To be argued by:

ROBERT C. REULAND
(10 minutes)

SUPREME COURT OF THE STATE OF NEW YORK

APPELLATE DIVISION: SECOND DEPARTMENT
-------------------------------------X
THE PEOPLE OF THE STATE OF NEW YORK,

Appellant,
APPELLATE DIV.
DOCKET NO.
-v- 2019-06285

KINGS CO.
IND. NO.
WILDON RODRIGUEZ a/k/a 4116/94
ERIC RODRIGUEZ

Defendant-Respondent.
-------------------------------------X

DEFENDANT-RESPONDENT’S BRIEF

ROBERT C. REULAND, ESQ.

Attorney for Defendant-Respondent
Law Offices of Robert C. Reuland, P.C.
26 Court St., Suite 1406
Brooklyn, New York 11242

Tel.: 718-300-0626
Email: robert@reulandlaw.com

February 25, 2020

 TABLE OF CONTENTS

TABLE OF CONTENTS ............................................. ii

TABLE OF AUTHORITIES ......................................... iii

COUNTERSTATEMENT OF QUESTIONS PRESENTED ........................ 4

STATEMENT OF THE CASE .......................................... 6

STATEMENT OF FACTS ............................................ 10

ARGUMENT ...................................................... 28

THE TRIAL COURT CORRECTLY FOUND THE PEOPLE

IMPROPERLY WITHHELD BRADY ................................ 30

THE TRIAL COURT CORRECTLY FOUND THE PEOPLE

KNOWINGLY ELICITED FALSE TESTIMONY AND LIED TO
THE JURY ................................................. 53

CONCLUSION .................................................... 59

ii
 TABLE OF AUTHORITIES

Cases

Brady v. Maryland, 373 U.S. 83 (1963) ................... 4, 6, 30

Collins v. City of New York, 923 F. Supp. 2d 462

(E.D.N.Y. 2013).............................................. 22

Giglio v. United States, 405 U.S. 150 (1972) .................. 30

People v. Baxley, 84 N.Y.2d 208 (1994) ........................ 41

People v. Colon, 13 N.Y.2d 343 (2009) ................. 42, 46, 56

People v. Craig, 293 A.D.2d 351 (1st Dep’t 2002) .............. 40

People v. Garrett, 23 N.Y.3d 878 (2014) ....................... 44

People v. Hubbard, 132 A.D.3d 1013 (2d Dep’t 2015) ............ 30

People v. Johnson, 107 A.D.3d 1161 (3d 2013) .............. 37, 38

People v. Jones, 24 N.Y.3d 623 (2014) ......................... 32

People v. Jones, 272 A.D.2d 930 (4th Dep’t 2000) .............. 41

People v. Santorelli, 95 N.Y.2d 412 (2000) .................... 30

People v. Sibadan, 240 A.D.2d 30 (1st Dep’t 1998) ......... 43, 44

People v. Steadman, 82 N.Y.2d 1 (1993) .................... 30, 57

People v. Tellier, 272 A.D.2d 347 (2d Dep’t 2000) ............. 43

People v. Wright, 86 N.Y.2d 591 (1995) .................... 40, 43

Quezada v. Brown, 08 CV 5088 (KAM) ............................ 23

iii
SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE DIVISION: SECOND DEPARTMENT
-------------------------------------X
THE PEOPLE OF THE STATE OF NEW YORK,

Appellant,
APPELLATE DIV.
DOCKET NO.
-v- 2019-06285

KINGS CO.
IND. NO.
WILDON RODRIGUEZ a/k/a 4116/94
ERIC RODRIGUEZ

Defendant-Respondent.
-------------------------------------X

COUNTERSTATEMENT OF QUESTIONS PRESENTED

(1) Whether the Supreme Court erred by finding that the

People violated their duty under Brady v. Maryland, 373 U.S. 83

(1963) by failing to disclose to the defense, among other things,

that the sole witness to identify defendant at trial:

a. Had received over $35,000 in direct and

indirect payments from the People;

b. Had received lenient treatment on numerous

criminal matters during the pendency of the

instant case;

c. Had been a purported witness in two earlier

homicide prosecutions; and

d. Was a confidential informant of the same

police detective investigating the instant

case.

4
 (2) Whether the Supreme Court erred by finding the People

wrongly misrepresented such witness, through questions and

comments to the jury, as free of that taint which such Brady

material would have shown, had it been duly disclosed.

5
SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE DIVISION: SECOND DEPARTMENT
-------------------------------------X
THE PEOPLE OF THE STATE OF NEW YORK,

Appellant,
APPELLATE DIV.
DOCKET NO.
-v- 2019-06285

KINGS CO.
IND. NO.
WILDON RODRIGUEZ a/k/a 4116/94
ERIC RODRIGUEZ

Defendant-Respondent.
-------------------------------------X

DEFENDANT-RESPONDENT’S BRIEF

STATEMENT OF THE CASE

The People of the State of New York appeal an order of the

Supreme Court, Kings County, Mangano, J., dated April 22, 2019,

vacating Rodriguez’s judgment of conviction upon his pro se motion

under C.P.L. § 440.10 alleging a failure by the People to disclose

to the defense, pursuant to Brady v. Maryland, 373 U.S. 83 (1963),

a massive trove of impeachment material relating to the sole

identifying witness against him.

Among other things, the People failed to disclose such

witness’ receipt of tens of thousands of dollars in benefits from

the People; that she had received lenient treatment on numerous

criminal matters during the pendency of the instant case; that she

had previously cooperated on two earlier homicide prosecutions;

and that she was a confidential informant of the police detective

6
charged with investigating Rodriguez’s case.

The court further found the People took advantage of

Rodriguez’s ignorance of such impeachment material by creating in

the mind of the jury, through questions and comments, the false

belief that such witness was free of that taint which this

impeachment material would have proven.

But for the People’s misconduct, Justice Mangano found, the

verdict “would very likely have been an acquittal” (10-11).1

Rodriguez stood convicted of Murder in the Second Degree

following a judgement of conviction rendered November 5, 1999 after

jury trial, receiving the maximum sentence of twenty-five years to

life incarceration. While imprisoned, however, Rodriguez obtained

evidence through Freedom of Information Law (FOIL) requests that

the People’s sole identifying witness, Althemease Cort, had

received over $35,000 in direct and indirect payments by the People

in connection with her cooperation on a second homicide

investigation and trial. (These FOIL records are annexed in their

entirety as an exhibit hereto.) Rodriguez also uncovered evidence

that Cort had received lenient treatment on numerous criminal

matters arising before and during the pendency of Rodriguez’s

prosecution. This leniency, among other things, allowed her to

avoid prison on two open felony matters upon agreeing to cooperate

1
Parenthetical reference to page numbers are to the People’s
Appendix unless otherwise indicated.

7
against Rodriguez.

Further, after the filing of Rodriguez’s motion, the People

for the first time in the long history of this case made a Brady

disclosure, revealing evidence that Cort was a confidential

informant of the same police detective investigating Rodriguez’s

case, Det. Joseph Yates. The People further disclosed that Cort

was a cooperating witness on a third murder trial conducted in

Brooklyn prior to Rodriquez’s trial.

None of this Brady material was ever disclosed to the defense

at Rodriquez’s trial. Worse, at trial, the prosecutor told the

jury that Cort:

didn't receive anything for coming forward. No one

cut her any deals. No one gave her any breaks. . .

. And you will hear how years later [Cort] is still

with us, not having received anything for her

testimony, not having received anything for coming

forward

(205). The People, therefore, at trial not merely disarmed the

defense of all cross-examination material that might have been

used to probe the veracity of the single eyewitness agaisnt him,

they took the additional step of declaring Cort pure of taint,

asking her on direct:

Q: [D]id you get any deals from the D.A.’s Office

to cooperate?

8
 A: No.

Q: As a matter of fact, you have not heard from

us for a long period of time?

A: No

(243-44).

Had the defense at trial been armed with the impeachment

material now known about Cort, Rodriguez “very likely” would have

been acquitted (10-11). Cort was the only eyewitness against

Rodriguez; their entire case hung upon her, as the trial prosecutor

admitted. The People thus had a clear incentive both to ensure

Cort cooperated and to keep her pristine for the jury. The People

met these twin aims by blandishing Cort with benefits and by hiding

prime cross-examination material from the defense. As Rodriguez

had no idea how deeply Cort was in the People’s pocket, the People

could present her falsely to the jury as a concerned citizen who

gained nothing for her years of cooperation with the government--

a utter falsehood which defense, wrongly deprived of this

information, could do nothing to rebut. It was not until years

after his conviction that Rodriguez, through repeated FOIL

requests and this motion, was able to learn the truth.

Justice Mangano found the failure of the People to abide by

their Brady obligations created a “reasonable probability that the

verdict would have been different” (12). His decision was just and

must be upheld.

9
 STATEMENT OF FACTS

Althemease Cort and the

Prosecution of Eric Rodriguez

Defendant-respondent Eric Rodriguez was accused of the murder

of Craig Jolly in Brooklyn in November 1993. Jolly was shot several

times and unable to name his assailant. Almost immediately the

investigation went cold. A few months after Jolly’s death, however,

the police caught a break. In January 1994, Althemease Cort was

arrested in Manhattan on a felony charge of possessing stolen

property. A resident of the same housing project where Jolly was

shot, Cort was interviewed by police at the time but told them she

knew nothing. Soon after her arrest in Manhattan, however, Cort

told police she could name the shooter.

Cort (also known as Althemease Ramsey among other aliases)

was in fact was a career shoplifter, having been convicted several

times on petit larceny charges in various jurisdictions. But Cort’s

1994 Manhattan case was not her first felony arrest. Five years

earlier, Cort had pleaded guilty in Brooklyn on the more serious

felony charge of possessing crack cocaine in her apartment. (As

she possessed the narcotic in the home where she lived with her

children, she also faced an endangering charge.) Cort, however,

was given a deal at the time: the Brooklyn court promised her a

short, six-month city term despite facing a much longer upstate

prison sentence if convicted after trial. Cort took the plea, but

10
she failed to appear for sentencing in 1989 whereupon the court

issued a warrant for her arrest. Cort remained a fugitive from

justice five years until she was re-arrested in Manhattan on the

stolen property charge just mentioned.

Thus, in early 1994, Cort was jailed on Rikers Island with

two big problems. First, she had been indicted by a Manhattan grand

jury on a felony charge of possessing stolen property. Second, and

potentially more problematic, was the still-outstanding sentence

on her 1989 narcotics plea in Brooklyn. Because she warranted

before sentencing, the Brooklyn judge was not bound by the terms

of her plea agreement. Indeed, the court had promised to sentence

Cort to “state prison” if she failed to appear.

At the time of Cort’s Manhattan arrest, the investigation

into the death of Jolly had run into a wall. Police needed a

witness to close the case. As it happened, Cort needed something

too: powerful friends. So, on March 1, 1994, Cort was taken from

her Rikers Island cell by Det. Joseph Yates to the Brooklyn

District Attorney’s Office where she gave the police what they

needed: she told investigators not only that she had witnessed

Jolly’s death, but that she could also identify the shooter as

Rodriguez, whom she knew from the neighborhood. That very day Cort

picked Rodriguez from a photo array. A month later, she identified

him in a lineup. Cort then, on April 7, 1994, testified in a grand

jury, which indicted Rodriguez for the murder of Craig Jolly.

11
 Rodriguez, indicted on the sole basis of Cort’s

identification, was arrested in 1998. (Owing to an evident error

by police, he was released after the 1994 lineup and not located

until later.) His attorney before trial twice made a demand for

all Brady information in the People’s possession. And, twice, the

People--by now-discredited prosecutor Kyle Reeves--replied they

had none.2 The case against Rodriguez proceeded to trial in October

1999 before Justice Plummer Lott with Cort giving testimony against

Rodriguez. No other evidence was adduced to establish Rodriguez’s

identity as the perpetrator. Cort was, Reeves told the jury, “the

People’s case” (208).

Nor, more important to this appeal, did the defense have any

means to convince the jury that Cort was something other than that

which the People presented her to be, i.e., a concerned citizen

who came forward to aid police in their investigation who received

nothing for her cooperation. As will be discussed, the People were

aware of significant material that certainly would have changed

the verdict had it been duly disclosed under Brady. As it was,

however, Rodriguez had to rely upon two witnesses; the first showed

2
Reeves, of course, is the same prosecutor whom the Kings
County District Attorney’s Office accused of secreting Brady
material in a flawed murder investigation by the disgraced former
detective Louis Scarcella. Defendant Jabbar Washington was freed
after the office’s Conviction Review Unit determined Reeves had
failed to disclose exculpatory information to the defense,
resulting in Washington’s conviction. He was freed in 2017 after
languishing in prison twenty years owing to Reeves’ failure to
disclose evidence that would have prevented it.

12
him to be elsewhere at the time of Jolly’s shooting, and the second

placed Cort in a position where she could not possibly have

witnessed the incident. The jury, however, credited Cort’s

unimpeached testimony, convicting Rodriguez of murder. Justice

Lott imposed sentence of twenty-five years to life, and Rodriguez

remained incarcerated until released by Justice Mangano after

vacating Rodriguez’s conviction in April 2019, finding Reeves

committed a massive Brady violation among other wrongdoing.

Cort’s Lenient Treatment

on Two Open Felonies

On the two felonies pending at the commencement of her

cooperation against Rodriguez in early 1994, Cort clearly was given

lenient treatment by the People in exchange for her testimony. In

harsh language Justice Mangano faulted the prosecutor Reeves for

his “blatantly intentional misstatements to the jury” that Cort

had been given no “leniency . . . in criminal matters” (8-9). The

People, however, continue to deny the existence of any arrangement

through which Cort received leniency to obtain her trial testimony,

and unsurprisingly we have uncovered no written agreement between

them memorializing such an arrangement. Even so, the evidence of

such a quid pro quo is undeniable, supporting Justice Mangano’s

finding that Reeves lied to the jury in denying its existence.

Notably, Cort did not offer police any assistance until she

needed help herself. At the time of Jolly’s murder, in November

13
1993, she denied having evidence. Soon, however, her affairs took

a turn for the worse; as discussed supra, she was arrested on a

new felony charge in Manhattan in January 1994, and thereupon a

five year old warrant dropped in Brooklyn on which she facing

additional upstate time.

Fortunately for Cort, she had a powerful ally. The recent

disclosure by the People of a note long kept secret in Reeves’

case file shows that Cort was a confidential informant of Det.

Joseph Yates--a lead investigator on the Jolly case (133). Now

that she needed help, Cort reached out to Det. Yates through the

arresting officer on her Manhattan case, P.O. Daniel Sacco, who

tried belatedly to void Cort’s arrest. In the note, the unknown

author informs Det. Yates that he or she received a telephone call

from P.O. Sacco of Midtown South Precinct stating that he had

arrested Althemease Martin, one of Cort’s many aliases, who “told

him that she was your C.I., although it was too late to void the

arrest” (133). While the note is undated, the contents make plain

that it was written shortly after Cort’s Manhattan arrest in

January 1994.

The People now freely admit that Cort was Det. Yates’

informant, but they deny that they nor he ever offered her any

favor for her cooperation. (App. Brief, at 41-42.) Instead, the

People would have this Court believe that following Cort’s

solicitation of Det. Yates’ aid upon her arrest in Manhattan in

14
January 1994, Det. Yates made a wholly “unsolicited” visit to Cort

on Rikers Island shortly thereafter for routine questioning on the

Jolly case (App. Brief, at 7), that same day taking her to the

District Attorney’s Office in Brooklyn where she identified

Rodriguez as the shooter.

Despite the People’s contention that Det. Yates’ visit to

Cort was purely coincidental and that nothing was offered nor

exchanged between them, they cannot deny two facts: Cort’s future

brightened immediately thereafter, and Det. Yates was able to close

his cold case with an indictment of Rodriguez. The People persist

in saying the two occurrences were unrelated, despite Justice

Mangano’s finding that Cort received leniency on her criminal

matters. Specifically, on both her new Manhattan case and on her

five year old Brooklyn plea, Cort was facing years of upstate

prison. Indeed, on the latter case, the Brooklyn judge had promised

to sentence Cort to “state prison” if she failed to appear. Having

bench-warranted five years earlier, Cort surely realized she was

facing consecutive terms of incarceration in two jurisdictions,

and surely this fear prompted her to seek aid from Det. Yates

through P.O. Sacco.

Almost immediately upon doing so, Cort’s worries vanished. In

Manhattan on February 10, 1994, Cort was offered the minimum

sentence of 1-1/2 to 3 years on a plea--a resolution that would

only get better before sentence was imposed two months later. And

15
in Brooklyn on February 22, 1994, Cort was miraculously given her

originally-promised sentence of six months jail. Tellingly, the

People did not insist that the court throw out the 1989 plea

because Cort had broken her promise by bench-warranting five years

ealier. Nor did the People ask that Cort be sentenced to “state

prison,” as the court warned it would do. Instead, when the

Brooklyn judge protested that Cort had absconded, the People stated

they “would still rely upon the six-month split.”

Cort earned the People an indictment against Rodriguez a month

later, and the following week the Manhattan court reduced its

already generous sentence to the same six-month split sentence she

had just received in Brooklyn.3 More, the Manhattan court agreed

to run the time concurrent with Cort’s Brooklyn sentence. As a

result, Cort was released from Rikers Island in June 1994 having

completed the jail component on two felony arrests for which--

prior to her cooperation with the People--she had faced years of

consecutive terms in state prison.

The People unsuccessfully sought to convince Justice Mangano

3
The People argue the Manhattan court likely erred in believing
Cort was a predicate when it made the original plea offer in
February 1994, (App. Brief, at 6), yet this is irrelevant. The
error does not explain why Cort was offered the minimum in the
first place, nor why the promised sentence was further reduced
once the error was realized, nor most important why the Manhattan
court ran the time concurrent with Cort’s Brooklyn sentence. The
People acknowledge that the sentencing minutes have been lost, yet
they urge the Court to read the mind of the Manhattan court in a
manner friendliest to their position: that the revised Manhattan
sentence was a boon to Cort wholly unrelated to her cooperation.

16
that these events were wholly unrelated, and he censured them for

their “blatantly intentional misstatements to the jury” that Cort

had received no leniency on her criminal matters (8-9). Now the

People seem to think this Court is credulous enough to believe

police just happened to stop by Cort’s jail cell on a whim, that

Cort closed their murder case for them while expecting nothing in

return, and that she escaped certain upstate prison time on two

open felonies as a result of good fortune.

We submit what was obvious to Justice Mangano is that Cort,

following her Manhattan arrest, reached out from jail to Det. Yates

with an offer to cooperate in exchange for leniency on her open

cases. The People therefore hid from the defense two important

pieces of Brady material that make this credible: that Cort was

the confidential informant of Det. Yates, a lead investigator on

the Jolly case, and the note hidden in Reeves’ file, which proves

that Cort sought to contact Det. Yates through P.O. Sacco upon her

arrest in Manhattan.

Thus, it defies credibility to think--as the People claim--

that Det. Yates just happened upon his only eyewitness in the Jolly

case by sheer luck, or that his moment of good fortune coincided

perfectly with Cort’s own desperate need. Equally absurd is the

claim that Cort’s lenient treatment on her two open felony cases

had nothing to do with her cooperation with Det. Yates. Of course

we are unable to produce for the Court a document memorializing a

17
testimony-for-leniency agreement between the People and Cort.

Since the prosecutor Reeves was willing to hide Det. Yates’

connection to Cort as well as the handwritten note memorializing

her cry for help, Reeves would have no qualm in keeping such an

agreement secret as well.

Even in the absence of documentary proof, the existence of an

agreement is plain as day. All parties got what they wanted: Det.

Yates closed his case, the People prevailed at trial, and Cort

walked out of prison after weeks not years. In light of facts now

known about the relationship between Cort and Det. Yates, as well

as the undeniable evidence that both parties received the benefits

of a bargained-for exchange, the existence of a de facto agreement

between them is impossible to deny in good faith. Justice Mangano,

who sifted all of this information, concluded that Cort received

leniency on her criminal matters.

Cort’s Undisclosed
Cooperation and Benefits in
a Second Murder Case

As disturbing as the foregoing may be to the ear of any

experienced trial practitioner, Reeves’ failure to disclose the

leniency Cort was shown by the People as a result of her

cooperation was only the tip of the iceberg of his failure to

attend to the just demands of Brady. Completely unknown to defense

at time of trial, during the period of Cort’s cooperation against

18
Rodriguez she was also cooperating with the People on a second

murder case, People v. Louis Charriez, Kings Co. Ind. No.

1778/1997. As a result of that cooperation she received tens of

thousands of dollars in direct payment and indirect benefits, not

one penny of which was ever made known to Rodriguez. Instead,

Rodriguez learned of this hidden material only when it was produced

to him pursuant to a FOIL request in 2016. (These records are

attached hereto as an exhibit, hereinafter “Exh.”, to which the

Court’s attention is respectfully referred.)

As will be discussed, the People’s main defense to this clear

Brady failure is that these benefits were not disclosable to

Rodriguez since they arose in the “unrelated” case of Louis

Charriez. This argument, which is without legal merit, does not

even pass the red-face test since none of this impeachment material

was ever disclosed to Charriez either.4

On January 10, 1997, Cort purportedly witnessed the stabbing

death of a complainant in Brooklyn, and she agreed to give

testimony identifying Louis Charriez as the perpetrator. Cort

thereafter contended that she had been threatened by unknown

persons and the People relocated her, her girlfriend, and her

children to a new home, providing her with thousands of dollars in

4
The People’s failure to do so, inter alia, is the subject of
a motion pursuant to C.P.L. § 440.10 now pending before Justice
Tully in the Kings Co. Supreme Court. I have been assigned to
represent Charriez pursuant to County Law art. 18-b.

19
financial and other benefits and services for food, housing, and

living expenses over the course of several months.

Cort testified against Charriez at trial in December 1997,

and he was convicted of murder and sentenced in January 1998. Cort

continued to receive relocation benefits until April 24, 1999,

when she was terminated from the program. As it happens, trial

against Rodriguez commenced three days later on April 27, resulting

in a mistrial.

Cort was placed in “voluntary custody” with the District

Attorney’s Office in their “Relocation Program” on December 10,

1997 (Exh. at 5-6), coinciding with her trial testimony against

Charriez. Under the terms of this written agreement, Cort and her

family were housed in a hotel at government expense. She was

prohibited from making telephone calls and from receiving visitors

without the approval of the District Attorney’s Office. She was

given two double rooms to accommodate four adults, one of whom was

her girlfriend and fellow witness Fairlene Walton.

While the agreement specifically excluded “food, telephone or

movie privileges for this custody,” upon execution of the agreement

Cort was in fact given a stipend of $504 per week for “Meal money

for threatened witness + family,” calculated as “4 Adults $18.00

per day x 7 Days,” according to records obtained by Rodriguez

through FOIL request (See, e.g., Exh. at 10). These weekly

payments, which continued until the termination of her “hotel

20
custody” several months later, were paid directly to Cort, who

signed a receipt for each disbursement (E.g., Exh. at 7).

Although the precise location of her “hotel custody” is

redacted in the FOIL material, Cort was certainly situated in a

hotel, as the records show correspondence directed from Richard I.

Safianow, Deputy Director of Operations in the Kings County

District Attorney’s Office, to the attention of the “Reservation

Desk,” asking that Cort’s “custody” (the word “custody” is used

rather than “accommodations,” “lodgings,” or other similar term)

be extended for an additional week (E.g., Exh. at 15). Safianow

regularly made a request to extend Cort’s custody until, evidently,

she obtained alternate housing with the assistance of the District

Attorney’s Office.

Cort remained in a government-paid hotel for many months,

receiving a stipend for meals as well. On February 13, 1998, one

of the several times in which Cort was returned on a bench warrant

with impunity, she interrupts the proceedings to explain:

And I’m in the witness protection program. I’m in

the hotel. It’s not like I am not coming back to

court. It’s not that. It’s not like that.

People v. Althemease Cort, Kings Co. Ind. No. 4116-1988, Feb. 13,

1998, at 2. Cort then directs the judge to telephone the prosecutor

handing the Charriez matter as well as Det. Wishner. On the record,

Cort provides the Court with Wishner’s direct telephone line, which

21
Cort had committed to memory, evidencing her intimate familiarity

with her paymasters. Id. at 2-3.

Shortly thereafter, in or about May 1998, Cort was relocated

from a hotel to a private apartment. Even so, this move did not

terminate her financial connection to the District Attorney’s

Office: far from it. In an agreement between Cort and the District

Attorney’s Office, dated March 27, 1998, she again expresses her

agreement to “voluntary custody,” and the District Attorney’s

Office agrees to pay her monthly rent of $1,050 in addition to her

security deposit and realtor’s fee (Exh. at 68). In addition, the

People paid Cort’s moving expenses (Exh. at 69-70). On April 24,

1998 Cort was terminated from “voluntary custody” (Exh. at 62-63),

three days before trial commenced against Rodriguez.

The subjection of witnesses to “hotel custody” is a now-

discredited practice once used commonly by the Kings County

District Attorney’s Office. This unlawful and unethical practice

of “hotel custody” only came to light in 2013 in a federal civil

rights law suit against then-District Attorney Charles J. Hynes by

Jabbar Collins, who served sixteen years in prison for a murder he

did not commit. Collins’ conviction was overturned after it was

shown that police and prosecutors in Brooklyn coerced false

testimony from witnesses against him. Discovery and depositions

taken by Collins in that case, Collins v. City of New York, 923 F.

Supp. 2d 462 (E.D.N.Y. 2013), and in another case, Quezada v.

22
Brown, 08 CV 5088 (KAM), revealed the use of material witnesses

warrants, take-out orders, and unlawful detention of witnesses as

de facto prisoners in hotels.5 The new administration of Kenneth

Thompson promised changes, some of which were put into effect.

Recently, however, the District Attorney’s Office has evidently

rejected Thompson’s legacy and set upon a revanchist policy, as

their vehement defense of the instant litigation would suggest.

Cort Receives over $35,000 from

the District Attorney’s Office

The termination of Cort’s “hotel custody,” however, did not

end her financial reliance upon the District Attorney’s Office,

which continued by agreement to pay for her housing and meals for

both Cort and other members of her family. Cort continued to

receive a monthly check for $1,050 for rent for another year in

addition to a check for $504 weekly for meals, which she received

from December 1997 to May 1998. (See Exh. at 7 et seq.)

In the end, evidence in the FOIL documents received by

Rodriguez6 prove that Cort received fifteen months of rent and meal

payments, totaling $35,469.24, as follows:

Check No. Date Amount Stated Purpose

2782 5/14/97 $1,950 Unknown

5
See Matthew Maddux, “Hell In ‘Hotel Hynes’: Brooklyn DA
Accused of Coercing Witnesses to Give False Testimony,” NY Post,
May 30, 2013.
6
Similar documents were also received independently by Louis
Charriez pro se and by me pursuant to FOIL request and subpoena.

23
 12/10/97 $432 Meals
3266 12/29/97 $504 “
3309 1/12/98 $504 “
3332 1/19/98 $504 “
3349 1/20/98 $504 “
1/20/98 $50 Witness looks for apt.
3358 2/2/98 $504 Meals
3382 2/9/98 $504 “
3393 2/16/98 $504 “
3407 2/23/98 $504 “
2/27/98 $378 “
3375 2/28/98 $2,100 Housing
3421 3/2/98 $504 Meals
3/6/98 $378 “
3448 3/9/98 $504 “
1823 3/24/98 $2,100 Housing
3519 3/24/89 $1,050 “
3527 3/30/98 $504 Meals
3547 4/6/98 $504 “
3658 4/29/98 $100 Moving
3560 4/13/98 $504 Meals
3597 4/20/98 $504 “
3615 4/27/98 $504 “
3630 4/23/98 $400 Moving
3666 5/4/98 $504 Meals
3713 5/11/98 $1,008 “
5/18/98 $504 “
1917 5/20/98 $1,050 Housing
3742 5/25/98 $504 Meals
3776 5/28/98 $1,151.24 Unknown
1929 5/29/98 $1,050 Housing
1967 7/1/98 $1,050 “

24
 2034 8/26/98 $1,050 “
2082 9/24/98 $1,050 “
2105 10/28/98 $1,050 “
2139 11/25/98 $1,050 “
2157 12/23/98 $1,050 “
2217 1/27/99 $1,050 “
4213 2/10/99 $1,200 “
4214 2/10/99 $2,400 “
2242 2/25/99 $1,050 “
4334 4/2/99 $1,200 “

Total $35,469.24

The total amount paid to or on behalf of Cort of more than

$35,000 during this period is only that amount reflected in

documents produced under FOIL; the true amount is certainly

greater, since no records were produced to show payment by the

People to the various hotels where Cort was housed at government

expense during the five months of “hotel custody” between December

1997 and May 1998. This undisclosed figure was certainly

considerable, suggesting that the true amount given to Cort was

perhaps double the $35,000 figure proved by disclosed documents.

The People’s First Brady Disclosure:

Cort Was a Confidential Informant and a
Witness on a Third Murder Case

In addition to the trove of undisclosed Brady material

Rodriguez independently uncovered, the People made a limited but

25
remarkable disclosure of their own, albeit twenty years after

Rodriguez’s conviction. On April 27, 2018, after Rodriguez had

filed his pro se motion under section 440.10, the People for the

first time in the long history of this case made a production of

Brady material, revealing that Cort was a witness in a third murder

case; that she was a confidential informant of the same police

detective investigating the Jolly case; and that she had sought to

contact Det. Yates for assistance upon her arrest in Manhattan in

January 1994.

First, the People revealed that in addition to cooperating on

Rodriguez’s and Charriez’s murder cases, Cort was a cooperating

witness on yet a third homicide prosecution in Brooklyn, this from

1987, predating the other two. The fact of Cort’s cooperation with

the People on these two earlier trials was itself Brady

information. Common experience informs us that lightning doesn’t

strike twice, much less thrice. As lamentably common as murder is

in some precincts of the city, it is an exceedingly rare thing for

one to witness a single murder, much less two; and when one

purports to have witnessed three murders, we quite naturally become

more than merely skeptical. This skepticism becomes particularly

strong when we learn--as here--that the purported witness

benefited enormously by cooperating with law enforcement over the

years. This argument might have been made profitably to Rodriguez’s

jury.

26
 The jury in Rodriguez’s trial did not, however, know that

Cort claimed to have witnessed a second much less a third murder.

Had this information been duly disclosed, any competent trial

counsel would have had little difficulty in discrediting Cort’s

credibility by arguing that she was little more than a

“professional eyewitness.” Nor is it unreasonable to suppose that

Cort was such in light of news reports we have all read about the

People’s reliance upon the same witness in multiple homicides

investigated by now-disgraced Det. Louis Scarcella including the

Jabbar Washington case, footnoted supra, prosecuted by the same

assistant district attorney who tried Rodriguez, Kyle Reeves.

Given that Cort offered testimony in three separate murder

prosecutions, and benefited by her cooperation, we can rightly

question her credibility on that basis alone.

The second Brady disclosure made by the People in 2018 was

equally remarkable: a note kept long secret in Reeves’ case file

showing that Cort was a confidential informant operated by the

very same police detective assigned to the Jolly homicide

investigation, Joseph Yates. The note moreover memorialized that

Cort attempted to assert her relationship with Det. Yates to avoid

prosecution on a Manhattan stolen property felony charge in January

1994, discussed supra. We can therefore understand why the People

kept this Brady material hidden so long: it both proves a

preexisting cooperative relationship with the lead investigator on

27
the Jolly case and further proves Cort’s willingness to parlay

that relationship for personal gain.

As discussed earlier, this belated Brady disclosure cuts the

legs from under the People’s contention that Cort came forward on

her own to cooperate against Rodriguez and that she neither sought

nor received anything in exchange. That Cort was Det. Yates’

confidential informant, and that she moreover attempted to use

their relationship to avoid prosecution, is entirely consistent

with that picture of Cort that Rodriguez’s jury never saw: a woman

with a host of legal difficulties, imperiled with the almost

unavoidable certainty of years of upstate prison on two felony

cases, who nevertheless was able to avoid a day of reckoning by

offering her cooperation as a “witness” against Rodriguez.

For these reasons, Justice Mangano correctly found that the

People erred in secreting damning facts about their sole

identifying witness: facts that, had they been known, would “very

likely” have resulted in a Rodriguez’s acquittal.

ARGUMENT

Given the singular importance of Cort’s testimony, the People

had a very strong incentive to ensure that she stay pristine in

the eyes the jury. Cort was “the People’s case,” as the prosecutor

Reeves admitted (208). The hidden information now known about Cort

would have damaged her credibility beyond repair, and so the People

hid this information from the defense. As there was no other

28
evidence adduced at trial identifying Rodriguez as the

perpetrator, the verdict “would very likely have been an

acquittal,” as Justice Mangano found (7-8), had the People abided

by their Brady obligation.

In defense of the indefensible, the People now throw up an

array of excuses and misinterpretations of caselaw to justify their

hiding from the jury those facts about their sole “eyewitness”

that would have changed the verdict. Such conduct at trial was

inexcusable, but to persist in defending it now twenty years later

is appalling. One might have hoped that the People, having been

found engaging in so flagrant an effort to tip the scales of

justice, would have meekly acknowledged their misconduct, vowed to

do better, and accepted Justice Mangano’s chastisement. Instead,

we find them doubling-down, complaining that they--not Rodriguez,

whom they unfairly incarcerated for nearly the entirety of his

adult life--are the injured party.

With this appeal, the Court has the opportunity to send a

message in the clearest possible terms that the People cannot keep

hidden from the defense and the jury those facts about their

witnesses which, if known, would demonstrate that such witnesses

had powerful reasons to have shaped their testimony to favor the

People. Cort, whose testimony against Rodriguez purchased her

freedom, was moreover the recipient of tens of thousands of dollars

from the People during the pendency of the prosecution of

29
Rodriguez; she was clearly in the People’s thrall, and to have

hidden this information from the finders of fact harmed not only

Rodriguez very personally but the entire process of criminal

justice in New York.

POINT I

THE TRIAL COURT CORRECTLY FOUND THE

PEOPLE IMPROPERLY WITHHELD BRADY

Under Brady v. Maryland, 373 U.S. 83 (1963), the People have

an obligation to disclose to the defense exculpatory evidence and

material facts that may be used to impeach prosecution witnesses.

Giglio v. United States, 405 U.S. 150 (1972) see also People v.

Hubbard, 132 A.D.3d 1013 (2d Dep’t 2015). The People, of course,

do not now dispute their obligation to disclose impeachment

material to the defense. Nor do the People defend their conduct on

the ground that Reeves, the trial prosecutor, may not have been

personally aware of the favorable treatment given Cort by the

police and his own office. See People v. Santorelli, 95 N.Y.2d 412

(2000); People v. Steadman, 82 N.Y.2d 1 (1993). Rather, the People

urge the Court to find that the undisclosed facts about Cort were

not “material” and therefore their timely disclosure would not

have affected the outcome of the trial.

As a preliminary matter, we submit the People’s argument that

Justice Mangano erred in granting Rodriquez’s motion without an

evidentiary hearing is without basis since the record on submission

30
clearly showed a massive failure by the People to comply with their

Brady obligations, namely that their witness Cort:

a. Had received over $35,000 in direct and

indirect payments from the People;

b. Had received lenient treatment on numerous

criminal matters during the pendency of the

instant case;

c. Had been a purported “witness” in two earlier

homicide prosecutions; and

d. Was a confidential informant run by the same

police detective investigating the instant

case.

While the People argue that Cort was given no leniency, they not

dispute the factual basis of the other information we assert to be

Brady material. Rather, the People argue that such information was

not “material” and therefore removed from Brady consideration.

Thus, with the exception of the question whether Cort agreed to

trade testimony for leniency, there was no need for an evidentiary

hearing as there was no disputed fact.

Nor on the disputed issue of Cort’s cooperation agreement was

an evidentiary hearing required. Justice Mangano, the finder of

fact on Rodriguez’s motion to vacate, was satisfied with the

evidence before him on this point. He determined the record

sufficiently complete to find Cort was in fact given leniency for

31
her testimony, ultimately chastising the prosecutor Reeves for his

“blatantly intentional misstatements to the jury, as well as

questions to Althemease Cort, indicating there had been no benefits

received or leniency given in criminal matters” (11-12) (emphasis

added).

In any event, one cannot imagine what evidence the People

would seek to adduce at a hearing on this narrow, disputed issue.

They have already sworn to have found no such agreement after

combing their files. Even if Reeves or Det. Yates were called to

testify, their denial of an agreement would have added nothing.

The People below submitted the affirmation of a prosecutor, Matt

Stewart, denying an agreement on the basis of a hearsay telephone

conversation with Det. Yates (97). The People evidently made no

effort to obtain an affidavit from Det. Yates himself nor from

Reeves. Both men are retired from public service. Cort is dead.

Regardless, Justice Mangano as the finder of fact had

discretion either to grant or deny an evidentiary hearing. “Once

the parties have filed papers and all documentary evidence or

information has been submitted, the court is obligated to consider

the submitted material ‘for the purpose of ascertaining whether

the motion is determinable without a hearing to resolve questions

of fact.’” People v. Jones, 24 N.Y.3d 623, 634-35 (2014) (quoting

C.P.L. § 440.30(1)(a)). As Justice Mangano was satisfied with the

state of the record before him, he did not err in proceeding

32
without conducting an evidentiary hearing that would have

illuminated no fact then in dispute.

The People’s real complaint against Justice Mangano is not

that he ruled on submission; rather, the People complain only that

he failed to rule their way. On brief the People offer several

pages of tortured reasoning to explain how what appears to be a

cataract of prime impeachment material is in fact a dry creek bed.

To support their contention that this information is not “material”

and therefore removed from Brady consideration, the People make

two arguments: first, it is not material insofar as it arose in

the “unrelated” prosecution of Louis Charriez; and, second, the

information is not material since the defense would have elected

not to use it at trial. Neither excuse for the People’s misconduct

is well-taken.

Impeachment Material May Arise

in “Unrelated” Matters

First, the People err in claiming that Brady did not pertain

to the massive payouts they made to Cort since these payments arose

in a “unrelated” proceeding in which Cort was also a witness,

People v. Charriez, discussed supra. The People’s argument that

this information was material only to Louis Charriez might have

more intellectual heft if they had actually disclosed it to Louis

Charriez. They did not. As a result, it is unseemly at best and

hypocrisy at worst for them to claim their Brady obligation was

33
owed only to Charriez while Charriez himself languishes in state

prison because the People failed to provide this information to

him before trial.

Even if we ignore for the moment the two-faced nature of the

People’s argument, we cannot accept their assertion that their

life-changing payouts to Cort ceased magically to be prime

impeachment material simply because such payments were made in an

“unrelated” case. Is it truly the People’s belief that a jury would

have disregarded the tens of thousands of dollars Cort received

from them simply because the checks were drawn from a separate

ledger book? Even to advance such an argument evinces such an

ignorance of jurors’ minds that one cannot believe it made in

earnest. Speaking as one whose daily bread is earned examining

witnesses in such cases, I would have had a field day with Cort

armed such material. Surely for this reason Reeves kept these facts

to himself.

In urging their interpretation of Brady upon the Court, the

People ignore the other benefits Cort received from them, namely

the leniency shown her by the People from the start of her

cooperation. When coupled with the fact that Cort was working as

a confidential informant of the very detective investigating this

case, the benefits blandished upon her over the course of years

become an obvious motive for Cort to have shaped her testimony in

a manner friendly to her paymasters.

34
 The People quite naturally urge the Court to consider in

isolation each discrete failure by the People to disclose

impeachment material to the defense, hoping to minimize both their

own wrongdoing and the collective impact of the many secrets they

kept from the defense. We urge the Court to adopt a broader, more

pragmatic view of the People’s failure and the handicap it placed

upon the defense at trial. In reality, had Cort been confronted

before the jury with 1) the massive benefits she had received from

the People, 2) the leniency she had been shown on multiple criminal

matters, 3) the fact that she was an informant of the investigating

detective, and 4) that she was then testifying as a cooperating

witness at her third murder trial, can the People really say with

a straight face that it would have made not the least difference?

We urge the Court to find that the jury would have readily

understood that Cort was very much in the People’s pocket. As

Justice Mangano ruled below, “Had the jury been made aware of the

years of rent and allowance paid for by the same office prosecuting

this case, the result would very likely have been an acquittal”

(7-8).

Indeed, far from being seen as “unrelated,” had the jury

learned that Cort was cooperating on a second homicide

investigation, it would have damaged her credibility even further,

showing her to have had a deep relationship with the People that

made her cooperation with them more plausible. Surely this was the

35
reason why neither Rodriguez nor Charriez knew of the other’s case,

despite both pending in the same courthouse at the same time. Of

course, neither was the fact that Cort was a cooperating witness

on third homicide disclosed to either man before their respective

trials.

The People on brief would have this Court read Brady as both

a shield and sword. They urge the Court to adopt their

idiosyncratic reading of Brady protecting them from any obligation

to disclose prime impeachment evidence arising in an “unrelated”

prosecution, yet allowing them to present their witness as free of

the very taint such evidence would show. Thus, the People ask this

Court to place its imprimatur on the conduct of a trial prosecutor

who not merely failed to make any disclosure of truly alarming

impeachment material but who had the temerity to stand before the

jury and suggest Cort’s motives were pure as the driven snow.

Justice Mangano was particularly emphatic in his disapproval of

the People’s

blatantly intentional misstatements to the jury, as

well as questions to Althemease Cort, indicating

that there had been no benefits received or

leniency given in criminal matters

(8-9).

As uncomfortable as it is for any active criminal trial

practitioner to hear the People defend their failure to disclose

36
impeachment material “very likely” to have occasioned an

acquittal, it is altogether a bridge too far for the People to say

they committed no additional wrong in misrepresenting Cort to the

jury as having no motive to lie.

Brady simply does not insulate the People from the obligation

to disclose impeachment material arising in “unrelated” matters,

as they now argue. For this proposition the People rely upon a

number of cases, none of which support their radical argument.

Indeed, the first case they cite, People v. Johnson, 107 A.D.3d

1161 (3d Dep’t 2013), contains no such rule, and in fact clearly

states that

an unrelated matter may often not sufficiently bear

on the witness’ credibility or believability in the

present prosecution so as to constitute impeachment

material subject to Brady disclosure.

Id. at 1165 (emphasis added). Logically, the language “may often

not” contemplates the Court’s belief that such unrelated matters

often may bear on the witness’ credibility, thus triggering an

obligation to disclose. The People fail to mention that the Court

in Johnson went on to note:

Case law does not, however, offer a definitive

answer as to whether the People’s Brady obligation

here extended only to the benefits and leniency

conferred on [the] cooperating witness and her

37
 agreement to testify in this prosecution, or

whether the People’s Brady obligation extended

further to all terms of the cooperation agreement,

including her commitment to testify in an unrelated

prosecution. Under the circumstances of this case,

we find that a convincing argument can be made that

[the cooperating witness]’s additional obligation

to testify in the other matter . . . was relevant

to her credibility in this case.

Id. (emphasis added and citations omitted).

Ultimately, however, the Court in Johnson did not answer

whether the witness’ cooperation in the second case constituted

Brady material, finding the verdict turned on other evidence

instead. Id. at 1165-66.

By contrast, the crucial evidence against Rodriguez in the

case at bar came from Cort and from Cort only. She was the only

witness to identify him at trial, and there was no other evidence

establishing him as the perpetrator. In the prosecutor’s words to

the jury, Cort was “the People’s case” (208) and therefore “a

convincing argument can be made that [Cort]’s additional

obligation to testify in the other matter . . . was relevant to

her credibility in this case.” Id. at 1165.

Thus, in our view Johnson is more helpful to Rodriguez than

to the People. The Court in Johnson found that a witness’

38
cooperation in an “unrelated” prosecution can indeed be Brady

material, contrary to the People’s reading, depending upon the

terms of the cooperation and the facts and circumstances of the

case. This is a much wiser approach than the one now urged by the

People, i.e., a bright-line policy relieving them of any obligation

to disclose “unrelated” cooperation and benefits derived

therefrom. We believe that Johnson stands for the proposition that

where a witness is expected to offer testimony important to the

People’s case, the People are obliged under Brady and the Due

Process Clause to disclose all exculpatory or impeachment material

relative to such witness’ credibility regardless of the source.

No other case relied upon by the People compels a different

conclusion. In each cited case the question on appeal was whether

the testimony of the witness in an unrelated prosecution, sometimes

pursuant to a cooperation agreement, was disclosable as Brady

material. Often in these cases the witness received some benefit

from the government for his or her cooperation. The People

correctly note that in none of these cases did the reviewing court

find a Brady violation; but it is also true that in none of these

cases did the court set out a rule permitting the People to keep

secret a witness’ “unrelated” cooperation.

Rather, the cases for the most part find that where benefits

received by a witness in an “unrelated” case are not probative of

credibility, the People have no obligation to disclose it under

39
Brady. For example, in People v. Craig, 293 A.D.2d 351 (1st Dep’t

2002), the defense claimed a Brady violation where the witness had

earlier been assisted by the People in obtaining a housing

transfer. The First Department did not relieve the People of their

obligation to disclose this fact simply because it arose in a

separate proceeding, as the People here appear to argue. Rather,

the Court found the housing transfer “was too remote to create

such a bias in favor of the prosecution as to constitute

exculpatory evidence.” Id. at 352. Conversely, where the benefit

is close enough to create such a bias, it stands to reason that it

must be disclosed under Brady, notwithstanding that it was

conferred in an “unrelated” proceeding.

In so ruling, the Craig Court distinguished People v. Wright,

86 N.Y.2d 591 (1995), which the People here ignore. In Wright, the

Court of Appeals found a Brady violation where the People failed

to disclose that an important witness had previously operated as

a police informant. Obviously, this material arose in an

“unrelated” proceeding, but this did not compel the Court to

relieve the People of their obligation to ensure the Due Process

rights of the defendant by disclosing it. “Manifestly, [the

witness]’s status as a police informant was evidence favorable to

the defense.” Id. at 596 (emphasis added). The Wright decision, of

course, is doubly relevant to the instant case since Cort herself

served as a police informant for the very detective investigating

40
the Jolly murder, Det. Yates, which People here disclosed twenty

years too late.

The People’s reliance on the Fourth Department’s ruling in

People v. Jones, 272 A.D.2d 930 (4th Dep’t 2000) does not require

a different result, even if this Court were bound by it. There,

the defendant supposedly confessed to a fellow inmate who later

testified against him. The People failed to disclose that the

witness was also cooperating on another case, and for that

cooperation he had been promised a reduced plea. On appeal, the

Fourth Department did not set down a rule that impeachment material

arising in “unrelated” matters loses its materiality on that basis

alone. While the Court noted that “[i]n the absence of any

connection between the plea agreement of the inmate and her

testimony against defendant, the probative value of that plea

agreement was minimal,” the Court nevertheless did not hold that

impeachment material arising in “unrelated” prosecutions is ipso

facto excluded from Brady. Rather, the Court simply found that “in

the context of the entire trial, the undisclosed evidence [did]

not undermine confidence in the verdict by creating a reasonable

doubt that did not otherwise exist.” Id. at 931-32 (emphasis added)

(quoting People v. Baxley, 84 N.Y.2d 208, 214 (1994)). Thus, Jones

is consistent with our view that impeachment information does not

cease to be Brady material simply because it arises in an unrelated

matter, provided it is probative of credibility in light of all

41
the facts and circumstances of the case.

The People also hope to distinguish People v. Colon, 13 N.Y.3d

343 (2009), cited in Justice Mangano’s decision granting vacatur,

in which the Court of Appeals faulted the trial prosecutor for

failing to disclose benefits he had given a witness and his family.

In attempting to distinguish Colon, the People again ride their

favorite legless hobby-horse, noting that the undisclosed benefits

at issue in Colon were not “unrelated” to the case in which the

witness gave testimony. The Colon Court, however, drew no such

distinction between “related” and “unrelated” Brady material, as

the People urge this Court to do. Instead the Court of Appeals

said in effect that Brady is Brady, holding, “By their very nature,

benefits conferred upon a witness by a prosecutor provide a basis

for the jury to question the veracity of a witness on the theory

that the witness may be biased in favor of the People.” Id. at

350. Colon thus follows the same pragmatic view of Brady that we

support: no matter the source, information touching upon a witness’

credibility ought to be disclosed if it could affect the outcome

of the trial.

Other cases relied upon by the People do not compel a

different result. In stark contrast to the present case--in which

Rodriguez would “very likely” (11) have been acquitted had the

People done their duty--in these other cases, the reviewing court

found the suppressed material would not have altered the verdict.

42
In People v. Tellier, 272 A.D.2d 347, 349 (2d Dep’t 2000), for

instance, there was “overwhelming evidence of the defendant's

guilt,” and the disclosure of an informal agreement of a witness

with federal prosecutors on an separate matter would not have

affected the outcome at trial. Id. at 349-50. Similarly, the First

Department, in People v. Sibadan, 240 A.D.2d 30 (1st Dep’t 1998),

noted there was “no evidence that [the witness] was promised

anything for his previous cooperation, and in any event there was

“no reasonable possibility that had the information been disclosed

the outcome of the proceeding would have been different” since

“there was overwhelming evidence establishing defendant's role.”

Id. at 35.

Interestingly, the First Department in Sibadan distinguished

the Court of Appeal’s decision in Wright, discussed supra, insofar

as the latter touched on the obligation of the People to disclose

a witness’ status as a police informant, an issue relevant to the

instant appeal. In Sibadan, the Court noted that whereas Wright

“did not establish a blanket rule” requiring disclosure of such

information pursuant to Brady, id. at 34, disclosure was required

where the unique facts of the case made plain that “a fertile

avenue of defense [would be] precluded by the People’s

nondisclosure.” Id. at 36-37. We submit that, even under the First

Department’s reading of Wright, disclosure of Cort’s status as an

police informant would have given the defense a holiday on cross-

43
examination, particularly since Cort was not merely a police

informant but an informant of the selfsame detective investigating

the Jolly case.

Thus, the jurisprudence of New York does not allow the People

to keep secret from the defense that information which can be used

to impeach a prosecution witness simply because that material

arises in an “unrelated” case. Rather, the question is whether the

information is material, using the standard measure of materiality

in such cases, i.e., whether there is a reasonable possibility (or

probability, depending upon the Brady demand)7 that the outcome of

the trial would have been different had the information been

disclosed. See People v. Garrett, 23 N.Y.3d 878 (2014); see also

Sibadan, 240 A.D.2d at 35.

Seen in isolation, Cort’s testimony in the “unrelated” case

against Charriez might have been only slightly probative of her

credibility at Rodriguez’s trial and perhaps insufficient per se

to have affected the verdict against him. Yet Rodriguez in his

7
Rodriguez’s trial counsel made two specific Brady demands,
one of which asked whether the People had a “confidential informant
and/or cooperating witness.” Justice Mangano did not find which
standard, i.e., reasonable possibility or reasonable probability,
pertained hereto, but the People suggest on brief that the latter
should apply since “defendant never made a specific request” for
the information eventually discovered by Rodriguez. (App. Brief,
at 27.) In our view, under either standard the People were obliged
to disclose this information, since the fact-finder Justice
Mangano ruled it “very likely” (11)--a much higher bar than either
reasonable possibility or reasonable probability--that the
People’s failure changed the verdict.

44
motion did not urge Justice Mangano to find the People erred in

failing merely to disclose Cort’s cooperation against Charriez.

Instead, Rodriguez complained of a much more significant,

pervasive scheme by the People to keep Cort pure: their decision

to hide a truly massive payout of tens of thousands of dollars in

direct and indirect benefits--including meals, rent, and other

living expenses--Cort and her family received over the course of

several months during the period immediately prior her testimony

against Rodriguez. This payout, had it been known to the jury,

could well have swayed their verdict, for trial counsel easily

could have shown her to have been in the People’s debt. More, since

filing his motion Rodriguez received additional information

affecting Cort’s credibility that the People previously kept

secret. In 2018 the People at last disclosed that Cort was the

confidential informant of Det. Joseph Yates, the lead investigator

on this case, and that Cort had sought his aid upon her arrest in

Manhattan in 1994, certainly commencing her cooperation against

Rodriguez.

Justice Mangano therefore based his decision not merely upon

isolated testimony in an “unrelated” case but upon a full record

showing Cort’s long and profitable connection to law enforcement

which the People assiduously kept secret, knowing its disclosure

would have ruined their case. This secret material showed Cort to

have been a witness in a remarkable three separate murder trials,

45
receiving tens of thousands of dollars in aid, and having been

given her literal freedom by the People in exchange for her

testimony against Rodriguez at trial.

Had the defense this information earlier, as Justice

Mangano’s decision finds in the most damning language imaginable,

it could have effortlessly shown that Cort was in the thrall of

the government and would say whatever was necessary to sustain the

favor of her paymasters. People v. Colon, 13 N.Y.3d 343, 350 (2009)

(“By their very nature, benefits conferred upon a witness by a

prosecutor provide a basis for the jury to question the veracity

of a witness on the theory that the witness may be biased in favor

of the People.”), cited in Justice Mangano’s decision below

granting vacatur (11).

Moreover, were the defense aware of these hidden facts, it

could easily have rebutted the People’s false claim that Cort had

not received “anything” for her cooperation against Rodriguez.

Indeed, the relevance and materiality of this suppressed

information has been determined as a matter of fact in this case

by Justice Mangano, who ruled that the verdict “would very likely

have been an acquittal” had the defense this information. Nothing

the People put forward on brief alters this factfinding by the

court or shows it to have been error.

It again bears noting that the People’s main argument in their

own defense on the instant appeal--that they had no obligation to

46
disclose Cort’s receipt of thousands of dollars in financial

benefits because such benefits pertained to the “unrelated”

prosecution of Louis Charriez--is wholly disingenuous since the

People kept this very same material secret from Charriez as well.

Had they made such a disclosure to Charriez before trial, their

present ungenerous reading of Brady might have more force, or at

least less hypocrisy. As it is, their position on appeal is

supported neither by the law of this state nor by the People’s

present argument.

We therefore urge the Court to conform to the reasoning of

Johnson which clearly contemplates the disclosure of “unrelated”

cooperation agreements where the facts and circumstances of such

cooperation would permit the jury to question such witness’

credibility.

The People Cannot Determine

“Materiality” by Using Their
Own Judgment of What
the Defense May Do with
Impeachment Information

In support of their contention that the trove of highly

damaging, previously undisclosed facts now known about their sole

putative eyewitness, Cort, was not in fact “material,” and

therefore not subject to Brady, the People apply a novel test:

their own post hoc judgment about what the defense might have done

with such information, had the People had disclosed it before

47
trial. Unsurprisingly, the People have decided for us that we would

not have used it, thereby absolving them of their failure to

disclose it.

As we understand the People’s argument, they say that had

they disclosed this impeachment material, and had we sought to

impeach Cort with it on cross-examination, they would have been

able to argue on re-direct examination--presumably to rebut a

charge of recent fabrication--that her initial identification of

Rodriguez preceded her receipt of any benefit and to allow them to

introduce evidence of same, namely an audiotaped statement Cort

had given, her photographic identification of Rodriguez, her grand

jury testimony, etc. For this reason, they say on our behalf, the

defense would have refrained from using such information in the

first place, rendering it immaterial for Brady purposes.

Needless to say, this is an exceedingly difficult, albeit

impressively acrobatic argument for the People to make. While it

is correct that Cort’s identification of Rodriguez preceded her

receipt of monetary benefits in the Charriez case, some three years

later, the People also hid from the defense other benefits received

by Cort pursuant to her cooperation against Rodriguez, namely her

freedom. As discussed at length above, Cort had two felony matters

pending when she first sought the aid of Det. Yates two months

after the Jolly shooting in November 1993. Upon her arrest in

Manhattan in January 1994 Cort reached out to Det. Yates through

48
her arresting officer, P.O. Daniel Sacco, evidenced by a document

hidden by the People from the defense for more than a quarter

century. Cort, of course, was Det. Yates’ confidential informant,

and Yates was the lead investigator on the Jolly case. One hand

duly washed the other, and whereas Cort faced certain upstate jail

time on two pending felony matters against her, she walked out of

Rikers a free woman just weeks after making Det. Yates’ case

against Rodriguez. The People’s insistence that no such deal

existed ignores Justice Mangano’s finding--after a review of all

this previously hidden material--that it did exist, noting the

prosecutor’s “blatantly intentional misstatements to the jury . .

. that there had been no benefits received or leniency given in

criminal matters” (11-12).

The People now urge upon this Court a silly argument that

evidence of life-altering benefits received by Cort was not

“material” since the defense would have hesitated to use it for

fear of a damaging rebuttal. The People’s argument should be

dismissed out of hand. Brady is Brady, and the courts not the

People determine whether they have erred in keeping it secret.

First, Brady material does not cease to be Brady material

simply because its use by the defense would permit the People to

marshal an argument that might blunt its impact upon the jury.

Second, the People’s use of such rebuttal evidence would have

been permitted only to counter a charge of recent fabrication, but

49
the defense at trial may not have made such a charge. Rather,

defense counsel might have urged the jury to find Cort was a

“professional witness” whose testimony over the years had been

purchased by the People with all manner of blandishments, including

benign treatment on open criminal matters, new arrests, violations

of probation, bench warrants, as well as massive monetary payouts

to Cort and her family. The defense would have been able to give

substance to such an argument by showing her tight connection to

law enforcement, particularly to the case detective Yates,

evidenced by her cooperation on an astounding two additional murder

trials.

Third, even if defense counsel argued that Cort’s trial

testimony was a recent fabrication, the use of such otherwise

prohibited evidence by the People would remained within the sound

discretion of the trial judge, who might well have denied its use.

One cannot presume that the trial judge would have sanctioned the

People’s attempt to rehabilitate such a witness as Cort, assuming

the trial judge was aware of all facts about Cort which the People

kept secret for so long. One can easily imagine the trial court

prohibiting such an effort by the People as a sanction for

presenting such a witness as a good citizen who received “nothing”

for her cooperation.

Fourth, and most important, the People’s argument puts

themselves into the head of Rodriguez’s trial counsel and asks

50
what he would have done more than twenty years ago had the People

duly discharged their Brady obligation to hand over this

impeachment material. Thus, the People propound a rule that

requires an act of clairvoyance to determine what is and what is

not Brady. Indeed, as a practical matter the People would reserve

to themselves this right to read minds, since the determination of

what to disclose is made by the People in the first instance, not

the courts. Do the People really suppose that they can judge what

decisions defense counsel might take when handed a trove of

impeachment material? Is it really for the government to put

themselves into the minds of defense counsel, and to use their own

determination of trial strategy to weigh whether a particular piece

of impeachment evidence is worth using?

In other words, the People contend this massive trove of prime

impeachment evidence--kept secret by them until uncovered by

Rodriguez in his jail cell--is in fact not what it seems. While at

first blush this evidence may appear to put Cort’s testimony in

somewhat of bad light, they contend, but in truth it is completely

harmless. It is harmless, they say, because they have thoughtfully

made a determination--on behalf of the defense--as to what we might

have done with it had the People duly disclosed it. They argue to

this Court, in effect, “If we had handed over this information,

and if trial counsel had sought to use it to impeach Cort, and if

the basis for the impeachment were an allegation of recent

51
fabrication, and if the trial judge permitted us to rebut such an

argument with other evidence, and if the jury was swayed by our

argument that Cort was merely doing her duty as a good citizen, or

if the defense recoiled from making such an argument for fear of

opening the door to our rebuttal evidence, then the verdict would

have been the same . . . .”

Such a Rube Goldberg device of an argument should be taken

for what it’s worth: very little. Yet it is the only support the

People make for their audacious claim that even explosive, verdict-

altering impeachment evidence constitutes Brady material if and

when they decide it is Brady material. As mighty as the government

may be, their powers do not run to mindreading, much less to

omnipotence. The People cannot arrogate to themselves the right to

think for the defense and to decide for them what impeachment

evidence we might use. This is not the wisdom of Brady.

Inasmuch as the People’s argument hangs upon what a trial

practitioner might have done with such evidence, had the People

disclosed the impeachment material here at issue, I can state

unequivocally--on the basis of more than twenty years experience

trying homicide cases--that were I Rodriguez’s counsel I would

have not hesitated to use it to impeach Cort. Indeed, any trial

counsel would have been rightly accused of ineffective assistance

had he or she failed to use it. Moreover, were it used to attack

Cort’s credibility, the verdict very likely would have been an

52
acquittal, as Justice Mangano--himself a highly respected jurist

of long service--found in his decision granting vacatur (10-11).

I would have had no fear whatsoever of the People’s so-called

rebuttal evidence, which would have shown only that Cort’s

cooperation commenced simultaneous with the leniency she received

from the People, a natural enough occurrence and no reason to have

shrunk from a cross-examination that would have proven her to be

a liar and the prosecutor something worse: a liar who swore an

oath to uphold the Constitution, a public servant who made

“blatantly intentional misstatements to the jury” (11-12).

In light of these facts, the People’s complaints show an

astounding temerity given the magnitude of their misconduct and

the injustice they inflicted upon Rodriguez with their poisoned

evidence.

POINT II

THE TRIAL COURT CORRECTLY FOUND THE

PEOPLE KNOWINGLY ELICITED FALSE
TESTIMONY AND LIED TO THE JURY

The court below, Justice Mangano, ended his decision vacating

judgment against Rodriquez by noting the various “blatantly

intentional misstatements” (11-12) to the jury by the trial

prosecutor Reeves and his elicitation of false testimony from his

witness Cort. These questions and comments by Reeves were clearly

intended to leave the jury with the false impression that Cort was

53
pure of taint. Justice Mangano rightly found such comments and

questions compounded the misconduct already discussed, i.e., the

massive Brady violation by the People. Thus the People at trial

not only kept the defense in the dark about facts they otherwise

could have used to impeach Cort’s credibility, the prosecutor

enhanced the jury’s impression of Cort’s credibility with

disingenuous questions and comments, knowing the defense was

powerless to do anything to correct the record.

Justice Mangano’s decision granting vacatur, therefore, did

not hinge upon his finding that Reeves had lied and elicited false

testimony; instead, the court found Reeves’ misconduct

“[c]ompound[ed] the above errors” (11), i.e., the People’s failure

to disclose Brady material. The decision evinces the court’s

disgust at the insult added to the injury sustained by Rodriguez

as a result of the People’s failure to make any Brady disclosure

whatsoever notwithstanding the treasure chest of impeachment

material in their possession. The court, which found that the

verdict “would very likely have been an acquittal” (10-11) had the

People disclosed this information, went on to object to the

prosecutor’s comments to the jury and questioning of Cort designed

to show the absence of the sort of taint belied by the very

information the People kept hidden.

Under these circumstances the court rightly found that the

prosecutor compounded the injury of his Brady failure by taking

54
the additional step of misrepresenting his witness to the jury, by

questions and comments, as a person of pure motive having no

connection or obligation to law enforcement. One reads Justice

Mangano’s decision and comes away with a strong impression of the

court’s outrage at the twin injury done to Rodriguez: keeping

powerful impeachment material secret from him, then using his

ignorance of such material to tout with impunity the goodness of

such a witness as Cort.

Rather than tucking tail and accepting Justice Mangano’s

admonishment with grace, the People double-down on their unlawful

conduct, seeking to excuse the inexcusable, offering no law or

compelling policy to justify hiding powerful impeachment material

from Rodriguez, defending Reeves’ scheme not merely passively to

hide the truth but actively to portray his sole “eyewitness” as

untainted by the facts he kept hidden: that Cort was deeply in

debt to his office, not merely for rent, food, and money, but for

her freedom.

Even so, while it is beyond debate that Justice Mangano

correctly found Reeves both elicited false testimony from Cort and

knowingly lied to the jury, the instant appeal does not rest upon

this Court upholding the court below on this point. That is,

Justice Mangano’s decision to vacate judgment was based upon his

finding of a massive Brady violation, and vacatur was the

appropriate remedy on this basis alone. That Reeves went on to

55
compound the fatal blow he delivered to Rodriguez does not make

the blow any less fatal.

The People admit that a prosecutor has an obligation “to

correct the knowingly false or mistaken material testimony of a

prosecution witness.” People v. Colon, 13 N.Y.2d 343, 349 (2009).

Astoundingly, however, they argue that Cort said nothing false nor

mistaken and that the prosecutor’s duty to correct the record was

therefore untriggered. To support this claim, the People hope to

focus the Court’s attention not on the entirely of Cort’s testimony

on this score, nor--more important--on Reeves’ clear purpose in

asking such questions, but upon just three questions and whether

Rodriguez “established that Cort’s answer to any of these three

questions were false.” (See App. Brief, at 49.)

Justice Mangano, however, did not limit his ruling to these

few questions upon which the People now fixate. Rather, he

concluded that Reeves’ comments to the jury and his questions to

Cort were designed to show “there had been no benefits received or

leniency given in criminal matters” (12). As the record before him

allowed Justice Mangano to find that Cort had in fact been given

benefits and leniency from the People to encourage her cooperation,

he rightly concluded that Reeves’ intentionally misled the jury

(8-9).

One has only to read Reeves’ direct examination of Cort on

this point to see he sought to show she was free of taint (240-

56
44). This intent is clear from Reeves’ opening remarks to the jury

that Cort “didn't receive anything for coming forward. No one cut

her any deals. No one gave her any breaks” (205). There is simply

no innocent explanation for these questions and comments. Reeves

knew8 of the benefits and leniency afforded to Cort, yet he

successfully created in the mind of the jury the belief that Cort

gained nothing for her cooperation. The questions put to Cort by

Reeves were clearly meant by him to enhance her credibility by

creating a false impression of her. Else, why ask?

At bottom, the People’s argument evinces a continuing refusal

to accept Justice Mangano’s finding that Reeves hid Brady

information from Rodriguez. Reeves’ elicited no false testimony

from Cort nor misrepresented any fact to the jury, the People

argue, because Rodriguez “has not proven” Cort received benefits

nor leniency for her cooperation. (App. Brief, at 48.) As has been

discussed at length above, Justice Mangano had a complete record

before him, and he found that Rodriguez showed that Cort received

8
The People coyly argue that there was no evidence that Reeves
had personal “knowledge of Cort’s involvement in the Charriez
prosecution, let alone the financial payments that the People made
on Cort’s behalf.” (App. Brief, at 56.) Justice Mangano correctly
dealt with this argument below (11), citing People v. Steadman, 82
N.Y. 2d 1 (1993) (knowledge of the prosecutor’s office as a whole
may be imputed to an individual prosecutor). As the People
themselves earlier cite Steadman, (App. Brief, at 47), one wonders
why they assert this argument now. Even so, it is specious to
suppose Reeves knew nothing of the Charriez case, since it was
pending in the same courthouse, at the same time, and with the
same prosecutor’s office.

57
benefits and leniency for her cooperation. On the basis of that

finding, Justice Mangano further found that Reeves “blatantly”

misstated facts by his questions and comments. The People’s

complaint, therefore, is not a legal argument but rather an

obstinate refusal to accept the conclusions of the factfinder,

Justice Mangano.

Thus, even if we assume for argument’s sake that Cort’s

answers to these three questions were technically “true,” which we

deny, Reeves knew the impression he created was false and that

Rodriguez could do nothing to correct it. Even so, one of the three

questions Reeves asked of Cort elicited an obvious falsehood.

Reeves inquired whether Cort had “not heard from us for a long

period of time,” to which she answered, “No” (243) (emphasis

added). In fact, as discussed supra, Cort at that time was in

regular contact with the District Attorney’s Office, which was

providing her payment for housing and food during the period from

at least December 1997 to April 1999--that is, until the very eve

of Rodriguez’s first trial.

Through his examination of Cort, Reeves clearly sought to

buttress his only eyewitness’ credibility by creating a false

impression that she had received nothing from law enforcement. In

truth, Cort was heavily indebted to law enforcement as a result of

years of involvement with them. Had the defense the slightest

inkling of this involvement, much less its monumental scale, it

58
would then have been able to destroy Cort’s credibility. Knowing

this, the People quite obviously kept this powerful ammunition

secret. Not only were the People therefore able to shield Cort

from vigorous cross-examination, they could use the defense’s

ignorance as a sword to enhance Cort’s credulity through questions

and comments designed to show she was free of taint.

Justice Mangano saw very clearly what the People were about

and gave them no quarter when they raised these nice arguments

below.

CONCLUSION

Althemease Cort, the only witness to identify Rodriguez as

the perpetrator, was “the People’s case.” To keep her pristine,

the People hid from the defense a host of impeachment material

that would have destroyed her utility as a witness. Justice Mangano

saw the injustice of this failure, finding that had the People

disclosed this material Rodriguez “very likely” would have been

acquitted. The court below further found the People unfairly

exploited Rodriguez’s ignorance of this material by using it as an

opportunity to bolster Cort’s credibility without fear of

rebuttal. For these reasons, we respectfully ask that the order of

the Supreme Court be affirmed.

Dated: Brooklyn, New York

February 25, 2020

59
Respectfully submitted,

ROBERT C. REULAND, ESQ.

Law Offices of
Robert C. Reuland, P.C.
26 Court St., Ste. 1406
Brooklyn, NY 11242
718-300-0626
robert@reulandlaw.com

60
 PRINTING SPECIFICATIONS STATEMENT

Certificate of Compliance pursuant to 22 NYCRR § 1250.8(j)

This brief was prepared on a computer. A monospace typeface

was used, to wit:

Name: Courier

Point: 12

Spacing: Double

The word count hereof, inclusive of point headings and

footnotes and exclusive of signature blocks and pages including

the table of contents, table of citations, proof of service,

certificate of compliance, or any addendum, is 13,064.

61
EXHIBIT
 DISTRICT ATTORNEY
KINGS COUNTY
350 JAY STREET
BROOKLYN, NY 11201-2908
(718) 250-2000
WWVv.BROOKLYNDA.ORG

Kenneth P. Thompson
District Attorney
February 9, 2016

Wildon Rodriguez
Inmate No. 9916661
Shawangunk Correctional Facility
P.O. Box 700
Wallkill, New York 12589

Re: FOIL Request

People v. Rodriguez
Kings County Ind. No. 4116/94

Mr. Rodriguez:

This letter will acknowledge receipt of your check for the sum of $24.is, which
represents reproduction fees for the records you requested pursuant to the Freedom of
Information Law (FOIL). Accordingly, enclosed please find the requested records.

Sincerely,

kvie Zoumnioti.s
Evie Kournniotis
Paralegal, Appeals Bureau
FOIL Records Access Officer

1
 I
i (
'·
DISTRICT ATTORNEY OF KINGS COUNTY
MUNICIPAL BUILDING
BROOKLYN, N.Y. 11201
(71 8) 250-2000

CHARLES J. HYNES
DISTRICT ATTORNEY

January 5, 1998

DearMs·~-

I am writing this letter on behalf of Ms. Althemease Cort and

her family, who was an eyewitness to a homicide on January 10,
1997.

. On that date, Ms. Cort hear an argument between two men on the
second floor of her apartment house. When she went out to look,
she observed one individual plunge a knife in to the chest .of
another man. Since that time, Ms. Cort has received repeated
threats against her life. These threats have come not onlv from
the defendant/ s family/ but from the defendant himself.
Consequently, Ms. Cort and her family fear a violent retaliation
for their cooperation with police and the District Attorney's
Office.

I strongly recommend that the housing request made by Ms.

Althemease Cort and her family be expedited.

If you should have any questions regarding this matter, please

do not hesitate to contact me.

~'.~
Timothy ~ugh
Assistant District Attorney
(718)-~.-

2
 DISTRICT ATTORNEY OF KINGS COUNTY ·-··
MUNICIPAL BU_JLDING
BROOKLYN, N.Y. 11201
(71 8) 250-2000

CHA~LES J. HYNES

Date /7'.\.
· b:2--· /LJ. I c;c:;1·
DISTRICT ATTORNEY
/ .-/]
;/..,,. I .

Custody
Dear Sir or Madam:
\

This letter is to confirm reservatio.ns -made on /) C..-',(;..,;[)/ I '?·77

, .:-.-::::-._
(date)
with for a (singl~(doubley
/~:;;o-~room.

This custody was reserved

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under the name of
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and Will begin 0!1))(:5[', 7 77
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and end On
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There will be no food, telephone or movie privileges for this

custody.

All billing is to ~e_directed to the Kings County District

Attorney's Office, Attention: Mr. Richard Safianow.
Should you have any questions, please contact me at 1

Very truly yours,

- \ .•_
Richard I. Safianow
Director of Operations

Confirmation, :,

OPER 25 - Rev. 10/96

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O1&-TRICT ATTORNEY OF KINGS·CoUNTY
MUNICIPAL BUILDING
BROOKLYN, N.Y. 11201
(71 8) 250.2000

CHARLES J. HYNES
DISTRICT ATTORNEY

WITNESS AGREEMENTFORM

I, i"::--------:~'presently
under voluntar' us o y of the o of the Kings County
District Attorney, have read, understand and agree to the
following conditions of my voluntary custody:

1. I may not use the telephone located in my room without

the express approval of the Office of the Kings County
;;.~District Attorn~y. All my personal calls are to be mad'e
from a coin operated telephone.
2. I may not order meals through room service.
3. I am prohibited from divulging my current whereabouts to
anyone without the express approval of the Office of the
Kings County District Attorney.

4. I am prohibited from using Pay TV services in my room.

5. No visitors are allowed in my room without the approval

of the Office ~f the Kings County Distriqt Attorney.

I realize that any viol tion of these rules in any way

may imme,~i,9-tely rmi custody.

\~~<r---=-r-~_at-~:-(
,,__<;_;_?-
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WRP.8
EH:mg

5
 r~
o'ts-TR!CT ATTORNEY OF KINGS COUNTY
r·
MUNICIPAL BUILDING
BROOKLYN, N.Y. 11201
(71 8) 250-2000

CHARLES J. HYNES
DISTRICT ATTORNEY

VOLUNTARYCUSTODY

j
I understand that I am in voluntary custody with the Kings
County. District Attorney's Office. As a participant in this
program, I will abide by the following rules and procedures.
\,·
1) I will not disclose the location where I am staying or have
visitors at the location.

2) I will not give out the telephone number.

j) I will not return or revisit the neighbor.hood where I was

moved from or where the incident occurred.

4) If I ( including any and all members of voluntary custody")"

conduct myself in any manner that will jeopardiz~ the
confidentiality - and/or safety of myself or the Relocation
·Program, · :r understand that I will be dismissed from the
Program.

If I violate any of these rules or procedures

will be immediately dismissed from the Relocation Pr

Signature :

Date

Witness

WRP. 7
EH:mg

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CltAND TOTAL f/:1,ooi·,a¼J !

I hercb1 ttrtif1 th&! the 11.bovcr:.ccount ofe.x:pcnditurca lJ Q tr.Jc and correct autcmcnt or dit.buncmcnu ~tla.l!y 'C).J.dcby :DC; thl~ the/
""-tlt:c for ;upp-er money included ui this &eeount "inl for aervicc&required a.fter rer,.ih.r bu,ineu houri 1.1\d authorind by cy cui>etvuor ;-

-
! tha.t the cx:pcnditum of the 1.bovc aum1 were ticccuuy

~
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in the p-er!ormancc o! my ,officii:.1 city datic:1; 11.nd further
rco! h.u beec J»,id to cic ..execpt u au. tcd thereon, uid thll the bt.li.ncc r..s :how-c therei!i i: i.ctully due i:nc.
9
e1:rti!y tiut M put'
,
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....·- ··-~· ... ·- . --. (···· ..•.......
,..............,.....•..... . ... . .... ' ..•... - . ·(

i>ERSONAL EXPENSE b ~/~ . · /

~"--~-i9;-
el) ?JA-,1-)) !Id/ ~ f/4;ef/LI 15
/~ / Pa.rec

DI sunCJ ATIORNµ' - KING

s com.TI
Bares.a or Di,-uion Mdrcu
''.tr ~ tlubi:and Cl lol.low11t

Car Auto Supp cir irl<VQ(

l?Ait'i"iCULA!llS Fare Expence :Tel.
Money Expenalf Mlac.
Mo. Day
.
{.::,/"t:> :
,0---;;j,~~
-:ciJ,) ~ /.77cf. 1 "7 ~ '
l+i'>/1- ~?<'.Gff
£ c;/ /}-/VU'
e--c._ ,,!,

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VA),.1,i,.1.:;:::-s_e:,· fd'1'r.Se' UiJ/4/-

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1 hcreb,- ~i{y thll the &b-ovt r.c:c:ount oC e.xpcndit11rc1 u a t::n:ic s.nd correct ,utcrncnt of disburacmcnu a.etuall1 i:u.dc b1 i:ic; thu the
i-ai1c:c for supi>er money i.tic:luded i.ti thi1 r.ec:ount wu for acn-icca required t.ftcr re,r,Jlr.r busineu houri iuic! authorircd by m1 11upcn-isor:
that the c:xpenditurn o! the ab-ove sumi were !lcccrn1.ry in the ~r{or-rna.nc:c of my ,official ciry ciatic1; acd Curt.her certify I.Mt n¢ put
co! hu ~ell p&id to inc c:xc:cpt IU ,uted thereon, uic! thtt the ba.lancc u ,howt1 therein is 11c:tia.l17 due file.

~ C }~ JOO;/ . . .

10
~~ .. ,_
 () .. _ ("
DISTRICT ATTORNEY OF KINGS COUNTY
MUNICIPAL BUILDING
BROOKLYN, N.Y. 11201
(7 18) 250-2000

CHARLES J. HYNES
DISTRICT ATTORNEY

To ·;\ y~--1/fV/ ~ 1
l( 6 . ,

From . seni::
Witness
Investigator
R location
Michael
Program
Wishner

Subject: ev~~

In order to effectively assist your witness/ witnesses, a

letter must be written by you which must include the following
information:
Type of Case (ie. Homicide, Sex Crime, Assault; etc.
Explanation of the nature of the threat) I

Type of Housing Requested

( ) Public Housing (NYCHA)
K) Section 8 Housing
( ) Housing Transfer
Projects Name ____________ _

(f)
(
New Application
) Application on file

Request for Assistance to Expedite Housing

The letter should never include the name of the defendant
or the indictment/docket number.

Please address the housing letter (2) ·to the appropriate

person. Check below

( )
Hopsing Manager
I :•

All letters must be brought directly to me within a 3 day

period. ·If you have any questions please contact me at #250-2816.

11
 /
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, btva r4~[vc4 Ct![cd tryr. t.he
et t.ba
Xf.l'lgr C.C1.:..it}' &>1 rtr!c-t. Att.orT\ry t..b1 iru of I .SOt'QQ
vh[c.h r11prut:rita
iru ailovLJica (or ll!)' es1l11 ~b!le Lr-. C\.!..!te>-dy ct t...l::i!IJ fgf{L0,.4J,, t'tii@
11\lJl I. 11 u ~ tu 1t d ! or Ii c 1.1, for t..b II r" r i ~ sf /J- / 7--JI D ;\UJ /'-/;;i.7I 9 J
'

X o:\ ! n d el! var a~ kry 1_-.;.,/

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Dlte1 __1_·L-_..l_./_2-_?V,_,__~7'----------
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...... •,... '•:·•:;+;••:-;-,.., •• .,. __
..

PERSONAL EXPEht~£

DISTRICT
ATIORNEY
- KINGS COUNTY
Barc&i:i or Dimioo Address
For ~ tlubc:r:rwd '" Follor.ou
Car Auto , Supper Trev cl
Fare ExpQn&e :Tai. Mlac.
Money Expen&IP'
Mo. Day

I I

I /'7 I) LW/.,~., I ./ / /
., './ I
r

··--

II
V

1 hereby certif7 th&t the 11.bove11.c:c:ountof cxpenditure1 Lt a tr.le r.nd correct 1a1cmcnt of d.i.lburaemcnta i:..:tua.11.rm:.dc by i:::ic: thu_ the
:l'W'l.llc:c{or s11pixr monc:r illc:ludcd ill thia &eeount WI.I !or aervicu required dtcr reiruh.r bu,incn hours e.nd authorized by my 11up-en-uor;
i th1.t the cxpcnditum of the &bovc aum, 'Utre ricc:euary in the p-er!o:-rn:.ncc of my,offic:i;.I city daties: li!lc further "rti/1 t.lut ~ put
:reof h.u b-een p,.id to me a:c:cp_t u sutcd thereon, o.nd th&t the bil;.ncc u &howti thcreui is aetia.ll7 due tile_. · .

14
 DISTR~ ATTORNEY OF KrNO 6 COUNTY
MUNICIPAL 8UILOINC3
6-ROOKLYN, N.Y. 11201--3745
(71~)!,02-200:>

°"7__,
~LES J. H'T'NES
~~y·

3DJ, 'I 77)

•

. .

O<lar Sir/Madam:
Please extend cu~tody No.
If you have any further questions, plea~e fe~l fr~~ t.o call
me at (718)'~.

Sincart1ly,

q1'~.J~
Richard I Safianov ·
Deputy Director of ~rations
RIS/sh

15
 (

Darn r:;~ YV-.1: x:,n:x

r,/Jc../4/4JSe {hr-; b,n r,;,_,!v,t_,.;:rn u, Ottlce mt ti•

J:.!rip ~1.:.."lt)'
t>'rtr.ic:-t J..tt.orn,y u, .-u of ,_'.)Di;Q~ vh!c..h repru1rnta
1rU,1i.lfOVLJic1t (or ty ~a.allf vh!h f...r.. C'.J...!to-6t cil 1t..b~st{t0-fJ., 'i:J:d@,;
s-~- i. Ii w ~ tl.J e d tor me i. l, tor t.b tr ~ r £ e,..6 a! I /:::, I U / I 12../ D'6 91>

X o,'\! u ci t1 ! v 4 r 1d t,y 1_...,,,.....!~:.......::::~~:..::::::;,..._.::.,.-===--::,-'"'9.---

g l r:'-1t u...r4 0 f 'it.£t..JH 11e 1~~~:::::::...!....===:::~~::::::::e=--~:...:::_:;:;;;...1--

t> 1 ta 1 /J;r/t3

u1 i7.?- C!nn..or
r:J( ( }.,;))...

16
 PERSONAL EX.PrTSE I
·:.,:·.··,;:·-.:·:· ···=~
_:.:,..:~(·.:
•.
...•:. ·i:
..
...
>'. .
'}' 1Paytc 1

- KINGS com.Tl'
DISTRJCTAUORNEY
Barc:aa or Di'l'i.1ica
Far~ tlubt:rNd ru I.Uoto•t
:: ·..."",~...... Auto
Car Supp or Travel
PAR.TICULA~S Far• E.xpan1• Toi, Expensl Mla1
Money
Mo. Day
{)a_-. ~-
~/'f::>QI/;
-,z)jf/ 7/ .W'. 7 '
,41),4 .·8:tJct.0if"
I( C//·,-/'JC/e" G .,,
7£.1
'/I),,. .:::s:s· 4 1.f.&-tM
e'7ts cr r {d,,/1..f-

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!//(~. l~t1UW ,rzJM.
rf~u--rr7oiJG1)
......-
U}//1),-,,<'.'5:,. er- b;,,C/
/ ,,..,
J--A1) 'vl~ F/%0b ////.-d1)/JJ/ A
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t:::::.

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CHECI<:/fr 330:Jo.
~uuN1,so<fxv
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;.· 6/4 I ))1::2;. fi !06:::G,..-,J,rJ/,,J<S I//;:?/
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• CiJVJ<t> TOTAL ~0~!?-<7
I

I bcrcb7 etrtifT that the 11.lx,n account of cx~ndituru u a trae &nd cCC"Tect,u.tcment of dhbur1er:ncnu &.ctw.lly i:ade by me; th•~ the
LllowJ.nce {or aupptr monc7 included IA this account 11ru for 1en-icu required &!ter n:'°"lu basineu hour, ud authori:ttd by er aul>(NUOT:
.,.., ,nd thu the c:xpcriditurc1 of the ,.ix, .. 1um, were 1>cccu1ry in the i><:rCorm•ncc or my,offici1I cicy datie1; and !urt.hcr ~rtifr th>.t Z>¢ put
lh<,rco! h.u bcca p.,.id 10 r:ne except a., St&tcd !.hereon, &ad t.hll the balance a., aho= therein 11 actually due cc.

FTR IR - Aav ~/Q?

---------.. ........
-
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; .. ••,::, :····-·

•'•, .• ~ • • •t~':, ~-....•--\•·--·~, .. ~••.•/,••I~,.•.,·,~.::,>·.•,,_.. \j~.,.•, • :~,·. • • :: • •;,• -~··::-•~:: • ., ,~• ,;,,~·.-._. ..;:..,.~.', · .. •· ,>~-=.,~·
:•,.,•!,', ·,.:·· .~··.-~~ •• ;·,.::·:· •, :• ·, ,· ,•, .'•' '•,:• •',·' .::• '-;.·..,, ••. • • .,,• .. •., '.•,
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17
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018TRlCT ATTORNEY OF KrNOS COUNT'Y

MUNICIPAL BUILDING
. 8-R<X)KLY N, N. Y. 11201--37.( .5
(718)602--2000
I
(.

~LES J. HYNES
~~y-

Please ertend custody No. ·.• : until~ :SOI I '.z2J/.

If you have any further quection~, plea~e feel fr~e to call
~e at (71Bi:

Sinc~raly 1

~~-../~·
Richard I Safianov -
Deputy Director ot ~r~tioM
RIS/£h

19
 r· '·· .

X o .~( ll d t1 { v Hi j kry 1 _ __:.).,!..l..t_:.p.--------r=-c---r:---

! f ·\'I-! t u..rCl O[

CC( rn.. D[r« c:-LOr

r' r I D)..

20
 D1S1J3JCT ·AUORN'E;Y- KINGS COUhTf
B wcui or Din.doc Addrcu

car Auto Supper Trav&I

P.ARTJCULAlUi Fare· Expcncc: :Tc.I.
Exp11ns4'. Miac.
Money
Mo. Day
:

0<.~/#~
-r;:;1) /# - 17 .
/.7_7;· ,> ,

41>/1·8?1t{Gff:
.£ C///J-/4,...d/er'C- ·t.!,

IA)/ 7i1 ,; A_r/l-e-m0t:se

.:::::s: Cn;/2.../-

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Cil.A.11(0TOT AL ~t")cftJ-o
I
I bercb1 c-trtif1 th&! the above account of v::pcndituru u II by roe: that_the
tr-Ile:.nd correct iU.lement of d.uburacmenta actually fl:l..1dc
-uncc for pup~r moncr i..l:lduded i..1:1this 11.ecount wu for 1crricc1 reciuired a.!ter rcrular bu,ioeu hours II.lid authorind by %!ly aup-en-uor;
th11.1 the expenditures or the a.bovc sum, 'lircrc :eece1ury in the per!orma.ncc or my,offic:i11.Icity datie1; e.nd !urther c-ertirr th&t M part
:o! hu ~en p,,.id to me except Al l!U tcd thereon, ~nd thii the bah.nee u ,ho'i<ll therein is l.\ctt.al!y due l::lc.

21
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22
 DISTRICT ATTORNEY OF KINGS COUNTY
MUNICIPAL BUILDING
• BROOKLYN, N.Y. 11201
(71 8) 250-2CX)()

CHARLES J. HYNES
DISTRICT ATTORNEY

ENCLOSED PLEASE FIND PAPERWORK ON BEHALF OF THE HOUSING APPLICANT

LISTED BELOW:

Na.me:

Address:

S.S.#:

() NEW N.Y.C.H.A. APPLICANT

(} N.Y.C.H.A. APPLICATION ON FILE

() N.Y.C.H.A. TRANSFER

( )· NEW SECTION 8 APPLICANT

(/SECTI~N 8 APPLICATION ON FILE

~D.A.'S LETTER

is being processed by the Kings county District

·tness Relocation Program.

MICHAEL WISHNER
.DETECTIVE INVESTIGATOR
WITNESS RELOCATION PROGRAM

23
 .,--. (·-
. ) ..· ( ,·· ·..... . .\

DISTRICT ATIORNEY
- KINGS CO'O"hTI
Bure:u1 or Diriiion AddreH
P'~ ~ r:lubc:t1'1Htd
u Fo!.lotc11t
Car Auto Supper Truv111
PAlitTICULAlil!.S Fare Expenc.e Tel.
Money Expona.a' Mice.
Mo. Day
:

th~~
-:C:V;) Y / 77f- 1 "7 · '
41)/1-831ttGtf!
£. C///1-,/'Jl/e'"c- :t,.I.

( ,4 r/ fc::m y-113·e
0) / /,{/:::;-·.;_ G)/4/-

.I I
f/1(t:;.-Jf-(_
f'h..dU?!-/ ht-1..H/PtL'-'1}-fdUC-1) /
--
(v ti 1J1::...:>S•-:;- ~1,l~/ '
/ /'I

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ET
mt.AND TOT AL
~Oft2-<2
I

I hereby eu1H,- th&t the i:.bove account o( ~pcnditurc1 u e. t:ruc !lnd correct :u.te:ncnt 0f d.uburiement1 ~tinily =udc by ll:lC: thtt the
nnce for sup~r c::1e1ne7 itlcluded ill this account 'inl for acrvice, required &!ter rc~l&r bu1ine11 houra ru,d 11uthorired by my au~n-isor;
thi; · the c.xpcnditurcr of the· :.bovc ,um, were ?lcccu1ry in the pcr!ormancc- or my ,offic:ia.lcity datics i li.'?ld {urt.her certify tlat M pi.rt

____________
co! hu been ~id to me except e.s cutcd thereon, and thu the b11.b.ncce.s 11hoW'!ltherei..il is eetu:.ll.r due me.

_,_;
24
'~OVED Bi'
41!,.o () ~/(\, M -
 ...,· /l ·-·

-···•..., ...... ·········\. •• ---·. ·- •• - ••• • • 7 (

'·

,?7
PERSONAL EXPENSE %!t:}'
.-.
----.-- --
I~-

_ti
C
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· ;__/(....::::..0);}>_2t;_/,t.1_~_:,..,--_____ }1/) , . . I> Jt::/(
/ ~11.yec

DISTR!CT AUORNP,'- KINGS CO~UN::'..!.:..::ITT--=-------

- Bar~a or Diriskio Md.res,

Ccr Auto Supper Tr11v111

li'AR.TiCULAil.S Far11 Expanse ·T11I. E i: p 11n1:'d' Ml&c.
Money
Mo. Day
{.Sic:> . .. .:
i?tti-,:'~
--r:ui) l.T/ 7.7f'. 1 ·7 ·' I

A;),# ~~G if-: I

£ C///r-/"JU e--<:..- "'-':

uJu1~(,·A_rl l-c::-m
e'lf;S ~ c";r;/Z_/-

·; I
IJI(e,1j-(__.
11'1_.i,),;_}?<,/hH- Ht-6V:r11-~
C:r'/)
/
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;t, 1/1)C£Lls if/goo 10:::r-rt>

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Sof (.;O

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. ;
~I>TOTAL ~s-of·&,;
I

I bereb:r «rtif:r that the &l:>ovt ac:c:ouot o{ expenditure, u a tn:ic &nd c:on-cc:t su.temcnt of cfubunemccta iu:tuaI!y 1:n1de by i::ie; tha~ the
1"11.tic:c
for sup~r moner included in thil account W'l.1 {or acrvicc, required s.!tcr rcg-uh:.r buiineu houri L"\d :.uthorind by ~.r iUJ>Hvuor;
th1t the c.:q,cnditurc1 o! the aboYe aum, were :iec:cuary in the ;>erforrnince of my,offic:ic.l c:ity datics; and further c-1:rti!.r~t ~ ran
co! hu ~ell p-,.id to rnc except IU ctucd thereon, aed th1t the b1l1ncc u tho...-:i therein is lletw:.ll:r due me.

------------,--- ...9,i C"\

~OYED BY
; 1 ' " . . .. 25
/i I VJ./t1,~
 ('

D !STRICT ATTORNEY OF K rNO S C0vNTY

MUNICIPAL BUILDING
BROOKLYN, N. Y. 11201~745
~1¾ (T15) 802 ..ZOOO
I

~
!•

(iHARLES J. HYNES
~ ~y.

· Dear
Pleas@ extend CU.gtody until (iijf 13, 1 /9-;? ..
• I

· If you have any furth~r questions, plea~e fe~l !r~e to ~ll

m£i at (718)~·

Sincerely,

qt'k,,,t,_
../~
Richard I Safianov ·
Deputy Director of Op«r~tion.s
RIS/ch

26
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27
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.
,

PERSONAL EXPENSE. . ~ ~-- c;

JJ)~?'#l;~-&1~-;;;:-19/J P&yec
'
DISTRICTATIORNEY
- KINGS COUNTY
Bareta M Dirisio:i A.dd.reu

PA.RT!CU!.A!Ul
Car
Fara Expenao
Auto I ·Tel.
Supper Trl!IVl!ll
Expena·t Mh:;c.
s.4on~y
Mo. Day ..
:

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C.JlA.Nt>TOTAL ~of t
riY;
I hereby c:utifr that the ah-on account of c.x:pcnditure1 u a t:r-ac e.nd c:o:-rec:t stuernent of cfuburaemcnta ~tut.Uy mi.de by me; thr.t. the
n.ticc for sup~r money il:lc:luded ill thi1 s.ecount "llrl.l for tcrYicc1 required a.!ter rc,rub.r bu,inen houri IUld 0uthori.nd by my au~nu:or;
tha.t the c::xpcnditurri of the 11.t>ovcsum, "-'trt necctary in the performance o! my ,offic:iLIciry datics; and {urthcr c-erti!y t.hl.t :l-0 pa.rt
eof h.u beco ~id to me cxc:cpt iu &t.ttcd thereon, 11.:idthlt the bib.nee su 1ho'Kll thcreill ii i.etiall1 due me. . ·

'lWVE.D JBY
28
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PERSONAL.EXPENSE

DISTRICT AITORNEY
- KINGS COUKTY
Bare.11.nor DiTUi.oo
J7o-r ~ rJ.Ub tc:1"Tl1lld f/U f fl,[10 CDI I

I Clir
I Auto
I
Supper Tr11ve(
ft A _it T I C U L A E! ! Far• Expenae Tel.
Exp~na< 1.11.c.
Money
Mo. Day

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.CJlA.NI> TOTAL
' .- ~OfiiYJ
ct:rtif,- th11 the a.bove account of e..x:pcnditure, Ls a t:n:ic and correct at.a.tcroc:nt of duburaemeou
I hcrtb,- ~tua.Ilr i:u.dc b1 'i:oc; thu. the
t!l this &eco•.mt ,n.1 !or u:rvicu n,Quired ll.fter reculu buli0u, houra a.nci c.uthorired b1 er auixn-uor;
'R'Ulc:c for supper money ~duded
th2.t the cxpendi1urc1 of the 11.b-ovcsum, 'llrcrc neccuLry in the ixr!orm1.ncc of my,offic:ia.l city datie1; c.nd further c-crtif1 tha.l
·cd ha., l>ccn ~id to me except .u ,utcd thereon, a.nd thr.t the ba.1,ncc ;..s ;.howt1 therein is ectiall,- due cc. ·
put =
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.
D18TR ICT ATTOR.N EY OF K rNO S C0VNTv
MUNICIPAL 6UILOINO

~~
8RoOKLYN, N.Y.11201--3745
(715)&02--2000
i.•
~
GH,ARLES J. HVNES
~ ~y. .

?lease ~rtend CU~tody

I . .
If you hava any further feel free to C4ll
giQ at (718) s'r~'
Sincerely,

~~-J~
Richard I Safianow ·
Deputy Dir~ctor o~ ~rations
RIS/i:h

31
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'.h:-·ERSONAL
EXPENSE

D1STR10: ATTORNfY - KINGS

Barei.12 or Diruioo
COUJ-,."TY
,,
/1"'------:;-'-----:A&;-:;-:dr;:-:-~:-:-,---------

,. OT ~ dub rr:rttd Cl I .Uoc.ce t

li"A.RTICULAi!tS
Car
Farw
Auto
Expenga Tc!.
I
Supp
Money
e·r Tra v II I
Exp•na( Mlac.
Mo. Day

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I bcrcbr etrtifr that the t.bove account of e.icpendituru Lt II tna e.nd correct aurement of clliburacmenta ~tua.ll.r cadc by me: thll. the
innc:c for aup?(r money i.ncludcd i.n thi, 1.c:c:ount 'inl !or acl'Yicc, rcQuired a.!tcr rcculu bu,iocu hour, IU!d lluthorind by my 11upen-uor:
thu the c::q,cnditurc1 of the 1.bove sum, were neceua.ry in the -pcr!orm1.ncc of my•offic:ia.l city datic:1; r:.od {urther c;-;:,1..ify
~t r.c pH!
Uld lhll the b1.]1nct 1U ,hoWll therein U t.etUR.IJ)" due ZI:IC.

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p,tid to l:llC 7Cept AJ IUtCd acreon,

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PERSONAL EXPENSE -~-0._~_ ~
19
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11.tJ1s/-,;3erc
{_KF&ycc
1/}
DISTRICTATTORNEY
- }CINGS COUKTI
Add.rc:u
Jro-r a:rrtfXDtll d U.b rr:rtt d tJU f 9l.J.oCDII t
.......... r
C er Auto Supper Travel.
P'A.a.TICULAl:1.5 Fara Expanco Tai.
l,(onoy Exp11naC:: Ml~c.
Mo.• Day
i
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I herebr etrtifr lh&t t~c &l>ovc fl.cco1;1ntof e:.,::pcndituru !J •. t:rge an~ correct @U.ternent of. cl!bcr,c::ic:it: r.ct.u.llr. m.1.deby me; thi.!. the
;.nee for ntp~r r:ooney included 1.0thu li.cc:ount ~, for 1en-1ce1 required i.ftcr rer,i!u burnieu hour, IUld authonnd by m:r 11u~n-uor;
thr.t the c.:q,cnditurc1 of the ai>ovc aum, were neceu1ry in the perfonn11.ncc of my,officia.1 city datiel'; 11.nd {urthcr ~rt.Hy thl.l ·.o-opa.rt·
of h.t., b<:cD~id ·to me except u au ted thereon, .G.Ddthat the bdJ.ncc 1U ,ho'll<"tl therein u 11.ctut.lly due me. '

-------------9 35
a.ovrn BY
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36
 ·· DI STRICT A TTOfUlEY OF K rNQ S CouNTy
MUNICIPAL BUILDING
6-ROOKLYN, N.Y. 11201--l745
(i1B) 002--2000

attn_: ~wl[(7o9~J<;
~ar Sir/Madam:
until __..3,:-.-.;/
~a...,.:-;(--,--9_!........,.
_4

I /, . I

If you have any furth~r quaGtion~, pl@ame ~e@l fre~ t.o el?.ll

Sinc4!traly,

/fk-l_0~
Richard I Safiano~
Deputy Dir~ctor of Oper~tions
RIS/sh

I.

37
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PERSONALEXPENSE

DISTRICT ATIORNEY- KINGS COUhTI

Barei.u ~ Dirilioo Md.rc:u

Car Auto Supper Tr.::vwl

i"A.itilCULAiUii Fare Exp11nse Tel.
ExpenG( l.lh,c.
Money
Mo. Day
;

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1 bcreb1 cmif1 th&! the above account of cx:pcndit1.1re1 u a tnic 11.ndcorrect autcment of cfuburcemenu t.et1.1s.I11:c:udc by me; thtt. the
W11.ncc!or ,upper money included in this &cco1.1nt ·wu !or 1crYicc1 required 11.!tcr rci;-ulu bu,ioeu houri IU!d authori:ed by my s1.1~n-uor;
thtt the o:pcnditurcs of the above ,urn, '7crc ziecc,ury in the !)Cr!orma.ncc o( my ,officitl city deities; 1.0d !urther r:i:nify tiut no put
'.e'>f hu bf:ca ·P',id to me except 1/.J auted thereon, 1.nd thr.t the bi:.b.ncc u ihoW1l therein u·c.ctu.a.lly due CH'.,

3 ..2- ,9 9r
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PR.DY.EDl!Y 38
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'
DISTR}CT ATTORNEY OF KrNOS C0Vt-rrY
MUNICIPAL BUILDING
8-ROOKLYN, N.Y.11201--374'5
(71B) &02-2000
(
!•

~LES J. HYNES
l:>tllmwcT
~y .

·-;;··-.
~ar Sir/~ada~:
Pleasa artend

If you have any further

CUmtody

questions,
·. ,until

plea~@ feel
3£71;2
J. ')
free
V
..
to et:.11
...
me at (7lS}r

Sincerely,

qt'Ll,./~
Richard I Safianow
Dep~ty Director· of OIXiratio~ ·.
R.IS/&h

1·

40
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D1STRlCT
AUORNTI
- RINGS CO~UN::..:..:..:rrY:...:..------
. Bara.i;i OJ" Di-ruio0 Addrcu
F e:tr ~ flub r:u-Hd fU I.Uow11I
.. ,...car· .. .Auto .. ..-:·---- Supper! Tr11v111_
Fara Expen1111 :Tor;· Money. Expeni:o Mli:c.

·3i SlJ -lL,_J

I hereby cmHr thlt the tb-on ~~~~unt of expenditure, ls II t:r"llc&ndcorrect suternent of cfuburtcmcnu ututlly 1:1adc by r::c: thl! the
:rR1.nec £or i:uppi:r monc:1mt:luded m thia Account wu !or service, required r.!ter te('llu· ·bu,ineu hour, a.nd 11uthorind by m:r aupcn-isor:
:1 tha. t the cx-pcndituru of the &boYt ,um, ,..,re tieccuiry in the i,er!ormincc o! my ,ofiici11.Icit)' dt:1tie1: 1uid !urthcr eert.i!;r th.It Z)C pa.rt
:reof hu becc ~id to me except u su.tcd thereon, t.nd thr.t the b&lanec u 1how-i:itherein is_cct~llr due ttlc.

~--------------9
Paov:ED BY

BURE.ZillCHIEF 42
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. 'FOR ___ __;______________ u..v~ ~\jk '-...--''--..../V 'v\l '::'\A l'M..J.\ NP
~~~~~~Wii®@~
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PERSONALEXPENSE

_ DI STIUCT ATIORNEY - }CINGS COUNTY

Bares.a or Diriiioll Addrcu
P'or ~ tl ul,r.rrN d e, I.Uow• t

Car Auto Supper Tr12vlill

i'Jd'tTICt.TLAJtS F11re Expen11e Ted. Money Explilncd' Mllic.
Mo. Day

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 ..,-
,

DISTRICT ATTORNEY OF K rNO S C0vNTy

MUNICIPAL BUILDING
BAOOKLYN, N.Y.112'Q1..,'j745
(71B f &02-2000

~LES J. H"YNES
~ ~y.

Dear Sir/Madam:
Pl~ase extend custooy N· .• til ,.4,,i,
ir
l m, , 11y . I •

If you have any furth~r questions, pleame fe~l fre~ ta call

m@ at (718_

Sinceraly:

cf'~.,.#~
Richard I Safianow .
Deputy Dir~ctor of Op-eratioru
RIS/s:h

.----.·

45
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DISTR!CT.ATTORNrY
- KINGS COUNTY
.Bwc.i.g or Diriti-oo Mcl.reu
ji' M' ~ tJ!ubrz:rndtiU (~OCDII I

ri'tdtTiCOLAil.S
Car Auto
Sopp"! Tmol.
Fare Exp11n11111 :Tel. Money Expen1111 Mll:c.
Mo. Day

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CJtAMD TOT AL ~O/t,-yJ
I

l berebr Ctrtifr th;.t the a.hove account cf upcnditure, is II tnie tnd correct euternent of disburoemenu ~tutlly f.llldc b)' \:le: thr.~ the
~t1ce for i:upper money i.ilcluded in this 1.ccount wu !or aervicc1 required a.fter reiruli:.r bu,iceu houri end outhori:ed by i:::iy 11upen-uor:
1d thi.t the c:rpcnditurc1 of the &.bovc 1um1· ~ere tleceiury in the per!orrnance cf my ,official city dt:ties i and further ~rtif1 t.hAt n.o put
uecf hu btcn i)Lid to me except u cu tcd thereon, uid thlt the !ab.nee t.l ,how-tl therein is 0.eually due me.
47
:.t:e___ g~
3=-./_-_3=....;;;0_/\_.yr;/9
 (
(

RECEIPT FOR APAATMENT/RE.AL ESTATE

I, ,, have received ~rom the Office

of .the Kings_,f6unty Dis ict Attorney; a check (I /cf .'.2.--.3 )
amount of $cx,,(trD ·ob. his check is payable t
and is for the payment of an apartment/real estate fee for a
apartment located for me by the District Attorney's Office.

If the check is not payable to me, I will forward it the

i
~he proper party, and certi~y/that it will belrsed for the purpose
intended. oo Z~(-J.t1CroF A1--T/rfe-t#~
Cc~
Signature of·Witness: . " :tz\
Check r~cei ved from:
Date: ,5
M
p/ ,c;;e
X l, 1A..=
...
_

48
 RECEIPT FOR APARTMEN'!'/RE.ALESTATE

I,· ~-' have received from the Office

of the Kings_~ ty D.1 trfcf. ttorney; a check(#
amount of $ ·I 05"'0 ·0 o. This check is payable to
and is for the payment of an apartment/real estate fe
apartment located for me by the District Attorney's Office.

If the check is not payable to me, I will fon.iard it the

the proper party, and certify that it will be ~fed for the purpose
intended. OtJ ~1{r1.Lr oF; y:>'ICT
/yCT/tfz.-111C:!lfSr::
signature of Witness: ~~
,,,---lffl;U_,t:;,
Check received from: .4
//):J~&-,
\
~ j

Date:3 11//1Z

49
 -,.,..., ____
.,.__..,...______
.,..,--------
___
_.;;;C..----(..,,,' r ,_.. C.:,...

(_,.
.

DISTRICT·A'ITOfU{E'Y
- ONGS CbuNTY
Bare£c or DiTisiori Address
l'or a:mom'tb ~i.abrz:N1ed
,u l&!lowu

Car Auto Supper Travel

PAltTICULA.RS Fare Exp&1n11e ·Tel.
Money Expenae Mis
Mo. Day /Y

./};

,
• ..·

II··\.I '--- .
..~_:.j :..~~-:::/ ! I
;_ ,.......:-.. ···---.----~--·
~-

I I
c:at.AND TOT AL ///J(),(/0
J bereb)' etttif,- thr.t the above 11.CCOUllt of e.xpcnditutel U r1 t:rlle i.nd correct eU temcnt Of cfuhuncmctltl t.etUt!I)' cudc by mt i thlt. the
rJlciw&.~ec for supper moM,- lllcluded in this r.eeount wa.a for aen-ieca required alter rerulu b1aincaa houra and authorind by my supervuo:;
:.nd that the expenditures of the r.bove sums ,rerc ~cec1ury in the ;,cr!orm,nce of my ,officia.l city duties; 1.1:id !urthcr c:crtif.r tmt no put
~rco{ h.t.1 beeii ~id to me c:.i::ecptu cutcd thereon, 1uid thlt the· b1.l1ncc u ahoW'?l therein is t.ct1al!y due me.

o. _____________ _._9

A.P.Pl?.OVEDBY

BUREAU CHIEF DEPVTYDISTRICTATTORNEY

• I

FIS 18 - Rev. 5/92

··--·
...-... .-.u,vurn -n~u1r.t:1U··.t.O-i:::>t! ·n.Kr on US!tvery
NAME IBALAl\lri::: 1c:,.,. ,..
50(If Probablo Cost statement
PROBABLE COST CHARGE PLUS 25%)
nr ..
has:been given shipper ·the
·'

ADDRESS
 '•

Xo~fl, dtl[v,rti t:,-yr-/4:::....:::=:s:::::::::::....:.....:::::....L_-=:::'.....-:;:---====r

E f r--ut u.r • ot 1.:'f t.r. t1 t 1~,:..,c~=..:=-~-.,,,=:;.:....i,.,..,_..=.,""""-'-="-------.

ccc rn.. Dlr<c-t...or

r ,;1 < J-....)J,.

51
 (··

.•

cc1 f7J.. Dfr,c-t..or

r,1, D.l..

52
 /
(

PERSONALEXPENSE
A II.
}2~,41
DISTRlCT
AUQRNEY
- KINGS COUNTY
!la.res a or Dimioo

Mo. Day
P A ~
.
T 1. C V L A
.
_aS
C'1r
FIHCI
Auto
Expfins:ci :Tc.I.
s,,,.,1
IJ!onoy
Tmol
Expanui'
.
Mite.

(1/ Is7o/5<~
- #- /; 7 7xi 7.
I , 11 )/)
'
/K /-/ ~-~ue/-1
l$ r·
__
----
f-!-A?/&€2_ I

!.A)'\ //.// ],,~

/
/4-("
,
77.-kvr.
--~~·. ·c~/V-
Al I i I
/2;;_
J/jl/&IJ{_ MoA·"Jc--:-1 =jj!/;r&.~/~)
i,1·"
)/71)~'- ,J / -~;Y+;p//- 'l!/ .
- _/

t/ 14/'l~l?Z ~/g'-tJt),/25{ r);;1M 71)1~

/')'
"' ~I CfL)
I /·-
/ /~/
,

I
r--·----~- r-;_ ...
,.-.r-...
·-··-.~
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.,
\ \'i·'··: -· ·····-· ......i I
fl.1 ( ' . "'.-.
-. ·11''
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.1.:'\:-5-:,·-:1 c:oc...\,- ..
----..___,_ / / '\ ' J
hll IA) ee:KDe-G/.{)£ l//416 1-!t~lc;</
1; /I
' '

~OTOTAL ;f~tf -OiJ

I

~nee
l

~"o/ hu

"tt
~'r
hcuby ctrtif1 that the &bovt account of expenditures u a tnic and correct 1tueroent of d.ubunemenu
for i;up~r monc,- i?lc:ludcd i.ti thi1 ac:c:ount \;rl.l !or Gcr-YicesreQuired dtcr r-cin,ilr.i-bu,ineu
id thll the cxperiditurc1 of the i:.bon ium, 'lircre ticcc,nry

Lf
,,.;d to"" ='<Pl ., m1<d thmon, ••d thu

t (e 1s, 1i .
bd,ri" ~ oho= thmU> U tht d0< m~

53
u:tiall.r 1:Mdc by :ic; thtt the·._
houri ~d auttiorind l;,y z:iy r.u~n-uor;
in the f>Crforrntncc of my ,offic:i1d city duties; &Dd furl.her c:-ertifytlut ~ put
,

------==-------
.,,.,,11,

..) · 7 ~ 8il:;n.tnm r-.

P.Pl?.OVE.DBY_j1 ..r---.._ _,,- I I I ~\
--- .. /.

,,,,...
(

DtBTRlCT A~EY OF KrNOS COUN'TY

MUNICIPAL BUILDING
8-ROOKLYN; N. Y. 11201-.37.(5
(71tl) 802-2000

~LES J. HYNES
C>dtTNcT~y .

~:ar Sir/Madam:
Please extend· Cumtody No. . until
~
4,l 4/177/
V I
I! you hav@ any further questions, ple..!HHi feel free to e.all
. .
ee at (7-18 ).· ·

Sincerely,

ti'~ ../~
Richard I Safianov
Deputy Director of Op-erationm
RlS/ttb

54
 .........
i,,

'
'•

x,:1,, d<liv,uJ ry, S~

[ f 0,-t t \J..f C O[ l( [ t..J\ t t t I a -~~ _~,,~
o: t , 1 '-/ r/ Ou 1 f<'

CCI f7}. D!r(c-t.or

,,, < DJ..

55
 r··. (
,--
I
I \
\.

'DISTRICTAUORNEY- !ZINGS COUl\"TY

Barcu or Dimioc Add.res,
F o-r ~ iii.abr:::rH d eu I ollo u,& t

Car Auto SuppGr Tr&VGI

~AR.Tl CUL.A.a£ F11rG Exponce Tel. Expen1:cf Mli.c.
Money
Mo. Day

t:.~5Jf}ff:P
/.K/1 r'~t-f r-:;/f
'

[t.:Y 'rr_,f+A/?t/c/e2__ I

/;r)~ /
/-7{
,
rlk-ml"~ ~~

Al I ii
jlflw;{_ Mo,,,, /-;wt, 77-~/
1::::;---1 er~/')
i/t~J
....,
~_j;{J/
../
. •

~ TI: j//g'.t}ZJ~ 1),1!U'··7 lh/s

/1/)1-r_L
1-
·;,
"' 5o/di)
I
,
/' /~/

\\ I n I " I ·-;,
~i--J---\·-··· ~·---z:::.) n
r:
fi}-1Af)O 1 r.: 1GOit \jl! Ii,.
~,,

,r:::l
· ..
.. , I..... /I q
-::.-.-1 !,
. . :--...,._. - ..........
-l::i.i '?~~.... ~ .
.,;==':""...:./
•
0 .1r::01r
1 ~c
-,. ··-- . J ~...J._) f
:1J!.0Ui'!-Y c "', 1
/)c....)V\ ,.,.-

~
' ' I i / /
hi<- IA) ~K D&G/Li.«'
J//(.)6 JAuct/
JI I I - I

.
;
CJU.Nt> TOT AL /5'oL/-OiJ
I

I hereby etrtify !.hi.t the 1.txin S1c:c:011ntof e.xpcndituru i.J a t:n,c 11.ndcorrect ot.aternent of cllibuncmclltl ~tutll;r cu.de by me; thtt the
~Dee for et!pper mont:r i:ic:h:ded ill thii account 'int !or ocrrices required· dter rcr,ih.r b1aineu houri and r:uthorind by m;r suptn-uor:
d thtt the c:.r:pt:riditurc1 o! the &!xiYe ,um, were Dcccsury in the ;,trfonnr.ncc o{ my ,offic:i11.I city datica; 1znd !urt.her c-erti!y t.Ml :i-o put
:rec! hu been p&id :. me except u su. tcd thci;;· 11.ndt.hu the b11.ltncc u ,ho'R"D therein is 11.ctw.Urdut :ic. .

re lf f3 ,~qo r-·· -._. ,

\ ~~,,,JV
1
}G~rnre
56
\
'.Pi.DYED BY
 . /,
I
/·'
••

LlUIQ t;li YJ:A:, X2YD'.

r_{I\~ l
r'
Cc~/)'
/}
r 1
G~;'
11Lus11-se
to c 'f
tf
b(
c-t At f"1\
Y(

t..b c
r u: ..dvd
r 1.:..t O ( ~cx5 s:o§!Q
[r"" u,, c, • ( u,
r (pr
Of{
Q VA { c..i)
[
4. f UH C .
II ( t l ,. I l O _, u.. C ( [ 0 r l! r a ( l 1 ' Vb i 1 C i.ri C\1J t f O { 0-4/:
Lb L~ a (_1-f- . l f '/ l:i
!\U [,Lot>-< tLl«·d [or lillll,r (or t...bt p-.Lrf. i wt tzu1e( .t:..a />-7/t
/

XO."\ { ((, C c} [ V (f d t,y I --nlt~~~-=---f-l.!=-1\=+::::;=-

I f ru t u.r , o r 't<f t./\ u , 1_ _.Jq.D..L.:J:.1.X.Lffi)bJ.A_q;;..~-~;....,,,,.'+---

CC{ [7},. DJr<C"l...Or

r, 1 < D.l..

57
 DISTBlCT A'ITORNEY- KINGS CO::...:UN=ITY=.-"-------
Burua or Dirisi.oo A&d.re:u

Car Auto Supp or Tr11val

PAR.TJCULAft! Far• Expenu, :Tel.
Money Exp11nacf Mli.c.
Mo. Day
/4,I j S/08 /#~- .
-; J/J#- /j 7 7x~:....._ ,...;,._-----1---t--t--;:--t--+--+---+-
, ,1

.r ,

....., ./

1/ /--/~/
..
0
r ·.•
.• _ ..~ .!
'·· ..\ !
\ ...-...
/
I'
} --:1 ;\:!t'\
\ iTt\ • '\
'_,)r 1..-_.'·' __/ l \ \-.
. . . . .,.J \\ ~
I \l,\'7. .~ __\. .:.:...,~d~~:'-'(>· 11'\'-
I,
~ / 1
• ' • • _.... -~ ~- - if J \ ! ~
\.\ \ ..
:"'·:·...
-··· ..
·'::.:· ..·:·.· S~r \
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·;
_,,,,
_

··7
~ / / ."- ·./ I

1 berebr et:rtif1 that the a.bon Account of expenditures is 11. tnic ud correct cutement of cfubunemenu ~tut.Hy f!:Udc by c:ic; thtt. the
l:::,wuic:efor ,up~r conc1 it:lc:ludcdit! thia account w:.1 for aervic:ea required dter re(',llu lnaineu hour, t;..nd1n1th0ri:adby ci:r 11ui:>cn-uor:

~:•ol hubm ~(~ ''"''' .. 9't"·

•«:•pd ..,""'
,d that the expenditure, of the &boYc uun, were nec:eu1ry in the ~r!ormtnce

,h, ··''"" .. ,ho~

of m:r•offic:itlciry duties i and further c-crtif.rt.lat

""'"'u" llc:t\l.ll.l!y due CJC.

:>0 pa.rt

I ' \) ~~hire

PP.ilOVE.D BY ~- ~ __ ·-_____,=--....,....,,.-~~--
(~v_'f.:.....:;'Jv..:...\
~ CHIEF . Q;J;:PUTY DISTRICT ATTORNEY
58
 (. ERSONAL EXPENSE (

Addrcu

Car Auto Supper Tr11voI

PAaTJCULAlltS Far11 Expans:11 :Toi. Money Expens·e Mlac
Mo. Day

r!/,:,_,~hY~~/0~ ,,
J1
I-..,
('-J/?n/?/ - "/L..
I ~
t,___/

.
/ }77/74/ ,.,,.-,/4" ~ ~L, /} / .--,,,e_CU'..-, IJ//Jr
Y'.
/ - -- / . /_/ - -
. .
'
/
'
I '-.._~-IY .n~ /Y'/¼',,,.- /,,u .J

--r,;;;;:;:-. '\) fl':· \ \ . ,..,,'l

~

. tV
~jW.•,
.. -......,.._ - ~I.I')·~
\I
i:-·,···
I'
)
t'
I

---~-
---lrfl
...~.t
:~~ i:-:---:·--··.
~-~-;=:-:.::'":.1t~
Ch!:t ..:!·, a,, '70''1{)
I
I\,.
••-•
fl(""\l
• -
1 :'\,!"T

\..t~
-

~r., TOTAL JJJ/(JDrOl

l herebr Ct1"tif1 that the e.bove r.cc:ount cf expenditures iJ II tr-cc and correct ,utement cf cllibuncmcntt tetutll)' m:dc b)' ~c: t.htt the
Sow:.nc:e for 11upper mo!'le1 mduded ifl this i:ccount 'in1 for aervic:e, rcQuired 11.fter reirulu bu,incu hour, ~d &uthorind by l:l)' ,up-ervi.cor:
nd thi t the expenditure, of the 11.bovcsum, were !lec:euiry in the p-er!ormi:.ncc of my ,offic:ir.l city duties; 11.nd!urther ~rt.Hr t.lu.t no pa.rt
:'<of h.u b«o •d'to m, ''"'"' <, ,u•:d ~"'''· aod ,"" ,h, b,1,n« u ,h, ... thmio U;~•· .

l'.!'IWVE!l BY

BUREAJJCF..IEF
59
_, z ~.\ft'/=""
\ DEPUTY DISTRICT ATTORNEY
 RECEIPT FOR HONEY REC~!VEQ

..This is to certify that I I f}l.-1227°.IJJ

eA--SG t!al?L
received from the·Kings County Dis-trict Attorney's Office the

amount Of $~@./,e; t to be USed for t;.he purpose Of ,//J11l~·~~s

Signature:X~_;, ~
Received ,:om: C~ ~~
=
.
7 ;23( ·?!5 . ·
// ;> /

Date:

60
 (

3630

~~~·~12..
_[)ATE-.

·.$· ;-lj -;;;:-b.·.

-~·:
·. '~-·~ ..., ..r ....w-•
,' I• • _..":,; - --.. • -~-

.·.·

61
 DISTRICT ATTORNEY OF KINGS COUNTY
I
MUNICIPAL BUILDING !.
BROOKLYN, N.'Y.11201-3745

~i~ (718) B02-2000

~
CHARLES J. HYNES
DISTRICT ATTORNEY

TERMINATION OF VOLUNTARYCUSTODY om:,y

I, ,/JJ"1l}L)Y)e,/Jx.-({},lfr,
presently under voluntary custody of

the Office of the Kings County District Attorney, do voluntarily

terminate present custody effective al/; /Y9~

J9!?f<;L..
L have accepted an apartment provided by the District Att~rney's

Office for me ( and my family, also.). This fulfills and

terminates the obligation to me by this Office.

~c-&>
= Signature of Witness
~
Lj,-2-3-q 5<
• Date

cc: WPR Director

Case A.D.A.

62
-·
 ...
,,._
(
(

DISTRICT ATIORNEY OF KINGS COUNTY

MUNICIPAL BUILDING

~~
BROOKLYN. N.Y. mWt-3745
(718) 802-2000

J;§Ib /

CHARLES J. HYNES · .,
~
OISTP.IG'T
oa~.,, ~(_
7
r/,
7
/'t })/.
.. .
I

Please close custody

If you need any further informatfon,
(718 •,1,.~~~- ti

Sincerelye

,,fl~_/.;/"~
Richard I. Safianow
Deputy Director of Operations
RIS/sh

63
 (t·-··· ..
\.. .-:·
.r--

DISTRICT ATTORNEY OF KINGS COUNTY

MUNICIPAL BUILDING
BROOKLYN, N.Y. 11201
(71 8) 250-2000

CHARLES J. HYNES
DlSTRiCT ATTORNEY

I
9--"--Y_
Date.____,_1/_,__,_/4-+-:l/
,___,_/
I

To: Larry Itzkowitz, Fiscal Manager

From:· Michael Wishner, Witness Relocation Program

Subject: Placing witness(s) into a family center

Custody #_ _..:.,;

.·~

64
 ;

.,,.,
(
. .~

r, illLJrie f'\!\ ea5e 1 Cor-+ ~

h t v « r 11 ! v, i .,.,.tro-z. u. 11 o t tic e & t t.b,
J:{T\vt C..Cl.:..it'j P'rtrJ.C"'t J...ttorricy t..bt ~\:...i of #aOLLo~ vh[c:..h r•praii:r.t,
fl

<~
r l l A I I O \" U'i C l
[1 U> !,.c tu<d
[or
[or
1! 'f a
••t!,
t I l f
!\
't(b f J g i.ri
u,,
C"\LJt O<d)' Ci f. t..b 1 I O f { f.0-4
.r--<r <>a at. i//:i.7/Dt' U 51
, t"°b.14
fl/?

Xo~f~t dtl{vtraj f;,y1__ 1/l)..---:r;...i...:,:::.......,'----~'\"=~==::---

! f r'--1 t u.r Cl O[ 'i( f. t.t·-.et E 1_:_~0lki~·.:e.::..:.~~'---'-1-=----'--<--'..l.~,-----

CC I i7 ). () l r« c:-t..o r
r, r • >-.::>;.,.

65
 ~...-~~~~~~~,.,-;rlirJ~·~-,.~~ 1l1,1W!·;n¼$~~~sm9,,~~....._~'1Jill'V~\d~~_z-~~~~~~~~#4~U.i).~~-i ..'
1
u . ~ 3658 ~

,-.....A 0 9, 1-2
\, ~ 2102a
e,-12
L---\L <-,''

$:~r""""

fil='::1

66
M'
FOR_____ =-:-:---------=:;:::_;;;;;;

..
\
' -~ .·

,~ - \ ...
 ,JT-lBR.SONAL
EXPENSE
'·

. 01
DISTRlCT AUORNEY- KINGScom.TI
Bnre:ac er Dimioo A.dd..-c:u

C11r Auto Supper! Travel .

ll'AltTICULARS F11re Expena•
·T.,f.
Money Expenatl' Mlac
Mo. Day
/I./
··~ ASTo!S . . ,
-:-;,A)/}-f=/-.//77!( 7.J '.

/K/4 C/Jc:-~6/1
[A'
'\ -----
·r~H/V2/ue2.__
/AJ///'{J,,-~ /:1.( rf.lc-?Yf
/ I
A1-:-..cf' cjgh-
/

,,J I ii
"71) t~ !ffOA )<S-f ~ 7/~/o:zcJsl)
,
i/'v77 ),::_-::S.s.'.J./~-i:rA"14/
...... ../

J4I) u l 7J: .,f/ttJZJM

---;J
/;'
1),1/M 7 IJ1A
'" . tJLD
5>?
/'~ 1- /~/
-

--~
~\:. n, r·,
- r-..: - ~- . __: . .\ I I
'\
flt( ~nn"1S\ ,,.....,,..r.~ t 1·1
1\:-1! 1_1-....51lVl.'/V
/ f.l
(di ~ldji __~ . !)
~ __ ,, ,, ' " ,.. r
,->pp_x:.-,
-• •~~" 7r
•
AMOUNT ..- .. > C) e
.,7 0u 1~
r
~ / / ·, I I
H}/l u)er£KD~/IJA' )//(_)6 .dr//f)/
I
/ //

OJt.A.NO TOTAL J5of .od

I

I hereby. etrtify that the a.hove r.c:c:ount of c,;pcnditure1 is a true and correct 1t.uemcnt of clliburacmenu &.ct1U.llycudc by me; th1 ~ the
o-wt.ncc for cup?f;r mone1 inc:Luded in thia account wu for ,er-vice, required dter rerul1Lr bu,incu houri c.nd r.uthorind by my aup(!'YUOT;
d ths.t the cxpcriditure1 of the a.hove 1t2m, were ticccuLry in the Pf:T{orm,ncc of my ,offic:ic.lcity datiea; fl.nd further certify UU.t ra.oput
crto! hu ~en p.&id to me except u cuted thereon, uid thu the br.11.ncc iu ,hown therein iJ ac:tw..llr dac s:ic..

Y-):/- C/7 JP
'.PR.OV.EDEY

B™~.~ DEPUTYDISTRICTATTORNEY
67
 ,;··
( (
'

I DISTRICT ATTORNEY
MUNICIPAL
OF KINGS COUNTY
BUILDING
BROOKLYN, N.Y. 11201
(71 8) 250-2000

RELOCATION AGREEMENT AND TERMS:-

CHARLES J. HYNES
DISTRICT ATTORNEY

I, Althemease Cort, presently in voluntary cu~tody with the

Kings County District Attorney's Office Relocation Program
understand and agree to the following:
of my choice located at

I understand that the Kings County District Attorney's Office

will be providing me with one month's rent ($1050.00); one month's
security fee ($1050.00); and reaitor's fee ($1050.00); totaling;
$3,150. oo to obtain this apartment. The Kings county District
Attorney's Office will also be assisting me by paying for the
rental of a UHaul.
..
I have applied for Section 8 housing and I ,am waiting for
approval to o·btain a Section 8 certificate. I understand that the
Kings County District Attorney's Office will be paying $1050.00 in
rent for up to six months while my Section 8. At the end of the
six month period this office will review your current Section*
status. If Section 8 is denied, this office will not be
responsible for the rent.

I will not disclose the location where I am moving to nor

return to-or revisit the neighborhood where I was moved from or
where the incident occurred.

I will not conduct myself in any manner that will jeopardize

my safety or anyone else's safety.
!

No other promise or commitments have been made to me other

than what is contained in this agreement.

Failure to abide by this agreement will terminate all

responsibilities of-the Kings County District Attorney's Office.

This will fulfill and terminate the obligation to me by the

0. __
Kings County District Attorney's~

Signature

Date
a~O~
Office.

.3 l I
~
~ 7 l ?i
~

68
 ..

·:.·,--·:·:•··ctoN:i,;,:
I'rJ"E'R".:
, . ·- .....
:·.,,:
·,;:,
.:,l'~.'!.1!\''i§~s:o:itfoiin,EJ
,.~ ,_ .. , .-u, ... "'""' •.•• v
Suppiy
·~
,~·,,;.,:
-,":
·,,'P/(CK:ING'.....;,
,! 'Number: •Pcr1E:ach I E>::tonslonr !'Number• Per Each' 1Extcnsl
BARREL;dish,pack,drurri<etcetera ~-·:.-':-). ;, :-....... /$_ . ". 1.::..·....'.:I.· .,.. ·1r>.::;,·,.
BOXES;'no(over'.5"
cubic feet . f
f½''<f~.t/Ji:,(~Jrfi,~;:;;··;;f":.J.;·
CARTONS:''l:.liii'tli~ii' ;::,;;;'.;;
;,'.i:i.''.',) ;:::,~;-:;;,;;;·,,;·.;Ii.;
.. ·:·;.:·;;;1:/;;.:_:::;:; :;,:.';:":,:,,.,>:
..,·:,,r1½·CUb1CiT :;~~·:-..·::1f:_\.:?
·.1.\::r~=;
~ (.~·:,.:~;:.~::d -.~<:·/;:·-·
...~ f,-=~~=~
~-::-:=~:~.-J,·.- r.:'.?r•,
1;_1_1.1_':~ ". ~->:·:'{~:;
·,·'.'.:;:·"::~·~:::

Mattyes_r~1~gJrJ~xceeoin9:54"::x·-7s'f_l.iH:::,:
,.-,:~
..-:::·:··-~
.,· :• /~·;!i!:• .,::·. .; --~::~_/·t;:·:.:
''\'~t.::·/: ;::.,::·:,:·:/_:~'.;~
..·u .. -,.': :_; :r:·.-/
...
:..~·:: .,,..,,. ··-1··
I

MATT8/:?.f9.C?YER,(P.l_as'iic·or,papei},;
"''" !,'.,..,,,:-. I'"'·'
·,;:.,.,:..,.. ' ·,·.,,. ,.... ·+.',' ,C" :,, ;,,,, ,_..... ; .• '"/:·'. .,:;;'·::.11·".::.'.''.·,:,:
""''.:\ ,::;,.,,,::-.-,::"r ·,,,_
'. . -
CR.1>;r:es N~!=R,s·;:.·:-;
_IIND.:~C?/'!T .·-:c,.,-
..._.• _:;'·,, ,.,,,.,••,,:-,.;,. .,:· ...; • .,.,; .. ,:,, .,._,;·....,._,,..,,_,,;·., .· ,.... ;,;,!··.:: · ..::.,, ..,-;;;.:
.··.,:
. CRAif~$}ANR:9.9.~J:~l,f~-H~.R~J.Mfo.iffiUh,'~~·ng;!~
·..:::~:
..:.:~'.;';)· ~ .- :····r ·;: ,: ,. ;.i":.::;; ......, ~-
1
!: l·::·.~::~;::,·
~;i:·!.~.'"(;~·:i: ;. :,;/;:-;.-;;·;, ~~:.·~ ·:;: :ir:· ::~,it·.,~.. ·..... ;;,: ·.!- .

': ~ ~\ .,.,:·

. , ATTE!'ITION OF,

'Rec'd
:.,.
to_isiorase '_·---'-~---"""'·
('."'.lrahOUS(!):·
By, · Date____ .Per______ ...,;.__ _
~........ ;;.,....,__ .;..,,..;..,.;...,_ ... .;.....;;.;,,;..,.-;·
... ,...,...,~.;.;.;;.,....i.;.,,.·.;·<:,;W,;,:a;;r,;;•;,;,ho;;.u;;;•;,;•;,;m;•::;n:.;'s;.;S;;;l:;.Sn::;•;,;t;;u;.;r•;;>;;.-

. 0 COPYRIGHT1ssi: ~ILBI~ PRINTING, JNC:,.1290

PKWY.:
MOTOR HAUP;iucie:~~:;~·
ism)
582-8~ . c:UST011ER!S BI;LL & RECW~T; Forn; 252 C.
: ~-' . ·... _,. .. .. .. .. · ·. . (For Customer When Job I• Compiete'd) .

69
 w,,nruli!Vl rl . JSEHOLD GOODS BILL OF LADING __.l!D FREIGH"fi.,BILL
{Fo,__,tamportati!)n Services Performed on an HOl,JRLY BASIS-)
N\'DOTT-11412'

.~~~; :~:!;!~~J~1~\o~~ ·~,c

1
throu9hnu1 this c:cmtr::ict .u ntc.1ntn9 .lf\Y pcnon or corpor.l\loo
~1rir,i~~,bh~o~J,li~
;~~\S~~'fs;it~1n;.,~~~9~~,·~~k~~~~i'~~1:~i~~J~~~~ t~c~U~~~ 0a~}!'n~!~tch~:x;~; ~~~~~{~
1ti!ni~-~~r>~';{;~a~C.:'~~~~;:'
in poucstlon ol the properly unoor tnc contract) agrees to tr,:m~port lo dc.ttin.J.Cion indicJ
below: It t$ n tu.>Uy .:iqrccd. tn.1t cvcrY: iorvJr::e lo bi: pcrfofl~lcd hcrcuoocr sh,1Ube suDJcc_tto .JH con.dltions not prohibHcd by 1.1v.:.whether ptintca or wriH
hcrcln cont.ii c . wc:iucs,n 9 the .:om.Hllo!1.~on bo')Ckhc,cot, wh1eh Mc hereby Jgr~co to Uy Shipper and .1c.c~ptc.d (or nlm1clf o1ndhis .1ss19ns.

FL
Time__ _ TIME RECIJRO -\
.Start ______ ~_AM'---=-----,,--....1
Pt-j1, Cv111,mci hl\h~h

Fini;h -------~{t---,=-u-,-,o-,n-,-, ,..,n-.,-.,,..

11
__

. JOB."HOURS_·---,-.----------
. -TRAVEL TIME::--· ---;:::====--
TOTAL HOURS. ·
#.-· ····:·:...,1. VALUATION - HOURLY BASIS TRANSPORTATION SERVICES -_:HOURLY BASIS CHARGE
UNLESS THE SHIPPER EXPRESSLY RELEASES THE SHIP·
MENT T.O A,.llALU.!, OF 30 CENTS PER POUNO PER ARTICLE, STRAIGHT T_IME
THE CARRIER'S MAXIMUM LIABILITY FOR LOSS fNO _____ Voo{s~~en /-·--.-Hour. ot $ __ per hr,1----+--
DI\MAGE SHALL BE EITHER THE LUMP SUM VALUE 'DE·
CLAR ED OY THE SHIPPER OR S2500, WHICHEVER IS GREATER. 0VERTIME SERVIC~.;;
THE: SHIPMENT WILL MOVE SUOJECT TO THE RULES ANO CON• _____ Von{s)---Men·· _____ Hour, at s___.,er hr+-----l---
OITIONS OF THE CARRIER'S TARIFF. SHIPPER HEREBY RE:•
LEASES THE ENTIRE SHIPMENT TO A VALUE NOT E:XCEE:OJNG TravetTime · · ~Hours at $ __ per hr:

(TO ae: C9MPLi,;.:r;s,P. av PERSON SIGNING BELOW) ••.

. . ' .,/;-.
Valuation (Additional Liability! Charge,
5~ per $100 of declared vaiu!-._·___________ _
NOTICE: ·THE SHIPPER SIGNING THIS CONTRACT.MUST IN: . . . • •· ·,::r· •
SERT IN THE SPACE ABOVE. IN HIS OWN HANOWRlTING.- Other Ch~rgl!s" ;.-··-~
E\THER HIS DECLARATION Of' THE ACTUAL VALUE or-,THE ·
SHIPMENT. OR THE WORDS "30 cents- per. pound per article."
OTHERWISE THE SHIPMENT WILL BE DEEMED RELEASED
TO A LUMP SUM VALUE OF S2500.
Yl'arehou,c Handling ____ ._per_·___ @_____ _
I -~ ..,
Tr;:msitStorage: From____ To ___ _..@______ '_{_i_

SJ.T. Valu.ltion Char9e:{Additional liability)

rS"H'--IPc.;P
..E_R
_____________ ....0.,( .,de.,c.,la.,r,.e"d"'v"'a"'luilc"'""""'=""'"-'-",..._,=.,..:.l,;---=6--.
_,_"'r,~O~A~T~E~-'!:°"'.""-~'""'--S'i\'l"'."'00...,P,.•.r ..s,.10.,0.,0 ;J
CONTAINER
cotnAmens O Loan O Supply I, PACKING UNPACKING
Number l•Pcr E:u:n I Ex:tcn::tcri ! Nombar I Per E::aen Extension l Number' P~r E1eh Extcmlc,n
BARREL, di,h-pack, drum, etcetera , s I s I IS
BOXES, not ovct"5 cubicfcot
over 5 not ever 8 cubic feet ~~
zr
CARTONS: Los, thon 1 ½ cubic foct -1-· c, n
1½ cubic feet >o
z2
3 cµbic feet 0 ,;!
.r-· 4~fcU.bic feel •..1 · ........ ~z
6 C'!bic feet··~·· .,, m
...-:l.~\.. ,. >:;;:,
. 6¼ cubic feet n en
WARO.ROBE CARTON :3
CRIB MATTRESS CARTON
zG)
Mattress ~rton {Not exceeding 54" x 75")
..........
•'

l
Mattrc.-s Carton !Exceeding 54"-x 75")• . ,

MATTRESS COVER (Plast)c or paper) .• '<t,

CRATES ANO CONTAINERS
CRATES··ANO CONTAINERS (Minimum Chg.)
I.
TOTAL TOT_AL S TOTAL $ s
ALL CHARGES TO BE PAIO IN CASH, MONEY ORDER OR CERTIFIED !TOTAL CHARGES CharoeO Preoaid0 c.o.o.O
CHECK BEFORE PROPER'FY IS RELINQUISHED BY CARRIER OR !TOTAL PROBABLE COST CHARGES S
CARRIER SHALL BILL:

NAME
BALANCE DU. ('fs Working Dov,, Credit Extended if Rcq.)
ADDRESS
Prepayment Colle..~e<lBy
CITY t. STATE
BALANCE DUE
ATTENTION pF OEL!VERY A_GKNQ:{/LEDGEMENT:Shipment wo, received in goo<! condition
except ~s herein noted. and sorvicos ordered were perfo.-med. .
x,--,
Carrier agrees to'·1ransport the ll'-l'IIU''1/"'"" Rec'd for Storage ________ Consignee _________ _
shipper subject to the preceding {Warohousol
Signed ---~====r-,:-,.,.,.-,-,-,,,.,.,.,-...,,.,,.,..,.,.,.,....,,,..~----- By 1"'w'.:-:aC:ro"'n"'o::u",-:-•m=•-n•=-,-=s'"1g_n_a.,.tu-,--:.l
Dote---- Por----------
me~.
:OPYFIIGHT MllBINPf\lNilNG,INC.,1,soMOTOR
PKWY., NYmoo 1s1G)
HA\JPPA\JGE, ~-aooo CUSTOMER'S BILL ·&....g..~CEIPT'Form 2s2 c
(For Cus_tolllcr When Job I, Co,:r;:plcto<l)_
70
 71
YC:( ) J 1.J
10-U>J .• ,U JD
1
1 11'l ro
I
-,·::
 r·~.
•.. t

. . ~ . .. . ··.:.-

PERSONAL EXPENSE

!JI STR!CT ATIORNE)'.- KINGS COUHTI

.Bares a or Diritk>c Mdreu

C~r Auto SuppGr Traval

f'AR.TICULARS F11r•·· Expan11fl Tel.
Money Expense' Mice.
Mo. Day
·,:,...
1(1J.s7o5 - > .,·•.
--7 ,A.J/Jf:J.. //7 7XI 7/ '
At( /-l /~t-1 sit
[$ r··~H~vzi/a
e2..... /

/_,,) ;u ),.~· /Zl.(,

r/.-/2:-?Y{~v:_'-r'
/
{~/U-

Al . I ii
j/Jl!&fJ(__ll4oAJc7ri /4;;. -Tlkw /a?t.1,/)
""·
i.,r\//-- ...J /jth,_;;
J ).::..~· I {v
'-"· ./
·'I ' :""
;,/ J//;~,_,{_77:f'lff.OZJ~ (}/f(UJ9/Jt~ di)
(({)</..
f 1/ 1- /~/ , -

~ I

l
~ ~ 1
\it . \I : .\O.QI\ :\
\ ~~ ' \'~~\ 1,-~g
:
\ ~. I\
~-~ """"'
"'-~
..... r,. \...,_
-
cHE.C\Z:fr ·. J \ \};
",-,- /
A'rJ:UUl''
) \.<Qt.Jc>
·,..._,_ i/ I ./
"
fiJll .JA)c::e:KD~/D.u-1/A-16 ~Iii/ 9/y'
7
rr-- (/ ;K'/ q{'-
I

' !
I
I

GJlA..l'(O TOT Al. ;fJ.Oof(Od

I

I bcrcb1 et:rtif,- thlt the c.bovc r.c:c:ount of e.:i:pcnditures !J I tnic 11.ndc:o:rcct eutcmcnt of ditburiemcnu ~tutlly ~de by me: th11. the
r1nc:c for J\lp;>(r mone:r u:ic:ludcd in this a.c:c:ount 'in.I !or .,en-ices requ.ircd 1.ftcr rtt\111.T bu,iocu hours e.nd nuthori:cd by cy auixrvuor;
tha.t the crpcriditurc1 of the above aarn, ,,..err riec:ciary in the ;>(rformr.nc:e of my ,officill.1 city daties i and further ~rti{1 Wt ~ pz.rt
eo! hu ~en pa.id to cc except iU ,u.tcd thereon, s.nd thu thc.baluice72 &.1 ihoWil thcreu:i iJ netuallr due :ic. . .
 .
/

LI CTI n r:;Ji ~ JO 'fD'

. :r' MJ*'2
J:.!r..p C.C1.:.."ityt><rtric-t
~Ye
Attorn,y u,
i
" -,,_, V d fr Jh u' r, (( l C. • f t.l, I
1n.:..nof# 9/1:;QQ vrdc..h raprueritt
'tl r t. J 4 L l O Y LJ\ C I: f Or Iii)' fil n 1 a \r'b !1 o f...ri C\LJ f p f t..b lU Cf (,-f'e.e. , !' ld ll
l I t..o b-c tu , ~
I
&"\!.l! f o r 21 c t ltl ! o r t...ba JH r Xold" Ii ! 51 /,/I H/ u 57I~ I If'.>

)(°' {<l
t!r..itu.rc
d tl [ V HI~
of U!t.JHirirr
~ '-~~(===8-~.J.~::::::::~~~==::;:::===--·
~,&h-e (~~
$ 1YuJ
1
tntar

e:c1 n,i_ Dir«n..or

r:1( ( >--:)J.-

\1

73
 ,:--·•• ...
I
"'· (·
(

/
-

Xo~!a, d«1!vtr~~ ryr

E!r-,ttu..re ot i?:[t..r-,e:11

/
.·/
I

ccr rn, t>inn..or

r:, r ( >...::n.

74
 ;-·.
I
\
• r
\

: . PERSONALEXPENSE
l

DISTRICTATIORNn' - KINGS COUh"Tf

J~o/&1--
PLyec '

Bwc:r.1:1or Diruion Add.re:11

ccr Auto Supper Travel

PARTICULAiil.S Fcre Expe1n;11 Tai.
l,(onay Expenul Ml;c.
Mo. Day

-~1_:~~;;:;Jfif!lllii1~'-,;, '
.-,. :If
/K /-) /--./JuC.
I~ 'r'...ffA/a-·(f e_c_, ,.
.·\ MJ/.
IA)/ /-k r/.--lc-vr
~ ,,c:;J'r~,-/- ~/U-
-/ I

Al I ;/ .

ff/&79{_ 1110A
Jc-:-/h#. 7Jh-&:;.;f
/C-~)
i ,{"-·--
ill .I )c::::SS.'.J / [r7'AI
~~1{v
- /
'

~ /4;),.,LTi: !/lltJZJ~
';.

/),1/'M
"'
71)1A. 5>/(ii_)
I
/ 1- /~/
I

i .,.., ..',-·~
-·-::--.
..q;,,
~
'-----·).:..
..-"'".?\
r'"~
\rrr-- ,, ',('.f.l:9, \h\r...
\~ \ \fl
"(. ',, .. ,2.Jr.
___ ,..rr•·':' .... .: :
I \~ --~ .· ..;.i• \::::5 ~: •.....
- j

1. ]\\ :,.'J.::;r-"
;::--'
<1 . 1 ( .., _,
t ·:i··\ s(~':(.::.: _) ..\ "\
...,.- - \
V
. ::..\' ..·......... ~'\)"\
~
<
)
~ / /. . ' ,

fiJrt IA) ~K I
D~/.Ud'-.i,,:,,()6 c.; I ~.cl1 t/
"i. / I

~O TOTAL J5ot/ -OJ

I
1 hereby etrtify thr.t the al>ove 11c:count of expenditures Ls i t:nic and correct 1u terncnt of d.ubunen:icnu uua.lly ?nAdc b7 Clt; th&t. the
~nee for il.lpp.:r mof'aeyifiduded il:l thi1 ,ccount WJ.1 for acnice, rcQuired after rcrulu b1air.ieu boura e.nd cuthorind by my ;u~n-uor:
d th&t the cx-p;ri~iturc1 of the aboYc ,11~1 were ncccu&ry in the _p-erformancc of my,offici~I city duties; e.od further. c:t:rtif:r thl.t r.o put
:rco! h.u beell p-1.idto me except u au.tee! thereon, aod thtt the bs.lancc u ,ho'ir.l therein is c.ctw.11:r due %Ile.
·}/\ /I . ) . . .,-j .
tr / /(.-l >' - ' ... tQ --'---+~ff--i,'~--------------
·nwv.EDBY
/
..
!
I/. ;·"' . \ ':' z_/,
/'7·'\\! ·.__,,v
I '.. ) . _.-·
.,.....
,
75
(~v1~J
 I, /
··- •• w
,Y-~1.·· -
1-2
to<J028

76
I
E
( . ,. ~
•
: 11r.
M'
.utt,OU(
.,
 ( / \
il'ERSONA.L EXPENSE \
L

1 .. '.-·
1J1L~..:....de.
__ 1$

DlSTRlCT AITORNE'Y
- KINGS COUNTY
Bureu or Dimioo Adcircu
F o-r ~ dub c:::1'N d e11 I allow• :
Car Auto Supp or Tr!IVIII
PJd~.TICUt.A»tS Farit Expencc :Tel.
l,lon11y Expena'• Mis
Mo. Day
"•
C-c_,L<; ( tJ,\1/ $" _'.J.
.,
XZ!'r# /77J~7-~ 7 I
~ 1-1K!4 Qf.".1
£..<:
{:- 1-I
,· ~ .{~ f+-?'.:J,--; &- c-
c1/Cr ,,
l!c.ar,
.61) 7TiJ'2s..., A--u1-7,t.,,...-61r?f.l-':ic.'

/"\

/J '
,/
/Cc.~u~~ /4 ,,ec::<i-)---·
( <~lrk-c.
(i
/in)· ~r.
~

-;;l) 1,1-t (/, VA-V/fb(~ I

·-· ...·: ,;
~I
',.., .. ,. .,,.,. ·-•I _..

/) I

I// I I ~ I
t('

f l.1t1,.) C!_,/:-fc:;c
/(
I -;;;;)...J~\_J_lL~1 Yi
IB-(u l\l i"i {CO.'\
. .... 11\I ("\
i~'li·1I 1. - .. .J.!:, I
.. -·· ... .... ~
·---..-
¥.:n {~"'e.2. - ..--.
·--·,
icci
'-.1i t:-•....,, •••
_:!,. \ . \;.~:;:_.-
I

~ ./
l

·'.\!\l'n!JNT r)\
/I
w·~v
V i
-~
..
lo112 -rt..L-~lf100T1-!
- , of- ·--
•
r1t1Avl I '1 cv?
I
I (

I
I
l' hereby eer-tifr thu the at>ove Account of expenditures !l a tnic a~d correct suternent of d.uburiemenu ~tua.lly msdc by J:!lt_; th11.1. the
for ~upper moncr il:,c:luded in thit e.cc:ount WI.I for "nic:e, re Quired &.!ter re1.wla.r bu1inu1 hour, ll-.fld11.uthori:ed by c:r s:u1>crvu:or;
O'W'Z.tlc:e
d th, t the expenditures of the 1.l>o-rcauttu were iiecesury in the ;,er!orm:inc:e o! my ,offic::ia.lcity datiea i c.nd further t(r:tifr thl.t ~ pa.rt
~reef hu ~en ~id to me ex:ccpt u auted thereon, o.nd thtt the ba.11.ncc ,u 1hPWD therein is e.ct1a.lly due t:IC,

u_..;.....__________ _.9

:.P.R.0V£D 13Y

77 DEPUTYDISTRICTATTORNF.Y
 lfrutu..rd o[ i<[U-.ctt

cc1 ni Dlr(c-t..or
r_, t t DA

78
 :.·. ·--~'-.. ··r·-
·l-'ER.SONAL -EXPENSE !!/;)I ,~£-· . ~
lif-J-r;-
.
...:---.---i
. . .
~A

DISJ].'ICT AITORNEY - KINGS COUNTY

Barez.u or Diri:ioo Aodreu
F'or ~ ,li.,.F,r:::r-,,edtu f o!.low, t

Car Auto Supper Trevel

PA t't.TI CtJLAtl s Fzire Expense Tel.
Money Expeneo Mlec
Mo. Day ·.

~C.S fa,,,/~~
,. /')#
-:::c:z I 7 7j:: c;7 . .. ~ · ~-

A/vi/ ;/ (~i.' l-( ;:-

~-K -(~l-fA1c/CJis'· c__ ..,

Lear,
6-t)777J2,;_s;1:r-u7li-,:-tt:"'71,~~
-
..,,_
'
/-.. ~

/J I ..
.
/Cc;w
•.

uA"77iJG. A- Rd~i-.)1 r::./rk;-e. fi •,

/i,n.l {#</i).J__..:D.
-Ol> &.
Y/1J(.,(° tC//J-r/4-o
i

..
;j; ..... .. ··.j •.

' ..
//
'}

I
I
;/
I /
- i I I
:, -
<,;;:l\
,
....
t\~i.
_/ CA;;.) C!..,J+o-
K ~
))),/' . [\l "'
;

"-/ ......
~~)..---'"'
,-·· ----·~) {. -·'f'-\'0
1 ' ,,1
;_}\; .,.I;
.l ~,-.,,,.,
\\\J t ,~
v.\\).\ ·:=·
-7,,p • ?\
·\:fi~~:~
\ >- '
~

'{r---, ,.:(/ I ('I\ "11 ,_

• \.) /~-;::,_ '.n\'\o/ .. ..

.
C,\"t ... r.\.Y-;:..
· \V
,..~•.r.....
' .
/1
V I
~~ lo~Tf.lv H/OfJT/-1
. of- ·-
..-~n(tC~~ y·..
I <--1c; .. /
I

·.
w'I {JS{J
•,
CltANI> TOTAL -(90

I hereb1 etttif1 th&t tlie 11.l>oveaccount of expenditure, Is a t:na and co:-rec:t 11uternent of ciilburaemeou iu:tua.111 cu.de by me; th1.1_the
~nc:c

Ju.~r
{or ntp~r money included i.D this &.eeount -.ns !or aen-icu required &.{tcr re,rulu b1uioeu houri and 11uthorind by :::i,-,uix:n-uor:
r.nd tha. t the c:xpcnditure1 of the :.bovc :urn, \.ere Dece,u.r-y in the ptrfcrrna.ncc of my ,officill city chitics: ind furl.her eerti!y ~t
t.hertof p.&idto me except U Stilted thereon, Uld th&.t.the br.b.ncc &.s ahown th~rcin U ll.ct~lly due J:lt.
~ put

D;.t_e ) 1--
( IO Cl --,.:...~-,:...'-'-......_:,;::...,_
___ ;....______ _
/J'Pi.DVE.D B½?
r-t J~::=:::=
)~=-=>"'-. _-i _·_'! 79
- ~---l.:(-~~~=-\_)
__ 6_~-ti:-re ____ _
 ·····-·-··r-·- . ,· ......
l. (

· _-/ PERSONAL' EXPENSE

fi<2~1;.:-
-·'n1STRlCT A_TrORNJ:.7-
KINGS COUNTI
Bnruc or Dirision Address
Ii'trr ~ tluor:::rtredea I.Ilou,11 :
Car Auto Supper Travel
Fare Expense ·Tai. Money Expenso Mis
Mo. Day

_.,...- ·. ·.
\ '
( \~ '-,
............
".. .
.......,,,...-- .\ .
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catA.Nt> TOT AL

I hereby ce-rtif:r th& t the Ab-oveaccount of expenditures u a tnie and correct su 1ement of di.cbuncmenu e..c:tually tt.a.de by me i tha.1.the
~nee !or supper monc:r inc:ludcd in thi1 1.ec:ount wi.1 £or acrvicc, required a.her repihtr b1.uine11 houri 11..!ldauthorized by ::iy i.upervuo:;
and that the expenditure·, of the 1.b-ovc,um, were ncee,ury in the performance of :ny ,offidtl city cla ties; li.lld iunhcr eettif;r thl t ~ put
thereof h.;.; ~en p..id to me except AJ sutcd thereon, uid thtt the btltncc u ,howi:: therein is aetia.11:r due ::cc.

Dil~------------.-.9
li.l'Pll.OVED BY
80
BURR.ii.Tl r,-n;:,.:'
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I

.PERSONAL -_EXPENSE

_ DISTR1CT AITORNEY- KINGS co'\Th'T.t'

..
Bure:.c or Dirisio:i
Fo-r ~ du.bc:r:THdt::.1 1'*1.low,t
Car Auto
Tel.
Isupper Tre_.,cl
Fare Expc.n1a Money Expenc·o F.'ils
Mo. Day

CltA.MD TOTAL

I herebr ccrtifr thu the abon Account of c.;:pcnditure, u a tnic end correct su.tement of d.ubunemcnu t.ctutlly mt.de by me; th1.t. the
Ekr..n:.ncc!or supi:,er money inc:ludcd in this account ,;rz.s !or aeniccs required ll.!ter rei:-ulz.r bc,incu houri uid euthorind by m:r au~:,-uo:;
nd th1 t the expenditures of the r.boYC sum, were zicc:eua.ry in the i:,er!onna.ncc of my ,officii:.l city datie, i lltld !11rt.hcr c;ertifr t.l».t ~ pa.rt
:>creo! hu ~en p!.id to me c::.ccpt .u iU ted thereon, Uld th, t the bz.b.nc:cu ahowti thcrei:i u le-tu.ally due :ic.

ll ~v 19 en
84
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1
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1--:-.:..:.:..:-..:-_---'-:::~_-_-_-_-:-...:.-~---I- i
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CHASE Tho Chase Manhattan Bank J;
; 0 1LllJ . 177 MonjagueStreet .. ·i
' .,
1;
i
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·;
.:,:·_-:_i-;... -:: '-·~~__;_,.,.,...,---.,,..,,..:~~~~.,i;~~~-. :. '.
I
. :°\

85
~--
~ ~
 (~ERSONAL EXPENSE
·-.. .

DISTB,!CTA'ITORNEY
- KINGS COUNTY
Ba.reui or Dirick>o Md.re:u
/i' or ~ Iiu.E,r:t:rff d &11 · fell.ow a:

, Car Auto Supper Travel

·· Fare Expenae ·Tel. Mis
Mo. Day Mon11y ExpenG·e

I I I
CJl.A.ND TOT A.L ·I [7.S-O-cic
1 hereb;r etr1if1 thu the r.l>ove 1.ccount of expenditures u a tree and correct gUtement of cfubur1cnicnt1 11.ctut.llyc:ade by l:le; th1t_ the
lllawu:ic:e !or supper nioner included in this &c:c:ountwi.1 !or cervic:c, required i:Jtcr rce;ulu ·bu,ineu houri a.nd authori:ed by :or ;upcn-u:or;
1.nd th:t t the expenditure, of the above aum, were neccuz.ry in the ~r!ormanc:c of my ,offici1tl city duties; nnd further ~ttH.r thu nc ptrt
thereof hu ~co ~id to me c:x:ccp u su tcd thereon, e.nd thll the b:tb.ncc u &ho'llnl therein is l:.et\Ul.ll;r due me.

y J-r.99<{
Al'.PlWVED BY

BN .·~

86 . ' DEPUTY-DISTRICT
ATTORNEY
 i
PERSONAL
'
EX.PENSE
\

DISV,1CT A'ITORNEY- KINGS COUXTY

Bare&a or Dirui;on Addreu
For ClT'HXD'LU ti.i.sib cc:nt¢d <idlowa t
~
e., f
I
Car
P A it ·T I C U LA ~ S Fare .•r-.
Mo. Day

.r
rJ ,·· ..

G.iU.ND TOTAL . / [7 S-{J -c~Ja

1 hcreb:r etrtif:r thlt the al>ov·ca.ccount of expenditures !J a tnic t.nd c~cc:t eutement of cfuburccmcnt1 r.ctua!l:r i:adc b:r ::oe; thtt_. the
Bo-.n.ncc for &up.,er tnonc:r mcluded iJ:i this account nu for oen-icea ·re Quired dter re,rulz.r ba,ineu
rid thu the ex:pcn~iture, of the &.l>oYC
hereof hu bf:eo p.&.ldto me c::xccpt u nued
1um1 wer~. tiec:eutry in the .,er!ormancc o! my ,offit:id city duties; e.cd {urtlier ~n.if:r tht.t
thereon, and thtt the ba.h.nce u 1ho'Pf?l thcrcill u actu:.ll:r due cc.
=
houri and euthorind by r::i:r ,u~n-uor;
put

~tt--'o'- r~........
--------~-
..... pc/?

87
(U 'DEPUTYDISTRICT ATTORNEY
 r··,
/-.
i

Z.00e-
DISTRICT AITORNEY- KINGS COUh'TY
Burc:u or Diruico

Mo. Day

------r.·.

_,
"'1-
01\)

I ~

[\)
0
co

Cl\..A}{O TOTAL ·;o.s:~

1 hereby certify t.h1.1 the c.bove 11.cc:ountcf c.x.pcnditures /J 1. tnic c.nd correct cu.terocnt cf e.ubuncmcnt1 iu:tur.!ly r:::udc b:r me; th.
~nee !or supper mone;r included i.n this &ccount ,0.1 !or aen-icc, required c.!ter reJ11lr.r b1uiocu hour, a.nd authorized by_ z::iy super
u1d th~t the expenditures of the c.bovc aum, were tiecc,ury in the per!ormancc of my,cfficia.l city datics; uid·!urthcr c:1:n.iir that ~
thereof~, ~c~ ;,&id to me except A.t rutcd thereon, u:id th&t the bt1'.nc:c u cho'i<tl thcrei.!1 /J actiallr due me.

p 10

EPUTYDISTRICTATTORNEY
88
D1STR1CTAUORNEY
- KINGS.COUh'TY
Buren or Pirak>o Aodrcu

Car.
lrAltTICULA~S Fare
Mo. Day

_,
"'r
Oro
0

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i =S
\

c..R.ANP TOTAL

DEPUTY
DISTRICTATTORNEY
89
 f?~~~ONAL EXPENSE
[iv(~\o {
l
··.. ;

' ,£42
_,/

DISTRICT A'ITORlffY- KINGS COUNTY

Bo.rc:u or Diraioc
LPor ~ ,:l u E,~d e, I fil-!lou, 11t ·

Car
PA»tTICULAlll.S Fare
Mo. Day

,:..

.r

"'1-
-ON I

f;;
C,

_...,/ . BURE.ZillCHIEr DEPUTYDISTRICTATTORNEY

'_,...,-· 90
\
 DISTRICT AllORNn' - KINGS COUh'TY
Bw~:i or Piri:k>c Adcireu
Fer ~ llubc::ra,ed a fo:tlow•t

Csr Auto Supper Travel

~_l); ~TI CUL A ft S ' Faro e·.x:ponue ·Tel.
Mon•y Expena·e Ml
Mo. Day

~LS I t:J1\1/
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CRANO TOTAL ;f JOS-0,-6

of expenditures u n tna :.nd c.:orrcc:t~u.tement of cllibuncmcntl ~tut.Uy m.1dc b.r me; thtt. th
l hereby etrtify t.hit the 1.bovc ac.:c.:ount
ulo\nnc:e for sup~r money included ui lhi1 account '-I.a for aen-icea required a.fter repib.r b:i,ineu houri IUld authori:cd by i:iy au~rYuor
1.nd thr.t the. cr:pcnditure1 of the Above ,urn, ~ere rieccur.ry in the ~dormt.nc.:e of my,offidt.l city chaiu; c.ed further certify t.h:.t~ P' 1
thereof hu bf:cn ~id lo me except f.l auted thereon, 11.ndthr.t the ba.h.nce u iho'l';'fltherein is nct1.1£.ll,r
due :cc.
/2,(2-r·: w1/ .
AP.P:aovE.D BY . ~ .

-;;;_ -- ~~-=---- EPUTYDISTRICT ATTORNEY

~B ?~CHIEF ·
91
 r- 1-2
to<>D28
~-
i~ )j;},au~~-
;l!fu~<i'r~f .~-- - .
i v~1bo~5~
!
0
()CHASE
ll'P

92
/
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.....
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 . /
I
-~--ti
S

DISIB!CT A'ITORNµ'- KINGSCOUHTY

Btll""a or Diriii-oc
Jl'o-r~ du£rr:rnd SI ffU!OCDII

Auto Suppcir Tra.val

PA~TICULAi.S Exponi:o ·Toi.
Mon,;iy Expcna'e Ml
Mo. Day

<.·

!
I'\'.
I'\'.
I-'
--.;

I =S
_foi

Cl'lANO TO'tAL

I hereby et11if1 that the 11.l>ovcacc:outit of cx:~nditurcr u a t1'1lc 1rnd correct sutement of d.ubur,cmcnu t.etut.lly tl1de br =ie: thtt. the
~nc:c for sup~r mone1 11:.cludedill this e.cc:ount -cna !or eenicc, required· t.lter rcrutu btuincu houri ~d i:uthorircd by cir cu~n-uor:
,nd thtt the expenditures of the 11.bovc sum, ""ere :ieccutry in the per!orm1.ncc of my •official city duties; 1.0d !urlhcr c-ert.ifrtht.t ~ put
.hereof bu wen pt.id to me except e..t cu.tcd thereon,• 1.0d thtt the b11.l,nce u thowii therein ls actud!y due %:le.

\ II 2-s- ,oc:r-, .
.PnOVED BY f?l\IJ
~
DEPUTYDISTRICTATTORNEY

93
i;'TC' 1n
 ~ ..~ :{:::_·
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=-\: f..·:
:.: ·'.·. . ·.·:=····.:..:.:·:····· ·· ·=·~.~-:
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····--~-:
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..=.:.=:-:·:·.:

12 . ~
· fiooo2a ~ 221 7 l
-~~WVVj'Y7v9-)

-~ $· fOSO~
.'

~028
210
~- .w,s '
~
22 4-~- ~
i::.. l

.' . . it£0\?>.
~
LJ.U~~~~b~~~~~~~~:::-_~IDS~
The Chase Manhattan Bank·
177 MontagueStreet
Brooklyn, NY11201

94
 ~,.

.....,!i;;..:..,:,.6J,j,1,,.11;,'-".......,.~~..__--r,.;=.:,,:..;.::..~O~tm::::.!.m'~------
lhren cc Pin: ictl
fl'M' ~ dlde:,"'Hi a., f .rt1nli1t

Mo. D:y

.I

~, ____________
..... ,

95 ~r,t--·DlSTRlCT ATTORNEY
 ..
'
~~~.4'i'aa@.ranml~~'y'.ffiinl\~ltn~~r,,..~.!lll©~~
4213
Jal $tQ.mf•~.m
l.!J~t-o..
The Chase Manhattan Bank
d•CHASE
\
-~ ~D . 177 Montague Street
Brooklyn,NY 11201
M'
·.:.·~~
.....
_:
...
~~s:;:;;;;;;,lffffil\l!~~~o;;:;,;;pm~@§i1ijiffi\· --~~~;;:1))/m//t;)jll\~"-""'<lllPli'·~~~
4214

96
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(}.RJ$~ 2.:0.0.Q~
:: '\ ~~ ' ~'-->--.I..:::::,,~ ~Vv V :X \,),JJ\~.lx..-fu ;m:~~ ill=.'::'
...•
FOR______ - M'
::::
.:,~--q\ltjjjj@}ji~~ ,~'"!:'"-
,,
·-:.•-
..,
:.-;::
...
 ffl /6~
___________ y ti
~j 7 . (Ii,
co0e-.V

DISTR!CTAITORND'
7
..

- KINGS CO~UN::.:..;..::ITYc.:-
____ _
Bll!'et.ll or Dirido::i Addrc:11
F ttr ~ Ii~E:~d .u f c'l[Jow• :

cu Auto Suppi;ir Trevar

P A ~ T I C .U L A ill S Fe.re Expeni:11 ·T,al. Money Ei:pen,·• MIi
Mo. Day

L-us le,',,/~
-::CZ !')-;i/L I 77l 9 7 -· -
/JKA Oa (,.( ~ 1./ ..
~~ ·rv,;~ · c/cre- c_ -
.6-1) 7Ti(;f2 s..:; /-ruT¼/ "",=-"~~er-- Gar, I

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I

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r-.. ::: r •• : ·:·· (__.. t:/ \ c---
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~ kr1-T1 ..b Jr/o
-
077-f., o·P
IN\r.,dl C- f-} /777. . .
V I
/ !

GlU!-<t> TOTAL ;f / 0 S'{J -C"JO

l hereb1 c:trtH,- thu the c.b-ovc acc:oun·t of e,:;J)1::nditure~ u a tn:e tnd correct ,u tement of d.ubunemcnt, t.ctudly eadc b,- i:ie: thu. the
~nee !or sup~r tllOl\c;r included ill thi1 c.ec:ount ..-i., for eerYic:e, required dtcr rc:-ultr ba,incu hour, ~d authorized by %D1,upuYuor:
ld thtt the expenditure, of the c.bovc sum, -.rcrc ticc:eu1ry {n the ;>tr!ormanec of my ,offic:it.l city duties; atid further cert.if,- tlu.t r.o put
i.creo{ hu ~en ~id to me except aJ ;utcd thereon, 1.::id thtt the b1!1ncc u aho~ therei.:i is actu.dlr due ::::ic.

... 2 h 'l. ,. c::i~ . (tt

PnDVED BY
I

B~ ~, , I I,
l w DEPUTY
DI::I:~
ATTORNEY
97 FIS 1A - Don
 •lffi,j;i!)ffih\b.~G,; ~":-iilv/n:l@dll,;.:'~
~.:;;3ll10J:1~ffijlt~-;,<i11ffiliiwll~,jllji@m1%',;;::;:;;ww~
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g
Q
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FOR-------------,--,--,----,--- ,i,
1:.
..;
•

98
,·
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