EFTA00750913.pdf

THIS DOCUMENT IS PROTECTED BY THE ATTORNEY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE To: Robert Critton From: William Riley / Christine Jannotti Date: July 14, 2009 Re: Epstein / Background re: re File: 8577R On July 14, 2009 Investigator Christine M. Jannotti completed initial background research of available public records on: , white male DOB: SSN: FL/DL: LKA: ALIASES: None identified SPOUSE: None Identified OTHER: Mother: Girlfriend: (father of one of her children) The purpose of this background research was to identify and obtain background related information as it relates to CRIMINAL Criminal Court Case Research A review of the indexes, both computer and microfiche of the Southern District of Florida (federal) and on a national basis for the past seven (7) years, Palm RILEY KIRALY 1 5645 CORAL RIDGE DRIVE, BOX 391. CORAL SPRINGS. FLORIDA 33076 OFFICE: 305.825.6120 FACSIMILE: 305.825.1101 www.rilevkiralv.com EFTA00750913  THIS DOCUMENT IS PROTECTED BY THE ATTORNEY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE Beach County, Florida and in Tuscarawas County, Ohio (state) to include the Domestic Violence, indicated was named in seven (7) criminal cases. The following information was developed: 1) Palm Beach County, Felony Court Case was filed on 02/08/08 when was arrested for Sale of Cocaine after the DEA conducted an investigation that started on 08/25/06 along with the W. Palm Beach Police and the Palm Beach Sheriffs offices and a confidential source and officers arranged for a sale and purchased $700.00 worth of cocaine and (11) Ecstasy pills from was arrested on 02/07/08 as per a warrant from the under cover investigation. The case was closed on 04/24/08 when was found guilty and was given a withhold of adjudication and sentenced to (2) years of probation which was transferred to Ohio and fined $663.00. On 07/24/08 he violated his probation and we re- arrested on 08/06/08 and sentenced on 09/26/08 to (6) months in jail with credit for (85) days already served. On 11/05/08 he violated again and his probation was revoked. 2) Palm Beach County, Felony Court Case was filed on 09/27/06 when was arrested for Reckless Driving, Resisting Officer/Fleeing, Driving While License Suspended and Resisting Arrest without Violence after was seen speeding at a high rate of speed in an illegal lane and then ran a stop sign squealing the tires while turning. Officers waived him to stop, but he fled and was caught by police and arrested. The case was set for arraignment and he failed to appear and was re-arrested on 02/14/07. On 03/14/07 the case was closed and he was found guilty and sentenced to (28) days in jail with credit for time served and fined $333.00. RILEY KIRALY 2 5645 CORAL RIDGE DRIVE, BOX 391. CORAL SPRINGS. FLORIDA 33076 OFFICE: 305.825.6120 FACSIMILE: 305.825.1101 1,wnv.rilevkiralv.com EFTA00750914 THIS DOCUMENT IS PROTECTED BY THE ATTORNEY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE 3) Palm Beach County, Felony Court Case was filed on 04/06/06 when was arrested for Child Neglect when a neighbor called police because child was naked and sitting on the porch crying for help. Officers searched the house and found asleep and he told officers when asked that "Bubba" was missing and that they had fallen asleep together in the bed. The bed was under an open window. It was believed that the baby crawled through the open window, pushed out the screen and fell (3-4) feet to the ground. Officers pounded on the doors and windows before finding was arrested. DCF was notified and told officers that they had been to the house before in reference to using drugs in front of the (2) year old child. was not allowed near the child pending clearance from DCF. The case was closed and Nolle Prossed by the State Attorneys Offices on 05/31/06. 4) Palm Beach County, Misdemeanor Court Case was filed on 02/16/06 when was arrested for Possession of Cannabis after a traffic stop for no tail lights. On 04/03/06 the case was closed and he was found Guilty and fined $333.00 and on 08/07/06 his driver's license was suspended for not paying the fine. 5) Palm Beach County Misdemeanor Court Case was filed on 07/11/03 when was arrested for Possession of Cannabis during a DUI check point and discovered bald tires. They also smelled marijuana and searched the vehicle and located the drugs. On 03/01/04 the case was closed and he was found Guilty and fined $166.00. 6) Palm Beach County Misdemeanor Court Case was filed on 02/24/03 when was arrested for Possession of Cannabis after a traffic stop for no tail lights since was leaving a known RILEY KIRALY 3 5645 CORAL RIDGE DRIVE, BOX 391. CORAL SPRINGS. FLORIDA 33076 OFFICE: 305.825.6120 FACSIMILE: 305.825.1101 1,wew.rilevkiralv.com EFTA00750915  THIS DOCUMENT IS PROTECTED BY THE ATTORNEY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE drug house the vehicle was searched and the marijuana was discovered. On 04/29/03 the case was closed and was Nolle Prossed after completion of a Diversion Program for Substance Abuse. A copy of citation Notice to Appear and disposition are enclosed. 7) Palm Beach County Misdemeanor Court Case was filed on 02/01/02 when was arrested on 01/31/02 for Petty Theft with Charles Wilms after they stole a (12) pack of beer from a Hess Station and fled in a car with . All three were arrested and charged with theft. On 08/02/08 the case was closed and Nolle Prossed after completion of a Deferred Prosecution Agreement with the National Community Corporation. FDLE Research was conducted with the Florida Department of Law Enforcement for any Criminal History records on and research revealed the above arrests. POLICE RECORDS Research was conducted with the Palm Beach County Sheriffs Offices, West Palm Beach and the Royal Palm Beach Police Departments for any victim/subject/incident reports on and research revealed the above arrests and the following reports: 1) Palm Beach County Sheriffs Office Case was filed on 07/16/08 in reference to Child Abuse involving after DCF was called to investigate after tested positive for cocaine while on probation. Officers were called and told that only visits the child and does not live with him. The child lives with the Great Aunt. RILEY KIRALY 4 5645 CORAL RIDGE DRIVE, BOX 391. CORAL SPRINGS. FLORIDA 33076 OFFICE: 305.825.6120 FACSIMILE: 305.825.1101 1,wnv.rilevkiralv.com EFTA00750916 THIS DOCUMENT IS PROTECTED BY THE ATTORNEY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE 2) Palm Beach County Sheriffs Offices Case was filed on 05/18/08 in reference to a Resist of an Officer after investigating an Aggravated Assault with a firearm involving the arrest of was at the residence at the time of the incident. 3) Palm Beach County Sheriffs Offices Case was filed on 11/26/07 in reference to a Burglary that occurred when broke into a house with his cousin . It was a house was living at and had moved out of. was the owner of the house and was on vacation when they entered the house. They said the door was unlocked and they only retrieved her belongings. 4) Palm Beach County Sheriffs Offices Case is an active criminal case report and is not public record. 5) Palm Beach County Sheriffs Offices Case was filed on 06/20/05 in reference to an Armed Burglary that occurred when ROBBED home. was later arrested for dealing in the selling of the stolen property from the robbery. Later san anonymous caller called police and told them was bragging about the robbery. WAS ASKED TO GIVE A POLYGRAPH AND REFUSED. Due to lack of evidence, was not charged. 6) Palm Beach County Sheriffs Offices Case was filed on 04/13/05 in reference to a Battery involving boyfriend and threatened to put a bullet in his head if anything ever happened to his sister. started arguing with her brother and slapped him and RILEY KIRALY 5 5645 CORAL RIDGE DRIVE, BOX 391. CORAL SPRINGS. FLORIDA 33076 OFFICE: 305.825.6120 FACSIMILE: 305.825.1101 Iwv.rilevkiralv.com EFTA00750917  THIS DOCUMENT IS PROTECTED BY THE ATTORNEY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE he pushed her to the ground. was arrested for Battery. 7) Palm Beach County Sheriffs Offices Case was filed on 03/25/97 in reference to a Battery involving and his brother over a bicycle. They were living with their grandmother who was bed ridden at the time. 8) Palm Beach County Sheriffs Offices Case was filed on 06/09/96 in reference to a Burglary that occurred when attempted to rob while she and her son ( ) were watching TV tried to forcibly gain entry through their back door. 9) Palm Beach County Sheriffs Offices Case was filed on 10/27/95 in reference to a Domestic Disturbance involving and his mother who told police she was having nothing but trouble with her (11) year old son because of a bitter divorce. was running away from home and told police his mother is a drug addict and he doesn't want to live there anymore. His mother wanted him Baker Acted but police said he didn't fit the criteria. CORPORATE A review of the indexes for the State of Florida, Department of State, Division of Corporations indicates was not named in any corporations and/or business entities. These indexes were reviewed in an attempt to identify corporate or business entities is or may have been involved in order to further develop research as it relates to potential background information. RILEY KIRALY 6 5645 CORAL RIDGE DRIVE, BOX 391. CORAL SPRINGS. FLORIDA 33076 OFFICE: 305.825.6120 FACSIMILE: 305.825.1101 1,wew.rilevkiralv.com EFTA00750918  THIS DOCUMENT IS PROTECTED BY THE ATTORNEY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE CIVIL A review of the indexes for the Southern District of Florida (federal) and on a national basis for the past seven (7) years to include Bankruptcy Court, Palm Beach County, Florida and Tuscarawas County, Ohio Circuit and County Courts to include Domestic Violence revealed was named in four (4) cases, liens and/or judgments. The purpose of this review is to further develop information and identify witnesses as it relates to potential background information. The following information was developed: 1) Tuscarawas County Court, Ohio, Southern District Civil Case was a civil case that was filed on 03/01/07 and dismissed on 04/18/07. 2) Palm Beach County, Family Court Case State of Florida re: vs. Shawn W. was a Petition for Child Support that was filed on 02/15/05. The case was closed on 05/23/05 when an Order for support was granted. See memo for copies. 3) Palm Beach County, County Court Case Martha Lendzion-Venherm vs. was an Eviction case that was filed on 11/09/04 and was dismissed on 11/22/05. 4) Tuscarawas County Court, Ohio, Southern District Civil Case oney Now vs. was a civil case that was filed on 10/17/03 and dismissed on 03/01/04. OTHER RELATED RESEARCH FLORIDA DRIVERS LICENSE RILEY KIRALY 7 5645 CORAL RIDGE DRIVE, BOX 391. CORAL SPRINGS. FLORIDA 33076 OFFICE: 305.825.6120 FACSIMILE: 305.825.1101 Iwv.rilevkiralv.com EFTA00750919  THIS DOCUMENT IS PROTECTED BY THE ATTORNEY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE Research was conducted with the State of Florida, Department of Motor Vehicles, Division of Drivers licenses and research revealed an identification record issued originally to for identification purposes only on 01/16/02 under license ID and expires on 12/03/2011 at an address of The license shows suspensions for not paying traffic fines, not paying court costs, driving while license suspended and felony possession of a controlled substance suspensions for (2) years as of 09/26/08. The license is currently under suspension for the possession charges and for not paying fines as recently as 05/07/09. A copy of the history is enclosed. (See exhibit 21) FORMER OR PRIOR ADDRESSES has listed or used that following addresses in addition to those mentioned previously in this report: CMJ: WHR Enclosures 8577R.Gitchrlst.Donald RILEY KIRALY 8 5645 CORAL RIDGE DRIVE, BOX 391. CORAL SPRINGS. FLORIDA 33076 OFFICE: 305.825.6120 FACSIMILE: 305.825.1101 1,wew.rilevkiralv.com EFTA00750920