The First Motion Guertin Ever Filed Was a Discovery Demand. The Second Was a Motion to Compel. Every Motion After That Was the Same Fight.
Guertin's first-ever court filing, dated January 5, 2024, is a one-page pro se letter to Assistant Hennepin County Attorney Jacqueline Perez formally requesting four items under Minnesota Rule of Criminal Procedure 9: all Brady material, squad video, audio tapes, and "all 104 police photographs (as is listed in Dr. Jill Rogstad's 'Confidential Forensic Evaluation Report')" in their original, non-compressed digital format. Perez did not respond.
Three months later — April 4, 2024 — Guertin filed a 40-page pro se Motion to Compel Discovery with an Affidavit of Fact and 13 supporting exhibits. The exhibits catalog specific anomalies in the 80-photograph set that his first defense counsel Michael Biglow had emailed him on August 3, 2023 after the civil commitment hearing. Missing images. Systematic cropping. Duplicate frames disguised as unique. Image rotation confirmed via lens-distortion analysis.
Nothing happened. The state did not respond. The court did not rule.
Over the next four months, every filing was pro se. Every filing centered on fraudulent discovery:
- May 3, 2024 — Follow-up correspondence reiterating the April 4 Motion to Compel, Motion for Judicial Notice, and Motion to Compel Production of Medical Records. None had been acknowledged.
- May 10, 2024 — 21-page Petition for Discretionary Review filed in the Minnesota Court of Appeals (case A24-0780). Five issues raised; all five anchored in the discovery fraud and circular handling analysis.
- May 15, 2024 — 43-page Petitioner's Addendum 2 repackaging the Motion to Compel for the appellate record; 31-page sworn Affidavit of Fact presenting a Python-scripted analysis of 3,556 MCRO PDFs across 163 Hennepin County cases.
- June 3, 2024 — Brief follow-up letter; Motion for Substitute Counsel; 5-page Renewed Motion to Compel Discovery. Same day. Three filings. All pro se.
No response. No ruling. No materials produced.
On July 8, 2024, Guertin filed a federal civil rights complaint under
42 U.S.C. §§ 1983 and 1985 in the U.S. District Court for the District of
Minnesota (0:24-cv-02646-JRT-DLM) naming Hennepin County, the Minnesota Attorney General,
the Hennepin County Attorney, Assistant County Administrator Chela Guzman-Weigart, two referees, two Rule
20 evaluators, Perez, and Bruce Rivers as defendants. Nine days later — under the pressure of being
personally named as a federal defendant — Rivers handed Guertin a USB flash drive containing a
second set of discovery materials.
It was missing the same 28 images Guertin had initially flagged as cropped.
Exhibit Y — The Logic Trap
On September 2, 2024, Guertin filed Exhibit Y in the federal case. Seven pages. Three parts. The argument, rendered verbatim from the filing:
This was on the federal docket in September 2024 — five months before the March 5 hearing. Every defendant named in the federal case, including the Hennepin County Attorney's office, had notice of the trap.
The Second Round of Fabrication
The state's response — produced through the Hennepin County Public Defender's Office via OneDrive on February 13, 2025 — was a new discovery set that restored the 28 missing images. But all 20 of the photographs that had previously shown measurable non-uniform aspect ratios (1:1.696, 1:1.734, 1:1.620) now appeared in uniform 16:9. Every inconsistency smoothed. Every anomaly uniformed. The images had been physically compressed — some by as much as 8.75% horizontally — to make them match.
Guertin caught it in five days.
Meanwhile: The Two Rule 20 Reports
While Guertin was fighting for discovery for sixteen months, two court-appointed psychological evaluators were writing reports for the record that pathologized the fight itself.
Dr. Adam Milz · Rule 20 Report · January 11, 2024 — filed six days after Guertin's first discovery demand:
Treatment recommendation: antipsychotic medications.
Dr. Katheryn Cranbrook · Rule 20 Report · December 20, 2024 — written without a single clinical interview of Guertin:
Treatment recommendation: neuroleptic medications.
Both reports — it was later forensically authenticated at
/2nd-and-3rd-rule20-reports/ — carry the same Anne Hines author metadata,
the same Adobe XMP Toolkit fingerprint, and the same Microsoft: Print To PDF producer string.
Neither doctor wrote the report that bears their name. But both reports cite Guertin's
belief in fraudulent discovery as the symptomatic basis for the schizophrenia-spectrum diagnosis that
would authorize forcibly injecting him with antipsychotic medication.
This is the spine. The criminal case paused while Guertin fought for discovery. The fight for discovery was cited as evidence he was too psychotic to stand trial. The psychotic-diagnosis report recommended forced medication. The medication would be administered on the basis of the belief that the fraud existed. On March 5, 2025, the state admitted the fraud existed.
11,451 Lines of Forensic Substantiation. Pro Se. Five Days Before the Hearing.
Guertin did not file general objections. He filed proof.
Filing 122 — Exhibit List A–E · 4,001 lines. Mathematical proof of aspect-ratio tampering. Twenty photographs with measurable original aspect ratios (1:1.696, 1:1.734, 1:1.620) all retroactively converted to uniform 16:9 in the February 2025 OneDrive production. A 40-image flipbook pairs each manipulated image with its reference — designed to be viewed in page-flip mode so manipulation becomes visually obvious.
Filing 123 — Exhibit List F–J · 3,890 lines. Five independent forensic analyses using homography transformation, pixel measurement, and metadata evaluation. The standout: Exhibit G cross-references Guertin's own US Patent 11,577,177 technical drawing ("FB – Fans") that physically appears on the wall in the discovery photograph. The patent drawing — already a precision-aligned digital artifact — becomes the geometric reference for measuring the compression. Result: 4.6% to 8.75% horizontal compression, consistent across multiple images.
Filing 124 — Exhibit List K–L · 2,525 lines. Specialized vector tracing using US Patent D727,456S (Hexmag magazine) as geometric reference, plus a flash-and-shadow forensic analysis. EXIF metadata claims an iPhone 12 with flash "Did not fire"; the hard shadows and light-ray geometry contradict the metadata.
Filing 125 — Exhibit List M–Q · 1,035 lines. Motive framing tied to US Patent 11,810,254 (Netflix) citing US 11,577,177 (Guertin) at the top of References Cited. Not central to the March 5 discovery-fraud argument, but establishes why every other party in the case had motive to keep the fraud buried.
What exists on the public docket five days before the hearing: the mathematical proof of aspect-ratio tampering, independent forensic substantiation using established image-forensic techniques, metadata-vs-physical-evidence contradictions, and the strategic motive frame. 11,451 lines. Four filings. All pro se. All bearing Guertin's signature. The defense team has it. The prosecutor has it. The court has it.
The Defense Framed the Fraud. Hamid Acknowledged It. Donnelly Buried the Exhibits.
This was Guertin's first opportunity in the entire 26-month case to testify under oath. Donnelly's opening framing on the record (Card 9):
Guertin testified for hours. On direct, he described — in his own words — the trap he had pre-filed into federal court in September 2024:
The Hamid Cross-Examination
Ms. Hamid did not contest a single substantive claim about the photographs. Instead, she acknowledged the problem and planned her trial strategy around it on the record:
MS. HAMID:Yeah, so you said that these photos have a problem; is that correct?
MR. GUERTIN:Yeah, they have a problem.
MS. HAMID:If you disagree with your attorney that the photos are not a problem how would you go about — when those photos are introduced in court?
… [Court rephrases the question] …
MS. HAMID:Yes, I'm just giving you a scenario in a situation where that would happen, you know, those images that you disagreed with will be admitted into court and will be in evidence against you, how would you handle that?
Read it three times. The Assistant Hennepin County Attorney — on cross-examination, at a contested competency hearing, in front of a Minnesota district court judge — is asking the defendant how he will behave when the state introduces the same photographs he has just proven to be manipulated. She does not deny the manipulation. She does not contest it. She plans her trial strategy around it on the record. "Those images that you disagreed with will be admitted into court and will be in evidence against you."
The Burial
After closing arguments, while the court reporter logs the exchange as "housekeeping," Donnelly puts the following on the record (Cards 333–339):
MR. DONNELLY:Can I say one thing?
THE COURT:Sure.
MR. DONNELLY:One piece of housekeeping that's left undone is the exhibits that were filed by Mr. Guertin on Friday... He did reference in his testimony what he thought the relevance of those were. Those weren't really offered here or were discussed, and I don't think we need to offer them outside of the record that has already been made.
THE COURT:Okay. So just the testimony about it?
MR. DONNELLY:I think so.
The attorney who had framed the doctored-discovery claim as the basis for finding his own client competent affirmatively withdrew all four pre-filed forensic exhibit lists from the formal evidentiary record. The 11,451 lines of forensic proof became invisible at the moment they were about to become evidence. Only Guertin's testimony about them remained — testimony that, per Cranbrook's report, is itself the diagnostic indicator of psychosis.
Koch Found Guertin Competent Anyway.
Twenty-nine days after the hearing, Judge William Koch issued a 12-page order finding Guertin competent to proceed. In the context of the Hennepin County record, the order is an outlier on its face: of 157 incompetency orders in the forensic corpus, 75.2% contain zero unique text — their entire substance template-cloned from prior orders. Koch's order is one of only two in the entire cohort with individually reasoned legal analysis engaging the specific facts of the case.
The state did not appeal. Under Minnesota Rule of Criminal Procedure 20.01 subd. 7, restoration of competency returned the case to the criminal calendar. The Motion to Dismiss was next.
Twenty-six days later, Judge Sarah Hudleston vacated Koch's finding from the bench without touching the order itself.
50 Pages. Pro Se. Four Statutory Grounds. The Discovery Fraud on Every Page.
Guertin filed the Pro Se Motion to Dismiss With Prejudice (Filing 131 · 2,231 lines) on April 16 — the day before his first criminal-court appearance in front of Judge Hudleston. Four statutory grounds: Minn. Stat. §§ 609.66(1a)(3) and 609.667(3) on the underlying firearms charges; Sixth Amendment speedy-trial under Barker v. Wingo; Fifth and Fourteenth Amendment due process. The motion's operative core is Section IV — the discovery-fraud section — which tracks the Set A → B → C → D photograph chain exhibit-by-exhibit, cross-referenced to the Feb 28 filings and to the Rule 20 reports that pathologized the fraud claim.
Self-framing from the motion itself:
The motion's "Diagnostic Inversion" passage names the precise trap:
"Frivolous Motions." Without Having Read It.
At the first criminal-court appearance, Guertin asked the court to consider the pro se Motion to Dismiss on its merits. Donnelly's statement on the record (Card 8):
Hudleston's response on the record (Card 15) — her stated legal basis for declining to consider the motion:
Hudleston — on April 17, in open court — framed Guertin's pro se Motion to Dismiss as presumptively frivolous. She characterized Donnelly's refusal to advance it as the ethical obligation of an officer of the court. She declined to read it. She set the next hearing for April 29.
Twelve days later she reversed herself — citing the same motion as the basis for the reversal.
She Acknowledged the Logical Victory on the Record. And Ordered the Fourth Rule 20 Anyway.
The decision was pre-made. The hallway conference before the hearing — recorded, captioned,
preserved in the 2025-04-29 card set — opens with Raissa Carpenter informing Guertin
(Card 1):
On the record, Hudleston acknowledged Guertin's intellect (Card 36):
The Read-Receipt Problem
The single most surgical exchange of the hearing is Hudleston's own admission on the record (Card 38):
On April 17, Hudleston framed Guertin's motion as presumptively frivolous — under the theory that his attorneys were sworn not to advance motions without "a sound legal basis" — and declined to read it. On April 29, she stated she had read it and was using it as her basis for ordering a fourth Rule 20 evaluation.
She called it frivolous without reading it. Then she read it and found that reading it proved he was mentally ill. Both of those cannot be true at once. The second of them is the operative ruling.
The Acknowledgment of the Logical Victory
Card 58, Hudleston on the record:
The judge acknowledged, on the record, that Guertin had won the logical argument. She then ordered a fourth Rule 20 evaluation anyway — because "my decision is made."
Guertin's reply (Card 59):
The Hamid Perjury
Card 56. Verbatim from the transcript:
THE COURT:Also with regard to Mr. Guertin's assertions about doctored manipulated initial discovery, do you know — can you speak to that?
MS. HAMID:No, Your Honor. The state is not aware of any of that information.
THE COURT:Okay. Do you know what I'm referring to when he said some initial images were mathematically incorrect and altered, and then when compared to later discovery they were inconsistent?
MS. HAMID:Yes, Your Honor. It was part of the competency hearing, and it was briefly discussed during that hearing. But the state is not aware of any manipulation of the evidence, Your Honor.
Two consecutive answers. In the same exchange. From the prosecutor whose own cross-examination of Guertin on March 5 contained the words "those photos have a problem" and the phrase "when those photos are introduced in court."
The denial and the admission are in the same paragraph of the same transcript. There is no reading of these two answers in which both are true.
The Two Operative Orders
Order 187 — Fourth Rule 20.01 Competency Evaluation. Orders the evaluation by the Chief of Psychological Services or designee — the same unit whose Chief (Dr. Katheryn Cranbrook) authored the Rule 20 report that this entire hearing existed to dispute. Pauses the criminal case for 2.5 months. Return hearing set for July 15, 2025. The Motion to Dismiss cannot be heard during the pause.
Order 188 — Forensic Navigator. Authorizes a 96-hour sweep of every category of personal record — medical, psychological, behavioral, chemical dependency, social service, probation, correctional, jail, developmental disability, military, Social Security, employment, educational. The order overrides HIPAA, the Minnesota Government Data Practices Act, and the Minnesota Health Records Act by its own explicit text.
Hudleston's own closing framing on the record (Card 68):
The "material changes" are Guertin's pro se filings substantiating the discovery fraud — the same filings his own defense counsel had refused to file or adopt.
"The Judiciary Cannot Have It Both Ways."
Eight days after the reversal, Guertin filed two emergency motions. Filing 190 — Emergency Motion to Stay and Vacate the April 29 Rule 20.01 Order (2,615 lines) is built around a single argument quoted verbatim from Section II.B:
The motion incorporates the Hamid perjury transcript passage by reference and cites Mathews v. Eldridge, Brady v. Maryland, Faretta v. California, Mapp v. Ohio, and Dombrowski v. Pfister. Relief requested: immediate stay, vacation of both April 29 orders, quashing of all subpoenas issued under them, expedited hearing within five business days.
Filing 191 — Motion to Confirm Pro Se Status and Discharge Counsel (657 lines) runs in parallel. Carpenter and Donnelly have "essentially joined the prosecution in portraying Mr. Guertin as delusional or misguided."
As of the date this page was written: Filing 131 has not been heard. Filing 190 has not been ruled on. The Hamid perjury has not been adjudicated. The exhibits Donnelly withdrew on March 5 have not been restored to the record. The two April 29 orders remain operative. The fourth Rule 20 evaluation produced no outcome that has freed Guertin from the framework.
Everything on This Page Survives Its Own Verification Check.
Anne Hines author metadata, identical Adobe XMP Toolkit fingerprint. Neither doctor authored the report bearing their name.hearing-2025-03-05, doc-2025-04-03, hearing-2025-04-17, hearing-2025-04-29.