IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

ABILENE DIVISION

CHRISTOPHER JAMES REGAN,

Movant,

v.

UNITED STATES OF AMERICA,

Respondent.

No. 1:22-CV-00037-P

(1:19-CR-00021-P-2)

APPENDIX TO 

RESPONSE TO MOTION UNDER 28 U.S.C. § 2255

Respectfully submitted,

Chad E. Meacham

United States Attorney

s/ Ann Howey 

Ann Howey

Assistant United States Attorney

Texas Bar No. 24032312

1205 Texas Avenue, Suite 700

Lubbock, Texas 79401

Telephone: (806) 472-7560

Email: ann.howey.usdoj.gov

Steven J. Grocki

Chief, Child Exploitation and Obscenity Section

U.S. Dept. of Justice, Criminal Division

Kyle P. Reynolds

Trial Attorney

New York Bar No. 4703856

Authorized to Practice Under L. Cr. R. 57.11

1301 New York Avenue, NW

Washington, DC 20005

Telephone: (202) 616-2842

Kyle.reynolds@usdoj.gov

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CERTIFICATE OF SERVICE 

I certify that on August 24, 2022, I filed this appendix with the Clerk of Court for 

the U.S. District Court, Northern District of Texas. I also certify that a copy of this 

appendix was sent by certified mail to Christopher James Regan, Register Number 

28400-078, Tucson USP, P.O. Box 2400078, Tucson, Arizona 85734. 

s/ Ann Howey 

Ann Howey 

 Assistant United States Attorney 

Case 1:22-cv-00037-P Document 11 Filed 08/24/22 Page 2 of 6 PageID 93
From: jacob.blizzard@blizzardlawfirm.com <jacob.blizzard@blizzardlawfirm.com> 

Sent: Tuesday, July 28, 2020 11:47 AM

To: Haag, Jeffrey (USATXN) <JHaag@usa.doj.gov>; Reynolds, Kyle (CRM)

<Kyle.Reynolds@CRM.USDOJ.GOV>

Cc: matt.zimmerman@blizzardlawfirm.com

Subject: Letter regarding Russell Lorfing

Jeff and Kyle,

Please find attached a letter from my office.

Sincerely,

Jacob Blizzard

Jacob Blizzard

Board Certified – Criminal Law & Criminal Appellate Law

Texas Board of Legal Specialization

Capital Murder Appellate List Qualified Attorney, 7th Judicial Region

Blizzard & Zimmerman, P.L.L.C.

441 Butternut St.

Abilene, TX 79602

Page 1 of 4

GOVERNMENT 

EXHIBIT

A

Case 1:22-cv-00037-P Document 11 Filed 08/24/22 Page 3 of 6 PageID 94
w. (325) 676-1000

f. (325) 455-8842

jacob.blizzard@blizzardlawfirm.com

www.BlizzardLawFirm.com

Satisfied with our legal services? Please review us online by clicking here.

What is a Criminal Law Board Certified Attorney?

Initial certification requires the attorney having been licensed five years, devote a required

percentage of practice to criminal law, demonstrate proficient experience and involvement,

undergo peer review from prosecutors, fellow attorneys, and judges, regularly attend criminal

law continuing legal education seminar, and pass a day long exam on criminal law. To remain

certified, an attorney must apply for recertification every five years and meet practice, peer

review and continuing legal education requirements for the specialty field. An attorney who is

Board Certified by the Texas Board of Legal Specialization in Criminal Law must have

experience in the preparation, trial, and appeal of serious criminal matters. The attorney must

also have extensive knowledge of state and federal constitutional law, evidence, procedure and

penal laws involved in the trial of these matters. Less than 10% of all attorneys are board

certified. For more information visit: www.tbls.org.

***Notice of Confidentiality***

This e-mail message and attachments, if any, are intended solely for the use of the addressee

hereof. In addition, this message and attachments, if any, may contain information that is

confidential, privileged, and exempt from disclosure under applicable law. If you are not the

intended recipient of this message, you are prohibited from reading, disclosing, reproducing,

distributing, disseminating, or otherwise using this transmission. Delivery of this message to

any person other than the intended recipient is not intended to waive any right or privilege. If

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immediately delete this message from your system.

Page 2 of 4

Case 1:22-cv-00037-P Document 11 Filed 08/24/22 Page 4 of 6 PageID 95
Mr. Jeff Haag and Mr. Kyle Reynolds 

c/o Jeff Haag

United States Attorney’s Office 

1205 Texas Avenue, Suite 700 

Lubbock, Texas 79401-4029

Dear Jeff and Kyle,

I am writing you to inform you that Russell Lorfing is joining Blizzard & 

Zimmerman, P.L.L.C. as an attorney effective August 1, 2020. Pursuant to Texas 

Disciplinary Rules of Professional Conduct 1.10:

(a) Except as law may otherwise expressly permit, a lawyer shall not represent a 

private client in connection with a matter in which the lawyer participated 

personally and substantially as a public officer or employee, unless the 

appropriate government agency consents after consultation.

(b) No lawyer in a firm with which a lawyer subject to paragraph (a) is 

associated may knowingly undertake or continue representation in such a 

matter unless:

(1) The lawyer subject to paragraph (a) is screened from any 

participation in the matter and is apportioned no part of the fee 

therefrom; and

(2) written notice is given with reasonable promptness to the 

appropriate government agency.

Our law firm is only aware of two potential cases which requires screening 

under 1.10, Chris Regan and Bryan Collins. You have my and Matt’s personal 

assurances that Mr. Lorfing will be screened from any participation in these

matters, and he will not be apportioned any part of the fee from the cases. If either 

our firm or Mr. Lorfing discover that there are other cases which present a 

conflict of interest, the same procedures will be put in place.

Page 3 of 4

Case 1:22-cv-00037-P Document 11 Filed 08/24/22 Page 5 of 6 PageID 96
Confidential 

May 1, 2013

2

I am providing this written notice pursuant to (b)(2) in advance of the 

conflicts occurring, and I will provide reasonably prompt notice of any other 

conflict of which our firm becomes aware.

Sincerely,

/s/ Jacob Blizzard

Jacob Blizzard

Page 4 of 4

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