Randeep S Mann, MD.

BOP #24775-009
United States
Penitentiary
PO Box 24550
Tucson, AZ, 85734
Date: Oct 18, 2019
Steve Womack
Re: Case No 4-09-CR-00099-BSM, United States vs Randeep S Mann
-The fabrication and planting of evidence by the Government/ATF Agent(s) and their confederates, where a box
of 40mm HE grenades was planted near my house and used by the government to obtain a search warrant of my
house, office, and property, to incarcerate me prior to trial, deny my bond, obtain my conviction and that of my
spouse on obstruction of justice charges, all consistent with “fraud on the court”.
-Cover up by the District Court and Eight Circuit Court of Appeals in attempt to keep the “fraud on the courts”
from being litigated and hence exposed, even going as far as calling the overtly fabricated evidence as being
“overwhelming evidence of my guilt”. While at the same time denying me any form of hearing, which prevented
me from exposing the Government’s egregious conduct.
-Prosecutorial misconduct by the United States Attorneys and Assistant United States Attorneys, Eastern District
of Arkansas who along with their confederates in law enforcement, suborned perjured testimony from numerous
individuals, knowingly using it in the legal proceedings, having the executive office for the United States
Attorneys withhold data and documents that I have sought since May 13, 2013, that were withheld by the
government in violation of the brady and Giglio.

Dear Mr Womack,
Having exhausted all available options available to me, despite my having exhibited due diligence to
obtain exculpatory data and documents pertaining to me, which would have assisted me in my establishing my
innocence, my efforts continue to be thwarted and stonewalled, leaving me with no option other than to plead for
your assistance in the following:
A. Having the issues that I am alluding to investigated
B. Obtaining the data and documents that I have sought from the EOUSA, ATF, and USMS which will assist
with the relevant investigations.
Other than that, I have been left with no option but to involve the media, a step that would only make this
quest of mine a dog and pony show, something that would be nothing but counterproductive in the long
run. Recently there has been much in the news media pertaining to the elaborate planning, execution and
coverup by the Saudi government and its Crown Prince, Muhammad Bin Salaam in the killing of one of
its citizens, Jamal Khashoggi. The egregiousness of that act is along the same lines as to what the US
Government did in my case, with perhaps the only difference being that unlike Jamal Khashoggi, I am
still alive even though serving a life sentence in a US Penitentiary.

Background:

My targeting by the ATF Agents and their confederates from other State and Federal law enforcement
agencies began shortly after I moved to London, Arkansas in 1999 setting up my Medical practice in
adjoining Russellville, Arkansas, when Special Agent of the ATF Warren Newman came under the
mistaken belief that his niece, Ellie Harris, had overdosed on medication that were obtained from me, and
that I was somehow responsible for her death.

Numerous Sting Operations were conducted by Agent Newman and his confederates in an attempt to
make me violate the law over the ensuing years. All of them were aborted as they were unsuccessful in
their goal of making me succumb to them.

On Feb 3, 2009 an explosion in West Memphis, Arkansas led to Dr Pierce being injured. A month later, a
box of 40 mm HE grenades was “found and excavated” by two individuals, Mark Reinke and Ryan
Kimbell. There was vehement testimony from them at my trial in that
a. The box that contained 98 of the 40mm HE grenades was completely buried in the ground.
b. That it took them 20 mins of excavation to get it out of the ground
c. That the pictures of the scene of the “finding” were taken by Office Smith of the Arkansas Police a
few minutes later after the 911 call was placed.
The photographs were evaluated by three PhD’s in the fields of Soil Science/Geology, Botany, and
Photogrammetry. In addition, there was a crime scene recreation at the same site of the “finding” where
an identical box was buried and subsequently excavated.
Dr West observed that the soil surrounding the depression in the Government’s pictures was tan to brown
color, whereas the soil in the clearing was red with clay which was below 3 to 5 inches. That was
identical to the soil surrounding the 2014 scene recreation, where the hole was large enough to hold the
container. The soil surrounding the 2014 scene recreation where the hole was large enough to hold the
container. The soil surrounding the depression appeared to have been “walked-on or rained on for some
time” concluding that the hole in the Government pictures was not “freshly dug”.
Professor Dr Spiegel found the soil in the depression in the Government’s pictures to be “clearly
weathered, more than would be consistent” with its having been “opened in the previous few hours”. The
depression in the Government’s exhibits is “not a freshly dug or freshly opened hole, but had been open
for at least several weeks before the pictures were taken”. It would have taken that long for the leaves in
the hole to be consistent with those surrounding the hole. In addition, the leaves in the bottom of the hole
in the Government’s pictures are “substantially less flattened and fragmented” than those for only two
days under a weighted cannister of the same size and shape as the actual exhibit when it contained 98
grenades.
Professor Dr Hung used photogrammetry to extrapolate from a) the length in pixels and hence inches of
objects of known dimensions in Government’s pictures to b) the dimensions of the depression. Using an
ATF ruler and a piece of in the Government’s exhibits as reference objects, he calculated that the
depression “could be no more than 10.231 inches deep”, which would have been the hypotenuse, the side
wall of the depression, and not even the vertical depth.
The Government could not obtain expert opinions in any field to refute what the experts have stated based
on scientific facts and principles.
The issue is rather basic and even a fifth grader of average intelligence could infer that a) there was no
excavation, let alone 20 minutes of digging, as Rinke and Kimball had claimed. b) That the hole was not
a few minutes old, but rather an old depression that had existed at the site for weeks or months and c) that
it was not big enough to have contained within it its entirety a box the size depicted in the governments’
pictures, the box being 18.5 inches in length, 7.5 inches in with and 14 to 15 inches in height as its
internal dimensions.
The Eighth Circuit Court of Appeals claimed this very fabricated evidence as being “overwhelming
evidence of my guilt”. The District Court refused to allow an Evidentiary Hearing on this matter, which
would have answered a lot of questions about the “fabrication and planting” of the evidence which would
have been scandalous, exposing egregious conduct of the ATF officers, US Attorneys, and those who
participated in the endeavour which was clearly and convincingly “Fraud on the Courts”.
This coverup is no less egregious than the planning, killing, and coverup associated with the killing of
Jamal Khashoggi by Government entities, with the only difference being that in my case there was an
attempt to legitimise it through the Court System. In denying me even an Evidentiary Hearing, the
District Court stated a) that I was time barred in raising the 5 th Amendment Violation issue as my
Trial/Direct Appeal attorneys had not raised the issue in my Direct Appeal, and that I was now time
barred, b) as regard to the 6 th Amendment violation as it related to ineffective assistance by my Trial
Counsel, the Court ruled that not obtaining experts and raising the issue of evidence fabrication and its
subsequent planting by Govt entities would not have been believed by the jury, making me appear as if I
were a crank, something that would have led to my conviction of the more serious bombing charges, for
which there was no evidence and that c) I could raise the issue in a subsequent “actual innocence” claim,
which would in any circumstance be a high hurdle to cross. With the government withholding my FOIA
data and document request and its various agencies withholding data under the guise of it being “exempt”
from being released makes my job of proving my innocence even harder, if no entirely impossible. This
has become a catch-22 issue for me, despite the fact that data I am seeking has been withheld from me in
violation of Brady and Giglio. This is data that I was slated to receive prior to the commencement of my
trial.
One does not have to be an expert or hold a PhD in any relevant field to apply common sense when
viewing the Government presented pictures. There is no way that individuals with superior IQs such as
the US District and Circuit Court judges could have missed the overt findings of fraud. They simply just
wanted to coverup for their government confederates. There is no other plausible explanation for their
turning a blind eye to such obvious findings.

The hole/depression in this

picture, taken from nearly
5 feet, is not or barely
discernible, despite the
claims of it being freshly
dug. The date is March 3,
2009 with the leaves
having fallen in fall,
months earlier and not just
minutes earlier while the
“digging” was in progress
or had been done. A
freshly dug hole would
have stood out like a sore
thumb, being visible from
a distance
 Another picture of the box
in relation to the hole
reveals as to the size
discrepancy of the two.
There is no possibility that
a hole of the size depicted
could even hold that box
within it in its entirety.
Again, the hole appears
well camoflauged on
account of the leaves
having fallen in it over the
past few months or weeks

A close-up view of the

hole reveals the dirt at the
bottom to be wet. The
leaves at the surface are
dry whereas those deeper
are moist. There is no
physical trauma to any
leaf. One leaf even shows
evidence of decay. Not a
spoonful of dirt anywhere,
let alone any evidence of
20 minutes of excavation
having taken place. Even
a stick with a lichen growth
on it has no dirt stain on
it.
With the box having been
removed, the dirt around
the hole is noted to be dry,
trampled and compacted
on the right side of it.
None appears at any other
side where the carpet of
leaves covers the forest
floor and the hole. Any
excavated dirt would have
been wet in conformity
with the dirt in the depths
of the hole.
 Another view with the box
having been removed helps
in comparing the dirt Rinke
alleges to have excavated
from the hole with the dirt
in the hole. As is obvious
the reddish dirt to the right
is different both in
composition and degree of
hydration as compared to
that in the hole, making it
obvious that the said dirt
did not come from the

In granting any form of hearing, the District Court successfully kept issues from being litigated, investigated, and
hence exposed, such as:
1. Why were there no fingerprints or DNA of mine on the box or grenades?
2. Why were there three sets of fingerprints on the box in question, and as to whom they belonged to, as
none belonged to anyone known or associated with me?
3. Whose fingerprints showed up on the other 5 boxes in my possession?
4. Whose fingerprints were on 2 identical boxes possessed by Gerald Riley, a government witness, who
claimed to have dropped off the boxes in my garage in my absence months earlier?
5. Why there were no fingerprints or DNA of Rinke and Kimbell on the box or grenades despite their not
having used any protective gloves when they did their alleged “excavation”?
6. Why were there fingerprints and DNA of ATF Agent Warren Newman on the grenades when he
would have used gloves and protective clothing when he conducted his analysis? (This was the very
same Agent who was responsible in conducting the Sting Operations, paying witnesses to render
false testimony against me, trying to entrap me to violate the law, and more)
7. Why the plastic sheeting that the box was wrapped in did not match the sheeting that I had in my
possession or in my flower bed?
8. Why the duct tape on the box did not match the duct tape that I had in my possession?
9. Why was there no DNA from the fauna and flora in the woods on the grenades despite the fact that they
had been allegedly removed from the box prior to AR State Police being called?
10. Who all had or could have had access to the boxes as they lay in my garage, where Riley claimed to have
placed them, if indeed the box did actually once belong to me?
11. Who removed the box from my premises, and at whose behest, if indeed the box in the woods was one
that Riley placed in my garage?
12. How did the box come to be in the possession of Rinke and Kimbell as it certainly, as forensic evidence
and expert opinions showed, was not excavated from the hole in the woods?
13. Who provided the 40mm HE grenades to Rinke and Kimball?
14. What was the actual source of the grenades?
15. What instructions were given to Rinke and Kimball? What promises were made to them? What rewards
were given to them for their role in the fabrication?
16. Why the ATF still has the grenades in their possession, in violation of storage protocols when they were
supposedly diverted from the US Army way back in the 1970’s?
17. Why the K-9 who was capable of detecting explosives from the distance of a mile could not detect the
presence of explosives in the “fabricated” hole?

There are more questions in this case than answers. This case has uncanny similarities to the Khashoggi
case. Only the Government did not use a bone cutting saw to do their coverup, they used the court system
in an attempt to show a degree of refinement over the Saudis.

I can assure you that no matter how hard you try, given your influence, power and position, you will not
be able to get either Rinke or Kimball, or ATF Agent Warren Newman, the principal actors in this crime,
to talk or interact with you. It does not take one to be a genius to figure out that a crime was committed
by the Government and its confederates and their talking with you would defy the basis laws of self-
preservation.

I would greatly appreciate if you could either;

a) Assist me in getting the FOIA data and documents from the Executive Office for the US Attorneys,
United States Marshall’s Office, and the ATF that I have been asking for since May 2013, as my
requests even after my showing a “compelling need” for them continue to be ignored or
b) Have investigated the matter of “fabrication and the planting” of evidence resulting in Fraud on the
Courts. I am willing to cover the cost of any investigation into this matter which borders on being a
Human Rights violation by officers of our Government.
This is only the tip of the iceberg as there are numerous other issues that arose when the Government
chose to alter the facts to make the means justify the end. Do contact me if you have any questions or
queries or if I could assist you in any way.
Sincerely yours,
Randeep S Mann, MD.
I, Randeep Singh Mann, MD, declare under penalty of perjury, as authorized by 28 USC 1746 that the
foregoing is true and correct to the best of my knowledge and belief.
Date: October 18, 2019