Read Kilmar Aramando Abrego Garcia’s Motion

Shortly after that meeting, and for months thereafter, Attorney General Bondi and other
federal officials attacked Mr. Abrego publicly. As detailed in a prior defense motion, officials variously labelled Mr. Abrego a “gangbanger,” “monster,” “illegal predator,” “illegal alien terrorist,” “wife beater,” and “human trafficker.”17 (See Dkt. 69 at 1, 3-5).
While the government waged this public campaign to discredit and punish Mr. Abrego, it also sought to use its criminal investigative authority for the same purpose. In late April 2025, the government opened a new criminal investigation into Mr. Abrego, the better to support its arguments against him in the court of public opinion. 18
The investigation began by focusing on a 2022 traffic stop of Mr. Abrego that, at the time, led to neither charges nor a citation. That stop took place on November 30, 2022, when Mr. Abrego was pulled over by the Tennessee Highway Patrol (“THP”), allegedly for speeding, while he was driving nine passengers in a Chevy Suburban in Putnam County, Tennessee. (Dkt. 61 at 13:7-15:18). Mr. Abrego was neither ticketed nor charged; he and his passengers were allowed to

(@nayibbukele), X (Feb. 3, 2025, at 9:44 P.M.),

https://x.com/nayibbukele/status/1886606794614587573; see How It’s Going, U.S. Dep’t of Homeland Sec., https://www.dhs.gov/medialibrary/assets/video/59108 (Noem: “This facility is one of the tools in our toolkit that we will use”).
17 See, e.g., Attorney General Pamela Bondi (@AGPamBondi), X (Apr. 16, 2025, at 9:42 P.M.), https://x.com/AGPamBondi/status/1912682960156795369; Karoline Leavitt talks Kilmar Abrego Garcia at White House briefing, Fox 9 (YouTube Apr. 16, 2025),
https://www.youtube.com/watch?v=c6j4_DT73vM; Rapid Response 47 (@RapidResponse47), X (May 27, 2025, at 1:57 P.M.), https://x.com/RapidResponse47/status/1927423875828056513; Sarah Fortinsky, Rubio to Van Hollen: We deported gang members, including the one you had a margarita with,’ Hill (May 20, 2025), https://thehill.com/homenews/senate/5310018-rubio-van- hollen-trump-administration-deportations/; Stephen Miller (@StephenM), X (June 6, 2025, at 5:26 P.M.), https://x.com/StephenM/status/1931100469515993431; Tricia McLaughlin (@TriciaOhio), X (May 3, 2025, at 10:45 A.M.),
https://x.com/TriciaOhio/status/1918678209475887560; Homeland Security (@DHSgov), X (May 14, 2025, at 11:17 A.M.), https://x.com/DHSgov/status/1922672678340555173.

18

At the June 13 detention hearing before Magistrate Judge Holmes, Special Agent Peter Joseph testified that he joined the investigation of Mr. Abrego on April 28. See Dkt. 61 at 12:19-25. DHS records produced in discovery, which the defense can provide to the Court upon request, provide a case-opening date of April 23, 2025.

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