TABLE OF CONTENTS
1. The State and the Previous Trial Courts Engaged in Egregious
A. The Prosecutor Introduced Inadmissible Alleged Other Acts “Evidence” at Trial,
After Acknowledging Its Inadmissibility and After Assuring Defense Counsel and
C. During a Heated Ex Parte Discussion in Chambers, Pertaining to This
Case, Between Judge Collier and the Assistant Prosecutor, the Judge
Was Overheard to Shout at the Prosecutor, “I’ll Help You!” ............................... 13
3. Trial Court I and the Court Reporter Deliberately Edited, Tampered
With, and Materially Altered the “Official” Transcript of the
A. Judge Collier is Involved in a Longstanding Sexual Relationship With His
B. Mr. Hartman Extensively Briefed the Issue of the Tampered and Altered
C. The Post-Trial Briefs Noticed Trial Court I of the Appellate Issues ................ 17
E. A Portion of The Suppression Hearing Testimony of Inspector Hartman
F. The Suppression Hearing Testimony of Deputy Frank Telatko
G. Deputy Telatko’s Actual Suppression Testimony Was Deliberately
H. Defense Counsel Impeached Telatko at Trial with His Actual
I. The Testimony of Deputy Clinage Was Deliberately Altered in the
K. The Corrupted Transcript Demonstrates an Obvious Deletion From
L. The Corrupted Transcript Demonstrates an Obvious Gap and
M. The Corrupted Transcript Demonstrates Other Irregularities
4. The Transcript of Mr. Hartman’s October 28, 2013 Bond Hearing
Has Been Deliberately Edited and Materially Altered in an Attempt to
5. Judge Collier and His Court Reporter Have Been Materially Altering
C. State v. David L. Reed, Medina Case No. 10CR0407 ......................................... 36
D. State v. Joel Hysell, Medina Case No. 12CR0700 .............................................. 37
B. State v. Michael Gunner, Medina Case No. 05CR0235, Judge Kimbler ............... 42
7. Inspector Hartman, Who Operates a Blog Exposing the Corruption
Endemic in the Medina County “Justice" System, Has Received an
Estimated 400 Offensive Electronic Messages From “Publius,” who
A. In an Exchange of Email Messages With Inspector Hartman,
B. After Acknowledging Being Served With Defense Subpoenas Duces Tecum, Which
Attempted to Identify “Publius” and His “Sockpuppets,” Multiple Internet Service
Providers Failed to Provide the Subpoenaed Documents to the Defense,
C. “Publius” Displays Intimate Knowledge of This Case, Not
D. “Publius” Made Certain Damning Admissions in His Messages
F. “Publius” Laced His Messages to Inspector Hartman With
H. “Publius” Attempted to Pressure, Intimidate and CoerceInspector Hartman to Delete His Blog .............................................................................................................................. 56
J. Inspector Hartman Has Developed Additional Evidence Pointing
8. Judge Collier Has Facilitated Apparent Thefts of Public Funds
D. State v. Stevenson, Medina Case No. 09CR0386, Judge Collier ............................. 62
F. State v. James McDonald, Medina Case No. 11CR0267, Judge Collier ................. 63
H. State v. George Mose, Medina Case No. 09CR0515, Judge Collier ....................... 64
privileged custodial telephone communications between Defendant
and his counsel and the defense investigator.
repetitive deliberate misstatement of material facts in pleadings
before the Ninth District Court of Appeals.
filed in Indiana, which the court withheld from the defense.
Hartman, detailing an ex parte discussion between the judge and
the assistant prosecutor wherein Judge Collier shouted at the
I’ll help you.”
of State identifying Judge Collier’s court reporter Donna Garrity as
a principal in Medina Court Reporters, Inc.
reporter Donna Garrity, delaying the filing of the corrupted
transcript of Defendant’s Trial I until December 27, 2010.
of Appeals documenting that Donna Garrity filed no fewer than
she was served the Praecipe by Mr. Hartman’s appellate counsel.
Exhibit Nine Copy of the October 8, 2014 Affidavit of Inspector Hartman pertaining to the longstanding and ongoing sexual relationship
between Judge Christopher Collier and his court reporter Donna
suppression hearing testimony.
Hartman’s first trial, quoting the precise language of Deputy
Exhibit Fourteen Copy of the suppression-hearing transcript, pp. 243-244,
Acquittal, pp. 6-7, filed more than 12 months prior to the corrupted
transcript, memorializing Deputy Clinage’s actual testimony at the
suppression hearing, later deliberately altered in the corrupted
suppression hearing testimony of Deputy Douglas Clinage,
fair cross-examination of the State’s witnesses, which were later
Exhibit Eighteen Copy of the corrupted trial transcript, pp. 265, demonstrating an
from the corrupted trial transcript.
transcript of his suppression hearing, held before Judge Collier,
Mr. Mack raised the issue of corrupted transcripts on appeal;
Exhibit Twenty-Two Copy of the Affidavit of Mr. Frank P. Wood averring that the transcript of his trial, before Judge Collier, was materially altered
and that exculpatory testimony had been deleted from the
Exhibit Twenty-Three Copy of the Affidavit of Mr. David Reed who avers that Judge Collier imposed an illegal sentence upon him, which he appealed
to Collier. The judge dismissed Mr. Reed’s motions as “untrue,”
indicating the judge tampered with the transcript of Reed’s
sentencing hearing, or the docket in his case, or both.
Exhibit Twenty-Four Copy of the Affidavit of Ms. Ashley Marrs, who entered Collier’s courtroom as an observer in support of her fiancé Joel Hysell and
who was denigrated and publicly humiliated by Judge Collier in
open court while she was seated in the gallery. Mrs. Eva Marrs,
Ashley’s mother, ordered a transcript of the hearing, which Donna
all of Collier’s inappropriate and unprofessional remarks.
Exhibit Twenty-Five Copy of the memorandum of interview of Ms. Lynn Vandeusen,
who was charged, prosecuted, convicted, and sentenced to a jail
Exhibit Twenty-Six Copy of the Affidavit of Mrs. Holly Powell, mother of juvenile J.G, who, on two separate occasions requested and paid for
woefully incomplete and inconsistent “transcripts” in an apparent
deliberate attempt to frustrate her appeal of the magistrate’s
finding that J.G. is a delinquent child.
County Common Pleas Judge James Kimbler had been materially
averring that the transcript of the sentencing hearing held beforeJudge Kimbler had been materially altered.
Exhibit Thirty Copy of the Affidavit of Ms. Jacqueline Davey, a family friend who was present at and witnessed Michael Gunner’s sentencing
hearing before Judge Kimbler and avers that the language of Judge
Exhibit Thirty-One Copy of a letter from Ms. Joan Lewis, family friend who attended the sentencing hearing of Michael Gunner, disputing the transcript
of the sentencing hearing before Judge Kimbler. Ms. Lewis poses
Exhibit Thirty-Three Copies of an email exchange between Inspector Hartman, who used the pen name “Miguel Sword” in his published blog, and
Exhibit Thirty-Four Copies of subpoenas served upon Internet Service Providers seeking to positively identify “Publius.” Each and every one of
the Defense, leading to the inescapable conclusion that person(s) in
a position of authority interfered with the production.
Exhibit Thirty-Five Copies of representative samples of electronic messages “Publius”
Exhibit Thirty-Six Copies of representative samples of electronic messages “Publius”
admissions, some damning.
planting drugs in his car, and unlawfully arresting Inspector
Hartman on a charge of OVI and assuring conviction by means
of a “canned sample.”
Hartman using vile racist pejoratives including, but not limited, to
Exhibit Thirty-Nine Copies of representative samples of electronic messages “Publius”