Arjun Singh <arjun@dcnf.

org>

Daily Caller Conversation Today About Client

Carroll, Kevin <Kevin.Carroll@hugheshubbard.com> Fri, Apr 21, 2023 at 5:21 PM
To: Arjun Singh <arjun@dcnf.org>
Cc: Kevin Byrnes <kbyrnes@fhhfirm.com>

Here’s a copy of the text of her declaration, with redacted parts in ellipsis.
 
I, … hereby declare:
 
1. I am over eighteen years of age and am fully competent to testify to the facts set forth in this declaration.

2. I, Petitioner, am an employee of the U.S. government …

3. On July 13, 2022, on or about 3:45pm, on a federal reservation in … County, after a pattern and practice of
sending myself and other female colleagues sexually explicit messages and other inappropriate conduct, my co-
worker, Respondent … snuck up behind me in Stairwell #2 … Without my consent, on a midsummer afternoon,
Respondent wrapped a thick winter scarf around my neck, strangled me, manhandled me, attempted to kiss my
mouth, and throughout this assault stated words to the effect of, “This is what I want to do to you” and “There are
many uses for this” (in reference to the scarf).  My circulation and respiration were impeded by the pressure
Respondent’s scarf placed on my neck, likely causing me internal soft-tissue injury.

4. I exclaimed “Stop!”, I pushed Respondent away, and attempted to flee, whereupon Respondent again, from
behind, attempted to throw the scarf over my head and wrap the scarf around my neck (this time unsuccessfully). 
Respondent ultimately caught up with me in a hallway and, without consent, grabbed my arm, pulled me towards
him, and kissed my cheek.  Respondent subsequently instant messaged me twice, inquiring “You good?”.

5. I took timely notes of the assault, informed my family, friends, and other colleagues of the assault, and within forty-
eight hours, reported the assault to multiple offices at my employer.

6. I spoke to representatives of my employer’s offices of security, threat management, equal opportunity, anti-
harassment, employee assistance, ombudsman, sexual assault response, and general counsel.  I was told that
mine was “a guinea pig case.”  I received a steady stream of inaccurate, conflicting, and even illegal guidance from
my employer:

a.     I was ordered not to conduct a controlled call or instant messaging exchange with Respondent to attempt
to obtain a further inculpatory statement.

b.        I was ordered on September 21, 2022, not speak about the assault, including to my employer’s
counseling services.

 
 c.        I was discouraged from informing my father and husband about the assault … for stated fear that they
might retaliate against Respondent.

d.     I was told that reporting the assault to law enforcement, or receiving necessary health care, would cause
negative career impacts necessitating me to consider a different career.

e.     I was told that if I made a report to law enforcement, my employer’s threat management unit would cease
to act upon my behalf.

f.          I was ordered that if I did speak to law enforcement, I must misstate or not include certain facts in my
statement.  I understand that this order was illegal.

 
7. Respondent substantially admitted his assault of me to our employer (which admission was recorded in writing),
but upon information and belief, as a purported defense, Respondent falsely stated that his physical misconduct in
the stairwell and hallway was a joke made in the context of a discussion of sexual practices with others.

8. I am forced to engage in professional electronic communications with Respondent.  My employer suggested that I
not attend professional events where Respondent may be present.  My employer stated that there is nothing it will
do to protect me from Respondent unless and until he engages in stalking or further assaultive conduct ….

9. …

10. Absent any definitive (and properly legal) guidance from my employer, after over four months of effort to obtain
such guidance, upon the advice of counsel I reported Respondent’s assault to law enforcement:  to the Federal
Bureau of Investigation on December 2, 2022, and to … Police on December 19, 2022 ….

11. Upon advice of counsel, I believe that Respondent may have committed acts of violence, force, and threat,
specifically, assault, battery, and strangulation under Virginia law, see VA Law §§ 18.2-57 and 18.2-51.6, and
assault with a dangerous weapon, simple assault, and attempted aggravated sexual abuse under federal law, see
18 U.S.C. §§ 113(a)(3)-(5) and 2241(a)(1)-(2) ….

I declare under penalty of perjury under the laws of the United States of America that the foregoing is
true and accurate to the best of my knowledge, information, and belief.
 
Executed on December 21, 2022 ….
 
 
__________/s/_____________