Page 1 – REQUEST FOR PRETRIAL DISCOVERY 

Thomas K. Coan, OSB #89173

tom@tomcoan.com

Attorney at Law

1001 SW Fifth Ave., Suite 1400

Portland, OR 97204

(503) 221-8736

Attorney for Defendant Santilli

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON

PORTLAND DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

vs.

PETER SANTILLI,

Defendant.

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Case No. 3:16-cr-00051-BR

DEFENDANT PETER SANTILLI’S 

REQUEST FOR PRETRIAL

DISCOVERY 

Defendant Peter Santilli, through his attorney Thomas K. Coan, hereby joins in the 

discovery request filed by defendant Joseph O’Shaughnessy. [Doc 180]

In addition to the information identified in defendant O’Shaughnessy’s request, 

Santilli specifically requests the following documents and information:

1. All documents and information relating to orders or requests any law 

enforcement officer made to Santilli asking or directing him to change his broadcasts in 

any way from April 1, 2014 through January 26, 2016.

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2. All documents and information relating to any notice from law enforcement 

officers to Santilli from April 1, 2014 through January 26, 2016 that his broadcasts were 

considered to be unlawful in any way.

3. All documents and information showing whether Santilli is or was on the 

terror watch list anytime from January 2013 to the present, and, if his name was on the 

terror watch list, all documents showing why it was so placed there.

4. All documents and information showing whether Santilli acted as an 

informant for the FBI or any other federal law enforcement agency from January 2011 to 

the present.

5. All documents and information showing any efforts the FBI or any other 

federal law enforcement agency took to investigate the false information published on the 

Internet from January 2014 to the present claiming that Santilli had worked as an FBI 

informant.

6. All documents and information showing communications from or by any 

federal law enforcement agent relating to or naming Santilli from January 2013 to the 

present, including but not limited to any email or text communications.

7. All documents and information showing or relating to any communications 

naming or relating to Pete Santilli, sent to or from BLM Special Agent Daniel P. Love 

and/or FBI Special Agent Gregory Bretzing, including but not limited to all email and text

communications naming or relating to Santilli, from January 2014 to the present.

8. All documents showing whether the FBI or any other law enforcement 

agency has or had super administrator privileges or back-door administrative privileges 

with The PeteSantilliShow.com, Guerilla Media Network, Santilli’s YouTube channel, or 

Case 3:16-cr-00051-BR Document 234 Filed 03/01/16 Page 2 of 3
Page 3 – REQUEST FOR PRETRIAL DISCOVERY 

other Internet sites through which Santilli publishes content such as Spreaker or Facebook, 

from January 2013 through the present.

9. All notes, reports or other documents relating to federal law enforcement 

officer(s) watching Santilli online, his live streaming video productions, or The Pete 

Santilli Show, from March 2014 to the present, including the names of any officers 

watching Santilli, the date the officer watched Santilli, the show episode number and any 

notes or reports generated from watching him or his show.

DATED this 1st day of March 2016. 

Thomas K. Coan

Thomas K. Coan, OSB 89173

Attorney for Defendant

Case 3:16-cr-00051-BR Document 234 Filed 03/01/16 Page 3 of 3