Tyler Robinson in the 12 months before September 10, 2025. Includes any person who may have psychologically manipulated, radicalized, handled, or directed Robinson. Includes jail snitch Jaxson Thomas Fox. Includes any person who appeared at Robinson's court hearings in October 2025.

• P25) All elected officials, appointed officials, and government employees at federal, state, or local level who had knowledge of, involvement in, or communicated about the Charlie Kirk investigation, the UVU event, or related matters. Specifically includes Governor Spencer Cox (Utah), any member of Congress who received briefings, Mike Huckabee (US Ambassador to Israel), and any White House staff or advisors who communicated about the case. Includes any official who made decisions about the scope of investigation, who intervened to block or limit investigations, or who communicated with foreign governments — including the offices of Benjamin Netanyahu and Emmanuel Macron — about the case.

• P26) All persons affiliated with AIPAC, ADL, Faith & Freedom Coalition, Heritage Foundation, Philos Project, or any other lobbying organization or political advocacy group that communicated about Charlie Kirk's policy positions on Israel, engaged in pressure campaigns directed at Kirk, or had any interaction with any person in this definition related to the investigation. Includes any person connected to the reported "hit" or threats against Candace Owens, Tucker Carlson, or Ian Carroll.

• P27) All journalists, media executives, and media personnel who received early or advance information about Charlie Kirk's death (including the Jerusalem Post, which reportedly announced his death before he was pronounced dead at the hospital). Includes any media person who received leaks, tips, or information from law enforcement or intelligence about the investigation. Includes Charlie Kirk Show producers and staff who were authorized to discuss matters otherwise under gag order.

• P28) All employees, contractors, officers, and associates of Accurate Energetic Systems (AES) in McEwen, Tennessee, who worked on DoD contract N0016425PJ538 or had knowledge of the miniaturized anti-personnel charges. Includes surviving employees (16 were killed in the October 10, 2025 explosion). Includes any person involved in the August 25, 2025 delivery. Includes any NSWC Crane personnel who authorized, managed, or received deliverables under this contract.

• P29) All rental car company employees and hotel/lodging staff who served foreign nationals, intelligence operatives, or persons of interest connected to the investigation in the Provo/Orem/Salt Lake City area between August 25 and September 15, 2025. Includes any person who can identify rental vehicles or lodging used by persons in this definition.

• P30) All employees of telecommunications companies, social media platforms, or technology companies who processed requests from law enforcement to preserve, produce, or delete data related to the investigation. Includes any person at Google who was involved in the reported deletion of Google Search evidence. Includes any person at cell phone carriers (US and foreign) who handled cell tower data requests. Includes Signal, Telegram, and any encrypted messaging platform employees who handled legal process related to Charlie Kirk's communications.

• P31) All Utah Valley University administrators, faculty, staff, campus security, and facilities personnel who were involved in planning the TPUSA event, managing security for the event, providing building access (including roof access to the Losee Center), or who had knowledge of any unusual activity on campus in the days before September 10, 2025. Includes any UVU person who communicated with FBI, TPUSA security, or any other entity about the event logistics or aftermath.

• P32) All passengers, crew, and persons who boarded or deplaned any aircraft listed in Schedule A Item #1 (including SU-BTT, SU-BND, SU-BTU, SU-BTV, SU-BGM, N1098L, N888KG, N59906, N560TW, N102DZ, N40JD, N872RA, 99-0404, T7ELL, EJM36, N55906) at any time between July 1, 2025 and November 30, 2025. Includes all persons on the August 25, 2025 flight from Heber City, UT to John Tune Airport, Nashville, TN. Includes all persons aboard N560TW on its September 10, 2025 flight from Scottsdale to Provo and return.

• P33) Scott Lazerson and all persons who met with, communicated with, or traveled with Scott Lazerson between August 1, 2025 and September 15, 2025. Includes Jessica Krauss (House Inhabit), Tami Radabaugh, Sean Parnell, Sean Reyes, and any person Lazerson met with at the Pentagon. Includes any person connected to the SAM flight into Las Vegas on August 25-26, 2025.

• P34) All religious leaders, pastors, rabbis, or faith organization leaders who communicated with Charlie Kirk, TPUSA, or any person in this definition about Charlie Kirk's Israel policy positions or who participated in meetings or interventions. Includes Rob McCoy (pastor, Calvary Church), Rabbi Pesach Wolicki, and any other clergy involved in pressure campaigns or communications with Kirk in the months before his death.

• P35) Any other person, whether named or unnamed in this Act, who possesses information relevant to understanding the full circumstances of Charlie Kirk's death, including but not limited to: persons who received payments from unknown sources to be present at or near UVU on September 10, 2025; persons who communicated with any foreign intelligence service about Charlie Kirk; persons who participated in any meeting where harm to Charlie Kirk was discussed, planned, or approved; and any person whose identity is known to any covered agency as relevant to the investigation but who has not been publicly identified.

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Section 5: Definitions

(a) "Covered agencies" means the Department of Justice, the Federal Bureau of Investigation, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), U.S. Customs and Border Protection (CBP), the Transportation Security Administration (TSA), the Department of Homeland Security, the Financial Crimes Enforcement Network (FinCEN), the Department of the Treasury, the Internal Revenue Service (IRS), and any federal, state, or local law enforcement agency that has participated in, contributed to, or possesses information related to the investigation of the death of Charlie Kirk, the prosecution of any person in connection therewith, or any matter peripheral to or connected with the investigation.

(b) "Covered records" means any and all files, documents, communications, reports, forensic evidence, witness statements, surveillance records, digital records, photographs, video recordings, audio recordings, cell site location information, geofence warrant data, flight records, financial records, ballistics analyses, autopsy reports, crime scene evidence, and any other information, in any format, that is related to or could reasonably assist in understanding the circumstances of the death of Charlie Kirk, including but not limited to:

1. All records specifically enumerated in Schedule A (227 Critical Disclosure Items)
2. Any records that could identify or suggest the identity of any person involved in, connected to, or with knowledge of the death
3. Any records relating to foreign intelligence service activity in the State of Utah during the period January 1, 2025 through December 31, 2025
4. Any records relating to threats against Charlie Kirk or similarly situated public figures
5. Any records relating to the activities, communications, or movements of any person of interest in the investigation
6. Any records that contradict, supplement, or provide context to the official investigation narrative
7. Any internal communications regarding the investigation, including charging decisions, case strategy, investigative priorities, and decisions regarding what information to withhold from defense counsel or the public
8. Any records relating to evidence collection, preservation, alteration, or destruction at the crime scene or any related location

(c) "Good-faith compliance" means the production of all responsive records with a genuine effort to identify, locate, and disclose every covered record, without evasion, delay, or use of technicalities to withhold material information.

(d) "Death of Charlie Kirk" means the killing of Charles J. Kirk on September 10, 2025, at Utah Valley University, Orem, Utah, and all events, planning, coordination, and circumstances leading to, surrounding, and following that event.

(e) "Investigation" means any federal, state, or local law enforcement inquiry, intelligence assessment, counterintelligence investigation, congressional inquiry, or other governmental examination related to the death of Charlie Kirk, including but not limited to the criminal prosecution in State of Utah v. Tyler Alexander Robinson (Case No. 251403576, Fourth Judicial District Court, Utah County).

(f) "People Involved" or "People Listed" means the categories of persons defined in Schedule B of this Act, encompassing categories P1 through P35.

(g) "Designated Trusted Investigator" means an investigator designated under the Charlie Kirk Trusted Investigators Act, if enacted; or, if such Act has not been enacted, any independent investigator appointed by the review board established under Section 11 of this Act.

(h) "Disclosure body" means the independent review board established under Section 11 of this Act.

(i) "Final output information" means all intelligence and investigative products, including but not limited to: raw signals intelligence intercepts and transcripts, satellite imagery, cable traffic, source reports, briefing materials, intelligence assessments, analytical products, forensic data, and any information from which conclusions were or could be drawn. The distinction between raw intelligence and finished intelligence, or between raw investigative data and completed analyses, shall not be used to withhold any covered record. Agencies may not disclose only their own conclusions while withholding the underlying evidence from which those conclusions were derived.

Section 6: Prohibited Grounds for Withholding

(a) No record shall be withheld, delayed, or redacted on the basis of:

1. Embarrassment, reputational harm, or political sensitivity to any government official, public figure, or foreign dignitary
2. Any ongoing investigation (except as narrowly provided below)
3. Executive privilege
4. Deliberative process privilege
5. The inter-agency or intra-agency memorandums or letters exemption (5 U.S.C. § 552(b)(5)) — no covered record shall be withheld on the ground that it constitutes an inter-agency or intra-agency memorandum or letter that would not be available by law to a party other than an agency in litigation with the agency; all such memorandums and letters in the possession of any covered agency that relate to the death of Charlie Kirk or any person involved shall be disclosed in full
6. Law enforcement privilege
7. Any claim that records were "lost," "destroyed," or "cannot be located" without forensic verification
8. Grand jury secrecy (Federal Rule of Criminal Procedure 6(e)) — Congress hereby exercises its authority to override grand jury secrecy with respect to covered records
9. Privacy of government employees acting in their official capacity
10. Attorney-client privilege between any covered agency and its counsel regarding the investigation

(b) Narrow Permitted Redactions. The only permissible redactions from covered records are:

1. Names of confidential human sources currently active in unrelated ongoing investigations where disclosure would create an imminent threat to life
2. Child sexual abuse material as defined under 18 U.S.C. Section 2256

(c) All redactions must be:

1. Individually justified in writing
2. Published in the Federal Register
3. Submitted to the Judiciary Committees of both houses of Congress
4. Subject to judicial review upon challenge by any party

(d) No blanket exemptions or classifications shall be permitted.

(e) Third Party Rule Override and Foreign Liaison Information. The Third Party Rule — the intelligence-sharing convention under which information received from a foreign government or foreign intelligence service may not be disclosed without that partner's consent — shall not apply to any covered record under this Act. Congress, exercising its constitutional authority over national security oversight and its power to compel disclosure of all information in the possession of the United States government, hereby overrides any agreement, memorandum of understanding, or informal arrangement between any covered agency and any foreign government, foreign intelligence service, or international organization that would restrict disclosure of covered records. This override applies to information received from any foreign source, including but not limited to: any foreign government and its intelligence services, the Arab Republic of Egypt and the Egyptian General Intelligence Directorate (GID), the United Kingdom and MI5/MI6/GCHQ, and all other Five Eyes partners (Australia, Canada, New Zealand). No covered agency may withhold, delay, or redact any covered record on the ground that it was received from or shared with a foreign partner. Within 14 days of enactment, the Director of National Intelligence shall formally request all foreign liaison partners from whom covered information was received to authorize public disclosure. The results of all such requests — including which partners authorized, which refused, and which did not respond — shall be reported to the congressional intelligence committees within 14 days of the request. Regardless of whether foreign partners authorize disclosure, all covered records shall be disclosed as required by this Act.

(f) Declassification of Covered Records. All classification markings on covered records are automatically removed upon enactment of this Act. No covered record may be reclassified after enactment. Covered agencies shall process declassification within the 30-day disclosure window. Classification shall not excuse non-production; if an agency cannot complete declassification review within 30 days, the record shall be produced to the review board in classified form, with a public redacted version produced simultaneously, and the full unclassified version produced within 60 days. Any agency seeking to maintain classification on specific records must petition the review board established under Section 11 within 7 days of enactment, identifying each record with particularity and demonstrating by clear and convincing evidence that disclosure would cause grave and specific harm to a currently active intelligence operation. The burden of proof rests entirely on the petitioning agency. The review board shall rule on each petition within 14 days. Failure to petition within 7 days constitutes waiver of any classification claim. The review board may grant temporary classification for no more than 90 days, subject to renewal only upon a renewed showing of grave and specific harm.

Section 7: No Foreign Government Exception

(a) No record shall be withheld on the basis that it relates to, was received from, or could affect relations with any foreign government, any foreign intelligence service, or any entity acting on behalf of or in coordination with any foreign government.

(b) The documented pattern of suppressing foreign-government-related records in the JFK Assassination Records Collection Act (100,000+ documents relating to foreign government involvement remain unreleased after 60+ years) and the Epstein Files Transparency Act (records connecting Epstein to foreign intelligence operations heavily redacted) shall not be repeated under this Act.

(c) This prohibition extends to records relating to any foreign government or foreign intelligence service, including but not limited to records involving any foreign government that may be acting through proxies or in coordination with other foreign intelligence services.

(d) Any invocation of foreign government relations, foreign intelligence cooperation, or foreign diplomatic sensitivities to justify withholding constitutes obstruction under Section 10(a).

Section 8: Records Preservation

(a) Upon introduction of this bill, all covered agencies shall immediately preserve all covered records and issue written preservation orders to all personnel. This preservation duty is enforceable upon enactment.

(b) Upon enactment, any person who destroyed, altered, concealed, or removed any covered record after the date this bill was introduced in Congress shall be subject to criminal prosecution and imprisonment of up to 15 years. Destruction of covered records after the date of introduction shall create an adverse inference in any proceeding under this Act that the destroyed records contained information favorable to full disclosure and adverse to the destroying agency's position. Existing federal law, including 18 U.S.C. 1519 (obstruction by destruction of records), applies independently to any pre-enactment destruction.

(c) Each covered agency shall be subject to a digital forensic audit of its document management systems to verify that no records have been deleted, altered, or moved after September 10, 2025. Forensic auditors shall be selected by the review board established under Section 11 and shall operate independently of the audited agency. No covered agency shall conduct its own forensic audit or select its own auditors for purposes of compliance with this subsection. The audit results shall be provided to Congress and the independent review board. The audited agency shall provide full and unrestricted access to all systems, databases, backup media, and audit logs as directed by the independent forensic auditors.

(d) Agencies that have destroyed records related to the investigation must provide a complete accounting of all destroyed records, including what was destroyed, when, by whom, and under whose authorization.

(e) Anti-Transfer Provision. Any transfer of covered records to any entity — including any other government agency, private contractor, or foreign government — after September 10, 2025, does not relieve the transferring agency of its disclosure obligations under this Act. The transferring agency remains fully responsible for producing the transferred records or compelling their return. Transfer of covered records to a foreign government or foreign entity after September 10, 2025, shall be treated as destruction of records and shall subject the responsible officials to the 15-year criminal penalty under Section 10(a) of this Act.

(f) Personal Device Preservation. The preservation obligations of this section extend to personal cell phones, personal email accounts, personal cloud storage, and encrypted messaging applications (including but not limited to Signal, Telegram, WhatsApp, and iMessage) of any person who is an employee, official, or agent of a covered agency and who worked on, participated in, or possessed knowledge of the investigation. Within 48 hours of enactment, each covered agency shall collect or cause to be forensically imaged all personal devices of persons of interest identified by the review board. Refusal to surrender a personal device for forensic imaging upon lawful demand shall constitute obstruction under Section 10(a).

(g) Independent Forensic Imaging Within 72 Hours. Within 72 hours of enactment, each covered agency shall submit to forensic imaging of all servers, databases, email archives, backup systems, and storage media by independent forensic firms selected by the review board. No covered agency may conduct its own forensic imaging for purposes of compliance with this subsection. The imaging shall be performed by firms with no current or recent contractual relationship with any covered agency.

(h) Complete Deletion Audit Logs. Each covered agency shall produce to the review board complete audit logs of all file deletions, modifications, access events, and system changes since September 10, 2025, across all systems containing or potentially containing covered records.

Section 9: Whistleblower Protections

(a) Right to Contact Investigation Teams. Any government employee, government contractor, subcontractor, grantee, or any person who has or has had access to covered information through any relationship with the United States government, may voluntarily submit covered records, information, leads, or evidence to any of the following recipients:

• The designated disclosure body (review board) established under this Act
• Any Designated Trusted Investigator or investigation team established under the Charlie Kirk Trusted Investigators Act (Law 4)
• Any investigation team established under the Charlie Kirk Mandatory Investigation Act (Law 3), including the FBI, CIA, NSA, and DNI-directed teams
• The external independent monitor established under the Charlie Kirk Mandatory Investigation Act (Law 3)
• The congressional oversight committees (including the Senate and House Judiciary Committees and Intelligence Committees)
• Any federal, state, or local law enforcement agency
• Directly to the public

This right applies to any information related to the death of Charlie Kirk and to any information about the investigation itself, including but not limited to evidence of obstruction, mismanagement, cover-up, evidence tampering, witness intimidation, or any failure to investigate leads.

(b) It shall be unlawful for any supervisor, manager, agency head, or any other person to retaliate against, terminate, demote, reassign, harass, revoke security clearance of, or in any way persecute any government employee or contractor for disclosing information pursuant to this Act.

(c) Any adverse personnel action taken against a disclosing employee or contractor within 2 years of disclosure shall create a rebuttable presumption of retaliation.

(d) Violations of subsection (b) shall be punishable by:

• Criminal penalties of up to 5 years imprisonment
• Civil liability for damages
• Mandatory reinstatement of any employee wrongfully affected
• Back pay for the full period of any wrongful separation
• Treble damages for willful violations

(e) NDA and Secrecy Agreement Override. No non-disclosure agreement, confidentiality agreement, secrecy agreement, or similar contractual provision — whether entered into with a government agency or a private entity — shall be enforceable to the extent it would prohibit any person from disclosing information related to the death of Charlie Kirk or the investigation thereof to any recipient listed in subsection (a).

(f) Statutory Secrecy Override. No provision of any statute — including but not limited to the Espionage Act (18 U.S.C. Sections 793-798), the Intelligence Identities Protection Act (50 U.S.C. Section 3121), the Classified Information Procedures Act, or any agency-specific secrecy statute — shall be construed to prohibit, penalize, or deter any person from disclosing covered information to any recipient listed in subsection (a). Any person who discloses covered information to a listed recipient in good faith shall be immune from criminal prosecution, civil liability, and administrative penalty under any secrecy or classification statute with respect to that disclosure. This subsection does not authorize disclosure of information unrelated to the death of Charlie Kirk or the investigation thereof.

(g) Private Sector Whistleblower Protections. The protections of subsections (b), (c), (d), (e), and (f) shall extend to any private sector employee, contractor, subcontractor, or agent who discloses information related to the death of Charlie Kirk or the investigation thereof pursuant to this Act. No employer may terminate, demote, harass, or otherwise retaliate against any person for making disclosures under this Act. This subsection is modeled on 18 U.S.C. 1514A (Sarbanes-Oxley whistleblower provisions) and shall be construed broadly to protect all persons who provide information.

Section 10: Penalties for Non-Compliance

(a) Any official who willfully withholds, destroys, conceals, or fails to produce covered records shall be subject to criminal prosecution and imprisonment of up to 10 years.

(b) Any agency that fails to comply within the 30-day timeline shall be subject to the following automatic, self-executing budget reductions: the non-compliant agency's discretionary law enforcement funding shall be reduced by 25% per month of non-compliance, with no cap on cumulative reductions. These reductions are automatic and self-executing upon certification of non-compliance by the review board established under Section 11 — no additional congressional action, appropriations rider, or executive branch approval is required. The Office of Management and Budget shall implement certified reductions within 5 business days of review board certification. Funds specifically appropriated for compliance with this Act are exempt from such reductions. Reductions apply prospectively to new discretionary appropriations, not retroactively to already-obligated funds.

(b-1) Escalating Weekly Budget Reductions. In addition to the monthly budget reductions under subsection (b), beginning on the 31st day after enactment, non-compliant agencies shall be subject to weekly escalating budget reductions: 5% in week 1 of non-compliance, 10% in week 2, 15% in week 3, and 25% per week thereafter, calculated on the agency's remaining discretionary budget. These reductions are cumulative with the monthly reductions.

(b-2) Individual Compliance Officer Liability. The senior compliance officer designated under Section 2(c) shall be personally and criminally liable for non-compliance. If the agency fails to meet the 30-day deadline, the compliance officer shall be subject to criminal prosecution for obstruction under this Act, independent of any prosecution of other agency officials.

(b-3) Independent Completeness Audit. The review board shall commission an independent technical audit team — composed of forensic IT specialists, records management experts, and legal professionals who are not current or former employees of any covered agency — to verify the completeness of each agency's production. The audit team shall assess whether search methodologies were adequate, whether all systems were searched, and whether negative certifications are credible. The review board, not any covered agency, shall determine whether compliance has been achieved.

(b-4) Real-Time Public Compliance Dashboard. Each covered agency shall publish and maintain a real-time public dashboard showing compliance status for each of the Schedule A items, including: records identified, records produced, records withheld (with stated basis), and records under review. The dashboard shall be updated no less than daily.

(c) Certification under penalty of perjury that all records have been produced, when records are later found to have been withheld, constitutes perjury and is subject to prosecution under 18 U.S.C. Section 1621.

(d) The Attorney General's failure to comply with this Act shall be grounds for contempt of Congress proceedings. Congress may proceed through civil contempt in federal court, bypassing the requirement of referral to the U.S. Attorney for the District of Columbia. Either chamber may retain independent counsel to prosecute the contempt. The review board may seek judicial enforcement directly.

(f) DOJ Inspector General Mandatory Investigation. The DOJ Inspector General shall investigate all findings of non-compliance by the review board and publish reports within 30 days of each finding.

(e) Attorney General Conflict of Interest — Presumptive Recusal. Given that allegations of FBI cover-up, evidence destruction, witness intimidation, and obstruction of justice are central to this legislation and among the core reasons for its enactment, a presumptive conflict of interest exists for the Department of Justice in overseeing its own compliance. Accordingly, upon enactment of this Act, a Special Master shall be automatically appointed by the United States District Court for the District of Columbia to oversee all DOJ and FBI compliance with this Act. The Attorney General is presumptively recused from all compliance decisions under this Act. The Special Master shall have authority to: (1) access all DOJ and FBI systems, files, and databases; (2) compel production of records; (3) direct DOJ personnel to perform specific searches and produce specific records; (4) report non-compliance directly to the review board and Congress; and (5) refer any person for criminal prosecution. The Attorney General may petition the review board to lift the presumptive recusal by demonstrating, by clear and convincing evidence, that DOJ personnel are not implicated in any allegation covered by this Act. The review board, not the Attorney General, shall have final authority to certify completeness of DOJ disclosure.

Section 11: Independent Oversight

(a) Establishment and Appointment. An independent review board of 5 members shall be established within 30 days of enactment to verify completeness of disclosures. Members shall be appointed as follows: 2 members shall be appointed from outside government — specifically, attorneys, journalists, or citizen investigators with demonstrated expertise in government accountability — by the Comptroller General of the United States (head of the Government Accountability Office); 1 member by the Speaker of the House of Representatives; 1 member by the Senate Majority Leader; and 1 member by the Senate Minority Leader. At least 3 of the 5 members shall be from outside government. Members shall have demonstrated expertise in law, forensic investigation, intelligence oversight, or government accountability. Members shall serve for terms of 4 years and may be removed only for cause. A quorum of 3 members is required for official action. The board's functions are advisory, investigatory, and reporting in nature. The President shall have no role in appointing, confirming, or removing board members. Each Designated Trusted Investigator under Law 4 shall have observer status on the review board with the right to attend meetings, review materials, and refer matters for enforcement action.

(b) The review board shall:

1. Have full access to agency systems and files to verify compliance
2. Have authority to compel production of additional records
3. Have subpoena power, including over private entities holding records described in Schedule A
4. Report to Congress monthly on compliance status
5. Publish public reports on its findings
6. Have authority to direct covered agencies to pursue specific investigative leads or records production that the board determines have been neglected

(c) The review board shall be permanent and shall continue to operate until it certifies that full compliance has been achieved.

(c-1) Authority to Compel Testimony of Foreign Nationals. The review board and any investigation team operating under companion legislation (the Charlie Kirk Mandatory Investigation Act or the Charlie Kirk Trusted Investigators Act) shall have authority to issue subpoenas to any person physically present in the United States, regardless of citizenship or immigration status. For persons claiming diplomatic immunity, the Secretary of State shall request a waiver of immunity from the sending state within 14 days of written request. If the sending state refuses the waiver, the Secretary of State shall publicly report the refusal to Congress within 7 days.

(d) Board members may not have been employed by any covered agency within the preceding 10 years.

(e) Public Contact Information. Within 14 days of the review board's establishment, the board shall publish and maintain the following public contact channels to allow any member of the public, any witness, any whistleblower, or any person with relevant information to communicate directly with the review board:

1. A publicly accessible email address, hosted on a .gov domain independent of any covered agency, prominently displayed on the review board's public website
2. A physical mailing address for submission of documents and evidence
3. A toll-free telephone hotline staffed during business hours, with voicemail available 24 hours
4. A secure online submission portal with end-to-end encryption for sensitive documents and tips
5. For persons holding active security clearances who wish to submit classified information, the review board shall maintain at least one classified communication channel at an appropriate classification level, accessible through a Sensitive Compartmented Information Facility (SCIF) maintained independently of any covered agency. The existence and access procedures for classified channels shall be published on the review board's public website without revealing technical details that would compromise security.

The review board shall acknowledge receipt of all submissions within 7 days. No covered agency may monitor, intercept, or access communications sent to the review board through any of these channels. Interference with public communications to the review board constitutes obstruction under Section 10(a).

(f) Special Master. Upon a finding of non-compliance by any covered agency, any federal district court may appoint a Special Master with authority to: (1) access agency systems, databases, and physical storage facilities; (2) compel production of specific records; (3) report directly to the court and the review board; and (4) be funded by the non-compliant agency's budget. The review board may petition any federal court for appointment of a Special Master without demonstrating individual standing.

Section 12: Private Right of Action

(a) Any citizen of the United States may bring an action in the United States District Court for the District of Columbia to compel compliance with this Act, provided that: (1) the citizen has provided 60 days' written notice to the non-compliant agency and the Attorney General specifying the alleged non-compliance; (2) the 30-day disclosure deadline under Section 2 has passed; and (3) the alleged non-compliance has not been fully remedied during the notice period. The injury cognizable under this section is the denial of the statutory right to receive covered records disclosed under this Act.

(a-1) Emergency Injunction for Imminent Evidence Destruction. Notwithstanding the 14-day notice requirement of subsection (a), any citizen may file an emergency action without prior notice when the citizen has a reasonable basis to believe that covered records are being destroyed, concealed, altered, or transferred in a manner that would frustrate the purposes of this Act. The court shall hold a hearing within 48 hours of filing and may issue a temporary restraining order or preliminary injunction to preserve records without bond. The standard for such emergency relief shall be a showing that: (1) there is a reasonable basis to believe evidence destruction or concealment is imminent or ongoing; and (2) the records at issue are or may be covered records under this Act.

(b) Prevailing plaintiffs shall be entitled to reasonable attorney's fees and costs.

(c) Courts shall apply a presumption in favor of disclosure in any proceeding under this Act.

(d) Courts may dismiss claims that are frivolous or filed in bad faith, with sanctions available under Federal Rule of Civil Procedure 11.

Section 13: Report to Congress

(a) Not later than 15 days after completion of the release required under Section 2, the Attorney General shall submit to the Committee on the Judiciary of the House of Representatives and the Committee on the Judiciary of the Senate a report containing:

1. All categories of records released and withheld
2. A summary of redactions made, including the legal basis for each
3. A list of all government officials and politically exposed persons named or referenced in the released materials, with no redactions permitted
4. Certification that all items enumerated in Schedule A have been fully addressed, with specific response to each of the 227 items

Section 14: No Presidential Override

(a) Congressional Finding of Compelling Interest. Congress finds that the compelling public interest in disclosure of covered records, as established in Section 1, overcomes any claim of executive privilege with respect to such records.

(b) The President may not order, direct, or authorize the continued withholding, delay, or suppression of any covered record beyond the statutory deadline established in Section 2. No classification decision, executive order, presidential memorandum, or other presidential directive may override the disclosure requirements of this Act.

(c) Any assertion of executive privilege over a covered record shall be submitted to the independent review board and reviewed by a federal court within 14 days. There shall be a presumption against privilege. The burden of proof shall be on the asserting party to demonstrate by clear and convincing evidence that disclosure would cause grave and imminent harm to an identified national security interest that outweighs the public interest in disclosure.

(d) No executive order, presidential memorandum, or other presidential directive may suspend or override the requirements of this Act. Any presidential delay of disclosure under subsection (c) shall not exceed 30 days beyond the statutory deadline without court approval.

(e) Prohibition on Coordinated Suppression. No person — including but not limited to White House staff, National Security Council personnel, the White House Counsel, the President's personal attorney, any presidential subordinate or designee, any congressional staff member, or any person acting at the direction of any of the foregoing — may coordinate, direct, suggest, or facilitate the withholding, delay, or suppression of records across agencies. Any person who coordinates or attempts to coordinate cross-agency withholding of records required under this Act commits a federal crime punishable under the obstruction provisions of this Act.

Section 15: State and Local Cooperation

(a) Any state or local law enforcement agency that has received federal funding of any kind and possesses covered records shall produce such records within 30 days. Non-compliance shall result in suspension of 25% of ALL federal funding to the non-compliant state or local agency — including but not limited to Edward Byrne Memorial Justice Assistance Grants (Byrne JAG), Community Oriented Policing Services (COPS) grants, Department of Homeland Security grants, Department of Education grants, Department of Transportation grants, and any other federal grants, contracts, or cooperative agreements. Any state or local official who willfully obstructs, delays, or prevents disclosure of covered records under this Act shall be subject to individual criminal liability, including imprisonment of up to 5 years and a fine of up to $250,000 per offense. State sovereign immunity and qualified immunity shall not be defenses to criminal prosecution under this subsection.

(b) The Attorney General shall notify all state and local agencies of their obligations under this Act within 7 days of enactment, specifying which grants are subject to suspension for non-compliance.

(c) Before any grant suspension takes effect, the non-compliant state or local agency shall receive 30 days' written notice identifying the specific non-compliance and shall be afforded a 30-day cure period in which to produce the covered records.

Section 16: Foreign Government Records and Diplomatic Channels

(a) Mutual Legal Assistance Treaty Requests. Within 15 days of enactment, the Secretary of State shall invoke all applicable Mutual Legal Assistance Treaties (MLATs) with any foreign government identified as possessing relevant records, including but not limited to the Arab Republic of Egypt and the French Republic, to obtain all records in the possession of those governments related to the death of Charlie Kirk, including records of their intelligence services, military personnel, diplomatic communications, and any information regarding the activities of their nationals in the United States during the period July 1, 2025 through November 30, 2025.

(b) Interpol Channels. Within 15 days of enactment, the Attorney General shall submit formal requests through Interpol channels for all records held by foreign law enforcement agencies related to the death of Charlie Kirk and all persons listed in Schedule B.

(c) Disclosure of Prior Diplomatic Communications. Each covered agency, the Department of State, and the Office of the Director of National Intelligence shall disclose all prior diplomatic communications, intelligence sharing, and liaison activity regarding the Charlie Kirk investigation conducted before the date of enactment.

(d) Public Reporting of Foreign Non-Cooperation. If any foreign government refuses to cooperate with requests made under subsections (a) or (b), or fails to respond within 60 days, the Secretary of State shall publicly report such refusal or non-response, including: (1) the specific records requested; (2) the foreign government's stated reason for refusal, if any; and (3) any diplomatic consequences proposed or imposed.

(e) Classification Prohibition for Foreign Government Records. For the avoidance of doubt, the automatic declassification provision of Section 6(f) applies with full force to all records obtained from or relating to foreign governments under this section. No covered record obtained through MLAT requests, Interpol channels, diplomatic communications, or any other foreign government interaction may be classified, reclassified, or withheld on the basis of classification after enactment of this Act. See Section 6(f) for the complete declassification framework.

(f) No Diplomatic Immunity for Evidence. No claim of diplomatic immunity, sovereign immunity, act-of-state doctrine, or any other immunity recognized under international or domestic law may be used to withhold records from the review board, from any investigation team, or from any Designated Trusted Investigator. Any person claiming diplomatic immunity to avoid producing covered records shall be reported to Congress by the Secretary of State within 7 days, and such refusal shall trigger automatic congressional review of all aid and intelligence-sharing agreements with the claiming government.

Section 17: Interim Disclosure Milestones

(a) The 30-day disclosure timeline established in Section 2 shall include the following interim milestones, compliance with which shall be monitored by the review board:

1. Within 7 days of enactment: Each covered agency shall produce a complete index of all identified covered records, including estimated page counts, format, classification level, and the agency division or office in possession of each record.
2. Within 14 days of enactment: Each covered agency shall produce all covered records already in digital format, including electronic documents, emails, databases, and digital media.
3. Within 21 days of enactment: Each covered agency shall produce all remaining covered records, including scanned copies of physical documents.
4. Within 30 days of enactment: Each covered agency shall certify completeness of disclosure as required by Section 2(c).

(b) Failure to meet any interim milestone shall trigger immediate reporting by the review board to Congress, identifying the non-compliant agency, the scope of non-compliance, and recommended corrective action.

(c) No covered agency may use the interim milestone structure to delay production of records that are readily available before the applicable milestone date.

(d) Failure to meet any interim milestone shall also trigger the escalating weekly budget reductions under Section 10(b-1) for the non-compliant agency.

(e) Physical Impossibility Claims. Any agency claiming the 30-day deadline is physically impossible must file a detailed declaration with the review board within 7 days of enactment specifying the exact logistical barriers and must accept independent technical assistance to meet the deadline. The 30-day deadline applies to production, not review — agencies shall produce first, and review may continue after production. No physical impossibility claim may excuse partial compliance; all records in digital format shall be produced within 14 days regardless of any claimed impossibility for physical records.

Section 18: Pending Criminal Prosecution

(a) Acknowledgment of Pending Case. Congress acknowledges the pending criminal prosecution in State of Utah v. Tyler Alexander Robinson (Case No. 251403576, Fourth Judicial District Court, Utah County).

(b) No Determination of Fact. Nothing in this Act, and no disclosure made pursuant to this Act, shall constitute a determination, finding, or implication regarding any fact at issue in the criminal case, the guilt or innocence of any defendant, or the credibility of any witness.

(c) Fair Trial Protection. If the trial court in the Robinson prosecution determines, upon motion by any party and after an evidentiary hearing, that specific covered records would irreparably prejudice the defendant's constitutional right to a fair trial, those records may be produced under seal to the review board and to defense counsel, with public release deferred until after the conclusion of the criminal case (including all appeals). This exception:

1. Applies only to records for which the trial court makes a specific, individualized finding of irreparable prejudice
2. Does not permit blanket sealing of categories of records
3. Expires automatically upon conclusion of the criminal case, at which point all sealed records shall be publicly released within 14 days
4. Does not affect the obligation of covered agencies to produce all records to the review board and defense counsel within the timelines established by this Act

(d) Brady Rights Override. The disclosure mandates of this Act serve the defendant's constitutional rights under Brady v. Maryland. Any claim by DOJ that disclosure would harm the prosecution is to be decided by the review board, not by DOJ.

Section 19: Technical Specifications for Public Disclosure Format

(a) Wherever this Act requires records to be made publicly available in a searchable and downloadable format, the following specifications shall apply:

1. Text-searchable format. All documents shall be produced as text-searchable PDF files or in their original digital format (including native spreadsheet, email, database, and multimedia formats). Scanned images of documents without embedded text are not compliant.
2. Optical Character Recognition (OCR). All scanned documents shall be processed with optical character recognition technology to produce machine-readable text.
3. Public website. All disclosed records shall be hosted on a publicly accessible website operated by the review board, requiring no user login, account creation, or payment to access.
4. Bulk download. The website shall provide bulk download capability allowing users to download all disclosed records or any subset thereof in a single operation.
5. Machine-readable index. The review board shall maintain and publish a machine-readable index of all disclosed documents in a standard format (CSV, JSON, or XML), including for each document: a unique identifier, title or description, originating agency, date, classification status, and Schedule A item number(s) to which the document is responsive.

Section 20: Statute of Limitations for Criminal Penalties

(a) No prosecution under this Act shall be barred by the passage of time. The statute of limitations for any offense under this Act shall be 45 years from the date the offense is discovered by the review board, Congress, or any law enforcement authority.

(b) For purposes of this section, an offense is "discovered" when sufficient facts are known to establish probable cause, regardless of when the underlying conduct occurred.

Section 21: Relationship to Companion Legislation

(a) Companion Statutes. This Act is part of a series of four companion statutes addressing the death of Charlie Kirk:

1. This Act (Law 1): the Charlie Kirk Files Forced Disclosure Act — Law Enforcement, requiring law enforcement agencies to disclose all records.
2. Law 2: the Charlie Kirk Intelligence Services Disclosure Act, requiring U.S. Intelligence Community agencies to disclose all records.
3. Law 3: the Charlie Kirk Mandatory Investigation Act, requiring the FBI and intelligence community to conduct a thorough investigation of all 227 Schedule A items.
4. Law 4: the Charlie Kirk Trusted Investigators Act, establishing independent investigation teams led by Designated Trusted Investigators with full access to agency records and systems.

(b) Independent and Standalone Operation. This Act shall be fully operative and enforceable regardless of whether any companion legislation — including the Charlie Kirk Files Forced Disclosure Act — Intelligence Services (Law 2), the Charlie Kirk Mandatory Investigation Act (Law 3), or the Charlie Kirk Trusted Investigators Act (Law 4) — is enacted. All obligations, penalties, and enforcement mechanisms in this Act are fully operative as standalone provisions. No court, agency, or official may delay, suspend, or refuse compliance with this Act on the ground that companion legislation has not been enacted or is pending.

(c) Consistent Definitions. Where this Act and any companion statute define the same term, the definitions shall be construed consistently. In the event of conflict, the broader definition shall apply.

(d) Designated Trusted Investigator. As used in this Act, "Designated Trusted Investigator" means an investigator designated under the Charlie Kirk Trusted Investigators Act (Law 4), if enacted; or, if such Act has not been enacted, any independent investigator appointed by the review board established under Section 11 of this Act to fulfill comparable oversight functions.

Section 22: Agency Bad Faith and Adverse Inference

(a) In any judicial, congressional, or administrative proceeding under this Act or any other law, the destruction, loss, alteration, or concealment of covered records by a covered agency shall create a rebuttable presumption that the destroyed, lost, altered, or concealed records contained information adverse to the agency's position and favorable to full disclosure.

(b) This presumption applies regardless of whether the destruction, loss, alteration, or concealment occurred before or after enactment, and regardless of whether it was intentional or negligent.

(c) A covered agency may rebut the presumption only by demonstrating, by clear and convincing evidence, that: (1) the loss was genuinely accidental; (2) the agency took all reasonable preservation measures; and (3) the agency promptly reported the loss and cooperated fully in reconstructing the records.

Section 23: Enforcement for Forensic Audits

(a) The refusal by any covered agency or official to permit, facilitate, or complete a forensic audit required by Section 8(c) of this Act shall constitute obstruction under the criminal penalty provisions of Section 10(a).

(b) Any person who interferes with, obstructs, or delays a forensic audit, including by denying auditors access to systems, altering audit logs, or providing false information to auditors, shall be subject to imprisonment of up to 10 years.

(c) The review board may direct forensic audits at any time and of any covered agency system, and may retain independent forensic auditors funded by the non-compliant agency's budget.

Section 24: Anti-Delay Litigation

(a) Expedited Constitutional Review. Any constitutional challenge to this Act shall be heard by a three-judge panel of the United States Court of Appeals for the District of Columbia Circuit, convened within 30 days of filing. The panel shall issue its decision within 60 days of oral argument. Appeal shall lie directly to the Supreme Court of the United States.

(b) No Nationwide Injunctions. No single district court judge may issue a nationwide injunction suspending the operation of this Act. Only the three-judge D.C. Circuit panel described in subsection (a) may enjoin the operation of this Act, and only upon a finding that the challenged provision is facially unconstitutional by clear and convincing evidence.

(c) Prospective-Only Injunctions. Any injunction issued under this section shall operate prospectively only and shall not require the return, re-classification, or withdrawal of any records already disclosed pursuant to this Act. Once a covered record has been publicly released under this Act, it shall remain publicly available regardless of any subsequent judicial order.

Section 25: Gag Order Override and Federal Supremacy

(a) Federal Supremacy Over Conflicting Court Orders. No judicial order — including state court gag orders, protective orders, or sealing orders — shall prohibit, restrict, or delay the disclosure of covered records to the review board, investigation teams established under companion legislation, Designated Trusted Investigators, or Congress under this Act. This Act, enacted pursuant to Congress's Article I powers, preempts any conflicting state or federal court order to the extent such order would prevent disclosure required by this Act.

(b) Any person who withholds covered records by claiming compliance with a conflicting court order shall not be excused from the penalties of this Act. The proper course is to seek modification of the conflicting order, not to violate this Act.

Section 26: Brady v. Maryland Statutory Codification

(a) Statutory Brady Obligation. The FBI, all covered agencies, and all persons acting on their behalf are hereby established as custodial agencies with respect to all exculpatory, impeachment, and mitigating evidence in the case of State of Utah v. Tyler Alexander Robinson (Case No. 251403576, Fourth Judicial District Court, Utah County). All such agencies and persons have a statutory obligation, enforceable under this Act, to disclose all material that is favorable to the defense — including exculpatory evidence, impeachment evidence, and mitigating evidence — to defense counsel in the Robinson case.

(b) 5-Day Disclosure Requirement. Any covered agency that discovers or comes into possession of information favorable to the defense in the Robinson case shall disclose such information to defense counsel within 5 days of discovery. Failure to comply with this requirement shall constitute a violation of this Act and shall be subject to all penalties under Section 10.

(c) Codification of Brady v. Maryland. This section codifies and extends the constitutional obligation established in Brady v. Maryland, 373 U.S. 83 (1963), and its progeny, to all federal agencies acting as custodial parties in the Robinson prosecution. The Brady obligation under this section is not limited to the prosecuting attorney but extends to every covered agency in possession of potentially exculpatory material.

(d) Brady Compliance Officer. Each covered agency shall designate a Brady compliance officer who reviews all records produced under this Act for exculpatory material relevant to the defense of Tyler Robinson in State of Utah v. Tyler Alexander Robinson (Case No. 251403576, Fourth Judicial District Court, Utah County). Any exculpatory material shall be produced to Robinson's defense counsel within 5 days of identification.

Section 27: Mandatory Appropriations and Funding Protection

(a) Mandatory Appropriation. There is hereby appropriated, out of any money in the Treasury not otherwise appropriated, $10,000,000 annually for the operations of the independent review board established under Section 11, including staff, forensic auditors, legal counsel, and administrative costs. This appropriation is mandatory and self-executing — it does not require inclusion in any annual appropriations bill, continuing resolution, or omnibus spending bill. The account shall be established at the United States Treasury within 14 days of enactment. The host agency's Chief Financial Officer shall have no access to or authority over the account.

(b) Agency Compliance Funding. There is hereby appropriated such sums as may be necessary for covered agencies to comply with the disclosure requirements of this Act.

(c) Immediate Availability. Funds appropriated under this section shall be available immediately upon enactment and shall remain available until expended.

(d) Appropriations Protection. No appropriations bill, continuing resolution, or omnibus spending bill may include any provision that reduces, restricts, conditions, or eliminates funding for compliance with or enforcement of this Act. Any such provision included in any legislation shall have no force or effect with respect to the mandatory appropriations established by this section.

(e) Discharge Petition Mechanism. If the committee of jurisdiction in the House of Representatives does not report this bill within 60 calendar days of introduction, any 218 Members of the House may file a discharge petition to bring the bill directly to the floor for a vote. If the committee of jurisdiction in the Senate does not report this bill within 60 calendar days of introduction, any 30 Senators may move to discharge the committee, and the motion shall be non-debatable and decided by simple majority vote.

Section 28: Severability

If any provision of this Act, or the application thereof to any person or circumstance, is held invalid by a court of competent jurisdiction, the remainder of this Act and the application of such provision to other persons or circumstances shall not be affected thereby.

Section 29: Judicial Protections Against Suppression

(a) Jurisdiction for all challenges to this Act shall lie with a three-judge panel of the United States District Court for the District of Columbia, drawn by random lot from the pool of active district judges, not by assignment.

(b) No court may issue a stay of the disclosure requirements of this Act pending litigation. If a court finds any provision unconstitutional, the severability clause (Section 28) keeps all other provisions in force, and disclosure of non-challenged records shall proceed without interruption.

(c) All judicial proceedings under this Act shall be conducted in public session. No proceeding may be sealed absent a specific finding, supported by clear and convincing evidence, that sealing is necessary to protect a currently active human intelligence source whose life would be endangered.

(d) Any person may seek a writ of mandamus in federal court to compel compliance with this Act. Prevailing plaintiffs shall be awarded reasonable attorney's fees and costs.

(e) 60-Day Maximum Judicial Delay. There is a statutory presumption that no judicial order — including temporary restraining orders, preliminary injunctions, stays pending appeal, or any other form of judicial relief — may delay the disclosure of any covered record for more than 60 days total from the date of enactment. Any judicial proceeding that has not been fully resolved within 60 days of enactment shall not prevent disclosure from proceeding. The burden is on the party seeking continued delay to demonstrate, by clear and convincing evidence, that immediate disclosure would create an imminent threat to the physical safety of an identified individual. Generalized claims of national security, diplomatic embarrassment, or institutional harm do not satisfy this standard.

Section 30: Self-Executing Enforcement and Entrenchment

(a) Self-Executing Mechanisms. Every enforcement mechanism in this Act — including budget reductions, criminal referrals, and adverse inferences — is self-executing and requires no additional congressional action, appropriations rider, executive branch approval, or judicial order to take effect.

(b) Independent Prosecution Authority. Upon a finding of non-compliance by the review board, a Special Counsel shall be automatically appointed by the Chief Judge of the United States District Court for the District of Columbia to investigate and prosecute violations of this Act. The Special Counsel shall have full prosecutorial authority independent of the Department of Justice. Any Designated Trusted Investigator under Law 4 may refer matters directly to the Special Counsel.

(c) Qui Tam Actions. Any citizen may bring a qui tam action under this Act against any person or agency that has violated the disclosure requirements. Successful qui tam plaintiffs shall be entitled to treble damages and 25% of any fine or budget reduction imposed as a result of the action.

(d) Structural Funding Defense. The enforcement provisions of this Act (Sections 7, 8, 9, 12L, and 12M) are funded through mandatory appropriations under Section 27 that do not require annual reauthorization. Any legislation that would amend, repeal, or weaken any enforcement provision of this Act shall require a two-thirds supermajority vote in both chambers of Congress. Congress declares its intent that the mandatory funding established by this Act shall continue for a minimum of 10 years from the date of enactment.

Section 31: Personal Liability of Agency Heads

(a) Personal Responsibility. The head of each covered agency is personally responsible for that agency's compliance with this Act. Delegation of compliance duties to subordinates does not relieve the agency head of personal liability for non-compliance.

(b) Rebuttable Presumption of Willful Obstruction. If a covered agency fails to achieve substantial compliance with the disclosure requirements of this Act within 30 days of enactment, the agency head shall be presumed to have willfully obstructed compliance. The agency head may rebut this presumption only by demonstrating, by clear and convincing evidence, that: (1) the agency head took specific, documented, affirmative steps to ensure compliance; (2) the agency head personally directed the production of all covered records known to the agency; and (3) the failure was due to circumstances genuinely beyond the agency head's control despite good-faith efforts.

(c) Referral for Prosecution. The review board established under Section 11 may refer any agency head to the Department of Justice for criminal prosecution under Section 10(a) without requiring proof of the agency head's specific knowledge of specific withheld records. The rebuttable presumption established in subsection (b) shall apply in any such prosecution. If the Department of Justice declines prosecution within 60 days of referral, the review board may appoint independent counsel to prosecute.

(d) Liability Survives Resignation or Removal. An agency head who resigns, retires, or is removed from office before full compliance is achieved remains subject to prosecution for obstruction occurring during the period of their tenure. No resignation, retirement, or removal shall moot or extinguish liability under this section.

(e) Acting Officials. Any individual serving in an acting capacity as head of a covered agency bears the same personal liability as a Senate-confirmed appointee. Rotating acting officials to avoid the 30-day compliance deadline constitutes obstruction under Section 10(a).

(f) 48-Hour Emergency Response for Evidence Destruction. Notwithstanding the 30-day compliance timeline elsewhere in this section, in any case involving active or imminent destruction of evidence, active concealment of covered records, witness intimidation, or any other exigent circumstance requiring immediate action:

1. Any member of the review board established under Section 11, any member of a congressional oversight committee, or any citizen with reasonable basis to believe that covered records are being or are about to be destroyed, concealed, or altered, may report the exigent circumstance to the review board, to Congress, or to any federal district court.
2. Upon receipt of such a report, the agency head shall have 48 hours to halt all destruction, concealment, or alteration and to preserve all records identified in the report. This 48-hour deadline is absolute and may not be extended by any official, court, or other authority.
3. Failure to comply within 48 hours triggers an immediate rebuttable presumption of willful obstruction under subsection (b), without waiting for the standard 30-day period.
4. The review board or any congressional oversight committee may immediately refer the agency head for prosecution under subsection (c) upon expiration of the 48-hour period.
5. Any federal district court may issue emergency preservation orders under this subsection and shall rule on emergency petitions within 48 hours of filing. Violation of such orders constitutes criminal contempt punishable by imprisonment of up to 5 years per violation.
6. This subsection applies to all covered agencies and to any person acting on behalf of a covered agency, regardless of rank or position.

(g) Certification Requirement. Within 30 days of enactment, each agency head shall personally certify under penalty of perjury that all covered records have been identified, preserved, and produced. A false certification constitutes perjury under 18 U.S.C. Section 1621 and obstruction under Section 10(a) of this Act.

Section 32: Effective Date

This Act shall take effect immediately upon enactment. All criminal penalties under this Act apply prospectively from the date of enactment. Records preservation requirements (Section 8) take effect upon introduction of this bill, with enforcement as provided in Section 8(b).

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Each item in Schedule A is individually mandated for complete disclosure. Partial compliance with Schedule A does not constitute compliance with this Act.

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Supplemental Definitions

The following definitions supplement and do not limit the definitions provided in Section 5 of this Act. Where a term is defined both in Section 5 and in this section, the broader definition shall control.

(a) "Investigation" means any federal, state, or local law enforcement inquiry, intelligence assessment, counterintelligence investigation, administrative review, congressional inquiry, inspector general review, or any other official or unofficial examination of facts, circumstances, evidence, or allegations related to the death of Charlie Kirk, including but not limited to: the criminal prosecution in State of Utah v. Tyler Alexander Robinson (Case No. 251403576, Fourth Judicial District Court, Utah County); any parallel federal investigation; any intelligence community assessment; any congressional committee inquiry; any review by the independent review board established under Section 11; any investigation by Designated Trusted Investigators; and any citizen investigation or journalistic inquiry that has produced information relevant to understanding the circumstances of Charlie Kirk's death.

(b) "Death of Charlie Kirk" means the killing of Charles J. Kirk on September 10, 2025, at Utah Valley University, Orem, Utah, and all events, circumstances, planning, coordination, communications, meetings, financial transactions, intelligence operations, and actions related thereto — whether occurring before, during, or after September 10, 2025, and whether occurring within or outside the United States.

(c) "Disclosure body" means the independent review board established under Section 11 of this Act, including any Special Master appointed pursuant to Section 11(f), and any successor body established by Congress to carry out the disclosure and oversight functions of this Act.

(d) "People Involved" or "People Listed" means the categories of persons defined in Schedule B of this Act, encompassing all 35 categories (P1 through P35) of persons with potential knowledge of, involvement in, proximity to, or information about matters addressed by this Act. This definition shall be construed as broadly as possible to ensure that no person with relevant information is excluded from the disclosure requirements of this Act.

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Back to README | Human Requirements | Legal Notes | Output Analysis

Peer laws: Law 2 - US Intel Disclosure | Law 3 - Mandatory Investigation | Law 4 - Trusted Investigators

Precedent: Epstein Files Transparency Act | JFK Records Act