THE PROOF, THEY SAY, IS IN THE PUDDING!
Set out, below, are the exhibits offered to the Disciplinary Counsel of the Ohio Supreme Court in support of the Complaint of Judicial and Prosecutorial Misconduct of CHRISTOPHER COLLIER, DEAN HOLMAN, and SCOTT SALISBURY.
As one can easily see, there's plenty of pudding to be spread around between these three corrupt functionaries of the corrupt Medina County Courts.
Exhibit 1 Common Pleas Docket,
Exhibit 2 Newspaper article, dated October 8, 2008, published online by the Medina Gazette, in which Medina County Prosecutor Dean Holman touts the 98% conviction rate of his office.
Exhibit 3 Copy of the legally deficient indictment returned by the Medina County grand jury, charging Defendant with Aggravated Burglary, in violation of O.R.C §2911.11.
Exhibit 4 Photograph of County Rd., looking northbound, toward Flintstone residence, from parents' residence.
Exhibit 5 Photograph of firearms kept parents’ home, to which Defendant had access.
Exhibit 6 Photograph of ammunition kept in parents’ home, to which Defendant had access.
Exhibit 7 Photograph of the tree line concealing the Flintstone driveway, looking northbound on County Rd. on the approach to the Flintstone residence
Exhibit 8 Photograph of the Flintstone driveway and residence, looking westbound from County Rd.
Exhibit 9 Copy of the cell telephone billing record of Defendant’s wife, documenting receipt of telephone call from Homerville, Ohio cell tower at 6:03 pm.
Exhibit 10 Transcript of excerpts from the May 27, 2009 911 call in which the State’s key witness admitted that she never saw Defendant on May 27, 2009 and was unable to observe or hear events outside the bedroom where she remained, admitted into evidence at the suppression hearing.
Exhibit 11 Timeline of events during the purported incident of May 27, 2009, constructed from the official reports of the Medina County Sheriff’s Office.
Exhibit 12 Copy of the constitutionally defective and unsworn criminal complaint, filed by Deputy Douglas Clinage with the Wadsworth Municipal Court, charging Defendant with Burglary; and lacking a statement of essential facts from which a neutral and detached judicial officer might otherwise find probable cause.
Exhibit 13 Copy of the constitutionally defective arrest warrant
Exhibit 14 Copy of Defendant’s Motion to Suppress
Exhibit 15 Copy of Defendant’s Supplement to the Motion to Suppress
Exhibit 16 Copy of the document falsified by the assistant prosecutor, which he turned over to the defense in discovery proceedings.
Exhibit 17 Copy of the narrative report of Deputy Frank Telatko
Exhibit 18 Copy of the pertinent portion of the narrative report of Deputy Douglas Clinage
Exhibit 19 Copy of Defendant’s Motion For An Order To Show Cause Why The Assistant Prosecutor Should Not Be Held In Contempt Of Court And Subject To Sanctions
Exhibit 20 Copy of Salisbury’s Notice of Underlying Crimes, none of which were considered by the Medina County grand jury.
Exhibit 21 Copy of Defendant’s Opposition to Prosecutors’ Alleged “Notice of Underlying Crimes”
Exhibit 22 Affidavits of Defense Investigator regarding the invasion of the defense camp by assistant prosecutor Salisbury, filed with the court.
Exhibit 23 Copy of the uncontested letter from Defense Counsel to assistant prosecutor Salisbury, dated November 11, 2009, memorializing her conversation with Salisbury wherein he conceded, prior to trial, that the alleged “other acts” evidence was inadmissible. Salisbury reconfirmed his agreement during the court’s discussion of the Motions in limine.
Exhibit 24 Motion to Quash with Affidavit of Defendant’s wife, filed with the court on July 27, 2009, asserting her spousal privilege.
Exhibit 25 Supplement to Motion to Quash with Affidavit of Defendant’s wife, filed with the court on September 11, 2009, again asserting her spousal privilege.
Exhibit 26 Copy of a personal letter sent by the Defendant’s wife to Salisbury, asserting her spousal privilege
Exhibit 27 Copy of Defendant’s proposed redactions to the 911 tape recording
Exhibit 28 Transcript of the relevant sworn testimony of Wilma Flintsone acquired during the trial wherein Wilma concedes that her trial testimony is inconsistent with her report to the 911 dispatcher on May 27, 2009, at which time she reported that she never saw Defendant.
Exhibit 29 Copy of the Victim Impact Statement submitted to the trial judge by homeowner Fred Flinstone advising the judge that Defendant did not commit the alleged “aggravated burglary” of Fred’s home. (Fred had previously advised the sheriff’s deputies that Defendant committed no crime and that Fred was not pressing charges against his friend. The prosecutor and the trial judge withheld this exculpatory evidence.)
Exhibit 30 Affidavit of trial Defense Counsel, attached to Defendant’s post-trial motions package.
Exhibit 31 Copy of the Medina County Sheriff’s evidence log, annotated by the evidence custodian to indicate specific items to be withheld from the defense per the instruction and order of Salisbury
Exhibit 32 Copy of the Defendant’s Motion for Acquittal; Motion for New Trial; Motion for Arrest of Judgment; Motion to Suspend Execution of Sentence; and Motion for Bail Pending Appeal
Exhibit 33 Copy of Defendant’s Additional Authorities and Exhibits in Support of the Defendant’s Motion for Acquittal; Motion for New Trial; Motion for Arrest of Judgment; Motion to Suspend Execution of Sentence; and Motion for Bail Pending Appeal
Exhibit 34 Affidavit of Defense Investigator concerning improper ex parte discussions between the trial judge and the assistant county prosecutor on December 18, 2009.
Exhibit 35 Affidavit of witness regarding subsequent admissions of Wilma Flintstone, the State’s only witness to incriminate Defendant, that Wilma had committed perjury at trial.
Exhibit 36 Copy of Defendant’s Post-Hearing Rebuttal Memorandum With Exhibits
Exhibit 37 Copy of a letter from Defense Counsel to Medina County Prosecutor Dean Holman, requesting a meeting to discuss the misconduct of Assistant County Prosecutor Scott Salisbury.
Exhibit 38 Copy of Salisbury’s post-hearing sham pleading, failing to cite any case authority.
Exhibit 39 Copy of Defendant’s Motion for Appointment of Appellate Counsel and for Transcripts
Exhibit 40 Copy of Judgment Entry re: Sentencing
Exhibit 41 Copy of Judgment Entry re: Appointment of Appellate Counsel
Exhibit 42 Defendant’s Combined Requests For Discovery, A Bill of Particulars, And Notice of State’s Intention To Use Specified Evidence
Exhibit 43 Defendant’s Motion To Compel Discovery; And Renewed Motion For A Bill Of Particulars
Exhibit 44 Message posted by Salisbury to Craigslist on November 16, 2010
Exhibit 45 Message posted by Salisbury to Craigslist on November 18, 2010
Exhibit 46 Stream of email messages from Salisbury, using the email address of “letitbe8691@aol.com,” and a reader and supporter of the blog, found at http://medinacorruption.blogspot.com
Exhibit 47 Message posted by Salisbury to Craigslist on December 27, 2010
Exhibit 48 Extortionate email from Salisbury to the publisher of the blog, found at http://medinacorruption.blogspot.com
Exhibit 49 Message posted by Salisbury to Craigslist on January 1, 2011, admitting that Brady “is almost impossible to enforce which is why the abuse is going on.”
Exhibit 50 Public Records Request to the Medina County Sheriff’s Office, dated February 17, 2010
Exhibit 51 Letter from the Medina County Sheriff’s Office, dated February 22, 2010, relating that the Public Records Request had been referred to Dean Holman
Exhibit 52 Letter from Dean Holman’s Office, denying my public records request for lack of clarity and particularity.
COLLIER, HOLMAN, and SALISBURY, it would seem, may very well have a difficult time lying their way out of this situation, given all the proof presented to the Ohio Supreme Court, as evidence above.
MUCH MORE TO COME ....
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