Greetings and Salutations,

When one raises allegations of false statements, forgery of public records, bribery, alteration and destruction of court records, falsification of court records, witness tampering and intimidation, victim tampering and intimidation, fraud upon the court, enterprise RICO conspiracy, civil rights conspiracy, or any related offense, the burden of proof is intentionally set high to guard against misuse. When such allegations implicate members of the judiciary, that burden reaches its highest point, reflecting the institutional gravity of the accusation.

Fully aware of this, I have not proceeded on presumption, inference, or belief. My standard has been absolute certainty. Yet even absolute certainty can be tested where complex legal analysis or voluminous evidentiary records make it difficult to distinguish deliberate deception from error.

The only viable solution is to reduce the question to one of binary truth: it either is or is not; it happened, or it did not; the statement is either true or false. There is no room for interpretation, no shades of gray, no marginal deference, no interpretive elasticity. The proof must render the matter black or white—because in cases involving judicial fraud or corruption, anything less is vulnerability by design.

District Judge Brendan A. Hurson was added as a defendant, in both a personal and professional capacity, in February 2025. The ongoing investigation has now yielded more than sufficient evidence to name the following individuals in both a personal and professional capacity:

1. Chief Circuit Judge Albert Diaz;
2. Circuit Judge J. Harvie Wilkinson III;
3. Circuit Court Clerk Nwamaka Anowi; and
4. U.S. Marshal Louie McKinney Jr.

Their conduct further undermines public confidence in the judiciary and foreseeably heightens security risks to judges and their families. It reflects a disregard for the institution and the duties imposed by their oaths. They have therefore forfeited the due deference, courtesies of office, honorifics, and other protocols ordinarily accorded.

“After inviting them to attend the judicial conference”
To date, no attorney has appeared for any party in the federal action. In context, “them” follows “a vendor,” yet the sentence then describes that “vendor” as “attorneys involved in his civil lawsuit,” obscuring Judge Wilkinson’s assertion that the Fourth Circuit invited the defendants—Miles & Stockbridge, P.C., and Robert S. Brennen—to an invitation-only judicial conference. Extending such an invitation to one side necessarily entails ex parte contact with “parties or counsel for one side,” which is cognizable misconduct under Rules for Judicial-Conduct and Judicial-Disability Proceedings R. 4(a)(1)(C) and R.4(a)(7). In May, Chief Judge Albert Diaz identified Judge Brendan A. Hurson as “the judge” the Case Manager said had full custody of the original filing and gave “directions to court staff as to how the contents of a CD-ROM should be docketed”. Mr. Hurson’s instructed the Case Manager to upload altered exhibits rather than complete copies from the signed physical CD, with a filing date a week later. Neither court has produced the missing originals, including those with wet-ink signatures. These admissions, coupled with knowingly false statements designed to defeat the complaint and “protect” the accused, establish substantial merit and constitute interference under R. 4(a)(5). Destruction and alteration of court records and obstruction of justice are “various criminal acts”; coordinating to conceal them satisfies “participating in a conspiracy”. Finally, the show-cause order violates the First Amendment by imposing sanctions without prior notice and an opportunity to be heard.
Miles & Stockbridge Reception: Exhibit 402-T, at 179 [LINK]	July 28, 2025, Wilkinson Order: Exhibit 501T, at 3 [LINK] July 28, 2025, Wilkinson Order: Exhibit 501T, at 6 [LINK]	May 27, 2025, Diaz Order: Exhibit 501G, at 5 [LINK] May 27, 2025, Diaz Order: Exhibit 501G, at 5 [LINK] Hurson’s Falsifcation And Alteration Of Government Records: Exhibit Series 503 [LINK] Hurson’s Over 2 Million Dollars Of Unreported Income: Exhibit Series 502 [LINK]

“No evidence whatsoever”
On July 8, 2025, Circuit Court Clerk Nwamaka Anowi acknowledged receipt of a judicial-misconduct complaint against Judge Brendan A. Hurson and other judges. On July 10, Ms. Anowi—and on July 28, Mr. Wilkinson—recast it as a complaint against every Fourth Circuit judge and every District of Maryland judge, “except the presiding district judge.” On July 8, Ms. Anowi said the zip-filed evidence was “inaccessible due to its size and format,” then on July 10 confirmed receiving “multiple exhibits.” Yet on July 28, Mr. Wilkinson asserted there was “no evidence whatsoever.” Failure to report or disclose is cognizable misconduct (R.4(a)(6)); a “complaint” includes “information from any source” (R.3(c)); and failure to comply with the complaint process is likewise misconduct. R. 4(a)(5). Mr. Wilkinson then repeated claims of “no evidence whatsoever,” “lacking evidentiary support,” and “baseless claims” to support a show-cause order imposing permanent prohibitory sanctions. Sanctions that restrict speech or filings are punitive, not corrective; used this way, they operate as criminal, not civil, sanctions, aimed at the First Amendment right to petition and shielding ongoing misconduct.
July 28, 2025, Wilkinson Order: Exhibit 501T, at 3 [LINK] July 28, 2025, Wilkinson Order: Exhibit 501T, at 4 [LINK]	July 7, 2025, Complaint: Exhibit 501J, at 1 [LINK] 2025July7-combined-hurson-dcmd-4^th-judicial-complaint.zip: Downloadable Zip [LINK] July 8, 2025, Anowi Letter: Exhibit 501K, at 2 [LINK]	July 8, 2025, Exhibit 401 (Email 1 of 4): Exhibit 501L [LINK] July 8, 2025, Exhibit 402 (Email 2 of 4): Exhibit 501M [LINK] July 8, 2025, Exhibit 403 (Email 3 of 4) Exhibit 501N [LINK] July 8, 2025, Exhibit 404 (Email 4 of 4) Exhibit 501O [LINK] July 9, 2025, Anowi Letter: Exhibit 501P, at 2 [LINK] July 9, 2025, Inquiry to 4^th Circuit Exhibit 501Q, at 2 [LINK] July 10, 2025, Anowi Letter: Exhibit 501R, at 2 [LINK]

“Implies” allegations of retaliation from district court filing intended to intimidate
Mr. Wilkerson asserts that the statement “it is retaliation, it was intended to intimidate me” was only implied. On June 25, 2025, data-size limits required Exhibits 402 and 403 to be divided into four parts each. On June 27, the Case Manager began docketing the exhibits and called to confirm their entry. The return call at 11:44 a.m. coincided with docketing Exhibit 403. Before Exhibit 402 could be docketed, “the courts reached out to” the U.S. Marshals, who then arrived at the private residence of Ryan Dillon-Capps. Three vehicles were identified; agents in a red vehicle parked at a neighbor’s property, unaware of newly installed cameras, including one aimed at that location. One agent, taking a route to avoid perceived camera coverage, spoke with the neighbor, instructed them not to notify Dillon-Capps, and provided Louie McKinney Jr.’s business card. The other two agents approached Dillon-Capps’s front door and left without notice or documentation. Local FBI and Secret Service offices denied knowledge of the visit.
June 25, 2025: District Size Limits Exhibit 506D, at 1[LINK] June 25, 2025, MDD Submitted 401 Exhibit 506E, at 1 [LINK] June 25, 2025, MDD Submitted 404 Exhibit 506F, at 1 [LINK] June 25, 2025, MDD Submitted 402 (All 4) Exhibit 506G, at 1 [LINK] June 25, 2025, MDD Submitted 403 (1 and 4) Exhibit 506H, at 1 [LINK] June 25, 2025, MDD Submitted 403 (2) Exhibit 506I, at 1 [LINK] June 25, 2025, MDD Submitted 403 (3) Exhibit 506J, at 1 [LINK] June 27, 2025, @ 11:31 AM MDD Docket 45 (401) Exhibit 506K, at 1 [LINK] June 27, 2025, @ 11:34 AM MDD Docket 46 (404) Exhibit 506L, at 1 [LINK] June 27, 2025, @ 11:44 AM Phone Call w/bw5s Exhibit 506U, at 1 [LINK] June 27, 2025, @ 11:44 AM MDD Docket 47 (403) Exhibit 506M, at 1 [LINK]	June 27, 2025, @ 3:14 PM USMS Exhinbit 506R, at 1 [LINK] June 27, 2025, @ 3:15 PM USMS Exhinbit 506S, at 1 [LINK]	July 28, 2025, Wilkinson Order Exhibit 501T, at 3 [LINK] July 8, 2025, Refiled Complaint 1of4 Exhibit 501L, at 117[LINK] June 27, 2025, McKiney Jr. Card Exhibit 506R, at 2 [LINK]

On June 28, McKinney replied to a prior evening’s text from Dillon-Capps using an invisible tracking pixel that traversed Verizon’s, Sybase365’s, and AT&T’s networks before reaching a “honeypot.” This unofficial use of government resources crossed state lines to an intercarrier facility in Virginia before delivery to a privately owned device, which was then searched without a warrant or lawful basis. The Marshals’ conduct has expanded the scope of discovery and depositions to include the Marshals Service, telecommunications and internet providers, and intercarrier entities, based on their participation in a conspiracy to interfere with civil rights, failure to intervene, and engagement in RICO-defined predicate acts in furtherance of the enterprise conspiracy. On July 1, Exhibit 402 was docketed; on July 2, Exhibits 404 and 402 were altered. I have no access to the records and present no evidence beyond the fact that alterations occurred on July 2. Shortly thereafter, the Fourth Circuit Court Clerk asserted that a complaint filed in the Fourth Circuit should reference the District Court docket—even though the complaint concerns court record tampering in the District Court for a case that has been on stay since February 20, 2025. Pages 118–124 of Exhibit 501L contain the final portion of the judicial complaint: a condensed table of exhibits with citations to exhibit numbers and corresponding page references. According to Anowi, these dozen pages of citations should match the District Court’s records.

June 28, 2025, McKinney Jr. Text Exhibit 506D, at 1[LINK] June 28, 2025, 401&404 to U.S. Marshals Exhibit 506A [LINK] June 28, 2025, 402 to U.S. Marshals Exhibit 506B [LINK] June 28, 2025, 403 to U.S. Marshals Exhibit 506C [LINK]

July 1, 2025 @ 3:24 PM Docket 48 (No Doc) Exhibit 506N [LINK] July 1, 2025 @ 3:28 PM Docket 48 (402) Exhibit 506N [LINK] July 2, 2025 @ 8:29 AM Docket 46 (404) – UNAUTHORIZED UPDATE Exhibit 506N [LINK] July 2, 2025 @ 8:30 AM Docket 48 (402) – UNAUTHORIZED UPDATE Exhibit 506N [LINK] July 8, 2025, Anowi Letter: Exhibit 501K, at 2 [LINK] June 25, 2025, MDD Exhibit 401—Exhibit 401 through 404 details Exhibit 501L, at 118–124 [LINK]

Formal Challenge of 4th Circuit Court Involvement and Judge Ishida’s Signature
I am challenging the authenticity of the signature on the July 28, 2025, document purporting to be issued by the Fourth Circuit Judicial Counsel and signed by Circuit Executive James N. Ishida. If Mr. Ishida affirms that the document and signature are his and that it was issued on behalf of the Fourth Circuit Judicial Council, I will proceed accordingly. Given the irregularities in both the document and the signature, and as the potential victim, the initial determination of authenticity rests with Mr. Ishida.
July 28, 2025 “Order” claiming to be signed by Judge Ishida Exhibit 501S, at 5 [LINK]	2023 Genuine Order and Signature of Judge Ishida Exhibit 501W, at 1 [LINK]

Mr. Florino Whitwell & Mr. McKinney Jr.
After the U.S. Marshals were unlawfully dispatched by the judiciary, I, Ryan Dillon-Capps, had three primary objectives: 1. Verification of Procedural Compliance Confirm whether required protocols were followed, including notice to local FBI and Secret Service field offices. Adherence indicates deception; intentional deviation indicates complicity. 2. Raise the Alarm from within the U.S. Marshals Identify any USMS member with the requisite background. Mr. Florino Whitwell (formerly, Investigative Operations Division) fit that profile. Exhibit 506S, at 1–2, confirms he is not the person at the door, and the data strongly supports a conclusion that Mr. Whitwell’s inclusion is responsible for stopping Mr. McKinney Jr., and the acceptance of the judicial complaint. Leading to Wilkerson and Anowi’s efforts to create the appearance that the complaint had been forwarded appropriately. If Mr. Whitwell is responsible, I express appreciation and apologize for his temporary inclusion by name as part of a necessary ruse. 3. Clarification of Mr. McKinney Jr.’s Identity and Role. Exhibit 506R, at 1–2, shows the person approaching my neighbor’s residence is unlikely to be Mr. McKinney Jr. My text to McKinney tested whether he was involved, or his credentials were being misused. The responding text with the tracker confirmed his complicity and awareness of illegality. My responding email asserted that “I have possessed the home address of all subjects under investigation” with preloaded evidence of Mr. Hurson’s home purchase. Compared to the publicly posted conference information, the lack of follow up from what was provided in response to the tracker being sent renders McKinney’s assertion of causation and any plausibility of legitimacy completely refuted because there was no phone call, no follow up text or email, and even when prompted McKinney Jr. has refused to communicate any further.	June 28, 2025, Email to U.S. Marshals Exhibit 506A, at 1 [LINK] (the strike out text represent a truthful correction)
Exhibit 506R, at 1–2 [LINK]	Exhibit 506S, at 1–2 [LINK]

Respectfully Submitted

August 11, 2025	/s/ Ryan Dillon-Capps	1334 Maple Avenue Essex, Maryland 21221 ryan@mxt3.com 703-303-1113
	Ryan Dillon-Capps