Usa V Samsel Jan12th Notice of Supersede Indictment

Case 1:21-cr-00537-TJK Document 79 Filed 01/12/22 Page 1 of 6
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v. Case No. 1:21-cr-00537-TJK

D-1 RYAN SAMSEL Case No. 1:21-cr-00332-JMC
D-2 JAMES TATE GRANT
D-3 PAUL RUSSELL JOHNSON
D-4 STEPHEN CHASE RANDOLPH
Defendants.
NOTICE UNDER LOCAL CRIMINAL RULE 40.5(b)(3) OF RELATED CASES AND

INTENT TO SUPERSEDE INDICTMENT
The United States of America, by and through its attorney, the United States Attorney
for the District of Columbia, respectfully files notice, pursuant to Local Criminal Rule
40.5(b)(3), that United States v. Ryan Samsel and James Tate Grant, No. 21-cr-00537 (TJK) and
United States v. Paul Russell Johnson and Stephen Chase Randolph, No. 21-cr-00332 (JMC)
are related cases. These four offenders are all currently charged with aiding and abetting one
another to commit the same crimes, at the same time and location, against the same victim,
Officer C.E. Their collective action – that is violently picking up and pushing a metal barricade
at United States Capitol Police Officers, who were manning the barricade in an effort to protect
and defend the U.S. Capitol and the certification of the Electoral College vote – opened up the
floodgates to the Capitol for the thousands of rioters who followed. Their collective action led
to at least one U.S. Capitol Police Officer sustaining injuries that have required continual
1
medical care since January 6.
Samsel and Grant were the first two to approach the restricted area just ahead of the rest
of the crowd on January 6, and Grant waved others to follow them. All four defendants then
took up positions along the same barrier consisting of attached crowd control barriers, and they
acted in concert to lift and push the barricade violently onto the officers stationed on the other
side of the barricade. At least one of those officers, Officer C.E. suffered injuries as a result of
the defendants’ collective actions. Additionally, after they pushed down the barricade, Randolph
physically attacked Officer D.C further.
Defendants Samsel and Grant are currently joined together as co-defendants before the
Honorable Timothy J. Kelly. The majority of the charges against them are for the Peace Circle
incident described above. (No. 21-cr-00537 (TJK), R. 69: Dec. 15, 2021, Second Superseding
Indictment). Defendants Johnson and Randolph are presently joined together as co-defendants
before the Honorable Jia M. Cobb.1 All of the charges against them relate to the incident at
Peace Circle and surrounding circumstances. (No. 21-cr-332 (JMC), R. 61: Dec. 1, 2021,
Superseding Indictment).2
Because the primary criminal conduct alleged against these individuals overlaps both
temporally and geographically, and the evidence against them will be mutually admissible,
including the testimony of witnesses and the victims, the government is preparing to charge this
1
On January 7, 2022, Johnson and Randolph’s case was reassigned from the Honorable Paul L.
Friedman to the Honorable Jia M. Cobb. See United States v. Johnson et al., No. 21-cr-332 (R.
75).
2
The Government takes no position on which Judge should be assigned the cases if joined.
Johnson and Randolph were initially indicted in April, 2021; Samsel was indicted in August, 2021
and Grant indicted in December, 2021. The Government notes that defendant Samsel has made
allegations concerning his medical conditions and treatment in federal facilities, and there have
been numerous motions, status reports, and hearings in that case. Samsel is currently in a unique
position in that he has been temporarily released to state custody with a federal detainer following
a defense motion related to his alleged medical concerns.
2
group3 in a single indictment and to present evidence against them in a single trial. 4
MATTHEW M. GRAVES
United States Attorney
D.C. Bar No. 481052
By: s/ April Nicole Russo

APRIL NICOLE RUSSO
PA Bar No. 313475
Assistant United States Attorney
555 4th Street, NW
Washington, DC 20530
(202) 252-1717
April.Russo@usdoj.gov
s/ Danielle Rosborough
DANIELLE ROSBOROUGH
D.C. Bar No. 1016234
Trial Attorney, National Security Division
950 Pennsylvania Avenue
(202) 514-0073
Danielle.Rosborough@usdoj.gov
3
The government anticipates adding a fifth uncharged subject, who also participated in the Peace
Circle incident described above, and who also pushed and pulled on the barricades, resulting in
injuries to Officer C.E., to this indictment.
4
Other Capitol Riot cases involving conduct by groups of defendants have been joined. See, e.g.,
United States v. Federico Klein et al., No. 21-cr-236 (R. 45) and United States v. McCaughey, et
al., No. 21-cr-40 (TNM). In Klein and McCaughey, the government filed notice under Local
Criminal Rule 57.12(b)(3) of Related Cases regarding nine subjects charged with assaultive
conduct on law enforcement officers in and around the first landing of the Lower West Terrace as
well as the Lower West Terrace archway. One subject, Klein, was charged alone in a case before
the Honorable John D. Bates, while the other eight subjects were charged in one case before the
Honorable Trevor N. McFadden. Following the filing of a superseding indictment joining the nine
defendants, the Klein case was reassigned to the Honorable Trevor N. McFadden.
3
s/ Christopher D. Amore
CHRISTOPHER D. AMORE
NY Bar No. 5032882
Capitol Riot Detailee
555 4th Street, NW
(973) 645-2757
Christopher.Amore@usdoj.gov
s/ Hava Arin Levenson Mirell

HAVA ARIN LEVENSON MIRELL
CA Bar No. 311098\
555 4th Street, NW
(213) 894-0717
Hava.Mirell@usdoj.gov
s/ Robert Juman
ROBERT JUMAN
NJ Bar No. 033201993
555 4th Street, NW
(786) 514-9990
Robert.Juman@usdoj.gov
4
Certificate of Service
I hereby certify that on January 12th 2022, I electronically filed the Notice Under Local
Criminal Rule 40.5(b)(3) of Related Cases and Intent to Supersede Indictment with the Clerk of
the Court of the District of Columbia using the ECF system, which will send notification of such
filing to defense counsel via electronic mail.
s/ April Nicole Russo

APRIL NICOLE RUSSO
PA Bar No. 31347
555 4th Street, NW,
(202) 252-1717
April.Russo@usdoj.gov
s/ Hava Arin Levenson Mirell

HAVA ARIN LEVENSON MIRELL
CA Bar No. 311098
555 4th Street, NW,
(213) 894-0717
Hava.Mirell@usdoj.gov
1

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Case 1:21-cr-00537-TJK Document 79 Filed 01/12/22 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA

v. Case No. 1:21-cr-00537-TJK

NOTICE UNDER LOCAL CRIMINAL RULE 40.5(b)(3) OF RELATED CASES AND

medical care since January 6.

physically attacked Officer D.C further.

By: s/ April Nicole Russo

s/ Hava Arin Levenson Mirell

filing to defense counsel via electronic mail.

s/ April Nicole Russo

s/ Hava Arin Levenson Mirell

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