De 174 - Deft's Verified Motion to Dismiss, To Disqualify the Prosecution Team, For a Taint Hearing and a Continuance

7/26/2019 De 174 - Deft's Verified Motion to Dismiss, To Disqualify the Prosecution Team, For a Taint Hearing and a Continua

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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA

CASE NO. 14-20715-CR-COOKE/TORRES

UNITED STATES OF AMERICA, :Plaintiff, :

v. ::

SALO SCHAPIRO, et al., :Defendants. :

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :

DEFENDANT SCHAPIROS VERIFIED MOTION TO DISMISS,

TO DISQUALIFY THE PROSECUTION TEAM,FOR A TAINT HEARING AND

A CONTINUANCE

For the past sixteen months, contrary to the representations made to

undersigned, the FBI case agent has been surreptitiously obtaining from the

Government-contracted copy service CDs containing duplicates of the subset of

discovery documents that Dr. Schapiro and his defense team hand-selected for

copying to be used by the defense team in preparing his defense at trial classic

work-product. The FBI agent has confessed that she opened four of the CDs and

copied materials from those CDS to prepare for the prosecution of this case. When

undersigned learned of this intrusion, undersigned confronted the Director of the

copy service, who stated that this practice of cloning the defendants work-product

had been done at the request of an agent of the Government and has been the

practice of the U.S. Attorneys Office for the Southern District of Florida for at

Case 1:14-cr-20715-MGC Document 174 Entered on FLSD Docket 05/26/2016 Page 1 of 17


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least ten years. Undersigned has since learned of a series of additional deceptions

and misrepresentations made by the Director of the copy service to undersigned that

has compromised the integrity of the entire discovery process.

Pursuant to Rules 12 and 16 of the Federal Rules of Criminal Procedure, the

Fifth and Sixth Amendments to the United States Constitution, and the

supervisory powers of this court, Dr. Schapiro moves to dismiss the indictment with

prejudice.

I. STATEMENT OF FACTS

Dr. Schapiro was indicted on September 25, 2014. The government

promptly informed defense counsel that discovery included 220 boxes of

documents seized from Biscayne Milieu, and that defense counsel could review

that discovery at the FBI warehouse in Miramar. The documents in those boxes

were not Bates-stamped. The documents in those boxes were randomly placed in

the boxes, in no particular order.

Beginning as early as December 2014, and continuing until as recently as

April 2016, attorney Rossana Arteaga-Gomez, on behalf of Dr. Schapiro, visited

the FBI warehouse in Miramar, Florida, to review that discovery. Ms. Arteaga-

Gomez was often accompanied by Dr. Schapiro and/or other members of Dr.

Schapiros defense team. At the warehouse, the Schapiro defense team was

escorted by a federal agent into a very large conference room full of bankers



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boxes with approximately eight long, picnic-sized conference room tables. The

conference room has two double doors on each end. Whenever the defense team

was reviewing documents at the warehouse, a federal agent was present in the

room, presumably to ensure that none of the documents were tampered with or

removed from the premises. However, the defense team always sat at a distance

sufficiently far away so that the agent could not overhear any of the confidential

communications between members of the defense team.

During the first visit to the warehouse, Ms. Arteaga-Gomez was informed by

federal agents that if she wanted to copy any documents, she would have to use a

particular copy service, Imaging Universe, whose Director is Ignacio Montero.

Ms. Arteaga-Gomez was told that each bankers box was numbered. She was

instructed to set aside any documents that she wanted copied from each box and

to write on a post-it note the number of the box from which the documents came

and place the post-it note on the toppage of each set of documents retrieved from

the numbered box. At the end of each visit, all of the documents set aside by the

defense team were placed into an empty box for Imaging Universe to pick up. Ms.

Arteaga-Gomez was told that Imaging Universe would pick up the documents and

that a representative of Imaging Universe would contact her to discuss how she

wanted the documents copied. Ms. Arteaga-Gomez expected that once the hand-

selected documents were copied, the documents would be placed back into the



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numbered box from where they came, without anyone from the prosecution team

using the copy-process as a subterfuge for tracking the documents that the defense

team deemed signicant.

The defense team followed this procedure each time they visited the

warehouse since at least December 2014. Ms. Arteaga-Gomez has visited the

warehouse approximately thirteen times at least on three occasions with Dr.

Schapiro, who himself selected documents to be copied and conferred with Ms.

Arteaga-Gomez about those selections. At other discovery conferences, Ms.

Arteaga Gomez was accompanied by either one or two private investigators and a

nursing consultant.

Each time members of the defense team visited the warehouse, they selected

and compiled documents for scanning that they believed were important to the

defense. Some of the documents selected were chosen because they would be

useful to cross-examine and impeach government witnesses; others were selected

because they would be important for Dr. Schapiro to review in preparation for his

trial testimony (should he choose to testify); others were selected to assist the

defense team in deciding who to call as defense witnesses and to allow those

witnesses to prepare for their testimony. The documents selected thus reveal areas

of cross examination of key government witnesses, theories of defense and the

identity of potential defense witnesses. Overall, these documents reflect Dr.



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Schapiros defense strategy. The documents selected constitute a small subset of

the documents contained in the 220 boxes of discovery seized from Biscayne

Milieu.

After Ms. Arteaga-Gomezs first visit to the warehouse, Ignacio Montero

from Imaging Universe contacted Ms. Arteaga-Gomez to discuss in what format

she wanted the documents copied. Ms. Arteaga-Gomez instructed Mr. Montero to

scan the documents, Bates-stamp them, and save them as PDF files onto a CD.

These instructions were presumably followed by Mr. Montero every single time he

picked up documents from the warehouse. The CDs were sent to Ms. Arteaga-

Gomez containing PDFs of the documents selected for scanning.

Early on, the PDFs were named/titled by someone at Imaging Universe,

identifying the document that had been scanned. In subsequent productions, Ms.

Arteaga-Gomez herself instructed Mr. Montero to title the PDFs with labels she

indicated on a separate post-it note that she put on the physical document that was

going to be scanned (separate from the post-it note reflecting the number of the

box from which the document came). Ms. Arteaga-Gomez further instructed Mr.

Montero to remove the post-it notes with her labeling instructions before returning

the documents to the FBI warehouse. Mr. Montero assured Ms. Arteaga-Gomez

that he would follow those instructions. Mr. Montero also assured Ms. Arteaga-

Gomez that he was not providing a copy of the CDs to the Government and that



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no one from the Government had asked for a copy.

On March 16, 2016, Ms. Arteaga-Gomez asked Mr. Montero to rescan

certain documents because the scans were either too light to read or were missing

content from the original document (i.e., a portion of the document had been cut

off during the scanning process). Days later, Mr. Montero explained to Ms.

Arteaga-Gomez that it had taken longer than usual to re-scan the documents

because, after removing Ms. Arteaga-Gomezs post-it notes, it had taken a long

time to find the documents in the numbered boxes.

Over the course of approximately sixteen months, Imaging Universe made

nine discovery productions to the defense team, consisting of twelve CDs,

containing approximately 1,140 PDFs (many consisting of multiple pages), at a

cost to Dr. Schapiro of approximately $8,200 so far. The delivery dates

corresponding to those productions were: 12/29/14; 2/8/15; 4/3/15; 5/6/15; 9/21/15;

10/7/15; 3/14/16; 3/24/16; 4/20/16.1

Turns out, Mr. Montero lied to Ms. Arteaga-Gomez about the discovery

process. It appears that Mr. Montero had not been removing Ms. Arteaga-Gomezs

post-it notes after scanning the hand-selected documents; and, all along, Mr.

1Although the copy service produced 12 CDs, two of them contain the documentsthat were re-scanned from an earlier production. When we say that the 12 CDscontain 1,140 PDFs, that does not double-count for the approximately 240 PDFs thatwere re-scanned. There is a pending invoice of approximately $900 that Dr. Schapirohas not yet paid.



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Montero had been providing a duplicate CD of the defense teams hand-selected

discovery documents to F B I Agent Deanne Lindsey, the case agent on the

Schapiro case, who thereafter opened at least four of the CDs and used the

contents of the CDs as part of her pre-trial preparation. It appears that this practice

of surreptitiously duplicating the discovery work-product of defense counsel in the

Southern District of Florida has been the norm for at least the last ten years. Here

is how we know all of this:

In an April 21, 2016 email from Mr. Montero to Cori Weiss, Healthcare

Fraud Paralegal Specialist at the U.S. Attorneys Office, Mr. Montero wrote that

Ms. Arteaga-Gomez wanted Mr. Montero to remove the post it notes prior to

returning the files and to ensure your office [U.S. Attorneys Office] does not

receive a copy of the disc. In the email, Mr. Montero further states:

I do not want it to jeopardize the case and it is for this reason that I amadvising the AUSA, Agent to please advise moving forward so that

my providing of a disc being paid by your [U.S. Attorneys] officewill not affect this case.Also, does the AUSA/Agent want our office

to remove these post it notes as they are your offices originals andnot opposing counsels.

See Ex. 1, Email 4/21/16 from Montero to Weiss (emphasis added). This

email suggests that Mr. Montero was not removing Ms. Arteaga-Gomezs post-it

notes before returning the documents to the FBI warehouse, and confirms that he

was providing a copy of the CDs to the government, contrary to the representations

made to Ms. Arteaga-Gomez.



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In an April 22, 2016, telephone conversation, AUSA Hayes informed Ms.

Arteaga-Gomez that Mr. Montero had in fact been providing one of the federal

agents copies of the CDs. AUSA Hayes proposed to immediately destroy the CDs.

Ms. Arteaga-Gomez asked AUSA Hayes to instead send her the CDs, rather than

destroy them, which he did. They remain in the possession of undersigned law firm

in the same condition that they were produced to us by AUSA Hayes. This April

22, 2016 conversation with AUSA Hayes was the first time that the defense team

was informed that the federal agent had been surreptitiously receiving the CDs.

Also on April 25, 2016, Ms. Arteaga-Gomez called Mr. Montero to ask him

who had instructed him to provide copies of the CDs to the government. Mr.

Montero stated that an agent had asked the Office Manager at Imaging Universe,

Jackie Balzola (a female), to provide the CDs to the government. Mr. Montero then

stated that he had been providing to the U.S. Attorneys Office for the past 10

years duplicate copies of the discovery documents selected by defense counsel in

other cases. On that day, Mr. Montero forwarded to Ms. Arteaga-Gomez his April

21, 2016 email to Cori Weiss (discussed above). In the forwarded email, Mr.

Montero writes:

Here is the email I sent the FBI and this practice has been one that hasbeen going on since 2006 that both Xpediacopy my old company andImaging Universe have provided the U.S.D.O.J. in the majority of thecases where the government was not paying for the discovery servicesor were paying for half of the services.



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See Ex. 1, Email from Ignacio Montero, Director of Imaging Universe.

On April 26, 2016, Ms. Arteaga-Gomez received an email, purporting to be

from Jackie Balzola, Office Manager of the copy service. In that email, Jackie

Balzola tells Ms. Arteaga-Gomez that she does

not work full time any longer due to surgery with my knees as well as Iam dealing with Lupus. I come in early in the morning set up invoicesand deliveries for the day and then I go home. Regarding BiscayneMillieu, I have not spoken to or been given instructions by any agentto provide a disc, this is something that has been ongoing as perIgnacio on every case.

See Ex. 2, Email (4/26/16) from Jackie Balzola, Office Manager.

In the last several weeks, undersigned counsel have had multiple

conversations with the prosecutors and their supervisors about this situation. The

U.S. Attorneys Office (USAO) has admitted that Agent Deanne Lindsey had been

receiving copies of the CDs and had been keeping the duplicate CDs in a folder as

she received them; that she confessed to opening four of those duplicate CDs to

locate files that were contained on those CDs; that she copied and pasted some of

the files on those duplicate CDs onto her own CDs and provided those new CDs to

the Governments expert witness for trial preparation.

In order for FBI Agent Lindsey to locate files on the duplicate CDs that she

admits she copied, she would have had the opportunity to see the titles of all of the

PDFs that were contained on the CDs, even if she did not look at the PDFs

themselves. The titles of the PDFs reveal the identity of the hand selected



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documents that Dr. Schapiro and counsel deemed important to the defense at trial.

This week, the USAO notified undersigned that the Director of the copy

service, Ignacio Montero, has confessed to lying to Rossana Arteaga-Gomez about

the discovery process. Montero lied when he told Rossana Arteaga-Gomez that the

CDs were not being provided to the Government; he lied when he told Rossana

Arteaga-Gomez that Jackie Balzola was the Office Manager at Imaging Universe

(apparently, she has not worked at Imaging Universe for some time); he used a

shadow email address with Jackie Balzolas name and signature when sending

emails to Rossana Arteaga-Gomez, making it appear that the emails were coming

from Jackie Balzola, when someone else (perhaps Ignacio, himself) was emailing

Rossana Arteaga-Gomez; and he enlisted an unidentified girlfriend to falsely

impersonate Jackie Balzola when Rossana Arteaga-Gomez called to discuss

problems with copying the Rule 16 discovery.

II. LEGAL ARGUMENT

The conduct of the Government and the copy service is alarming. The

integrity of the Rule 16 discovery process has been compromised. The defendants

right to prepare for trial without Government intrusion has been violated. The case

should be dismissed.

The work-product doctrine applies to criminal litigation. United States v.

Nobles, 422 U.S. 225, 236 (1975). At its core, the work-product doctrine shelters



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the mental processes of the attorney, providing a privileged area within which he

can analyze and prepare his clients case. Id. at 238. A defense attorneys

selection and compilation of documents in preparation for trial constitutes work

product. United States v. Horn, 811 F. Supp. 739, 746 (D.N.H. 1992); see also

United States v. June, 10-30021, 2011 WL 5330788, at *2 (D. Mass Oct. 19,

2011). Courts have concluded that the selection process itself reveals counsels

mental impressions as to how evidence relates to issues and defenses in the

litigation.Horn, 811 F. Supp. at 746 (citing Sporck v. Peil, 759 F.2d 312, 315 (3d

Cir. 1985). The Horn court found that in a criminal proceeding where important

constitutional rights of due process under the Fifth Amendment and effective

assistance of counsel under the Sixth Amendment are at stake, along with the

liberty interests of the defendant[], this work product deserves special protection.

Id. at 747 (citingNobles, 422 U.S. at 238).

The government is forbidden from eavesdropping or planting agents to hear

or disrupt councils of the defense. See, e.g., United States v. Henry, 447 U.S. 264

(1980); O'Brien v. United States, 386 U.S. 345 (1967);Black v. United States, 385

U.S. 26 (1966); see also In re Terkeltoub, 256 F. Supp. 683, 685 (S.D.N.Y. 1966)

(The defendant has the right to prepare in secret . . . The prosecutions secret

intrusion offends both the Fifth and Sixth Amendment.) (citations omitted).



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Although the Sixth Amendment is concerned primarily with fairness

at trial, it is not limited to that function. The right to counsel protects

the whole range of the accuseds interests implicated by a criminal

prosecution. These interests may extend beyond the wish for

exoneration to include, for example, the possibilities of a lessercharge, a lighter sentence, or the alleviation of the practical burdens

of a trial.

***

Moreover, the appellants need not prove that the prosecution actually

used the information obtained. The prosecution makes a host of

discretionary and judgmental decisions in preparing its case. It would

be virtually impossible for an appellant or a court to sort out how any

particular piece of information in the possession of the prosecutionwas consciously or subconsciously factored into each of those

decisions. Mere possession by the prosecution of otherwise

confidential knowledge about the defense's strategy or position is

sufficient in itself to establish detriment to the criminal defendant.

Such information is inherently detrimental, ... unfairly advantage[s]

the prosecution, and threaten[s] to subvert the adversary system of

criminal justice. Further, once the investigatory arm of thegovernment has obtained information, that information may

reasonably be assumed to have been passed on to other governmental

organs responsible for prosecution. Such a presumption merely

reflects the normal high level of formal and informal cooperation

which exists between the two arms of the executive.

Briggs v. Goodwin, 698 F.2d 486, 494-95 (D.C. Cir.) (quoting Weatherford v.

Bursey, 429 U.S. 545, 556 (1977), rehg granted and opinion vacated on other

grounds, 712 F.2d 1444 (D.C. Cir. 1983).

Here, Agent Lindsey was obtaining duplicate copies of all of the CDs that

contained the defense teams work product. Agent Lindsey opened at least four of



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the CDs and disseminated at least some of the contents of CDs to the

Governments expert witness. Meanwhile Agent Lindsey placed before her own

eyes an index of the defendants hand-selected documents significant to his

defense. And Mr. Monteros email exposed that this practice is not the actions of

just one rogue agent or prosecutor. Compare Horn (one prosecutor in one case).

Rather, there appears to be an office-wide policy of the U.S. Attorneys Office

in the Southern District of Florida and the Federal Bureau of Investigations in

practice for at least ten years of surreptitiously copying defense counsels work

product through the government-contracted copy service that the Government

requires defense counsel to use to obtain the discovery documents needed to

properly prepare for trial.

Covertly cloning defense counsels work-product to obtain a tactical

advantage is nothing short of shocking to the universal sense of justice,

mandated by the Due Process Clause of the Fifth Amendment. United States v.

Russell, 411 U.S. 423, 432 (1973) (quoting Kinsella v. United States ex rel.

Singleton, 361 U.S. 234, 246 (1960)). Just the act of opening the CDs gave Agent

Lindsey an unauthorized preview of the titles of the documents hand-selected by

Dr. Schapiro and his defense team say nothing of Agent Lindsey actually helping

herself to the content of the CDs to prepare the case for the prosecution. To the

extent that the prosecution team can infer from Dr. Schapiros selection of



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discovery documents his thought process, the government has violated his Fifth

Amendment right not to be compelled to be a witness against himself. This

intrusion into the attorney-client relationship has also violated Dr. Schapiros Sixth

Amendment right to the effective assistance of counsel. See Massiah v. United

States, 377 U.S. 201, 206 (1964) (finding a Sixth Amendment violation where

agent surreptitiously listened in on defendants conversation after he was indicted

and represented by counsel). That the government-contracted copy service misled

Ms. Arteaga-Gomez in order to cover-up the office-wide policy makes this case

especially egregious. Dismissal with prejudice is the appropriate remedy. See

United States v. Levy, 577 F.2d 200, 208 (3rd Cir. 1978) (dismissing indictment,

rather than merely disqualifying prosecution team, where government invaded

the defense camp and learned defense strategies: The government's

knowledge of any part of the defense strategy might benefit the government in

its further investigation of the case, in the subtle process of pretrial discussion

with potential witnesses, in the selection of jurors, or in the dynamics of trial

itself. . . The government's knowledge of this planned strategy would permit it not

only to anticipate and counter such an attack on its witnesses credibility, but also

to select jurors who would be more receptive . . . .).

Alternatively, this Court should disqualify the entire prosecution team from

any further participation in the prosecution of Dr. Schapiro. The intrusion by any



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member of the prosecution team taints them all no different than when a conflict

of interest of one lawyer in a law firm disqualifies the entire law firm from

representation. See Freund v. Butterworth, 165 F.3d 839, 863 (11th Cir. 1999)

([A]ny conflict of interest attributable to Colton imputes equally to his current

partners and employees. Cox v. American Cast Iron Pipe Co., 847 F.2d 725, 729

(11th Cir. 1988); see also Rule Regulating Fla. Bar 41.10(a) (While lawyers are

associated in a firm, none of them shall knowingly represent a client when any 1 of

them practicing alone would be prohibited from doing so[.]). After all, Agent

Lindsey is the case agent, responsible for organizing the documents and

debriefing the cooperating witnesses in preparation for trial. She has tainted

herself and others by her unauthorized review of the defendants work-product.

The court should convene a taint hearing to identify who else had

possession of or access to the work-product and to require that the government bear

the burden of proving that it has not, nor will it, make any direct or derivative use

of the illegally obtained work-product. See generally Kastigar v. United States,

406 U.S. 441 (1972). Insofar as members of the t a i n t e d prosecution team

have prepared government witnesses to testify against Dr. Shapiro after the

instrusion, those witnesses should be excluded.

Meanwhile, the entire discovery process has been compromised and

paralyzed. For several weeks, while the USAO has been conducting its own



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internal investigation into the misconduct, there has been no reliable means for the

defense to continue its review and copying of the discovery. If this case is to

proceed to trial, the court must intervene and establish enforceable rules for the

continued review of the discovery and grant a meaningful continuance so that the

defense can regain access to the discovery and assure itself that the CDs that were

provided to date contain all of the key documents that the defendant requested

during the last 16 months.2

Respectfully submitted,

BLACK, SREBNICK, KORNSPAN& STUMPF, P.A.

201 South Biscayne Boulevard, Suite 1300Miami, Florida 33131Ph. (305) 371-6421 Fax (305) 358-2006E-mail:[email protected]

/s/ Howard SrebnickHOWARD SREBNICK, ESQ.Florida Bar No. 919063

/s/ Rossana Arteaga-GomezROSSANA ARTEAGA-GOMEZ, ESQ.Florida Bar No. 0014932

Counsel for Salo Schapiro

2Just yesterday, the Government notified defense cousel that additional Discoverywent out via FedEx, encl[osing] 4 DVDs of 302s and Medicare/SGS documents.

mailto:[email protected]:[email protected]


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VERIFICATION

I declare under penalty of perjury under the laws of the United States that

the facts as alleged in this pleading are true and correct to the best of my

knowledge, see 28 U.S.C. 1746.


CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on May 2, 2016, a draft of this motion was

served upon Assistant United States Attorney Jim Hayes for his review in an

attempt to resolve the issue without court intervention. The parties were not able to

resolve the matter.


Counsel for Salo Schapiro



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EXHIBIT 1

Case 1:14-cr-20715-MGC Document 174-1 Entered on FLSD Docket 05/26/2016 Page 1 of 2


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Rossana Arteaga-Gomez

From: Ignacio Montero

Sent: Monday, April 25, 2016 10:53 AM

To: Rossana Arteaga-Gomez

Subject: FW: Biscayne Millieu

HereistheemailIsenttheFBIandthispracticehasbeenonethathasbeengoingonsince2006thatbothXpediacopy

myoldcompanyandImagingUniversehaveprovidedtheU.S.D.O.Jinthemajorityofthecaseswherethegovernment

wasnotpayingforthediscoveryservicesorwerepayingforhalfoftheservices.

From:Ignacio Montero [mailto:[email protected]]Sent:Thursday, April 21, 2016 12:12 AMTo:'Weiss, Cori (USAFLS)'Subject:Biscayne Millieu

Cori,

Iapologize

Ihave

so

many

names

in

my

head

that

Ido

not

remember

the

agent

on

the

BM

case,

Iwant

to

let

her

know

thatwearedonewiththeproductionIamcurrentlyholdingitperopposingcounselasshewouldliketocheckthe

imagesfirstandhavemeremovethepostitnotespriortoreturningthefiles. Shealsowouldliketoensureyouroffice

doesnotreceiveacopyofthedisc. Yourofficeasifitweretheotherwayaroundcanpurchasethediscastheseare

youroriginals. Idonotknowwhattosayanymore,butIwouldlikesomeonewhetheritistheAUSAonthecasetobe

awareandmovingforwardIneedtohavearecordformyselfandwouldneedaprintordershouldyourofficewantthe

copyofthediscasyouknowthepriceis$15.00. IdonotwantittojeopardizethecaseanditisforthisreasonthatIam

advisingtheAUSA,Agenttopleaseadvisemovingforwardsothatmyprovidingofadiscbeingpaidbyyourofficewill

notaffectthiscase. Also,doestheAUSA/Agentwantourofficetoremovethesepostitnotesastheyareyouroffices

originalsandnotopposingcounsels. Mycellularislistedbelowforanyone,IwillbeindisposedattheVAtomorrowand

Iamnotsurehowlongthatwilltake,itistheVAbutpleaseletmeknowatyourearliest,Iwillcheckmyvoicemailand

respondas

quickly

as

Ican.

Ialso

may

not

have

access

to

my

email

and

may

reply

later

so

please

use

the

cellular

ifit

is

after4/21/1611am,thankyou.

Sincerely,

IgnacioE.Montero

Director

3350S.W.3rdAve.Ste.6

Fort

Lauderdale,

FL

33315

(954) 4688442Office

(954) 4681950Fax

(954) 6088646Cellular

www.imaginguniverse.com



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EXHIBIT 2



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Rossana Arteaga-Gomez

From: Imaging Universe, Inc. Info

Sent: Tuesday, April 26, 2016 6:57 AM

To: Rossana Arteaga-Gomez

Subject: Biscayne Millieu

Rosanna,

Goodmorning,Iwillcallyoualittlelaterinthemorning, Idonotworkfulltimeanylongerduetosurgerywithmy

kneesaswellasIamdealingwithLupus. Icomeinearlyinthemorningsetupinvoicesanddeliveriesforthedayand

thenIgohome. RegardingBiscayneMillieu,Ihavenotspokentoorbeengiveninstructionsbyanyagenttoprovidea

disc,thisissomethingthathasbeenongoingasperIgnaciooneverycase.

Warmregards,

JackieBalzola

OfficeManager

3350S.W.3rdAve.Ste.6

FortLauderdale,FL 3315

(954) 4688442Office

(954) 4681950Fax

www.imaginguniverse.com


Documents

De 174 - Deft's Verified Motion to Dismiss, To Disqualify the Prosecution Team, For a Taint Hearing and a Continuance