STATE OF MICHIGAN

IN THE 12th JUDICIAL DISTRICT COURT

COUNTY OF JACKSON

PEOPLE OF THE STATE OF MICHIGAN,

Plaintiff,
HON. Michael J. Klaeren
v Case No. 2003173 FY

PETE MUSICO,
Defendant.

/
GREGORY J. TOWNSEND (P35857)
Sunita Doddamani (P67459)
Assistant Attorneys General
Attorneys for the People
3030 W. Grand Blvd., Suite 10-200
Detroit, MI 48202
(313) 456-0180
--------------------------------------------------

PEOPLE’S BRIEF IN SUPPORT OF THE PEOPLE’S RESPONSE TO

DEFENDANT’S MOTION FOR PRE-TRIAL RELEASE UNDER M.C.R. 6.106

The defendant seeks to have this Court reduce his bond to $20,000.00. The
People believe that the bond, set by the Magistrate, is appropriate as a result of the
actions of this defendant to implement the violent intentions of the Wolverine
Watchmen as well as other terrorist groups.

MCR 6.106 (E) states: “If the court determines for reasons it states on the
record that the defendant’s appearance or the protection of the public cannot
otherwise be assured, money bail, with or without conditions described in subrule
(D), may be required.” (Emphasis added). The primary requirement of the
government is the protection of the public. This case is no different. The People
will demonstrate that this defendant Pete Musico is a danger to the general public,
but government officials and law enforcement officers in particular.

Pete Musico is one of the founding members of the terrorist group Wolverine
Watchmen. The Wolverine Watchmen was committed to violence. Wolverine
Watchmen was listed as a private facebook group and is described as:

1
“Wolverine Watchmen is a group of Patriots to network and assemble and
recruit like minded individuals. Develop regional QRFs and squad tactics.
Only add people you trust no statist, no fudds, no bootlickers and no cops or
feds. If you're serious get a wire and message an admin your username.”
One of the Facebook group rules is listed as “Boojahidden only, No feds,
statist, cops, bootlickers or commies or ethnonationalist.” 1

“Boojahidden” is a term derived from the term “mujahedeen” and is a

reference to fighters with weapons, gear, and training who are willing to die for
their cause. Boojahideen fighters are often rogue military members or rogue law
enforcement officers who are prepared for the “boogaloo”, which is a term used for
the upcoming civil war, which will result from an uprising against the government.
“QRF” stands for Quick Reaction Force, which is a tactical term used for a team of
armed individuals who can respond to a dangerous situation. “Statist” is a term
used to describe the political ideology of a belief in legitimate government
intervention of centralized control over social and economic affairs. “Fudds” is a
derogatory reference based on the cartoon character “Elmer Fudd” which is used to
describe gun owners who are not competent tactically or who are not willing to
stand up for their beliefs. “Bootlicker” is a derogatory term for individuals who are
servile or followers of the government.

Wolverine Watchmen advocates violence targeted against the government

and politicians. One example of this is contained in a communication between Pete
Musico and Adam Fox on October 1, 2020. Adam Fox is another individual,
presently charged by the Federal Government. Musico, in this communication,
stated:

“…just like I said there are a lot of people that are bringing the boot
movement to the media because we have to have the hearts and minds of the
people to accomplish our goal this is not just about picking up a rifle and
killing a bunch of people thinking that we’re going to reset the system this is
about taking down the giant. 2

Members of the Wolverine Watchmen were encouraged to identify law

enforcement officer’s home addresses in order to target the officers. They were also
required to participate in tactical training. 3 Musico was involved in discussions,
with other members and other groups, to assault the Capitol and plans to kidnap
the Governor of the State of Michigan, Governor Whitmer. Defendant Musico had
his own “Plan B.” His “Plan B” was to target the homes of politicians and kidnap
them. 4

1
Exhibit 1 (Serial 7)
2
Exhibit 2 (communications between Fox and Musico)
3
Exhibit 3 (Serial 130, 141)
4
Exhibit 4 (Serial 147)
2
 Pete Musico, along with Joe Morrison, did certain actions to accomplish the
goals of violence against the government and governmental officials. Pete Musico
and Joe Morrison had multiple tactical trainings exercises on their property in
Munith Michigan. 5

During the June 14, 2020 exercise the following was the training schedule: 6

5
Exhibit 5 (Serial 8, 79, 159, 168)
6
Exhibit 6 (Serial 136)
3
 In a post-arrest interview, Defendant Musico admitted that he has advocated
violence to the group. 7

Additionally, at a tactical training held at his residence in March 2020,

Musico stated that in the past, he had thrown a Molotov Cocktail into the residence
of a police officer who pulled him over. He stated he waited outside the back door of
the house and planned to shoot the officer when he came out, but ultimately decided
not to. 8

On June 28, 2020 defendant Musico and Joe Morrison, with full knowledge of
Adam Fox’s plan to assault the Capitol hosted a tactical training exercise at their
property in Munith, Michigan. 9 Musico had a private conversation with an
individual expressing doubt about Fox’s plan and stated they should go forward
with Musico’s politician kidnapping plan, they were already training for that type of
mission by practicing tactical team door entries and room clearing. 10

Pete Musico, during a meeting addressed the group and gave them an
ultimatum: the group was heading toward “real shit” action which required
dedication to the group and cause. 11 If they had been training to improve their
tactical skills, that was okay, but they needed to leave immediately if they didn’t
want to be part of what was coming. No one in the group left. At this meeting
defendant Musico and Morrison offered to recruit Michigan Militia of Love for
plans. 12 Musico also advised an individual that he was preparing to produce more
pounds of C-4 explosives in anticipation of planned events. 13

During a meeting on March 30, 2020 at Musico and Morrison’s home, Pete
Musico stated he was preparing for a citizen’s arrest of Governor Whitmer. 14 At a
training session on April 19, 2020 at Musico and Morrison’s home, Musico stated he
wanted to obtain the Governor’s address. 15

On April 9, 2020 during preparation and planning for upcoming tactical

training on April 13, 2020, Musico (under the name “grandpa”) stated on Wire “So is
Monday's still on or people going to bitch out.and if you do show up do know there is
a possibility that law enforcement could show up to break us up and if so we're

7
Exhibit 7 (MSP OIC Russell report)
8
Exhibit 8 (Serial 162)
9
Exhibit 9 (Serial 175, 177, 155)
10
Exhibit 10 (Serial 177, 150)
11
Id.
12
Id.
13
Id.
14
Exhibit 11 (Serial 9)
15
Exhibit 12 (Serial 79)
4
already in gear...” followed by the statement “Put your vest on gear up and hunt the
rich.” 16

At the Lansing Capitol Building on April 30, 2020, Pete Musico attended
along with fellow Wolverine Watchmen members attended a protest and can be
seen in the far right in this picture:

He can also be seen here on the same date attempting to intimidate State
Troopers at the protest:

16
Exhibit 13 (wire chat)
5
 In a chat thread on an encypted platform following that day, Musico declared
that he was attempting to get the State Troopers to touch him. 17

There was a 2nd Amendment rally at the Lansing Capitol Building on June
18, 2020. Joe Morrison, Pete Musico, Ty Garbin, Paul Bellar, Daniel Harris, Adam
Fox and Amanda Keller were all in attendance. When Adam Fox met the Wolverine
Watchmen, he immediately put his hands on their chest and back checking for
“wires”. 18

Adam Fox spoke to them regarding his current strategy, which consisted of a
primary plan and a secondary plan. 19 Plan A consisted of recruiting 200 men and
then storm the Capitol building in Lansing while Congress was in session. They
were to take hostages, execute tyrants and have it televised. It would take about
one week and that no one is coming out alive.

The secondary plan was to storm the Capitol building in Lansing when
Congress was in session. They would then lock the entrances/exits to the structure.
They would then set the building on fire.

Defendant Musico suggested that there were tactical difficulties with the
main strategy, stating it was a “fishbowl” around the Capitol building. Musico,
referring to the politicians, stated “everyone has addresses” and then suggested
they look up the addresses of the politician’s residences and execute the secondary
plan at the politician’s residences. Adam Fox also referenced a meeting/training
event in Wisconsin on the second weekend of July and invited the Wolverine
Watchmen to attend. Both Joe Morrison and Pete Musico indicated they were
interested in attending. 20

The above information is just a small portion of the statements and actions of
this defendant. The Court should be aware that the people have hours of
conversations of this defendant on tape expounding his terroristic views.

MCR 6.106(F) also allows the Court to consider a defendant’s past record:

(F) Decision; Statement of Reasons

(1) In deciding which release to use and what terms and conditions to impose, the
court is to consider relevant information, including
(a) defendant’s prior criminal record, including juvenile offenses.

17
Exhibit 14 (wire chat)
18
Exhibit 4 (Serial 147)
19
Id.
20
Id.
6
 The Court, in determining this defendant’s bond should be aware the Pete
Musico, under the name of Phillip Westenberger had a juvenile adjudication of
Second-Degree Criminal Sexual Conduct on September 16, 1993. Then as an adult
he was convicted of Felony Forgery on August 16, 1995.

MCR 6.106(D) discusses conditional release:

(D) Conditional Release. If the court determines that the release described in
subrule (C) will not reasonably ensure the appearance of the defendant as required,
or will not reasonably ensure the safety of the public, the court may order the
pretrial release of the defendant on the condition or combination of conditions that
the court determines are appropriate”

Based on Musico’s past statements, some of which are public videos, 21 he

voices hostility about “government control,” and his ability to follow bond conditions
are doubtful. Among these statements he says: It should be illegal for politicians to
make laws to wear seatbelts and this is tantamount to forcing people to be safe; that
the government is “overreaching” and “its time for people to start stepping up and
stepping back against the system”; that its “time to go after the government for
their overreach.” Further, Musico admitted in his post-arrest interview that the
Wolverine Watchmen group was started immediately after Joseph Morrison
concluded a weapons violation charge. 22

It is quite evident that this defendant holds extreme violent views concerning
the government and governmental officials. This defendant poses an immediate
and constant threat to a multitude of government officials including the Governor of
the State of Michigan. Musico not only made terrorist threats and communicated
those threat to other persons, which is a crime in and of itself, but also conducted
overt operations and discussion to put into effect terrorist actions against the
Government and Government servants.

WHEREFORE, the People respectfully requests this Court to deny and dismiss
defendant’s Motion for Pre-Trial release.

21
Can be found online at: https://www.youtube.com/watch?v=zWsAlpIKUwo
22
Exhibit 7 (MSP OIC Russell report)
7
 Respectfully submitted,

DANA NESSEL
Attorney General

______________________________
Sunita Doddamani (P67459)
Assistant Attorney General

______________________________
Gregory J. Townsend (P35857)
Assistant Attorney General