To
Office Of Inspector General
Investigations Division / Civil Rights &
Civil Liberties Violation Complaints
950 Pennsylvania Avenue NW, Suite # 4706
Washington, DC 2O53O

RE: Violations of Randeep S. Mann's Civil Rights (Amendments I, IV, V, and XIV) by the Department Of Justice Employees (AUSA s and ATF Agents)
- Fabrication and the planting of evidence by the Ail. Agents (March 2009)
- Sponsoring and suborning perjured Grand Jury testimony by AUSAs and ATF Agents (January 201]
- Sponsoring and suborning perjured testimony by the ATF Agents at the ASMB hearings (June 2(
- Malicious harassment by ATF Agents, State and Local LE Agencies (Post September 2001)
- Disregarding and denial of FOIA requests by the Art, (June 2013 to date)

Violation of Dan Carlton (Mann)'s Civil Rights (Amendment I) by Department Of Justice Employees (ATF Agents)
- Intimidation by threats of incarceration as retribution for Investigating LE Misconduct by ATF Agents (November 2013)

Dear Sir / Madam,

I, Randeep S. Mann MD, am currently serving a life sentence, convicted in August 2010 for (1) Conspiring and aiding & abetting unknown persons in the bombing that critically injured Trent Pierce MD, (2) Constructive possession of 98 40mm HE grenades, (3) Possession of one illegal machine gun, and (4) Obstruction of justice. I am vehemently and categorically stating that I am innocent of all these charges.

I am aware of the fact that I am bringing forth some extremely serious allegations. These are not mere conclusory statements created out of speculation and conjecture. You are renowned for being objective and just, holding the letter of law above everything else. Being in a revered position of authority, wielding tremendous power and influence through both your office and your very person you hold the key to having my allegations and insinuations investigated, exposed and addressed in any manner that you deem appropriate.

I know that a substantial number of acts that I allude to, in and of themselves, do not represent any wrong doing on the part of the LE Agencies in question. The acts being, run of the mill modalities that officers resort to in order to acquire evidence and investigate allegations of infractions of the law. That was precisely how it was when LE initially started investigating me. Unfortunately, with the passage of time, their investment in the form of their exhaustive commitment both in man power and putting into play their vast array of resources did not yield the anticipated dividends. It was then that their misguided zest to get a conviction at all cost got the better of their judgement. They then crossed the line, violating the very law that they had sworn to protect in the most shameless and despicable manner.

I am originally from India, a Hindu by religion, having a rather heavy Indian accent and appearing by looks to be middle-eastern, as would be expected. I immigrated to the United States in 1983, acquiring US citizenship in 1986. I am a physician Board Certified in Internal Medicine, Emergency Medicine and Pain Management who had lived in London, AR practicing in adjoining Russellville, AR since 1999. I was a gun enthusiast and collector since the gun ban in 1990. Having acquired a Class 3 license, I was permitted to deal, both buy and sell machine guns. As a result, I had a vast inventory of NFA weapons.

The hate environment that followed the events of September 11, 2001 were the building blocks exploited by the ATF Agents and in particular Agent Warren Newman who set about targeting me. Two Sting Operations were initiated and pursued aggressively, overzealously and ruthlessly with just one purpose, which was to get me at all cost, no holds barred.

The First Sting Operation entailed getting felons to buy weapons from me. ATF Agent Warren Newman who spearheaded that Sting enlisted the assistance of Officers Glenn Daniel (currently with the Russellville Police Dept.) and Chris Goodman (currently with the AR State Police). Daisy Edberg a patient of mine, was offered $2,500 if she would buy a machine gun - from me, without proper documentation (see transcription of phone recording, exhibit 1). Similar deals were struck with my patient Richard Herrera, who despite having a felony record was told that his cocaine related charge would be annulled upon his having me sell him a gun (see transcription of phone recording,exhibit 2 ). Deals in the same theme were also made with my patient Julie Hernandez (see transcription of phone recording, exhibit 3), and patients David and Patricia Blevins (see transcription of phone recording, exhibit 4). Rewards were offered to my patient Barry Downs, a felon and an informant, upon his purchasing a gun from me. Feeling confident in his entrapment measures, Agent Newman began bragging publicly as to how he would confiscate all my property, keeping my Dodge Viper for himself as his reward (see transcription of phone recording, exhibit 5). Finally, upon having had enough of these shenanigans I went to the Little Rock ATF Office and personally met with Agent Newman's boss, Mr. Brzozowski. I went into great details describing Agent Newman's activities, requesting Mr. Brzozowski to have Agent Newman quit targeting and harassing me. Also to have the Agents from interfering with my medical practice (see copy of letter, exhibit 6). Despite that, Agent Newman did not back down. I even met personally with FBI Agent Lance Smythe at the Little Rock FBI Office to discuss my predicament and to solicit his assistance. Getting none I even took my plea to DEA Agents Hickman, Bill Bryant and others. That too proved to be an exercise in futility (see transcription of phone recording, exhibit 6). Nonetheless, unable to entrap me, Agent Newman resorted to a new scheme.

The Second Sting Operation entailed attempting to get patients of mine into a sexual relationship with me in order to make me lose my medical license. In addition, if an exchange of drugs took place to go ahead and arrest and convict me. When Daisy Edberg propositioned me, I went ahead and let Mr. Brzczowski know of that endeavor as well. Paradoxically instead of backing down, Agent Newman even sent his own wife, Terry Jacobs, a registered nurse who lived and worked in Little Rock, AR to become a patient of mine, all done with the sole purpose of getting me into an illicit relationship with her and thereby having my medical license revoked. When Terry Jacobs advances were spurned Agent Newman, in a state of desperation, resorted to even more nefarious measures. He embarked on a venture to suborn some extremely damning perjured testimony from my patients. Sums of money, among other deals were offered to patients who would falsely testify that they had sexual relations with me in exchange for drugs provided by me. A patient of mine Amanda Virden, testified at the Arkansas State Medical Board hearings in June 2003, as to how she had been offered $500 by Agent Newman and Officers that accompanied him, just to say falsely that I had sex with her in exchange for drugs that I had provided (see transcription of AS MB hearings, exhibit 7).

Before my trial commenced, Tony Haley and several other Agents once again approached Amanda Virden and paradoxically served her with a subpoena to appear in court as a Government witness. Yet at the same time, she was told to stay away from the actual proceedings and not under any circumstances to make an appearance on her own volition. All this in an effort to keep the defense team from contacting her, for fear of evoking an obstruction of justice insinuation.

Recently after my son Dan Carlton / Mann posted some factual data on the internet regarding the case, Chris Ridenour, one of the Officers who had worked under Agent Newman, was confronted regarding the endeavors to destroy my medical career by having Amanda Virden falsely testify before the ASMB way back in 2003. To that Officer Ridenour very nonchalantly and mockingly replied, "Had we pulled it off back then, he (Dr. Mann) would not have done the bombing...".

Other patients of mine, Shelly Green (see affidavit, exhibit 8) and Asia Montgomery - Wells (see affidavit, exhibit 9) also came forth with how Officers Goodman, Glenn Daniel and John Waid had tried to persuade them to file false reports against me, alleging them having had sex with me in exchange for drugs in order to have their pending legal charges expunged. Brenda Beavers, another patient, claimed that Officer Waid had maliciously slanderer me., telling her that she should find a new doctor if she cared about her health (see affidavit,exhibit 10). Finally getting nowhere with their Sting Operations Agent Newman and his enlisted underlings appeared to have backed down for a while.

Of late, I have made several attempts to get the ATF, under the Freedom Of Information Act to provide me with the details and specifics of these Sting Operations. Yet despite making four separate requests to their Washington, DC and Little Rock, AR Offices neither have they provided me with any information, nor have they even acknowledged any of my requests (see copy of the FOIA requests, exhibit 11).

Numerous attempts were made before and during the trial to serve subpoenas to the ATF Agents in order to get them on the stand. Only under oath and having the threat of perjury looming over their heads, would they have been expected to truthfully answer and clarify the plethora of the quasi-legal and the outright illegal issues that permeated my case. The ATF Agents kept dodging the subpoenas with the process server being unable to deliver them. The Judge was even made aware of this situation and at one time even went as far as threatening to declare a mistrial if the Agents continued to dodge the subpoenas and not make an appearance as was required of them. Nonetheless, the ATF Agents continued to dodge the subpoenas and as a result, avoided taking the stand altogether. Being well aware of the wishy - washy testimony that the Government had presented in my case, my attorneys decided not to push the mistrial option, which of course was not declared (see trial transcript, exhibit 22).

On February 3, 2009, a bomb placed near Dr. Pierce's car, in West Memphis, AR detonated critically injuring him. The ATF had no leads or perpetrators. There was no evidence either in the form of correspondence, e-mails, phone calls or testimony to link me to the act. Yet once again they decided to target me, setting about on a quest to make the means fit the end. To 'make' me the perpetrator of the crime.

Incidentally, a month later, on March 3, 2009 an individual, Mark Rinke while walking through the woods, 300 yards away from my house 'found' a box containing 98 40mm grenades. The Pope County Sheriff's Department arrived upon 911 being called. Pictures were taken by the Officer immediately upon his getting to the scene. The testimony of Mark Rinke was (1) That the box was completely buried in the ground. It getting exposed when he accidently stepped on it. (2) That it took him 20 minutes to 'dig' it up out of the ground. (3) That the pictures were taken by the Sheriff's Department's Officer just 'several minutes' after he 'dug' it out (see transcript of Rinke's and Kimball's trial testimony, exhibit 13 and exhibit 14).

The pictures taken and in evidence show clearly, convincingly and conclusively that (1) That the hole is not 'several minutes' old, but rather weeks to months old. (2) That the hole is not big enough to have accommodated a box the size depicted [ 17 3/8" X 7 1/2" X 14 3/8" ] within it in its entirety. (3) That there is no evidence of any excavation whatsoever, let alone '20 minutes' of it, as was Rinke's testimony. These views have been shared by experts in the fields of Photogrammetry, Soil Science and Crime Scene Recreation. Nonetheless, having independent experts, possibly even those employed by the Department Of Justice evaluate the evidence and render their fair and unbiased opinions will lay further credence to at I am so emphatically alleging: That the box and its contained contraband was never dug out of that hole on March 3, 2009 as was the sworn testimony of Mark Rinke and Ryan Kimball. This was evidence that was fabricated and subsequently planted next to a pre-existing hole in the woods, in order to obtain a search warrant and a conviction (see the enclosed pictures that were in evidence, exhibit 15).

Rinke's subsequent statements to a reporter in an interview revealed some material differences from what was in testimony at trial, in that the box being only 'half buried', so as to explain its not so outlandish coincidental discovery. For a clip of Rinke's interview and the entire trial testimony of Rinke and Kimball see exhibit 19

Further evidence of the planting of evidence is the fact that (1) The DNA and fingerprints found on the grenades were not mine, but instead those of Agent Newman. (2) The box had three sets of finger prints on it. None of those matched mine. (3) The plastic and duct tape that had been used to wrap the box in did not match the plastic and duct tape taken from my premises after a search warrant was promptly issued and executed. Nonetheless, the 8th Circuit Court of Appeals affirmed my conviction citing that very fabricated and planted evidence as being 'overwhelming evidence of my guilt'.

Interestingly, when the latter set of pictures taken by the ATF on March 4, 2009 are viewed alongside the former set taken by the Officer responding to the 911 call on March 3, 2009 and a comparative analysis undertaken, another extremely alarming fact comes to light. Paradoxically, the latter set of pictures taken by the Ari show the hole to be fresher' a day later from the day it was allegedly 'dug' out. The well settled leaves appear to have agitated, the soil loose, the walls of the hole freshened revealing moist soil. That however is not the norm in nature. It is rather obvious, even to an individual of average intelligence that this was yet another attempt by the ATF Agents to alter the evidence in order to make it appear that the hole was indeed, newly excavated. Arguendo, even if the hole was 'unaltered’, it was still not wide enough or deep enough to have accommodated a box of the given diminutions within it, in its entirety. This being yet another example of how far the ATF was willing to go to build a case against me. In that, not only did they plant the evidence, but also took pains to deliberately alter it as well, all to enhance the credibility, which it so obviously lacked.

Recently when the Mayor of London, AR Mr. Edwin Price who also happens to be Mark Rinke's boss, attempted to question Rinke about the questionable testimony and circumstances pertaining to the discovery of the box, Rinke stated, "I was told not to talk about it", before abruptly walking away. Rinke did not provide specifics as to who told him not to talk about the 'discovery' of the box, to whom and as to when he was so instructed.

While I was incarcerated, the Government continued to work desperately in trying to indict me for the bombing on which they had nothing to inculpate me. In line with their creation of the means to fit the end, Assistant US Attorneys Karen Whatley and Michael Gordon along with two ATF Agents approached Hamis Alshareqi / Aisharki (BOP # 25438-009) an inmate who at one time had been housed with me. The Government worked on Alshareqi, threatening, coercing and even bribing him with promises of immigration to provide false testimony derogatory, and inculpatory to me. Coached and prepared, Alshareqi was then taken to the Grand Jury where he conformed to the wishes of the Government. His suborned perjured testimony to the fact that I had confessed to him of my involvement in the bombing and the fact that I had possessed the grenades was instrumental in getting the needed indictment for the Government. A few months later, well before my trial was to commence Alshareqi recanted his testimony. He essentially said that the US Attorneys and the ATF Agents had wanted him to lie as they had no direct evidence against me. That in essence proved to be just the case. In that twenty-page recantation, addressed to the Judge, Alshareqi explains in vivid detail as to how the Government systematically suborned that perjured testimony (see affidavit, exhibit 16)

By recanting, Alshareqi had then become a rather substantial liability to the Government. While at Pulaski County Regional Detention Facility, Little Rock, AR another Government informant, Steven Briscoe managed to provoke Alshareqi into a physical altercation. That event provided the Government the opportunity it needed. Alshareqi was threatened with extreme retribution, possibly even a thirty-year incarceration for ‘assaulting a Government witness with an intent to kill’, if he turned against the Government. Petrified of that consequence, Alshareqi never took the stand. By Alshareqi's not getting to testify, these egregious acts were never brought to light.

After my brother, Sandip S. Mann posted the pictures of the box, the testimonies of Rinke and Kimball from the trial, Rinke's TV interview with its discrepancies and even the entire trial transcript on the internet, the response obtained was overwhelming to say the least. Thousands expressed their sentiments as to how appalled they were that such nefarious conduct could even be introduced into our courts and even shocked that it could have unanimously convinced a jury, in addition to the 8th Circuit Court Of Appeals seconding the Jury's verdict. All that in a Nation renowned for having by far the best legal system in the world. Incensed by my victimization by the Government my son, Dan Carlton (Mann) quit his job where he worked for Tyson in Clarksville, AR so as to spend time ascertaining the truth related to the fabricated evidence. The Private Investigator we had retained before the trial had been unsuccessful in getting to talk to anyone pertinent, and had essentially gotten nowhere. Dan tirelessly canvassed the neighborhoods in London, AR where he took up. a part time job working at Dollar General. He doggedly spread the word around about the bogus evidence and testimony related to it. The conspiratorial agreement between the Government and the two individuals who 'found' and 'dug' up the box was blatantly obvious to all. As the word of the 'set up' spread through the community, increasing number of intrigued people came to Dollar General to meet him, see the evidence for themselves, discus the facts, express their views and opinions in addition to rendering their suggestions. It wasn't before long that Rosa Torres, a resident of London also met my son and learnt about the circumstances and facts behind the discovery of the grenades. She in turn made a mention of the salient facts to Will Elkins, who now was able to put the facts in perspective. Till then, everyone seemed to have the notion that the grenades were found on my premises, dug out of my back yard. Now he knew that wasn't the case. Elkins who way back on March 1, 2009 while working for his boss Donnie Arnold, digging a trench in general vicinity of the woods in the subdivision happened to witness Mark Rinke, Ryan Kimball along with a third individual unknown to him carry and bury a box. The box which had two handles and appeared black (which was the color of the plastic it was wrapped in) was buried and a few hours later retrieved by them from the same general area where the box was 'found' by Mark Rinke on March 3, 2009 (see narrative, exhibit 17)

Now that a growing number people in the community were talking about these new developments, trying persistently albeit unsuccessfully to get Rinke and Kimball to divulge as to what really happened, it did not take long before the ATF got wind of it. The lead Agent, Agent David Oliver and Agent Newman came to London, AR where they interrogated Will Elkins before taking him before a Grand Jury in December 2013. Incessantly targeting my family, this time they endeavored to indict my son, Dan Carlton (Mann) for witness tampering The ATF Agents, understandingly found it incredible that there could have been an eye witness at that early an hour on that particular day. That Will Elkins had to have received some form of compensation for his testimony, which would be in line with the modus operandi of the ATF Agents themselves. That however proved not to be the case. The Grand Jury transcript could be accessed by you.

Becky Kimball, the ex-spouse of Ryan Kimball who had been married to Ryan Kimball back in March 20O9, was another person who my son, Dan met while he had been canvassing in London, AR. Becky recalled Ryan telling her way back when the grenades had been 'found' that a grenade launcher too had been recovered. Recently when Becky text messaged Ryan, feigning the fact that some individuals had been inquiring about the grenade launcher that he had referred to in the past, Ryan got extremely agitated and paranoid stating, "You don't know shit about it. So don't tell them shit". Apparently, Lloyd Hahn, a gun dealer and Government witness who had testified against me at trial under cover of immunity, in his Grand Jury testimony had referred to a grenade launcher that he had sold to me illegally in the mid to late nineties. I can only surmise that way back in March 20O9, the planting of a grenade launcher may very well have been in the works, along with the grenades.

Agent Oliver met with my son Dan when Agent Oliver was in London. Dan was told unequivocally, to cease going around asking questions and digging into the case, that Dan was liable to get himself in trouble if he continued to snoop around, saying, "I don't know why you are still talking to people and investigating this stuff. You need to worry about yourself Dan. Your Dad is never getting out". The threat of retribution was enough to scare my son into backing off. He has witnessed, first hand as to what the capability and capacity of these Agents is. He is only too aware that they are untouchable, above the law, subject to no scrutiny in the normal course of events, go rogue with no regard for the “Due Process" guaranteed by our Constitution. He has witnessed what they did to his mother, Sangeeta Mann for staying by my side through this ordeal. Being realistic, in that we are too small and insignificant to take on the juggernauts that not only represent our Government, but are the Government we decided to solicit the assistance of Investigative Agencies, such as yours.

Recently, Phil Barthelme a witness for the Government came forth to reveal how he had been coerced, before the initiation of my trial, to concoct the testimony that he finally provided. Phil Barthelme had been interrogated at the Russellville Police Station in a room where in the presence of AUSA Michael Gordon, four or five Agents grilled him incessantly. The Agents had, prior to the interrogation, already made up their minds as to what they had wanted Court to hear for the record. Finally, when that didn't materialize even after hours of continuous badgering, the Agents got agitated and irate. Barthelme was threatened with incarceration, in that they would ‘cuff and stuff him’ if he didn't tell them ‘what they wanted to hear’. Being the sole provider of a family comprising of two minor children and a handicapped wife, Barthelme had no choice but to conform to the wishes of the Government. He did what it took, as egregious as it may have been, to keep himself from being incarcerated and his family devastated (see affidavit, exhibit 18)

The Supreme Court has time and again., reiterated, as they did way back in Olmstead v United States, 277 US 438 (1928)... that decency, security and liberty alike demand that Government Officials be subjected to the same rules of conduct that are commanded to all citizens. In a Government of laws, existence of Government shall be periled if it fails to obey the law scrupulously... To declare that in the administration of the criminal law the end justifies the means, to declare that the Government may commit crimes in order to secure the conviction of a private citizen, would bring terrible retribution. Against that pernicious doctrine this court should resolutely set its face.

There is nothing in our legal system that shocks the conscience more than the very Agents of the Government, sworn to uphold the law, go about desecrating it, fueled by prejudice and hatred towards an individual targeting him because of his being different, be it his race, color, accent, way of life or ethnicity.

If you have any questions or if you would like more information, please feel free to get in touch.

My entire family and I would be extremely grateful if you could do everything in your power to have these reprehensible and egregiously corrupt acts investigated and addressed. Thank you for any and all assistance you could provide us in this regard.

Yours sincerely,

Randeep S. Mann (BOP # 24775-009) (9)

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