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Law 2: Charlie Kirk Investigation - Intelligence Services Disclosure Act

AUTHOR: Bryan Starbuck (BryanStarbuck@gmail.com)

Short Title​

This Act may be cited as the "Charlie Kirk Files Forced Disclosure Act — Intelligence Community."

Title​

The Charlie Kirk Files Forced Disclosure Act - Intelligence Services

Purpose​

To require all United States Intelligence Community agencies to release all information in their possession that could identify the perpetrator(s) of, or provide substantive insight into, the death of Charlie Kirk, including but not limited to the 227 specific disclosure items enumerated in Schedule A of this Act, while protecting only currently active intelligence sources.

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: Broad Mandatory Disclosure​

(a) Catch-All Requirement. Within 30 days of enactment, all Intelligence Community agencies shall produce and make publicly available all final output information as defined in this Act. This requirement extends to any and all intelligence products, analyses, assessments, and information that could in any way assist in understanding the circumstances of Charlie Kirk's death. This requirement is not limited to the specific items enumerated in this Act or in Schedule A.

(b) The Director of National Intelligence shall coordinate disclosure across all agencies to ensure completeness. No agency may defer to another agency's production obligations as grounds for withholding records in its own possession.

(c) Each agency head shall certify under penalty of perjury that all responsive information has been identified, located, and disclosed.

(d) Each agency shall conduct a comprehensive search of all intelligence databases, file systems, cable archives, and classified storage systems, and shall submit to the congressional intelligence committees a classified declaration describing the scope and methodology of the search.

(e) Compulsory Process for Private Entity Records. Within 15 days of enactment, each Intelligence Community agency shall coordinate with law enforcement agencies to issue subpoenas, National Security Letters, or other compulsory process for all intelligence-related records described in Schedule A that are held by private entities. The review board established under Section 17 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 12.

Section 2: Interim Disclosure Milestones​

(a) In addition to the 30-day final disclosure deadline under Section 1, each covered agency shall meet the following interim milestones:

  1. 7 days after enactment: Each covered agency shall produce to the review board and publish a comprehensive index of all records in its possession, custody, or control that are or may be responsive to this Act, including the classification level, format, volume, and storage location of each category of records
  2. 14 days after enactment: Each covered agency shall produce all records that exist in digital format, including electronic databases, email archives, cable traffic, and digitized documents
  3. 21 days after enactment: Each covered agency shall produce all remaining records, including physical files, paper records, and any records requiring format conversion
  4. 30 days after enactment: Each agency head shall certify under penalty of perjury that all responsive records have been identified, produced, and made publicly available, and that no responsive records have been withheld, destroyed, or concealed

(b) The review board shall monitor compliance with each interim milestone and shall report any failure to Congress within 48 hours of a missed milestone.

(c) Failure to meet any interim milestone shall trigger the automatic budget reduction provisions of Section 12(d), calculated from the date of the missed milestone rather than the 30-day final deadline.

(d) The interim milestones are cumulative and do not excuse an agency from meeting the 30-day final deadline for complete production.

Section 3: Rolling 72-Hour Intelligence 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 intelligence product, analysis, assessment, report, cable, intercept, 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 intelligence product created by the agency after enactment that touches on any Schedule A subject
  2. Any intelligence received from a foreign liaison partner after enactment that relates to any Schedule A subject
  3. Any previously existing record discovered after the initial 30-day production deadline
  4. Any intelligence product generated by any analytical tool, database query, or automated system that relates to Schedule A subjects
  5. Oral briefings, which must be memorialized in writing within 24 hours of delivery
  6. Informal assessments, email analyses, and any communication containing analytical conclusions related to Schedule A subjects
  7. 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 intelligence records in the possession of a covered agency under this Act
  8. 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
  9. Any intelligence product 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)

(c) Each covered agency shall designate a compliance officer responsible for monitoring all new intelligence 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 analytical activities related to Schedule A subjects and provide it to the review board weekly.

(d) Failure to produce a newly generated intelligence product within 72 hours constitutes obstruction under Section 12. The 72-hour deadline may not be extended by classification review, legal 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 intelligence 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: Negative Certification for Non-Existent Records​

(a) Each covered agency shall file a sworn declaration listing every category in Schedule A and stating, for each category: (1) what records the agency found responsive; (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 and capabilities. A bare assertion of "no responsive records found" without explanation shall be treated as non-compliance. (b) The review board may challenge any negative certification and require demonstration under oath of search methodology. (c) Cross-reference: if another agency's records reference a record that the claiming agency denies having, the denial is per se invalid and constitutes evidence of obstruction. (d) The review board may require polygraph examinations of certifying officials where it suspects false certification.

Section 5: Prohibition on Coordinated Suppression​

(a) Each Intelligence Community agency shall make independent compliance decisions. ODNI coordination under this Act is limited to logistics — not to determining what to withhold. (b) The DNI may not issue guidance, directives, or recommendations that limit what individual agencies disclose. (c) Each agency head shall certify independently under penalty of perjury. (d) Whistleblower protections under Section 14 apply to any agency employee who reports pressure from any source to withhold records.

(e) Prohibition Extends Beyond ODNI. No person — including but not limited to the Director of National Intelligence, 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. The prohibition on presidential override in this Act extends to any presidential subordinate or designee. Any person who coordinates or attempts to coordinate cross-agency withholding of records required under this Act commits a federal crime punishable by up to 10 years imprisonment under Section 12.

(f) Anti-Circumvention. The prohibitions in this Section may not be circumvented by routing coordination through informal channels, oral communications, intermediaries, or any other mechanism designed to avoid a written record. Any agency employee who receives an oral instruction to withhold records shall memorialize the instruction in writing within 24 hours and report it to the review board and the congressional intelligence committees.

Section 6: Specific Mandatory Disclosures​

(a) In addition to the broad catch-all requirement, the following categories are specifically mandated for disclosure, cross-referencing Schedule A items:

Foreign Intelligence Service Activity in Utah (Items #2, #26, #56, #63-#67):

  1. All intelligence regarding threats, plans, or actions by any foreign intelligence service toward the assassination of Charlie Kirk
  2. All intelligence regarding foreign intelligence service activity in Utah from January 2023 to present
  3. All intelligence regarding the approximately 12 foreign-registered cell phones at UVU on September 10, 2025, including NSA tracking data, subscriber identification, and location history
  4. All intelligence regarding threats or consideration of harm to similarly situated individuals (Marjorie Taylor Greene, Matt Gaetz, Andrew Breitbart, Candace Owens, Tucker Carlson, Thomas Massie)
  5. All SIGINT, HUMINT, IMINT, and MASINT products related to foreign intelligence operations in the Utah area

Aircraft and Surveillance Operations (Items #1, #15, #50, #82-#87, #157-#161):

  1. All intelligence regarding Egyptian aircraft SU-BTT, SU-BND, SU-BTU, SU-BTV, SU-BGM, and Egyptian military aircraft T7ELL and EJM36
  2. All intelligence regarding surveillance aircraft N1098L (HADES spy plane), including who contracted, operated, and received its surveillance feed
  3. All intelligence regarding military or civilian drones operating at or near UVU on September 10, 2025
  4. All intelligence regarding U.S. Air Force VIP transport jet 99-0404 (SAM callsign) flights September 8-9, 2025
  5. All intelligence regarding any aircraft on the Schedule A plane list that flew with transponders off

Electronic Warfare and Signals (Items #11, #68-#74):

  1. All intelligence regarding electronic jamming of cell or internet signals at UVU on September 10, 2025
  2. All NSA or signals intelligence products related to communications intercepts at UVU
  3. All intelligence regarding cell tower anomalies or signal disruption in the UVU area
  4. NSA shall produce the analytical conclusions regarding the approximately 12 foreign-registered cell phones at UVU — including the identities of the phone holders, their locations, who they called, and their activities — even if the specific collection technique is protected under Section 10(b)(2). NSA shall produce any subscriber identification obtained through MLAT with foreign carriers. The existence of foreign intelligence collection capabilities that are already publicly known or widely reported shall not be grounds for withholding.

Meetings and Pre-Planning (Items #28-#31, #51, #196):

  1. All intelligence regarding meetings at Fort Huachuca, AZ (September 1-11, 2025) related to Charlie Kirk
  2. All intelligence regarding meetings at One Rodney Square, Wilmington, DE (September 1-11, 2025) related to Charlie Kirk
  3. All intelligence regarding the Hampton meeting (August 3-6, 2025) including foreign intelligence presence
  4. All intelligence regarding any pre-planning or foreknowledge of the assassination

TPUSA and Personnel (Items #3-#4, #54, #162-#167):

  1. All intelligence regarding foreign intelligence recruitment or contact with TPUSA personnel
  2. All intelligence regarding TPUSA security chief connections to foreign intelligence
  3. All intelligence regarding foreign communications with TPUSA donors within 3 months before the assassination
  4. All intelligence regarding Charlie Kirk's DOGE-equivalent audit of TPUSA financial irregularities

Psychological Operations and Handler Activity (Items #39-#42):

  1. All intelligence regarding psychological operations or manipulation of Tyler Robinson or Lance Twiggs
  2. All intelligence regarding any interactions between Tyler Robinson, Lance Twiggs, or their associates with any intelligence service
  3. All intelligence regarding communications via Discord, Steam, in-game voice chat, or encrypted messaging connected to the case

DoD Contracts and Weapons (Items related to N0016425PJ538, #192-#193, #203):

  1. All intelligence regarding DoD contract N0016425PJ538 for miniaturized anti-personnel charges
  2. All intelligence regarding the AES factory explosion (October 10, 2025)
  3. All intelligence regarding any weaponized microphone or explosive device technology
  4. All intelligence regarding DOD contracts awarded to Bilt Inc. in June 2025 totaling approximately $8 million from the U.S. Air Force, including all intelligence assessments of the contracts' purpose, the identity and background of Bilt Inc. personnel, all financial flows, and any connection to the Charlie Kirk investigation or any person listed in Schedule B (Items #223-#227)

International Communications (Items #173-#177):

  1. All communications between U.S. intelligence and any foreign intelligence service regarding the case
  2. All communications between U.S. intelligence and Egyptian intelligence regarding Egyptian aircraft or personnel
  3. All Interpol communications regarding the case
  4. All MLAT requests or responses
  5. All diplomatic or intelligence cables regarding the assassination

(b) Schedule A shall be the document titled "Charlie Kirk 227 Critical Disclosure Items" as maintained 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.

(b-1) Schedule A Unification. 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 Files Forced 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.

(c) The specific enumeration does not limit the broad catch-all requirement. Both apply concurrently.

Section 7: Mandatory NSA Targeted Database Queries​

(a) Mandatory SIGINT Queries. Within 30 days of enactment, the National Security Agency shall conduct targeted queries of XKeyscore and all comparable mass surveillance, signals intelligence, and communications intelligence tools, databases, and systems for:

  1. All persons listed in Schedule B (categories P1 through P35), using all known names, aliases, phone numbers, email addresses, and device identifiers
  2. All phone numbers and device identifiers referenced in Schedule A, including but not limited to the approximately 12 foreign-registered cell phones, all foreign roaming phones, and all phones identified through cell tower dumps
  3. All aircraft tail numbers listed in Schedule A: SU-BTT, SU-BND, SU-BTU, SU-BTV, SU-BGM, N1098L, N888KG, N59906, N560TW, N102DZ, N40JD, N872RA, 99-0404, T7ELL, EJM36, N55906, and N582MM
  4. All addresses and locations referenced in Schedule A, including Fort Huachuca AZ, One Rodney Square Wilmington DE, UVU campus, Provo Municipal Airport, and the AES facility in Nashville
  5. All financial account numbers, wire transfer identifiers, and transaction records referenced in Schedule A

(b) No "No Responsive Records" Evasion. NSA may not claim "no responsive records exist" if the responsive data exists within its databases but has not been queried. The obligation under this Section is to conduct the queries — not merely to search existing analytical products. If raw intercepts exist in NSA databases that are responsive to any Schedule A item, NSA shall produce the analytical conclusions derived from those intercepts within 30 days. If no prior analysis was conducted, NSA shall conduct the analysis and produce the results within 30 days.

(c) Query Documentation. NSA shall provide the review board with a certified declaration documenting: (1) each query conducted; (2) the database or system queried; (3) the search terms used; (4) the date range searched; (5) the volume of results; and (6) a summary of responsive results. The review board may direct NSA to conduct additional queries on terms the board identifies.

(d) Comparable Agencies. The obligations in this Section apply equally to any other Intelligence Community agency that maintains signals intelligence, communications intelligence, or electronic surveillance databases, including but not limited to the FBI's Electronic Surveillance Unit, DIA signals intelligence components, and any agency operating under Executive Order 12333 collection authorities.

Schedule A: 227 Critical Disclosure Items​

Construction Rules:

(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.

(b) "People Listed" (PEOPLE_LISTED) means the categories of persons for whom disclosure is required under this Act, as defined in Schedule B. The categories are: 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.

Table of Contents​

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

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 further produce all records related to investigating the assassination or anything peripheral, or any connection to anyone in the Charlie Kirk investigation.

  • #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 further 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 further 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 further 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. 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 further 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. 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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. 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 further 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 further 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 further 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 further 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 further 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 further 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. 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. All records establishing whether any distraction person was ever offered money or received money from any source, and all financial payments they received. All records of the question-asker's communications and coordination with any person before and after the event. Each covered agency shall further 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 further 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 further 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 further 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 further 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. 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 further 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 further 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 further 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 further 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 further 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 further 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, tail number 99-0404, or 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 further 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. 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. 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. 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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. 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 further 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. 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 further 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. 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 further 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. 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further produce all records relating to any threat pattern or coordinated targeting of public figures with similar political profiles.

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 further 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 further 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 further 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 further 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 further produce all records relating to any modification, expansion, or restriction of the investigation's scope after opening.

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 further 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 further 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 further 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 further 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 further produce all records relating to any electronic surveillance authorized by any court related to the investigation.

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 further 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 further 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 further 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 further 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 further 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 further 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 further produce all records relating to any effort to identify owners of foreign-registered devices detected at investigation-related locations.

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 further 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 further 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 further 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 further 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 further 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 further 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: All biometric captures (fingerprints, facial recognition) from the DHS Biometric Identity Management System for foreign arrivals during the relevant period. Each covered agency shall further produce all records relating to any biometric data collected from any foreign national entering Utah during 2025.

Egyptian Planes (#82–#87)​

  • #82: Egyptian Plane SU-BTT Flight Records: 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 further 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: All flight records for Egyptian plane SU-BND, including transponder activation records around September 15, 2025. Each covered agency shall further 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: All passenger manifests and crew lists for SU-BTT, including names of all 4–6 military contractors who deplaned. Each covered agency shall further 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 further 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 further 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 further produce all records relating to any ground transportation, lodging, or movement by Egyptian nationals who arrived on the listed aircraft.

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 further 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 further 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: All call detail records for the Israeli phones, showing all calls and texts to and from Utah numbers. Each covered agency shall further 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 further 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 further produce all records relating to any FBI request to or response from Israeli government entities about the case.

Provo Airport (#93–#98)​

  • #93: Airport Badge Access Logs: 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 further 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 further 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 further 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 further 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 further 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 further produce all records relating to any non-standard security screening or access granted to any person at PVU during 2025.

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 further 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 further 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 further 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 further 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 further 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 further 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 further produce all records relating to any FBI financial investigation, FinCEN query, or bank subpoena related to the Charlie Kirk investigation.

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. 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. 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 further 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 further 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 further 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: Each covered agency shall produce the names and reports of the FBI agents who directed the re-search that located the weapon. Each covered agency shall further 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 further 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 further 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 further 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 further produce all records relating to any internal review, complaint, or investigation regarding the handling of physical evidence in this case.

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 further 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 further 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 further 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 further 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 further produce all records relating to any FBI interview with any public figure about threats connected to the Charlie Kirk case.

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 further 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 further 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 further 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 further 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: All ATM camera footage from banks in Utah County from August 25 through September 15, 2025. Each covered agency shall further 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 further produce all records relating to any LPR data in Utah showing vehicles connected to the investigation during August–October 2025.

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 further 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 further 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 further 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 further 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 further 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 further 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 further produce 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 further 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.

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 further 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 further 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 further 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 further 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 further produce all records relating to any hotel facility usage by persons connected to the investigation that could indicate operational planning or communications.

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 further 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 further 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 further 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 further 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 further 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 further produce all records relating to any network activity, device connections, or data transmissions at UVU during the incident.

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 further 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 further 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 further 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 further 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 further 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 further 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 further produce all records relating to any similarity between evidence in this case and methods used by any foreign intelligence service.

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 further 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 further 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 further 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 further 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 further produce all records relating to any phone activity by persons of interest at UVU on September 10, 2025.

  • #155: UVU Attendee Travel Records: All airline and CBP records of recent international travel by UVU attendees. Each covered agency shall further 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 further produce all records relating to any social media activity by persons at UVU suggesting foreign intelligence contact or operational coordination.

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 further 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 further 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 further 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 further 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 further produce all records relating to any person or entity that contracted aerial surveillance in the Utah County area during September 2025.

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 further 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 further 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 further 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 further 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 further 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 further produce all records relating to any foreign intelligence activity, influence, or presence at any TPUSA donor or leadership meeting during 2025.

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. 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 further 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 further 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: All medical examiner toxicology reports, anomaly reports, and any unusual findings from the Utah Office of Medical Examiner. All records establishing whether Charlie Kirk's heart stopped before his neck wound occurred. 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. 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 further 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 further 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 further produce all records relating to any analysis establishing the exact timeline of the fatal event and Kirk's death.

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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further 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 further produce all 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). 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 further 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.

Mosaic Pro Events / AV Equipment (#189–#191)​

  • #189: 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 further produce all contracts, work orders, and communications between Mosaic Pro Events and TPUSA regarding the UVU event.

  • #190: 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 further 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.

  • #191: Mikey McCoy's Mic-Up Video: Each covered agency shall produce the close-up video filmed by Mikey McCoy showing Charlie Kirk being mic'd up before the event. Each covered agency shall further 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 (#192–#193)​

  • #192: 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. 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 further produce all of Butch Hibbs's communications in the 60 days before and 30 days after the assassination.

  • #193: 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 further 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 (#194–#195)​

  • #194: 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 further 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.

  • #195: 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 further 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 (#196)​

  • #196: 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 further 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 (#197)​

  • #197: 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 further 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 (#198–#200)​

  • #198: 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 further 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).

  • #199: 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 further 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.

  • #200: 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 (#201)​

  • #201: 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. 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 further produce all chain-of-custody records for these casings from discovery through current storage.

Crime Scene Paving (#202)​

  • #202: 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. 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 further produce all communications between UVU administration and any government agency regarding the crime scene.

AES Factory Explosion (#203)​

  • #203: 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 further 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 (#204–#207)​

  • #204: 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 further produce 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. 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 further produce all records relating to Tyler Robinson's movements for the 30 days prior to the shooting.

  • #205: 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 further 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 further produce any investigation into whether Robinson conducted reconnaissance or scouting visits to the campus, and whether any other person accompanied him on any prior visit.

  • #206: 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. 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 further produce all records relating to whether any person other than Robinson was on the rooftop at the time of the shot.

  • #207: Rooftop Suspect Movement at Moment of Shot: 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. All surveillance camera angles, drone footage, aerial footage, and any other visual evidence capturing the rooftop at the time of the shooting. 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 further 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 (#208–#209)​

  • #208: 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. 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.

  • #209: 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. 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.

MASINT & Satellite Intelligence (#210–#211)​

  • #210: MASINT Products for UVU Area: Each covered agency shall produce all Measurement and Signature Intelligence (MASINT) products related to the Utah Valley University campus and surrounding areas for the period September 1-30, 2025, including explosive residue signatures, acoustic signatures, seismic data, chemical detection, nuclear/radiological signatures, and any other MASINT collection modality. Each covered agency shall further produce all MASINT data from any sensor, platform, or collection system that was operating in or monitoring the Provo/Orem area during September 2025.

  • #211: Satellite Imagery of Key Locations: Each covered agency shall produce all NRO and NGA satellite imagery of UVU campus for September 9-11, 2025; Provo Municipal Airport for August 25-September 15, 2025; all flight paths of aircraft identified in Schedule A; Fort Huachuca, Arizona area for August-September 2025; and AES facility in Nashville, Tennessee for September-October 2025. Each covered agency shall further produce all satellite imagery, electro-optical imagery, synthetic aperture radar imagery, and any other overhead collection of any location referenced in Schedule A during the relevant time periods.

Foreign Digital Surveillance (#212)​

  • #212: Israeli IP Surveillance Targeting Records: Each covered agency shall produce all NSA, CIA, or any Intelligence Community records 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 systematically searching for Timpanogos Hospital surgeons, medical examiner, defense counsel, crime scene contractors, and hospital CEO Andrew Zenger. Each covered agency shall further produce all records of any foreign government or foreign intelligence service conducting digital reconnaissance, IP-based surveillance, or electronic targeting of any person connected to the Charlie Kirk investigation.

AES Explosion Intelligence (#213)​

  • #213: AES Factory Explosion Intelligence Assessment: Each covered agency shall produce all Intelligence Community assessments, analyses, or reports evaluating whether the AES factory explosion on October 10, 2025 in Nashville, Tennessee was deliberately caused, including any assessment of whether it was intended to destroy evidence connected to the Charlie Kirk case or DoD contract N0016425PJ538. Each covered agency shall further produce all intelligence products, threat assessments, or analytical conclusions regarding the cause, timing, and purpose of the AES explosion, including any connection to the 16 employees killed and their knowledge of the miniaturized anti-personnel charges contract.

State Official Communications (#214)​

  • #214: State Official Federal Agency Communications: Each covered agency shall produce all Intelligence Community records of communications between Utah state officials and any federal agency or intelligence element regarding the Charlie Kirk investigation, prosecution, or judicial orders. Each covered agency shall further produce all records of any communication between any state government official — including but not limited to Governor Spencer Cox, the Utah Attorney General, Utah County Attorney Jeffrey S. Gray, and any state judge — and any Intelligence Community agency, FBI intelligence division, or other federal entity regarding any aspect of the Charlie Kirk case.

Hospital Compromise (#215)​

  • #215: Hospital Intelligence Service Contact Records: Each covered agency shall produce all Intelligence Community records relating to whether Timpanogos Regional Hospital, its medical personnel, or CEO Andrew Zenger was subject to intelligence service contact, direction, influence, or pre-planned placement of personnel in connection with the Charlie Kirk case. Each covered agency shall further produce all records of any intelligence service — foreign or domestic — approaching, directing, pressuring, or placing personnel at any medical facility involved in the treatment, transport, or post-mortem examination of Charlie Kirk.

Hospital Bomb Threat and Diversion (#216)​

  • #216: Hospital Bomb Threat Intelligence Assessment: Each covered agency shall produce all Intelligence Community records, assessments, and analyses 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 intelligence products assessing whether the bomb threat was coordinated with the assassination to divert Charlie Kirk away from the closer hospital to a controlled facility, all signals intelligence or communications intelligence related to the bomb threat caller, and all records of any intelligence service — foreign or domestic — involvement in creating, directing, or coordinating the hospital bomb threat.

Carbyne 911 System Intelligence Access (#217)​

  • #217: Carbyne 911 System Foreign Intelligence Access: Each covered agency shall produce all Intelligence Community records, assessments, and analyses 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 intelligence assessments of foreign intelligence access to Carbyne 911 data for the Provo/Orem area on September 10, 2025. Each covered agency shall produce all intelligence products identifying data transmissions from the Carbyne system to any foreign server, all assessments of whether any foreign intelligence service had real-time access to 911 calls and first responder communications through the Carbyne system, and all records of any U.S. Intelligence Community awareness of or concern about foreign intelligence exploitation of the Carbyne 911 platform.

Independent Ballistics and Forensic Testing Authority (#218)​

  • #218: Independent Ballistics and Forensic Testing: The review board established under Section 17 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 intelligence-related 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 (#219)​

  • #219: 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 further produce all intelligence assessments or products analyzing the movements of this aircraft in connection with TPUSA operations, the assassination, or the Fort Huachuca meetings.

Egyptian Aircraft Return to Provo (#220)​

  • #220: Egyptian Aircraft Return to Provo in 2026: Each covered agency shall produce all intelligence records, assessments, and analyses 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 intelligence products identifying passengers, cargo, and purpose of travel; (2) any intelligence assessments of the correlation between Egyptian aircraft arrivals in Utah and French diplomatic visits to the United States, including Brigitte Macron's March 2026 visit to Washington D.C.; (3) all signals intelligence, imagery intelligence, or other intelligence products related to Egyptian military aircraft movements to the United States during 2025–2026; (4) all intelligence assessments of the operational significance of repeated Egyptian military aircraft visits to Provo; and (5) all records of any intelligence service — foreign or domestic — awareness of, interest in, or monitoring of these flights. Each covered agency shall further produce all intelligence products analyzing any pattern of coordinated movement between Egyptian aircraft and French diplomatic travel.

TPUSA Employee and Contractor Unusual Payments (#221)​

  • #221: 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 intelligence assessments, FinCEN records, Suspicious Activity Reports, and Currency Transaction Reports related to any TPUSA-connected individual during this period.

VanceKirk2028.com Domain Registration (#222)​

  • #222: VanceKirk2028.com Domain Registration and Foreknowledge: Each covered agency shall produce all intelligence assessments, signals intelligence, and 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 produce: (1) any intelligence community assessment of who registered the domain and whether it reflects foreknowledge of the assassination; (2) all NSA, CIA, or other IC records identifying the true registrant through signals intelligence, financial intelligence, or cyber operations; (3) all records of the IP address from which the domain was registered and any attribution analysis; (4) all records relating to the hosting infrastructure on AWS Global Accelerator (IP addresses 13.248.243.5 and 76.223.105.230) and any intelligence community monitoring of that infrastructure; (5) all records establishing whether any foreign intelligence service, political operation, or person with foreknowledge of the assassination registered or directed the registration of this domain; and (6) 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. Each covered agency shall also produce all intelligence community analysis of whether the domain registration pattern indicates pre-positioning for a post-assassination political narrative.

Bilt Inc. DOD Contracts (#223–#227)​

  • #223: Bilt Inc. DOD Contract Details and Authorization: Each covered agency shall produce all intelligence regarding 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) all intelligence assessments of the contracts' purpose and whether they served as cover for intelligence operations or funding conduits; (2) the identity and intelligence background of all government officials who authorized the award; (3) all signals intelligence, financial intelligence, or human intelligence relating to Bilt Inc. or its principals; and (4) all communications between intelligence community personnel and DOD contracting officials regarding Bilt Inc. Each covered agency shall also produce all records relating to any intelligence community awareness of, involvement in, or assessment of DOD contracts to Bilt Inc. from January 2020 through the date of enactment.

  • #224: Bilt Inc. Ownership and Personnel Intelligence: Each covered agency shall produce all intelligence identifying every person behind Bilt Inc., including but not limited to: (1) all counterintelligence assessments of Bilt Inc. owners, officers, employees, and contractors; (2) all records of any Bilt Inc. personnel holding security clearances, SCIFs access, or intelligence community contracts; (3) all intelligence regarding connections between Bilt Inc. personnel and any foreign intelligence service; and (4) all intelligence regarding Bilt Inc. as a potential front company, cutout, or funding mechanism for intelligence operations. Each covered agency shall also produce all records relating to any connection between Bilt Inc. personnel and any person listed in Schedule B.

  • #225: Bilt Inc. Financial Flow Intelligence: Each covered agency shall produce all financial intelligence regarding 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 SIGINT intercepts of communications involving Bilt Inc. financial transactions; (2) all FinCEN data, Treasury intelligence, and bank intelligence relating to Bilt Inc.; (3) all intelligence regarding payments from Bilt Inc. to any person, entity, or account connected to the Charlie Kirk investigation; and (4) all intelligence regarding the ultimate destination of the approximately $8 million in DOD funds. Each covered agency shall also produce all intelligence assessments of whether Bilt Inc. DOD contracts were used as a financial pass-through or laundering mechanism.

  • #226: Bilt Inc. Invoice and Deliverable Intelligence: Each covered agency shall produce all intelligence assessing whether the approximately $8 million in DOD payments to Bilt Inc. in June 2025 corresponded to legitimate goods or services, including but not limited to: (1) all intelligence regarding what — if anything — Bilt Inc. actually delivered under these contracts; (2) all intelligence regarding whether the contracts were used to fund operations unrelated to their stated purpose; (3) all intelligence regarding any DOD Inspector General or audit findings; and (4) all intelligence regarding similar patterns of unprecedented contract awards to other companies during the same period. Each covered agency shall also produce all records of any intelligence community inquiry or assessment of Bilt Inc. contract legitimacy.

  • #227: Bilt Inc. Connection to Charlie Kirk Investigation: Each covered agency shall produce all intelligence 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.

Schedule B: List of People​

"People Listed" (PEOPLE_LISTED) means the categories of persons for whom disclosure is required under this Act, defined as follows:

  • 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.

Section 8: 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 over the Intelligence Community, the Spending Clause (Article I, Section 15, Clause 1) with respect to intelligence agency appropriations and state and local cooperation, and the Commerce Clause (Article I, Section 15, Clause 3) with respect to financial records and interstate and international 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: failure to investigate credible leads regarding foreign intelligence activity, including approximately 12 Israeli-registered cell phones detected at the shooting site, Egyptian military aircraft (SU-BTT, SU-BND) delivering personnel with Defense Attaché badges to Provo Municipal Airport, a HADES surveillance aircraft (N1098L) circling 35 minutes before the shooting, Counter-UAS testing at Provo Airport from September 4-10, DoD contract N0016425PJ538 for miniaturized anti-personnel charges, and evidence of electronic signal jamming at the venue. The Intelligence Community has failed to disclose its knowledge of these activities or to conduct adequate counterintelligence assessments.

(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 intelligence records for over 30 years, with the Intelligence Community exploiting classification authority to prevent public access. 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 intelligence-related records were withheld on sources and methods grounds without meaningful oversight. This Act is designed to remedy these structural deficiencies by narrowly defining permissible protections and establishing robust independent oversight.

(d) Public Interest in Transparency. The public has a compelling interest in full disclosure of all intelligence records related to the death of Charlie Kirk, a prominent public figure killed in a public venue, where substantial evidence suggests foreign intelligence involvement and potential complicity by elements of the U.S. Intelligence Community. The integrity of the Intelligence Community and democratic governance depends upon transparency and accountability.

Section 9: Definitions​

(a) "Intelligence Community agencies" means all agencies and elements of the Intelligence Community as defined in 50 U.S.C. 3003(4), including but not limited to: the Central Intelligence Agency (CIA), the National Security Agency (NSA), the Defense Intelligence Agency (DIA), the National Reconnaissance Office (NRO), the National Geospatial-Intelligence Agency (NGA), intelligence elements of the Armed Forces (including Army Intelligence and Security Command, Naval Criminal Investigative Service, Air Force Office of Special Investigations), the FBI's intelligence division, the Department of Homeland Security's intelligence elements, the Office of the Director of National Intelligence (ODNI), the Department of Energy's intelligence element, the Department of Treasury's intelligence element (including the Office of Intelligence and Analysis, the Internal Revenue Service Criminal Investigation Division, and the Financial Crimes Enforcement Network (FinCEN)), the Department of State's Bureau of Intelligence and Research (INR), and any other element of the United States government engaged in intelligence activities.

(b) "Covered information" means any intelligence product, analysis, report, communication intercept, surveillance data, satellite imagery, signals intelligence, human intelligence reporting, assessment, cable traffic, or any other information, in any format, that could:

  1. Identify or suggest the identity of any person involved in the death of Charlie Kirk
  2. Provide context, motive, or operational details related to the death
  3. Reveal any government awareness, foreknowledge, or involvement
  4. Contradict or supplement the official investigation narrative
  5. Relate to any foreign intelligence service activity in the State of Utah during the period January 1, 2025 through December 31, 2025
  6. Relate to threats against Charlie Kirk or similarly situated public figures by any foreign or domestic entity
  7. Relate to any of the specific items enumerated in Schedule A, including but not limited to: foreign aircraft activity (Items #1, #82-#87), foreign cell phones at UVU (Items #26, #88-#92), electronic jamming (Item #11), drone and surveillance operations (Items #8, #9, #12, #15, #156-#161), foreign intelligence contacts with TPUSA personnel (Items #3-#4, #54, #162-#167), psychological operations (Item #39), and international liaison communications (Items #173-#177)
  8. Relate to any aspect of the Charlie Kirk investigation, the prosecution of Tyler Robinson, or any matter that could help establish the full truth about the circumstances of Charlie Kirk's death

(c) "Final output information" means all intelligence products, including but not limited to: raw signals intelligence intercepts and transcripts, satellite imagery, cable traffic, source reports, briefing materials, intelligence assessments, analytical products, and any information from which conclusions were or could be drawn. The distinction between raw intelligence and finished intelligence shall not be used to withhold any covered information. The only permissible exclusions from final output information are the specific identity of currently active human intelligence sources whose disclosure would create an imminent threat to life, and specific technical collection methods currently in active operational use — but the substantive content, conclusions, and factual findings derived from such sources and methods shall always be disclosed.

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

(e) "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 17 of this Act.

(f) "Disclosure body" means the independent review board established under Section 17 of this Act.

(g) "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.

(h) "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).

Section 10: Sources and Methods Protection / Prohibited Grounds for Withholding​

(a) No covered information 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 information 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 Intelligence Community agency that relate to the death of Charlie Kirk or any person involved shall be disclosed in full
  6. Intelligence community privilege or "sources and methods" (except as narrowly provided below)
  7. Diplomatic relations with any foreign government
  8. Any claim that records were "lost," "destroyed," or "cannot be located" without forensic verification

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

  1. The true identity of currently active human intelligence sources whose disclosure would create an imminent threat to life
  2. Specific technical collection methods currently in active operational use

No "sources and methods" claim may be asserted in bulk for categories of records. Each claim must be individually justified for each specific document. The review board shall include at least 2 members with active TS/SCI clearances who can review classified materials and challenge claims.

  1. Child sexual abuse material as defined under 18 U.S.C. Section 2256

(c) The substance and conclusions of any intelligence must be disclosed even if the source is protected. No redaction of sources shall be used to withhold the analytical conclusions derived from those sources. Furthermore, raw intelligence — including but not limited to signals intercepts, satellite imagery, cable traffic, and source reports — shall be disclosed in full alongside any finished intelligence products. The distinction between raw intelligence and finished intelligence shall not constitute a basis for withholding any covered information.

(c-1) Original Records Required. Agencies shall produce original records — including raw intelligence cables, intercepts, assessments, and reports — not summaries, abstracts, or gists. Any agency producing a summary instead of the original record has not complied with this Act. This requirement applies to signals intercepts, satellite imagery, cable traffic, source reports, and all other forms of raw and finished intelligence. Original records shall be produced in a format that allows the review board and investigation teams under the Charlie Kirk Mandatory Investigation Act (Law 3) and the Charlie Kirk Trusted Investigators Act (Law 4) to understand and analyze them, including any indices, search tools, metadata, analytical context, and interpretive information necessary for comprehension. An agency that produces raw data — including raw signals intelligence intercepts — without the tools, indices, and context necessary to analyze that data has not complied with this Act. For signals intelligence, this means NSA shall provide not only raw intercepts but also any existing translations, transcripts, analytical summaries, database search interfaces, and metadata tags associated with the intercepts.

(d) All redactions must be:

  1. Individually justified in writing, with a classified annex provided to the congressional intelligence committees
  2. Published in the Federal Register (in summary form sufficient to identify the scope of the redaction)
  3. Submitted to the Intelligence Committees of both houses of Congress
  4. Subject to judicial review upon challenge by any party
  5. Accompanied by an unclassified summary of the substance of the redacted information

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

(f) 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 information 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, intelligence-sharing compact, or informal arrangement between any Intelligence Community agency and any foreign government, foreign intelligence service, or international organization that would restrict disclosure of covered information. This override applies to all forms of intelligence received from any foreign source, including but not limited to:

  1. Any foreign government and its intelligence services — including any intelligence related to the approximately 12 foreign-registered cell phones detected at or near Utah Valley University on or around September 10, 2025
  2. The Arab Republic of Egypt and the Egyptian General Intelligence Directorate (GID) — including any intelligence related to Egyptian-registered aircraft (SU-BTT, SU-BND) and military contractors with Defense Attache badges observed in the Provo, Utah area
  3. The United Kingdom and MI5, MI6, and GCHQ
  4. All Five Eyes partners: Australia (ASIS, ASD), Canada (CSIS, CSE), and New Zealand (NZSIS, GCSB)
  5. Any other foreign government, foreign intelligence service, or international organization from whom any covered information was received or with whom any covered information was shared

No Intelligence Community agency may withhold, delay, or redact any covered information on the ground that it was received from, shared with, or originated from a foreign partner. Any invocation of the Third Party Rule, any foreign disclosure restriction, or any intelligence-sharing agreement to justify withholding covered information constitutes obstruction under Section 12.

(g) Mandatory Foreign Liaison Disclosure Request. Within 14 days of enactment, the Director of National Intelligence shall:

  1. Formally request all foreign liaison partners from whom covered information was received to authorize full public disclosure of that information
  2. Identify all foreign liaison partners who possess information related to the death of Charlie Kirk, whether or not such information has been shared with the United States
  3. Request all identified foreign partners to produce any information in their possession related to the death of Charlie Kirk
  4. Report to the congressional intelligence committees within 14 days of the requests, disclosing: which partners were contacted, which authorized disclosure, which refused, which did not respond, and the nature and scope of information known to be held by each partner
  5. Regardless of whether foreign partners authorize disclosure, all covered information in the possession of the United States shall be disclosed as required by this Act

(h) Foreign Government Records and Diplomatic Channels. Within 15 days of enactment:

  1. 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, formally requesting production of all records in those governments' possession related to the death of Charlie Kirk, including intelligence files, diplomatic communications, military contractor records, and aircraft operations
  2. The Director of National Intelligence shall submit formal requests through intelligence liaison channels to the intelligence services of all foreign governments identified as possessing relevant records, including but not limited to Egypt (GID), France (DGSE, DGSI), the United Kingdom (MI5, MI6, GCHQ), and all Five Eyes partners for production of all information related to the death of Charlie Kirk
  3. Each covered agency shall disclose all prior diplomatic or intelligence-sharing communications with any foreign government regarding the investigation, including communications predating enactment of this Act
  4. If any foreign government refuses to comply with a request under this subsection or fails to respond within 60 days, the Director of National Intelligence shall publicly report that refusal or non-response, including the scope of information believed to be held by that government, within 7 days of the refusal or the expiration of the 60-day period
  5. No Diplomatic Immunity for Evidence. No claim of diplomatic immunity, sovereign immunity, or act-of-state doctrine may be used to withhold records from the review board or any investigation team. Any person claiming diplomatic immunity to avoid producing covered records shall be reported to Congress within 7 days.

(i) Declassification of Covered Information. All classification markings on covered information are automatically removed upon enactment of this Act. No covered information may be reclassified after disclosure under this Act. 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 information shall be produced to the review board in classified form, with a public version produced simultaneously, and the full unclassified version produced within 60 days. Any agency seeking to maintain classification on specific covered records must petition the review board established under Section 17 within 7 days of enactment, identifying each record with particularity and demonstrating by clear and convincing evidence that disclosure would cause grave and imminent harm to an identified national security interest. The burden of proof rests entirely on the petitioning agency. The review board shall rule on all such petitions within 14 days. Failure to petition within 7 days constitutes a waiver of any classification claim.

Section 11: No Foreign Government Exception​

(a) No covered information 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 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 12.

Section 12: Criminal Prohibition on Obstruction and Penalties for Non-Compliance​

(a) It shall be a federal crime, punishable by up to 10 years imprisonment, for any person employed by or acting on behalf of the United States Intelligence Community or any branch of the United States government to:

  • Prevent, obstruct, or discourage any government employee from releasing covered information
  • Order, direct, or pressure any person to withhold covered information
  • Destroy, alter, or conceal covered information
  • Classify or reclassify information for the purpose of preventing its disclosure under this Act
  • Use the "sources and methods" exception to withhold analytical conclusions or final output information
  • Invoke the distinction between raw intelligence and finished intelligence to withhold any covered information, including but not limited to signals intercepts, satellite imagery, cable traffic, and source reports

(b) This prohibition applies regardless of the rank, position, or security clearance of the person engaging in obstruction.

(c) Attempted violations carry the same penalties as completed violations.

(d) Any agency that fails to comply within the 30-day timeline shall be subject to automatic, self-executing budget reductions: the non-compliant agency's discretionary intelligence 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 the expiration of each month of non-compliance, requiring no further congressional action, appropriations rider, or agency cooperation. The Office of Management and Budget shall implement each monthly reduction within 5 business days of the monthly non-compliance determination by the review board. 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.

(d-1) Escalating Weekly Budget Reductions. Beginning on the 31st day after enactment, non-compliant agencies shall be subject to weekly escalating budget reductions: 5% in week 1, 10% in week 2, 15% in week 3, and 25% per week thereafter, cumulative with monthly reductions. (d-2) Individual Compliance Officer Liability. Each agency's compliance officer shall be personally and criminally liable for non-compliance if the agency fails to meet the 30-day deadline. (d-3) Independent Completeness Audit. The review board shall commission an independent technical audit team — not current or former intelligence agency employees — to verify completeness. The review board, not any agency, determines compliance. (d-4) Real-Time Public Compliance Dashboard. Each agency shall maintain a real-time public dashboard showing compliance status for each Schedule A item.

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

(f) The DNI's failure to ensure compliance 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.

(g) DNI Conflict of Interest. If the review board finds evidence that Intelligence Community personnel are implicated in the investigation — including allegations of evidence destruction, obstruction, or involvement in the events surrounding the death of Charlie Kirk — compliance authority shall transfer to a court-appointed Special Master. The Director of National Intelligence shall recuse from compliance decisions affecting information that could implicate Intelligence Community personnel. The review board, not the DNI, shall have final authority to certify completeness of disclosure.

Section 13: Records Preservation​

(a) Upon introduction of this bill, all Intelligence Community agencies shall immediately preserve all covered information and issue written preservation orders to all personnel with access to relevant systems.

(b) Criminal Penalties for Destruction. Upon enactment of this Act, any person who destroyed, altered, concealed, or removed any covered information after the date this bill was introduced in Congress shall be guilty of a federal crime punishable by up to 15 years imprisonment. The criminal prohibition under this subsection is enforceable upon enactment and applies retroactively to any act of destruction, alteration, concealment, or removal occurring on or after the date of introduction. Destruction of covered information 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 (Sarbanes-Oxley obstruction of justice by destruction, alteration, or falsification of records), provides an independent legal basis for prosecution of any destruction of covered records occurring before enactment; the penalties under this subsection are cumulative with, and do not displace, penalties available under 18 U.S.C. 1519 or any other applicable federal statute.

(c) Each agency shall conduct a forensic audit of its classified and unclassified systems to verify no records have been deleted or altered after September 10, 2025.

(d) Agencies that have destroyed records must provide a complete classified accounting to the congressional intelligence committees, including what was destroyed, when, by whom, and under whose authorization.

(e) Independent Forensic Imaging Within 72 Hours. Within 72 hours of enactment, each covered agency shall submit to forensic imaging of all servers, databases, and storage media by independent forensic firms selected by the review board, not by the agencies themselves. (f) Complete Deletion Audit Logs. Each covered agency shall produce complete audit logs of all file deletions, modifications, and access events since September 10, 2025.

Section 14: 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 — including intelligence community personnel at any clearance level — 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 or under the Charlie Kirk Files Forced Disclosure Act (Law 1)
  • 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 Intelligence Committees, Judiciary Committees, and any special or select committee with jurisdiction)
  • 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, classification abuse, or any failure to investigate leads.

(b) No person shall retaliate against, terminate, demote, reassign, revoke security clearance of, harass, or in any way persecute any government employee or contractor for disclosing information pursuant to this Act.

(c) Security clearance revocation or 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 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, the National Security Act of 1947, 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 immunity extends to disclosures of information classified at any level, including Top Secret, Sensitive Compartmented Information (SCI), and Special Access Programs (SAP), when the disclosure relates to the death of Charlie Kirk or the investigation thereof. 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 15: No Presidential Override​

(a) Congressional Finding of Compelling Interest. Congress finds that the compelling public interest in disclosure of covered information, as established in Section 8, overcomes any claim of executive privilege with respect to such information.

(b) The President may not order, direct, or authorize the continued withholding of any covered information under this Act.

(c) No executive order, presidential memorandum, classification decision, or other presidential directive may suspend, modify, or override the requirements of this Act.

(d) Any assertion of executive privilege over covered information 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.

(e) Any presidential delay of disclosure under subsection (d) shall not exceed 30 days beyond the statutory deadline without court approval.

Section 16: Prohibition on Classification​

(a) No information related to the Charlie Kirk investigation may be classified, reclassified, or withheld under any classification authority if it pertains to, reveals, or suggests the involvement of, foreknowledge by, or connection to any of the following: any foreign country, any foreign intelligence service, any U.S. intelligence service (including but not limited to the CIA and NSA), the FBI, or any branch or component of the U.S. military. Any existing classification of such information is automatically void upon enactment. Any attempt to classify or reclassify such information constitutes obstruction under Section 12.

Section 17: Congressional 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 by the Speaker of the House of Representatives, 2 members by the Senate Majority Leader, and 1 member by the Senate Minority Leader. Members shall have demonstrated expertise in law, intelligence oversight, national security, forensic investigation, 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.

(b) The review board shall:

  1. Have full access to agency systems, databases, and files — including classified systems — 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 Intelligence Community 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.

(d) Board members may not have been employed by any Intelligence Community agency or 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 intelligence 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 classified communication channels at appropriate classification levels — including at the TOP SECRET/SCI level — accessible through a Sensitive Compartmented Information Facility (SCIF) maintained independently of any covered intelligence 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.
  6. For persons located outside the United States who wish to submit information, including foreign nationals, the review board shall maintain a secure international submission channel accessible without requiring a U.S. security clearance.

The review board shall acknowledge receipt of all submissions within 7 days. No covered intelligence 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 12.

(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, including classified compartments; (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.

(g) Each of the 227 items in Schedule A that falls within intelligence jurisdiction shall be individually addressed in the compliance report with specific response.

(h) Monthly compliance reports shall be provided to Congress.

Section 18: Mandatory Public Hearing Requirement​

(a) Required Testimony. Within 60 days of enactment, each of the following officials shall appear and testify under oath in public session before the congressional intelligence committees (the Senate Select Committee on Intelligence and the House Permanent Select Committee on Intelligence, sitting jointly or separately):

  1. The Director of the Central Intelligence Agency (CIA)
  2. The Director of the National Security Agency (NSA)
  3. The Director of the Defense Intelligence Agency (DIA)
  4. The Director of National Intelligence (DNI)

(b) Scope of Testimony. Each official shall testify regarding:

  1. The agency's compliance with this Act, including a complete accounting of all records produced and any records withheld
  2. All intelligence in the agency's possession related to the death of Charlie Kirk and the items enumerated in Schedule A
  3. Any foreign intelligence activity in Utah related to the death of Charlie Kirk
  4. Any obstruction, delay, or failure to investigate identified by the review board

(c) Criminal Contempt for Refusal. Any official who refuses to appear, refuses to testify, provides materially false testimony, or asserts any privilege to avoid answering questions related to this Act's disclosure requirements shall be subject to criminal contempt of Congress proceedings under 2 U.S.C. 192, punishable by a fine of up to $100,000 and imprisonment of not less than one month and not more than 12 months. Either chamber of Congress may retain independent counsel to prosecute the contempt, bypassing referral to the Department of Justice.

(d) No Classification Shield. Testimony regarding the existence, scope, and compliance status of records production shall be provided in public session. If specific intelligence content requires classified discussion, such discussion shall occur in closed session immediately following the public session, but the fact that classified records exist and their general subject matter shall be disclosed publicly.

(e) Recurring Hearings. The congressional intelligence committees shall hold follow-up public hearings at 90-day intervals until the review board certifies full compliance.

Section 19: 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 Director of National Intelligence specifying the alleged non-compliance; (2) the 30-day disclosure deadline under Section 1 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 information disclosed under this Act.

(a-1) Emergency Injunction for Imminent Evidence Destruction. Notwithstanding the 60-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) Courts shall apply a presumption in favor of disclosure in any proceeding under this Act.

(c) Prevailing plaintiffs shall receive reasonable attorney's fees and costs.

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

Section 20: Report to Congress​

(a) Not later than 15 days after completion of the release required under Section 1, the Director of National Intelligence shall submit to the congressional intelligence committees a report containing:

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

Section 21: 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 17, 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.

(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. The funds appropriated under subsection (a) shall be deposited in a separate account established at the U.S. Treasury within 14 days of enactment, with the chair of the independent review board as sole signatory. The host agency's Chief Financial Officer shall have no access to or authority over the account. Disbursements from the account shall be made solely at the direction of the review board chair, and no covered agency may condition, delay, or restrict any disbursement.

(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 22: 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 23: Personal Liability of Agency Heads​

(a) Personal Responsibility. The head of each covered intelligence agency is personally responsible for that agency's compliance with this Act. Delegation of compliance duties to subordinates, including general counsels, classification officers, or deputy directors, does not relieve the agency head of personal liability for non-compliance.

(b) Rebuttable Presumption of Willful Obstruction. If a covered intelligence 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. Reliance on classification review timelines or counsel's advice regarding sources and methods shall not constitute a valid rebuttal absent a showing that the agency head personally reviewed the claimed exemptions.

(c) Referral for Prosecution. The congressional intelligence oversight committees, acting jointly or individually, may refer any agency head to the Department of Justice for criminal prosecution under Section 12 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 referring committee 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 intelligence 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 12 of this Act.

(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 congressional intelligence oversight committees, any member of the review board established under companion legislation (Law 1), or any citizen with reasonable basis to believe that covered intelligence records are being or are about to be destroyed, concealed, or altered, may report the exigent circumstance to the oversight committees, to the review board, or to any federal district court.
  2. Upon receipt of such a report, the intelligence 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. Classification review timelines do not excuse non-compliance with this emergency preservation requirement.
  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 congressional intelligence oversight committees 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. The existence of classified information shall not delay the court's ruling; the court may issue the preservation order under seal if necessary, but shall not delay issuance.
  6. This subsection applies to all covered intelligence agencies and to any person acting on behalf of a covered intelligence agency, regardless of rank, position, or security clearance level.

(g) Certification Requirement. Within 30 days of enactment, each intelligence agency head shall personally certify under penalty of perjury that all covered records have been identified, preserved, and produced. Any claim that records are exempt under Section 10 (sources and methods) must be personally reviewed and approved by the agency head, not delegated to subordinate classification authorities. A false certification constitutes perjury under 18 U.S.C. Section 1621 and obstruction under Section 12 of this Act.

(h) Director of National Intelligence. The Director of National Intelligence bears personal liability for compliance by the Office of the Director of National Intelligence. Each Intelligence Community element head bears independent personal liability for their agency's compliance. The DNI's coordination authority under 50 U.S.C. 3024 does not create DNI liability for another agency's independent failure to comply, nor does it relieve any agency head of independent responsibility. The DNI may not claim that component agency autonomy relieves the DNI of responsibility for the ODNI's own compliance obligations, including the DNI's duty to coordinate, notify, and report non-compliance by other agencies to Congress and the review board.

Section 24: State and Local Cooperation​

(a) Any state or local agency that possesses intelligence-related covered information shall produce such information within 30 days of enactment. This requirement explicitly includes state intelligence fusion centers (including but not limited to the Utah Statewide Information and Analysis Center), state Department of Public Safety intelligence divisions, and any state or local entity that receives, processes, or stores intelligence products from federal agencies. Non-compliance shall result in automatic suspension of 25% of ALL federal funding to the non-compliant state or local agency — including but not limited to intelligence-sharing grants, law enforcement cooperation grants, Homeland Security Grant Program funds, Urban Area Security Initiative funds, and any other federal grant or cooperative agreement — for each month of non-compliance, with no cap on cumulative reductions.

(b) The DNI shall notify all relevant 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 information.

Section 25: Statute of Limitations​

The statute of limitations for any criminal offense under this Act shall be 45 years from the date the offense is discovered by any person with standing to report or prosecute the offense. Discovery occurs when facts sufficient to reasonably indicate the offense become known to any member of the review board, any member of Congress, or any person who files a complaint. This extended limitations period applies regardless of any shorter limitations period that would otherwise apply under federal law.

Section 26: Pending Criminal Prosecution​

(a) Acknowledgment of State Proceedings. Congress acknowledges the pending criminal prosecution in State of Utah v. Tyler Alexander Robinson (Case No. 251403576, Fourth Judicial District Court, Utah County, Utah). Nothing in this Act shall be construed to determine any fact at issue in that prosecution, to establish or negate the guilt or innocence of any defendant, or to constitute a congressional finding regarding the criminal case.

(b) Under-Seal Production. If the trial court in Case No. 251403576 finds, upon motion by any party, that public disclosure of specific covered records would create a substantial risk of prejudice to the defendant's right to a fair trial, the trial court may order that such records be produced under seal to the court and to counsel of record, pending completion of the trial. Any under-seal order shall identify the specific records with particularity, shall be narrowly tailored, and shall expire automatically upon the earlier of: (1) the conclusion of trial proceedings, including sentencing; or (2) 18 months from the date of the order.

(c) No Broader Exception. The under-seal provision in subsection (b) does not authorize any covered agency to withhold records from the review board, from Congress, or from Designated Trusted Investigators. It applies only to the timing of public release of specific records and only upon a judicial finding of prejudice. Any covered agency that invokes this provision to justify broader withholding commits obstruction under Section 12.

Section 27: Technical Specification for Disclosure Format​

(a) All records disclosed under this Act shall be produced in the following formats:

  1. Text-searchable PDF for all textual documents, or in the original digital format if the original is a database, spreadsheet, or structured data file
  2. Optical Character Recognition (OCR) shall be applied to all scanned documents, photographs of documents, and any other image-based text before production
  3. Original digital format shall be preserved and produced alongside any converted format, including metadata, timestamps, and file properties
  4. Audio and video recordings shall be produced in their original format with no reduction in quality

(b) All disclosed records shall be published on a publicly accessible website maintained by the review board that:

  1. Requires no login, account registration, or personal information to access
  2. Provides full-text search capability across all disclosed records
  3. Provides bulk download capability for all records, organized by Schedule A item number and by originating agency
  4. Includes a machine-readable index in open data format (JSON or CSV) listing every disclosed record with metadata including originating agency, date, classification level prior to disclosure, Schedule A item(s) addressed, and file format

(c) The review board shall maintain the disclosure website for a minimum of 25 years after enactment.

Section 28: Cross-Reference to Companion Laws​

(a) This Act is one of four companion statutes addressing the death of Charlie Kirk:

  1. Law 1: Charlie Kirk Files Forced Disclosure Act — Law Enforcement (requiring DoJ, FBI, ATF, CBP, TSA, DHS, FinCEN, and all federal, state, and local law enforcement agencies to disclose all files related to the investigation)
  2. Law 2: This Act (requiring all Intelligence Community agencies to disclose all intelligence-related files)
  3. Law 3: Charlie Kirk Mandatory Investigation Act (requiring the FBI and Intelligence Community to conduct a thorough, good-faith investigation of all 227 Schedule A items)
  4. Law 4: Charlie Kirk Trusted Investigators Act (establishing independent investigation teams led by Designated Trusted Investigators with full access to all agency files)

(b) Independent Operation and Standalone Fallback. This Act shall be fully operative and enforceable regardless of whether any companion legislation is enacted, funded, or remains in effect. No provision of this Act is contingent upon the enactment or continued operation of any other statute. References to Designated Trusted Investigators shall, if the Charlie Kirk Trusted Investigators Act (Law 4) is not enacted, vest equivalent authority in the Congressional Review Board established under Section 17 of this Act, including all investigative powers, access rights, and reporting obligations that would otherwise be exercised by Designated Trusted Investigators. References to investigation teams under the Charlie Kirk Mandatory Investigation Act (Law 3) shall, if that Act is not enacted, vest equivalent investigative authority in the review board, which may appoint independent investigators with the same powers. If a companion statute is enacted, definitions, Schedule A, and Schedule B shall be construed consistently across all companion statutes, with the broader definition controlling in any case of conflict.

(c) Non-Duplication. Compliance with a companion statute does not excuse non-compliance with this Act. Each statute imposes independent obligations. Records produced under a companion statute must also be independently certified as complete under this Act.

Section 29: Enforcement for Forensic Audits​

(a) Each covered agency shall permit and facilitate forensic audits of its classified and unclassified systems as directed by the review board under Section 13(c) and Section 17.

(b) Refusal to permit a forensic audit, obstruction of a forensic audit in progress, delay of a forensic audit beyond 48 hours after the review board's request, or any act designed to impede or compromise the integrity of a forensic audit constitutes obstruction under Section 12 and is subject to the criminal penalties provided therein, including up to 10 years imprisonment.

(c) Forensic auditors shall be selected by the review board and shall operate independently of the audited agency. No audited agency may require forensic auditors to obtain security clearances through the audited agency's own clearance process; the review board shall arrange clearances through the ODNI or an independent clearance authority.

Section 30: Self-Executing Enforcement and Independent Prosecution​

(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 are funded through mandatory appropriations under Section 21 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: Federal Supremacy Over Conflicting Court Orders​

(a) Gag Order Override. This Act establishes a federal statutory right to disclosure of covered records that supersedes any conflicting court order, including but not limited to state court gag orders, protective orders, sealing orders, and any other judicial directive that would restrict, delay, or prohibit the disclosure of covered records under this Act. The Supremacy Clause of the United States Constitution (Article VI, Clause 2) compels this result.

(b) No state court order — including any order issued in State of Utah v. Tyler Alexander Robinson (Case No. 251403576) or any related proceeding — shall be construed to prohibit, restrict, or penalize compliance with this Act by any covered agency, any member of the review board, any Designated Trusted Investigator, or any person acting under authority of this Act.

(c) Any person who is subject to a conflicting state court order and who discloses covered records in compliance with this Act shall be immune from contempt, sanctions, or any other penalty imposed by any state court for such disclosure.

(d) Nothing in this section limits the under-seal provision of Section 26(b), which addresses only the timing of public release of specific records upon a judicial finding of trial prejudice.

Section 32: 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, not by assignment. (b) No court may issue a stay of the disclosure requirements of this Act pending litigation. (c) All judicial proceedings under this Act shall be conducted in public session. No proceeding may be sealed absent a specific finding 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. Prevailing plaintiffs shall be awarded attorney's fees.

(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, sources and methods protection, or institutional harm do not satisfy this standard.

Section 33: Statutory Brady Obligation for Intelligence Community​

(a) Codification of Brady Obligations. All covered Intelligence Community agencies are hereby established as custodial agencies with respect to the criminal prosecution in State of Utah v. Tyler Alexander Robinson (Case No. 251403576, Fourth Judicial District Court, Utah County, Utah). Each covered agency has a statutory obligation, independent of and in addition to any constitutional obligation under Brady v. Maryland, 373 U.S. 83 (1963), and its progeny, to identify and disclose to the defense all exculpatory, impeachment, and mitigating information in its possession, custody, or control that relates to the charges, the defendant, or any person involved in the death of Charlie Kirk.

(b) This statutory Brady obligation extends to:

  1. Any intelligence suggesting that any person other than Tyler Robinson participated in, planned, directed, or facilitated the death of Charlie Kirk
  2. Any intelligence suggesting foreign intelligence service involvement
  3. Any intelligence that contradicts the prosecution's theory of the case
  4. Any intelligence regarding the mental state, manipulation, or handling of Tyler Robinson by any intelligence service or government agent
  5. Any intelligence relevant to sentencing, including mitigating factors

(c) Each covered agency shall designate a Brady compliance officer who shall review all covered records for Brady material and produce such material to the defense within 14 days of enactment, with rolling production of any newly discovered Brady material within 48 hours of discovery.

(d) Failure to comply with this section constitutes both obstruction under Section 12 of this Act and a violation of the defendant's constitutional rights under the Fifth and Sixth Amendments. Any covered agency official who willfully withholds Brady material shall be subject to criminal prosecution under 18 U.S.C. 1519 in addition to penalties under this Act.

Section 34: Effective Date​

This Act shall take effect immediately upon enactment. All criminal penalties under this Act apply prospectively from the date of enactment; no person shall be subject to criminal liability under this Act for conduct occurring before enactment, except that the records preservation and destruction penalties under Section 13(b) apply retroactively to destruction occurring after the date of introduction as provided therein. Records preservation requirements (Section 13) take effect upon introduction of this bill, with enforcement as provided in Section 13(b).

Supplemental Definitions​

The following definitions supplement and are consistent with the definitions provided in Section 9 of this Act. In the event of any conflict between a definition in this section and one in Section 9, the broader definition shall control.

(a) "Investigation" means any federal, state, or local law enforcement inquiry, intelligence assessment, counterintelligence investigation, administrative review, Inspector General inquiry, congressional inquiry, grand jury proceeding, or any other official or unofficial examination of facts 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 related federal investigation, any intelligence community assessment or after-action review, and any inquiry by any foreign government or international organization. This definition encompasses investigations that have been opened and closed, investigations that were prevented from being opened, and any review or examination of the adequacy of prior investigations.

(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 activities, and actions related thereto — whether occurring before, during, or after September 10, 2025 — including but not limited to the criminal prosecution of Tyler Alexander Robinson, the investigation and its conduct, all cover-up or obstruction activities, and all consequences flowing from the death.

(c) "Disclosure body" means the independent review board established under Section 17 of this Act, including any Special Master appointed under Section 17(f), and any successor body exercising the review board's functions.

(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 or involvement in matters addressed by this Act.

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

Peer laws: Law 1 - DoJ/FBI Disclosure | Law 3 - Mandatory Investigation | Law 4 - Trusted Investigators

Precedent: Epstein Files Transparency Act | JFK Records Act