Amicus Brief filed in Misty Croslin appeal

Document: Florida Governor Rick Scott has possessed evidence of child pornography of missing child HaLeigh Cummings since October, 2015

by Timothy Charles Holmseth on March 7, 2016 at 11:51 A.M.

An Amicus Brief regarding the Appeal filed by Misty Croslin was submitted to St. Johns County Clerk of Court Hunter S. Conrad today.

The Brief was submitted to Clerk Conrad by investigative journalist Timothy Charles Holmseth.

The Brief details evidence that shows Misty Croslin was in fact the victim of entrapment, and under trauma based mind control due to rape and torture.

The Brief details evidence that interested non-party Timothy Charles Holmseth is being threatened with death and mutilation by the same individuals that conspired to entrap Misty Croslin.

The Brief contains documentation from the Office of Florida Governor Rick Scott regarding child pornography that was manufactured of the missing child HaLeigh Cummings after she was reported missing.

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CASE NO. 10-0141-CFM






Timothy Charles Holmseth
320 17th Street N.W.
Unit # 17
East Grand Forks, MN
218.230.1597 (cell)



Timothy Charles Holmseth is a journalist and publisher that conducted recorded interviews with multiple persons and agencies involved in the national profile kidnapping of HaLeigh Ann-Marie Cummings.

Because of information, facts, media, surveillance evidence, and recorded interviews acquired during journalistic investigations, and the desire of persons seeking to avoid detection and prosecution, Timothy Holmseth and his small children became the target of death threats by a criminal enterprise determined to keep him silent.

The threats, intimidation, and harassment against Timothy Holmseth and his children became so extreme the matter needed to be addressed by the Minnesota District Court and a privately paid professional mediation service was assigned to Minnesota 9th Judicial District – Case Number 68-FA-06-146.
The Minnesota District Court set forth a family plan that Timothy Holmseth would be the parent to legally address the on-going threats against his minor child with law enforcement, while the child’s mother would keep and shield the child from daily exposure to the attacks.

These extended matters are also associated with HOLMSETH V. CITY OF EAST GRAND FORKS ET AL – United State District Court – District of Minnesota – Civil Action No. 14-CV-2970 (DWF/LIB).

Evidence pertaining to threats and extended matters is also contained in the files of the East Grand Forks Police Department, Minnesota, as well as the Grand Forks Police Department, Grand Forks, North Dakota.

Timothy Holmseth is a perpetual target of a criminal enterprise seeking to violate his constitutional protections secured by the 1st, 2nd, 4th, 6th, and 14th Amendments.

Many of the operations against Timothy Holmseth are being staged out of the state of Florida.

Timothy Holmseth possesses a trove of information regarding the kidnapping of HaLeigh Cummings, drug trafficking, and child pornography crimes that pertains directly to MISTY CROSLIN.

On March 4, 2016, Timothy Holmseth learned through a media report published in the Florida Times-Union that a hearing was scheduled for MISTY CROSLIN. Media reports contained a PDF file of MISTY’S CROSIN’s Motion to the Court, which Timothy Holmseth reviewed.

Because of time constraints, this ‘Amicus Brief’ is not being prepared to present poignant legal arguments and statutory citations, per say.

Rather, this is being prepared and submitted to the Florida Court as Prima Facie evidence that MISTY CROSLIN is being truthful in her assertions contained in her MOTION FOR POST CONVICTION RELIEF that COUNSEL WAS INEFFECTIVE FOR FAILURE TO INVESTIGATE AND PRESENT ENTRAPMENT A PLEA DEFENSE.


Corrupt individuals in multiple agencies and/or groups actively participated, or were complicit in, the hoax kidnapping of HaLeigh Ann-Marie Cummings.

The same aforementioned individuals then became actively involved in the persecution and criminal prosecution of Misty Janette Croslin for purposes of protecting an extended criminal enterprise.

The criminal prosecution of MISTY CROSLIN was the express result of entrapment and trauma based mind control.


My name is Timothy Charles Holmseth. I am 47 years old. My address is 320 17th Street N.W., Unit 17, East Grand Forks, Minnesota, 56721.

I am a former news reporter; now an independent journalist, songwriter, and author. I have an Associates Degree in Media Communications from Northland Community College, Thief River Falls, Minnesota.

I have been employed by newspapers of record in Minnesota and North Dakota and received first place awards from the North Dakota News Paper Association (NDNA) for writing and reporting. I have worked contractually with music companies as a songwriter. I have worked contractually with magazines as a feature content writer. I have been employed as a social worker in refugee relocation services.

In 2008, I received a first place award from the NDNA for Best News Series for a story that spanned nearly a year of coverage. My professional references include an officer of the Minnesota court, county attorney, elected officials, and hand-written letters of commendation from respected community leaders. I have served beside local leaders on community civic boards and was invited to be a featured guest speaker at a public event honoring veterans.

I have passed a federal background check performed through the United States Department of Commerce to work in a secure federal facility and move freely through secure areas. I was deemed “credible” by Special Agent A.J. Eilermann, Minneapolis FBI, during a kidnapping investigation by the Jacksonville FBI of the missing child HaLeigh Ann-Marie Cummings.  

I am a successful single parent and had sole physical custody of my daughter from the time she was approximately four years-old until adulthood. I raised her alone. She is now a mother and studies at the University of Minnesota. I also have a minor son and share legal custody with his mother. I am a proud grandfather.

In the spring of 2009 I began obtaining recorded statements from individuals involved in the national profile kidnapping case of HaLeigh Ann-Marie Cummings.  My interviews and acquisition of evidence continued for several years as involved individuals continued to proactively contact me.



I possess evidence that MISTY CROSLIN was a rape and torture victim. The victimization began when she was a minor child.

MISTY CROSLIN was under trauma based mind-control at all relevant times during:

  1. The murder of John Doe at 202 Green Lane, Satsuma, Florida, shortly before the disappearance of HaLeigh Cummings
  2. The disposing of John Doe
  3. The disappearance/kidnapping of HaLeigh Cummings
  4. The child pornography shoot of HaLeigh Cummings
  5. Involvement with the trafficking of drugs in Florida


MISTY CROSLIN was in fact entrapped.
MISTY CROSLIN was entrapped by members of an organized criminal apparatus because of sensitive information she possessed that made her a liability to the entire organization.  

MISTY CROSLIN, while still a minor (underage) teenage girl, became tangled up in the criminal activities of her adult boyfriend Ronald Cummings.

The illegal conspiracy to entrap MISTY CROSLIN began when she was a minor child and involved multiple members of a large scale drug trafficking, child sex trafficking, child pornography, and international baby-selling operation in Florida.  

Following the arrest of MISTY CROSLIN for drug trafficking, I was contacted by her attorney Robert Fields. Attorney Fields told me he was aware MISTY CROSLIN was receiving death threats and in constant danger. 

Attorney Fields said he was abundantly aware MISTY CROSLIN was being stalked, harassed, threatened, and beaten as she moved about in her life.

Attorney Fields told me he had been contacted by national profile figures (e.g. bounty hunter) that claimed they could offer MISTY CROSLIN protection if they could take physical custody of her and move her into another country.

During my conversations with Attorney Fields he became aware that I, too, was in danger.


MISTY CROSLIN was raped when she was a little girl beginning at the age of 7.

When MISTY CROSLIN was a teenager she met Ronald Cummings.  

According to multiple case witnesses I interviewed, Ronald Cummings physically and sexually abused MISTY CROSLIN.  Acts of abuse, which were attributed to Ronald Cummings and/or his mother, Teresa Neves, involved, but are certainly not limited to, Ronald Cummings holding MISTY CROSLIN down on the ground and pounding on her belly with his closed fists because he believed she was pregnant. He was trying to kill the baby inside her.

Another example of abuse involved Ronald Cummings and his mother, Teresa Neves, locking a young girl in a closet. Ronald Cummings and Teresa Neves were drug traffickers.

According to author Wayanne Kruger, who officially served as HaLeigh’s mother’s (Crystal Sheffield) victim’s advocate, MISTY CROSLIN exhibited very pronounced signs of trauma-based mind control in the presence of Teresa Neves.

Wayanne Kruger told me she believed that in March, 2009, MISTY CROSLIN was about ready to tell her the true facts and circumstances surrounding the mysterious disappearance of HaLeigh Cummings during prayer in the Cummings trailer-home at 202 Green Lane. Kruger said Teresa Neves came into the room and MISTY CROSLIN’S demeanor abruptly switched from sobbing uncontrollably and convulsively shaking as she lay in Kruger’s lap; to rising up, wiping her tears, putting her hair back in a pony tail, and standing obediently and silently next to Teresa Neves.


Facts and circumstances show the minor child MISTY CROSLIN became a great liability to her overseers – the adult criminals in her life that abused her.

According to the product of my journalistic investigations:

  1. Misty Croslin was present during a murder that occurred at 202 Green Lane, Satsuma, Florida.
  1. HaLeigh Cummings, 5, was present and witnessed the murder at 202 Green Lane, Satsuma, Florida.
  1. Misty Croslin was present during a child porn shoot of five year-old HaLeigh Cummings.
  1. Misty Croslin knows the identity of a murderer(s), child pornographers(s), and drug traffickers.


Misty Croslin was carefully entrapped by members of a drug, child porn, and human trafficking enterprise. The criminal enterprise involves murder, death threats, kidnapping threats, witness intimidation, cyber-stalking, criminal defamation, abuse of legal process, and perjury.

The operation is ongoing to this day.

Criminally involved and or complicit persons identified to and/or by me, are, but not limited to:

  • FDLE Agent Travis Smith
  • FDLE  Agent Matt Sears
  • PCSO Sheriff Jeff Hardy
  • PCSO Detective John Merchant
  • PCSO Detective Peggy Cone
  • PCSO Captain Dominic Piscitello
  • PCSO Major John Greenwood
  • States Attorney Investigator Chris Middleton
  • FDCF Child Protection social worker Bonnie Warner
  • REDACTED REDACTED, convicted felon, husband of REDACTED REDACTED
  • William E. Staubs, Case Closed, Inc
  • Paula Andrews, former girlfriend of William Staubs
  • Art Harris, Busystreet Productions
  • Nancy Grace, HLN network
  • Jane Valez Mitchell, HLN network
  • Jeremiah Regan, drifter
  • John Regan, convicted pedophile, FBI agent impersonator, clergy impersonator  
  • Wayanne Kruger, Victim’s Advocate and author
  • Rev. Richard Grund, admitted Satanist, paranormal specialist and demon hunter    
  • Christine (Tina) Church, Specialized Investigative Consultants, Indiana
  • REDACTED, Florida  
  • Levi Page, Tennessee  
  • Thomas Norman Olsen, Florida  
  • Rev. Bob Enyart, FBI domestic terrorism suspect, Planned Parenthood shooting
  • Alexandria Goddard, Ohio   
  • Ronald Cummings
  • Teresa Neves
  • Marie Griffis
  • John Sheffield
  • Crystal Sheffield
  • Connie Sheffield
  • Ruby Kanger
  • Jerri Greene
  • Matthew Staubs
  • Donna Wagoner, Xentel, Inc.  
  • John Doe, owner of WWW.RADIONEWZ.NET
  • Pete Klismet, Criminal Profiling Associates


The true facts and circumstances surrounding the disappearance of HaLeigh Cummings show the five year-old disappeared at the direction and knowledge of her very own family who conspired to orchestrate a hoax ‘kidnapping’ to explain the child’s disappearance.

HaLeigh Cummings was a witness to a murder, as well as being used for child pornography.

Your Affiant believes the aforementioned murder victim may have been Chad Eugene Reynolds. Reynolds is a convicted sex offender that was last seen on February 1, 2009. 

The mastermind behind the hoax kidnapping of HaLeigh Cummings was William E. Staubs – a.k.a. ‘Cobra the Bounty Hunter’.

William Staubs is/was a member of a drug trafficking operation that involved Ronald Cummings.

MISTY CROSLIN is not responsible for the mysterious hoax disappearance of HaLeigh Cummings.

Misty Croslin’s intimate knowledge of the aforementioned crimes eventually required members of the criminal trafficking operations to entrap her so she could be criminally prosecuted and serve as the symbolic scapegoat for HaLeigh’s disappearance.  


I spoke with Donald Knop. He was an employee of REDACTED REDACTED REDACTED Office.  REDACTED REDACTED was Crystal Sheffield’s (HaLeigh’s mother) REDACTED until some time in the summer of 2009 when Crystal Sheffield fired REDACTED. I had several recorded conversations with Donald Knop regarding photographs he handled, copied, and observed while an employee for REDACTED REDACTED REDACTED Office.

Donald Knop told me he was given photographs of HaLeigh Cummings that featured HaLeigh naked. He told me the pictures contained close-ups of her vagina. On one occasion Mr. Knop made it clear that HaLeigh’s vagina appeared damaged by sexual assault.

Donald Knop said some of the pictures were given to him by Jeremiah Regan.

Donald Knop said the team working for REDACTED REDACTED REDACTED had been gathering ‘evidence’ for over a month to support a change of custody recommendation regarding HaLeigh’s little brother, Ronald Cummings Jr., by the Florida Department of Children and Families (DCF).

Florida court records will show REDACTED REDACTED NEVER filed any motion on behalf of Crystal Sheffield regarding child custody or any other matter.

Karen Simmer, Galesburg, Illinois, reported to the Florida Department of Law Enforcement (FDLE), Putnam County Sheriff’s Office, Opa Locka Police Department, Florida DCF, America’s Most Wanted, FBI/U.S. D.O.J., U.S. Attorney’s Office, Attorney Greg Kimball, Florida BAR Association, that Attorney REDACTED REDACTED told her HaLeigh Cummings was “healthy, well fed, and growing”. SEE ATTACHED AFFIDAVIT

Karen Simmer said Attorney REDACTED asked her to file false DCF reports against MISTY CROSLIN and Ronald Cummings. I possess Karen Simmer’s emails that she exchanged with Attorney REDACTED. I also possess Karen Simmer’s telephone records that show she was speaking with Attorney REDACTED on the telephone.

It is an indisputable fact that Attorney REDACTED, a lawyer from REDACTED, REDACTED, was actively communicating with Karen Simmer, a woman from Illinois, and asking her to contact the Florida Department of Children and Families regarding MISTY CROSLIN – a person Simmer had never met in her life. 

As an investigative journalist I was able to determine was actually occurring. 

REDACTED REDACTED was ‘MANUFACTURING’ an unofficial, underground child custody case, through underground connections within the Florida Department of Children and Families through a (corrupt) child protection social worker named Bonnie Warner.

The objective was to change the custody of Ronald Cummings Jr. and HaLeigh Cummings through a DCF decision. The secret proceedings were to include the consideration of ‘evidence’ that consisted of photos of five year-old HaLeigh Cummings’ raped vagina.

Evidence indicates HaLeigh Cummings was strategically raped while in the custody of her caregivers so her damaged vagina could be photographed. The sexual assault was to be attributed to HaLeigh’s father, Ronald Cummings.

The sick and disturbing criminal plot becomes even more disturbing in light of an article entitled ‘Haleigh Cummings’ Mom Wants Custody!’ The article was published by REDACTED REDACTED’s media consultant, Art Harris, on March 11, 2009, that reveals fame and fortune was being sought by REDACTED REDACTED.  

The following is the lead to Harris’ article:

“In what could set a legal precedent for missing children, The Bald Truth has learned exclusively that the mother of five year old Haleigh Cummings aims to fight for legal custody of a daughter abducted a month ago from her father’s home while he was at work and his 17 year old girlfriend slept nearby,” Art Harris reported.

Donald Knop told me during a recorded interview that he personally handed the naked photos of HaLeigh to READACTED REDACTED. He said she looked at them and then told him to give the photos, along with other information they had gathered pertaining to MISTY CROSLIN, to a Florida DCF child protection social worker named Bonnie Warner.

Donald Knop told me REDACTED REDACTED had been meeting and/or communicating with Bonnie Warner “daily”.

Donald Knop told me that after REDACTED REDACTED handed him the naked photos of HaLeigh, he arranged to meet Bonnie Warner in gas station parking lot near San Mateo, Florida. They met after regular business hours and Mr. Knop gave Ms. Warner a CD that contained the secret naked photos and other information.

In 2009, William Staubs telephoned me and I activated a tape recorder. He then telephoned Bonnie Warner, the DCF social worker assigned to the Cummings family file. During that conversation Bonnie Warner acknowledges receiving the CD from Donald Knop. Bonnie Warner refers to the “pictures” as something that could not be shown to her supervisor. 


In 2009, I was told by William Staubs that REDACTED REDACTED REDACTED approached him and stated they should frame Misty Croslin, and a local black man, Gregory Lewis Page, for HaLeigh’s disappearance.

William Staubs told me Donald Knop witnessed the conversation. Donald Knop confirmed that to me. Mr. Staubs also told me he had recordings of REDACTED REDACTED saying these things.

I reported the aforementioned to the Office of the Florida Attorney General Bill McCollum shortly after the statements were made to me.

The Office of Florida Governor Rick Scott/AG Pam Bondi acknowledges being aware of my original communications to the Governor’s office in 2009.  


MISTY CROSLIN, through her knowledge, became a liability to a criminal enterprise that was operating a drug trafficking ring in Florida.

The drug trafficking operation included government officials visiting First Impressions Weight Loss clinic in Tallahassee where they were obtaining controlled prescription medication without doctor’s orders, which is a felony in the state of Florida.

Following the disappearance of HaLeigh Cummings, William Staubs told me he infiltrated and spied on First Impressions weight loss clinic.

Based upon known facts, documents, and information, I believe William Staubs was spying on First Impressions to gather evidence against government officials. The reason he was gathering such evidence was because he had been charged with felony false imprisonment by the Putnam County Sheriff’s Office and needed leverage to get the charges dropped. 

I acquired and possess medical charts that revealed employees of the following Florida agencies went to First Impressions Weight Loss clinic and obtained drugs without an order from a doctor. 

  • Chief Inspector General / Office of the Governor
  • Second Judicial Circuit of Florida
  • United States Attorney’s Office
  • Office of the State’s Attorney
  • Gadsden County Sheriff's Office
  • Florida Highway Patrol
  • Tallahassee Police Department
  • Dept of Corrections
  • Dept of Agriculture
  • Florida Department of Law Enforcement
  • Florida Department of Health
  • Leon County Sheriff’s Office
  • Capital Police
  • Leon County Commission
  • Florida Department of Revenue
  • Republican Party of Florida
  • Florida House of Representatives
  • Dept of Energy
  • Dept Motor Vehicles


Members of the child sex trafficking operation contacted the East Grand Forks Police Department (EGFPD) and told the police I was in possession of child pornography.

Members of the operation believed I possessed the secret naked photos of HaLeigh (which they, themselves, created and distributed) because I was able to write about the photos, based upon descriptions given to me by Donald Knop.

One member of the child trafficking operation, Tina Church, Specialized Investigative Consultants, Indiana, telephoned the EGFPD in 2011 and told them I claimed to have HaLeigh Cummings in my apartment.

The EGFPD and Minnesota Pine to Prairie Gang and Drug Task Force raided my home/office with guns and bullet-proof vests and seized my computer hard-drive, cameras, and all of my data storage devices.

The hard-drive was subsequently ordered returned by a Minnesota District Judge. Polk County Sheriff’s Sgt. Investigator Michael Norland reported, and testified in Court, that the hard-drive contained “no sign of illegal activity”.  

All of the individuals that conspired to have me arrested (framed) for rape and murder of the missing child HaLeigh Cummings are involved on some level with the same targeting of MISTY CROSLIN.

Evidence shows the criminal enterprise remains in contact (monitoring) with MISTY CROSLIN and/or her family to this very day.

On March 1, 2016, the website WWW.RADIONEWZ.NET announced MISTY CROSLIN has a lawyer and began soliciting donations from the public. 

The following is as excerpt:

Misty now has an attorney!
Misty Croslin has hired an experienced criminal law attorney to represent her in her legal battle to reduce her sentence. As is customary, her attorney fees, $17,500, were paid up front by a friend of the family, and Misty’s mother and father, Hank and Lisa Croslin, have approved this website as a way to repay those funds through donations from her friends and supporters.

The article does not state who MISTY CROSLIN’S attorney is or who is receiving the online donations.

However, MISTY CROSLIN’S present Motion to the Court says she is representing herself and makes no mention of a lawyer.

REDACTED REDACTED REDACTED announced on REDACTED official Twitter account that REDACTED is the “General Counsel” representing the website 


An abundance of evidence exists to show that MISTY CROSLIN and Timothy Holmseth are victims of organized crime by a syndicate that is in violation of the Racketeer Influence Corrupt Organization Act.


An abundance of evidence exists to show that MISTY CROSLIN, HaLeigh Cummings, and Timothy Holmseth’s Constitutional rights are being violated.


All assertions and statements contained herein are supported by media evidence in the possession of Timothy Holmseth.

Respectfully submitted,
Timothy Charles Holmseth

Timothy Charles Holmseth
320 17th Street N.W.
Unit # 17
East Grand Forks, MN
218.230.1597 (cell)

Cc: Joe Stenzel, Minnesota District Case Number 68-FA-06-146

Attached: DCF Inspector General PDF, Affidavit of Karen Simmer




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