The source documents

Read the filings. Make an informed decision.

Seven PDFs, 112 pages. The documents bring together two related concerns: the request for an impartial tribunal in the SEC civil case and the effort to fund specialized counsel for the criminal appeal.

How to read this collection

These are copies supplied to the campaign with court filing stamps, not a complete or live docket. Motions present legal arguments; affidavits and declarations state their authors' accounts. The discovery order within ECF 832-2 is a court ruling on discovery, not a finding of judicial bias or a decision on the appeal.

Files are reproduced as supplied, including existing redactions, signatures, highlights and annotations. Some pages are scans and may not be searchable or readable by assistive technology. The summaries below provide a text guide; PDF page references count from the first page, including covers. No ruling on either 2026 motion is included in this collection.

01 - Impartiality

The SEC disqualification filings

Filed October 2, 2026 in SEC v. NAC Foundation, LLC, et al., No. 3:20-cv-04188-RS. Start with the affidavit, then read the motion and its two CIPA attachments.

SEC civil case - ECF 61-3

Rowland Marcus Andrade's sworn affidavit

Filed October 2, 2026 · PDF · 13 pages · 193 KB

Andrade's statement supporting disqualification in SEC v. NAC Foundation, LLC, et al. It sets out his account of related proceedings, evidence disputes and the reasons for his belief that recusal is warranted.

Start here: PDF pp. 3-5 cover reassignment and the CIPA dispute; pp. 6-10 discuss declarations, trial rulings and statements; pp. 11-13 connect the concerns to the civil case. These are the declarant's assertions, not findings of misconduct.

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SEC civil case - ECF 61

Motion for disqualification and legal memorandum

Filed October 2, 2026 · PDF · 19 pages · 252 KB

The defense asks Judge Richard Seeborg to recuse from the SEC civil action under 28 U.S.C. § 455 or, if the affidavit satisfies § 144, to refer the request under Civil Local Rule 3-14.

PDF pp. 5-8 explain the procedural history and legal standards; pp. 11-16 present the arguments and requested relief. A filed motion is a request, not an order granting it.

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SEC civil case - ECF 61-1

Exhibit A - Kerrie Dent's CIPA declaration

Filed October 2, 2026 · PDF · 14 pages · 8.4 MB

A cover sheet and a copy of former defense counsel Kerrie Dent's October 3, 2024 declaration supporting the corrected CIPA submission. It describes discovery disputes and the defense's account of Jack Abramoff's activities.

PDF pp. 3-4 describe discovery and background; pp. 12-13 contain paragraph 24's request for informant-file materials. The attachment is largely scanned and includes existing emphasis marks.

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SEC civil case - ECF 61-2

Exhibit B - corrected defense CIPA submission

Filed October 2, 2026 · PDF · 23 pages · 15.1 MB

A cover sheet and the defense's October 3, 2024 corrected ex parte CIPA submission, reproduced as an attachment to the civil motion. It explains why the defense sought discovery concerning Abramoff and related activities.

PDF pp. 5-9 introduce the defense theory; pp. 9-10 discuss discovery standards; pp. 17-22 address additional discovery and informant-related questions. This is the supplied filed copy, not a release of classified evidence. It is largely scanned.

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02 - Access to counsel

The criminal appellate-funding filings

Filed April 7, 2026 in United States v. Andrade, No. 3:20-cr-00249-RS. These concern a proposed stock transaction, not an approved donation allocation or a new token offering.

Criminal case - ECF 832

Motion to reconsider the appellate-funding ruling

Filed April 7, 2026 · PDF · 13 pages · 378 KB

The defense asks the court to reconsider the ripeness ruling on a proposed Black Gold Coin stock transaction, or approve a specified transaction to help fund appellate counsel, litigation expenses and family support.

PDF pp. 2-5 explain the dispute and proposed 30/70 split of transaction proceeds; pp. 8-10 discuss the request and relief. That proposed allocation is not a donation budget or court approval.

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Criminal case - ECF 832-1

Michel Paradis's declaration on appellate representation

Filed April 7, 2026 · PDF · 4 pages · 50 KB

Paradis describes his national-security appellate experience, a requested $500,000 retainer and estimated litigation expenses that could exceed $800,000. He states he had not undertaken representation because funding was not secured.

PDF pp. 2-3, paragraphs 5-10, addresses the funding conditions and his recollection of the government's position on proposed stock proceeds. These are April 2026 statements, not a current bill, fundraising target or assurance that donations retain counsel.

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Criminal case - ECF 832-2

Supporting exhibits - declaration, transcript and discovery order

Filed April 7, 2026 · PDF · 26 pages · 2.9 MB

A compilation containing Dent's February 6, 2025 declaration, trial-transcript excerpts, communications and investigative materials, and Magistrate Judge Laurel Beeler's April 7, 2023 discovery order.

PDF pp. 1-3 are a declaration; pp. 4-8 are transcript excerpts; pp. 9-13 are reproduced exhibits; pp. 14-26 are a judicial discovery order. Different parts have different evidentiary roles. Handwritten exhibits can be difficult to read.

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