The Ohio Supreme Court will probe the Medina County Court of Common Pleas and the specific conduct of CORRUPT JUDGE CHRISTOPHER COLLIER, and CORRUPT MEDINA COUNTY PROSECUTORS DEAN HOLMAN and SCOTT SALISBURY.
The blog has received access to the COMPLAINT OF JUDICIAL AND PROSECUTORIAL MISCONDUCT filed by the father of the Defendant, whose case is currently being profiled at this blog. The father is a retired Federal Law Enforcement Officer with more than a passing knowledge of the law and the Rules of evidence (unlike COLLIER and SALISBURY).
THE COMPLAINT OF JUDICIAL AND PROSECUTORIAL MISCONDUCT, WITH EXHIBITS. IS AN ESTIMATED 350 PAGES IN LENGTH.
Given the length of the Complaint, it is impossible to publish here in its entirety. So, as in prior posts, the blog will display the various headings and subheadings in the Complaint so that you, the reader, will get a sense of the MISCONDUCT OF COLLIER AND SALISBURY AT TRIAL OF THIS DEFENDANT.
FIRST, EXCERPTED FROM THE PROLOGUE TO THE COMPLAINT:
"There is no greater prima facie evidence that the assistant county prosecutor Salisbury has relied upon the trial judge to consistently rule in his favor, notwithstanding the facts and the law, than the fact that the assistant prosecutor failed to file a single brief in opposition to any of Defendant’s many meritorious motions. "
HERE, NOW, ARE THE VARIOUS HEADINGS AND SUBHEADINGS FROM THE COMPLAINT OF JUDICIAL AND PROSECUTORIAL CONDUCT OF COLLIER, HOLMAN, AND SALISBURY:
TABLE OF CONTENTS
I. THE INCIDENT
II. THE UNLAWFUL ARREST
III. THE FATALLY DEFECTIVE CRIMINAL COMPLAINT AND ARREST WARRANT
IV. THE SUPPRESSION HEARING
1. The Falsified Discovery Document
2. The Defective Indictment
3. Collier Refused to Review the Transcript of the Testimony of Deputy Douglas Clinage to Determine What Testimony, if Any, was Given by Clinage Before the Grand Jury as to The Defendant’s Conduct Giving Rise to the Unspecified “Criminal Offense” as Charged in the Indictment
4. The Tape Recorded 911 Call
5. Collier’s Calculated Untimely Rulings on Suppression Motions; Denial of The Right to a Speedy Trial
V. THE PRE-TRIAL CONFERENCE
1. Salisbury Admitted to Invading the Defense Camp by Monitoring Privileged Telephone Communications, which “Invalidates the trial at which it occurred” according to the United States Supreme Court
2. Salisbury Invaded the Defense Camp by Placing an Undercover Operative in the Medina County Jail to Gather Information from the Defendant, Who Was Represented By Legal Counsel
3. Salisbury Sprung Inadmissible Evidence of Alleged “Other Acts” Upon the Defense on the Friday, November 6, 2009, on the Very Eve of Trial
VI. THE INTENTIONALLY BIASED, UNFAIR, AND FATALLY
FLAWED TRIAL
1. The Fatally Flawed Voire Dire
2. The Hearing on Motions in limine
3. Collier Compelled the Defendant’s Wife to Testify Despite Her Assertion of Her Spousal Privilege, in violation of the provisions of §2945.42 O.R.C.
4. Collier Knowingly Permitted Salisbury to Introduce Forbidden Alleged “Other Acts” Evidence, Over Defense Objection, And Without Conducting a Balancing Test or Contemporaneous Limiting Instruction, All With Calculation and Design to Prejudice the Defendant
5. Collier Permitted Salisbury to Play the Tape Recorded 911 Telephone Call Contrary to the Prevailing Case Law and Over Defense Objection
6. Collier Refused to Order Salisbury to Redact the Prejudicial and Inflammatory Remarks of Kimberly Leighton From the Tape Recorded 911 Telephone Call Contrary to the Prevailing Case Law and Over Defense Objection
7. Collier Permitted Salisbury to Introduce the Testimony of Kimberly Leighton, an Incompetent Witness, After Having Been Presented With Uncontroverted Evidence That Mrs. Leighton Did Not Observe the Events About Which She Offered Testimony, in Violation of Evid.R. 602
8. Collier Repeatedly Permitted Salisbury to Question Witnesses About The Testimony of Other Witnesses and Further Permitted Salisbury to Mischaracterize Such Testimony of Prior Witnesses Under the Guise of Posing Questions, All Over Defense Objections
9. Collier Intentionally Limited Defense Counsel’s Cross-Examination of the State’s Witnesses Roy and Kimberly Leighton With The Specific Intent to Prejudice the Defendant
10. Collier, With the Specific Intent to Prejudice the Defendant, Intentionally Prevented Defense Counsel From Cross-Examining Deputy Frank Telatko Regarding Exculpatory Statements Made by the Defendant
11. Collier, With the Specific Intent to Prejudice the Defendant, Intentionally Prevented Defense Counsel From Cross-Examining Deputy Frank Telatko Regarding Statements Made by Roy Leighton to Sheriff’s Deputies at the Scene on May 27, 2009
12. Collier Improperly Excluded the Defense Investigator From the Trial Proceedings, With the Intent to Impede the Effective Presentation of the Defense Case, in Violation of Evid. R. 615
13. Collier Permitted the Prosecutor to Badger, Harass, Denigrate, and Scream at Defense Witnesses, Over Defense Objections, With the Specific Intention to Prejudice the Defendant
14. Collier Personally Concealed and Withheld Evidence Favorable to the Defendant
15. COLLIER Withheld and Concealed State’s Exculpatory Photographs from Defendant
16. COLLIER Withheld and Concealed the Exculpatory Audio Tape of the Third Interview of Roy Leighton
17. Collier Prevented Defense Counsel From Fully Developing the Defense Theory of the Case by Refusing to Permit the Defendant From Presenting Material Evidence to the Jury
18. Collier Impermissibly Offered Personal Testimony at Trial When Denying the Defense the Opportunity to Introduce Verizon Cell Tower Evidence to the Jury
19. Collier Made No Attempt to Compel Salisbury to Produce Deputy Douglas Clinage, the State’s Agent, Who Failed to Appear at Trial, Ignoring the Defense Subpoena to Appear Offer Testimony, in violation of the Compulsory Clause
20. During Sidebar Conferences, Collier and Salisbury Spoke With Elevated Voices So As to Be Heard By the Jury, Thus Intentionally Prejudicing the Defendant
21. Collier Refused To Instruct the Jury On The Lesser Included Offense of Criminal Trespass, Over Defense Objection, Disingenuously and Wrongly Holding, by Design, That Defendant Relied Solely On the Complete Defense of Privilege, All With the Specific Intention to Prejudice the Defendant
22. Collier Permitted Salisbury to Repeatedly Denigrate Defense Counsel During the Suppression Hearing and at Trial
23. Collier’s Personal Demeanor During the Trial Was Inappropriate and Was Specifically Calculated and Designed to Prejudice the Defendant
VII. THE VERDICT
VIII. THE POST-CONVICTION “HEARING”
1. Ex Parte Communications Between Collier and Salisbury
2. The “Hearing”
IX. THE SENTENCING
X. THE JUDMENT ENTRY RE: SENTENCING
XI. THE PROPER RESOLUTION: APPOINTMENT OF A SPECIAL PROSECUTOR, INVESTIGATION, REMOVAL FROM THE BENCH, PROSECUTION, LOCAL JUDICIAL REFORM
1. Collier, a Republican, Sits on the Bench of the Medina County Court of Common Pleas at the Pleasure of the Democrat County Prosecutor and the Democrat Party
ADDENDUM
XII. THE EVIDENCE VIEW
Not surprisingly, each and every of the items that Salisbury instructed the Evidence Custodian to withhold from the defense contained exculpatory evidence.
XIII. SALISBURY TAUNTED THE DEFENDANT DURING PRE-TRIAL PROCEEDINGS
XIV. SALISBURY SUBORNED PERJURY
XV. POST-CONVICTION THREATS AND A STUNNING ADMISSION FROM SALISBURY
XVI. SALISBURY’S PLAINTIVE PLEA
XVII. SALISBURY’S THREAT
XVIII. SALISBURY ENGAGED IN EXCHANGES OF HARASSING EMAILS WITH BLOG SUPPORTERS
XIX. SALISBURY THREATENS TO PUBLICLY DISCLOSE THE IDENTITY OF THE DEFENDANT’S MINOR CHILDREN
XX. SALISBURY ATTEMPTED EXTORTION TO SILENCE THE BLOG
XXI. A STUNNING ADMISSION FROM SALISBURY
“While I understand Brady v Maryland (1963) says they must do this, it is almost impossible to enforce which is why the abuse has been going on.”
XXII. HOLMAN WAS TWICE PRESENT IN COURT TO ASSURE THAT COLLIER DID NOT FAIL TO BEND TO HIS WILL
XXIII. HOLMAN HAS STONEWALLED ATTEMPTS TO BY THE DEFENSE TO GATHER CORROBORATIVE EVIDENCE
There you have it. The Supreme Court certainly has fertile ground to plow in its investigation of the corrupt and unethical practices and conduct of COLLIER, HOLMAN, and SALISBURY!
AND THIS IS BUT ONE CASE AMONG MANY!
MUCH MORE TO COME ....
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