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helped each other in the past, and the circumstances of the kidnapping suggest the act was done to once again support the colleague in furtherance of the mutually beneficial relationship. Statement of Facts This memo analyzes whether the government will be able to prove all elements of federal kidnapping against thirty nine-year-old Dr. Alan Grant. Prior to the alleged kidnapping, both Grant and the alleged victim, Dr. Mary Schweitzer, were invited to Helena, Montana, to attend a meeting on Monday, June 20, 2011, designed to prepare Dr. Jack Horner for a hearing to take place on Wednesday, June 22, on his grant proposal at the National Science Foundation. Grant Stmt. p. 1; Schweitzer Stmt. p. 5. Dr. Jack Horner is a paleontologist and the director of the Museum of the Rockies located in Bozeman, Montana. Grant Stmt. p. 1. Upon arriving at the meeting on Monday, June 20, Schweitzer stated that she had made a discovery that cast serious doubts on the viability of Horner’s proposal. Schweitzer Stmt. p. 5; Grant Stmt. p. 2. Grant stated that Horner “did not want [Schweitzer] appearing before the NSF panel” and that he had asked Grant to “talk some sense into her.” Grant Stmt. p. 2. Later that day, Grant invited Schweitzer to an early dinner, to which she agreed. Grant Stmt. p. 2; Schweitzer Stmt. p. 5. They went to dinner, and when they got back into Grant’s truck, Grant announced that they were going to the Museum of the Rockies in Bozeman. Grant Stmt. p. 2. Grant said the trip was necessary for Schweitzer to “better understand the implications of [her] planned 2
testimony before the NSF.” Schweitzer Stmt. p. 5. Schweitzer said she told Grant that she “didn’t want to go there” but he “acted like he didn’t hear [her].” Id. Schweitzer said she “repeatedly told him to turn around and take [her] back to Helena so [she] could gather [her] things and catch [her] flight. [But] he just wouldn’t listen to [her].” Id. Grant admitted that Schweitzer said she didn’t want to go to the museum, but he “kept driving and she kept complaining.” Grant Stmt. p. 3. Grant said he “tuned her out.” Id. During the trip to the museum, Grant stated that a major accident on I-90 involving semi-trailer trucks caused him to take a detour onto I-15, which runs toward Idaho. Grant Stmt. p. 3. They traveled into Idaho before they could catch a direct road back into Montana and to the museum. Id. When they arrived at the museum, Schweitzer got out of Grant’s truck and attempted to walk back to the main road. Id. Grant “directed her into the museum by holding her arm.” Id. Once inside, Grant “flipped a switch to bolt down the fire doors” and he “took her cell phone.” Schweitzer Stmt. p. 6. Schweitzer tried to yell to get someone’s attention. Id. No one else was at the museum, however, because Dr. Horner always closes the museum during that particular week in June. Grant Stmt. p. 3. Grant and Schweitzer stayed at the museum from Monday evening until Thursday morning. Id. Grant maintains that he did not kidnap Schweitzer. Grant Stmt. p. 4. He said they were comfortable at the museum and that they were “colleagues having an important discussion about career-changing matters.” Id. Grant further stated that he was prompted to take these actions because he and Dr. Horner are “good friends” and he “wanted to do 3
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Page 5 and 6: was crossed while the victim was st
Page 7 and 8: oad, he “took [Schweitzer’s] ar
Page 9 and 10: courts reached this conclusion prio
Page 11 and 12: state lines is relevant. Id. (citin
Page 13: his truck at the museum, Schweitzer

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