Intervention on Chapter 22 for claim of executive privilege

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% Note: Check official NW reporter for final Peterzalek citation/page numbers if available
\newcommand{\peterzalekcite}{\textit{Peterzalek v. Iowa Dist. Ct. for Polk Cnty.}, 999 N.W.2d 100 (Iowa 2024)} % Placeholder citation until final

\begin{document}

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% START OF MOTION TO INTERVENE
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\begin{center}
\textbf{IN THE IOWA DISTRICT COURT FOR POLK COUNTY}
\vspace{1em}

\textbf{RECORDS CUSTODIAN OF THE} \\
\textbf{GOVERNOR and} \\
\textbf{IOWA OFFICE OF} \\
\textbf{THE GOVERNOR,} \\
\vspace{0.5em}
\hspace*{1em} \textbf{Plaintiffs,} \\
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\textbf{v.} \\
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\textbf{THE DES MOINES REGISTER} \\
\textbf{\& TRIBUNE COMPANY d/b/a} \\
\textbf{THE DES MOINES REGISTER} \\
\textbf{and d/b/a DES MOINES} \\
\textbf{REGISTER MEDIA,} \\
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\hspace*{1em} \textbf{Defendant.} \\
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\textbf{Case No. [Insert Case Number Assigned by Clerk]} \\
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\textbf{MOTION TO INTERVENE} \\
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\end{center}

\noindent\textbf{Proposed Intervenor:} \\
Chad Brewbaker, individually and as a resident of Urbandale, Iowa; \\
State of Iowa ex rel. Brewbaker (as qui tam relator);\\
Brewbaker for Iowa; and \\
Flying Dog Solutions LLC / Flying Access Residuals LLC \\
\vspace{2em}

Comes now Proposed Intervenor, Chad Brewbaker, appearing \textit{pro se} on behalf of himself individually as a resident and taxpayer of Iowa,as \textit{qui tam} relator, and potentially on behalf of Brewbaker for Iowa and Flying Dog Solutions LLC / Flying Access Residuals LLC (collectively "Brewbaker"), and pursuant to Iowa Rule of Civil Procedure 1.407, moves this Court for an Order permitting intervention in the above-captioned action. In support of this Motion, Brewbaker states as follows:

\section{INTRODUCTION}
\begin{enumerate}
      \item Plaintiffs, the Governor's Office and its Records Custodian (represented by the Attorney General's office), initiated this action under Iowa Code \S~22.8 seeking an injunction to prevent disclosure of four specific public records (emails) requested by Defendant. Plaintiffs assert a novel "executive privilege" unrecognized in Iowa statute or constitution, effectively asking this Court to override the Legislature's comprehensive public records framework in Chapter 22.
    \item Proposed Intervenor Brewbaker possesses multiple direct, substantial, and legally protected interests relating to the subject of this action---the four withheld emails and the principle of executive secrecy asserted by Plaintiffs---that mandate intervention as a matter of right under Rule 1.407(a).
    \item \textbf{Primary Interest: Liberty as Criminal Defendant.} Brewbaker's most critical interest arises from his status as a criminal defendant facing a charge (allegedly simple misdemeanor 708.7(1)(a)(1)) widely viewed as retaliatory "lawfare" for his whistleblowing and campaign activities. This charge stems directly from a May 15, 2024, whistleblower email Brewbaker sent to officials, including Plaintiffs' counsel AAG Eric Wessan, detailing alleged non-profit fraud. The four withheld emails (Feb 5-10, 2025, concerning LSI/money laundering allegations/Congressional testimony response) directly relate to the State's handling of similar non-profit issues. These emails are highly likely to contain exculpatory or impeachment evidence (\textit{Brady}/\textit{Giglio} material) regarding official knowledge, bias, motive, or misconduct essential to Brewbaker's defense, particularly given the State's alleged efforts to declare him "incompetent" without a proper evidentiary hearing.
    \item \textbf{Other Interests:} Brewbaker also holds interests as a \textit{qui tam} relator (\textit{State ex rel. Brewbaker}) whose actions are impeded by the alleged state concealment exemplified here, and as a journalist/researcher investigating government misconduct potentially involving the Governor's family and finances (\S\S~13.7/331.757).
    \item Brewbaker seeks intervention to protect these fundamental interests, defeat Plaintiffs' baseless privilege claim, expose the alleged pattern of concealment and potential corruption underlying this secrecy attempt, and ensure procedural fairness. Disposition favoring Plaintiffs would directly impair Brewbaker's ability to protect his liberty (by potentially validating suppression of \textit{Brady}/\textit{Giglio} material) and financial interests, which are demonstrably not adequately represented by the current Defendant, especially given Plaintiffs' counsel's own conflicting arguments on discovery/privilege in \peterzalekcite{}.
\end{enumerate}

\section{PARTIES}
\begin{enumerate}
    \item Plaintiffs are the Records Custodian of the Governor and the Iowa Office of the Governor, represented by the Attorney General's Office.
    \item Defendant is The Des Moines Register \& Tribune Company d/b/a The Des Moines Register and d/b/a Des Moines Register Media (Gannett), a foreign corporation.
    \item Proposed Intervenor Chad Brewbaker resides in Urbandale, Iowa. Brewbaker is currently facing a pending simple misdemeanor criminal charge allegedly arising from his May 15, 2024, whistleblower email sent to state and federal officials, \textbf{including Plaintiffs' counsel AAG Eric Wessan}. Brewbaker is also the \textit{qui tam} relator in sealed Iowa False Claims Act cases (\textit{State ex rel Brewbaker v. Miller}, (Polk 2017, 2023), an active Iowa House canidiate, and journalist/researcher.
\end{enumerate}

\section{BASIS FOR INTERVENTION (Rule 1.407)}
\begin{enumerate}
    \item \textbf{Intervention of Right (Rule 1.407(a))}: Brewbaker meets all requirements for intervention as a matter of right.
    \begin{enumerate}
        \item \textit{Interest Relating to the Subject of the Action:} Brewbaker possesses multiple direct and substantial interests in the four withheld emails and the legal principle of executive secrecy being litigated:
            \begin{enumerate}
            
         
                  \item \textbf{\textit{Primary Interest: Criminal Defense / Brady \& Giglio Material:}} Brewbaker's liberty interest as a criminal defendant is paramount. The charge (allegedly 708.7(1)(a)(1)) stems directly from his May 15, 2024, whistleblower email to officials including AAG Wessan regarding alleged non-profit fraud potentially involving entities connected to the Governor or LSI. The four withheld emails (Feb 5-10, 2025, concerning LSI/money laundering allegations/Congressional testimony response) were generated during a period highly relevant to the state's handling of related non-profit issues. These specific emails could reasonably contain information directly impacting his defense: (a) Internal acknowledgment of the validity or seriousness of such non-profit concerns, undermining the State's claim his email was merely frivolous "annoyance"; (b) Discussions revealing official bias, motive, or strategy for handling critics/whistleblowers like Brewbaker raising these sensitive issues; (c) Information impeaching state officials (potentially including AAG Wessan or others involved in decisions related to Brewbaker's email or subsequent charge) regarding their credibility or handling of the underlying matters. This constitutes potential exculpatory or impeachment evidence (\textit{Brady}/\textit{Giglio} material) essential to Brewbaker's defense, especially given alleged due process violations in the criminal case (e.g., competency proceedings without hearing). The State cannot assert a novel privilege in a civil case to shield evidence crucial to the defense of an individual it is prosecuting.
            
             \item \textit{Financial Interest as Qui Tam Relator:} As relator in \textit{State ex rel Brewbaker}, Brewbaker has significant financial interests under the Iowa False Claims Act. Plaintiffs' attempt to establish broad executive secrecy here directly threatens Brewbaker's ability to obtain necessary evidence regarding alleged misuse of public funds (including \S~13.7/\S~13.11 violations) that his FCA actions target. The principle decided impacts his potential recovery.
                \item \textit{Interest as Journalist/Researcher:} Brewbaker actively investigates and reports on alleged financial misconduct and lack of transparency (ISU funds, LenderClose, \S 13.7 payments, etc.). Establishing an executive privilege would severely impede his (and the public's) ability to access information crucial for government oversight, directly harming his work.
                \item \textit{Relevance to Governor's Personal Connections \& Potential Motive:} The emails concern the LSI controversy, potentially intertwined with Governor Reynolds' connections (e.g., brother Doug Strawn/LenderClose, cousin Amy Strawn Davis) and related disputes involving Brewbaker (patent, lease, missing exhibits). The emails could shed light on motivations regarding these interconnected issues.
            
          \end{enumerate}  
           
           
           
             
     \item \textit{Impairment of Interest (Rule 1.407(a)(2))}: A disposition favoring Plaintiffs would directly and practically impair Brewbaker's interests. It would establish precedent validating the secrecy he opposes, hindering his FCA and journalistic work. Most critically, it would impair his liberty interest: Given the alleged systemic obstruction in his criminal case (due to asserted violations of \S 331.757/\textit{Hoegh}, alleged magistrate bias, nearly year-long delay without trial on a simple misdemeanor via competency proceedings), discovery there is effectively nonexistent. This Chapter 22 action may be the only currently viable avenue to access these potentially crucial *Brady/Giglio* emails. A ruling upholding privilege *here* would undoubtedly be used by the State (same AG's office) to block disclosure in the criminal case, effectively denying access indefinitely and severely impairing his defense rights \textit{now}.
     
     
     \item \textit{Inadequate Representation (Rule 1.407(a)(3))}: Defendant Gannett, a foreign corporation focused on general press access, cannot adequately represent Brewbaker's unique and profound interests as an Iowa citizen, elector, criminal defendant, and \textit{qui tam} relator. Gannett lacks Brewbaker's specific liberty interest and cannot argue the \textit{Brady/Giglio} relevance from that perspective. It lacks his \textit{qui tam} financial stake and has not reported on the broader alleged financial context (\S~13.7 violations, LenderClose connections, etc.) that may underpin the motive for secrecy. Crucially, Gannett is unlikely to aggressively challenge Plaintiffs' counsel (AAG Wessan) regarding his conflicting stance on privilege/discovery burdens compared to \peterzalekcite{} or his potential role as a fact witness regarding Brewbaker's May 15 whistleblower email. Gannett seeks general transparency; Brewbaker seeks transparency \textit{plus} evidence essential to his liberty, financial claims, and exposure of specific alleged misconduct impacting state funds and potentially the Governor's family – interests foreign corporation Gannett cannot adequately represent. The public interest in accountable governance and electoral integrity, impacted by the alleged secrecy surrounding potential corruption, is also better represented by an affected citizen/candidate/relator than a corporate media entity. Plaintiffs' selection of only Gannett further suggests Brewbaker's distinct interests are unrepresented. Recall in Trump v. Selzer (4:24-cv-00449)
District Court, S.D. Iowa that foreign corporation Gannett largely admitted this - removing itself from the Iowa Courts. 
        
        
  \end{enumerate}
 
 
 \item \textbf{Permissive Intervention (Rule 1.407(b))}: Alternatively, Brewbaker's claims regarding access under Chapter 22 and the invalidity of the privilege share common questions of law and fact with the main action. Intervention will aid the Court by providing critical context, legal arguments (e.g., on *Peterzalek*'s implications, AG conflicts), and perspective not offered by the existing parties.
    \item \textbf{Timeliness}: This Motion is filed promptly after Brewbaker became aware of the specifics of this action and its direct implications for his rights.
\end{enumerate}
 
 
 
 \section{PROPOSED PLEADING}
\begin{enumerate}
    \item Attached hereto as \textbf{Exhibit A} is Proposed Intervenor's Resistance to Plaintiffs' Petition for Injunctive Relief.
\end{enumerate}
 

\section{PRAYER FOR RELIEF}
\noindent WHEREFORE, Proposed Intervenor Chad Brewbaker requests the Court grant this Motion to Intervene as a matter of right, permit the filing of Exhibit A, and allow Brewbaker to participate fully as a party in this action.

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\noindent Dated: \rule{2in}{0.4pt} % Placeholder for date

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\noindent Respectfully submitted, \\
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\noindent \rule{3in}{0.4pt} \\
Chad Brewbaker, \textit{Pro Se} \\
[Your Street Address] \\
Urbandale, IA [Your Zip Code] \\
[Your Phone Number] \\
[Your Email Address] \\
\textit{Proposed Intervenor}

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\section*{CERTIFICATE OF SERVICE} % Unnumbered section
I hereby certify that on \rule{1.5in}{0.4pt} [Date], I electronically filed the foregoing Motion to Intervene with the Iowa E-File system which will send notification of such filing to all counsel of record.

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\noindent \rule{3in}{0.4pt} \\
Chad Brewbaker

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% START OF EXHIBIT A: PROPOSED INTERVENOR'S RESISTANCE
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\begin{center}
\textbf{IN THE IOWA DISTRICT COURT FOR POLK COUNTY}
\vspace{1em}

% ... [Case Caption as before] ...
\textbf{RECORDS CUSTODIAN OF THE} \\
\textbf{GOVERNOR and} \\
\textbf{IOWA OFFICE OF} \\
\textbf{THE GOVERNOR,} \\
\vspace{0.5em}
\hspace*{1em} \textbf{Plaintiffs,} \\
\vspace{1em}
\textbf{v.} \\
\vspace{1em}
\textbf{THE DES MOINES REGISTER} \\
\textbf{\& TRIBUNE COMPANY d/b/a} \\
\textbf{THE DES MOINES REGISTER} \\
\textbf{and d/b/a DES MOINES} \\
\textbf{REGISTER MEDIA,} \\
\vspace{0.5em}
\hspace*{1em} \textbf{Defendant.} \\
\vspace{2em}
\textbf{Case No. [Insert Case Number Assigned by Clerk]} \\
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\textbf{EXHIBIT A: PROPOSED INTERVENOR'S RESISTANCE TO} \\
\textbf{PLAINTIFFS' PETITION FOR INJUNCTIVE RELIEF} \\
\vspace{2em}
\end{center}

\noindent\textbf{Proposed Intervenor:} \\
Chad Brewbaker, individually and as a resident of Urbandale, Iowa; \\
State of Iowa ex rel. Brewbaker (as qui tam relator); \\
Brewbaker for Iowa; and \\
Flying Dog Solutions LLC / Flying Access Residuals LLC \\
\vspace{2em}

Proposed Intervenor Chad Brewbaker ("Brewbaker"), having been granted leave to intervene, resists Plaintiffs' Petition for Injunctive Relief under Iowa Code \S~22.8, stating as follows:

\section{INTRODUCTION}
\begin{enumerate}
    \item Plaintiffs seek to shield four public records from disclosure based on a fabricated "executive privilege" unknown to Iowa law. This action arises from a public controversy involving Governor Reynolds, social media figures (Jennica Pounds, Elon Musk), Congress (Rep. Krishnamoorthi), and allegations against Lutheran Services in Iowa (LSI) surrounding the Governor's Feb 5, 2025 testimony and Feb 10, 2025 clarification.
    \item The Des Moines Register's request targeted communications from the Governor's senior staff during this exact timeframe (Feb 5-10, 2025) using keywords reflecting the controversy ("Lutheran," "Money-laundering," "raja," "krishnamoorthi"). The four withheld emails concern the Governor's office's handling of this scrutiny.
    \item This case directly impacts Brewbaker's rights as a criminal defendant potentially entitled to \textit{Brady/Giglio} material within these emails, as a \textit{qui tam} relator fighting state financial secrecy, and as a journalist investigating related matters including alleged improper use of state funds and potential conflicts involving the Governor's family (LenderClose). Plaintiffs' attempt to invent a privilege here is an abuse of process aimed at concealing potentially damaging or exculpatory information relevant to ongoing legal matters and public accountability.
\end{enumerate}


\section{ARGUMENT}

\subsection{Plaintiffs' Petition is an Abuse of Process, Resting on a Flawed Premise and Seeking to Improperly Shield Potential Evidence.}
\begin{enumerate}
    \item This \S~22.8 proceeding is illegitimate and constitutes an abuse of process due to multiple factors demonstrating Plaintiffs' lack of good faith and attempt to misuse the courts:
        \begin{enumerate}
             \item \textit{Potential Brady/Giglio Suppression:} The withheld emails (Feb 5-10, LSI/Krishnamoorthi) directly relate to the subject matter (state handling of non-profit issues/allegations) surrounding Brewbaker's May 15, 2024 whistleblower email, which allegedly led to his retaliatory criminal charge and was received by Plaintiffs' counsel AAG Wessan. The emails could contain critical exculpatory or impeachment material regarding state officials' knowledge, actions, bias, or motive concerning the underlying issues or the response to whistleblowers like Brewbaker. Plaintiffs cannot use a civil injunction proceeding asserting a novel privilege to potentially conceal evidence relevant to a criminal prosecution they (or related state actors) are pursuing, especially where criminal discovery is allegedly blocked. This use of \S~22.8 constitutes an abuse of process aimed at suppressing potential \textit{Brady/Giglio} material.
            \item \textit{Plaintiffs' Inconsistent Position on Attorney Discovery/Privilege (\peterzalekcite{}):} Plaintiffs' counsel (Solicitor General Wessan/AG's Office) recently argued forcefully \textit{against} deposing attorneys in \peterzalekcite{}, emphasizing burden, privilege, and the need for stringent limits (\textit{Shelton} test). \textit{Id.} at 105-06. Yet here, the same office initiates litigation seeking to establish a \textit{new, broad document privilege} based on generalized concerns ("candid advice"), contradicting their prior stance on the limits of privilege and discovery burdens. This stark inconsistency highlights the potential pretextual nature of their claim and undermines their credibility. They cannot credibly argue attorney depositions are uniquely burdensome and protected (\textit{Peterzalek}) while simultaneously inventing a sweeping document privilege under Chapter 22. Furthermore, AAG Wessan's role as recipient of Brewbaker's May 15 email makes him a potential fact witness, creating a conflict with his advocacy for secrecy here.
            \item \textit{Tainted by Alleged Systemic Illegality (\textit{Hoegh}) / § 13.7 Violations:} The alleged widespread use of private attorneys by state/local entities without proper authorization under \S~13.7/\S~331.757 (potentially including counsel involved directly or indirectly with Brewbaker's matters) taints related state actions per \textit{State v. Hoegh} and undermines Plaintiffs' standing to seek equity. This alleged illegality has also obstructed Brewbaker's criminal proceedings.
            \item \textit{Pattern of Concealment Impedes Informed Request:} Plaintiffs' alleged pattern of concealing financial information (\S~13.7 fees, \S~13.11 funds, ISU matters/LenderClose/missing exhibits, Wells Fargo loans) creates informational asymmetry and demonstrates a practice contrary to Chapter 22's purpose. Brewbaker's own Chapter 22 requests on related matters since Dec 2024 have allegedly been ignored.
            \item \textit{Defendant's Inadequate Representation:} Defendant Gannett (a foreign corporation) cannot adequately represent Brewbaker's specific Iowa citizen interests, particularly his liberty interest (\textit{Brady/Giglio}) and \textit{qui tam} interest tied to the alleged underlying financial misconduct involving potential gubernatorial conflicts.
            \item \textit{Petition Lacks Legitimacy:} This § 22.8 action, arising from this flawed predicate, potential \textit{Brady}/\textit{Giglio} suppression, Plaintiffs' inconsistent legal positions (\textit{Peterzalek}), alleged underlying illegalities, and conflicts involving Plaintiffs' counsel and the Governor's family/business connections, lacks good faith and is an abuse of the judicial process.
        \end{enumerate}
\end{enumerate}


\subsection{Plaintiffs' Baseless "Executive Privilege" Claim is an Unconstitutional Attempt to Override Statute.}
\begin{enumerate}
     \item \textit{Statutory Silence is Determinative:} Iowa Code Chapter 22 meticulously lists specific exemptions in \S~22.7; "executive privilege" is conspicuously absent. The Legislature's express mention of certain exemptions implies the exclusion of others (\textit{expressio unius est exclusio alterius}). This comprehensive scheme leaves no room for judicially created exceptions.
    \item \textit{Constitutional Arguments Misapplied:} Plaintiffs' reliance on general separation of powers principles (Art. III \S~1, Art. IV \S~1) to invent a privilege overriding a specific statute is misplaced. Chapter 22 *is* the constitutional exercise of legislative power regarding public records access (Art. XII \S~1). It does not impermissibly interfere with core executive functions.
    \item \textit{Separation of Powers Requires Respect for Statute:} The judiciary creating a constitutional exemption where the legislature explicitly did not would usurp the legislative function, violating separation of powers.
    \item \textit{No Compelling Interest Justifies Overriding Statute:} Even if an inherent privilege could theoretically exist, it would require satisfying strict scrutiny where fundamental rights (access, defense) are impacted. Plaintiffs offer only vague assertions of "candid advice," failing utterly to show a compelling interest that outweighs the clear statutory mandate for disclosure and Brewbaker's specific constitutional rights, nor is their claim narrowly tailored.
    \item \textit{Case Law/Other Statutes Inapplicable:} Dicta in cases like \textit{Howard v. Des Moines Register & Tribune Co.}, 283 N.W.2d 289 (Iowa 1979) or federal cases like \textit{Nixon} do not establish this privilege under Iowa's distinct Chapter 22 framework. The attorney work product/privilege discussion in \peterzalekcite{} concerned attorney *depositions* under discovery rules, not a Chapter 22 *document privilege*, and actually reinforces the limits of such claims. Iowa Code \S~622.11 (confidential communications) is also inapplicable here.
\end{enumerate}

\subsection{Secrecy Here Contradicts Public Interest, Especially Given Liberty and Financial Integrity Stakes.}
\begin{enumerate}
    \item The strong public policy favoring disclosure under Chapter 22 is paramount. Given the potential \textit{Brady}/\textit{Giglio} implications for Brewbaker's liberty, the alleged pattern of financial misconduct and concealment (\S~13.7/331.757, \S~13.11, ISU/LenderClose, missing exhibits), Plaintiffs' inconsistent positions (\textit{Peterzalek}), and the context of retaliatory prosecution, secrecy is profoundly contrary to the public interest. Disclosure is essential for accountability and justice.
    \item The alleged pattern of misconduct—including issues raised in the 2018 ISU Daily article, NAAG/"slush fund" controversies, the sealed FCA case, alleged Wessan/Legislature concealment, non-response to Brewbaker's own requests, alleged actions involving Governor's family (Strawn/LenderClose/Davis) and missing trial exhibits, and attempts to deem Brewbaker "incompetent"—destroys any claim Plaintiffs might have to the equities favoring secrecy.
\end{enumerate}


\subsection{Rigorous Judicial Scrutiny, Including Threshold Inquiry into Foundational Compliance, is Mandated.}
\begin{enumerate}
    \item Given the serious allegations of abuse of process, potential \textit{Brady}/\textit{Giglio} suppression via this civil action, alleged systemic illegalities (\textit{Hoegh}), and Plaintiffs' suspect claims, the Court must intervene proactively and skeptically.
    \item \textit{In camera} review of the four emails is the absolute minimum required.
    \item \textit{Threshold Inquiry into Ministerial Compliance and Good Faith Required:} This is not premature discovery, but a necessary step to assess the legitimacy of Plaintiffs' Petition itself. To determine if Plaintiffs have standing to seek equity and are acting in good faith, and to uncover potential \textit{Brady}/\textit{Giglio} material being shielded *by this very action*, the Court must conduct an immediate \textit{in camera} review of foundational documentation verifying (or refuting) basic legal compliance related to the context of this dispute. This threshold review must include documentation regarding:
        \begin{enumerate}
            \item Authorization (or lack thereof) for \S~13.7/\S~331.757 payments to private law firms potentially involved (e.g., Nyemaster, Daigle, Belin McCormick, Brick Gentry, Husch Blackwell, Handley Law).
            \item Records showing flow/use of funds under \S~8.44 (Additional Funds Received) potentially related to NAAG/RAGA or other sources relevant to alleged FCA violations.
            \item Status/details of alleged unauthorized ISU/Wells Fargo loans, ISU Foundation offshore funds, and LenderClose-related financial records potentially involving state action/funds (e.g., alleged undisclosed \$1m payment).
            \item Any AG/DPS communications regarding handling of Brewbaker's whistleblower complaints or related criminal case strategy (esp. involving AAG Wessan).
            \item Records concerning alleged state payments related to US Courts judicial non-disclosures.
            \item The status and location of the missing 2019 State trial exhibits related to LenderClose.
        \end{enumerate}
    Accessing this baseline information is critical to evaluate Plaintiffs' good faith in bringing this § 22.8 action and to ensure the process is not being abused to conceal evidence relevant to Brewbaker's liberty (\textit{Brady}/\textit{Giglio}) and financial interests (\textit{qui tam}).
\end{enumerate}

\section{PRAYER FOR RELIEF}
\noindent WHEREFORE, Proposed Intervenor Brewbaker requests the Court:
\begin{enumerate}
    \item Grant intervention as a matter of right.
    \item Deny Plaintiffs' Petition for Injunctive Relief in its entirety as baseless and an abuse of process.
    \item Declare the asserted "executive privilege" invalid under Iowa Code Chapter 22 and Iowa's Constitution.
    \item Order immediate \textit{in camera} review of the four withheld emails AND conduct the threshold \textit{in camera} review of the foundational compliance documents listed in Section II.D, Para. 16(a)-(f) above to assess the legitimacy of this Petition and identify potential \textit{Brady}/\textit{Giglio} material or evidence of misconduct relevant to Brewbaker's rights being improperly shielded by this action.
    \item Issue a detailed public factual summary of the four emails following review.
    \item Issue appropriate orders regarding the disclosure or preservation of any identified \textit{Brady}/\textit{Giglio} material or evidence of financial misconduct found during the threshold review pertinent to Brewbaker's ongoing legal matters.
    \item Order Plaintiffs to immediately release the four withheld documents to Defendant and Intervenor.
    \item Award Intervenor his costs and reasonable attorney fees (if applicable \textit{pro se}) pursuant to \S~22.10(3)(c).
    \item Grant such other relief as is necessary to protect Intervenor's constitutional rights and ensure justice, including potential dismissal of the petition due to abuse of process or referral of matters for investigation.
\end{enumerate}


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\noindent Dated: \rule{2in}{0.4pt} % Placeholder for date

\vspace{2em}

\noindent Respectfully submitted, \\
\vspace{2em}
\noindent \rule{3in}{0.4pt} \\
Chad Brewbaker, \textit{Pro Se} \\
[Your Street Address] \\
Urbandale, IA [Your Zip Code] \\
[Your Phone Number] \\
[Your Email Address] \\
\textit{Proposed Intervenor}

\end{document}