Then-former President Donald Trump delivers a speech at the Ellipse on Jan. 6, shortly before his mob of supporters ran riot inside the U.S. Capitol (Photo by Tasos Katopodis/Getty Images).
A federal judge in Florida has ordered an organizer of the Jan. 6, 2021, “Save America Rally” to pay a hefty fine for each day she continues to ignore a subpoena in a civil lawsuit brought by Capitol Police officers.
In a three-page order on a motion for contempt, U.S. District Judge Donald M. Middlebrooks, a Bill Clinton appointee, ordered Republican Party fundraiser Caroline Wren to pay “a daily fine of $2,000” until she “produces all responsive documents that fall within the scope of” the subpoena issued by the police officer plaintiffs.
Wren, however, is not the subject of the lawsuit itself.
Rather, some information said to be in her possession is being sought by Conrad Smith and other members of law enforcement “who suffered injuries” during the pro-Donald Trump attack on the U.S. Capitol Complex following the rally, the court”s order notes.
The underlying lawsuit was filed in Washington, D.C., federal court in August 2021; the 45th and 47th president is the named defendant. The lawsuit has taken numerous twists and turns over the years and is premised on alleged violations of the Ku Klux Klan Act of 1871, a federal law barring mob violence directed at federal officials.
While the litigation is weeks away from its fourth year, and while Trump’s attorneys have forcefully pushed back as to the extent of his liability, the trajectory of the cumulative rulings in the case has largely been in the plaintiffs’ favor – in terms of discovery, at the very least.
Pushing this advantage, the plaintiffs moved to subpoena Wren in 2023 – belatedly serving her with the court document in May 2024, according to their motion to compel compliance with the subpoena.
Wren “failed to respond” to the subpoena, the plaintiffs say. So, they filed an eight-page motion to compel compliance in September 2024.
“Ms. Wren is a Republican fundraiser who was closely involved in organizing the Save America Rally at the Ellipse in Washington, D.C., on January 6, 2021,” the motion reads. “On December 22, 2022, Julie Fancelli, a long-time donor to Defendant Trump, reached out to Ms. Wren regarding a donation to promote the Rally and increase attendance. Ms. Wren then became heavily involved in planning the Rally and surrounding logistics. Indeed, she was listed as a ‘VIP ADVISOR’ on the permit for the Rally.”
The United States Capitol Building in Washington, D.C. was breached by thousands of protesters during a “Stop The Steal” rally in support of President Donald Trump during the worldwide coronavirus pandemic (John Nacion/STAR MAX/IPx 2021 1/6/21).
The filing goes on like this, at length:
Ms. Wren acted as a key contact between Defendant Trump, the Trump Campaign, and event organizers such as Women for America First. Ms. Wren exchanged plans for the event with Katrina Pierson, an advisor to the Trump Campaign, and Justin Caporale, Defendant Trump’s former staffer who was closely involved in planning the Rally. They both texted her in advance of the Rally that Defendant Trump intended to start a march to the Capitol. Ms. Wren and Mr. Caporale texted about when Defendant Trump would direct the march to the Capitol during the Rally. Ms. Wren helped arrange for Ali Alexander, the leader of the Stop the Steal movement, to promote the Rally. Ms. Wren worked on the initial speaker list for the Rally, suggesting Mr. Alexander, Roger Stone, and Alex Jones—two other individuals associated with the Stop the Steal movement—as speakers. Ms. Wren also prepared the speech that Ms. Guilfoyle gave at the Rally. On January 6, 2021, during the Rally, Ms. Wren even communicated with Mr. Alexander—among others—regarding exact logistics for marching to the Capitol…
“Based on her involvement with the Rally, Movants identified Ms. Wren as a third-party subpoena target who can provide information relevant to their claims,” the motion continues. “The Subpoena requests documents regarding the Rally, including planning the programming, fundraising, communications about planning, the VIP section, security, and encouraging attendance.”
Now, after several orders from the court itself, Wren finds herself in contempt.
“On September 11, 2024, I ordered Respondent to secure counsel or advise the Court of her intent to proceed pro se by September 18, 2024,” Middlebrooks explains. “After Movants unsuccessfully attempted to serve my Order and a copy of their Motion to Compel on Respondent, I directed the U.S. Marshals to serve Respondent.”
The court details the timeline that followed:
The Marshals successfully served Respondent on February 7, 2025. On April 24, 2025, Movants filed a Renewed Motion to Compel, which I granted on April 28, 2025. In my Order, I instructed Respondent to comply with Movants’ subpoena on or by May 16, 2025. Now, Movants request that I hold Respondent in civil contempt, as she has failed to comply with my Order or otherwise contact Movants’ counsel.
The relatively terse order then runs through the standards for civil contempt – and finds that they apply in the present situation.
“Respondent has still failed to appear, respond to the subpoena, or heed this Court’s instructions to secure counsel or appear pro se,” the order goes on. “She has also failed to comply with the Court’s Order to Compel and Order to Show Cause, and has not made any attempt to explain her refusal to engage in proceedings. This ‘pattern of disregard and non-engagement’ has unduly delayed proceedings in the Underlying Action and deprived Movants of the fair and full access to discoverable material to which they are entitled. I will therefore hold Respondent in civil contempt, and impose a daily monetary fine until Respondent complies. If these fines prove ineffective, I will consider additional steps to spur her compliance.”
