2023-24 Case Problem,

A cagey situation in a new jurisdiction

State of Midlands
v.
B.F. De la Porta
&
Poe Cameron
BY THE AMTA CRIMINAL CASE COMMITTEE
NEAL SCHUETT • MAHMUD BARI • DAVID BEN-MERRE
ROBSON HAUSER • GRAHAM HENRY
ELIZABETH SMILEY • BUCHANAN J. VINES • JEREMY ZARZYCKI
 August 15, 2023
American Mock
Trial Association

www.collegemocktrial.org People of Midlands:

[email protected]
Welcome to AMTA’s 40th competitive season! I’m just as excited as you are to dig in to
Tel: (515) 259-6625 State v. De la Porta.

Officers
Please join me in congratulating Elijah Bullie, Ethan Donovan, Anthony Palacios, and
Johnathan G. Woodward, Esq. Emberlynn St. Hilaire from The University of Chicago, and Kole Alfonso, Lydia Faris,
President Haley Farrokhi, and Hannah Le from UCLA, who were respectively the champions and
Jacinth Sohi runners-up of the recent Rookie Rumble tournament. I hope all of you who participated
President-Elect in the Rumble found it fun and helpful for getting ready for a criminal case season.
Michael D’Ippolito, Esq.
Secretary What I don’t think I realized when I was an AMTA competitor, and what you may not
realize as you read this note, is how the long list of people you see in the left hand
William Warihay, Esq. column of this letterhead are thinking about you. (Yes, you!) All of the work we do to
Treasurer
write cases, plan tournaments, debate rules, recruit (and beg and grovel) for judges isn’t
David D. Cross, Esq. for us – it’s because we want you to experience the thrill of this activity, we want you to
Legal Counsel
have fun, and we want you to stay involved with AMTA even after your time in Midlands
Board of Directors courtrooms comes to an end.
David Ben-Merre, Ph.D.
Justin Bernstein, Esq.
Adam Detsky, Esq. I want to briefly reprise a sentiment I included in last year’s welcome letter. There are
Matthew Eslick, Esq. lots of things you can’t control in mock trial – how good your judges are, which team
Samantha Feak, Esq. you randomly draw in round 1, whether the freshman will lose the easel (they absolutely
Michael Gelfand, Esq.
Glen Halva-Neubauer, Ph.D. will), whether your opponent steals your favorite witness call…the list goes on. What
Hon. Daniel Haughey you can control is whether you treat others with kindness. Success in this activity, just like
Graham Henry, Esq. your success in life, does not depend on your ability to be adversarial and difficult.
Hon. Toby Heytens
Andy Hogan
Devon Holstad, Esq. If there are any mock trial thoughts on your mind, especially about ways you think
Sam Jahangir, Esq.
Susan Johnson
AMTA could do better, my email is always open: [email protected].
Barry Langford, Esq. I can’t wait to see you on the #RoadToChicago!
DeLois Leapheart, Esq.
Joshua Leckrone, Esq.
Diane Michalak, Esq.
Angela Minor, Esq. Sincerely,
Brian Olson, Esq.
Thomas Parker, Esq.
Margaret Randels Schuette, Esq.
Neal Schuett, Esq.
Elizabeth Smiley, Esq. Johnathan G. Woodward
Jacinth Sohi
Kyle Thomason, Esq. AMTA President
Michael Walsh, Esq.
Melissa Watt, Esq.
Elise Wilson, Esq.
 SYNOPSIS‹
During the annual charity gala for Sohi Children’s Hospital, four masked individuals break into
the vault at Miller Tower. During the heist, one of the armed robbers and Emory Sands, a Miller
Tower security officer, are severely wounded. Two of the robbers flee via a helicopter on the
rooftop and two flee into the streets of Santa Ivo City. After an extensive investigation on the local
and federal level, Poe Cameron is arrested as one of the four suspected armed robbers, and local
billionaire Berkley De la Porta is arrested for funding the criminal operation.

AVAILABLE WITNESSES
• Kit Bahmani, police detective • Amarii Ebi, forensic analyst
• Shar Burke, federal investigator • M. Nguyen, forensic lab tech
• Jun Cage, vendor • Blaise Nova, property manager
• Poe Cameron, accused citizen • Parker Orlov, wait staff
• Cyprus Cosmos, philanthropist • Emory Sands, security officer
• Berkley De la Porta, venture capitalist

SUSPECTED ERRORS
Please report any typos or other suspected errors to [email protected].

LICENSING FEE FOR INVITATIONAL TOURNAMENTS HOSTS

These case materials are the intellectual property of the American Mock Trial Association. By
paying the School Registration Fee, a school acquires a license to use this case for internal
educational purposes and to compete at AMTA-sanctioned tournaments (that is, Regionals, ORCS,
and the National Championship Tournament). Under AMTA’s Intellectual Property policy,
however, this license does not by itself permit use of these case materials to host an invitational
tournament. Instead, schools wishing to use these case materials to host an invitational tournament
must obtain a separate license to do so. Unlicensed use may result in sanctions. If you have any
questions, please contact [email protected].

NOTES AND ACKNOWLEDGEMENTS

This case is a work of fiction. Any similarity to real people, companies, physical geographic
locations, trade names, service marks, or copyrighted material is purely coincidental. Although the
Criminal Case Committee has attempted to make the case problem realistic, we have, for the sake
of brevity and competition, simplified various matters. Please do not rely on the information
contained in the case problem outside of the mock trial context.

The Committee wishes to thank and acknowledge:

• Judge Daniel Haughey, Judge Toby Heytens, Sam Jahangir, Bradley Ouambo, and Anna
Eldridge for proofreading the case.
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 Revised 12/12/23

SPECIAL INSTRUCTIONS

1. Witness Selection and Captains’ Meeting Procedures. The Captains’ Meeting Form
explains the procedures regarding witness selection, character pronouns, and characters’
personal traits.
2. Revision Dates. Revision dates do not indicate anything about the history of case documents.
They exist solely to ensure participants use the most recent version at trial. Parties may not
use these dates to introduce facts about the case.
3. Documents and Characters Are What and Who They Purport to Be. Witnesses must
acknowledge authorship of any document that purports to be authored by them and the
authenticity of any signature that purports to be theirs. A witness whose affidavit, report, or
trial transcript states a witness is familiar with a particular document must acknowledge that
the witness is familiar with that document and that the referenced document is the same
version as the corresponding document in the current case. In addition, a witness whose
affidavit, report, or interrogation states that a witness is familiar with or recognizes a
particular person must acknowledge that the student portraying any witness of the same name
during a given round is the same person referenced in the affidavit, report, or transcript.
4. Indictments. B.F. De la Porta shall only be prosecuted on charges from De la Porta’s
indictment dated August 1, 2023. Poe Cameron shall only be prosecuted on charges from
Cameron’s indictment dated August 2, 2023.
5. Offender Selection. The prosecuting team must select either B.F. De la Porta or Poe
Cameron to prosecute. Once the prosecuting team has selected their desired defendant, the
prosecution must also select which charges they will pursue against their desired defendant
based on the following instructions.
(A) If the Prosecution decides to prosecute B.F. De la Porta.
(1) The prosecuting team must pursue at least one of the first four counts in De la Porta’s
indictment and may elect to also pursue count five (Receiving Stolen Property).
(2) During the trial of B.F. De la Porta, Supplemental Stipulation #1 exists and may be
read onto the record during trial pursuant to the time limits established in Special
Instruction 25.
(B) If the Prosecution decides to prosecute Poe Cameron.
(1) The Prosecution must select at least two indicted charges to pursue at trial from
Cameron’s indictment.
(2) During the trial of Poe Cameron, Supplemental Stipulation #1 does not exist and shall
not be used during the trial.
6. Constructive Superseding Indictment. If the prosecuting team elects to pursue fewer
charges than are listed on either defendant’s respective indictment, within the rules
established in Special Instruction 5, then both teams should proceed as if a constructive
superseding indictment has been issued by the grand jury. Neither team shall comment
during the trial on the charges in the original indictment that the prosecuting team did not
elect to pursue.

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7. Potential Affirmative Defense. A defense team representing B.F. De la Porta must argue
that De la Porta did not commit the charged offenses and is not guilty except as provided by
Special Instruction 8. No affirmative defenses may be offered in De la Porta’s trial.
However, a defense team representing Poe Cameron may elect to pursue the affirmative
defense of duress, as defined by Relevant Midlands Law. If the defense team elects to pursue
the duress defense, it must notify the prosecuting team as described on the Captains’ Meeting
Form.
If Cameron’s defense attorneys do not elect to argue duress, no other affirmative defenses
may be offered in Cameron’s trial, and Cameron’s defense attorneys must argue that
Cameron is not guilty.
(Note: An affirmative defense is an admission of criminal wrongdoing (committed the
applicable crime) by the defendant; however, the defense team is allowed to argue that the
defendant is “not guilty” based on the legal defense of duress. A defense team cannot argue
duress without Cameron admitting that Cameron committed the charged offenses. Duress is
an all-or-nothing proposition. Defense teams cannot argue duress for a lesser-included (e.g.
burglary) but deny the aggravating factor. Further, defense teams cannot argue the
affirmative defense of duress for one count but argue a negative defense (i.e. the typical “not
guilty” defense) for one or the remainder of charged offenses.)
8. Admitting to RSP (De la Porta). If the prosecution elects to prosecute Berkley F. De la
Porta and opts to pursue count five (receiving stolen property), Berkley De la Porta and De la
Porta’s counsel are permitted to offer testimony that De la Porta admits to the offense of
receiving stolen property consistent with the statements contained in De la Porta’s affidavit.
However, De la Porta is prohibited from entering a guilty plea during or prior to trial.
9. Affidavits. Unless otherwise stated herein, all of the witness affidavits, reports, and
interrogations are “affidavits” pursuant to AMTA Rule 7.21 including Detective Kit
Bahmani’s interview (Exhibit 22) and both of M. Nguyen’s reports (DNA & Fingerprint).
Exhibits 18 and 19 are not affidavits pursuant to AMTA Rule 7.21.
10. Poe Cameron’s “Affidavit.”
(A) Unlike Berkley De la Porta, Poe Cameron does not have an affidavit. Cameron’s
11/21/22 and 12/5/22 interrogations are not an “affidavit” for purposes of AMTA Rules
7.17 (Admission) or 7.21 (Invention of Fact). Accordingly, Rules 7.17 and 7.21 do not
apply to the 11/21/22 or 12/5/22 interrogations except as described below.
(B) Students playing Cameron may build their testimony using the interrogation and other
documents in the case. Cameron (and only Cameron) may also invent facts outside of the
case documents but is still subject to being cross examined on those inventions using the
interrogation, exhibits, or other case materials which Cameron is familiar.
(C) Only in rounds where Cameron will assert the affirmative defense of duress, Cameron
may claim that Cameron lied to Detective Bahmani during the 11/21/22 and 12/5/22
interrogations when, and only when, Cameron stated that (1) Cameron was not involved
in the 10/31/22 Miller Tower heist, (2) Cameron was never at the Ivy Lane apartment
complex or in Ivy Lane unit 322, (3) Cameron was not at the Miller Tower prior to
10/31/22 taking pictures of security cameras and doors, and (4) “Memphis never did
nothing to me.” (12/5/22 interview)

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(D) Unless otherwise expressly stated in Special Instruction10(C) all inventions of fact by
Cameron must comply with all AMTA Rules and other special instructions in the case. In
particular, Cameron shall not (a) deny giving the answers attributed to Cameron in the
interrogations; (b) claim that Cameron was lying during either interrogation; (c) recant
the answers given in the interrogations (see Rule 6.11(3)); (d) deny or argue that
Cameron’s prior conviction record (Exhibit 20) is inaccurate or fabricated; (e) deny
ownership or the authenticity of the Halloween mask receipt (Exhibit 6) or ring (Exhibit
7). This list is intended to be illustrative, and it is not exhaustive. Violations of this
instruction will be subject to a review procedure similar to the procedures described in
Rule 7.21.
(E) The attorneys representing Cameron are allowed to refer to Cameron’s inventions during
opening statements and closing arguments. The defense attorneys representing Cameron
are also permitted to create demonstratives utilizing the inventions of fact created through
the Cameron testimony. Note that a “demonstrative” is distinct from an “exhibit.” Teams
are not permitted to create new exhibits and offer them into evidence in support of
Cameron’s story. The exhibits in the case packet are the only ones that may be offered
into evidence. This instruction is simply clarifying that teams may create demonstratives
related to Cameron’s inventions (including, but not limited to, demonstratives such as
timelines, drawing on the maps or exhibits provided in the case packet, utilizing
photographs provided in the case packet, etc.) without running afoul of the invention
parameters of Rule 7.20(2)(b).
11. Cameron/De la Porta Availability Toggle. If the prosecuting team elects to prosecute
Cameron, De la Porta is not available to be selected as a witness. Similarly, if the prosecuting
teams elects to prosecute De la Porta, Cameron is not available to be selected as a witness.
Note: This Special Instruction is referring to the witness selection process and “unavailable”
is not being used within this instruction in the same way “unavailable” is used in MRE 804.
12. Cameron Interrogations. If Berkley De la Porta is being prosecuted, the prosecuting team
may not introduce either of Cameron’s interrogations, in whole or in part, as evidence. If De
la Porta is being prosecuted, both teams should treat Cameron’s 11/21/22 and 12/5/22
interrogations as nonexistent. Instead, both teams should proceed as if Poe Cameron gave no
statements to Detective Bahmani or any other officer prior to pleading guilty consistent to the
terms of Supplemental Stipulation #1.
13. Party Representatives. For the purposes of Rule 615 of the Midlands Rules of Evidence: (1)
Detective Kit Bahmani is the only permissible “representative” for the State of Midlands; (2)
when Poe Cameron is the defendant, Cameron must be the “party” for the defense team; and
(3) when B.F. De la Porta is the defendant, De la Porta must be the “party” for the defense
team.
14. Identification of Defendant. Identification of a criminal defendant is an essential element of
the charge and, therefore, must be presented by the prosecution as part of its burden of proof.
See State v. Homel (2010). Accordingly, prosecution teams must call a witness that can
identify the Defendant. Teams that have more than six members on their rosters must have a
defendant seated at defense counsel table for in-court identification purposes. If the defense
team does not have enough members to seat someone at defense counsel table as the
defendant, then the defendant will be constructively present at trial. Before the trial begins,
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the defense team must let the prosecution team know whether the defendant will be
constructively present and, if so, what the defendant is constructively wearing for in-court
identification purposes by the prosecuting witnesses.
15. Confrontation Clause Objections are Prohibited. Teams are prohibited from making
objections on any 6th Amendment Confrontation Clause grounds. For example, a defense
team is prohibited from objecting to statements provided to Detective Bahmani or Agent
Burke on constitutional grounds that the statements violate the defendant’s right to
confrontation. This prohibition includes any objections based on the holdings of United
States v. Bruton and Crawford v. Washington and its progeny. However, neither team is
prohibited from objecting to evidence based on the Midlands Rules of Evidence or Relevant
Midlands Law contained herein.
16. Fifth Amendment (Witnesses). No available witness may refuse to answer any question—
and no attorney may instruct a witness not to respond—based on the witness’s Fifth
Amendment rights.
17. Closed-Universe Problem. The only legal materials that competitors may mention, or
judges may rely upon, for any purpose are those set forth in the Relevant Midlands Law and
the Midlands Rules of Evidence. All participants must acknowledge such if asked by a judge.
This means that no objections may be made on constitutional grounds.
18. Mask. Exhibit 23 shall be provided by the prosecuting team. The mask that will be identified
as Exhibit 23 must be disclosed to the defense team during the Captains’ Meeting prior to
trial. The mask shall not be a depiction of any living human, a body part, or that anything that
is offensive or is lewd in nature. Neither team shall comment on whether the mask identified
as Exhibit 23 would fit the student playing Cameron. Neither team shall ask or allow any
witnesses to put on Exhibit 23. Neither team may put any markings or other depictions of
blood from Emory Sands on the mask. The amount of blood is not included in the case
packet and, thus, cannot be depicted on the mask. (Note: The Case Committee wants
competitors to be able to have fun and be creative with the mask that they select. However, if
this privilege is abused or becomes a source of complaints about insensitive or inappropriate
masks, the Case Committee will alter this Special Instruction and case to remove this option.)
19. Exhibit 28 (AMTA supplied mask picture). Exhibit 28 exists only if the prosecuting team
fails to disclose a mask at Captains’ Meeting to use as Exhibit 23 pursuant to Special
Instruction 18. If Exhibit 28 is being used in the trial, all case materials hereafter that refer to
Exhibit 23 are constructively amended to read Exhibit 28.
20. DNA. Any DNA testing that would have resulted in sex-specific determinations is
considered to be a match to the gender identity of the student portraying the role, or
alternatively if no student is portraying the role, to the gender identity chosen by the team
empowered to make the choice in captains. No participant, including the closing attorney for
either team, is permitted to imply that the DNA results are more or less accurate because of
the lack of presence of sex-specific loci within the DNA testing.
21. Legal Documents. All documents identified as “Legal Documents” (on the Available Case
Documents page) that use “De la Porta/Cameron” in the case heading for the defendant may
be used in all trials, regardless of which defendant is prosecuted, unless otherwise noted in
these Special Instructions. Teams should proceed as if the case heading constructively
contains only the defendant being prosecuted in their specific trial.
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22. Using Jury Instructions. The jury instructions are provided as educational tools. They are
not exhibits or evidence to be admitted at trial. These documents are designed to help you
understand the law and how juries are instructed before deliberation. Closing attorneys may
not contradict the jury instructions; however, they are not required to use or reference the
jury instructions during their closing arguments. Attorneys can presume that the jury
instructions will be constructively read to the jury by the presiding judge before both parties
have presented closing arguments.
23. Best Evidence Rule Limited to Items in the Case Packet. No attorney may object under
Rule 1002 of the Midlands Rules of Evidence if the “original writing, recording, or
photograph” in question is not among the documents contained in this case packet.
24. Black-and-White Copies. No objection may be raised on the ground that a document,
exhibit, or demonstrative was altered by printing it in black-and-white.
25. Time Limits. Should a team wish to publish part or all of a document by reading it onto the
record, the time spent reading shall be deducted from the publishing team’s total direct or
cross time, depending on whether the reading occurs during the publisher’s case-in-chief or
that of the other team. Publication may not occur before opening statements or after the
defense team closes its case-in-chief.
26. Auction Brochure. The auction brochure (Exhibit 2) was designed to be assembled/folded
into booklet form. The witnesses would have seen the Exhibit 2 in a booklet form. However,
no witness may deny recognizing or assert that Exhibit 2 is inauthentic if Exhibit 2 is not
assembled or folded into booklet form. Teams may also assemble Exhibit 2 into booklet form
for use during trial, though that is not required.
27. Pictures of Poe Cameron & Memphis Raynes. Defense teams are permitted to bring their
own pictures for Poe Cameron (Exhibit 25) and Memphis Raynes (Exhibit 26) so long as
both exhibits comply with the terms established herein. Raynes and Cameron are biological
siblings and have the same gender identity but are not identical twins. A team may not
slightly alter a photo of the person portraying Poe Cameron in order to make the Memphis
Raynes photo look nearly identical to Cameron. To obtain the photos for these exhibits,
teams may either (1) have photographs of two different non-identical real people for Exhibit
26 and 27, or (2) to create a photo of Memphis Raynes, teams are permitted to use AI image
generators. However, the only permissible AI generators are those that combine two faces
together. Teams opting for AI generated images should be ready to show their source images
used for combination in the AI generator at the captains meeting. Any pictures selected by
the Defense team must adhere to these terms. The determination of whether these terms have
been complied with is subject to interpretation by the AMTA Representatives during the
Captains Meeting. Failure to adhere to these terms may result in your photo of Memphis
Raynes not being permitted to use at trial. In trials where Cameron will neither be called as a
witness nor sitting at counsel table and the Defense team has not supplied photos of Poe
Cameron and Memphis Raynes, the Prosecution team may supply the photos to be used as
Exhibits 25 and 26..
28. Duress Defense Limitation. Defense teams are prohibited from arguing or presenting
evidence of a duress defense based on sexual assault or threats thereof.

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29. Knowledge of De la Porta’s affidavit. Agent Shar Burke and Detective Kit Bahmani have
read and are familiar with Berkley F. De la Porta’s affidavit. This familiarity exists regardless
of which defendant is being prosecuted.

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AVAILABLE CASE DOCUMENTS

Legal Documents
1. Notice of Intent to Offer Character Evidence
2. Indictment (B.F. De la Porta)
3. Indictment (Poe Cameron)
4. Relevant Midlands Law
5. Stipulations
6. Orders on Motion in Limine
7. Jury Instructions

Witness Materials
1. Affidavit of Cyprus Cosmos
2. Affidavit of Parker Orlov
3. Affidavit of Jun Cage
4. Affidavit of Blaise Nova
5. Affidavit of Emory Sands
6. Affidavit of Berkley F. De la Porta
7. Report of Shar Burke
8. Report of Kit Bahmani
9. Report of M. Nguyen (DNA)
10. Report of M. Nguyen (Fingerprint)
11. Report of M. Nguyen (Mass Spectrometry Report)
12. Report of Amarii Ebi
13. Interrogation #1 of Poe Cameron
14. Interrogation #2 of Poe Cameron

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EXHIBIT LIST
1. Invitation to the Sohi Children’s Hospital Gala at Miller Tower
2. Brochure for auction items
3. Diagram of Miller Tower: 40th Floor
4. Diagram of Miller Tower: Roof
5. Picture of Miller Tower Key Card
6. Picture of Poe Cameron’s receipt
7. Picture of Poe Cameron’s ring
8. Diagram of Ivy Lane unit 322
9. Picture of purple key fob for unit 322
10. Picture of blue key fob for unit 322
11. Picture of red key fob for unit 322
12. Ivy Lane lease agreement for unit 322
13. FBI 302 Form: Transcript of CI call
14. “Miller Tower phone” call log screenshot (Cameron)
15. “Miller Tower phone” call log screenshot (Raynes)
16. “Miller Tower phone” call log screenshot (Bidder 1050)
17. FBI ESD0312 Form: Confidential Profile
18. “So It Was Written” Article
19. “Santo Ivo Tech Talk” Article
20. Public Records Request (Cameron)
21. Public Records Request (Raynes)
22. Interview Transcript of Det. Kit Bahmani
23. Mask
24. MSIG Business Card
25. Photo of Poe Cameron
26. Photo of Memphis Raynes
27. Medical Report for Emory Sands
28. Mask photo supplied by AMTA
29. Detective Bahmani’s Security Footage Notes
30. Text Message Report & Declaration

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Captains’ Meeting Form

Before receiving ballots, teams must turn in one completed copy of this form to the AMTA Representative.
Participants may not view (or attempt to view) the form for any trial in which their team does not compete.
All selections are final and binding once announced.

Room Number: __________ Team Numbers: ___________________ Round: 1 2 3 4

The Captains’ Meeting proceeds in the following order:

1. INDICTMENT SELECTION. The Prosecution team must select 1) the Defendant and 2) the
charge(s) it is pursuing pursuant to Special Instruction 5.
Prosecution Selections
(circle the defendant and all charges the Prosecution team is pursuing)
Cons. – Grand Cons. – Agg. Cons. – Agg. Wire Receipt of
Berkley F. De la Porta
Theft Burglary Robbery Fraud Stolen Property
Cons. – Grand Agg.
Poe Cameron Agg. Burglary Agg. Robbery Kidnapping
Theft Assault
a. If Poe Cameron is the defendant, Defense must notify Prosecution, before witnesses are selected, if
Cameron will assert an affirmative defense of duress:
Cameron will assert the defense of duress Cameron will not assert the defense of duress

2. WITNESS SELECTION & IN-ROUND CALL ORDER. Only the Prosecution may call Burke,
Bahmani, Nguyen, Nova, and Sands. Only the Defense may call Cameron, De la Porta, Ebi, and Orlov.
Either side may call Cosmos and Cage. The witness call order shall proceed as follows: P-D-D-P-D-P.
Memphis Raynes is not an available witness.
Fill in the order in which the witnesses will testify.
Prosecution Witness Selections Defense Witness Selections
Witness Name Call # Witness Name Call #

3. GENDERS/PRONOUNS. Defense announces the selected defendant’s preferred pronouns. State of

Midlands will determine the pronouns for all side-constrained Prosecution witnesses. Defense will determine
pronouns of all side-constrained Defense witnesses, including Memphis Raynes. The pronouns of Cosmos
and Cage will be determined by the team calling that witness (or by Prosecution if that witness will not be
called.) Teams shall also complete the Gender/Pronouns Form included herein.
Prosecution Pronoun Defense Pronoun Other Pronoun
Burke Cameron Cosmos
Bahmani De la Porta Cage
Nguyen Ebi
Nova Orlov
Sands Raynes
4. CHARACTER EVIDENCE NOTICE. Both parties must disclose their intentions as enumerated on the
Notice of Intent to Offer Character Evidence form attached herein.
5. EXHIBITS AND DEMONSTRATIVES. Teams must show any demonstrative aid within the meaning
of AMTA Rule 7.20 to the other team during the Captains’ Meeting. Failure to do so shall constitute an
absolute bar to using the demonstrative in any way during trial. Any objections based on the Special
Instructions or AMTA Rules must be raised and brought to the AMTA Representatives’ attention during the
Captains’ Meeting and may not be raised or renewed during trial. Objections based on the Midlands Rules of
Evidence, however, may and must be made at trial.
 Revised 8/27/23

Gender Pronouns Form

During the Captains’ Meeting, teams must complete one copy of this form. One completed copy of
this form must be provided to the presiding judge during pre-trial.

Room Number: ________________ Round: 1 2 3 4

Prosecution Team Number: _________ Defense Team Number: _________

Please complete this form in the following order:

1. ATTORNEY PRONOUNS. Please include the names and pronouns of all attorneys who will be
competing in the round.

Plaintiff Attorney Name Pronouns Defense Attorney Name Pronouns

2. TESTIFYING WITNESS PRONOUNS. Please include the character names and pronouns of
all witnesses who will be called to testify during the round. Do not include any witnesses who will
not be testifying.

Prosecution Witnesses Defense Witnesses

Witness Name Pronouns Witness Name Pronouns

3. PROSECUTION’S REPRESENTATIVE & PARTY PRONOUNS. Teams who will not call
a Prosecution’s representative or party to testify but will have them seated at counsel table either in
person or constructively, must include the applicable pronouns below. Teams who will neither call
a representative nor have them seated at counsel table may leave this section blank. The applicable
defendant’s pronouns must be identified prior to trial.

Prosecution’s Representative Defense Party

Witness Name Pronouns Defendant Name Pronouns
Detective Kit Bahmani
 IN THE CIRCUIT COURT, CRIMINAL DIVISION
CHARLOTTE COUNTY, MIDLANDS

STATE OF MIDLANDS, *
Plaintiff, *
*
v. *
*
DE LA PORTA/CAMERON, *
Defendant. *
*
NOTICE OF INTENT TO OFFER CHARACTER EVIDENCE

The parties give notice of their intention to offer character evidence as follows:
1. ___ The defendant will offer evidence under Rule 404(a)(2)(A) of the following traits
of his/her own character: _______________________________________ and
understands that, in lieu of rebuttal witnesses, the prosecution may offer rebuttal
evidence of those same traits of character during its case in chief.
2. ___ The prosecution will offer evidence of prior crimes, wrongs, or acts under Rule
404(b)(2).
3. ___The defendant will offer opinion and/or reputation evidence of a prosecution
witness’s character for truthfulness/untruthfulness under Rule 608(a) and understand
that, in lieu of rebuttal witnesses, the prosecution may rebut this evidence during its
case in chief. The defendant intends to offer evidence under this rule about the following
witnesses:

Signed:

_________________________, Attorney for Defendant __________________

_________________________, Attorney for the State of Midlands

NOTE TO JUDGES: Parties may offer evidence of the character of a person during
their case in chief, consistent with the Midlands Rules of Evidence

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IN THE CIRCUIT COURT, CRIMINAL DIVISION

CHARLOTTE COUNTY, MIDLANDS

STATE OF MIDLANDS, * CASE NO.: CR2023-08-0992

Plaintiff, *
*
v. *
*
BERKLEY DE LA PORTA, *
Defendant. *
*
INDICTMENT
STATE OF MIDLANDS,
COUNTY OF CHARLOTTE, SS:
In the Year 2023

THE JURORS OF THE GRAND JURY OF THE STATE OF MIDLANDS, within

and for the body for the County aforesaid, on their oaths, in the name and by the
authority of the State of Midlands, do find and present that:

COUNT ONE
CONSPIRACY—GRAND THEFT
On or about August 1, 2022 to October 31, 2022, in Charlotte County, Midlands, Berkley
F. De la Porta (1) purposefully entered into an agreement with another person or
persons to commit Grand Theft in violation of MPC §18-668(B)(1), or to solicit another
person or persons to commit Grand Theft in violation of MPC §18-668(B)(1), and (2) a
party to the agreement committed an overt act in furtherance of this agreement, which
constitutes the offense of Conspiracy to Grand Theft, a Class 1 Felony, in violation of
MPC §18-371~§18-668(B)(1), and against the peace and dignity of the State of Midlands.

COUNT TWO
CONSPIRACY—AGGRAVATED BURGLARY
On or about August 1, 2022 to October 31, 2022, in Charlotte County, Midlands, Berkley
F. De la Porta (1) purposefully entered into an agreement with another person or
persons to commit Aggravated Burglary in violation of MPC §18-103.2(B)(1), or to solicit
another person or persons to commit Aggravated Burglary in violation of MPC §18-
103.2(B)(1), and (2) a party to the agreement committed an overt act in furtherance of
this agreement, which constitutes the offense of Conspiracy to Aggravated Burglary, a
Class 1 Felony, in violation of MPC §18-371~§18-103.2(B)(1), and against the peace and
dignity of the State of Midlands.

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COUNT THREE
CONSPIRACY—AGGRAVATED ROBBERY
On or about August 1, 2022 to October 31, 2022, in Charlotte County, Midlands, Berkley
F. De la Porta (1) purposefully entered into an agreement with another person or
persons to commit Aggravated Robbery in violation of MPC §18-103.1(B)(1), or to solicit
another person or persons to commit Aggravated Robbery in violation of MPC §18-
103.1(B)(1), and (2) a party to the agreement committed an overt act in furtherance of
this agreement, which constitutes the offense of Conspiracy to Aggravated Robbery, a
Class 1 Felony, in violation of MPC §18-371~§18-103.1(B)(1), and against the peace and
dignity of the State of Midlands.

COUNT FOUR
WIRE FRAUD
On or about August 1, 2022 to December 25, 2022, in Charlotte County, Midlands,
Berkley F. De la Porta knowingly created or participated in a scheme to defraud another
out of money or property with an intent to defraud wherein it was reasonably
foreseeable that the offender would use wire communications and the offender did, in
fact, use wire communications in furtherance of the offense, which constitutes the
offense of Wire Fraud, a Class 1 Felony, in violation of MPC §18-1343, and against the
peace and dignity of the State of Midlands.

COUNT FIVE
RECEIVING STOLEN PROPERTY—OBJECT OF CULTURAL HERITAGE
On or about August 1, 2022 to January 31, 2023, in Charlotte County, Midlands, Berkley
F. De la Porta received, concealed, exhibited, or disposed of an object of cultural
heritage, knowing that the object had been stolen or obtained by fraud, and, in fact, the
object was stolen or obtained by fraud from the care, custody, or control of a museum,
legitimate auction house, charity organization, nonprofit organization, or similarly
situated organization in lawful possession of any object of cultural heritage, receives,
conceals, exhibits, or disposes of the object, which constitutes the offense of Receiving
Stolen Property, a Class 2 Felony, in violation of Midlands Penal Code 18-668(B)(2),
and against the peace and dignity of the State of Midlands.

A. Gurtatta
A. Gurtatta (0086034)
ASST. PROSECUTING ATTORNEY
CHARLOTTE COUNTY
A TRUE BILL
L. Zedell
FOREPERSON, GRAND JURY
Date Signed: August 1, 2023

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IN THE CIRCUIT COURT, CRIMINAL DIVISION

CHARLOTTE COUNTY, MIDLANDS

STATE OF MIDLANDS, * CASE NO.: CR2023-08-0992

Plaintiff, *
*
v. *
*
POE CAMERON, *
Defendant. *
*
INDICTMENT
STATE OF MIDLANDS,
COUNTY OF CHARLOTTE, SS:
In the Year 2023

THE JURORS OF THE GRAND JURY OF THE STATE OF MIDLANDS, within

and for the body for the County aforesaid, on their oaths, in the name and by the
authority of the State of Midlands, do find and present that:

COUNT ONE
CONSPIRACY—GRAND THEFT
On or about August 1, 2022 to October 31, 2022, in Charlotte County, Midlands, Poe
Cameron (1) purposefully entered into an agreement with another person or persons to
commit Grand Theft in violation of MPC §18-668(B)(1), or to solicit another person or
persons to commit Grand Theft in violation of MPC §18-668(B)(1), and (2) a party to the
agreement committed an overt act in furtherance of this agreement, which constitutes
the offense of Conspiracy to Grand Theft, a Class 1 Felony, in violation of MPC §18-
371~§18-668(B)(1), and against the peace and dignity of the State of Midlands.

COUNT TWO
AGGRAVATED BURGLARY
On or about October 31, 2022, in Charlotte County, Midlands, Poe Cameron entered a
building or occupied structure or separately secured or occupied portion thereof with
the purpose of committing a crime therein, and in doing so, knowingly caused or
attempted to cause serious bodily harm to Emory Sands, or knowingly caused or
attempted to cause bodily injury to Emory Sands with a deadly weapon, which
constitutes the offense of AGGRAVATED BURGLARY, a Class 1 Felony, in violation of
Midlands Penal Code §18-103.2, and against the peace and dignity of the State of
Midlands.

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COUNT THREE
AGGRAVATED ROBBERY
On or about October 31, 2022, in Charlotte County, Midlands, Poe Cameron took or
attempted to take, with the intent to steal, the property of another person or persons
against their will by violence or imminent threat of force against such other person or
persons, and in doing so, knowingly caused or attempted to cause serious bodily harm to
Emory Sands, or knowingly caused or attempted to cause bodily injury to Emory Sands
with a deadly weapon, which constitutes the offense of AGGRAVATED ROBBERY, a
Class 1 Felony, in violation of Midlands Penal Code §18-103.1, and against the peace and
dignity of the State of Midlands.

COUNT FOUR
AGGRAVATED ASSAULT
On or about October 31, 2022, in Charlotte County, Midlands, Poe Cameron knowingly
caused or attempted to cause serious bodily harm to Emory Sands, or knowingly caused
or attempted to cause bodily injury to Emory Sands with a deadly weapon, which
constitutes the offense of AGGRAVATED ASSAULT, a Class 2 Felony, in violation of
Midlands Penal Code §18-111.2, and against the peace and dignity of the State of
Midlands.

COUNT FIVE
KIDNAPPING
On or about October 31, 2022, in Charlotte County, Midlands, Poe Cameron (1) took or
attempted to take Emory Sands from one place to another against their will, or (2)
purposefully confined Emory Sands to a controlled space, which constitutes the offense
of KIDNAPPING, a Class 3 Felony, in violation of Midlands Penal Code §18-155, and
against the peace and dignity of the State of Midlands.

N. Muldrow
N. Muldrow (0081437)
ASST. PROSECUTING ATTORNEY
CHARLOTTE COUNTY
A TRUE BILL
T. Chatterjee
FOREPERSON, GRAND JURY
Date Signed: August 2, 2023

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RELEVANT MIDLANDS LAW

The statutes and cases listed below, along with the Midlands Rules of Evidence, are the only
legal authorities that may be cited in trial.

Applicable Provisions from Midlands Penal Code

Midlands Penal Code §18-100.1 Knowingly Defined
(A) A person acts knowingly with respect to a material element of an offense when: (i) if the
element involves the nature of the person’s conduct or the attendant circumstances, the
person is aware that their conduct is of that nature or that such circumstances exist; or (ii)
if the element involves a result of their conduct, the person is aware that it is practically
certain that their conduct will cause such a result.

Midlands Penal Code §18-100.2 Purposefully Defined

(A) A person acts purposefully when that person acts with the intent to cause a certain result.

Midlands Penal Code §18-100.3 Reckless Defined

(A) A person acts recklessly when, with heedless indifference to the consequences, the person
disregards a substantial and unjustifiable risk that the person’s conduct is likely to cause a
certain result or is likely to be of a certain nature.

Midlands Penal Code §18-100.23 Weapons control definitions

(A) “Deadly weapon” means any instrument, device, or thing capable of inflicting death, and
designed or specially adapted for use as a weapon, or possessed, carried, or used as a
weapon.

Midlands Penal Code §18-103.1 Robbery

(A) Offenses—A person is guilty of robbery if that person—
(1) attempts to take or takes with the intent to steal the property of another person or
persons against their will by violence or imminent threat of force against such other
person or persons.
(B) Aggravating Factor—A person is guilty of aggravated robbery if that person—
(1) in violating (A)(1) of this section, knowingly causes or attempts to cause serious bodily
harm to another person, or knowingly causes or attempts to cause bodily injury to
another with a deadly weapon.

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Midlands Penal Code §18-103.2 Burglary

(A) Offenses—A person is guilty of burglary if that person—
(1) enters a building or occupied structure or separately secured or occupied portion
thereof with the purpose of committing a crime therein unless the premises are open
to the public or the person is licensed to enter the building, occupied structure, or
separately secured or occupied portion thereof.
(B) Aggravating Factor—A person is guilty of aggravated burglary if that person—
(1) in violating (A)(1) of this section, knowingly causes or attempts to cause serious bodily
harm to another person, or knowingly causes or attempts to cause bodily injury to
another with a deadly weapon.

Midlands Penal Code §18-111.2 Aggravated Assault

(A) Offenses—A person is guilty of aggravated assault if that person—
(1) attempts to cause serious bodily harm to another, or causes such harm purposefully,
knowingly, or recklessly under circumstances manifesting extreme indifference to the
value of human life; or
(2) attempts to cause or purposefully or knowingly causes bodily injury to another with a
deadly weapon.

Midlands Penal Code §18-155 Kidnapping

(A) Offenses—A person is guilty of kidnapping if that person—
(1) attempts to take or takes another person or persons from one place to another against
their will, or the purposeful confinement of another person or persons to a controlled
space.

Midlands Penal Code §18-371 Conspiracy

(A) Offenses—A person is guilty of conspiracy to commit a crime if—
(1) with the purpose of promoting or facilitating the commission of a crime a person:
a. agrees with another person or persons that they, or one or more of them, will
engage in conduct that constitutes such crime or an attempt or solicitation to
commit such crime; or
b. agrees to aid such other person or persons in the planning or commission of
such crime or of an attempt or solicitation to commit such crime.
(B) Scope of Conspiratorial Relationship
(1) If a person guilty of conspiracy, as defined by Subsection (A)(1) of this Section, knows
that a person with whom they conspired to commit a crime has conspired to with
another person or persons to commit the same crime, that person is guilty of conspiring
with such other person or persons, whether or not they know the identity of other such
person or persons, to commit such crime.
(C) Conspiracy with Multiple Criminal Objectives
(1) If a person conspires to commit a number of crimes, that person is guilty of only one
conspiracy so long as such multiple crimes are the object of the same agreement or
continuous conspiratorial relationship.

(D) Definitions

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(1) Overt Act

a. No person may be convicted of conspiracy to commit a crime unless an overt
act in pursuance of such conspiracy is alleged and proven to have been done by
said person or by another person with whom they conspired.

Midlands Penal Code §18-668 Grand Theft; Receiving Stolen Property Thereof
(A) Definitions—In this section—
(1) “Object of cultural heritage” means an object that is:
a. Over 100 years old and worth in excess of $5,000; or
b. Worth at least $100,000
(B) Offenses—A person who—
(1) steals or obtains by fraud from the care, custody, or control of a museum, legitimate
auction house, charity organization, nonprofit organization, or similarly situated
organization in lawful possession of any object of cultural heritage; or
(2) knowing that an object of cultural heritage has been stolen or obtained by fraud, if in
fact the object was stolen or obtained from the care, custody, or control of a museum,
legitimate auction house, charity organization, nonprofit organization, or similarly
situated organization in lawful possession of any object of cultural heritage (whether
or not that fact is known to the person), receives, conceals, exhibits, or disposes of the
object.

Midlands Penal Code §18-1343 Wire Fraud

(A) Offenses—A person is guilty of wire fraud if that person—
(1) knowingly creates or participates in a scheme to defraud another out of money or
property with an intent to defraud wherein it was reasonably foreseeable that the
offender would use wire communications and the offender did, in fact, use wire
communications in furtherance of the offense.

Midlands Penal Code §18-9999 Penalties [Selected Provisions]

The following penalties shall apply:
Class 1 Felony: No less than 20 years imprisonment. No greater than life without parole.
Class 2 Felony: No less than 10 years imprisonment. No greater than 25 years.
Class 3 Felony: No less than 5 years imprisonment. No greater than 8 years.
Class 4 Felony: No less than 9 months imprisonment. No greater than 3 years.
Class 5 Felony: No less than 6 months imprisonment. No greater than 1 year.
Misdemeanor: Up to 1 year of imprisonment.

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Relevant Cases
All cases are rulings of the Midlands Supreme Court, the highest court in Midlands, unless
otherwise specified.

Mens Rea & Actus Reus

State v. Shapiro (1975)

Defendant charged with offense requiring a mental state of “knowingly” argued that the evidence
was insufficient because there was no indication she desired or hoped for a particular result.
Held: Conviction affirmed. A defendant who acted purposefully or who intended a particular
result certainly acted knowingly, MPC 18-100.1 makes clear there is no such requirement.

State v. Lawan (2019)

Defendant argued that his conviction for aggravated robbery MPC 18-103.1 was not supported
by the manifest weight of the evidence and that the State had not offered sufficient evidence of a
specific intent to cause serious bodily harm to another person when he acted. Held: Conviction
affirmed. The General Assembly conspicuously used the “knowingly” mens rea in MPC 18-
103.1, not “purposeful” or language that mandates a specific intent to harm.

State v. Wilson (2000)

As used in MPC 18-103.2, “occupied structure” means any house, building, or shelter, to which
any of the following applies:
(1) It is maintained as a permanent or temporary dwelling, even though it is temporarily
unoccupied and whether or not any person is actually present;
(2) At the time, it is occupied as the permanent or temporary habitation of any person,
whether or not any person is actually present;
(3) At the time, it is specifically adapted for the overnight accommodation of any person,
whether or not any person is actually present;
(4) At the time, any person is present or likely to be present.

State v. Sims (2018)

As used in MPC 18-111.2, “substantial risk” means a strong possibility, as contrasted with a
remote or significant possibility, that a certain result may occur or that certain circumstances
may exist.

State v. Kenney (2003)

Under MPC 18-111.2 and any criminal statute that contains an “Aggravating Factor”
enhancement offense, “serious bodily harm to any person” means any of the following:
(1) Any mental illness or condition of such gravity as would normally require hospitalization
or prolonged psychiatric treatment;
(2) Any physical harm that carries a substantial risk of death;
(3) Any physical harm that involves some permanent incapacity, whether partial or total, or
that involves some temporary, substantial incapacity;
(4) Any physical harm that involves some permanent disfigurement or that involves some
temporary, serious disfigurement;

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(5) Any physical harm that involves acute pain of such duration as to result in substantial
suffering or that involves any degree of prolonged or intractable pain.
“Substantial risk” was previously defined by this Court in State v. Sims.

State v. Orduz (1999)

As used in MPC 18-668, “steal” is just a synonym for “theft.” Accordingly, all the same
elements for common law theft apply to the term “steal.” “Theft” has long been defined as the
taking or exerting control over the property of another with the intent to deprive the owner
thereof.

State v. Lee (2005)

Defendant charged with petty theft argued that she did not “take” the jewelry from the victim
because the victim voluntarily gave the defendant the jewelry. Defendant’s argument is without
merit. The victim was not only the victim of theft but a victim of deception by the defendant to
induce the victim to “voluntarily” transfer the jewelry to the defendant. It is still theft if the thief
accomplishes the “taking” (of the property of another) through means of deception, threat,
intimidation, or by breaching the terms of agency established between the agent and principal.

State v. LaRue (2012)

As used in MPC 18-1343, “defraud” means the act of knowingly obtaining some benefit for
oneself or another by deception, or knowingly cause some detriment to another person or entity
by deception. Furthermore, a defendant acts with the intent to deceive when that defendant
makes false statements or utilizes other forms of dishonesty or trickery. Deception occurs when a
defendant (1) engages in a scheme or artifice to defraud or obtain money and/or property, or (2)
deprives a victim of money and/or property through acts of dishonesty or trickery.

State v. Webb (2018)

As used in MPC 18-1343, “wire communications” includes digital and cellular communications.
The fact that almost all communication in modern society is done via wireless communication
devices does not exculpate a defendant from “wire fraud” charges when that defendant uses text
messages or email messages to participate in a scheme to defraud another out of money or
property.

State v. Cawthon (2022)

Defendant’s conviction for wire fraud is vacated. Put simply, the offense of “wire fraud” cannot
be proven by merely showing the defendant used technology in a plan or scheme to obtain or
receive stolen property. Knowingly purchasing or taking possession of stolen property, even
using an anonymous online username, is not engaging in wire fraud. It’s simply a modern-day
version of receiving stolen property. Fraud requires scienter; specifically, it requires an intent to
defraud. Buying stolen property, alone, does not satisfy the specific intent to defraud that is
required for wire fraud—even when the buyer uses an anonymous profile name. However, if a
defendant were to engage in a scheme to knowingly sell stolen property or aided others in the
theft of property so that she could then later purchase the stolen items, that would satisfy the
elements of MPC-1343 and is consistent with this Court’s holding in State v. LaRue (2010).

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State v. Blaine (2020)

In order for a defendant to succeed on a claim of “duress,” the defendant must present sufficient
evidence that (1) they had an actual fear of serious and immediate bodily injury or death to
himself or others; (2) they had no reasonable means to escape from the situation; and (3) as a
result, they were forced to participate in criminal activity. In asserting the affirmative defense of
“duress,” the criminal defendant must prove all three aforementioned elements by a
preponderance of the evidence to be acquitted. If the defendant actively takes part in a violent
act, a rebuttable presumption is created that the defendant’s actions were voluntary.

State v. Reuben (2021)

It is the defendant’s burden to prove an affirmative defense of duress. But a claim of duress does
not relieve the State of Midlands of its burden to prove all charged offenses beyond a reasonable
doubt. If a defendant claiming duress elects to testify, the prosecutor is allowed to question the
defendant on the elements and otherwise relevant facts related to the charged offenses. If a
defendant claiming duress elects not to testify, the prosecutor is allowed to question or argue the
credibility of the evidence offered to prove the defendant’s duress claim. The believability of a
claim of duress is always a relevant issue for the trier of fact.

State v. Monk (2020)

MPC 18-371(A)(1) reuires an agreement to commit a crime for a defendant to be convicted of
conspiracy. It is well settled law that the agreement must be to commit a specific crime. Before
us now, is the question: if a defendant agrees to commit aggravated burglary, does that
agreement include the lesser included burglary as well? We answer in the affirmative; conviction
affirmed. However, we do not agree with the State’s position that an agreement to commit
burglary would necessarily prove a conspiracy for aggravated burglary offense. That is a separate
aggrement to the aggravating factor.

State v. Burnett (2015)

An “overt act” is a volitional act, but it need not be inherently illicit. An action that may be
innocent itself can be used as evidence of the defendant’s participation in a criminal conspiracy
if that volitional act by the defendant was in preparation or furtherance of a crime. For example,
buying fertilizer from a local hardware store is a perfectly innocent act. Unless, of course, the
person is buying the fertilizer to build a bomb instead of enriching the soil of their garden.

Burden of Proof / Presumption of Innocence

State v. White (1904)

In a criminal case, the burden is proof beyond a reasonable doubt with respect to each and every
element of the charged offense(s). The burden is on the State and never shifts to the defendant.

State v. Joseph (1981)

The State’s burden of proof applies to elements, not discrete facts. The question in every case is
whether cumulative impact of the otherwise-admissible evidence is sufficient to convince the
fact finder beyond a reasonable doubt that the element has been proven.

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State v. Ball (2015)

A criminal defendant is never required to present evidence or offer an alternative theory of the
crime. If a defendant does so, however, a prosecutor may note the defense’s failure to offer
evidence in support of its theory of the case. Such comments do not imply that the burden of
proof has shifted to the defense, nor do they necessarily constitute an infringement on a
defendant’s exercise of the right to remain silent.

State v. Arun (2016)

Criminal defendants have a constitutionally protected right to refuse to speak with police officers
and to decline to testify in their own defense. No prosecutor or witness may comment (expressly
or implicitly) on a defendant’s exercise of either right or suggest that refusal to testify or
termination of a police interrogation demonstrates consciousness of guilt.

State v. Homel (2010)

It is axiomatic that identification of the defendant is an essential element of the charge in a
criminal trial. Whether or not the statute explicitly requires identification as an element of the
offense is a nonstarter. Common law tradition requires the identification of the defendant to
assure that the government has not charged the wrong person. Identification is a necessary
function to aid the government in its attempt to overcome the presumption of innocence that is
afforded every criminal defendant.

Trial Procedures

State v. Feliciano (2007)

In Midlands, all criminal trials are bifurcated with a guilt phase followed by a penalty phase.

State v. Schoeberl (2009)

During the guilt phase, evidence is not relevant if it is directed solely to the penalty to be given to
the defendant if found guilty. It also is improper for an attorney to comment on sentencing or
discuss potential penalties during the guilt phase of the trial. Such conduct is grounds for a
mistrial and may constitute conduct for which sanctions are appropriate.

State v. Ammerman (2002)

Under Midlands practice, both sides may always present evidence to prove or rebut any element
of a charged offense. Neither side may object to such evidence on the ground that the objecting
party is no longer pursuing (or challenging) the pertinent issue.

State v. Bilal (1945)

Unlike some jurisdictions, MRE 615 allows for the sequestration of the lead investigating officer
in a criminal case if that police officer is not elected to be the State’s representative during
pretrial matters.

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Gill v. Hiles (2014)

Civil case arising from alleged assault. The plaintiff was called as a witness and testified fully on
direct examination. On cross examination, however, the plaintiff failed to respond to some
questions, purportedly because of a condition arising from the assault. Held: The judgment for
the plaintiff must be reversed. The reason why the witness failed to respond to questions on cross
examination is immaterial. If a witness becomes unable or unwilling to respond to otherwise
proper questions on cross examination, the trial court must strike the witness’s testimony in its
entirety.

Character Evidence

State v. Gaston (1986)

Under MRE 404, general evidence of a defendant’s good character is not admissible. However,
under MRE 404(a)(1), a criminal defendant may offer certain evidence of a “pertinent” character
trait. The requirement that evidence be “pertinent” significantly exceeds the comparably low bar
of relevancy. “Pertinence” is a more exacting standard by which the trait itself must directly
relate to a particular element or facet of the crime charged.

State v. Kumar (2013)

Given the complex nature of the criminal prosecutions, the courts have been split on what
constitutes a “pertinent trait” under MRE 404 and State v. Gaston in conspiracy cases.
Accordingly, while this list is not exhaustive and every conspiracy case has different elements
and motives, we find that character traits pertinent to conspiracy cases to include being law-
abiding and a community caretaker. In cases where the underlying crime is a violent felony like
homicide, assault, robbery, burglary, or kidnapping, the same pertinent character trait of “non-
violence” that is relevant to the violent felony offense is also a relevant consideration in a
conspiracy to commit a violent felony case.

State v. Sun (2010)

In accordance with this Court’s reasoning and holding in the civil action of Estate of Hamilton v.
Walton last year, this Court hereby adopts the same reasoning and holding for criminal actions as
well. Testimony about a psychological condition does not constitute “[e]vidence of a person’s
character or character trait,” the only evidence excluded by MRE 404(a)(1).

State v. Young (2016)

Appellants challenge the decision of the district court to allow testimony by the State’s witness
rebutting properly noticed “good character” evidence from the defense under MRE 404(a) during
the State’s case-in-chief. Due to the lack of rebuttal witnesses in the State of Midlands, our rules
differ from other jurisdictions, particularly with respect to the presentation of character evidence.
We hold that the language of MRE 404(a) is clear, that if the defense “opens the door, by noting
its intention before trial to offer “good character” evidence, the State may use its case in chief to
offer “bad character” evidence of the defendant regarding the same traits enumerated by the
defendant, pursuant to the procedures outlined in MRE 405.

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State v. Hamdan (2010)

MRE 609 does not categorically exclude evidence of a witness’s prior criminal conviction
punishable by less than one year of imprisonment, especially when the offense was a crime of
moral turpitude like fraud, theft, or other crimes of dishonesty. Such evidence may still be
admissible, subject to the MRE, on a case-by-case basis.

Grounds and Basis for Evidentiary Rulings

State v. Harper (1975)

The beyond-a-reasonable-doubt burden does not apply to threshold matters involving the
admissibility of evidence. In Midlands, the proponent of evidence need only prove these
evidentiary matters by a preponderance of the evidence (i.e., it must establish that all elements
are more likely than not true).

Zomerfeld v. Noto (2012)

Under MRE 104(a), when evaluating the admissibility of evidence, a trial court is permitted to
rely on both admissible and inadmissible evidence. The use of underlying inadmissible evidence
does not make that inadmissible evidence admissible. Instead, the court is permitted to consider
the underlying inadmissible evidence to assess the admissibility of the offered evidence. In a jury
trial, the jury may not always be privy to the underlying facts used to determine what evidence is
admissible, but the Court may hear it. Previously upheld examples included using character
evidence to make ruling on hearsay exceptions, using hearsay to make a ruling on character
evidence, and using hearsay to decide whether an expert has adequate foundation to testify.

Foltz v. Young (1998)

Under MRE 104(a), courts may consider custodial documents, such as clerks’ certifications or
affidavits of records keepers, when determining the admissibility of other evidence without
regard for the admissibility of the custodial document itself. The custodial document typically
only addresses preliminary matters of admissibility and is not entered into evidence.

Authentication

Jacoby v. McKay (2002)

As long as the proponent of the statement produces evidence that would permit a reasonable jury
to find, by a preponderance of the evidence, that a given person made a particular statement, a
court assessing admissibility must assume that the statement was made by that person.

Ginger v. Heisman (2015)

Absent particularized reason to believe that the communication may have been sent by someone
else, the fact that an electronic communication (an email, text, or social media post) is listed as
coming from a number or account that is either known or purports to belong to a particular
person is sufficient foundation that the communication was sent by the person.

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Experts

Davis v. Adams (1993)

Trial judges must ensure that any scientific testimony or evidence admitted is not only relevant
but reliable. In determining reliability, judges should consider only the methods employed and
the data relied upon, not the conclusions themselves. The proponent of the evidence has the
burden of proving each section of MRE 702 by a preponderance of the evidence.

Tarot Readers Association of Midlands v. Merrell Dow (1994)

In assessing reliability under MRE 702(c), judges should consider whether the theory or
technique has been or can be tested, whether it has been subjected to peer review and
publication, whether it has a known error rate, and whether it has gained widespread acceptance
within the field. These factors, while relevant, are not necessarily dispositive. For example, lack
of publication does not automatically foreclose admission; sometimes well-grounded but
innovative theories will not have been published. There is no definitive checklist. Judges must
make such assessments based on the totality of the circumstances.

Richards v. Mississippi BBQ (1997)

Midlands Rule of Evidence 703 does not permit experts to testify or present a chart in a manner
that simply summarizes inadmissible hearsay without first relating that hearsay to some
specialized knowledge on the expert’s part. The court must distinguish experts relying on
otherwise inadmissible hearsay to form scientific conclusions from conduits who merely repeat
what they are told. The testimony of the former is admissible; that of the latter is not. Of course,
statements that would otherwise be admissible are not inadmissible simply because they are
offered by or through an expert witness.

State v. Richardson (2017)

It was not an abuse of discretion for the trial court to allow the forensic pathologist to testify to
the cause and manner of death even though the pathologist was not tendered as an expert prior to
providing her testimony. Unlike other jurisdictions, Midlands does not require a party to “tender
an expert” before eliciting an expert opinion. Whether MRE 702 foundational requirements have
been satisfied is an evidentiary determination that rests within the sound discretion of the trial
court.

Ullrich v. Scarlet Lady Shipping (2023)

It was never the intention of this Court for its holding in Tarot Readers Assoc. and its progeny to
create a rigid and unyielding standard for expert opinions. It is very common for juries to hear
testimony from experts that utilized a comparative analysis when creating their report and
opinions. So long as the expert can sufficiently explain their expertise, training, and method for
review, Tarot Readers Assoc. shall not be used by trial courts to prohibit otherwise credible and
admissible opinions simply because there is not a known error rate or prior peer review of the
comparative analysis. Such questions and potential challenges of credibility are better left to
cross examination.

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Kane Software Co. v. Mars Investigations (1995)

Midlands does not permit parties to use their experts as weapons in a trial by ambush or for
unfair surprise. Expert reports that are exchanged prior to trial must contain a complete statement
of all opinions the expert will testify to and the basis and reasons for them, the facts or data
considered by the expert in forming their opinions, and the expert’s qualifications. Experts are
strictly prohibited from testifying on direct or redirect examination about any opinions or
conclusions not stated in their report, and such testimony must be excluded upon a timely
objection from opposing counsel. For example, an expert may not testify on direct or redirect
examination that they formed a conclusion based on evidence that came out during trial that the
expert did not previously review. However, if an expert is asked during cross-examination about
matters not contained in their report, the expert may freely answer the question as long as the
answer is responsive.

State v. Dawson (2012)

The historical practice of all Midlands circuit court criminal divisions has been proven to be
consistent with the holding of Kane Software Co. v. Mars Investigations (1995) for criminal
trials. We interpret the Midlands Rules of Criminal Procedure to be consistent with Kane as well.
Thus, there can be no doubt that our holding in Kane applies to criminal trials.

State v. Berzon and Jensen (2020)

Appellant-Defendants appeal their conviction. Specifically, Appellants argue that the trial court
improperly excluded testimony from the defense expert on the basis that certain testimony
amounted to "trial by ambush" under the precedent set by Kane Software Co. v. Mars
Investigations (1995) and State v. Dawson (2012). Appellants admit that the defense expert was
attempting to testify to certain underlying facts that were not expressly disclosed in the expert
report and that such facts contributed to th’e expert's conclusion, but they argue that the
conclusion itself was disclosed and thus it was unnecessary for every underlying detail to be
disclosed. We believe that the Appellants' argument has merit. Experts should not be expected to
include in their reports every basic scientific fact and known realities that support their
conclusion. Such a requirement would lead to expert reports that are hundreds, if not thousands,
of pages long. For example, an accident reconstructionist need not explain Newton’s laws of
motion in her report. However, if an expert wishes to testify that they believe the indentations on
a vehicle’s door mean that the vehicle collided with a streetlamp at 45 MPH, then measurements,
equations, and other relevant facts that form the basis for that specific conclusion must be
disclosed in the expert’s report. Reversed and remanded to the trial court for reconsideration
consistent with this decision.

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State v. Sutcliffe (2021)

Generally, law enforcement officers are not “experts” subject to Midlands Rule of Evidence 702
or this Court’s holding in Tarot Readers Association of Midlands v. Merrell Dow (1994) and its
progeny. However, law enforcement officers do have specialized training, skills, and experience
beyond the average citizen as contemplated by MRE 701, and may testify based on such
specialized knowledge. Insofar as a law enforcement officer is asked to provide an opinion based
on that officer’s general training, skills, and experience as a law enforcement officer (e.g.
whether the officer followed standard protocol in collecting evidence), the admissibility
thresholds of MRE 702 and Tarot Readers do not apply. Rather, the admissibility of a law
enforcement officer’s non-expert opinion is subject to the standards of MRE 701 and any other
applicable rule of evidence.

Hearsay

America’s Best Cookie v. International House of Waffles (2009)

The Court recognizes that practices differ in other jurisdictions. But, in Midlands, the definition
of “hearsay” includes out-of-court statements by a witness who is on the stand or by another
person who has or will be testifying in a particular trial.

State v. Kennan (1997)

Midlands Rule of Evidence 801(d)(2) may be invoked in only one direction in a criminal case.
Specifically, MRE 801(d)(2) permits the State to offer statements by a criminal defendant.
Subject to MRE 106, MRE 801(d)(2) does not permit the defense to offer the defendant’s own
statements, even if the State has already elicited other out-of-court statements by a defendant
during a preceding examination.

Moss v. Wiener (2015)

For purposes of MRE 801(d)(2), police officers, prosecutors, informants, and others working
with law enforcement officials are not an “opposing party” of a criminal defendant.

State v. Vanderslice (2012)

The business-records hearsay exception (MRE 803(6)) cannot be used to “back door” evidence
that would not be admissible in a criminal case under the public-records hearsay exception of
MRE 803(8)(ii).

State v. Velazquez (2015)

A public record of a criminal conviction is not a police report and, thus, is not excluded by MRE
803(8)(A)(ii).

State v. Sosa (1985)

MRE 801(d)(2) governs statements “offered against an opposing party.” This rule does not
require the proponent of the evidence to offer the statement “against the party’s interests” in
order to qualify as an exemption to hearsay under MRE 801(d)(2)—that language is notably only
found in MRE 804(b)(3). If the drafters of the MRE had wanted 801(d)(2) to only apply if the
statement was “against the party’s interest,” it would have drafted the rule as such.

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State v. Owens (2010)

For a statement to qualify under the hearsay exclusion of MRE 801(d)(2)(E), the proponent of
the statement must establish the existence of said conspiracy by a preponderance of the evidence.
In addition, the statement may be admitted conditionally, subject to MRE 104, meaning that the
proponent of such statements may lay proper foundation before offering the statements under
MRE801(d)(2)(E) or the trial court may allow the proponent to admit the statements first and lay
foundation for the predicate conspiracy during the remainder of the trial. As MRE 801(d)(2)(E)
makes clear, proof of conspiracy may be based, in part, on the statements themselves, but the
proof must also include some independent corroborative evidence. Pursuing a charge of
conspiracy is not required in order to seek the admission of statements via MRE 801(d)(2)(E).

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IN THE CIRCUIT COURT, CRIMINAL DIVISION

CHARLOTTE COUNTY, MIDLANDS

STATE OF MIDLANDS, *
Plaintiff, *
*
v. *
* STIPULATIONS
DE LA PORTA/CAMERON, *
Defendant. *
*
1. For the convenience of the parties, witnesses, court, and jury, all exhibits have been
pre-labeled and pre-numbered. Those numbers will be used for all purposes at trial
regardless of which party first offers the exhibit or the order in which the exhibits are
offered.
2. Both parties fully complied with their discovery obligations. No pertinent
information or evidence was withheld during discovery.
3. All parties and witnesses are of at least normal intelligence; none has or ever has had
a mental condition that would impact a person’s perception, memory, or ability to
respond to questions during a direct or cross examination.
4. All notice requirements of Midlands Rules of Evidence 902(11) and 902(12) have
been satisfied for all exhibits.
5. The parties and witnesses waive all objections arising under the U.S. Constitution.
6. Chain of custody was properly documented for all exhibits, and all exhibits have been
properly preserved prior to trial. For the purposes of this stipulation, “chain of
custody” refers to the movement of evidence from the location it was collected to a
law enforcement storage facility and/or Midlands forensics lab to the prosecutor’s
office for presentation at trial.
7. Other than issues related to MRE 404, 405, 608, and 609, any and all notice
requirements and/or other discovery obligations pursuant to the MRE and Midlands
Rules of Criminal Procedure have been satisfied by all parties.
8. Both parties agree that Exhibits 1 (charity gala invitation), Exhibit 2 (auction
brochure), Exhibits 3 (diagram of Miller Tower’s 40th floor), Exhibit 4 (diagram of
Miller Tower’s roof), and Exhibit 27 (medical report for Emory Sands) are
preadmitted and may be published to the jury at any time after opening statements.
The parties further agree that these exhibits may be referenced and shown to the jury
during opening statements.
9. All blood found on Exhibit 23 (mask) was matched to Emory Sands.
10. Exhibit 7 (ring) belongs to Poe Cameron.
11. Poe Cameron and Memphis Raynes are biological siblings and have the same gender
identity but are not identical twins (either genetically or in physical appearance).

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12. Both parties waive any hearsay objections to Exhibit 6 (receipt), as it is an exception
to the hearsay rule pursuant to R.803(6). Parties further waive any objections to
identification or authenticity of Exhibit 6; it is what it purports to be.
13. Both parties agree that the Sohi Hospital Charity Gala and its host’s nonprofit
organization satisfies the “museum, legitimate auction house, charity organization,
nonprofit organization, or similarly situated organization in lawful possession of any
object of cultural heritage” element of §18-668(B).
14. The Ivy Lane apartment complex is located in the Oakley neighborhood of Santa Ivo
which is 1.75 miles west of Miller Tower.
15. Both parties agree that Detective Kit Bahmani’s personal review and written
description of the October 31, 2022 Miller Tower security footage occurred prior to
the malware attack on the Santa Ivo Police Department and Federal Bureau of
Investigation’s servers on August 1, 2023 that resulted in the footage being
destroyed. Parties further agree that Detective Bahmani’s written description of the
security footage within Bahmani’s written report is an accurate depiction of what
happened in the video.
16. Both parties agree that Berkley F. De la Porta was not in Santa Ivo, Midlands on
October 31, 2022. Parties further agree that Federal Aviation Agency records confirm
De la Porta departed from Santa Ivo International Airport on October 30, 2022 on a
flight bound to Auckland Airport in New Zealand. De la Porta’s plane landed at
Auckland Airport 16h 10m later. De la Porta’s plane returned to Santa Ivo
International Airport on November 4, 2022.
17. Both parties agree that Berkley F. De la Porta is a majority owner of Midlands Santa
Ivo Group (“MSIG”) and a majority owner of MSIG’s subsidiary companies
Goodspeed Industries and Matchstick & Sons.
18. Defendant has knowing, intelligently, and voluntarily waived any and all objections
based on the Sixth Amendment’s Confrontation Clause.
19. Both parties agree that the blockchain records collected in this case by Agent Shar
Burke are properly described and reflected in Agent Burke’s report. Parties further
agree that the blockchain records are too voluminous to be offered into evidence as
an exhibit.
20. The Morisot paintings, Paysanne Nouvelle dans les Terres, Halva Dans les Terres,
and Dans les Terres du Millieu, that were on display at the October 31, 2022 Sohi
Hospiral Charity Gala and were placed in the Miller Tower 40th floor vault after the
auction were the original versions of those paintings and were not forgeries.
21. The jury instructions in this case are based on the recommended jury instructions
from the Midlands Jury Instructions templates drafted by the Supreme Court of
Midlands. Both parties have reviewed and agree that the jury instructions in this case
are an accurate statement of the law. Both parties have waived all objections to the
jury instructions.
22. Both parties waive all hearsay objections to Exhibhits 14, 15, and 16.

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IN THE CIRCUIT COURT, CRIMINAL DIVISION

CHARLOTTE COUNTY, MIDLANDS

STATE OF MIDLANDS, * CASE NO.: CR2023-08-0992

Plaintiff, *
*
v. *
* SUPPLEMENTAL STIPULATIONS
BERKLEY F. DE LA PORTA, *
Defendant. *
*
1. Prior to Berkley F. De la Porta’s trial, Poe Cameron entered a guilty plea to
Aggravated Robbery, Kidnapping, and Conspiracy to Grand Theft for Cameron’s role
in the armed heist that occurred at the Miller Tower on October 31, 2022 in Santa
Ivo City, Charlotte County, Midlands.

2. At the time of Berkley F. De la Porta’s trial, Poe Cameron still awaits sentencing.
Therefore, Cameron is unavailable to testify for either party in the above-captioned
case.
 Revised 12/12/23

IN THE CIRCUIT COURT, CRIMINAL DIVISION

CHARLOTTE COUNTY, MIDLANDS

STATE OF MIDLANDS, *
Plaintiff, *
*
v. *
* ORDER ON MOTIONS
DE LA PORTA/CAMERON, * IN LIMINE
Defendant. *
*

This matter is before the Court on several pre-trial motions filed by the State of
Midlands and Defendant. The Court rules on the following issues and reserves ruling on
all other evidentiary issues until proper objection at trial. The rulings set forth herein
may not be revisited at trial.

Preemptory Character Evidence

The court first addresses a pretrial motion by the State of Midlands to compel
notice from Defendant of any character evidence of the accused or of the victim that
Defendant intends to offer under Mid. R. Evid. 404(a). Defendant objected to the State’s
request for notice.
In other jurisdictions, if the Defense elected to introduce character evidence, the
State would be afforded the opportunity to offer rebuttal witness testimony following
Defense case-in-chief. However, for better or worse, Midlands’ focus on judicial
economy has created a unique local rule that prohibits the State from calling rebuttal
witnesses. Therefore, this Court GRANTS the State’s motion to compel and orders as
follows:
1. Defendant must provide the State of Midlands with notice of any intent by
defendant to offer evidence of the character of Defendant or victim
pursuant to R. 404(a)(1). Defendant must indicate the specific traits,
including pertinent traits, of character intended to be pursued.
2. Upon receipt of notice by Defendant that Defendant intends to offer
evidence under R. 404(a)(2), the State of Midlands may elect to pursue
“preemptory rebuttal evidence” of competing traits during its case-in-
chief. If Defendant does not provide notice of its intent to offer R.
404(a)(2) evidence, neither party may introduce such evidence at trial.

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3. The State of Midlands must, as always, offer similar notice to Defendant

regarding its intent to offer any evidence of prior crimes, wrongs, or acts,
pursuant to R. 404(b), and whether it will offer evidence of the alleged
victim’s trait of peacefulness to rebut evidence that the victim was the first
aggressor under R. 404(A)(2)(c).

Tarot Readers Assoc. Ruling

The court held an evidentiary hearing regarding pretrial motions related to the
admissibility of expert testimony that were filed by both parties pursuant to Tarot
Readers Association of Midlands v. Merrell Dow (1994). The Court finds that both
listed expert witnesses in this case, M. Nguyen and Amarii Ebi, qualify as an “expert”
based on their knowledge, skill, experience, training, or education. However, this Court
will reserve ruling on the admissibility of the case-specific opinions of each expert
pending the appropriate foundation being laid in trial pursuant to Mid. R. Evid. 702.
Moreover, consistent with the Midlands Supreme Court’s holding in State v.
Sutcliffe (2021), this Court further finds that, as law enforcement officers, Detective Kit
Bahmani and Agent Shar Burke have specialized knowledge, skills, and training beyond
that of everyday citizens; however, Bahmani and Burke are not “experts” as
contemplated by R. 702 that are allowed to provide “expert” scientific conclusions like
Nguyen or Ebi. For example, Bahmani and Burke may testify to proper law enforcement
protocols for collecting evidence or conducting interviews with witnesses and suspects,
but Bahmani and Burke shall not offer opinions on the validity of Nguyen’s forensic
tests. Being a law enforcement officer does not allow the State to use that witness as a
conduit for admitting expert opinions that require Rule 702 foundation. However, if the
opinion evidence is limited to general police procedures or explaining why particular
investigative decisions were made in this case, the Court is inclined to admit the
evidence and provide a limiting instruction to the jury.

Now, the Court also understands that the State may offer Agent Burke as an
expert in the area of cryptocurrency investigations and digital forensics. The court
makes no determination as to whether Agent Burke’s qualifications or opinions meets
the standards of 702—as those are questions for the trial court. However, this court does
find that Agent Burke’s opinions listed in the section titled “Digital Forensics to Identify

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Heist Participants” could be expert opinions, provided the proper foundation is laid
under Mid. R. Evid. 702 and the applicable case law. Agent Burke’s opinions in this
section alone could be given the status of “expert” opinions. Any other sections of Agent
Burke’s reports otherwise fall into the category of evidence of law enforcement officers
as stated in the above paragraph.

Malware Attack and Lost Evidence

The Defendant is asking this Court to dismiss the indictment because the State of
Midlands and Federal Bureau of Investigation (“FBI”) were the victims of a malicious,
coordinated cyberattack that resulted in the Santa Ivo Police Department and FBI losing
multiple pieces of evidence that were material to guilt or punishment. The Court denies
the Defendant’s request. An indictment that is valid on its face is a sufficiently valid
pleading to proceed to trial.
In the alternative to a motion to dismiss, the Defendant also requested this Court
prohibit the State of Midlands from offering any evidence based on the lost digital
evidence. The Defendant’s motion is not well taken and is denied.
An evidentiary hearing was held on this matter. The Defendant was given an
opportunity to present evidence of wrongdoing by the State of Midlands or FBI and
failed to do so. Specific to the digital evidence lost in the cyberattacks on the Santa Ivo
Police Department (“SIPD”) and FBI’s evidence storage servers, this Court finds that
the Charlotte County Prosecutor’s Office, the SIPD and FBI (1) did not violate any rules
of criminal procedure; (2) did not engage in any acts worthy of sanctions; (3) did not
cause the malware cyber-attack that occurred on its servers; and (4) were the victims of
a coordinated cyberattack to destroy evidence related to this case and this case only.
Therefore, this Court will not prohibit testimony about the collection of the now lost
evidence. Furthermore, Detective Bahmani and Agent Burke are permitted to testify to
their recollection of what the evidence was without violating the “best evidence rule”
(Midlands Rules of Evidence 1002).
Defendant may, however, object to testimony that goes beyond Detective
Bahmani and Agent Burke’s personal recollections of what they saw, heard, or otherwise
experienced in collecting or reviewing the evidence. The best evidence of Detective
Bahmani and Agent Burke’s personal experiences is their own individual memories.

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However, a witness may not attempt to backdoor otherwise inadmissible evidence by

using “I recall” or “I remember” or some similar phrase. For example, Detective
Bahmani may not testify to impermissible hearsay simply because the Detective says, “I
remember (witness name) saying….”
Similarly, Agent Burke may not testify to the contents of financial records as fact
without those documents being present, but rather must clearly state only what Agent
Burke recalls about those records. For example, Agent Burke is prohibited from stating,
“the financial record showed a transaction occurred” on a date certain. However, Agent
Burke may testify “I believe a transaction occurred” on a date certain. The distinction is
an important one. The former statement would be testimony about statements
contained in a financial record that no longer exists. Such testimony would be
prohibited under Article VIII and Article X of the Midlands Rules of Evidence. Whereas
the latter statement is merely a statement of belief by Agent Burke that is subject to the
scrutiny of cross examination.
Finally, Defendant is permitted to cross-examine Agent Burke and Detective
Bahmani on the loss of evidence but is prohibited from arguing or even suggesting that
the Charlotte County Prosecutor’s Office, Burke or Bahmani or their respective agencies
were responsible for the cyber-attack and subsequent loss of evidence. This Court has
already ruled on that issue and Defendant is prohibited from continuing to pursue that
line of argument during witness testimony, opening statement, and closing argument.
This ruling governs all evidence listed in Exhibit A which is attached to this Order.

So Ordered,
E. V. Lynne
Date: August 14, 2023 Hon. E. V. Lynne

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IN THE CIRCUIT COURT, CRIMINAL DIVISION

CHARLOTTE COUNTY, MIDLANDS

STATE OF MIDLANDS, *
Plaintiff, *
*
v. *
* EXHIBIT A
DE LA PORTA/CAMERON, *
Defendant. *
*

The following pieces of digital evidence were lost during the cyber-attack against
the Santa Ivo Police Department and FBI evidence servers on August 1, 2023 and any
discussion during trial of these items is controlled by this Court’s August 14, 2023
Order:

a. Screenshot of dark web auction site (taken by Agent Burke; 12/22/22)

b. Recording of “Morisot Mastermind” call with Confidential Informant (recorded
by Agent Burke; 12/23/22)
c. Recordings of Poe Cameron 11/21/22 and 12/5/22 interviews
d. Screenshot of encrypted chatroom (taken by Agent Burke; 12/24/22)
e. Financial records for Bern-Steel Ltd, Goodspeed Industries, and Matchstick &
Sons (collected by Agent Burke)
f. All security footage from Miller Tower on 10/31/22 (collected by SIPD)
g. Miller Tower M10T Vault security system access log for 10/31/22 (collected by
SIPD)
h. Miller Tower 40th floor security system access log for 10/31/22 (collected by
SIPD)
i. Miller Tower M10T Vault specification documents (collected by SIPD)
j. Pictures of Emory Sands’s injuries (taken by SIPD; 10/31/22)
k. Pictures of shredded paper scraps collected from Ivy Lane (collected by SIPD;
12/3/22)
l. Witness interview and investigation notes (written by Detective Bahmani)
 Revised 12/12/23

IN THE CIRCUIT COURT, CRIMINAL DIVISION

CHARLOTTE COUNTY, MIDLANDS

STATE OF MIDLANDS, *
Plaintiff, *
*
v. *
* JURY INSTRUCTIONS
DE LA PORTA/CAMERON, *
Defendant. *
*

A defendant is charged with criminal offenses through an indictment. You must

not let the existence of an indictment influence you in any way. An indictment is simply
a legal document to provide notice to a defendant of the offense(s) alleged by the State
of Midlands. You must find the defendant not guilty unless you find that the State of
Midlands has proven beyond a reasonable doubt that the defendant is guilty of every
element of every offense(s) argued here today.

INSTRUCTION NO. 1: OFFENSE(S) CHARGED

You will find the defendant, guilty if, and only if, the government has proven
beyond a reasonable doubt all of the elements of the offense(s) as listed in the attached
Superseding Indictment.

INSTRUCTION NO. 2: STATE OF MIND DEFINITIONS

Knowledge: A person acts knowingly if they are aware that their conduct will
result in a certain outcome. In other words, a defendant acts knowingly if they are
aware that it is practically certain that their conduct will cause a specific result.

Purposefully: A person acts purposefully when that person acts with the intent to
cause a certain result.

Recklessly: A person acts recklessly when, with heedless indifference to the

consequences, the person disregards a substantial and unjustifiable risk that the
person’s conduct is likely to cause a certain result or is likely to be of a certain
nature.

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INSTRUCTION NO. 3: OTHER RELEVANT DEFINITIONS

A. Serious bodily harm to any person: Any injury, illness, or other physiological
impairment, regardless of its gravity or duration, that carries a substantial risk of
death.
B. Substantial risk: A strong possibility that a certain result may occur or that
certain circumstances may exit. The opposite of a remote or insignificant
possibility.
C. Occupied structure: A dwelling or place of residence where a person or persons
are permanently or temporarily dwelling even if no one is actually present at the
time of the offense. A structure will still be considered to be an occupied structure
if at the time of the offense any person was present or was likely to be present in
it.
D. Purpose to defraud: An offender acts with the “purpose to defraud” if the offender
knowingly obtains some benefit for the offender or another person by deception,
or they knowingly caused some detriment to another person or entity by
deception.

INSTRUCTION NO. 4: CONSPIRACY (**if relevant**)

The government has charged defendant with the inchoate offense of conspiracy. An
inchoate offense is a type of crime that is committed by taking a punishable step towards
the commission of another specifc crime. Therefore, the government must prove that the
defendant (1) entered into an agreement with another person or persons to engage in
conduct that constitutes a specific crime or an attempt or solicitation to commit that
specific crime, and (2) a party to the corrupt agreement took an overt act in furtherance
of that agreement. An overt act is a volitional act.

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INSTRUCTION NO. 5: AGGRAVATED ROBBERY (**if relevant**)

The government has charged defendant with the offense of aggravated robbery.
Therefore, the government must prove that the defendant (1) took the property of another
person(s) or attempted to take the property of another person(s) (2) against their will (3)
with the intent to deprive the owner(s) of said property (4) by means of violence or an
imminent threat of force against such other person(s) and (5) knowingly caused or
attempted to cause serious bodily harm to another person(s) or caused bodily injury to
another person(s) with a deadly weapon.

INSTRUCTION NO. 6: AGGRAVATED BURGLARY (**if relevant**)

The government has charged defendant with the offense of aggravated burglary.
Therefore, the government must prove that the defendant (1) entered a building or
occupied structure or separately secured or occupied portion thereof (2) with the purpose
of committing a crime therein and (3) knowingly caused or attempted to cause serious
bodily harm to another person(s) or caused bodily injury to another person(s) with a
deadly weapon.

INSTRUCTION NO. 7: AGGRAVATED ASSAULT (**if relevant**)

The government has charged defendant with the offense of aggravated assault. Therefore,
the government must prove that the defendant (1) caused or attempted to cause serious
bodily harm to another person(s) purposefully, knowingly, or recklessly under
circumstances manifesting extreme indifference to the value of human life or (2)
purposefully or knowingly caused or attempted to cause bodily injury to another
person(s) with a deadly weapon.

INSTRUCTION NO. 8: KIDNAPPING (**if relevant**)

The government has charged defendant with the offense of kidnapping. Therefore, the
government must prove that the defendant (1) attempted to take or took another
person(s) from one place to another place against their will or (2) purposefully confined
another person(s) to a controlled space.

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INSTRUCTION NO. 9: GRAND THEFT (**if relevant**)

The government has charged defendant with the offense of grand theft. Therefore, the
government must prove that the defendant (1) stole or obtained possession by means of
fraud (2) any object(s) of cultural heritage (3) from the care, custody, or control (4) of a
museum, legitimate auction house, charity organization, nonprofit organization, or
similarly situated organization (5) in lawful possession of such object(s) of cultural
heritage.

INSTRUCTION NO. 10: RECEIVING STOLEN PROPERTY (**if relevant**)

The government has charged defendant with the offense of receiving stolen property.
Therefore, the government must prove that the defendant (1) received, concealed,
exhibited, or disposed (2) of an object(s) of cultural heritage (3) knowing that such
object(s) (4) had been stolen or obtained by fraud (5) from the care, custody, or control
(6) of a museum, legitimate auction house, charity organization, nonprofit organization,
or similarly situated organization.

INSTRUCTION NO. 11: WIRE FRAUD (**if relevant**)

The government has charged defendant with the offense of wire fraud. Therefore, the
government must prove that the defendant (1) knowingly created or participated (2) in a
scheme to defraud another person (3) out of money or property (4) with the intent to
defraud (5) wherein it was reasonably foreseeable (6) that the defendant would use wire
communication and (7) the defendant did use wire communications (8) in furtherance
of the offense.

An intent to defraud is an intent to deceive or cheat another person or person. Deceitful

statements or half-truths may constitute false or fraudulent representations that can be
used as proof of an intent to defraud if the statements were made with an intent to trick
another person or persons out of their rightfully owned property or money.

The deceitful acts or statements do not have to be conducted solely through wire
communications in order to constitute wire fraud. Rather, a wire communication must
be used to carry out or attempt to carry out an essential part of the overall scheme.

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INSTRUCTION NO. 12: PRESUMPTION OF INNOCENCE

The law presumes a defendant to be innocent of a crime, and the indictment shall not be
considered as evidence or as having any weight against the defendant. You shall find the
defendant not guilty unless you are satisfied from the evidence alone and beyond a
reasonable doubt that the defendant is guilty. If upon the whole case you have a
reasonable doubt as to guilt, you must find the defendant not guilty.

INSTRUCTION NO. 13: RIGHT TO REMAIN SILENT

The defendant is not required to testify, and the fact that a defendant does not testify
cannot be used as an inference of guilt.

INSTRUCTION NO. 14: DEFENDANT MAY ELECT TO TAKE ON BURDEN

The burden of proving the essential elements of the charge beyond a reasonable doubt
rests with the prosecution alone. However, as charged, the defendant may, though is not
required to, elect to take on a burden as well if a viable affirmative defense exists. If the
defendant elected to present an affirmative defense of duress, then the defendant must
prove that claim by the preponderance of the evidence, or simply put, by the greater
weight of the evidence. It is a lesser burden that beyond a reasonable doubt, but the
claim must still be more likely than not for the defendant to have met their burden. If
the defendant does not elect to take on this burden, then you need not consider whether
the defendant’s criminal offenses are legally justified as an act of duress, and you will
proceed in assessing the defendant’s guilt consistent with the other instructions given to
you by the court.

INSTRUCTION NO. 15: DEFENDANT ARGUED DURESS (**if relevant**)

First, the prosecution must prove, beyond a reasonable doubt, the elements of the
charged offense for which the defendant claims duress. Second, the defendant must
affirmatively concede the elements of the charged offense for which the defendant
claims duress. The defendant may concede the elements of the charged offense through
testimony of the defendant or through evidence presented by defense counsel on behalf

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of the defendant. A defendant is precluded from arguing the affirmative defense of

duress if the defendant failed to affirmatively concede all the material elements of the
charged offense for which the defendant claims duress. You are the sole judge of the
believability or credibility of the defendant’s claim of duress.

INSTRUCTION NO. 16: ARGUMENTS AND REMARKS OF COUNSEL

Remarks of the attorneys are not evidence. If the remarks suggest certain facts not in
evidence, disregard those remarks. However, you are to consider carefully the closing
arguments of the attorneys. Ultimately you must draw your own conclusions and decide
your verdict according to the evidence, under the instructions given to you by the court.

INSTRUCTION NO. 17: CREDIBILITY OF WITNESSES

It is the duty of the jury to scrutinize and weigh the testimony of witnesses and to
determine the effect of the evidence as a whole. You are the sole judges of the credibility,
that is, the believability, of the witnesses and of the weight to be given to their
testimony. In determining the credibility of each witness and the weight to give the
testimony of each witness, consider these factors:

A. whether the witness has an interest or lack of interest in the result of this trial;
B. the witness’s conduct, appearance, and demeanor on the witness stand;
C. the clearness or lack of clearness of the witness’s recollections;
D. the opportunity the witness had for observing and for knowing the matters
the witness testified about;
E. the reasonableness of the witness’s testimony;
F. the apparent intelligence of the witness;
G. bias or prejudice, if any has been shown;
H. possible motives for falsifying testimony; and
I. all other facts and circumstances during the trial which tend either to support
or to discredit the testimony.
Then give to the testimony of each witness the weight you believe it should receive.
There is no predetermined way for you to evaluate the testimony; instead, you should
use your common sense and experience.

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INSTRUCTION NO. 18: INTERPRETING EVIDENCE

When making your decision, you may rely on both direct and circumstantial evidence.
Direct evidence is testimony by a witness about what that witness personally did, saw, or
heard. Circumstantial evidence is indirect evidence from which the fact finder may infer
that another fact is true. Neither type of evidence should be given categorically more
weight than the other.

The State’s burden of proving its case beyond a reasonable doubt applies to each and
every element of the crime charged. This burden, however, does not operate on the
many subordinate, evidentiary, or incidental facts as distinguished from proof of the
elements of the crime or of an ultimate fact. Where, however, the State relies in whole or
in part on circumstantial evidence to prove an element of a crime, although each link in
the chain of evidence need not be proven beyond a reasonable doubt, the cumulative
impact of that evidence must, in order to support that inference, convince the finder of
fact beyond a reasonable doubt that the element has been proven.

INSTRUCTION NO. 19: UNANIMOUS VERDICT

The verdict of the Jury must be unanimous as to guilty or not guilty and be signed by
one of you as Foreperson.

DATE: ___________________ _______________________

JUDGE

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AFFIDAVIT OF CYPRUS COSMOS

1 After being duly sworn upon oath, the Affiant hereby states as follows: I am over 18 and
2 competent to make this affidavit. I was subpoenaed to testify, of course. I have far better things
3 to be doing now. But I must admit, it is rather flattering to know that you need me to see that
4 justice is done.
5 As you know, my name is Cyprus Cosmos. I am one of Santa Ivo City’s proudest
6 humanitarians, activists, and philanthropists. In fact, I dare say that my generosity and reputation
7 extend all throughout Midlands. I feel blessed to be able to help all the disadvantaged residents
8 of the state. Additionally, I am also an actor (you’ll remember my line from my role in Santa Ivo
9 City Theater’s production of Midland Summer Night’s Dream), a poet (I have a poem scheduled
10 to be published in my friend J.T. Tung’s online journal in 2025), and I fancy myself an emerging
11 visual artist (though I have yet to get started on that). People think that having such wealth and
12 fame makes life easy, but it does not. I cannot express how exhausting spa lunches and gallery
13 openings and charity dinners can be. It is a wonder that I am even able to maintain my esteemed
14 Executive Board position at Santa Ivo City University and Board of Directors position for the
15 Sohi Children’s Hospital.
16 Naturally, I know Berkley F. De la Porta, although I cannot say that I am a big admirer.
17 There is something a bit sinister about De la Porta, and I don’t say that just because De la Porta
18 always seems to be outbidding me at our charity auctions. Maybe it’s because De la Porta insists
19 on going by “B.F.” when no one knows what the “F” stands for, and De la Porta has a reputation
20 for always getting what De la Porta wants. Our paths often cross, and we have friends in similar
21 circles. We serve together on the Sohi Children’s Hospital Board of Directors, and we are both
22 long-time Executive Members of the Harper Country Club. More recently, we were supposed to
23 go in together as 50/50 investors ($500,000 each) in the newly renovated Peony Estates Winery,
24 but De la Porta backed out at the last moment. I heard from a mutual friend that De la Porta was
25 having some financial trouble and was unable to liquidate some of De la Porta’s assets.
26 At one time, we were much closer. In 2016, a year after we met, De la Porta invited me
27 and my partner to a screening on De la Porta’s yacht, the Hepburn. De la Porta was showing an
28 advanced screening of Olson’s Eleven—a picture filmed and produced by Trifecta

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29 Entertainment, right here in Santa Ivo City. The film starred Alex Grace (a close friend of De la
30 Porta, of course) as Brianne Olson, a Robin Hood-like thief who assembled a crew of misfits to
31 rob the fictional Alexis Blueblood, the owner of the real (and famous) Black Bear Casino. All
32 night, De la Porta kept saying how De la Porta thought De la Porta was just like the film’s hero
33 Olson. But those of us on the yacht kept looking at each other, as if we all knew that De la Porta
34 was much more like Blueblood than Olson. Someone even made a little joke about it, and De la
35 Porta said something like “when I end up robbing a casino, you’ll see that I’m the real hero.”
36 After that night, De la Porta and I were always cordial to each other, but more in a professional
37 sense. I was never invited back on the yacht, but it was probably because De la Porta had to sell
38 the yacht a couple months later when, as I heard, De la Porta couldn’t keep up the financing.
39 As I said, De la Porta and I are both on the Board of Directors for the Sohi Children’s
40 Hospital. We meet each month and sometimes more often if something important arises. Because
41 De la Porta and I are both on the Planning Subcommittee for our Annual Gala Auction, we met
42 every other week from mid-July 2022 through October 2022. De la Porta was actually the co-
43 chair of the seven-person Planning Subcommittee—something De la Porta said they wanted to
44 do for a long time. The committee selected Miller Tower as our location for 2022, put together a
45 special invitation list of a hundred and fifty of Midlands’s luminaries and affluent individuals,
46 and designed a general overview of the night’s artistic staging and dinner menu. We didn’t wade
47 too far into the details—that is for the less important people to do.
48 Our biggest task for the event was assembling the materials for auction. As is customary
49 for our gala, 90% of the sale price would go to the item’s owner, 5% would go toward the annual
50 gala fund, and 5% would go directly to the Sohi Children’s Hospital. This was an important year
51 for us because the Board was planning to construct a new hospital wing, beginning in 2026. Most
52 of the money for the wing is to come from donations for various naming rights, but we hoped to
53 supplement the endowment with funds from the yearly gala auctions.
54 The Planning Committee, including De la Porta and myself, worked tirelessly over the
55 summer of 2022 securing items for the auction. These items included statues, 18th- and 19th-
56 century artwork, rare jewelry, several authenticated pre-Revolutionary documents, and one of
57 Alexander Hamilton’s drafts of Federalist No. 78 of The Federalist Papers. The total pre-auction
58 valuation of the various items was around $24 million, which meant $1.2 million toward the new
59 hospital wing.

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60 I tried to get De la Porta to sell the gem of De la Porta’s collection, Dans les Terres du
61 Milieu, by the great French impressionist Berthe Morisot (valued at over $8 million), but De la
62 Porta laughed in my face. I knew this was probably not going to happen, because as everyone
63 knows De la Porta is a huge collector of Morisot paintings. De la Porta even has a not-so-secret
64 room which showcases the collection. I’ve never been in this room myself, but I heard from a
65 MSIG lawyer that De la Porta is secretly stashing there a couple of the Morisot paintings that
66 went missing from the Santo Ivo City Art Museum a few years ago.
67 Even though De la Pota was not going to auction Dans les Terres du Milieu,, De la Porta
68 said that they would lend the gala the Dans les Terres du Milieu painting for display purposes.
69 De la Porta bragged, “I know if my Morisot is on display, then Bancroft’s pride will get in the
70 way and they wouldn’t be able to resist having Morisot’s two companion paintings that are
71 owned by Bancroft Estates be displayed at the auction as well.” I remember that De la Porta told
72 me that De la Porta had unsuccessfully tried for years to purchase the two companion Morisot
73 paintings held by Bancroft Estates. “Those greedy scumbags won’t let their dirty hands off those
74 great works, and they won’t even take my calls anymore. My calls.” Something clearly changed
75 because not only did Bancroft Estates take De la Porta’s call, but somehow De la Porta got
76 Bancroft Estates to agree to loan the gala their Morisot companion paintings so that De la Porta’s
77 Dans les Terres du Milieu could be viewed as a set just like Morisot intended. It was att our
78 Planning Committee meeting during the first week of August, that De la Porta told everyone the
79 good news. “It’ll be good to have the pieces there,” De la Porta said, “even if they’re not for sale.
80 I will figure something else out.” I did not know what else De la Porta had in mind, but, De la
81 Porta always says when there is a dispute, “De la Porta eventually gets what De la Porta wants.”
82 I was curious about how De la Porta managed to get Bancroft Estates to change their mind, so I
83 joined in on one of the phone calls between De la Porta and the Art Manager at Bancroft Estates.
84 I heard De la Porta give a “personal guarantee as a Morisot fanatic that I (De la Porta) would
85 make sure the paintings would be handled with great care to, from, and in the vault. Safe passage
86 in and out of Miller Tower guaranteed with your paints returned the next day guaranteed!”
87 Everything else leading up to the gala seemed to go according to plan. I oversaw the
88 decoration arrangements. De la Porta was in charge of where the auction items would be placed
89 for viewing. De la Porta also wanted to make sure that the items would be kept in extra-secure
90 spaces (the Miller Tower has a secure vault on its 40th floor and extra security guards would be

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91 hired for the event). To this end, Director of Security at Miller Tower, Emory Sands, told me that
92 De la Porta spent quite a few afternoons at Miller Tower going over all the security arrangements
93 with their staff and guards. I accompanied De la Porta on one of these afternoons, a week before
94 the auction. The Miller Tower event staff was setting up for a different event that night, so the
95 floor was already buzzing, but we were still able to walk through the space with a security team,
96 double-checking what the set-up would be for our upcoming event. Each of the organizers for the
97 charity gala were given individual keycards so that we would have special access to some of the
98 more secure locations. During our walkthrough of the 40th floor, security told all the event
99 organizers that we could keep our phones if we didn’t take them out during the tour (they didn’t
100 want anyone taking pictures inside). Joking, De la Porta said, “don’t worry if you want to know
101 all the vault blueprints and how the security system works just ask because I have it all
102 memorized,” and we all laughed. We then all left the vault area, except De la Porta, who hung
103 back beside the open vault door to take a phone call. I am pretty sure I heard De la Porta say, “I
104 can send a snapshot of the vault spec—” but I was walking away so I can’t be 100% sure. After
105 most of the group dispersed, De la Porta found me in the North Staging Area of the 40th floor. “I
106 have to show you something,” De la Porta told me, and took me down the hallway to the
107 staircase accessing the roof. De la Porta slid the Miller Tower security keycard through the
108 mechanism, the door unlocked, and we were headed up the staircase. It was one of the most
109 amazing views of Santa Ivo City I had ever had!
110 October 31—the day of the 2022 gala—soon arrived. The executive assistant to the Chair
111 of the Board of Directors for the Sohi Children’s Hospital called me around 11am to tell me that
112 De la Porta had called the hospital earlier that morning. The executive assistant said that De la
113 Porta said that their cousin was in a car accident the night before, and De la Porta wouldn’t be
114 able to attend our gala. This was unbelievable. De la Porta had never missed one of our annual
115 galas, and De la Porta was supposed to offer some of the opening remarks. Of course, I said I
116 would be honored to offer those remarks instead.
117 I arrived at the gala at 5:30pm. It is usually important for me to arrive late, so that I can
118 make a grand entrance, but this time I wanted to make sure everything was arranged. Some of
119 the flowers were in the wrong places and the greeting table in the Entryway was situated in the
120 wrong spot, so I took care to let the help know this needed to be fixed. It was good I got there
121 early. Soon after these things were moved around, the spaces looked impeccable—clearly due to

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122 my tireless work on the Planning Committee. I am sure others helped, too, though. Around 6pm,
123 the security detail started to bring our auction items to the Cocktail Room. The plan was to have
124 a cocktail hour accompanying our silent auction. Our guests would mingle, masked in their
125 Halloween attire, as they walked around the Cocktail Room submitting bids on our magnificent
126 items. We wanted to keep the bidding time short, in order to keep the pressure up. (Our guests
127 were provided a beautiful brochure of most of our auction items, including all of our featured
128 items, two weeks earlier.) The auction items were all secured in the Cocktail Room by 6:20, and
129 ten minutes later the room was opened for the guests. I could see about a half dozen members of
130 the security team safeguarding the room, and there were others patrolling the 40th floor. Berthe
131 Morisot’s Dans les Terres du Milieu (De la Porta’s painting) was the clear treasure of the
132 evening. Placed between its two Morisot companion pieces, its beauty and value shone. I can’t
133 even imagine how much they would have gone at auction (if their owners had wanted to sell).
134 The cocktail hour went well. Most guests remembered to dress up in costume. I didn’t
135 recognize many of these costumes, though. I imagine they were all Tikchat or TwitterTube stars.
136 I asked a couple about two of the masks I didn’t recognize, and they said they were dressed as
137 Kelly Doos and I can’t remember the other one. But I do remember that, later in the week, the
138 police asked me about some of the masks I had seen. Santa Ivo City’s own Mayor Leapheart was
139 in attendance, as were Drew Walton Jr. (whom I hear is considering a gubernatorial run),
140 councilmembers Kenough, Zeigler, and Racheter, and I swear I caught a glimpse of Blake
141 Lexington as well! There was even someone dressed as the mayor. If you weren’t close enough,
142 you wouldn’t be able to tell them apart. I could see our guests place auction bids via the secure
143 app designed by De la Porta’s company, MSIG. About fifteen minutes before the bidding was
144 supposed to end, one of the clumsy servers dropped a tray of hors d’oeuvres in the middle of the
145 room, startling everybody and halting the conversations and bidding momentarily. I kindly
146 informed the server (obviously, I didn’t know the server’s name) that they were perhaps better
147 off remaining in the kitchen the rest of the night. I often have a good sense of what is best suited
148 for those struggling common people. As was our tradition for the last couple years, at 7:29, we
149 gave our 1-minute warning and then a reminder with 30 seconds to go, and then everyone did a
150 countdown from twenty for the bidding to close. There was a loud ovation once we hit zero, and
151 afterward the servers begin to motion our guests into the Ballroom.

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152 Despite the night’s energy, our guests were sluggish departing the Cocktail Room, but by
153 around 7:35pm they had all taken their seats at the couple dozen large round tables in the
154 Ballroom. The sun had gone down, and the sunset colors through the windowed wall were
155 simply extraordinary. The first courses of dinner were served around 7:45pm. During this time,
156 the security team was tasked with returning the auction items to the vault through the event
157 staging area. They would then secure and seal the vault. At 8:00pm, we began our award
158 ceremony in the Ballroom. Although I was not asked to deliver the opening remarks (another
159 Board member was asked), they still went well. We then recognized the hospital’s major donors,
160 our top doctors, and bestowed our “Caring Professional of the Year” award and the highly
161 cherished “Adolescent Medical Technician Award.” Then, a few minutes after 8:30pm, we
162 began to announce the auction winners.
163 Just before 9pm, the announcements had concluded, and it was now time for celebration.
164 We had raised $1.25M for the Sohi Children’s Hospital. I was proud that this had been in no
165 small part thanks to my individual efforts. We were instructed to return to the Cocktail Room for
166 dancing and dessert. The staff had already set up the beautifully arranged dessert tables along the
167 back wall, and the bistro tables from earlier had been removed so that the center of the room
168 could be free for dancing. By now, most of the waitstaff had already left for the night. The music
169 was thunderous, and our guests had been appropriately satiated. I wanted to call De la Porta to
170 tell them how well the night went but, oddly, my cell phone was not working. I thought nothing
171 of it. A few minutes later, I tried again. This was at 9:21pm. I remember seeing that time
172 explicitly on the cell phone. I asked the two guests beside me if their phones were working; one
173 (implausibly) did not have a phone and the other’s phone was also not working. I excused myself
174 and headed to the Entryway beside the elevators.
175 As I walked toward the Entryway, I saw two people come out from behind the event
176 staging area door and into the Cocktail Room. They were not wearing a full costume that I
177 recognized from earlier that evening. One of them was wearing a black ski mask (how unoriginal
178 for a Halloween party!). The other person had a mask on top of their head, but it wasn’t covering
179 their face at all. At first, the maskless person was standing so that I could only see a side profile
180 of their face. It was a bit dark, but the maskless person had the same skin color, eye color, hair
181 color, and face shape as the pictures I saw of Poe Cameron on Blitz News Network. I was able to
182 clearly see the profile view of Cameron’s face for 10 seconds before Cameron and I made eye

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183 contact and Cameron quickly pulled the mask down to cover Cameron’s face. Once Cameron
184 had the mask on, Cameron turned towards me, for maybe two or three seconds to see if I was
185 still watching them so I was able to clearly see the mask Cameron had pulled down over
186 Cameron’s face. I recognized the mask Cameron put on as one that I had seen earlier during the
187 cocktail hour.
188 I yelled out, “hey, what are you two doing? This is a private event! Show me your
189 invitations!” It was at that point that I noticed that the security guards were strangely absent from
190 the Entryway. Cameron and the other person in the ski mask looked at each other. They didn’t
191 speak but Cameron gestured Cameron’s head towards me twice and then Cameron raised their
192 shoulders like it was a question. The person in the ski mask nodded and started to reach for their
193 back pants pocket. Suddenly, a member of the waitstaff appeared through one of the Ballroom
194 doors. When I turned to look, Cameron and the other masked individual pushed past me and ran
195 into the Entryway. When I turned back around, I didn’t see exactly where they went but I saw the
196 leg of Cameron (it matched the dark outfit they were wearing) disappear into the emergency exit
197 stairway.
198 I very politely but sternly asked the server (I later learned was named Parker something
199 or other) where the security guards had all gone. The server seemed stunned, so I grabbed the
200 server’s arms, shook them, and told the server to take me through the staging area to the Security
201 Office. We reached the Security Office at precisely 9:30pm. (There is a large clock on the wall
202 outside it.) No one was there. We knocked loudly on the door anyway, in case anyone was
203 picking up paper clips behind the desk or whatever those people do in the downtime when they
204 are supposed to be working. Nothing. Suddenly, the server pointed out that the door to the vault
205 was open. We ran over and looked inside and saw someone wearing a security guard uniform
206 unconscious on the vault floor. I couldn’t see the person’s face at first. But once we got closer to
207 the person, I recognized the person to be Security Director Emory Sands! Sands was bleeding all
208 over and their eye was swollen to the size of a Fabergé egg. All at once, I realized what was
209 happening. We were being robbed! The Sohi Children’s Hospital Gala Auction was being
210 robbed! On impulse, I reached for my phone. Again, there was no signal. I told the server to stay
211 with Sands (I did not want to get any blood on my clothing), and I headed back into the
212 Entryway. As soon as I came through the doors, I saw a mass of police officers in the room and

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213 still others coming through the stairwell. I told them about Sands and collapsed onto the floor. It
214 was all just too much.
215 Even after the area had been secured, the police kept everyone there for hours, asking
216 questions and checking IDs. I was approached by Kit Bahmani and explained over and over the
217 plan for the gala and described all the auction items that were listed in our brochure including the
218 Morisot paintings that were on loan and just for display. Even though I hadn’t been in the vault
219 that night, I presumed all of the items, including the Morisot paintings, had been stolen. More
220 importantly, however, I kept telling Bahmani that they needed to release our guests. These were
221 the cream of the crop of Midlands, and they needed to go home after this terrible occurrence.
222 De la Porta called me the day after the gala, but I was still too shaken to talk. De la Porta
223 called me again the following day. This time, I answered. De la Porta wanted to know everything
224 that happened. After telling De la Porta about seeing Cameron (though I didn’t know Cameron’s
225 name at the time, I just described the individuals by the masks that I saw them wearing) and the
226 person in the ski mask when I was headed to the Entryway, I remembered about De la Porta’s
227 family emergency and felt incredibly rude to not ask about it. I asked De la Porta how their
228 cousin was doing. “What cousin?” De la Porta replied, adding “I don’t have any cousins.” Then
229 De la Porta began to ask me a lot of odd questions: “Did I see the faces of the individuals in the
230 Entryway?” (I told De la Porta that I saw the profile of the maskless person) “Did I recognize the
231 person that wasn’t masked?” (I told De la Porta that I didn’t recognize the maskless person.
232 Before I saw the news coverage with Poe Cameron’s picture, that was true.) “Did they leave
233 anything behind?” (I told De la Porta I didn’t know. I didn’t see anything left behind.) “Was
234 there a lot of blood?” (I told De la Porta Emory Sands was clearly injured and bleeding a lot.)
235 Then I told De la Porta that they might contact the police for better answers than I could give to
236 these questions. It was weird, De la Porta did not even ask about De la Porta’s prized Morisot
237 painting that was stolen along with the auction items. Luckily, the auction items were all insured,
238 so the owners will be getting their full value in compensation. Unfortunately, the Sohi Children’s
239 Hospital will not be getting any of its share. I am sure, though, that some of our very well-to-do
240 gala invitees will find it in their hearts to make a donation. For my part, I will be donating two
241 hundred dollars.

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242 I cannot believe De la Porta was arrested for this heinous crime. Clearly, De la Porta did
243 not do it. De la Porta was not even there that night. And why would De la Porta arrange to have
244 their own masterpiece stolen?! That just does not make any sense.
245 I am familiar with following exhibits:
246 Exhibit 1 is one of our invitations for the October 31, 2022 Sohi Children’s Hospital
247 charity gala at Miller Tower. It has not been altered in any way from when we mailed them out
248 to our guests.
249 Exhibit 2 is the auction brochure for the Sohi Children’s Hospital charity gala that was
250 held at Miller Tower on October 31, 2022. The brochure has not been altered in any way from
251 when we mailed them out with the invitations (Exhibit 2). All of the items contained in this
252 brochure, including the three Morisot paintings that were for display only, were stored in the
253 vault on the 40th floor of the Miller Tower. All of the items in this brochure, including the
254 Morisot paintings were stolen on October 31, 2022. This brochure has not been altered in any
255 way from the version that was mailed out to our guests.
256 Exhibit 3 is a diagram of the 40th floor of the Miller Tower. It accurately depicts the 40th
257 floor as it existed during our walkthroughs prior to and during the October 31, 2022 charity gala.
258 Exhibit 5 is a picture of a security keycard for Miller Tower. I was given a similar
259 looking security keycard as an organizer for the Sohi Children’s Hospital charity gala. This
260 exhibit is an accurate depiction of the security keycards that all of the organizers were given
261 prior to the October 31, 2022 charity gala.
262 Exhibits 18 and 19 are copies of articles that I have read. They are fair and accurate
263 copies of the articles. I have no reason to believe the information contained in the articles is
264 inaccurate.
265 Exhibit 23 is the mask that I saw Poe Cameron wearing in the 40th floor Entryway of the
266 Miller Tower during the Sohi Children’s Hospital charity gala on October 31, 2022.
267 Exhibit 25 is a photograph of Poe Cameron. It accurately depicts what Poe Cameron
268 looked like on October 31, 2022 when I saw Cameron in the 40th floor Entryway of the Miller
269 Tower during the Sohi Children’s Hospital charity gala.
270 Exhibit 26 is a photograph of someone that looks like Poe Cameron but clearly is not Poe
271 Cameron. I did not see this person on or before October 31, 2022.

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272 I swear or affirm the truthfulness of everything stated in this affidavit. Before giving this
273 statement, I was told I should include everything that I know may be relevant to my testimony,
274 and I followed those instructions. I know that I can and must update this affidavit if anything
275 new occurs to me until the moment before opening statements begin in this case.
276
277 ____________________________________
278 /s/CYPRUS COSMOS
279
280
281 Duly Subscribed and Sworn By Me:
282 ____________________________________
283 /s/MADHAVI SUBRAMANIAM
284 Notary Public
285

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AFFIDAVIT OF PARKER ORLOV

1 After being duly sworn upon oath, the Affiant hereby states as follows: I am over 18 and
2 competent to make this affidavit. I was subpoenaed to testify.
3 My name is Parker Orlov, and I live at 1985 Drake Boulevard in Santa Ivo City,
4 Midlands. I currently work for Blaire Osborne Catering, a subsidiary of ESTR-OVO Co. I’ve
5 worked various jobs in the foodservice and hospitality industry in the past. For a time, I even
6 worked at Chuggie’s Bar & Grill in Midlands Center. I had hoped to get a job there again after it
7 was rebuilt following the fire in 2020, but it is just too popular a place now. There are franchises
8 of Chuggie’s all over Midlands now. It’s like a cockroach that you just can’t kill. But in a good
9 way, you know? Everyone wants to work there, even in this strong labor market. Instead, I was
10 able to get a job with Osborne Catering as a server at special events.
11 I was working for Osborne Catering at Miller Tower on October 31, 2022—the day of the
12 art heist. We were hired directly by the Sohi Children’s Hospital to cater its annual gala event.
13 We catered this event the year before at the Harper Country Club, and, although I wasn’t there,
14 from what I heard it was a success. About a month before the event, the Osborne staff met with
15 the co-planners of the gala. This was on Sunday, September 25. I remember the date because we
16 were catering the Jahangir Jazz Jubilee later that evening. That day, we met at 10am on the 40th
17 floor of the Miller Tower (where the event would be held). The run-through was led by a
18 manager of the Miller Tower and Faulkner Heytens, one of the co-organizers of the gala. The
19 other co-organizer, Berkley F. De la Porta, and the head of security for Miller Tower were also in
20 attendance, but they arrived well after 11am. Although I never met De la Porta, I knew about De
21 la Porta from the feature interviews De la Porta gave in “So It Was Written” ezine (Exhibit 18)
22 and the “Santa Ivo Tech Talk” newsletter (Exhibit 19) I also learned from the Blitz News
23 Network that De la Porta has a bit of a reputation for being a fine art collector.
24 Anyway, on the day of the run-through, the Osborne staff was given a tour of the 40th
25 floor of the Miller Tower, and we went over the scheduling plan for the gala night. The catering
26 menu had already been set, but we still needed to get a sense of where and when everything
27 needed to be laid out. We were shown the Entryway, the Ballroom, and the Cocktail Room
28 spaces and told how the gala guests would be moving through these rooms throughout the night.
29 We were given a detailed tour of the newly renovated kitchen. The head of Miller Security saw
30 some cans of paint thinner in the corner there and told one of the employees of Miller Tower to

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31 remove them ASAP. We were also shown the Event Staging Areas, which were located behind
32 these main rooms. We were going to be given access to the entire 40th floor of the tower, except
33 we were told to stay away from the Vault Area. I noticed that when we were escorted through the
34 hallway in front of the Vault, De la Porta held back and started speaking with someone in the
35 Security Office. I heard De la Porta say, “I’d like to get another look inside one day soon when
36 fewer people are around. Is there any way I could get my own key?” We were brought back into
37 the Cocktail Room and that was when the head of security spoke about the expensive artwork
38 that would be in there, reminded us to be careful walking around the room while the artwork was
39 there, and told us to contact one of the guards if we saw anything out of the ordinary the night of
40 the gala. Now, back with the group, De la Porta chimed in too: “You’d better be especially
41 careful with my Morisot painting. Oh, and, of course, with the two Morisots I sweet talked
42 Bancroft Estates to finally let out of their control. It would be a shame if those never made it
43 back to them. I personally guaranteed them that those paintings would be kept safe.” We were
44 also shown a brochure for the items that were going to be auctioned off. I have to admit—the
45 Morisot paintings were beautiful. It’s a good thing none of the staff were to be left alone with
46 them. Only the security officers were allowed to handle the auction items and the Morisot
47 paintings.
48 When we were walking out of the Vault Area back into the Event Staging Area, the
49 group stopped in the hallway. I heard one guard joke to the other, “What are we even hired for?
50 This vault is impossible to crack. But I’m happy to take a check to take a nap.” De la Porta, who
51 was standing a few feet away, snapped, “What did you just say? I plan to keep all these auction
52 items safe. If you and the rest of the security staff aren’t up to the job, then I can call in my own
53 MSIG security staff. The only time an MSIG vault has been breached was when the guards fell
54 asleep on the job and left their key out to be stolen. Human error is the only thing MSIG cannot
55 prevent. Was hiring you an error?” The guarded sputtered in reply, “oh no! Of course not, it was
56 just a joke. Sorry, boss!” De la Porta smiled and said, “I plan on keeping my word. All of the
57 auction items will be safe. I will not allow your ineptitude, or any other security guard’s
58 ineptitutde, to tarnish the MSIG name again!” De la Porta stormed off and we all stood there in
59 awkward silence for a few seconds, while the guard looked at the floor, before following De la
60 Porta into the Staging Area. The rest of the event planning was uneventful. After a few questions
61 from the staff, we were thanked and escorted back to the building lobby.

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62 A week later—eight days later, to be exact—I was at the Department of Motor Vehicles
63 in downtown Santa Ivo City, near Miller Tower. I won’t bore you with the details of my time
64 there—it must have been around three hours (but I am so bad with time)—but suffice it to say I
65 was starving for lunch by the time I got out. There’s a little diner with great beignets nearby, on
66 the ground floor of a neighboring building, so I ducked in there for a later lunch. Because of the
67 late-afternoon hour, it was mostly empty (even in downtown Santa Ivo City), so I sat down at
68 one of the booths by the window. As I was putting my order in (soda water, turkey club, side
69 salad), a group of four came through the door behind me, walked past my booth, and began to sit
70 down in the booth two over from me (not the one right beside me, but the one next to that). I
71 immediately recognized De la Porta. I started to wave a hello, but it was clear De la Porta didn’t
72 remember me from the week before. That’s understandable. I imagine in the business De la Porta
73 is in, De la Porta sees lots of new faces each day. I looked down for a second and then back up,
74 and I thought I saw Poe Cameron—someone I sort of know (just to nod “hello” at) from living in
75 the Walton Park neighborhood for a couple of years—but I can’t be 100% certain. Still, I’m
76 pretty sure it was Cameron because I remember Cameron was always helping the older folks in
77 the neighborhood carry their groceries and walked their dogs for free. Unlike Cameron’s sibling
78 Memphis Raynes, who was nothing but trouble. Even though I wasn’t friends with Cameron or
79 Memphis, I had seen them around Walton Park numerous times. I didn’t recognize the other two
80 people who were with Cameron and De la Porta.
81 I can’t imagine De la Porta and Cameron would run in the same circles, but maybe
82 they’re old friends. Maybe Cameron works for De la Porta—you know, at De la Porta’s
83 company MSIG? Who knows? After five or so minutes, I gathered my courage and was going to
84 walk over to say hello, but then one of the people I didn’t recognize sitting with Cameron and De
85 la Porta started screaming about numbers, something about the “deal being for 60%.” Cameron
86 looked really uncomfortable and started to get up. But the person that was just screaming about
87 numbers grabbed Cameron’s arm and yanked Cameron back into the seat. I could hear the next
88 words very clearly and they chilled me to the bone! The same person that grabbed Cameron and
89 yanked Cameron back down into the chair said, “If you ever try to leave again before we are
90 done with all this, I will make sure that your parents never see your next birthday. Got it?”
91 Cameron’s eyes got really big, and Cameron nodded without saying a word.

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92 After that it was all hushed talk again and I couldn’t hear them. As you can imagine, I
93 wasn’t about to go over there after that outburst. I motioned to the server, quietly asked to get my
94 order to go instead, and I was out of there as soon as the order came. I forgot to get some
95 beignets to go, but there was no way I was going back in there.
96 Things were busy over the next month: some weddings, a pretty lavish quinceañera, a
97 weekly tasting at Peony Estates (it was a far drive from Santa Ivo but worth the tips!), an
98 unrelated function at Miller Tower (not on the 40th floor), and two fundraising dinners for Mayor
99 Leapheart— De la Porta was at both of these mayoral events. October 31 arrived, and I headed to
100 Miller Tower, getting there just before 4pm. We were going to be a group of twenty that evening,
101 including one event manager and someone to oversee the kitchen. About half of us would be
102 working in the kitchen, and the other half would be serving the guests—first at cocktail hour and
103 then at the sit-down dinner in the Ballroom.
104 Initially, I was going to be one of the servers. Before the guests and hosts arrived, though,
105 we all needed to get the space in order. Things were a little hectic but we were moving quicky.
106 Then, for no reason whatsoever Cyprus Cosmos, one of the members of the gala committee,
107 arrived an hour early and started yelling at everyone that the flowers were all wrong and this was
108 wrong and that was wrong. I snuck into another room and left our event manager to deal with
109 that mess. By 6pm, though, Cosmos had calmed down and the 40th floor of the Miller Tower was
110 ready for the hospital gala. Around this time, a large contingent of armed security guards started
111 walking the auction items into the Cocktail Room through the North Event Staging Area. They
112 finished moving everything in at about 6:20 and most of them remained in the room to watch
113 over things. Some of the guests had already begun congregating in the Entryway by this time, but
114 two guards at the door kept them from entering the Cocktail Room until it was time. I guess no
115 one wanted to be late to the auction, because within ten minutes the Entryway was packed with
116 all 150 guests waiting to get in. (It didn’t help things that Cosmos had a greeting table moved to
117 an inconvenient place in front of the elevators.)
118 At 6:30, the doors to the Cocktail Room were opened and the guests moseyed in. I was
119 already in the Cocktail Room, carrying a tray of shrimp, with some of the other servers, who
120 carried trays of champagne and various other hors d’oeuvres. I had wanted to see some of the
121 incredible auction pieces that were there, but there just wasn’t time. What time there was sped
122 by. As soon as I came back into the Cocktail Room with a new tray, it was already empty. Guests

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123 were dressed up in such unusual costumes. Even though there were over a hundred people there,
124 I distinctly remember many of the costumes that were worn that evening. The gala hall was split
125 about 50% of guests wearing masks as their costume. Some of them were pretty creative. I
126 distinctly remember a Nixon mask, a Kelly Doos mask, and the mask that the police showed me
127 days later (Exhibit 23). I did get to see and chat lightly with some of Midland’s most famous
128 people. The movie star Alex Grace was there, the upcoming politico Drew Walton Jr. was there,
129 even Mayor Leapheart was in attendance. And what’s more—the mayor even remembered me
130 from her two fundraisers. She was so kind. What was weird, though, was that De la Porta wasn’t
131 anywhere to be seen, and I got the sense that De la Porta wouldn’t miss an opportunity to be seen
132 at an event like this. What’s more, it was De la Porta’s own gala.
133 At a quarter after 7—give or take a minute or two—I was walking through the middle of
134 the Cocktail Room with a fresh tray of smoked trout croquettes, when someone dressed up like
135 the mayor bumped into me from behind, and I dropped my tray. (I thought it was the actual
136 mayor at first; it’s really hard to tell two people who look alike apart.) I’ll admit, I might have
137 been a little distracted by the art and people all dressed up in the room, but it wasn’t entirely my
138 fault. Everyone turned around and stared at me, except the guards who kept their eyes mostly on
139 the auction items. But then things went back to how they were. Except, out of nowhere, Cosmos
140 pushes through the guests in the room and starts yelling at me: “how could you ruin this?!” And
141 then Cosmos told me that they better not see me again that night. Tears started welling up, and I
142 hurried back into the kitchen. I told our event manager what happened, and I was able to shift to
143 the kitchen for the rest of the night.
144 I was in the kitchen when the cocktail hour ended (even across the building, we could
145 hear the guests counting down the time). I spent the next hour (this would have been from 7:30
146 to 8:15 or so) helping to plate about 150 hundred dinners—this, times three, because there were
147 three courses for each guest. We were told not to go back in the Cocktail Room until after
148 8:15pm. The security team didn’t want anyone in there when they were moving the artworks
149 back to the Vault. The staff wasn’t even allowed in the North Staging Area while the security
150 guards moved the auction items and display artwork. Staff members could only be in the South
151 Staging Area until 8:15pm. The guests were going to be allowed back in the Cocktail Room at
152 8:45. At 8:30, most of the servers and kitchen staff left for the night. A few remained in the
153 Ballroom in case anyone needed anything. I helped bring the desserts to the Cocktail Room.

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154 Instead of having tray service again, we left the desserts out on tables in the room. We also
155 wheeled in a couple large bar-carts for after-dinner drinks. Two of my co-workers remained here
156 to bartend. The desserts and bar-carts were placed near the walls so that the partygoers could
157 have space for dancing. The awards presentation and auction winner announcements must have
158 run long, because it wasn’t until close to 9pm that guests started coming back into the Cocktail
159 Room.
160 I asked my boss if it was ok if I took off (as I was originally supposed to). The music in
161 the Cocktail Room was getting very loud, so it was hard to hear, but I did hear it when my boss
162 loudly repeated “no.” Because I switched to the kitchen, I was going to have to stay much later
163 than I was originally planning on. (I now had to help clean up the Ballroom and would need to
164 hang around in case anything came up with the guests.) When most of the guests had moved to
165 the Cocktail Room, I started bringing the dinner plates back into the kitchen from the Ballroom. I
166 stopped momentarily in order to call my babysitter because I was going to be getting home much
167 later than I wanted. But the number wasn’t dialing. I tried calling my parents to see if one of
168 them could head over to my apartment to watch the kids, but my phone wasn’t dialing them
169 either. Something was clearly wrong with my phone. I turned it off and on—still nothing. It was
170 already 9:15. This wasn’t good. I walked through the kitchen toward the North Staging Area in
171 order to try a different place in the building to make the call (and to get further away from the
172 loud music). There were a couple people loading things into the freight elevator. One was
173 wearing a black ski mask and the other mostly had their back to me with a Halloween mask on
174 the top of their head. For a moment, I’d say two or three seconds, the person with the mask on
175 their head turned to the side and I could get a profile view. I know it was quick, but, at the time, I
176 thought this person sort of looked like Poe Cameron or at least a close family relative. It could
177 have been Memphis, Poe’s sibling. It is not hard for me to tell them apart when I am not rushed,
178 and the person I saw with the Halloween mask on their head really looked more like Poe
179 Cameron than Memphis Raynes. But then again, it was a quick look. This mask very likely could
180 have been same one the police showed me later. (Exhibit 23). A Halloween mask is a Halloween
181 mask, you know? But the one the police showed me (Exhibit 23) is what I remember seeing on
182 top of the head of Poe Cameron or Cameron’s look-a-like.
183 Anyways, whoever these two individuals were, they weren’t part of our catering crew,
184 and they definitely weren’t hauling dinner trays. I figured they were part of the security team or

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185 some other Miller Tower employees, but I wasn’t sure why they were there at this time or
186 wearing masks. The one I thought could have been Poe Cameron gave me a scary look and
187 angrily said, “we’re almost done here. Go back inside.” It certainly didn’t sound like Poe
188 Cameron at that moment, but then I had never heard Cameron be angry with anyone before, so I
189 guess I can’t really rule out that it was Cameron either.
190 I figured I could just sneak out and head home. With everyone in costume, most of the
191 catering staff gone, and the party nearly over, I figured my boss wouldn’t realize if I’d left. I
192 went back through the kitchen door, into the Ballroom, and was heading toward the elevators in
193 the Entryway. When I opened the doors from the Ballroom, I saw Cyprus Cosmos talking to two
194 costumed individuals. Cosmos ran toward me, screaming about the security guards. “Where are
195 they?!? What are we paying you all for?!?” Cosmos yelled. Cosmos then grabbed my arms and
196 started shaking me. I was stunned but still able to tell Cosmos that there was a security office at
197 the end of the building, and I offered to go there. While this was happening, the two people who
198 were in the Entryway, ski mask person and the Cameron look-alike, went into the stairwell. But
199 this time Cameron had the mask I had seen on top of Cameron’s head down over Cameron’s
200 face. I don’t remember anyone else wearing that particular mask so I knew it was Cameron or the
201 look-alike I saw earlier. One of them dropped a piece of paper, which I picked up as we walked
202 toward the door. I didn’t see them again that night.
203 As we were walking toward the security office, Cosmos apologized and said it was just
204 an exhausting event. I couldn’t tell if Cosmos remembered that I was the one who dropped the
205 tray earlier, but, if I had to guess, I would say Cosmos didn’t. I sort of got the sense that night
206 that we were all interchangeable to Cosmos. We got to the security office a minute later. The
207 large clock outside the office said it was 9:30. No one was there. Cosmos kept banging on the
208 door and yelling through the window. While this was happening, I noticed that the Vault door
209 was open. I walked over and peeked inside with Cosmos following me (and berating me for I
210 don’t even know what for at the time). When I looked inside the Vault, I saw one of the security
211 guards there bleeding profusely. I pushed open the vault door even more and then I bent down to
212 help the guard and called Cosmos over. I took off my apron and tried to stop some of the
213 bleeding with it. I asked Cosmos to help, but Cosmos kept saying, “I’m not going to get any of
214 that blood on me.” Cosmos just kept saying, “It was those people in the lobby. They did this.” I
215 then said, “Stay here, just for a minute while I go get some help.” “No—you stay here,” Cosmos

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216 snapped at me, saying “I’ll get help.” Cosmos then turned the corner and headed back toward the
217 Entryway. The next thing I remember, a swarm of police officers were coming toward us, guns
218 drawn. “This person’s hurt,” I yelled. They had me move away from the guard on the floor. I
219 later learned that the guard’s name was Emory Sands. The police kept everyone there for another
220 couple hours. I was able to call my babysitter—so that was ok. I remembered the piece of paper I
221 saw one of the masked individuals drop. The paper was worn and appeared to have been a torn
222 off piece of a larger scrap of paper. The part I found read “IL 322.” After that quick look at the
223 piece of paper, I gave it to one of the police officers. I haven’t seen it since. I ended up being
224 questioned by two different officers that night, including Detective Kit Bahmani. The robbers
225 must have left a lot of evidence behind, because I heard Detective Bahmani say to another
226 officer, “Don’t worry about tracking down all the guests of the gala, Malus. One of the robbers
227 left blood everywhere, another was spotted by a street cart vendor ditching a mask in the alley,
228 and there are cameras everywhere. I’m going to see if the victim is conscious yet. But I think this
229 will be closed case really quick. I’m thinking it might be an inside job since the robbers knew
230 when to attack and how to get in the vault.” I spoke with Detective Bahmani again later in the
231 week. I told them everything I remembered about that night, and I am putting it all down here.
232 I heard that Emory Sands is doing better now, but the newspaper said that Sands’s
233 injuries were life-threatening, and that Sands had been in the ICU for weeks. I saw on the Blitz
234 News Network that Poe Cameron was arrested and that they were still looking for Memphis
235 Raynes. As I said, I knew them both (but not that well) from the Walton Park neighborhood.
236 Still, it’s hard to believe that Memphis or Poe would do this.
237 Even more, I can’t believe Berkley F. De la Porta had anything to do with this. De la
238 Porta, as far as I could tell, wasn’t even there that night. I know that I never saw De la Porta that
239 night. The news coverage kept showing an interview with De la Porta’s pilot saying that De la
240 Porta flew to New Zealand the night before the heist and was nowhere near Midlands on
241 Halloween night. Regan Thomas, that Blitz News Network reporter that is always digging up dirt
242 on everyone, found proof that De la Porta was indeed on a flight to New Zealand on October 30,
243 2022 and not back in Santa Ivo or even the state of Midlands until almost a week after
244 Halloween. Besides, why would De la Porta need to steal anything? De la Porta is beyond rich. If
245 De la Porta wants a fancy painting, De la Porta can just buy it. Everyone I talk to in Santa Ivo
246 says the same thing, De la Porta is too rich to be involved with the Halloween Helicopter Heist.

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247 My suspicions were confirmed that De la Porta was innocent when I worked a MSIG sponsored
248 event in November.
249 I was hired to work a Leapheart-for-Mayor event at the Harper Country Club on
250 November 18, 2022. MSIG and De la Porta were big donors for Leapheart’s reelection
251 campaign. De la Porta even gave a speech about how much De la Porta loved Mayor Leapheart’s
252 response to the Miller Tower heist. I was shocked when I heard De la Porta say, “I am so
253 impressed with how Mayor Leapheart handled the Miller Tower heist investigation. I know I feel
254 safer with Mayor Leapheart leading this town!” I had never heard De la Porta praise anyone but
255 De la Porta before. Later that night, I heard De la Porta talking to Mayor Leapheart during the
256 cocktail hour. De la Porta said, “I am beside myself. I can’t believe my beloved Morisot is gone.
257 I want whoever is responsible for this heinous crime to be severely punished!” Then De la Porta
258 shouted, “I will donate $500,000 as a reward for anyone that can offer information about who
259 committed this heist!” Everyone cheered and praised De la Porta’s commitment to truth and
260 justice. I think the police just must have screwed something up if they think De la Porta is behind
261 the Halloween heist at Miller Tower.
262 I am familiar with following exhibits:
263 Exhibit 1 is one of the invitations for the October 31, 2022 Sohi Children’s Hospital
264 charity gala at Miller Tower. I saw a whole stack of them sitting on the counter of the 40th floor
265 kitchen in Miller Tower in the week leading up to the charity gala. It has not been altered in any
266 way from when I saw them in the kitchen.
267 Exhibit 2 is the auction brochure for the Sohi Children’s Hospital charity gala that was
268 held at Miller Tower on October 31, 2022. The brochure has not been altered in any way from
269 when I saw a copy. There was a stack of these brochures right next to the stack of invitations on
270 the 40th floor kitchen counter of the Miller Tower. It has not been altered in any way since when
271 I last saw them in the kitchen.
272 Exhibit 3 is a diagram of the 40th floor of the Miller Tower. It accurately depicts the 40th
273 floor as it existed on October 31, 2022 during the charity gala.
274 Exhibit 5 is a picture of a security keycard for Miller Tower. I see all the charity gaga
275 bigwigs and security guards using them to access the secure hallways and stairwells on the 40th
276 floor of the Miller Tower.

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277 Exhibits 18 and 19 are copies of articles that I have read. They are fair and accurate
278 copies of the articles. I have no reason to believe the information contained in the articles is
279 inaccurate.
280 Exhibit 23 is the mask that I saw the person that may have been Poe Cameron wearing in
281 the 40th floor Entryway of the Miller Tower during the Sohi Children’s Hospital charity gala on
282 October 31, 2022.
283 Exhibit 25 is a photograph of Poe Cameron. It accurately depicts what I remember Poe
284 Cameron looking like during the fall of 2022. It looks just like the person I saw on October 31,
285 2022 in the 40th floor Entryway of the Miller Tower during the Sohi Children’s Hospital charity
286 gala. Poe Cameron never had another sibling growing up in Walton Park besides Memphis
287 Raynes.
288 Exhibit 26 is a photograph of Memphis Raynes. It accurately depicts what Memphis
289 Raynes looked like when I saw Memphis around the Walton Park neighborhood during the fall
290 of 2022 and is a similar picture to the one used for Memphis Raynes by Blitz News Network.
291 While Memphis and Poe have some similar features, they certainly aren’t identifcal twins or
292 even the same age.
293 I swear or affirm the truthfulness of everything stated in this affidavit. Before giving this
294 statement, I was told I should include everything that I know may be relevant to my testimony,
295 and I followed those instructions. I know that I can and must update this affidavit if anything
296 new occurs to me until the moment before opening statements begin in this case.
297
298 ____________________________________
299 /s/PARKER ORLOV
300
301 Duly Subscribed and Sworn By Me:
302 ____________________________________
303 /s/ GORDY GWILT
304 Notary Public
305

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AFFIDAVIT OF JUN CAGE

1 After being duly sworn upon oath, the Affiant hereby states as follows: I am over 18 and
2 competent to make this affidavit. I was subpoenaed to testify.
3 Never in a million years did I think I would be writing something like this! I have been a
4 lifelong Santa Ivo City resident. I grew up and still live in Walton Park, one of Santa Ivo City’s
5 32 boroughs. Walton Park is full of quaint and historic neighborhood districts like the rest of the
6 other 12 original inner boroughs. Within Walton Park, I currently live in the Pleasant Ridge
7 neighborhood. Poe Cameron and Memphis Raynes grew up not even a block away from my
8 house. Their parents must just be devastated. I mean everyone in Pleasant Ridge knew about
9 Raynes’s troubles, but Cameron was always the type of kid to make sure any litter on the ground
10 was thrown away and Cameron always held the door open for you at the local bodega. Whatever
11 forced Cameron into all this craziness must have been serious business.
12 Sure, Walton Park has its occasional petty crimes. What neighborhood doesn’t have
13 ornery teens shoplifting or vandalizing a local park bench or two? But never in my life did I
14 think violent crime like what happened at the Miller Tower would ever happen here in Santa Ivo
15 City! Those heinous biennial crimes I would always hear about on Blitz News Network were
16 things that happened in those lawless Midlands counties like Polk and Breckinridge. But not here
17 in Charlotte County! Never before! And to think that this once-in-a-lifetime occurrence involves
18 two people from my neighborhood who used to stop by my street cart every day to grab a meal.
19 I’m still in disbelief!
20 I didn’t always run a street cart empire. I started off in the kitchens of Santa Ivo City’s
21 finest restaurants after graduating at the top of my class from the Culinary Institute of Midlands.
22 But after being the head chef at Gastronomicom for five years and then at the Midlands Tea
23 Room for over ten years, I wanted to return to my roots. So, I invested in myself and started
24 selling meals from my Kwik Bites cart. Kwik Bites isn’t some kind of lobster roll or $19 truffle
25 fries “food truck” joint. It’s legit street food: pitas, kebabs, falafel, and rice dishes. Kwik Bites
26 now has over 25 different carts spread across downtown Santa Ivo City and the inner boroughs.
27 As a savvy business owner, of course I had my Kwik Bite carts out working on October
28 31, 2022. Kids might have their hearts set on a bag full of candy bars, but parents are hard
29 pressed to ignore a chance to grab a delicious bite that is meant to be eaten on the go. The trick-
30 or-treating was from 5:30-7:30pm. It ended right as the sun was setting. I took the cart shift in

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31 Walton Park that day. I love watching all the local families out and about in their costumes. I
32 always give a tasty prize to the best dressed dog!
33 I stayed out even after the trick-or-treating died down because I was going to work a
34 special shift at our cart downtown across from Miller Tower. Halloween isn’t just for ghouls and
35 goblins; everyone in Santa Ivo City knows that Halloween is the night of the annual gala. I know
36 what you’re thinking, “Jun, why would you work a cart across from a gala full of billionaires and
37 sycophants?” Because, when they leave all tipsy and full of charity vibes, they love to stop by
38 the Kwik Bites cart for the best food in the City! Last summer, one of the drunk guests even
39 mistakenly gave me $100 instead of a ten. But I didn’t say anything about it, of course. I didn’t
40 want to suggest the guest didn’t know what they were doing.
41 Anyways, I got to the Miller Tower cart around 8:30pm. I still have a lot of contacts in
42 the upper crust restaurant business, so I knew that the auction would end around 8:45pm.
43 Typically, the auction was followed by cocktails and dancing. That isn’t everyone’s cup of tea,
44 so I wanted to have my cart ready before 9pm to catch any early exiters.
45 The Miller Tower is one of Santa Ivo City’s most impressive skyscrapers. I know the
46 architect built other towers across Midlands, but, of course, our city’s version is the finest of the
47 bunch. The Miller Tower area is a great spot for a cart because the Tower is home to billion-
48 dollar businesses and regularly hosts charity events and conferences. The foot-traffic is amazing!
49 My Miller Tower Kwik Bites cart is my biggest money maker. But our permit doesn’t allow the
50 Miller Tower cart to be open past 9pm. On nights when Miller Tower has big social events, I
51 usually prep extra kebabs to give the local police officers for free so that I don’t get fined. Even
52 if I gave every downtown police officer on the third shift free kebabs, I would still be ahead
53 hundreds upon hundreds of dollars, sometimes even thousands of dollars, because the Miller
54 Tower events are extremely profitable for Kwik Bites.
55 On October 31, 2022, my first customers at the Miller Tower cart started trickling in
56 around 9:05pm. I heard a helicopter land on top of Miller Tower shortly after my first customers
57 came to my cart. I didn’t look at my watch because I was busy with customers. But I know it was
58 the first group of customers and I opened just after 9pm. It was common to hear helicopters
59 coming and going during these high society events. My only problem with these bigwigs using
60 helicopters was that it meant they weren’t going to walk by my cart before they left!

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61 The Sohi Children’s Hospital auction gala at the Miller Tower wasn’t the only show in
62 town that night. There was a Halloween-themed street festival with local bands, like Metabolize
63 to Freedom and Harambe & The Blowfish, a couple blocks away. It meant that a lot of the
64 nearby roads were closed off, but it was great for foot traffic and for business that night!
65 The stream of customers coming up to the Miller Tower cart was steady. The line was
66 never more than 5 people deep but it was a consistent flow of people. I was busy cooking and
67 making small talk with customers. I had no idea what terrible crimes were happening above us in
68 Miller Tower!
69 I remember hearing a helicopter take off from Miller Tower around 9:30pm. It might
70 have been a few minutes before 9:30pm because I heard the helicopter take off while I was
71 cooking and when I finished the order and the customer paid, I remember seeing that it was
72 9:30pm on my tablet that I use to process all my sales. Again, it wasn’t that notable to hear
73 helicopters come and go. I think this one only stood out because it was flying away from the area
74 when I saw Poe Cameron exiting Miller Tower. I didn’t know Cameron worked downtown. I
75 mean, Cameron certainly wasn’t the type of person that gets invited to the charity gala. There are
76 no multi-millionaires or billionaires living in Pleasant Ridge. Cameron’s parents buy lotto tickets
77 with me, so I know Cameron wasn’t there to put a bid on Berkley F. De la Porta’s fancy artwork.
78 In all my years working downtown, I had only seen Cameron near Miller Tower once before.
79 That was back in late-September or early October 2022 when I saw Cameron taking selfies near
80 various exterior doors of Miller Tower. I just figured it must be the newest Tikchat trend or
81 something.
82 I don’t know that I would have even looked up to see Poe Cameron leaving the Miller
83 Tower if the secondary security door that opens into the alley didn’t slam as Cameron exited. I
84 could tell Cameron was upset and clearly out of breath. Cameron turned around in circles and
85 looked lost. Like Cameron didn’t know which way to go. Cameron was holding a Halloween
86 mask (Exhibit 23) in Cameron’s hand and shaking it up and down. Then, suddenly, another
87 person wearing dark clothes with a black ski mask came out of the same door Cameron had just
88 exited from. This second person rolled up their ski mask, but I didn’t recognize them. They
89 certainly weren’t from Pleasant Ridge or Walden Park, or I would have known them. This
90 unknown person was wearing similar looking dark clothes as Cameron. The two of them looked
91 like they were arguing based on their hand gestures, but I couldn’t make anything out other than

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92 when Cameron said, “Made me do it!” Then Cameron kicked the alley security door to Miller
93 Tower and made a motion that looked like Cameron threw something on the ground in the alley.
94 I had never seen Cameron act like that. I called out to Cameron to see what was wrong. But
95 before I could get any answers Cameron and the unknown person with the ski mask ran off down
96 the street in opposite directions. It looked like Cameron might have run down the alley adjacent
97 to Miller Tower and turned towards the Oakley neighborhood. But I can’t be certain because it
98 was hard to see the end of the alley because the streetlight was burned out.
99 Just as I was watching Cameron run off, a police car pulled up with its lights running. I
100 instinctively reached for the extra kebabs I had prepped, but they ran right up the stairs into
101 Miller Tower. Within minutes the area was swarming with police and emergency vehicles. Kit
102 Bahmani arrived around 9:40pm and ordered the area cleared. Even my offer of free kebabs
103 couldn’t keep my cart open any longer. I was shut down but had to wait there because they told
104 me I would need to give them a statement. I didn’t end up providing them with a full statement
105 until a few weeks later though. My business lost a lot of money that night. I hope Berkley F. De
106 la Porta realizes that crime doesn’t just hurt the immediate victim. I’m sure the billionaire De la
107 Porta doesn’t care about little old Kwik Bites, but if I got five minutes alone with De la Porta, I’d
108 give that comic-book-villain-wannabe a piece of my mind!
109 I always knew De la Porta was bad news. No one with that much money and that much
110 face time on Blitz News Network can be up to anything good. Even though the Sohi Children’s
111 Hospital charity gala was hosted and run by De la Porta, I knew that was just because De la Porta
112 liked people showering praise on them. That’s why I was shocked when, a month earlier, I saw
113 Poe Cameron and Cameron’s sibling, Memphis Raynes, talking with De la Porta. Talk about an
114 odd couple!
115 It was just dumb luck I was even in Oakley in mid-September. My employee, Evelyn
116 Owens, runs the Kwik Carts that are in the Oakley and Hyde Park districts of Walton Park. Evy
117 got sick so I was making the rounds to my cart vendors when I saw this limousine pull up in
118 front of the Ivy Lane building. De la Porta gets out and goes inside Ivy Lane. A few moments
119 later Memphis Raynes’s car pulls up. That car is unmistakable! A Mustang GT500 with
120 “ELNOR2” plates. Sure enough, Raynes and Poe Cameron get out and go inside Ivy Lane too. I
121 might have thought it was just a weird coincidence if the three of them (De la Porta, Cameron,
122 and Raynes) hadn’t all walked out of Ivy Lane together just 15 minutes later. De la Porta’s

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123 company MSIG owns most of the buildings in downtown Santa Ivo City, so I figured Raynes
124 and Cameron were doing something for one of De la Porta’s subsidiary businesses. I didn’t
125 realize they were plotting an armed robbery! Raynes was doing all of the talking with De la Porta
126 as they walked toward the limousine. I clearly saw Raynes hand De la Porta something red. I
127 couldn’t be 100% what it was, but it looked like a red key fob or keychain. After the exchange,
128 De la Porta started to walk away from Raynes, but then De la Porta suddenly turned back with
129 this very intense look and shoutes, “Remember: key, card, hand, eye, only 10 seconds!” I had no
130 idea what that meant, it was like some sort of weird word game answer like you can play on the
131 Midlands Times app. But Memphis seemed unphased, and waved off De la Porta saying, “yeah,
132 yeah, I got it!” Cameron was walking about 3 feet behind them, not saying a word. Once De la
133 Porta left in their limousine, Raynes turned and started yelling at Cameron. I couldn’t make out
134 the exact words because of the traffic noise and the hum of the generator that powers my food
135 cart. But I am fairly certain I heard Raynes say something like, “you better do this or else you
136 know what happens!” Raynes then used both hands to push Cameron by the shoulders and got
137 back in their Mustang. Cameron just stood there for a moment looking down at their feet,
138 shoulders sagging, then Cameron got in Raynes’ car, and they drove off.
139 Cameron ended up walking past my cart in Pleasant Ridge later that same week after I
140 had seen Cameron, Raynes, and De la Porta together in Oakley. I asked Cameron if Cameron
141 was doing okay, and Cameron snapped at me to “mind my business!” It was very
142 uncharacteristic of Cameron to be rude. I let it be but made a mental note to follow up with
143 Cameron’s parents in the coming days. But I got busy and forgot to ask them.
144 It was a few weeks later when I was working at the Miller Tower cart that I saw Cameron
145 taking selfies outside of Miller Tower, as I mentioned earlier. But in weird places like by the
146 security door I later saw Cameron come out of on Halloween night. I don’t understand
147 everybody’s interest with Tikchat and being an influencer, but Cameron was taking a lot of
148 pictures of that area. I called out to Cameron, “Hey there big movie star what you doing?”
149 Cameron looked startled and responded, “Oh hey Jun! I didn’t expect to see you here. Long way
150 from Walton Park, huh?” I agreed and asked why Cameron was downtown by the Miller Tower.
151 Cameron just looked at me for about 5 seconds and then stuttered out, “uuuh uum, yeah, good
152 question, um, wwwhat am I doing here? Oh…right, taking pictures for the Tender dating app. I
153 thought this would be a great location to look sophisticated.” I chuckled and said, “I think all

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154 those security cameras and security doors are going to kill your chances!” “Oh but that’s just
155 what I wanted in the pictures, Jun!” Cameron replied. I will never understand these social media
156 crazes.
157 All that being said, there is no way that Poe Cameron hurt Emory Sands; I don’t care
158 what all the newspapers or Blitz News Network are reporting. Poe Cameron is a kind, peaceful
159 soul. I remember when Cameron stopped traffic to let a family of geese cross the road in our
160 neighborhood. Everyone hates geese! Cameron was the person that helped the older folks in the
161 neighborhood carry all their groceries up the steps to their house. Now, Memphis Raynes has a
162 temper; but Poe Cameron would never hurt another person. The mere fact that Cameron was
163 linked to De la Porta and this “Halloween Helicopter Heist” (as they call it on Blitz News
164 Network) tells me that someone must have threatened to hurt Poe Cameron’s family or
165 something. It doesn’t make any sense any other way.
166 When I talked to Detective Bahmani at the police station in mid-November, the interview
167 was pretty unremarkable. There was an FBI agent named Burke with Bahmani. I was a little
168 surprised to see a federal agent. Anyways, I mentioned seeing Cameron at Miller Tower taking
169 photos near the security cameras and on the night of the heist. I do not recall the specific
170 questions they asked, but I told Bahmani about everything in this affidavit except the stuff I had
171 seen at Ivy Lane involving De la Porta. Before I could talk about it Agent Burke said, “this is a
172 waste of time. This Cameron kid isn’t the mastermind. That’s who we should be focusing on.
173 I’m not here for small town crooks, I need to catch the big fish!” Then Bahmani and Burke
174 stepped away and I didn’t hear everything, but I heard “DLP” and “need to get them.” When
175 Bahmani came back, this time without Burke, Bahmani started asking me about whether I
176 thought Cameron was capable of hurting a security guard. I said I didn’t think so. I said that
177 Cameron was a good kid and that maybe Memphis Raynes was the real bad apple. Then
178 Bahmani said, “I don’t have any more questions for you, Jun. Thank you for coming in.” I never
179 did get around to telling the police about what I saw at Ivy Lane. I figured if the police wanted to
180 know more from me, they would ask, but I was never asked to speak with them again or talk
181 about what I saw until I was asked to write this affidavit.
182 I am familiar with following exhibits:
183 Exhibit 7 is a photograph of Poe Cameron’s ring. I’ve seen Poe Cameron wearing that
184 ring every day since the world opened back up in 2020.

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185 Exhibit 11 is a photograph that looks like the red object that I thought might be a key fob
186 that I saw Memphis Raynes pass to De la Porta outside Ivy Lane. I can’t tell you if it’s the same
187 one, but they look similar. It’s the same shape, size, and color of the red object I saw that day.
188 Exhibit 23 is the mask that I saw Poe Cameron holding when Cameron exited the Miller
189 Tower security door on October 31, 2022.
190 Exhibit 25 is a photograph of Poe Cameron. The photograph accurately reflects what Poe
191 Cameron looked like in 2022.
192 Exhibit 26 is a photograph of Memphis Raynes, Poe Cameron’s sibling. Cameron and
193 Raynes didn’t have any other siblings growing up in Walton Park. It was just Poe Cameron,
194 Memphis Raynes, and their parents. The photograph accurately reflects what Memphis Raynes
195 looked in 2022. Raynes and Cameron have some similar features, which makes sense because
196 they are siblings, but they certainly don’t look like twins or anything. Memphis Raynes is clearly
197 the older sibling.
198 I swear or affirm the truthfulness of everything stated in this affidavit. Before giving this
199 statement, I was told I should include everything that I know may be relevant to my testimony,
200 and I followed those instructions. I know that I can and must update this affidavit if anything
201 new occurs to me until the moment before opening statements begin in this case.
202
203 ____________________________________
204 /s/ JUN CAGE
205
206 Duly Subscribed and Sworn By Me:
207 ____________________________________
208 /s/ BERNARDI BIN JAMIN
209

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AFFIDAVIT OF BLAISE NOVA

1 After being duly sworn upon oath, the Affiant hereby states as follows: I am over 18 and
2 competent to make this affidavit. I was subpoenaed to testify.
3 My name is Blaise Nova. I have never written one of these things before, so I am going
4 to include everything that I think might be important. First, a little about me. I am happily
5 married to my spouse, Alex Nova, and we have three beautiful children together. Growing up I
6 was huge into cheerleading and tumbling. In college, I was a member of one of the best stunting
7 groups in the country three years running. I also have dabbled in magic since I was young. One
8 day, I hope to own my own magic shop right here in Santa Ivo City. That’s really more of a pipe
9 dream at this point, but I like to dream big!
10 I am a real estate agent by trade, but I also dabble in property management from time to
11 time. That’s why I’m relevant to this case, or so the attorneys tell me. I spoke to the attorneys
12 from both the prosecutor’s office and the defense before writing this. They interviewed me
13 together and then told me to write everything I know in this document. So, here we go!
14 In 2022, I was filling in for a friend of mine, Cherry. She asked me to take over as the
15 building manager for Ivy Lane for the year of 2022 so that she could pursue her dream of aerial
16 acrobatics for a new cutting-edge program called Ariel No Longer Under the Sea. She had been
17 cast as Ariel’s understudy. As soon as she came to me to ask for help, I looked her straight in the
18 eyes and said, “If you think I would ever not help you follow your life-long dream, you don’t
19 even know who I am. Yes! Of course, I’ll take over as the property manager!” Turns out that
20 people prefer seeing the Ariel under water rather than in the air, so sadly Cherry is back at Ivy
21 Lane, but does she have some great stories to tell!
22 Anyway, I started working as the property manager at Ivy Lane in January of 2022. Ivy
23 Lane is a multi-residence complex. It has a mix of condominiums and apartments. About half the
24 units are apartments and the other half are condos. The clientele is on the upper half of the
25 economic scale. It doesn’t cater to the super rich, but the people who lived there always seemed
26 to have a lot of cash. In all my years of real estate, I’ve never seen a building run quite like Ivy
27 Lane. Surprisingly, a lot of people who live there like to pay their rent in cash. The first time
28 someone asked if we would take cash for rent payments, I called Cherry to ask if that was ok.
29 She told me that that was totally normal for the building and that for the short-term rentals,
30 people often pay cash upfront for all the months. Since it was normal, I figured to each their

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31 own! And I have to admit that I got used to seeing people put down large chunks of money to
32 rent these apartments. The Ivy Lane safe in the manager’s office was bigger than usual to hold all
33 those cash payments.
34 The people who live there also sure do love their privacy. Back when I worked there,
35 there were no cameras in any public areas of the building. There is a camera in the area where we
36 keep the safe, which holds the rent payments and rental contracts. But other than that, the place
37 doesn’t have a single other camera. That’s not to say it’s not secure though. Getting into the
38 building requires a key fob. Every tenant has their own unique fob with a microchip key that
39 unlocks their apartment door. If they want, they can have extra fobs made for their unit. But it
40 costs extra. Also, once a lease is terminated all keys for that apartment get turned off and can no
41 longer access the premises. To get into each unit, the renters have a second key. This one is a
42 physical key, but it’s a special kind of lock that apparently is unpickable. I know for a couple
43 reasons, (a) because I googled it, and (b) because I thought I could work that into a new magic
44 trick I was working on—but that did not go well.
45 My role as property manager was pretty simple. I rented empty units to new tenants. I
46 also helped coordinate any cleanup and renovation of units that were newly vacant. I didn’t
47 really deal with maintenance requests. That’s my sibling-in-arms Riley Poole’s forte. RP is the
48 maintenance person over at Ivy Lane. I literally couldn’t have done my job without RP. Nothing
49 like having a great team, am I right? I also occasionally handled questions or issues raised by the
50 condo owners. The president of the homeowner’s association, Tray Westinmeier, is quite the
51 busy body. I swear, Tray came in twice a week freaking out about all sorts of bugs, but no matter
52 what we did to inspect the space, we found nothing in Tray’s unit. I tried to make a joke about
53 how the bugs always seem to disappear like magic—and then I would do a trick to make a card
54 disappear—but Tray never seemed to appreciate my jokes.
55 Anyway, the attorneys told me that I am supposed to talk about everything I know about
56 unit 322 during my year of running Ivy Lane. Unit 322 was empty for most of the time that I
57 worked at Ivy Lane. There had been a podcast about the former tenant of Unit 322 that went
58 missing under mysterious circumstances from a few years before. Rumors and internet chatter
59 always said the missing tenant was a secret paramour of Berkley De la Porta. Some really crazy
60 threads on the social media site Tumble claimed to have proof the missing tenant was involved in
61 black market art auctions. But you can find almost anything on the internet. Anyway, Cherry had

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62 said that no one ever wanted to rent it because it was supposedly haunted. But a Nova never
63 backs down from a challenge, and I told Cherry that I would have that unit rented out in no time.
64 Unfortunately, the initial prospective tenants did not share my optimism.
65 It was such a shame because unit 322 was a real beaut! Open concept floor plan, a full
66 kitchen, with two bedrooms and two baths. It had great floor to ceiling windows with a view of
67 the downtown skyline, including the Miller Tower. It was also a top floor corner unit right next
68 to the emergency stairs. And, it had a washer and dryer in the unit. No matter what I did to try to
69 get that unit rented, no one would bite.
70 That is, until my lucky day: August 9, 2022. On August 9th, someone called me asking
71 whether there were any units available in the building. I said, “there sure are! What exactly are
72 you looking for?” The person said they needed an open concept apartment with lots of room, a
73 corner unit if possible, full kitchen and laundry, with a view of downtown, and with close access
74 to a fire exit. I was so excited! They were describing unit 322. I tried not to count my chickens
75 before they hatched, so, as calmly as I could, I said, “I think I have the perfect unit available
76 now. Why don’t you come down today and take a look at it?” The person said that they could be
77 there by 1pm. I said I would meet them at the building then and hung up. A few hours later at
78 1pm, someone buzzed the desk asking to be let in. I asked who it was, and they said their name
79 was Memphis Raynes. They said that they had called earlier about renting a unit. I let them in
80 and met them face to face.
81 Memphis wasn’t very talkative. I tried to learn a little more about Memphis, but as soon
82 as I started to get into where they were from, they said, “Can we move this along? I have places
83 to be.” I didn’t want to push my luck, so I took Memphis straight up to unit 322. I gave Memphis
84 the whole spiel about the apartment’s great features. Memphis looked fairly unimpressed and
85 asked me a lot of questions about the neighbors. Memphis asked, “does anyone live in the
86 neighboring units?” I told Memphis that there was an elderly couple, the Lamperts, in the next
87 unit over who were quite lovely but were a bit hard of hearing and couldn’t quite see as well as
88 they used to be able to. And I also said that the unit on the other side was currently under
89 renovation and wouldn’t be available until December. Memphis smiled and kind of mumbled to
90 themselves “we’ll be long gone by then.” Memphis then said that they had to make a call and
91 check with someone before they could decide.

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92 Memphis then stepped away from me, but the apartment was completely empty, so it was
93 pretty easy for me to hear Memphis’s side of the phone call when they were across the room.
94 Memphis was whispering, but I heard Memphis say, “Yeah. This place looks like it will work. It
95 has a perfect view of Miller Tower. It also has plenty of space for what we need it for. Neighbors
96 won’t be a problem here. No one should bother us, and we can get a set of keys for everyone.”
97 Then Memphis was quiet for a bit like they were listening to the other person talk. Then
98 Memphis said, “Yeah. And you have the payments set up right? They’re coming from emsig
99 direct—geez ok. Ok. I won’t say that name when we are on calls.” Then a little more silence and
100 the call ended with Memphis saying “Yeah. I’ll sign the lease today and we can get the rest of
101 the crew together.” (I wasn’t sure what “emsig” was, but that is what it sounded like Memphis
102 said.).” At that point, I suddenly remembered that I hadn’t disclosed the murder and the possible
103 haunting. Midlands has very strict rules about home disclosures, even for renters. So, I started
104 trying to think of ways to positively spin the whole potential unsolved murder thing with a
105 possibly angry ghost lurking into something positive or quirky about the apartment. I couldn’t
106 think of anything, so I just kind of blurted it out all of a sudden. After my confession, Memphis
107 just kind of looked at me, ended the phone call, and then said, “ummm, ok.” Then Memphis did
108 another walk around the apartment and said, “I’ll take it.” I was ecstatic! I had done the
109 impossible: rented unit 322.
110 I told Memphis that we could get the rental paperwork completed that day if they wanted.
111 Memphis said, “let’s get it done now, if that’s ok.” Then we went down to the office and got the
112 rental agreement signed. Since it was a short-term lease, it was pretty standard. One thing that I
113 thought was odd was that Memphis asked for 5 sets of keys to be made for the unit. I tried to
114 make a joke about asking why so many people would need keys, and Memphis had a bit of a
115 strong reaction. At first, Memphis snapped, “It’s none of your business who comes in and out of
116 here.” I was taken aback, but then Memphis softened a little bit and said, “Sorry. I just know that
117 this place is known for its discretion. I can trust you to keep my trust, can’t I?” I replied, “Of
118 course! And sorry about that. I didn’t mean to pry.” I then told Memphis that the keys would be
119 ready for pick up tomorrow and Memphis could move in whenever. Memphis then signed the
120 rental agreement and said they would pay me in cash in full for the entire stay when I gave them
121 the keys the next day.

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122 On August 10, 2022, I gave Memphis the keys to unit 322, and Memphis paid me the
123 deposit with cash from a duffel bag. I wanted to be helpful and decided to do something out of
124 the ordinary for them. I made each of the key fobs a different color: green, blue, purple, red, and
125 grey. That way Memphis could keep track of which one was which. Memphis thanked me for my
126 discretion again and then gave me an extra $500 for my time, and told me, “if anybody ever asks,
127 you never met me.” Then we said goodbye and I told Memphis I would see Memphis around.
128 I didn’t see Memphis for the first few weeks. I had gotten reports from RP that furniture
129 had been moved into unit 322. Sometime in late August 2022, I remember seeing Memphis with
130 two other people. I said hello to Memphis and tried to introduce myself, but Memphis said they
131 had to get going, so I never learned their names. Though over the next several months, I saw
132 them come in and out of Ivy Lane a lot, mainly at night. While I agreed to take over the building
133 manager gig for Cherry, my day job was still selling real estate. So, most of the time that I was at
134 Ivy Lane—unless I was showing an apartment—was at night after dinners with my family. I was
135 happy to see that the color-coded keys were coming in handy. One person was always walking
136 around with the green key fob. (Since I didn’t know their name, I just started calling them
137 “Green” in my head.) I saw another person always walking around with the grey key fob, so I
138 called that person “Grey." Memphis had the purple key fob. I probably saw Memphis and the
139 other two at Ivy Lane about three times per week during September, and in October it seemed
140 like all three of them were just living in the apartment together they were there so much.
141 I like to make certain I get all my steps in for the day, so I spend my breaks walking the
142 complex. While on one of my walks in early September, I heard Memphis, Grey, and Green
143 talking about something while they were outside vaping. They weren’t supposed to be smoking
144 on the complex grounds, but I am not a narc. They were talking about Halloween and some sort
145 of gala. Though, really, they could have been talking about gala apples. I also heard Green say,
146 “I know where we can get a helicopter. That one air school that went out of business.” And then
147 Grey joked, “We will have to make sure there isn’t some sort of mechanical failure though.”
148 Then all three of them laughed. I thought they might be referring to KC Air because I hadn’t
149 heard about any other flight schools closing after a mechanical failure in one of their planes. A
150 couple weeks later I heard Grey ask Memphis if Grey “should bring an axe, just in case. DLP
151 said it might be a good idea.” I was a little alarmed at that question and must have made a noise
152 because Memphis turned my way. When Memphis looked at my shocked face, Memphis said,

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153 “We are making Halloween plans.” And I laughed and said, sounds like some intense plans.
154 Grey said, “you have no idea.” Then they both left. I wasn’t sure who or what “DLP” was at that
155 time.
156 At some point I saw a fourth person start to show up to Ivy Lane as well. It was during
157 October 2022 for sure. I think it was October 5th or 6th. I remember because I was putting up
158 Halloween decorations in the lobby, and the person came up to me and asked where the elevators
159 were. I saw that they had the blue key fob that I had given Memphis—naturally their name was
160 “Blue” in my head at that point. I asked “oh, you’re here for unit 322?” Blue kind of jumped a
161 little, started to look nervous and asked, “what makes you say that?” in a shaky voice. I said,
162 “because you have one of the key fobs I gave to Memphis silly! I’m the property manager. Me
163 and Memphis are cool.” Blue then looked a lot more relaxed, looked me up and down, and then
164 said in what sounded like a curious tone, “Oh ok. So, you know what they’re planning up there?”
165 Based on everything I had heard, I figured that Memphis and the other two were just super into
166 Halloween and maybe they had been planning a cool Halloween party. I said, “all I know is that
167 whatever they are doing for Halloween sounds off the hook!” And I really meant it. Blue said,
168 “wow I didn’t know how many people were involved in this. I figured it was just going to be the
169 four of us plus the boss.” I remember being confused by that and I think it showed on my face
170 because then Blue turned pale. Then Blue said, “forget everything I just said.” Then Blue kind of
171 made a forced laughing sound and said, “Halloween, am I right?”
172 Then Blue smiled and pointed at the decorations I was hanging and said, “your spider
173 web isn’t quite right.” I noticed for the first time that Blue had something in their hand. It looked
174 like a Halloween mask. Blue put the mask down and then came over and spent 10 minutes
175 helping me get the spider web I was trying to hang on the wall to look more authentic. Such a
176 nice person. After the cobwebs looked picture perfect, Blue said goodbye and then went up the
177 elevator. As Blue was leaving, I asked what the mask was for. Then Blue said “oh this? Memphis
178 told me to get it and told me to bring it here. My plan is to take it up to Memphis now.” It is
179 always nice to see two siblings taking care of each other. Though, Poe always looked a little
180 melancholy (like sad and/or upset based on their facial expression) around Memphis.
181 After everything that happened at Miller Tower during the charity auction gala on
182 October 31, 2022, I saw the picture of Poe Cameron on the news. I recognized Poe instantly as
183 Blue. After that first encounter, I saw Poe come in and out of Ivy Lane about 4 or 5 more times.

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184 Not nearly as much as Grey, Green, and Memphis, but still more than just a few times. I can’t
185 remember if Poe was alone every time or not. I think most of the time Poe was with Memphis,
186 but Poe could have been walking in the lobby alone once or twice.
187 In late September 2022, I was working at Ivy Lane during the day for once while I was
188 waiting to show one of the empty units when I had one of my first sort-of-celebrity sightings.
189 Well, it was more than a sighting, it was a full-on encounter! I was actually at a coffee shop next
190 door to Ivy Lane, just sitting at a table outside when I saw Berkley F. De la Porta just walking
191 down the street. I couldn’t believe it! De la Porta (or DLP as some people referred to them) is
192 super well known as the mega-millionaire owner of MSIG and also as a big investor in disruptive
193 new technologies. In my free time I had been working on a brand-new product. I won’t include
194 the details here because I could go on about it for pages but suffice it to say that it was a huge
195 idea that would be just up De la Porta’s alley. Anyway, De la Porta started walking across the
196 street towards where I was sitting while talking on the phone. I heard De la Porta say into the
197 phone something like “I don’t care if you don’t understand why we are making the payments,
198 Jerry! Just authorize the transactions to Bernie Steel and leave my name out of it.” Now, life
199 doesn’t give you too many chances, so I got up and stopped De la Porta on the street right then
200 and there. I introduced myself and De la Porta immediately hung up the phone; then we started
201 chatting. Eventually, I was able to turn the conversation over to my product idea. I’m not going
202 to lie; De la Porta seemed a bit on edge. At the time I thought maybe De la Porta was annoyed
203 that they hadn’t thought of my idea first or that I had interrupted them on the phone. But after
204 explaining my idea, De la Porta said, “It sounds great! Here is my business card. Send me an
205 email.” Then De la Porta walked off toward Ivy Lane.
206 I thought I saw De la Porta pull a red key fob, identical to the red one I had given
207 Memphis, out of their pocket as De la Porta walked away. But I wasn’t 100% sure at the time. It
208 was so fast that it could have been a watch band. I turned around for a second, but the next thing
209 I knew I could see De la Porta in the Ivy Lane lobby through the glass doors. I didn’t know that
210 De la Porta had any reason to be at Ivy Lane. I knew all the contracts for all the renters, and I
211 also knew all the buyers by name and face—real estate is a people profession! So, I knew that De
212 la Porta wasn’t a resident. I figured maybe De la Porta was visiting someone they maybe knew in
213 the building.

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214 However, a few weeks later around October 14, 2022, I saw De la Porta again. This time,
215 it was later in the day, around 5:30pm. I was about to leave Ivy Lane and had just started walking
216 across the lobby while typing out a text when De la Porta came into the building. We kind of
217 bumped into each other, in that rom-com meet-cute sort of way—though we never had anything
218 romantic between the two of us, as I am happily married to Alex after all! When I realized who I
219 had literally just bumped into, I said, “Hey! What are you doing here!?” De la Porta sort of froze
220 and said, “Uh…” Then I said, “Is this about my email? You liked the product idea?!” Then De la
221 Porta said slowly, “Yes… Of course… I am here to see you about your product idea.” De la
222 Porta’s tone seemed a bit off, but I didn’t think much of it at the time. I invited De la Porta back
223 to my office so that I could answer any questions they might have had. However, once we got
224 back to my office, we hadn’t been talking for more than 10 minutes when Alex called. There was
225 an emergency with one of the kids that I had to rush home to help with. I apologized profusely to
226 De la Porta. But De la Porta was incredibly gracious and said, “Don’t worry about it. Go ahead. I
227 can see myself out.” I thanked De la Porta and shuffled out the door as quickly as I could.
228 The joke was on me though because I forgot my keys and had to run back about 10
229 seconds after getting outside. When I went back into the building, I saw De la Porta swiping into
230 the elevators to go up to one of the floors. I thought it was odd, but I was in such a rush, I didn’t
231 call out to them or anything like that. This time I was pretty sure I saw a flash of the red key fob
232 in their hands, but I didn’t stop for a closer look, and I certainly didn’t ask them about it. I knew
233 that the red key fob I had given to Memphis was the only red key fob being used in the building.
234 It’s sort of a long story, but Cherry ironically hates the color red, so she hadn’t used any of our
235 red key fobs that we have in the office. The first time I was able to make one was for Memphis’s
236 unit 322. It made me wonder if Memphis and De la Porta knew each other. They didn’t seem like
237 they traveled in the same circles, but who am I to judge?
238 I was at Ivy Lane during the late night of Halloween/early morning of November 1, 2022.
239 Alex and I normally go all out for Halloween (hosting our annual haunted house), so I don’t
240 usually have anything else planned for that night. However, there was an issue at Ivy Lane that
241 needed my attention that night. I remembered that I had failed to prepare the required paperwork
242 for the cash pick up the next day. So, I had to head to Ivy Lane. I think it was around 11:45pm or
243 so when I got there. The roads were a mess. Now I know it was because the police were trying to
244 figure out how to follow the helicopter that had just robbed Miller Tower, but at the time it was

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245 quite the gauntlet to run. Regardless, after I got there, of course, Tray Westenmeier had a noise
246 complaint that Tray insisted that I handle personally. So, I dashed up to the third floor to tell the
247 Lamperts to quiet down their annual Halloween karaoke jamboree since it was after midnight
248 after all. Jessa was very sweet about the whole thing, but I did hear Gabriel mutter under his
249 breath that they wouldn’t have gotten noise complaints if they had just stayed in Wisconsin.
250 Afterwards, I decided to take the stairs back down to the lobby. I don’t want to get too far into it,
251 but my costume made the ride up the elevator very uncomfortable, so the stairs were definitely
252 the way to go.
253 As I had just entered the stairs, I heard the ding of the elevator and then some heavy
254 footsteps. My instincts told me to stay hidden, so I stayed behind the door for the most part and
255 watched what was happening in front of me. It was a bit dark in the hallway because the lights
256 dim in public areas after 12am every night. But it looked like two people were helping a third
257 person walk to the door of unit 322. It was dark on the floor so I couldn’t see exactly who was
258 talking each time someone spoke. But I had overheard Memphis, Grey, Green, and Blue talking
259 on at least five different occasions so I was fairly confident what each of their voices sounded
260 like. As they are walking towards unit 322, I heard someone who sounded an awful lot like Grey
261 say, “we need to do something. They are going in and out of consciousness.” Then the other
262 person, who sounded like Poe Cameron (the person I knew as Blue), said they were “already
263 dialing” and then I heard a voice come through the speaker phone of Poe’s phone. I only heard a
264 few words, but it sounded an awful lot like De la Porta’s voice saying in a very aggressive tone,
265 “What? You are not supposed to contact me on this phone—or at all for that matter—for at least
266 24 hours afterwards. What are you thinking?” Cameron said something I couldn’t quite hear and
267 then who I thought was De la Porta said, “well are the packages secure? You idiots seem to have
268 blown the job leaving blood everywhere, did you at least get what I asked for?” Then the person
269 in between Poe and Grey kind of whimpered a bit and they turned.
270 I could see from the hallway lights the face of the person that was being helped to the
271 door and they looked a lot like Memphis. I thought maybe Memphis had drunk too much, but I
272 did notice a big dark stain on Memphis’s clothing. It was mostly on Memphis’s left shoulder and
273 spread down Memphis’s back and left arm. It looked almost like blood, but I suppose it could
274 have been oil or paint. Grey then said into the phone “Yes, but we need to know what to do
275 with….” But then the door closed, and I couldn’t hear anymore. I couldn’t believe that it was De

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276 la Porta on the phone at first. It didn’t really make sense that De la Porta would be talking with
277 these people. But then I remembered seeing De la Porta with the red key fob, a couple people
278 mentioning “DLP” when talking, and I started to get the sense that De la Porta coming to Ivy
279 Lane had been to see the people in Unit 322. I didn’t really know what to make of it at the time.
280 But, after hearing about everything that had happened at Miller Tower on the news in the months
281 since the robbery, including that De la Porta was the mastermind behind the whole thing, it
282 makes sense that I was hearing De la Porta on the phone that night.
283 After that, everyone disappeared into unit 322. It was definitely a strange scene. But at
284 the time, since it was Halloween, I didn’t really know what to make of it. Clearly, Memphis had
285 people with them, so I figured there wasn’t anything else I could do. And I didn’t really know
286 what exactly was going on, so I thought it best to keep my nosiness to myself. So, I headed back
287 downstairs and then left Ivy Lane to return to my family’s Halloween party.
288 After that, I never saw anyone with the colored key fobs go in or out of unit 322. I also
289 didn’t see any of them in Ivy Lane again. I checked the apartment on November 11, 2022, after
290 the lease ended, and everything had been cleared out. I was surprised they were able to get
291 everything moved out without me or RP knowing. They must have been magicians! I also never
292 heard from De la Porta ever again about my product. That was quite disheartening. I had worked
293 so hard on my pitch and on the materials that I had sent to De la Porta via email, but nothing!
294 Blowing someone off like that makes me think that De la Porta is a bad person who has bad
295 things coming for them.
296 Just like practically everyone else in Midlands, I heard about the “Halloween Helicopter
297 Heist” on the news. At first, I thought the daring thieves were kind of cool, but then I learned that
298 they had robbed the Sohi Children’s Hospital charity fund! Who does that to a charity??
299 Especially, a charity for a children’s hospital at that! And what they did to that poor guard?
300 Monstrous! But I didn’t know that I had anything important to offer to the investigation until I
301 saw Memphis’s pictures on the news. This was several weeks after the heist, probably around the
302 end of November 2022. I remember that I was taking down the Thanksgiving turkey decorations
303 when their faces flashed across the screen. Apparently, Memphis was a wanted fugitive in
304 connection with the Halloween Helicopter Heist. After I saw that news cast, a lot of things that I
305 hadn’t thought were noteworthy started to make sense. So, I called the police to see if I had any
306 useful information.

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307 Eventually, I was put through to Detective Kit Bahmani, who scheduled a meeting with
308 me at Ivy Lane to talk about the investigation. Det. Bahmani and another person, an FBI agent,
309 named Agent Shar Burke showed up at Ivy Lane as scheduled. I talked with them for a good
310 while about everything mentioned above. They asked if unit 322 had been rented since the lease
311 had ended. I said no. They asked if they could search the unit for any possible evidence. I said
312 sure. So, we headed over to Ivy Lane.
313 The search itself was quite exciting! I took Det. Bahmani, Agent Burke, and who I think
314 was a forensic technician, I think “Nguyen” was the last name but I didn’t catch a first name,
315 with their assistants up to unit 322. I wasn’t allowed to really do anything there and had to wait
316 at the doorway while they searched. At first, it looked pretty bleak. There was no furniture left
317 behind. It looked like all the investigators were dusting every surface they could find for
318 fingerprints. They kept exclaiming how they were finding nothing. At one point all the
319 investigators and the forensic people were gathered in the main living area near the doorway
320 where I was hovering. They looked pretty defeated. Agent Burke even looked angry. The room
321 felt pretty tense, so I cracked a joke about how criminals can’t make it easy by leaving their used
322 glasses etc. around for investigators to find. Then the forensic tech looked at me and then crossed
323 to the dishwasher and opened it. Inside, there were a whole bunch of dirty dishes. The forensic
324 tech called the assistants over and told them to start collecting evidence from the dishware. Then
325 they asked if the unit had a washer dryer. I said “of course!” and pointed them to the washer
326 dryer closet tucked away in the corner. Then the forensic tech opened up the washer dryer and
327 pulled out what looked like old towels, sheets, rags, etc. Some of them looked like they had dried
328 blood all over them. I then heard Agent Burke say something like, “finally! After all these years
329 of trying to pin this on De la Porta and now I got them.”
330 After that, Det. Bahmani asked whether there was still any trash for this unit likely to be
331 located nearby. I told the detective that I didn’t know but it was possible. There had been a Santa
332 Ivo Trash Collector union strike going on for the past several weeks. So, I had no idea what was
333 there, but I said that it certainly smelled like it had been there a while. The police then went and
334 searched the area around the Ivy Lane building.
335 Wow, over 10 pages already?! I can’t believe I had that much to say! I think that’s
336 everything I can think of that could be helpful. Oh wait, I do remember one last thing that I heard
337 Poe say to Memphis when they were outside unit 322 on Halloween night. Poe was very angry

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338 with Memphis; I could tell by the tone of Poe’s voice. Poe said, very clearly, “I hate you for all
339 of this. I can’t believe you forced me into this! Now I don’t know what I can do to get out.” I
340 don’t know what any of that means, but it sure sounds important, doesn’t it?
341 I am familiar with following exhibits:
342 Exhibit 8 is an accurate diagram of Ivy Lane unit 322 during Memphis Raynes’s lease
343 agreement.
344 Exhibits 9, 10, and 11 are photographs depicting a purple, blue, and red key fob,
345 respectively. Each one of them looks like the key fobs to Ivy Lane unit 322 that I gave to
346 Memphis Raynes.
347 Exhibit 12 is a copy of the lease agreement between Ivy Lane apartments and Memphis
348 Raynes for Ivy Lanes unit 322 from August 9 to November 9, 2022. Exhibit 12 is a fair and
349 accurate copy of the lease agreement for unit 322 between Raynes and Ivy Lane.
350 Exhibits 14, 15, and 16 look like screenshots from a phone but I haven’t seen them ever
351 before and I can’t tell you where they came from. But the time stamp on Exhibit 14 has a time
352 stamp that is right around the time I saw Poe making that call with Memphis and Grey in the hall
353 on Halloween night. I can’t tell you if it is the same call though, just that they line up.
354 Exhibits 18 and 19 are copies of articles that I read. They are fair and accurate copies of
355 the articles I read. Nothing has been changed, even the links on the side are the same! To the best
356 of my knowledge the information contained in the articles is accurate.
357 Exhibit 23 is the mask I saw Poe Cameron with when I first met them at Ivy Lane. The
358 one Poe said was for Memphis. I actually think I saw Memphis with that mask at one point
359 closer to Halloween. Though I didn’t see it with them when they were back around midnight of
360 Halloween outside Unit 322.
361 Exhibit 25 is a picture of Poe Cameron or as I originally called Cameron, “Blue” because
362 Cameron had the blue key fob (Exhibit 10) for Ivy Lane unit 322.
363 Exhibit 26 is a picture of Memphis Raynes. That is exactly how Memphis looked in
364 2022.

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365 I swear or affirm the truthfulness of everything stated in this affidavit. Before giving this
366 statement, I was told I should include everything that I know may be relevant to my testimony,
367 and I followed those instructions. I know that I can and must update this affidavit if anything
368 new occurs to me until the moment before opening statements begin in this case.
369
370 ____________________________________
371 /s/BLAISE NOVA
372
373 Duly Subscribed and Sworn By Me:
374 ____________________________________
375 /s/CAMILLE RILEY MOON
376 Notary Public

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AFFIDAVIT OF EMORY SANDS

1 After being duly sworn upon oath, the Affiant hereby states as follows: I am over 18 and
2 competent to make this affidavit.
3 I’m Emory Sands, Director of Security at Miller Tower – or, I suppose, former Director
4 at this point. I’m here voluntarily (although I do miss court overtime pay – you can do pretty
5 well when somebody “forgets” to give you the message that a case had been adjourned). Miller
6 Tower was supposed to be my little gift in life, a quiet gig on top of my pension after 27 years on
7 the job with the Metropolitan Police Department in Midlands City, the last six of which were as
8 the lieutenant commanding the Homicide Squad. Santa Ivo City was the promised land – all the
9 urban amenities without all the crime and contentiousness of the big MC. Everybody knows
10 Mayor Leapheart runs a tight ship. And at some point in your life, you just decide you’ve spent
11 enough time alone in rooms with people who hack…well, no need for detail. Emory Sands had a
12 plan, alright – and we all know how that went, now. Instead of having that sweet bi-weekly
13 check on top of my pension, all I got to show for it is a hell of a lot of pain and some nasty facial
14 reworking. The only nest egg I got out of all this was the money De La Porta gave me, enough
15 to cover my medical bills and leave me with about twenty grand in the bank. I didn’t ask for it,
16 and I was shocked to get the transfer into my account a month after I was let go.
17 Miller Tower is the premier commercial property in Santa Ivo City, a commercial high
18 rise with two special features. (Well, three if you ask me – no residential units, and thus no
19 needy tenants calling that somebody stole their package with 37 bottles of disinfectant spray.)
20 The first 39 stories of the building were just offices – very nice offices, of course. I’m not sure
21 who came up with the idea to put the MSIG event hall and vault on the 40th floor, but there they
22 were, and both were engineering marvels. The MSIG hall had a ballroom, a gourmet kitchen, a
23 dining room, and everything else you needed for a high society soiree. The vault was built and
24 installed by MSIG—you know, the tech giant owned by the eccentric mega-millionaire Berkley
25 F. De la Porta. I think De la Porta wants to go to space or something. Anyway, the vault was
26 executed perfectly. Inches upon inches of steel and concrete, wired for even vibration if
27 somebody tried to breach it, and a door that looked like it belonged in a missile silo somewhere,
28 controlled by the latest in electronic and biometric security systems. We had all kinds of people
29 storing their can’t-lose stuff there – stock certificates and proprietary papers from the corporate
30 tenants, some computer back-up tapes from various clients across the city, even some people

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31 from the “State Department” who wouldn’t let me open the plain, brown wrapper on the stacks
32 of whatever they were bringing in. This was the highest value target on the property, maybe in
33 the City, but it was also hardly a worry for me. The security features baked into the construction
34 meant there was almost nothing for me to do except be present. Opening the vault required two
35 main steps: 1) start the unlocking process in the Command Center with my digitally coded key
36 and 2) provide my biometric signatures at the scanner kiosk outside the vault. The initial
37 unlocking process took several minutes so there was time to get from the Command Center to the
38 vault door for the biometric scanning process. Though if I took longer than 3 minutes to get from
39 the Command Center to the vault door, the vault would automatically lock and I would have to
40 start over. I was never without my vault key, which I kept right next to my lucky Midlands
41 Marauders keychain.
42 At the risk of boasting, I was pretty happy with the security operation we established at
43 Miller Tower. Our standard deployment was fairly small – a handful of guards during the day
44 running the lobby (and making sure nobody made it past our layered controls who shouldn’t),
45 and a floater as needed. I spent most of my time in the Command Center on the 40th floor.
46 Things were a bit more involved when we had events, but we’d worked out several tactical plans
47 that covered every need. We had planned deployments for low attendance events with high-
48 profile attendees, one for large crowds of people that nobody cared about, another for large
49 events with people who had their own security details. These covered pretty much everything,
50 and we’d mix and match if we needed to, supplementing the regular day crew with folks
51 moonlighting from the local Santa Ivo police department or college kids from the criminal justice
52 degree program over at Santa Ivo Tech. We’d dress them up in security guard uniforms, and no
53 one would know the difference. One ‘tac plan,’ though, we reserved for one night a year and one
54 night only – the annual Halloween charity gala. In 2022, that charity event was a going to be half
55 silent auction and half costumed cocktail party—all to benefit the sick kids over at Sohi
56 Children’s Hospital. I’m certain there is something to be said about the upper crust of society
57 needing to don masks and costumes to be separated from their money, but far be it from me to
58 connect those dots.
59 Anyway, the planning for the charity gala started not long after Labor Day, and I swear
60 those six weeks took about six years off my life. The job itself was complicated and it mattered.
61 Santa Ivo’s annual charity gala was always a large event with a lot of profile, some legitimate

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62 targets (especially political and cultural), and a bunch of art and artifacts for the silent auction
63 that were always worth millions – literally. I had real work to do to keep everyone and
64 everything safe. But I also had real pains to deal with, in the form of the gadflies and socialites
65 and whatever else they put on the planning committee. The worst part of the whole routine was
66 the walkthroughs, which were invariably repeated and lengthy, because the various calendars of
67 these “important” people were always so full and they could just NEVER get everyone together
68 at the same time. In order to make these people feel important during these walkthroughs, we
69 usually gave them individualized keycards that let them access special parts of the Miller Tower
70 – nothing super-secure, but they’re able to go up to the roof for an incredible view of the city.
71 The keycard codes usually expired after 48 hours, so there wasn’t a real long-term security risk.
72 These “planning” folks were never satisfied to sit back and let us security professionals do the
73 work. Oh no. They always had to be “in on” every detail.
74 Berkley De la Porta, who’s always co-chair of the planning committee, was the
75 ringleader of the walkthrough for the Halloween gala last year. De la Porta and I must have
76 walked the building a dozen times throughout the summer and early fall of 2022. Every time, De
77 la Porta asked about the same parts of the plan and the physical plant: How many guards are you
78 going to have at the door? How many guards are you going to have on the floor? How many
79 guards at each painting? De la Porta was really big about the paintings this last year. Apparently,
80 somebody had the bright idea to take three priceless works that weren’t even for sale and display
81 them during the auction for reasons surpassing my understanding. De la Porta said everything
82 had to be perfect for the paintings. I told De la Porta that I was thinking of trying to find some
83 kind of encasement for them that could roll from the vault to the floor without anybody having to
84 touch them and from which they couldn’t be removed without a bunch of work (the high society
85 version of those annoying plastic boxes the drug store keeps everything in these days). De la
86 Porta went through the roof – said, “I am not bringing my…” portrait of a penguin eating
87 blueberries or whatever De la Porta said, “…to sit in a big plastic case from which it couldn’t be
88 quickly removed if necessary.” I pointed out that the painting wasn’t going anywhere, and De la
89 Porta got flustered, and exclaimed, “Who said they were going anywhere? I just don’t want the,
90 uh, plastic to affect the lighting! There will be absolutely nothing attached to the paintings, and
91 you’re not going to have all those goons of yours standing around blocking people’s views.”

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92 I told De la Porta that the security associates that De la Porta was referring to weren’t
93 “goons,” but rather most comprised of highly trained members of local police departments who
94 were professionals earning a little extra cash for the family vacation or their kids’ piano lessons.
95 De la Porta lost it again and said, “That was the next thing I was going to talk to you about –
96 those goons do not set the right tone. I want you to use some of those nice young people who
97 you normally have checking tickets downstairs, I want them to be the ones handling the art and
98 artifacts for the entire night. People are tired of being scared by armed guards at these events.”
99 This went on for a bit. I pointed out that nobody had ever reported being scared before, and that
100 we had used the same security plan without incident for years, yet De la Porta insisted that they
101 knew a goon when they saw one. We’d never had a problem in the past and wanted to keep that
102 streak alive. But to be candid, De la Porta’s tantrum finally wore me down.
103 I figured that my guards would still be downstairs, so nobody could make it to the street
104 without real opposition. It just wasn’t worth the constant fighting with the adult temper tantrums
105 De la Porta kept having. We were on the 40th floor outside the Command Center and the vault
106 when De la Porta announced De la Porta wanted to walk the whole event hall again to see exactly
107 where my guards were going to be at every minute, and how many guards would be in each
108 location at any given time. I couldn’t take it anymore. I snapped at De la Porta, “You know, you
109 have such an eye for this. I’m really beginning to think maybe I’ve just lost my edge and that
110 you would have much better insight into security than I do. And because I have such…unique
111 feelings for you, I’m going to do something I never do.” And I did – I gave De la Porta a copy
112 of my tac plan for the Halloween charity gala, which had our security timeline, guard
113 deployment, and the security contingency plans written out. De la Porta took the tac plan and
114 clutched it to De la Porta’s chest. Then De la Porta leaned in as if about to hug me or something
115 – one of my hands went instinctively to my weapon, the other to block De la Porta’s approach.
116 De la Porta shrank back as I said, “You must be joking!” perhaps a bit uncharitably.
117 I had been trying to telegraph for some time that the walkthrough was over, but I couldn’t
118 seem to get De la Porta ‘s attention away from the October 31, 2022 tac plan. Finally, I pushed
119 for the elevator. It came – De la Porta did nothing. I coughed. Finally, I reached in and
120 announced, “Express to the lobby for one!” De la Porta looked startled and actually said
121 something that sounded like “Thank you.”

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122 But it was too good to be true – De la Porta hadn’t got but one foot in the elevator when
123 De la Porta stepped back out and whispered, “One last thing. There’s one thing I’ve always
124 worried about….” I stepped back and said, “There’s only one other person here on this floor
125 with you. I don’t think you have to whisper.” De la Porta straightened up and said, “Well, I’ve
126 always been concerned about the heliport. It seems like such a vulnerability. How can we be
127 sure nobody will land on the roof during the charity gala and rob us all blind?”
128 I had to chuckle. De la Porta actually seemed to think we were in some sort of fictional
129 universe. I told De la Porta that I had never liked the heliport myself but that there was nothing
130 to worry about. I said that when I came on board, I insisted that they reinforce the entrance from
131 the helipad to the building with two armored doors that could only be opened with an extra
132 special keycard or electronically from the control room. “It would take the crew from a local
133 firehouse, a couple of axes and a Halligan, and about twenty minutes to hack through those
134 doors,” I added, “so I think we’re safe.” De la Porta nodded and weirdly repeated what I said,
135 like De la Porta was trying to commit what I had said to memory. For a supposed “tech genius” it
136 all seemed a bit out of character, but De la Porta is nothing if not quirky.
137 Sarcastically, I said, “I’ll put a big post-it note that says “NO!” over that button in the
138 Command Center so nobody makes any mistakes if that will make you feel better.” De la Porta
139 punched the button for the elevator (which had left) and said, “Oh yes, that’s a very good idea.
140 Make sure that your replacement guards are very well instructed not to open the door for
141 anybody.” “You bet. See you later,” I said as the elevator doors finally closed.
142 I have spent a lot of time with a lot of different kinds of people but give me a serial killer
143 any day over that Berkley F. De la Porta and the yacht riding folks! I, of course, was pulling De
144 la Porta’s leg a bit. There had been talk about some kind of reinforced door at the helipad at
145 some point but the building manager never got around to implementing it. The helipad was
146 secured by one of the regular doors used everywhere else in the Miller Tower stairwells.
147 Anybody looking at it could tell that one good kick was all it was good for, and I imagine it
148 would stop an intruder for all of about thirty seconds.
149 De la Porta must have called me least three times during the week leading up to the Sohi
150 Children’s Hospital Halloween charity gala. Giving De la Porta that tac plan was the dumbest
151 thing I’d ever done. De la Porta kept wanting to go over it and make sure that our people were
152 going to be deployed just like in the plan. The night before the charity gala, I remember joking

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153 with De la Porta. I said, “You know, De la Porta, if the security isn’t up to snuff you can just
154 shoot me, how does that sound?” There was an awkward pause – too long of a pause – before
155 De la Porta replied, “Oh don’t be silly! Of course, I hope you won’t be hurt in all this.” I said,
156 “Great, we’re all done. See you tomorrow.” De la Porta responded, “Oh no, I won’t be there
157 tomorrow. I have a sudden emergency.”
158 I actually felt bad for a second (silly me) and told De la Porta that I hoped everyone was
159 alright. De la Porta seemed very chipper and just said, “Yes, of course, everything will be just
160 fine. I just have to go to, uh, the place where my sister lives because she’s having a little
161 surgery. Minor really. But you just never know, right? Now, it’s just very important that you
162 follow the plan to the letter because I won’t be within several states during the entire time of the
163 event. Quite a distance away, you see?” At the time I thought, “What a relief! Finally, a night
164 without De la Porta up in my business!”
165 But to keep the boss happy I said, “I hope you’ll be very involved next year, you’re so
166 important to what happens here.” De la Porta replied, “I certainly am, aren’t I? You could
167 almost call me a mastermind.” I laughed to be polite and ended the conversation.
168 The big day arrived at last. On October 31, 2022, we had our tac briefing and everybody
169 got their assignments. Another one of the “efficiencies,” which we received from De la Porta’s
170 company MSIG, was quite possibly the worst handheld radio system in history. Our events were
171 always quiet – just like Santa Ivo City itself – so there’d never really been an issue, but
172 somewhere a troop of school-aged scouts or a sleepover was looking for their toy walkie-talkies.
173 I handed them out, along with those in-ear-earpieces. They didn’t actually connect to our radios,
174 of course, but I’d discovered the effect on the crowd was pretty good. They liked indulging
175 themselves that they had their own private Secret Service to protect them from who knows what.
176 To be honest, we didn’t have a lot to do until it was time to bring out the artwork,
177 jewelry, and other items for each individual auction. While the servers and kitchen staff were
178 busy prepping cocktail trays of food, I monitored the security cameras from the Command
179 Center. It was all quiet, as expected. According to the tac plan, the only actual tense portion of
180 the evening was when we were transporting the auction items. We had to open the vault to
181 retrieve the artwork and other auction pieces (it had all been delivered to Miller Tower in an
182 armored truck around dawn), transport them to the event hall for auction, and then bring the
183 pieces back to be stored in the vault for the remainder of the evening. I had decided that after all

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184 the items were secured, that vault was not opening back up until the armored truck returned to
185 deliver the items to their new owners. De la Porta’s wishes notwithstanding, I had my best
186 “goons” monitoring the 40th floor and the transport of the auction items while I stayed in the
187 Command Center.
188 Nothing eventful happened during the silent auction’s cocktail hour from 6:30-7:30pm.
189 By 8pm, all the items were successfully transported to the vault and the vault door was locked. It
190 was supposed to be smooth sailing from there. I went to the kitchen and asked one of the
191 waitstaff (I later learned this person’s name is Parker Orlov) to have someone bring a tray with
192 some food down to the lobby for my crew, and, while I was there, I grabbed a glass of
193 champagne with the executive chef to toast a “job well done” by the kitchen and security staff.
194 I’m usually not one for the bubbly, but high-end champagne certainly goes down smoother than
195 the $8 bottle of André that I typically buy for New Year’s Eve festivities. I had the glass empty
196 in two quick gulps. At the time, I thought my night was essentially on cruise control at that point,
197 so I poured myself a second glass of champagne—this time all the way to the top of the glass—
198 and went back to my post at the Command Center. I sat in the Command Center casually
199 watching the security camera footage while I had myself a quick bite to eat. As I was eating and
200 about halfway through my glass of champagne, I noticed that the screen for the camera on the
201 roof was cutting in and out. I figured at the time it was just more glitchy tech from MSIG.
202 Eventually, the security footage stopped cutting out and I couldn’t believe my eyes! There was a
203 helicopter on the helipad! Our security policies require prior authorization to land on the helipad,
204 and no one had called or cleared a landing with me.
205 I radioed to my crew that we had a potential security breach, but I don’t know if anyone
206 received my call. After nothing but silence from the radio for what seemed like hours, though I
207 know it was likely just a minute or two, I decided I would leave the Command Center and
208 investigate the roof myself. I checked the clock in the Command Center, it read 9:13pm.
209 As I opened the door to the Command Center, I saw three figures in dark clothes rushing
210 at me. They were all in the same dark pants, dark boots, and some sort of long-sleeved dark
211 shirts. I distinctly remember one was wearing a black ski mask (how cliché, right?). Another was
212 wearing a cheap Halloween mask that was probably some Hollywood horror flick villain. I
213 remember that person in the horror mask yelled, “You’re going to have to get rid of that guard,
214 P! If you don’t, you know what happens!” At least I think that’s what the person in the horror

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215 mask said, because the mask did muffle the words a bit and it happened so fast. Then the third
216 person, P (I assume), who was wearing the mask that the police later showed me (Exhibit 23),
217 screamed like some sort of animal and punched me in the side of the head with something hard.
218 It wasn’t just knuckles. I’ve been in a plenty of fist fights; and this was something much harder
219 than human skin and bones. The lights went out immediately.
220 I don’t know how long passed by. At some point I woke up. I was out so cold they
221 hadn’t even bothered to restrain me or anything, just dragged me into the vault. I don’t know
222 how they could have accessed the vault. Unless you know how the security system works, there
223 is no way you can get in, even with explosives. As I mentioned before, it’s a two-step process.
224 First, a digitally coded key must be turned in the Command Center. The vault door scanner kiosk
225 won’t accept any input data if the key switch in the Command Center hasn’t been activated.
226 Once, the vault door scanner kiosk is activated, there is a very specific sequence that is required
227 to enter the vault. If you don’t put in your security card, handprint, and retinal scan in that order
228 and within 10 seconds from start-to-finish the system will lock down and send an emergency
229 message to the Santa Ivo Police Department. If the system locks down, an alarm sounds in the
230 Command Center as well. Not even I, the director of security, could override the emergency alert
231 system once the alarm was activated. The vault security system was the one thing that MSIG got
232 right.
233 I noticed that the person wearing the horror mask had my gun tucked into their
234 waistband. I thought for a second about just playing dead until they left, but there was no way to
235 know what the robbers intended to do with me. I took a couple of deep breaths and shifted so I
236 could raise up off the floor and propel myself into Horror Mask at the same time, grabbing for
237 my gun. I clearly surprised Horror Mask. I tackled Horror Mask and we both went to the floor.
238 My gun went clattering across the floor. Horror Mask and I were wrestling on the floor
239 exchanging punches. Horror Mask’s disguise was knocked to the side of their face and I was able
240 to clearly see the face underneath. Not surprisingly, by this point the other two robbers must have
241 heard the commotion and realized I was conscious because they ran in the vault. The robber in
242 the ski mask kicked me once or twice in the ribs. But the third one, jumped on top of me. It had
243 to be the robber wearing the mask the police recovered (Exhibit 23) but my vision was foggy and
244 my head was pounding so hard, but I remember the mask color and the pattern or design it had.
245 Then, after grabbing me, the same robber started pummeling the back of my head and face. I

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246 know it was the same person because I only felt one set of hands on me. Once again, something
247 metal was in or on their hand because it was a lot harder than a human fist. I remember my
248 attacker screaming “You idiot, how could you let this guard get the jump on you! Don’t think I
249 won’t kill them if I have to because nothing is coming between me and getting what I’m owed!”
250 and then last thing I remember is seeing the mask (Exhibit 23) right above my face before
251 someone grabbed my head and slammed it into the cement floor of the vault.
252 I woke up, albeit about two weeks later. It was another week before I was off the
253 ventilator, and then two more weeks before I went to an inpatient rehab for six months. I never
254 thought that the best day of my life would be the day they took me off the feeding tube and I got
255 to eat again for the first time in a month. Then I got another pleasant surprise a few days later
256 when I saw a large transfer pop up in the old savings account. I wasn’t sure where it came from
257 at first and, when I saw my bank statement entry list the payment came from MSIG, I assumed it
258 might be a mistake. Then I noticed a missed voicemail from De la Porta—I had De la Porta’s
259 work and personal cell number saved in my phone, and that’s the name that was listed in my in
260 my missed call history—in the voicemail De la Porta said something like, “Sorry we had to part
261 ways, wish I could have kept the job for you,” Then something else about them “always being in
262 my debt for accommodating their security concerns, even though the crew let me down.” I have
263 no idea what any of that means, but two decades with the police union taught me to not question
264 when I get paid. I deleted the voicemail after I listened to it just like I do with all my other
265 voicemails.
266 The rehab people worked wonders, but there was only so much they could do. I have my
267 good days and my bad days; I still occasionally walk with a limp. But it only seems to flare up
268 when the weather changes. Most days I don’t have a noticeable limp at all. But it’s been a long,
269 hard road back to recovery. The attackers left me to die on the floor of the vault with a ruptured
270 spleen, a fractured skull, and subdural hemorrhage. At first, I couldn’t even move one side, and
271 speaking was hard, not that I had anything much to say since I couldn’t remember anything at
272 first, especially short-term. But with months of work that’s still ongoing, I’m walking on my
273 own again, and you can just barely notice my limp. My speech and vocabulary have come back
274 entirely, which is a relief – all those years doing the Times crossword working midnights with no
275 cases paid off, apparently.

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276 Some of my memory of the details of that night might be fuzzy, but not much. I still
277 clearly remember Horror Mask’s face. I remember when I was sitting in my hospital bed
278 watching Blitz News Network and my attacker’s face appeared on the screen. The news anchor
279 said that face belonged to someone named Memphis Raynes and they were still at-large. The
280 story went on to say that the police only ever arrested one of my attackers. Someone named Poe
281 Cameron. I didn’t recognize their face. But then I didn’t see under the other two masks that
282 night. But I did later hear a recording of Cameron’s interrogation played on Blitz News
283 Network’s coverage of this case. And I am certain that Poe Cameron’s voice is the voice I heard
284 on Halloween Night at Miller Tower from the person that jumped on top of me and was
285 punching me with the object in or on their hand. I never heard the robber in the ski mask talk.
286 But the one wearing the mask recovered by the Santa Ivo police department (Exhibit 23), is
287 definitely Poe Cameron. Even through the mask, I know the voice I heard was Cameron’s voice.
288 I am familiar with following exhibits:
289 Exhibit 1 is one of the invitations for the October 31, 2022 Sohi Children’s Hospital
290 charity gala at Miller Tower. I saw a whole stack of them sitting on the counter of the 40th floor
291 kitchen in Miller Tower in the week leading up to the charity gala. It has not been altered in any
292 way from when I saw them in the kitchen.
293 Exhibit 2 is the auction brochure for the Sohi Children’s Hospital charity gala that was
294 held at Miller Tower on October 31, 2022. The brochure has not been altered in any way from
295 when I saw a copy. There was a stack of these brochures right next to the stack of invitations on
296 the 40th floor kitchen counter of the Miller Tower. It has not been altered in any way since when
297 I last saw them in the kitchen. All of the items listed as auction items and the three display only
298 Morisot paintings shown in the brochure were secured safely in the Miller Tower 40th floor vault
299 before I was attacked on October 31, 2022.
300 Exhibit 3 is a diagram of the 40th floor of the Miller Tower. It accurately depicts the 40th
301 floor as it existed on October 31, 2022 during the charity gala.
302 Exhibit 5 is a picture of a security keycard for Miller Tower. This keycard is required to
303 access the secure areas of Miller Tower’s 40th floor and roof.
304 Exhibit 23 is the mask that I saw my attacker, the one that was referred to as “P,” wearing
305 on October 31, 2022. The one that knocked me out in the vault.

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306 Exhibit 26 is a photograph of person that was wearing the horror mask on October 31,
307 2022. According to the news that person’s name is Memphis Raynes. But I had never seen
308 Raynes before October 31, 2022.
309 Exhibit 27 is an accurate copy of my medical records.
310 I swear or affirm the truthfulness of everything stated in this affidavit. Before giving this
311 statement, I was told I should include everything that I know may be relevant to my testimony,
312 and I followed those instructions. I know that I can and must update this affidavit if anything
313 new occurs to me until the moment before opening statements begin in this case.
314
315 ____________________________________
316 /s/EMORY SANDS
317
318 Duly Subscribed and Sworn By Me:
319
320 ____________________________________
321 /s/ALEX JIMENEZ
322 Notary Public

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1 AFFIDAVIT OF BERKLEY F. DE LA PORTA

2 After being duly sworn upon oath, the Affiant hereby states as follows: I am over 18 and
3 competent to make this affidavit. I am making this affidavit entirely of my own free will and
4 against the advice of counsel. But, as you’ll see, I truly hope this statement will get the
5 government all the way off my back about this heist.
6 My name is Berkley F. De la Porta, I’ve asked my current residence be redacted and I
7 guess the prosecutors agreed. Obviously, I have had multiple issues with “the press” over the
8 years; after all, every one of them are just tabloids trying to dig up dirt on me. Still, everyone
9 knows that I split time between Santa Ivo Heights, Paris, and the sleeping space at my secondary
10 office at the headquarters of my most recent acquisition “Little Bird Word” (the world’s sixth,
11 soon to be eighth, most popular social media service.) I also should note my counsel, the third
12 set of lawyers I’ve had to hire since this witch hunt started, have told me—and they asked me to
13 make explicitly clear they told me—not to make this affidavit. I am confident, though, once they
14 see my genius and I win the case for them they’ll forgive all the legal fees I still owe them. So,
15 obviously, they don’t have much room to talk.
16 A lot of people ask me, “Berkley, how did you overcome the adversity of getting an
17 engineering degree from the second best Ivy League school in the country because your parents
18 would not make a large enough donation to the best, the struggle of landing a job as only a vice
19 president in your uncle’s business when you graduated, and the indignity of being forced to start
20 your own business with only $50 million in seed money from your trust fund?” And I tell them,
21 “when you are an absolute mastermind like me it’s super easy, barely an inconvenience.” So,
22 with nothing more than my Bachelor’s from Yale and my paltry seed money, I set out in the
23 world of defense contracting.
24 I’ll give you a little bit of my history before we get to the events in question. Once upon a
25 time, I set out to start a defense contracting firm known as the Midlands Santa Ivo Group, MSIG
26 (pronounced M-Sig by some) in 2008. MSIG is now an internationally renowned engineering
27 firm that specializes in military and private security technology, surveillance, and aerospace
28 communications. We hold over fifteen thousand marketable patents and have licensed our
29 technology to every nation in NATO as well as a few groups that deal in special interest
30 assignments in Latin America and the Middle East. Our technology includes military grade
31 communications technology such as satellite phones, cell phone/frequency jammers, underwater
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32 communications apparatuses—basically if you can name a military grade product, we make it. I
33 am currently the majority shareholder and President of MSIG. MSIG has a number of subsidiary
34 corporations. I cannot even keep track of them all. I am on the corporate boards of many of them,
35 but not all of them. While I like to consider myself to be intimately knowledgeable about the
36 company I started, it is impossible for me to know everything that goes on in every single part of
37 my company on a daily basis. I know more about the companies for which I am a board member,
38 but still, it is not possible for me to be aware of every transaction ever made in my companies.
39 After that company was a smashing success—as I knew it would be despite the lack of
40 support I had from my parents to start it—the planets started to really call to me, specifically
41 Venus. I started another company called Blast Off to make that dream come true. And, wouldn’t
42 you know it, the fates and all the stars aligned so that Blast Off is at the pinnacle of Midlands’s
43 commercial space race. Most recently, I have purchased Little Bird Word, a social posting
44 application that allows users across the globe to post content to thousands of viewers. One of my
45 board members from MSIG told me I was crazy. He said, “You and I aren’t social media people;
46 we’re engineers and contractors!” But I’ll stand by that choice. I’ve already improved things at
47 Little Bird Word, even if the shareholders can’t see it yet.
48 Enough about me, I’m now going to move into the horrible events that I have been
49 accused of. I have read through the State of Midlands’s indictment of me. Everything in there is
50 just lie after lie. The State has nothing to show that the criminals who committed this heist ever
51 ended up in the same room at the same time. And obviously, any evidence presented by the State
52 is soiled by the presence of Agent Shar Burke in this investigation. Any evidence pointing to me
53 was clearly put there by the touch of a hand of Burke or one of Burke’s minions. Burke isn’t
54 even a state investigator, so why are they even involved in this investigation? I’ll get more into
55 my history with Burke later though.
56 To really understand my saga, we have to go back, all the way back to when this all
57 started on November 10, 2021. You see that was the day where I was selected to be one of the
58 committee chairs for the annual Sohi Children’s Hospital charity gala. It happens every year on
59 Halloween. I was very honored to be selected. I won’t get into too much detail here but suffice it
60 to say that I had a relative of mine that I am very close with who had to use the services of the
61 hospital when they were in their teenage years. I was grateful to be chosen for a charity so close
62 to my heart. That plus the fact that this is one of the best and most prestigious charities to be
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63 involved with in all of Midlands (and really this whole section of the US) really lit the fuse
64 within me to make this an event that everyone in the world would remember.
65 I know that Cyprus Cosmos is a witness that the State may use against me. Cyprus and I
66 have run in similar circles pretty much our whole lives. I don’t know Cyprus that well though.
67 We see each other at events and things like that, but I would not say that we are friends. I may
68 have had Cyprus on my yacht a time or two with several other people. I also may have started a
69 business venture that might not have worked out with Cyprus. Honestly, I don’t remember. I do
70 so much business all the time that it’s hard to keep everything clear. Working with Cyprus on the
71 gala was exhausting. Cyprus has always been jealous of me, my success, and my family. So,
72 Cyprus won’t hesitate to take any chances to take me down. Anyways, I was put in charge of
73 collecting all the items for auction and determining the aesthetic of the event. This was a difficult
74 and lengthy process because there really was a chain reaction of countermoves needed any time I
75 tried to secure specific pieces for the auction. People in our circles really don’t like to give up
76 their fine items. This process took me months of negotiating and telling my personal story of
77 why Sohi Children’s Hospital was so important. It probably took me until July of 2022 to get
78 every single piece I wanted to be at the auction that night.
79 One of the real coups I was able to pull was getting Bancroft Estates to allow the display
80 of two of their Berthe Morisot paintings. Morisot, in my humble opinion, is the best of the
81 French Impressionist movement—if not the most skilled artist in the world to ever exist. If you
82 take the time really to assess her work, you’ll see that she is able to solve the equation of lines,
83 composition, and color in a way that makes you feel something about her subjects. I remember
84 Cyprus telling me that I would never be able to get Bancroft Estates to allow those to be present
85 at our gala. I would never have asked Bancroft Estates to auction their paintings, because they
86 just don’t sell Morisot paintings—which I know from a previous experience trying to buy the
87 exact paintings lent to the charity for the 2022 event. The only group to hold more Morisot
88 paintings than me was Bancroft Estates, and their security was so tight that the paintings could
89 rarely even be seen. I knew that the only way for those paintings to be out in the open—for the
90 members of the public to see of course—was at this auction event. However, I knew, and I told
91 Cyprus, that I had the checkmate. I offered to display one of the Morisot paintings from my
92 personal collection to show how secure I felt the facilities at our chosen venue were. Cyprus was

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93 quite annoyed when I pulled it off. I remember smiling at Cyprus after I told the board about the
94 deal I struck and saying, “It was a deal I couldn’t lose.”
95 The location of the event was something that I strongly pushed for: Miller Tower. What
96 Cyprus proposed for the location was laughable. It had no security and would not provide our
97 donors the peace of mind required for them giving up their valuable items. If Cyprus’s proposal
98 had been chosen, then my plan for the gala would not have worked. So after Miller Tower was
99 selected over Cyprus’s pick, I went up to Cyprus and said, “I told you none of it was accidental. I
100 worked every member of the board to make Miller Tower the choice. And from even the first
101 night that you saw me at the board meeting, nothing was gonna stop me. I laid every single piece
102 of the groundwork to make this happen.” Then Cyprus responded, “And then what? Just like
103 clockwork everyone just listened to you? The pieces all just – the dominoes all just cascaded in a
104 line? No one is that good.” Then I jokingly said, “I do this for a living. What if I told you I’m a
105 mastermind when it comes to getting what I want.” After the location was set, the date was
106 obvious: the event is every year on Halloween. That was a bit awkward since Halloween that
107 year fell on a Monday, but the people who come to this event are very devoted and attend every
108 year regardless of the day the event falls on.
109 One of the main reasons why I pushed so hard to use Miller Tower was the incredibly
110 strong security measures. I must admit that I was slightly biased in pushing for this building
111 choice. The vault for Miller Tower is very unique in that the vault is on the top floor of the
112 building. And now I know what you’re thinking, who puts a storage vault up on the top of a 40-
113 story building? Well, there are many security advantages to that. For one thing, it makes getting
114 to the vault very difficult for criminals. Instead of tunneling in through the ground or being on
115 the very bottom floor of the building, criminals would have to make it up and down all 40 flights
116 with all the loot without being caught by building security. Now, the building also had a helipad
117 on the roof, so there was the potential for some truly daring and tenacious thieves to access the
118 building via helicopter, which I heard on the news was what happened in this case (but I knew
119 that that was a major weakness of the vault many years before the charity gala on October 31,
120 2022).
121 The difficulty of having a super secure vault up that high was the installation. What
122 company in their right mind would help with such an installation? Mine. MSIG is known for
123 being able to do the impossible in impossible situations. So, when my company was asked to
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124 install that vault, we did it. And it was all by design, to the exact specifications of the zany
125 architect who designed the building. The vault that my company installed was the Mach 10
126 Titanium (or the M10T for short). While I was involved in the negotiations to get the contract for
127 the project and to make sure the project was running on time and on budget, I was not heavily
128 involved in the actual design of the vault itself. I delegate things like that to my employees.
129 While I’m perfectly capable of understanding and coming up with designs like those for the
130 M10T based on my high IQ and engineering background, I’m much more valuable in other
131 ways. Because I’m a mastermind at making the business deals. I don’t weigh myself down in the
132 details of any specific product/service MSIG provides—unless they are needed for me to sell the
133 deal better. And to be honest, the Miller Tower builders wanted to know a lot about the vault, so
134 by the end of that deal I knew a lot about the vault specifications. The vault started installation in
135 May of 2021 and was complete by March 2022. And from what I can tell from the reports of
136 Detective Kit Bahmani and Agent Burke (both of which I have read thoroughly and know like
137 the back of my hand), the actual security in the vault did not fail. It was by-passed by the
138 cunning thieves who used the only fallible element of the security at Miller Tower: the human
139 guards. So the vault’s integrity, and by extension MSIG’s technology, has never been called in to
140 question despite all the buzz around the heist.
141 And you see, the human guard component of Miller Tower’s security was the thing that
142 gave me pause about choosing it for the gala. All the wisest security people—including men,
143 non-binary people, and women—recommend to me a full examination of the security protocols
144 before the event. They recommended I speak with the head of security, review camera
145 placements, examine key card access, and any weak points in the security. They said I had to do
146 it this way because we were risking a lot by having these high-priced items all together in one
147 place. So, that’s exactly what I did. I reviewed all the security protocols for Miller Tower. I
148 spoke with the security guards regularly in the weeks leading up to the event. Honestly, I feel
149 like I was born to be a security professional, even though I have no experience in combat or in
150 security itself, I’m great at finding the weaknesses in a security system. I see the unprotected
151 pawn in every situation and know how to exploit or fix that hole in the system. Really, security is
152 a chess lover’s game. A few weeks before the event everything seemed to be falling into place.
153 But, Emory Sands made it clear that no matter who I spoke to on the security team, Sands would

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154 be the one making the call on which guards were working on the night of the event and that
155 Sands might throw in some security “surprises” (whatever that meant).
156 Around October 1st, during one of my security walkthroughs, I was talking with Emory
157 Sands about the Miller Tower security. Sands seemed competent enough at their job, though
158 Sands kept complaining to me about how underpaid Sands was. Sands showed me all the
159 cameras that were installed on the 40th floor, including those in the secured area. I asked Sands if
160 we could go up onto the roof to check that out—I had been on the roof before when my own
161 helicopter had landed there several times in the years prior for various events at Miller Tower.
162 Sands said that Sands would prefer not to because Sands was afraid of heights. I explained the
163 importance that I be able to tell our big-ticket item owners about the roof’s security. As I said to
164 Sands, “If you fail to plan, you plan to fail!” Sands still looked pretty terrified at the idea of
165 going up there, so I tried a new strategy and said, “Why don’t you get me a security key card for
166 the roof and I can just go up there by myself. Ya know? Really get a good look so when I talk to
167 the big-ticket item owners I can give them something that really sets the scene for them.” Sands
168 said that doing that would be against protocol, but Sands would do it because Sands trusted me.
169 Sands and I then went to the security office and made a copy of a new key for me to use.
170 I don’t know what happened to that key. I used it to get to the roof and back down, but I don’t
171 recall where it went after that. That’s the tale as old as time for me though. I’m always losing
172 things. My assistant says I am a nightmare. The wind on top of the roof was pretty strong. But
173 everything looked the same as when I had landed in our helicopter before. I remember the wind
174 being just free flowing in each of those instances too. I honestly felt like I could have been
175 hanging from the sails of a ship it was so windy. It told me that anyone who would need to land
176 here would have to be pretty experienced—which is something I know since I have my
177 helicopter pilot’s license. I had just gotten it about 6 months before I was on the roof examining
178 the security. Those instructors at Koller-Campbell Air really knew what they were doing—at
179 least until they went out of business due to that lawsuit. Anyways, on the roof, I noted all the
180 security measures, including all the cameras I hadn’t noticed on my last trips.
181 Later in October, as we were getting closer and closer to the event, I remember things
182 going pretty smoothly. And everything really felt like it was falling into place, except for when
183 Cyprus had some sort of issue with the liquor in our cocktails that was easily resolved by

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184 changing vendors. Other than that, everything was on track for the night of the gala to be a
185 success for everyone involved. I knew a lot of money would be made that night.
186 Unfortunately for me though, something came up that prevented me from attending the
187 gala. What I am about to say here could get me in some hot water with certain individuals, but if
188 I told you that me missing the gala was not entirely accidental without telling you why I missed
189 it then I would look far more guilty than simply admitting where I was. This is going to sound a
190 bit ridiculous, but I am part of an underground MMA group for a select few. All involved signed
191 binding non-disclosure agreements so I cannot discuss details, but I can give you the broad
192 strokes. After fighting my way through every competitor, including a certain executive at a
193 certain other social media app, I emerged with a championship belt.
194 Overall, it’s a pretty intense competition set up. Real gladiatorial combat type stuff. Some
195 of the challenges you get put through are really tough. And the first night that I competed was a
196 real blood bath—a pretty intense, as it were, running of the gauntlet. I have a number of scars to
197 show it—which I won’t get into now, but they are there. The location and times of the fights are
198 not known well in advance. The one set for that fiscal quarter ended up falling on the date of the
199 charity gala. While I really wanted to be at the gala that night, the people involved in these fights
200 are no joke. So, I had to go to the fight in New Zealand. And as you likely know from the police
201 reports, and even Agent Burke had to admit, people saw me in New Zealand on the night of the
202 heist. My passport was stamped and everything. Though to go without somehow mentioning my
203 involvement, I lied to the people on the planning committee and said I had a sick family member
204 I had to deal with on that night. What else was I supposed to do? I knew I wanted to be at the
205 gala, but I had no choice but to miss it. While your interest in what I did there that weekend is
206 probably waning, I will say that I won my fight that night—though my body was pretty beat up
207 after.
208 I found out about the fight around October 17 and that’s when I laid the groundwork to
209 make sure I could miss the gala without problems and then I could spend all my free time
210 training. The security seemed to be going well though, just like clockwork. It seemed like all the
211 dominoes were set up and if the rest of the committee and the security folks would just have
212 made sure to do their parts everything would have cascaded perfectly in a line to make a
213 successful event. I left for New Zealand on my private jet around 8pm on October 30, 2022, and

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214 I had no idea, just like everyone else, that the gala auction would be the target of those devious
215 thieves.
216 I returned to Santa Ivo on November 4, 2022. Of course, by then I had heard the news
217 about what had happened at Miller Tower. It was such a shock. To think how daring those
218 thieves were and how all those high-ticket items had been stolen. My own Morisot was one of
219 the paintings stolen. I was outraged that the Miller Tower security guards had not been able to
220 protect the valuables they were charged with. I started calling all of the auction item owners to
221 help calm them down. I even talked with them about getting one of my law firms to begin filing
222 suit for negligence against the security company for negligent storge of our items. But then on
223 November 5, 2022, I got a call from Agent Burke. Burke has had a vendetta against me for many
224 years now. Burke called me up on the 5th and said, “What if I told you I’m on this helicopter
225 heist now? I know that you did this. You’re a mastermind and this is exactly the type of job that
226 you would pull.” I told Agent Burke that I didn’t know what Burke was talking about. Burke has
227 accused me in the past of being a part of other flashy and daring heists even though there hasn’t
228 been a lick of evidence to support those accusations. Burke then went on to say that “This crime
229 scene isn’t as clean as your last few. There was blood from one of the crew members at the
230 scene. And now you’re gonna be mine.” Burke continued to accuse me of the crime saying that it
231 was all my design. While the conversation was quite amusing—given that Burke has harassed
232 me about this for years without any ability to find me guilty of any crime whatsoever—after
233 Burke went on for a good three-minute diatribe, I just hung up. Any time Burke tried to contact
234 me directly after that, I informed Burke that my lawyers would be doing the talking. That made
235 those phone calls stop. I guess lawyers are good for something after all.
236 I thought everything had died down when I hadn’t heard anything from either the
237 detective in charge of the case or Agent Burke. But in February 2023, Detective Bahmani and
238 Agent Burke showed up on my front steps with a warrant to search my home. When I displayed
239 my outrage for this blatant and illegal invasion of my home, I asked Det. Bahmani “Is this
240 because Burke thinks I’m a mastermind of some sort? You know Burke has been harassing me
241 about this nonsense for years and is just out to get me.” When I said that, Bahmani looked a little
242 alarmed and fidgeted around as if they were nervous based on what I just said. But then Bahmani
243 said, “we have the evidence to support the warrant. You have an issue with the underlying

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244 evidence? Take it up with the courts.” Then the police, including Agent Burke, started ripping
245 apart my home.
246 One thing to know about me is that I have very particular architectural tastes. No one
247 wanted to play with me much as a little kid and I grew up in some drafty and strange old houses.
248 When I happened across a real-life secret passageway and room one day when other kids were
249 picking on me, I felt like I had found home. As I grew older, I learned about things like
250 prohibition tunnels and speakeasys. I’ve been scheming like a prohibition-era criminal ever since
251 to make each of my homes have these secret rooms and passageways. Of course, Agent Burke
252 was the first one to find one of these hidden rooms and acted like it was the find of the century.
253 Burke said, “they’re going to love me down at the office. And really, De la Porta, having a cache
254 of stuff like this, you make it seem effortless to catch the criminals like you.” I didn’t know what
255 Burke was talking about but then I saw Burke pointing to the bag of cell phones that I kept there.
256 I collect old cell phones so that I can test out MSIG’s cell phone jamming tech and other
257 technology I can’t disclose here. One of the cell phones Burke pulled out said “Miller Tower” on
258 the back. While the cell phones in that bag were generally mine, I swear Burke planted the Miller
259 Tower one! I would never use something as tacky as a label maker to label my phones. I later
260 learned that the phone they found had supposedly called two people known to be a part of the
261 heist crew from the helicopter heist. I don’t know how Burke got the phone of whoever was
262 communicating with those people, but it wasn’t mine! At that moment I called my lawyer and
263 told her to meet me at my home to help with the police.
264 Later on, in the search, Det. Bahmani discovered my hidden Morisot appreciation room.
265 Now, I know what was found in that room looks bad for me, but there is a perfectly logical
266 explanation. This is the first time I’ve felt the need to confess, but I will admit that the Morisot
267 that I provided for the gala as well as the two lent to us by Bancroft Estates were hanging in my
268 Morisot appreciation room. However—and I swear—I was not the one who stole them! Shortly
269 after the heist happened, I was quite bereft about the loss of such wonderful Morisot works. So,
270 with my knowledge of dark web stuff through some MSIG contracts that I can’t get into the
271 details of for purposes of national security, I began searching to see if I could find the works
272 through less than legal channels. And long story short, I did. So, I purchased those items and had
273 them placed in my home. I would provide more detail here, but I’m only being cryptic (and
274 maybe a bit Machiavellian seeming) because I care about protecting some of our most well-
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275 guarded cyber security secrets. So, as I told you, me having the paintings, well none of it was
276 accidental but there is nothing I can do to show exactly how I got those paintings. I have no
277 records of receipts or anything like that. Really this is just a crime of MSIG being so good at
278 what we do that I can’t explain how I got them back without revealing top secret information.
279 And maybe I should have returned the Bancroft Estates Morisot paintings the first night that I
280 found them, but you know me. As soon as I saw them for sale, I knew they were for me to keep.
281 And nothing was going to stop me from adding those two paintings to my collection and making
282 it the most complete collection of Morisot paintings in the world. I just couldn’t pass up the
283 opportunity to have those two from Bancroft Estates. Plus, Bancroft Estates keeps those
284 paintings so locked down. It was time for them to be somewhere where they could be
285 appreciated! If I am guilty of anything, it’s being an art lover. Obviously, buying art from less
286 than credible sources is tricky though. I was planning on having the paintings tested to make sure
287 that they were in fact the real Morisots, but the police conducted the search and found them
288 before I could. I’m not a certified art expert, but I have spotted some fake paintings before in
289 previous art sales. And if anyone knows Morisot’s work, it’s me. Those paintings looked like
290 they were the ones stolen from the vault—I examined each of the paintings closely before they
291 were to be displayed at the auction. But I can’t say with 100% certainty that the ones I bought
292 after the heist were the real paintings. I’d say I’m closer to 95% certainty that those are the same
293 Morisot paintings that were stolen.
294 I believe that the police have no actual evidence tying me to this crime and I believe that
295 soon their incompetence will be shown. I’ve seen all the evidence they have, and it doesn’t prove
296 anything. There is a reasonable explanation for everything they have provided:
297 Exhibit 1 is the invitation to the gala. Exhibit 2 is the brochure showing all the items up
298 for auction at the event. These are both true and accurate. I laid the groundwork for this event to
299 take place. And then, I have to admit I saw myself wearing a wide smirk when I saw these on the
300 exhibit list. You are crazy if you think these exhibits on their face prove anything about me being
301 involved in the heist.
302 Exhibits 14, 15, & 16 are the call logs between the phone Agent Burke supposedly found
303 in my home that said “Miller Tower” on the back. I have no reason to dispute that the calls were
304 placed between that cellphone and the cellphone numbers listed in the call log. However, the
305 “Miller Tower” cell phone is not mine.
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306 Exhibit 17 is the FBI profile that Agent Burke had developed, and it is something I have
307 seen before this case. Burke has shown me and my attorneys this profile several times before.
308 While the person or persons who have committed those crimes seem incredibly intelligent and
309 have quite the flair for dramatics, nothing in that profile shows that I am the one who committed
310 any of those crimes. Also, those are all past crimes that can’t even be linked to me. So is that
311 even important? I remember Agent Burke asking me after the Miller Tower heist at some point
312 “You knew that you would get caught right? You couldn’t think you could get away with this the
313 entire time, did you?” I didn’t even dignify that with a response.
314 Exhibit 3 & 4 are the schematics for the 40th floor and the roof of Miller Tower,
315 respectively. Now, I was familiar with a prior version of these schematics from when we were
316 installing the vault on the 40th floor. That prior version didn’t show the camera placements.
317 However, everything else (such as the room placement, doorways, etc.) looks exactly the same.
318 From my review of the building security in the lead up to the gala, I can confirm that the cameras
319 as shown on this schematic match up with the security that was in Miller Tower in the weeks
320 before and on the night of the heist.
321 Exhibit 18 is an article about MSIG’s installation of the M10T vault at Miller Tower. All
322 the information within it is accurate to my knowledge.
323 Exhibit 19 is an article containing an interview I gave to Santa Ivo Tech’s alumni
324 newsletter. All the information within it is accurate to my knowledge.
325 Exhibit 11 is a picture of a red RFID key fob. The police found this key fob at my home
326 and reported that it opens the door for Unit 322 at Ivy Lane. I have no explanation for how that
327 got into my home. I know that the police have a witness saying I was at Ivy Lane at some point
328 before the day of the heist. I can’t say for certain whether I ever went inside the Ivy Lane
329 building before. I may have gone there in the time before the heist, but I guess it’s possible I may
330 not have. I don’t know how I have a key fob for one of the specific apartments. The police
331 reported the someone named Blaise Nova identifies seeing me with this red key fob. I don’t
332 know who this Blaise Nova is. Such a weird name. I have never met the person before. Or maybe
333 I have? I mean, people are always trying to get my attention on the street. I am quite easily
334 recognized in the city. So perhaps I ran into them somewhere around Santa Ivo. I was also told
335 about supposedly being seen with the red key fob or a red watch. I did have a red watch back in
336 the fall of 2022. However, I no longer have that watch. I gave it away. Also, I would never wear
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337 a red bracelet or watch again, especially not in court. I have progressed from red to maroon—
338 which are completely different colors.
339 Exhibits 25 and 26 are photographs of two different people: Poe Cameron (Exhibit 25)
340 and Memphis Rayne (Exhibit 26). I recognize these people from the news. They were found to
341 be involved in the Miller Tower heist by the police. I understand that the police have connected
342 the people in these photos to the phones that supposedly called the phone found in my house as
343 shown in Exhibits 14 and 15 above. I have no reason to dispute that these people were tied to
344 those phones. I also can’t say whether I have ever seen these people before. I meet a lot of
345 people. I may have seen them at some point in my life. But I did not enter Miller Tower with
346 them and steal anything from the vault. Such a proposition is ludicrous.
347 Exhibit 5 is the key card that Emory Sands gave to me to look at the roof. I lost that
348 shortly after I visited the roof in early October. I know the police found it at the site of the heist. I
349 remember having it with me when I left Miller Tower on the day Sands gave it to me. So, I have
350 no idea how it ended up back in Miller Tower.
351 Exhibit 24 is my business card.
352 Exhibit 31 is the video footage of the Miller Tower heist. My attorneys showed me the
353 section of Detective Bahmani’s report that contained Detective Bahmani’s personal notes
354 describing the Miller Tower heist video footage. I have also reviewed Exhibit 29. And while I
355 hate to admit it, Detective Bahmani’s report notes and Exhibit 29 accurately described what
356 happened in the video footage as far as I was able to tell. Of course, seeing Cyprus engage with
357 the waitstaff and show Cyprus’s true colors was quite the treat. However, the beating of Emory
358 Sands was disturbing. I would never condone such actions or behavior. Sands was a great person
359 and didn’t deserve anything like that. Only a real brutish person would act in such a way.
360 Finally, I know that the police claim to have my fingerprints and DNA inside one of the
361 apartments. Clearly this is a mistake. I don’t know anything about DNA or fingerprint matching,
362 they are too much of a soft science for me to care. But clearly the science underlying them is
363 wrong if they found a match to me. I don’t even remember being in Ivy Lane, let alone in Unit
364 322.
365 If it isn’t obvious already—outside of what I have already discussed above—I deny all
366 the state's allegations and the evidence they will present against me in trial. I’m sure there are
367 many things they will try to unfairly accuse me of and try to ruin my good name. I reserve the
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368 right to deny any allegations or facts that I have not discussed in this affidavit in order to protect
369 myself and my name.
370 I swear or affirm the truthfulness of everything stated in this affidavit. Before giving this
371 statement, I was told I should include everything that I know may be relevant to my testimony,
372 and I followed those instructions. I know that I can and must update this affidavit if anything
373 new occurs to me until the moment before opening statements begin in this case. I will note
374 again that this affidavit was made against the advice of counsel, and I believe that it makes
375 everything clear. I soon expect the police to drop the charges against me once they see how
376 rational my explanations are.
377
378 ____________________________________
379 /s/BERKLEY F. DE LA PORTA
380
381 Duly Subscribed and Sworn By Me:
382
383 ____________________________________
384 /s/B.F. GATES
385 Notary Public

386 ADDENDUM TO AFFIDAVIT OF BERKLEY F. DE LA PORTA

387 I was recently informed of the FBI and SIPD’s failure to keep their electronic storage
388 secure. I guess they lost everything, including the footage in Exhibit 31 that I watched earlier.
389 You would not believe how shocked I am to learn of this development. I knew that the SIPD and
390 the Feds were wrongfully accusing me and saying that I’m a mastermind of heists. And now
391 this? Who would have thought that the SIPD and FBI would have fallen for something as
392 rudimentary as a phishing malware attack? When I heard that from my lawyers, I said, “You’re
393 kidding right?” If only there was a company of mine that SIPD and the DOJ could have
394 partnered with approximately 5 years ago to prevent such types of attacks. Yeah, all you haters
395 out there really thought Berkley was going down for this crime. But it’s a real shame that our
396 competitor that SIPD and the Department of Justice hired to protect their evidence servers had
397 that hole in their coding. Guess that’s what you get for always choosing the lowest bidder.

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398 Now their case is even weaker, and do you know what I did once I heard about the
399 attack? All I did was smile. Don’t even get me started on that terribly biased Agent Burke. But I
400 knew this malware attack would finally expose the SIPD and Agent Burke’s incompetence. I’m
401 not saying I have the knowhow to create the malware attack that was used on the SIPD’s system,
402 because I’m not sure if I do anymore. It’s been a while since I worked on programming. But
403 clearly whoever did that is really a mastermind.
404 Regardless, before the police start accusing me of things I didn’t do again, I figured I
405 would update my affidavit just to make it clear that I had nothing to do with the attack (and that I
406 am again making this statement against the strenuous—and annoying—advice of counsel).
407
408 ____________________________________
409 Date: August 13, 2023 /s/BERKLEY F. DE LA PORTA
410
411 Duly Subscribed and Sworn By Me:
412
413 ____________________________________
414 /s/JACKSON KUNDE

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1 I. Report of Investigation of Agent Shar Burke

2 Written: April 17, 2023
3 Special Agent, Art Crime Team
4 Federal Bureau of Investigation,
5 935 Pennsylvania Avenue,
6 Washington, D.C.

7 Background Information
8
9 I am Agent Shar Burke. I serve as a senior special agent for the Art Crime Team of the Federal Bureau of
10 Investigation (FBI). I am based out of the FBI’s Washington D.C. Field Office.

11 I joined the FBI as a special agent in 2006 and was assigned to the Violent Crime Squad in Boston. As
12 part of the Violent Crime Squad, I served on 14 high-value robbery investigations from 2006-2016. In
13 2016, I was promoted to senior special agent and deployed to Iraq as part of counterterrorism efforts to
14 recover Near Eastern antiquities and artifacts plundered by the Islamic State of Iraq and the Levant
15 (ISIL). Following the successful recovery and repatriation of approximately $49 million worth of
16 historical artifacts to the Iraq National Museum over a two-year operation, I returned stateside, where I
17 was relocated to Washington and assigned to the Art Crime Team.

18 The FBI’s Art Crime Team was established in 2004 with the mission of developing a rapid-deployment
19 team that could investigate the looting of the Baghdad Museum following the Iraq War. It is housed
20 within the FBI Criminal Investigative Division’s Transnational Organized Crime Section. Since its
21 inception, the Art Crime Team has recovered more than 20,000 objects valued at over $900 million.

22 It is difficult to paint a clear picture, statistically speaking, of the scale and impact of art crime. The
23 transnational phenomenon spans forgeries, fakes, money laundering, illicit trafficking, illicit excavation,
24 cultural spoliation, theft, and looting — and can be intertwined with other forms of organized crime, such
25 as drug smuggling and arms trafficking, as well. An annual report released by the International Criminal
26 Police Organization (Interpol) indicates that in 2020, the organization’s 72 member countries seized a
27 whopping 854,742 cultural objects including paintings, sculptures, numismatic items, archaeological
28 artifacts, and library materials. But Interpol’s seizure count pales in comparison to a more speculative
29 number released in 2020 by the United Nations Educational, Scientific and Cultural Organization
30 (UNESCO), which estimated that the illicit cultural property trade is worth $10 billion annually.

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31 The 24 special agents assigned to the Art Crime Team are responsible for any case of stolen art within
32 federal jurisdiction. These cases usually involve stolen art that has traveled across state lines or was stolen
33 from a museum. Cases come to the FBI in two ways. First, through local police departments, who act as
34 our partners in the investigation. Second, the FBI receives tips from the public or from a network of
35 confidential informants. This network of informants gives us an edge in pinpointing sales of stolen art
36 since art theft is not perpetrated by your average thief and stolen art is not sold to your run-of-the-mill
37 fence or pawnbroker.

38 Special agents serving on the Art Crime Team must undergo extensive specialized training. Agents are
39 trained not only in styles of art, the vocabulary of art, and art history, but also in the business of the art
40 world. Agents in the field are specialized in tracking and investigating market trends and often identify
41 stolen art just as it is coming back into the marketplace. Agents receive extensive training in art handling,
42 authentication, curation, conservation, and analytical techniques, both from a historical and a scientific
43 perspective. Agents are also experts in experts. Behind the Art Crime Team is a network of dozens of
44 subject matter experts in the art world who we turn to depending on artist or medium. Additionally, over
45 the course of several decades of art theft investigations, the Art Crime Team has also cultivated a network
46 of trusted art buyers, traders, and industry insiders who act as confidential sources of information during
47 investigations.

48 Alongside the aforementioned specialized training in art crime investigations, I have also received
49 training in various cybersecurity investigative methods. I have received Certified Information Systems
50 Security Professional (CISSP) and Certified Network Security Investigator (CNSI) certifications
51 following a month-long cybersecurity training with the FBI Cyber Action Team. This training included
52 extensive training in cryptocurrency investigations and digital forensics. I have also appeared as an expert
53 witness in art crime investigations in four cases, and my expert testimony has been accepted by the court
54 every time. In one of those cases I was also accepted as an expert in cryptocurrency investigations and
55 digital forensics. In each of those four cases, I have offered testimony for the prosecution. In this case, the
56 Bureau did not authorize any subpoenas to have me appear and testify as a witness at trial. While it is
57 typically appropriate protocol for the FBI to approve such subpoenas when a federal agent is requested to
58 appear in state court proceedings, I will be taking personal PTO days to offer testimony and will testify
59 voluntarily if called by the prosecution in today’s trial.

60 Initial Involvement with Miller Tower Heist

61
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62 On November 2, 2022, I was approached by my partner, special agent Michael Rogers, with the video
63 footage of an art theft in Miller Tower, Santa Ivo City, Midlands. Rogers did not inform me where he
64 obtained the footage from, but it is not unusual for local and state law enforcement agencies to contact the
65 Art Crime Team with evidence of art theft. Upon reviewing the footage, a few things immediately stood
66 out to me as notable:

67 ● The thieves appeared to be a party of some means. They were organized in their movements and
68 seemed to have a common plan. They were able to acquire and arrive in a private helicopter to
69 perform their initial infiltration of Miller Tower. Most common robbers, in my experience, do not
70 possess the resources to obtain such means of transportation.

71 ● Upon exiting the helicopter, one of the three thieves clearly held a key card in their hand as the group
72 approached the rooftop stairwell door. The thief holding the key card attempted to use it to access the
73 electronic control panel of the stairway access point on the roof of Miller Tower. The thieves were
74 admittedly unsuccessful in using the key card and had to resort to physical means to get the stairwell
75 door open. Yet the fact that they had a key card, and seemed to believe it would work on the control
76 panel, was notable in and of itself.

77 ● The thieves possessed a cell jammer. The use of jammers to block cell signals and radio
78 communications is highly regulated by federal law and suggests a degree of sophistication on the part
79 of the thieves. A degree of sophistication which was inconsistent with the thieves’ other various
80 blunders, like their failure to successfully operate the rooftop access door via the key card, and the
81 fact that one of the thieves dropped his or her firearm and engaged in a physical altercation with the
82 security guard. This suggested the possibility of an outside planner to me.

83 ● The thieves were never truly visible on the security camera feeds for the roof, hallways, and vault
84 without their masks. They appeared to place themselves away from camera positions and wore masks
85 while inside the vault. Their movements seemed to indicate they were aware of the locations for all of
86 the security cameras.

87 ● The thieves had prior knowledge of the dress code at the event at Miller Tower, given that they were
88 able to alter their clothing to blend in with the crowd prior to making their exit.

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89 After making these initial observations, I knew immediately who the perpetrator was. It was a criminal I
90 had been searching for the past five years, to no success. This criminal, who was responsible for five
91 other art thefts, was dubbed “The Morisot Mastermind” by the FBI. This criminal usually went after high-
92 profile targets (like the auction at Miller Tower), and usually targeted unobtainable pieces of art made by
93 the artist Berthe Morisot. Furthermore, every Morisot Mastermind theft suggested insider information,
94 including the thieves seemingly aware of camera positions, and having knowledge of access codes and
95 passes even though the security systems were installed by different companies. All of the similarities
96 between the prior Morisot Mastermind heists and the October 31st heist made it obvious that the Morisot
97 Mastermind was behind the Miller Tower heist as well.

98 Upon finding my old nemesis had once again reared their nefarious head—though at this point I did not
99 know the person’s actual identity yet—I leveraged my law enforcement contacts in Midlands to discover
100 the name of the investigator in charge of the Miller Tower investigation, Detective Kit Bahmani. I gave
101 Det. Bahmani a call on November 2, 2022, and explained my suspicions. I informed Det. Bahmani of the
102 sophisticated nature of the Morisot Mastermind and told them the Mastermind was likely not among the
103 thieves but controlling the theft from behind the scenes. While they were initially reluctant to cooperate, I
104 was able to convince Det. Bahmani that we were after the same suspect by detailing how the thief only
105 targeted Morisot paintings. I did not know if the Miller Tower heist featured any Morisot paintings at this
106 point, but I decided to stand by my initial suspicion. It was at this point that Det. Bahmani informed me
107 that among the numerous artifacts stolen from Miller Tower were three priceless Morisot paintings,
108 including “Dans les Terres du Millieu.” Two other Morisot paintings and other valuable artifacts had also
109 been stolen from the vault. Taking artifacts not made by Morisot did not fit the pattern established by the
110 Morisot Mastermind in any of their five prior heists, where they exclusively targeted Morisot paintings.
111 But given the similarities between the five prior thefts and the theft at Miller Tower, I stood by my hunch
112 that the Morisot Mastermind was the perpetrator of the Miller Tower heist and offered my expertise to
113 Det. Bahmani. They told me I could shadow the investigation in exchange for offering FBI resources, and
114 I booked a flight to Santa Ivo City immediately.

115 Investigation into Miller Tower Theft

116
117 My initial step upon arriving in Santa Ivo City was to try and locate any underground markets for stolen
118 artwork or jewels in the Santa Ivo city limits. But my investigation failed to uncover any leads. Santa Ivo
119 City has no trace of any active organized crime syndicates. On November 15, 2022, Det. Bahmani
120 informed me of several breakthroughs in the case. The Santa Ivo Police Department had collected blood

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121 evidence from the scene of the theft, which matched a known felon named Memphis Raynes. Blood was
122 also identified on a Halloween mask that was collected from the alley next to Miller Tower. However, the
123 blood did not match anyone in the Midlands criminal database. I was provided a copy of Det. Bahmani’s
124 written summary of the October 31, 2022 Miller Tower security footage (Exhibit 29). Det. Bahmani’s
125 summary of the security footage accurately depicts the footage that I watched. The FBI’s copy of the
126 Miller Tower security footage was stored on our server.

127 On December 3, 2022, Det. Bahmani gave me a call and asked me to meet them at an apartment building
128 called Ivy Lane at 1 PM. Upon arriving at the building, I was informed that Raynes had rented an
129 apartment at the building. Det. Bahmani and I questioned the property manager, Blaise Nova, about the
130 apartment in question, and Nova provided us with a lease agreement signed by Memphis Raynes for
131 apartment 322 from August 9, 2022 to November 9, 2022. Nova also confirmed that Raynes’s sibing, Poe
132 Cameron, had been seen at the apartment and had even engaged in a conversation with Nova. Based on
133 the possibility that there might be additional forensic evidence located inside the apartment, Det. Bahmani
134 called a forensic technician to perform a sweep of the unit, which commenced at 2:10 PM. The search
135 took approximately one hour and yielded several items, including unwashed silverware and china, linens
136 and towels which appeared to have blood on them, and all the garbage for the unit. I left Det. Bahmani to
137 oversee the garbage collection and review, and I left the scene to report back to the Art Crime Team.

138 By December 15, I knew, based on the patterns established by previous Morisot Mastermind heists, that
139 we had a limited amount of time to intercept the stolen art before it was sold to a buyer. According to
140 what we knew from the prior Morisot thefts, the artwork was usually sold within 60 days of the theft to a
141 buyer within the state, typically in auctions over the dark web. Based on these factors, speed was of
142 absolute importance to corner the thieves before they sold the paintings and vanished.

143 The FBI Art Crime Team regularly collaborates with the FBI’s Cyber Action Team, Cryptocurrency
144 Enforcement Team, and Virtual Currency Teams to track sales of stolen artifacts across the dark web.
145 Following standard procedure, I utilized all of those collaborative resources in this case. While dark web
146 investigations take a significant level of inter-agency cooperation, it is important to note that for the most
147 part, FBI teams execute individual dark web strategies containing various degrees of overlap and
148 comprehensiveness, without an overall coordinated agency-wide dark web strategy. While this means that
149 the FBI does not possess a uniform set of operational guidelines with regards to dark web investigations,
150 it leaves individual teams a great level of discretion and flexibility in crafting such investigations. Though
151 there was much inter-division and inter-agency work in this case, each step of the investigation was
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152 overseen by me, and the techniques utilized were all standard techniques used for cyber-tracking in the
153 field of digital forensics. These techniques have all been reviewed in various peer-reviewed journals
154 including the Midlands Journal of Hacking Techniques and Computer Virology, the Journal of
155 Cryptology, and the Journal of Cybersecurity by Oxford University Press.

156 Keeping those factors in mind, our goal was to craft a dark web digital forensic investigation which would
157 not only isolate the auctions we were looking for, but also give us enough information to track down the
158 identity of the Morisot Mastermind. Our investigative methodology was driven by trial and error. The
159 greatest challenge the Art Crime Team faced in locating the Morisot Mastermind’s identity up until the
160 Miller Tower investigation had been narrowing our search to the correct auction for the stolen art. In my
161 experience, following high profile art thefts like those perpetrated by the Morisot Mastermind, dark web
162 marketplaces are flooded with replica artwork or scammers attempting to exploit the theft. These so-
163 called “copy-cat” auctions have, in the past, caught investigators off guard and left us unable to pinpoint
164 the actual auction in time. To that end, I devised an investigative protocol for this case that would offer us
165 accuracy on an expedited timeline.

166 Setting Up Digital Sting Operation

167
168 The first step of the investigation was narrowing the scope of our search. The dark web is a sub-section of
169 the internet which is not indexed by any search engine. It is hidden by design and requires special
170 browsers to access. The size of the dark web is impossible to truly map, given that it is completely
171 unregulated and hidden. This naturally presents a unique set of challenges to finding one specific sale
172 among thousands of illicit marketplaces.

173 To aid in our narrowing efforts, I asked every Art Crime Team special agent to put out a call to every
174 contact they had within the Midlands arts industry. Once again, Agent Rogers came through, providing
175 me with the contact information for a grey market art dealer who frequently acted as a middleman for
176 wealthy purchasers in illicit art purchases. Agent Rogers informed me that his contact had never served as
177 an informant before, but the contact was willing to offer information in exchange for immunity in an art
178 forgery case they were being prosecuted for. I asked Agent Rogers to set up a meeting between myself
179 and the contact as soon as possible.

180 On December 21, 2022, I met with Agent Rogers’s contact, who confirmed the details of the art forgery
181 case they were being prosecuted for. I informed the contact that while I was not authorized to make any
182 deals, I could plead their case to the District Attorney, if their information proved useful. The contact
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183 agreed. They showed me a business card they had received a week before the Miller Tower theft. The
184 business card contained an IP address and a password. The password was MillerMorisot103122. The
185 informant indicated that they had spoken to several other grey and black-market traders around Midlands
186 who had received similar cards in the week preceding the theft. The specific details of the password,
187 including the date of the heist, suggested to me that there was a strong possibility that this was the auction
188 we were looking for.

189 Digital Sting

190
191 The presence of a specific IP address and password being required to access a marketplace once more
192 suggested a high level of sophistication on the part of the Morisot Mastermind. Most users who access the
193 dark web will do so using The Onion Router, or TOR, the most commonly used darknet browser. Many
194 sites on TOR are given a random URL which ends in .onion, and TOR will divert user traffic through
195 multiple nodes on its way to the client, making files somewhat difficult to trace. However, to a
196 cybersecurity professional, activity on TOR can still be traced, with the biggest vulnerability of the
197 browser being the point where information travels between the exit node and the destination site, which is
198 an unencrypted area. To circumvent this security risk, one might use a peer-to-peer (P2P) model of
199 encrypting information, which offers additional security safeguards than the TOR protocol. The
200 requirement of an IP address, password, and a network of pre-chosen individuals suggested the use of a
201 P2P network called Freenet, which is used to share highly encrypted, decentralized data. Access in
202 Freenet is restricted to a predetermined list of users, which provides a higher degree of security than other
203 encryption protocols. Access is created through a backend web application and requires both the IP
204 address and password to access. The traffic is then routed through each trusted user, who becomes a node
205 in the flow of data. System access is set to expire after 10 minutes, making it near impossible to trace.
206 This system, once used by dissidents to circumvent censorship laws, is now a popular tool for cyber
207 criminals to offload malicious content and stolen goods.

208 On December 21, 2022, I contacted FBI Cyber Action Team Special Agent Brian Dressel to assist me in
209 safely accessing Freenet and access the IP address our informant had provided us. Accessing the IP
210 address pulled up an auction page. The page design was minimalistic, only featuring the stolen non-
211 Morisot paintings on a black background. Clicking each painting took the user to a bidding site for that
212 painting, which showed the current maximum bid for the painting and a 48-hour countdown clock.

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213 Upon accessing the auction page, I contacted Det. Bahmani and devised a plan to track the auction back
214 to its source. Given the limited information and the 10-minute cutoff for all connections to the auction
215 site, unraveling the encryption on the auction site seemed highly improbable, especially factoring in the
216 tight window we knew we had before the Morisot Mastermind vanished. In the face of those restrictions, I
217 believed tracing the address of any potential cryptocurrency transaction for the stolen artwork would
218 maximize our chances of apprehending the thieves.

219 I contacted my supervisor, Supervisory Special Agent May Cooper, the agent-in-charge of the Art Crime
220 Unit. I briefed her on the situation and requested Bureau funds to secure a winning bid on the non-
221 Morisot paintings. Agent Cooper was initially opposed to the idea, as sales of the paintings were likely to
222 exceed $5.5M based on the latest estimates at the time. Agent Cooper also said that there was no
223 guarantee that this theft was the work of the Morisot Mastermind since we had never seen a Mastermind
224 theft that included non-Morisot artifacts. Agent Cooper also told me she had an issue with striking deals
225 with unknown criminals to get “unverifiable” information. I told Agent Cooper that this case had all the
226 hallmarks of the Morisot Mastermind and matched up perfectly with the FBI’s profile of the criminal. I
227 said that this could be the end of a five-year hunt for the Bureau. Finally, I was able to persuade Agent
228 Cooper to approve the use of funds with the rationale that the Bureau could retrieve the funds from the
229 Morisot Mastermind once we had them in custody.

230 Upon securing the use of funds on December 22, 2022, I set up a temporary command center at the FBI
231 Field Office in Midlands Center. The command center included me, Agent Dressel, who had flown in
232 from Boston, two cybersecurity technicians from the Midlands Center field office, and our informant. I
233 instructed Agent Dressel to use our informant’s login information to place bids on the two paintings.
234 After six hours of monitoring the auction site in 10-minute increments, Agent Dressel was able to secure
235 all three of the non-Morisot paintings at a combined price of $5.8M. Within 5-minutes of the auction
236 closing, at 2:59 AM on December 23, 2022, the auction site was taken offline. Digital images were taken
237 to preserve the auction site for evidence.

238 At approximately 3:31 AM on December 23, 2022, the informant received a phone call from a restricted
239 and secured phone number. The informant was instructed to answer, and the call was surveilled and
240 recorded by the cybersecurity technicians present in the room, who were unable to trace the caller’s
241 location during the call. The caller, using some form of voice anonymization, provided the informant with
242 a wallet address in the Bitcoin network. The informant was instructed to deposit 346 BTC (equivalent to
243 approximately $5.8 million) into the wallet within 24 hours. The informant was instructed to demand
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244 photographs for proof of authenticity and possession from the seller. The seller informed the informant to
245 use their auction IP address and password to access an encrypted Freenet chatroom in 24 hours.

246 At 3:35 AM on December 24, 2022, the anonymous caller provided photographs to verify authenticity
247 and possession through a secure Freenet one-way chatroom. The caller was provided with an address in
248 Midlands Center to send the paintings via courier delivery and payment was authorized. The bitcoin were
249 deposited in the wallet as instructed at 3:40 AM on December 24, 2022. At 11:21 AM on December 25,
250 2022, the paintings were delivered to the informant via courier and were taken into FBI possession.

251 Digital Forensics to Identify Heist Participants

252
253 In the weeks following the incident, the Art Crime Team, Cyber Action Team, and Cryptocurrency
254 Enforcement Team collaborated to trace cyber transactions and identify criminals. Despite the dark web’s
255 complexities, law enforcement, including the FBI, has developed tools to navigate the intricacies. Certain
256 tools originally used by criminals can actually be very helpful for criminal investigations.
257
258 One such example is cryptocurrency. Because this case involved Bitcoin, I will explain how these
259 systems work in terms of Bitcoin, but there are many other cryptocurrencies. Bitcoin is a cryptocurrency
260 leveraging Blockchain technology. Blockchain functions as a decentralized ledger that documents
261 transactions across a network of computers. Each transaction forms a block, and these blocks are
262 sequentially linked, forming a chronological and immutable chain. Bitcoin operates off of the Blockchain
263 technology, which means there is a publicly available ledger meticulously recording every cryptocurrency
264 transaction.
265
266 When a user initiates a Bitcoin transaction, it undergoes verification by the network’s nodes (computers).
267 These nodes deploy sophisticated cryptographic algorithms to authenticate the transaction, ensuring that
268 the sender possesses the requisite funds. Once verified, the transaction joins a block containing other
269 validated transactions. Crucially, the blocks are securely linked through cryptographic hashes, fortifying
270 the chain against tampering. The decentralized and transparent nature of this blockchain design
271 guarantees that no single entity controls the entire network, furnishing a level of security and trust absent
272 in traditional centralized systems. Operating on a peer-to-peer network, Bitcoin enables users to transact
273 without intermediaries like banks. The scarcity of bitcoins is maintained through mining, a process
274 wherein individuals or groups of miners employ powerful computers to solve intricate mathematical
275 problems. The first miner to solve the problem adds a new block to the blockchain and receives newly
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276 minted bitcoins as a reward. This process not only introduces new bitcoins but also validates and secures
277 transactions on the network. To store Bitcoin, a digital wallet is created. This can be done though crypto
278 exchanges or people can also create new local wallets by utilizing their devices (computers, smart phones,
279 etc.) to act as a node within Bitcoin’s network.
280
281 There are a number of things that made cryptocurrency a great investigative tool for digital forensic
282 investigations like this one. First, the ledger system makes it so that each and every transaction within the
283 Bitcoin system is traceable and trackable. Second, in order to translate cryptocurrency into the non-crypto
284 marketplace (where the vast majority of transactions occur on a day-to-day basis) one must cash out. This
285 exit point gives investigators the opportunity to connect the anonymous Bitcoin wallet owner to a fiat
286 (government regulated) currency bank account. Third, Bitcoin wallets can be seized by investigators to
287 retrieve stolen bitcoin and prevent the wallet owner from cashing out. Seizure is possible through
288 determining either the seed value or the private key for the wallet. Once one of those values is
289 determined, the wallet can be taken over just as easily as someone can take over an account using the
290 username and password.
291
292 For this case, we were able follow the blockchain ledger transactions to follow the money as soon as the
293 informant paid the $5.8 million (or 346 bitcoin). The names for wallets are long strings of numbers and
294 letters, so I will refer to these wallets as Wallet A, Wallet B, etc. The informant transferred the Bitcoin to
295 Wallet A (the wallet we were given by the anonymous caller). Within 20 seconds, the Bitcoin was
296 transferred out of Wallet A and, as they say, so the hunt began. We then followed the blockchain
297 transactions from Wallet A to Wallet B, then further transactions to Wallet C and another transaction to
298 Wallet D. Each transaction was the exact same amount of bitcoin. At Wallet D, the plot thickened, and the
299 amount was split between two wallets. Approximately 60% of the bitcoin (207.6 bitcoin) was sent to
300 Wallet E with the remaining 40% sent to Wallet F. The bitcoin in Wallet F was cashed out using a dark
301 web exchange within 10 seconds of the bitcoin hitting the wallet. Such dark web crypto exchanges are
302 untraceable and usually housed in countries without any sort of regulations to monitor such transactions.
303
304 Wallet E however was a different story. That wallet sat with the bitcoin in it for approximately 24 hours
305 without any movement. This allowed us to retrieve a warrant for seizure of the wallet. The FBI Cyber
306 Action Team was then able to seize the wallet after using standard FBI cyber decryption software to
307 determine Wallet E’s private key. I cannot reveal the methods used for this step as they are top secret.
308 However, such methods have been accepted by many courts—including the case mentioned above in
309 which I was certified as a digital forensics expert.
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310
311 Upon gaining control of Wallet E on December 28, 2022, we scrutinized its transaction history. All cash
312 outs were via TangerineNeonX (“TaNX”), a legal U.S. crypto exchange. To cash out, users typically need
313 to link their bank accounts to the exchange, sell their bitcoin on the platform, and then withdraw the
314 resulting currency to their bank. U.S. Legal exchanges are platforms that comply with financial
315 regulations and require users to undergo identity verification procedures, commonly known as “Know
316 Your Customer” (KYC) checks. This process ensures transparency, security, and adherence to legal
317 standards and also allows for investigations like this one to continue the trail. The KYC information
318 obtained via another warrant showed that Wallet E’s cash out transactions were all made to a bank
319 account owned by Bern-Steel Ltd. In the British Virgin Islands. Cooperation with British intelligence
320 authorities led us to obtaining the available financial records and corporate registration papers for Bern-
321 Steel which showed that it was a shell company. A shell company is an inactive legal entity without
322 substantial business operations, often established for specific financial purposes or to hold assets. It
323 provides a level of separation between its activities and the identities of its owners. Though recent
324 regulation changes in dark money market centers such as the British Virgin Islands, new regulations
325 require the recording with the corporate registration the name of a natural born (as in human) owner of the
326 business, which was listed as Memphis Raynes and Poe Cameron for the Bern-Steel company.
327
328 The transactions in the Bern-Steel bank account included a few deposits coming from TaNX over a 5-year
329 period, but also more recent payments coming in from an account registered to a MSIG subsidiary
330 company called Goodspeed Industries. Everyone knows De la Porta owns MSIG. It’s not a secret. The
331 first transaction was a $3,000 deposit on August 9, 2022 from Goodspeed Industries. Goodspeed
332 Industries deposited $1,500 on September 1st and October 1st 2022. Withdrawals in the amount of $1,500
333 occurred on September 1st and October 1st. Within one day of each of these deposits, the money was
334 withdrawn via money order. Money orders provide a level of anonymity as they do not include personal
335 banking details. These money orders can be cashed out at any banking institution without the requirement
336 of providing personal details. I cannot say for certain who exactly cashed out these money orders, but
337 they were cashed out from a bank account tied directly to Raynes and Cameron. Finally, two payments of
338 $10,000 were deposited into the Bern-Steel account from a Goodspeed Industries subsidiary company
339 called Matchstick & Sons on September 15th, October 15th, November 15th, and December 15th 2022. Each
340 of these payments were also cashed out separately via money order except for one of the payments on
341 December 15th 2022. This corresponds with the timeline of Cameron’s arrest and thus inability to obtain
342 the funds any longer. Seeing these transactions, I requested a warrant for the Goodspeed Industries
343 financials, which was granted.
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344 These records showed that De la Porta was a corporate board member for both Goodspeed Industries and
345 Matchstick & Sons along with 3 other people. I confirmed that the other people did not have any
346 connection to this heist and so I excluded any analysis related to them. Goodspeed Industries, a seemingly
347 legitimate part of MSIG’s financial enterprise, operated within a complex network of corporations,
348 holding companies, and trust accounts all owned by MSIG. The use of holding companies or shell
349 companies in and of themselves are not illegal—but the use of funds by those companies and the source
350 of the funds can indicate illegal activity. Goodspeed Industries’ financials included thousands of
351 seemingly legitimate transactions, but about 20 transactions raised suspicion. A pattern emerged when
352 comparing Wallet F’s transaction data with Goodspeed Industries’ records.
353
354 Over an 8-year period, whenever bitcoin was cashed out from Wallet F, a similar amount of money would
355 be deposited into Goodspeed Industries within 3 days. The amounts were not exact matches cent for cent
356 but looking at the rate of bitcoin for those 3-day time periods, the deposits were within 85-90% of the
357 value of bitcoin cashed out. This difference in amounts is easily explained by the volatility of bitcoin
358 value and the transaction fee for dark web exchanges which the FBI has averaged to be between 10% and
359 22.3% of the transaction (in comparison legal crypto exchanges have .01% and 1% transactions fees).
360 This included the cash out of the 138.4 bitcoin on December 24, 2022, which was traced from the
361 informant’s payment for the stolen paintings. A deposit of $2.021 million (which is 86.7% of the closing
362 day value of 138.4 bitcoin on December 24, 2022) was placed in Goodspeed Industries and labeled as
363 “EOY Cash Deposits 1.” While I cannot say with 100% certainty that the cash outs from Wallet F were
364 deposited in the Goodspeed Industries account, I can say in my experience with digital forensics and from
365 5 years of experience in tracking similar types of financials with the Art Crimes Division that I am highly
366 confident that these cash outs were directly paid to Goodspeed Industries following illegal heists or other
367 transactions, including the FBI’s purchase of the three paintings as part of the sting operation.

368 On February 10, 2023, I informed Det. Bahmani of the findings of my digital sting operation. I showed
369 them the financial and digital forensic evidence connecting De la Porta to the theft and explained that
370 based on the existing FBI profile, De la Porta was likely the Morisot Mastermind. Based on this evidence,
371 Det. Bahmani requested a warrant to search De la Porta’s home.

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372 FBI Profile

373
374 The existing FBI profile of the Morisot Mastermind has guided the Bureau’s efforts in apprehending the
375 criminal for the past five years. It is my opinion, based on my review of the profile, that Berkley F. De la
376 Porta was likely the Morisot Mastermind.

377 There are several key traits the profile identifies as being traits likely possessed by the Morisot
378 Mastermind. The profile notes a high degree of sophistication and intelligence and access to significant
379 resources and insider information. The Mastermind exhibits meticulous planning, attention to detail and a
380 strategic mindset, consistent with “individuals who hold positions where strategic thinking and attention
381 to detail are paramount, like top-level business executives.” They also prove themselves to be anything
382 but a petty criminal, organizing and executing complex operations to offload the stolen artifacts. Finally,
383 the Mastermind has proven countless times that they have a long reach. They have shown themselves
384 capable of hitting cities across the United States and vanishing within a short timeframe. Based on all
385 these factors, it seemed highly unlikely that Memphis Raynes and Poe Cameron, who were likely
386 involved in the actual theft at Miller Tower, would also be the Morisot Mastermind. The profile notes that
387 the Mastermind had a tendency to use different crews for their various thefts, and the Mastermind was
388 likely the puppet master pulling the operational strings from the background. This information suggests
389 that De la Porta, who was making payments to Raynes and Cameron, was the Morisot Mastermind.

390 Aftermath
391
392 Det. Bahmani and I executed the warrant for Berkley F. De la Porta’s home on February 15, 2023 at
393 10:14 AM. During the search we were able to recover all three of the stolen Morisot paintings, Paysanne
394 Nouvelle dans les Terres, Halva Dans les Terres, and Dans les Terres du Millieu, in one of De la Porta’s
395 underground cellar storage rooms which confirmed to me that De la Porta was the Morisot Mastermind.
396 De la Porta refused to make a statement regarding how the stolen items were in De la Porta’s possession.
397 Additional cultural heritage items (not stolen as part of the Miller Tower Heist) were uncovered at the De
398 la Porta home. All additional items were logged and were submitted for further investigative review
399 unrelated to the Morisot case. At the time of this report, none of the additional cultural heritage items are
400 believed to be connected to Morisot Mastermind cases. We also found a cell phone, which we processed
401 into evidence to analyze.

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402 The presence of the stolen Morisot painting was the final piece of evidence Det. Bahmani and I needed.
403 Det. Bahmani requested a warrant for the arrest of Berkley F. De la Porta, who was taken into custody by
404 the Santa Ivo Police Department on February 16, 2023. Eight days later, Det. Bahmani forwarded me the
405 Mass Spectrometry Testing Report of Midlands forensic analyst M. Nguyen. The test confirmed what I
406 already had assumed, that the three Morisot paintings found in De la Porta’s residence were authentic and
407 were the Morisot paintings stolen from Miller Tower on October 31, 2022. On March 3, 2023, I received
408 lab results confirming that De la Porta’s fingerprints had been found on the items retrieved from the
409 thieves’ apartment at Ivy Lane. On March 12, 2023, FBI technicians confirmed that the cell phone taken
410 from De la Porta’s home showed incoming calls received from both Memphis Raynes and Poe Cameron.
411 By April 8, 2023, the FBI Cyber Action Team identified four additional dark web auctions for some of
412 the other artifacts stolen from Miller Tower, including various Midlands historic memorabilia and
413 jewelry. These auctions were unable to be traced. The whereabouts of the additional stolen items which
414 did not appear for auction remain unknown.

415 I am familiar with the following exhibits:

416 Exhibit 1 is an invitation to the October 31, 2022 Sohi Children’s Hospital charity gala at Miller
417 Tower.
418 Exhibit 2 is a brochure for the October 31, 2022 Sohi Children’s Hospital charity gala at Miller
419 Tower.
420 Exhibit 3 and 4 are accurate diagrams of the 40th floor and rooftop of the Miller Tower,
421 respectively.
422 Exhibit 5 is a picture of a security keycard for the Miller Tower in Santa Ivo City, Midlands.
423 Exhibit 6 is a picture of Poe Cameron’s receipt from Zarzycki & Co dated October 7, 2022 for a
424 Halloween mask that was recovered by the Santa Ivo Police Department. It is a fair and accurate picture
425 of the receipt.
426 Exhibit 7 is a picture of Poe Cameron’s ring that was found by the Santa Ivo Police Department
427 during a search of Cameron’s residence pursuant to a search warrant. It is a fair and accurate picture of
428 Cameron’s ring.
429 Exhibits 9, 10, and 11 are pictures of the key fobs for Ivy Lane unit 322.
430 Exhibit 12 is the lease agreement for Ivy Lane unit 322 between Ivy Lane apartment complex and
431 Memphis Raynes.

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432 Exhibit 13 is the FBI transcript of our Confidential Informant’s December 23, 2022 call as part of
433 my investigation into the Morisot Mastermind case. The transcript is an accurate reflection of the
434 recorded call.
435 Exhibits 14, 15, and 16 are screenshots of call logs taken from the “Miller Tower” mobile phone
436 that was found in Berkley F. De la Porta’s home. Exhibit 14 identifies the call was received from “Poe
437 Cameron.” Exhibit 15 identifies the call was received from “Memphis Raynes.” Exhibit 16 is the same
438 date and time as the CI call that is transcribed in Exhibit 13. The number called was the number provided
439 to our CI as part of the Morisot Mastermind investigation.
440 Exhibit 17 is the confidential profile generated by the FBI for the Morisot Mastermind. I used it
441 as a part of my investigation. It is an accurate copy of that ESD0312 form.
442 Exhibits 18 and 19 are accurate copies of articles that I read as part of my investigation into
443 Berkley F. De la Porta. To the best of my knowledge, the statements attributed to De la Porta in the
444 articles are accurate statements. No corrections or redactions have been made.
445 Exhibit 20 and 21 are certified copies of the arrest records for Poe Cameron (Exhibit 20) and
446 Memphis Raynes (Exhibit 21).
447 Exhibit 23 is the mask that was found by in the alley next to the Miller Tower on October 31,
448 2022 by the Santa Ivo Police Department.
449 Exhibit 24 is a MSIG business card for Berkley F. De la Porta. I found a box of these cards at De
450 la Porta’s home when we executed our search warrant.
451 Exhibit 25 is an accurate photograph of Poe Cameron.
452 Exhibit 26 is an accurate photograph of Memphis Raynes.
453 Exhibit 27 is the medical records of Emory Sands detailing the injuries that Sands suffered during
454 the armed robbery on October 31, 2022.
455 Exhibit 29 contains the notes written by Detective Kit Bahmani after viewing the Miller Tower
456 security video footage from October 31, 2022. I separately reviewed the video footage and I agree with
457 Detective Bahmani’s descriptions of what happened during the October 31st heist.
458 Exhibit 30 is the text message report and declaration letter from Midlands Wireless for Poe
459 Cameron’s mobile phone that Detective Kit Bahmani received pursuant to a search warrant. It has not
460 been altered in any way since Detective Kit Bahmani showed it to me.
461 I have also reviewed the Report of Detective Kit Bahmani. I was aware generally of the
462 information Det. Bahmani was learning in real time because we would have regular discussions regarding
463 the aspects of the case that we each were handling. In addition, I was part of the search of Cameron’s
464 home as detailed in the section titled Supplemental Report 7 (12/05/22). Bahmani’s recollection of the
465 search and the items found in the search align with my memory of the events.
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466 I swear and affirm the truthfulness of everything stated in this report. Before writing this report, I was told
467 to include every relevant detail in my investigation. I have done so to the best of my abilities. I know that
468 I can and must update this report if anything new occurs to me, up until the moment before opening
469 statements begin at trial.
470
471 ____________________________________
472 /s/AGENT SHAR BURKE
473
474 Duly Subscribed and Sworn By Me:
475 ____________________________________
476 /s/HENRI LE MANS
477 Notary Public

478 ADDENDUM TO REPORT: August 14, 2023

479
480 On August 1, 2023, cybercriminals attacked FBI servers after gaining access through a software
481 vulnerability. The criminals were able to erase several pieces of evidence off the servers, including:

482 • Photo of auction site (taken 12/22/22)

483 • Recording of Morisot Mastermind call with Informant (created 12/23/22)
484 • Photo of encrypted chatroom (taken 12/24/22)
485 • Financial records for Bern-Steel Ltd, Goodspeed Industries, and Matchstick & Sons
486 o Since the completion of this investigation, Goodspeed Industries and Matchstick & Sons have
487 been declared bankrupt and reorganized within MSIG. Reobtaining any records from these is
488 therefore impossible.
489 • File on Informant
490 • FBI’s copy of the October 31, 2022 Miller Tower security footage

491 No other exhibits were affected by the cyber-attack.

492 I will also note that I have read the affidavit of Berkley De la Porta as amended on August 13, 2023.
493 While I have no proof that De la Porta was involved in the cyber-attack, De la Porta’s company MSIG
494 certainly has the capacity and ability to mount such an attack. They have been involved in a number of
495 cybersecurity deals with the U.S. Government, including the FBI. It would not surprise me if De la Porta
496 was behind these attacks.
497

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498 ____________________________________
499 /s/AGENT SHAR BURKE

500 Duly Subscribed and Sworn By Me:

501 ____________________________________
502 /s/HENRI LE MANS
503 Notary Public

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1
REPORT OF DETECTIVE KIT BAHMANI

1. TYPE
SANTA IVO POLICE DEPARTMENT
OFFENSE INCIDENT REPORT a. ORIGINAL
b. CONTINUATION c. SUPPLEMENT
OR FOLLOWUP
2. CODE NO. 2a. SORT 3. TYPE OF OFFENSE OR INCIDENT 4. CASE CONTROL NUMBER
0908 ARMED ROBBERY—GRAND LARCENY SIPD-22-0099
5. BUILDING NUMBER 6. ADDRESS
NA Miller Tower, 1985 Woodward Ave.
7. NAME OF AGENCY/BUREAU 8. AGENCY/BUREAU CODE 9. SPECIFIC LOCATION 10. LOCATION CODE
SANTA IVO POLICE M–27 40th Floor NA
DEPT.
11a. DATE OF OFFENSE/INCIDENT 11a. TIME OF OFFENSE/INCIDENT 12. DAY 13a. DATE REPORTED 13b. TIME REPORTED 14. DAY
10312022 Approx. 21:11 to 21:40 M 10312022 10312022 – 21:11 M
15. JURISDICTION (X) 16. NO. OF DEMONSTRATORS 17. NO. EVACUATED a. TIME START b. TIME END
EXCLUSIVE CONCURRENT PARTIAL PROPRIETARY 0 0 NA NA
ID CODE NAME AND ADDRESS AGE SEX RACE INJURY TELEPHONE
(a) (b) (c) (d) (e) CODE(f) (g)
Last Name, First, Middle Initial HOME
SANDS, EMORY UNK -- UNK 5 4155552375
RP
18. RELEVANT PARTIES

Number, Street, Apt. No., City and State BUSINESS

WOULDN”T YOU LIKE TO KNOW??
Last Name, First, Middle Initial HOME
SANDS, EMORY UNK UNK UNK 5 4155552375
VI Number, Street, Apt. No., City and State BUSINESS
WOULDN”T YOU LIKE TO KNOW??
Last Name, First, Middle Initial HOME
STILL AT LARGE AT TIME OF FILING UNK UNK UNK 0
SU
Number, Street, Apt. No., City and State BUSINESS
NA
1 STATEMENT OF FACTS/NARRATIVE: (10/31/22 to 11/01/22)
2 At 9:11pm on October 31, 2022, emergency services received a 911 call from someone
3 stating they were inside Miller Tower where masked persons were trying to enter through the
4 roof. The call cutout before the 911 operator could get all of the particulars. The 911 operator
5 forwarded the incomplete information to SIPD at 9:12pm. After receiving the information SIPD
6 dispatch sent out a priority call to all available units and investigators. I responded with a few
7 other patrol units. While this was a priority call, none of the units, including myself, were able to
8 arrive at the scene until 9:26pm. The Halloween parade downtown made getting from the station
9 to Miller Tower take three times longer than usual.
10 Upon arriving at the building, security seemed surprised by our presence. The security
11 guards on the ground floor were unaware of any call made and said that there was a party
12 happening on the 40th floor. We directed security to take us up to the 40th floor. Once there, we
13 found the party the guards had mentioned, and when we thought it had just been a prank call, a
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14 person came out of the secured area screaming for help. The person was dressed in an interesting
15 costume, but otherwise identified themselves as Cyprus Cosmos. Cosmos said that someone had
16 gained access to the secured vault in the back and that a security guard had been assaulted and
17 was lying there unconscious. We tried to radio for paramedics, but nothing was going through. I
18 sent Sergeant Rodrigo—one of my best officers who had recently transferred from crime ridden
19 Midlands Center—down to the first floor to call paramedics and to call for backup. I then
20 directed another set of officers to follow Cosmos to the injured guard and to secure the scene. I
21 then spoke to the DJ in the Cocktail Room, who identified themselves as Devin Johar, and asked
22 them to turn off the music. I addressed the crowd and told them to remain calm but that a police
23 investigation had begun and that none of them were allowed to leave the building until given
24 permission from SIPD. I then headed to the vault and saw building guard Emory Sands, the
25 Director of Security at Miller Tower, lying unconscious on the floor.
26 At 9:42pm, I returned to the elevator lobby and found Sgt. Rodrigo with the paramedics
27 and a few more officers. I directed the paramedics to the vault, then I directed Sgt. Rodrigo and
28 Officer Schaefer lead two teams of officers to collect statements and secure the 40th Floor. I
29 found someone who appeared to be a server for the event and asked them who was in charge of
30 the event. They said that Cosmos was the person to talk to.
31 Once the area was secured and all the party guests appeared to be calm, I proceeded into
32 the secured vault area to search for Cosmos. On my way through the area to the vault, Sgt.
33 Rodrigo flagged me down and showed me into what looked like a security office. Inside the
34 office, Sgt. Rodrigo had found what appeared to be a military grade signal jammer. Taking care
35 not to disturb any possible forensics on the signal jammer, I used a pencil to switch it off. My
36 suspicions that it was a signal jammer were confirmed because the moment I turned off the
37 device, both my and Sgt. Rodrigo’s radios began working again. Further, I now had cell phone
38 reception again and we were able to communicate with the rest of the team on scene.
39 I then found Cosmos near the vault door and asked for background on the event as well
40 as what was stored in the vault. Cosmos informed me that this was a big-ticket charity auction
41 and that there were many valuable pieces being stored in the vault. Big ticket items plus the
42 military grade signal jammer made me suspect at this point that we were dealing with a
43 sophisticated and well-thought-out heist. At 10:02pm, I called the forensics team and told them

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44 to arrive as quickly as they could. I asked Cosmos to remain in the kitchen until I was able to get
45 a full statement from them.
46 I then met with Sgt. Rodrigo in the security office again. Sgt. Rodrigo was able to find
47 security footage from earlier in the night. The security footage confirmed that there were several
48 individuals who had entered the secured area and removed items from the vault up to the roof
49 where a helicopter was waiting to take the items. I instructed Sgt. Rodrigo to have the forensic
50 folks pull all the security footage for the building.
51 The forensic team arrived around 10:30pm. I oversaw the collection of evidence during
52 that process. Blood was found in several places. First, on the door leading from the roof into the
53 internal stairwell down to the 40th Floor. Blood was also found in the vault with some blood
54 droplets in the hallway between the stairs and the vault. The forensic team also collected a
55 novelty Halloween mask in an alley near the security door exit on the ground floor of Miller
56 Tower. While it was Halloween and random discarded masks on the street is not uncommon, I
57 had a gut feeling that this might be connected to our heist crew. So, I asked the team to collect it
58 and send it to the forensics lab as well. In terms of other physical evidence, a number of items
59 were collected. A key card was found in the stairwell leading from the roof to the 40th floor. The
60 signal jammer was also collected for testing and examination.
61 By about 11:40pm, Sgt. Rodrigo and Officer Schaefer’s teams had completed the
62 preliminary interviews with guests and servers to help determine who at the party had any
63 possible information. They were able to identify about 10 people who were not compromised by
64 alcohol intoxication—Sgt. Rodrigo had a dust up with a particularly belligerent vampire at one
65 point apparently. But, after I spoke with the 10 sober people, I found that there were really only
66 two people with any information about the crime. No one else on the 40th floor had any
67 information related to the heist or what had happened in the secured area except for Cosmos and
68 a server named Parker Orlov. I interviewed both of them that night at Miller Tower and then
69 again the next day back at the District 2 precinct. My notes from those interviews are stored in
70 the department’s secured online file portal.
71 During our investigation, we were able to confirm from watching security footage and
72 talking with Miller Tower staff and members of the security team that all of the items listed in
73 the charity auction’s brochure (Exhibit 2) had arrived at Miller Tower via an armored truck
74 around dawn on October 31, 2022. I located a copy of the “security tac” plan in the 40th floor
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75 Command Center. It appeared from the “tac” plan that the auction items remained in the vault
76 from shortly after dawn until they were shuffled back and forth to the event hall for auction
77 during the cocktail hour that occurred from 6:30-7:30pm. At the end of the auction, the items
78 were to all be secured back in the vault until an armored truck arrived at Miller Tower when the
79 gala was over. From there the armored truck would deliver the items to their new owners.
80 Between reading the brochure and the “tac” plan, I was able to piece together a list of all
81 the items stolen from the vault and the approximate value of each item. I created a chart by hand
82 that evening that I later used to create the following table:
Item Value
Draft of Federalist No. 78 $1.4M
Gilbert du Motier Letter $750,000
Portrait of Lady Georgia $2M
Lord Felder Painting $1.5M
Columbia River Painting $1M
CMK ring $650,000
Duncan necklace $2.9M
Aqueousphish brooch & necklace $1.4M
Autographed baseball $500,000
Rare Cara Wine 2020 case $400,000
Chuggie’s bar stools (5) $800,000
Emerald & diamond earrings $1.1M
Cat-Lam diamond bracelet $850,000
Cutty Sark painting $450,000
Coronation tiara $975,000
Ouambo Thunderstorm painting $1.3M
Holstad Forest painting $1.1M
Midlands Constitution (draft) $2.5M
Leckrone Camera sketch $775,000
Boumbo charm bracelet $685,000
“Wealth of Nations” signed copy $1.7M

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83 In addition to the auction items, all three Berthe Morisot paintings that were provided for
84 display only (Paysanne Nouvelle dans les Terres, Halva Dans les Terres, and Dans les Terres du
85 Milieu) were also stolen from the vault. The three Morisot paintings were valued at just over $8
86 million dollars each, totaling $24.6 million for the set of three. These individual and aggregate
87 evaluations were all confirmed by the event organizers, Bancroft Estates, and Berkley F. De la
88 Porta. Evidence collection ended at approximately 1:08am on November 1, 2022. Afterwards I
89 returned to the station, updated Deputy Commissioner Benjamin on the investigation, and drafted
90 this report.

91 SUPPLEMENTAL REPORT 1: (11/02/22)

92 I received a phone call from someone named Shar Burke. They claimed to be an agent
93 with the Federal Bureau of Investigation. I was able to confirm that Burke was in fact an FBI
94 agent through the State-Federal Intersectional Database. Agent Burke informed me that they had
95 seen the heist at Miller Tower on the news and that the MO (modus operandi) for the crime fit
96 the profile of a criminal mastermind that Burke had been chasing. Agent Burke asked for access
97 to the SIPD investigation to help build the case against the person Agent Burke was chasing. I
98 agreed to allow Agent Burke to shadow the investigation and in exchange Agent Burke agreed to
99 provide SIPD access to FBI resources when needed.
100 We also received notice that a helicopter matching the tail number of the one that was
101 used during the Miller Tower heist was reported stolen from the now bankrupt Koller Campbell
102 Air on October 16, 2022. The Trustee in charge of the bankruptcy reported the theft to their local
103 police department the same day of the theft. The Trustee was cleared of all wrongdoing
104 connected to the helicopter theft. Despite a thorough canvassing of Charlotte County, we have so
105 far been unable to recover the missing helicopter.

106 SUPPLEMENTAL REPORT 2: (11/10/22)

107 After reviewing all of the camera footage from Miller Tower on October 31, 2022, I was
108 able to determine the following summary of events. No audio was recorded on any of the
109 security cameras.

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110 At 9:10pm, approximately three individuals landed on the helipad of Miller Tower via the
111 stolen helicopter. The pilot remained with the helicopter during the entirety of the heist. Two
112 people exit the helicopter and head towards the door to the stairs. One person was already
113 waiting inside for the helicopter. The masked person inside tried to use a keycard to let the
114 people on the roof into the building. The keycard apparently fails (the door does not open) and
115 the two people on the roof use an axe and a club to break down the door. After the two outside
116 manage to make a hole in the door big enough to enter through, they enter. One of them appears
117 to get their left shoulder caught on a jagged piece of the door. The footage plus the blood found
118 on the door itself led me to believe that the person who got caught on the door was injured at this
119 time. They then headed toward and entered the Command Center on the 40th floor.
120 There is no camera inside the Command Center, so there is no camera footage of what
121 happens inside the office. However, the footage shows the suspects carrying a signal jammer into
122 the office and the timing of when the 911 call cut out leads me to conclude that the signal
123 jammer cut off all communication ability for the guard on that floor.
124 At 9:14pm, all three suspects are seen on the camera footage dragging Emory Sands, who
125 appears unconscious, from the Command Center to the vault. The suspect wearing the mask
126 found in the alley next to Miller Tower (Exhibit 23) used Sands’s key card to access the vault’s
127 initial security panel, which is confirmed by the access log. The video footage also shows the
128 three suspects working together to lift Sands’s right hand and forcing open Sands’s right eye for
129 the biometric scanners. The biometric scanners function as a secondary security measure and are
130 required to enter the vault. Both of Sands’s biometric scans were confirmed by the access log.
131 There was no hesitation by the three suspects when using the biometric scanners; it’s as if they
132 knew Sands’s right hand and retina would need to be scanned.
133 After the vault doors opened, all three suspects entered the vault, dragging Sands’s
134 unmoving body into the vault as well. From about 9:15pm to 9:28pm, the crew members pack up
135 and remove all the items from the vault. They do this in two trips. The first trip appears to go
136 smoothly. However, between the first and second trip, Sands wakes up and tries to attack the
137 injured crew member—who was the only one in the vault at the time. The injured crew member
138 starts beating Sands. The attack is fairly vicious. When the other two return to the vault for their
139 second load, they also jump into the scuffle. After one or two hits, Sands doesn’t move but
140 continues to be struck repeatedly.
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141 The fight is over at 9:21pm and the crew appears to get back to business. But the injured
142 crew member collapses at one point and must be helped out of the vault when the crew moves to
143 leave. The placement of the injured crew member in the video lined up with where the blood
144 evidence was found in the vault. By 9:27pm all crew members are in the roof-access only freight
145 elevator and go up to the roof. Once on the roof, they walk over to the still waiting helicopter.
146 The key card access logs show that the crew continued to use Sands’s key card to access the
147 roof-access freight elevator. After helping load the second cargo of stolen materials from the
148 vault into the helicopter, the injured crew member is also loaded into the helicopter. Two of the
149 crew members do not enter the helicopter and return to the 40th floor. There, they enter the event
150 hall and join the crowd of other masked guests. The security footage is very grainy, and the event
151 hall lights were dimmed for the party so I was unable (based solely on the security footage) to
152 trace the exact path that the two suspects took once they entered the event hall.
153 After the crew members left the secured area, the security cameras show that Sands’s
154 unconscious body was found by Cosmos and Orlov.
155 There were many limitations to the video evidence. Based on the lighting and the all-
156 black clothing worn, I was not able to determine the height, weight, or build of any of the crew
157 members. I was also not able to see the faces of any of the crew members. They always turned
158 their faces away from the cameras and when it was not possible to hide their faces, they wore
159 masks. All of this led me to believe that we were dealing with a highly sophisticated crew.
160 Though, we were able to eliminate any sort of mafia, mob, cartel, or other organized crime
161 connections. Those groups had never really had a strong foothold in Santa Ivo and they were
162 completely eliminated in June of 2021 after they burned down Chuggie’s Bar & Grill, a famous
163 hole-in-the-wall in Midlands Center.

164 SUPPLEMENTAL REPORT 3: (11/15/22)

165 Forensic report from the scene of the crime has come back with a match. The blood
166 evidence found in the stairway and in the hallway came from a person named Memphis Raynes.
167 I know Raynes. Back before I was a detective, I arrested Raynes a number of times. I ran a recent
168 arrest record and found that Raynes had been up to even worse conduct after my run-ins with
169 them. From my past run-ins with Raynes, I know that they have a sibling named Poe Cameron. I
170 could hardly believe that Cameron was involved in this crime. From my memory, Cameron was
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171 always the good kid. I pulled Cameron’s criminal record and was disappointed to see that
172 Cameron had also had their run-ins with the law, though Cameron’s criminal activity paled in
173 comparison to Raynes’s.
174 The mask collected at the scene outside the building was found to have trace amounts of
175 blood on it. The DNA from the sample in the mask matched the injured guard Emory Sands.
176 This showed to me that the mask was worn by someone who was inside the vault at the time
177 Sands was assaulted. DNA inside the mask was also found, but, at this time, there were not any
178 matches with any samples from the Midlands felony offender database.
179 Based on the location of the blood samples, the video, and the DNA evidence, it was
180 clear that the injured crew member in the video was Raynes. A warrant for Raynes’s arrest was
181 issued based on the DNA and security camera evidence.

182 SUPPLEMENTAL REPORT 4: (11/21/22)

183 Despite all efforts to locate Raynes, we have not been successful. I called in Poe
184 Cameron for an interview today. Both Agent Burke and I were present for the interview. That
185 interview was audio recorded and a transcription is being made. Cameron was not able to give
186 me any information regarding Raynes’s location. Cameron confirmed that Cameron did not have
187 any injuries that would have been consistent with the injuries sustained by the injured crew
188 member from the security footage. Cameron agreed to provide a buccal swab DNA sample
189 because, as Cameron said, “I have nothing to hide.”

190 SUPPLEMENTAL REPORT 5: (12/03/22)

191 I received a call today from someone by the name of Blaise Nova. They claimed to have
192 information related to the Miller Tower heist. Nova told me that they had seen Raynes during the
193 weeks leading up to the heist at an apartment complex in the Oakley neighborhood called Ivy
194 Lane, which Nova had rented to Raynes. I asked why Nova was coming forward with this
195 information now. Nova stated that they had just seen a news story about a warrant for Raynes
196 related to the heist and called in because the news said the police were asking for any
197 information. Nova also asked if there was a reward for this type of information. I said no. Nova
198 replied, “Aw shucks” but said they were happy to help as much as possible. I set a meeting with

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199 Nova for later in the day at Ivy Lane. I then called Agent Burke and asked them to meet me at
200 Ivy Lane for the meeting at 1pm.
201 At 1:02pm, Agent Burke and I met with Nova in the property manager’s office at Ivy
202 Lane. We asked for all the information Nova could give to us about Raynes in the time leading
203 up to the heist. Nova provided us with a lease agreement signed by Raynes for apartment 322
204 from August 9, 2022 to November 9, 2022. We asked whether Raynes had been seen with
205 anyone else while at the apartment. Nova talked about a few other individuals and also went on
206 at length about something to do with colored key fobs that had been given to Raynes for access
207 to the apartment. Nova confirmed that these colored key fobs had only been given to Raynes for
208 access to unit 322. All other building access was via black key fobs. One of the names of the
209 people Nova said had met with Raynes was well known to both me and Burke: Berkley F. De la
210 Porta. De la Porta is a well-known entrepreneur and businessperson. I was surprised to learn that
211 Raynes and De la Porta had both been in this apartment complex before the heist. I asked
212 whether De la Porta was a tenant here and Nova checked all the lease agreements on file and said
213 that De la Porta was not a tenant. On a hunch, I showed Nova a picture of Poe Cameron and
214 asked whether Nova had seen Cameron at all either. Nova confirmed that they had in fact seen
215 Cameron at Ivy Lane and even chatted with Cameron. The above does not contain all of the
216 information provided to us by Nova. My notes from the full conversation with Nova are stored in
217 the department’s secured online file portal. From the information provided by Nova, it was clear
218 that the Ivy Lane apartment had been used as the heist crew’s meeting and planning spot. It also
219 sounded like it was where they came after the heist to deal with Raynes’s injuries.
220 At the end of the discussion, Agent Burke asked whether anyone had been in the
221 apartment since Raynes’s lease had ended. Nova said no. Then Nova asked whether we wanted
222 to take a look around inside. We said yes. I then called the forensic tech, Forensic Technician M.
223 Nguyen, who had been working this case and asked them to bring their team to Ivy Lane ASAP.
224 About 10 minutes later at 2:05pm, Nguyen and their team showed up. All of us headed up to
225 apartment 322 together.
226 Once we arrived, it was fairly anti-climactic. The apartment looked absolutely spotless
227 and there was no furniture. The forensic team started dusting for fingerprints and trying to find
228 and hairs or other evidence left behind. Despite the apartment appearing to be barren, I had
229 forensic tech M. Nguyen check the dishwasher on a whim. Inside the dishwasher were a number
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230 of plates, glasses, forks, knives, etc. that had been unwashed with an unused dish detergent pod
231 sitting in the bottom of the machine. Carefully, the techs processed everything that was in the
232 dishwasher and bagged it all for evidence. Based on our luck of finding the dirty dishes, I
233 wandered to the back of the apartment where I had seen a washer and dryer. The dryer was
234 empty but when I opened the washer, I found a number of linens and towels. I called out for the
235 forensic techs to come to the back of the apartment. They started processing the items from the
236 washing machine as well.
237 After that, I asked Nova where the trash from this apartment would have gone. Nova
238 informed me about several dumpsters at the back of the complex. Unfortunately, any trash was
239 long gone as Nova informed me that the dumpsters are emptied on a weekly basis. However, any
240 materials set aside for recycling are collected once a month. Nova mentioned that Raynes had
241 left some bags of shredded paper at the recycling center, but nothing else. I had the forensic techs
242 collect the bags from the Ivy Lane recycling center.
243 I oversaw the collection and review of the bags of shredded paper. It took many hours,
244 but after a while we were able to find several pieces of documents in the trash that were likely
245 linked to this heist. Those included pieces of the floor plans for roof and 40th floor of Miller
246 Tower, the security “tac plan” for the items to be auctioned off at the Halloween night silent
247 auction, an invitation to the Sohi Children’s Hospital charity gala (without an address or a name
248 included), and a guidebook with specifications for the vault of the same make and model of the
249 one used on the 40th floor of Miller Tower. Pictures were taken of the scraps individually and
250 grouped together as a document. The pictures were secured digitally on the Santa Ivo Police
251 Department evidence server. Consistent with current departmental policy regarding evidence
252 collection and storage, the individual scraps of paper were not kept as evidence.

253 SUPPLEMENTAL REPORT 6: (12/04/22)

254 Jun Cage contacted the police department asking to come in to give a written statement
255 about what Cage saw happening outside of Miller Tower on Halloween night. Cage had
256 previously provided Cage’s name and contact information to officers on Halloween night but
257 refused to give a full statement at that time. I was curious about Cage’s change of heart, so I
258 asked for Cage’s call to be transferred directly to me. In speaking with Cage, I learned that Cage
259 was familiar with both Poe Cameron and Memphis Raynes because they were all from the same
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260 neighborhood. Cage reported that Cage was running their kebab cart outside of Miller Tower the
261 night of the heist and had seen Cameron and someone else Cage didn’t recognize exit Miller
262 Tower through the ground level security door near the alley. I asked Cage to come down to the
263 station immediately to make a full report. The security exit that Cage reported seeing Cameron at
264 was in approximately the same location where the Halloween mask (Exhibit 23) was found.
265 Based on Cage’s statements, I filled out affidavits for an arrest warrant for Poe Cameron
266 and a search warrant for Poe Cameron’s residence. Charlotte County Common Pleas Judge
267 Daniel Hoy signed off on both warrants.

268 SUPPLEMENTAL REPORT 7: (12/05/22)

269 Cameron was arrested this morning during a routine traffic stop approximately 10 miles
270 from Cameron’s home. This stop was made about half a mile from the next exit, which was the
271 exit for the greyhound bus station. Cameron had $1000 in cash on them as well as a bus ticket to
272 Canada. Cameron was taken to the station.
273 Shortly after the arrest, I executed the search warrant for Cameron’s residence in the
274 Pleasant Ridge neighborhood. During the search, there was not much found. Cameron lived in a
275 two-bedroom apartment. There were pictures of Cameron and Raynes in the house along with
276 other family photos. A ring was found in Cameron’s bedroom with a distinct design. The design
277 pattern on the ring looked familiar to me. I pulled up pictures of Sands’s injuries from the night
278 of the heist on my phone. Bruising and cuts on Sands’s right forearm, forehead, and collarbone
279 area perfectly matched the distinctive patterns on the ring. The ring was photographed (Exhibit
280 7) and collected as evidence.
281 We also found two colorful key fobs in Cameron’s apartment matching the description
282 given to us by Blaise Nova of the key fobs that permitted access to unit 322 at Ivy Lane. The
283 fobs were purple (Exhibit 9) and blue (Exhibit 10). Finally, we collected a receipt for a
284 Halloween mask that had been purchased by Cameron on October 7, 2023, three and half weeks
285 before the heist (Exhibit 23). I contacted Nova to see if the fobs would still work to confirm the
286 fobs were in fact connected to unit 322. Nova said the fobs were programmed to work for the
287 specific dates listed in the lease agreement and automatically deactivate after the lease ends.
288 Thus, the key fobs could not be tested to confirm or deny any connection to Ivy Lane unit 322,

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289 but when I showed both key fobs to Nova, Nova confirmed that both key fobs looked exactly
290 like the fobs given to Memphis Raynes for unit 322.
291 No other evidence was collected or noted during the search of Cameron’s residence.
292 There was a second bedroom in the apartment. It is unclear whether another person or child was
293 living with Cameron prior to or after the heist. The other room did not look like it had been used
294 for many weeks and there was no written lease agreement for the room. The landlord renting
295 Cameron’s Pleasant Ridge unit stated that he didn’t like lawyers and so he did business the old-
296 fashioned way: with a handshake and a person’s word. He was also unable to tell us more about
297 Cameron’s living situation or whether anyone else lived in the apartment with Cameron. As far
298 as the Cameron’s landlord was concerned, that was Cameron’s business and the landlord prided
299 himself on staying out of other’s people’s business.
300 After we completed the search of the home, Sgt. Rodrigo informed me that Cameron had
301 been booked and processed so now was a good time for any sort of interrogation. I returned to
302 the station. At approximately 1:42pm, I began questioning Cameron. Cameron waived their Fifth
303 and Sixth Amendment rights at first and began answering my questions. The interview was audio
304 recorded and a transcript of the recording has been requested. After about 20 minutes, Cameron
305 said they were done talking to me and invoked their right to silence and to counsel. Upon
306 booking, as is standard procedure, a sample of Cameron’s fingerprints were collected.
307 Cameron’s mobile phone was collected from Cameron as part of the booking process. A
308 search warrant affidavit was created and approved by Judge Daniel Hoy to search for text
309 message conversations with Memphis Raynes. The warrant and request for text messages
310 between Poe Cameron and Memphis Raynes between September 1 and December 15, 2022 was
311 sent to Midlands Wireless.

312 SUPPLEMENTAL REPORT 8: (01/04/23)

313 DNA and fingerprint results from Ivy Lane have come back positive. There were three
314 sets of fingerprints and DNA that did not match anyone in the database, nor did they match
315 Blaise Nova or any of the staff at the Ivy Lane apartment complex. However, Memphis Raynes’s
316 DNA and fingerprints were identified as being present in Ivy Lane unit 322. Of particular
317 importance, the garments found in the washer had Raynes’s DNA on them. From my training at
318 the police academy, I know that DNA and fingerprints can be left on surfaces for weeks without
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319 degrading. It is impossible to tell how the DNA or fingerprints got on the items collect or the
320 context in which the DNA and fingerprints got on those items. No match at this time was made
321 to De la Porta, but that is not surprising because we do not have a sample of De la Porta’s DNA
322 or fingerprints to compare it to.
323 We also received test results connecting the mask found at the scene to Cameron. The
324 DNA inside the mask matched Cameron. In addition, the ring collected from Cameron’s
325 apartment was tested. The outside of the ring tested positive for blood and was a DNA match to
326 Sands. The outside also tested positive for Cameron’s DNA. The inside of the ring was tested for
327 DNA, but no DNA was found.
328 I also received an update from Agent Burke about their investigation into B. F. De la
329 Porta’s involvement with this crime. Burke was finishing up an investigation that Burke believed
330 would result in a search warrant for De la Porta’s financial records.

331 SUPPLEMENTAL REPORT 9: (01/05/23)

332 I received a warrant return from Midlands Wireless for text messages between Poe
333 Cameron and Memphis Raynes. It is clear from the text messages that Cameron was a late
334 addition to the heist crew but volunteered to join in. These messages contradict Cameron’s
335 statements during my December 5, 2022 interview of Cameron when Cameron said that
336 Memphis Raynes threatened Cameron if Cameron did not join the heist crew.

337 SUPPLEMENTAL REPORT 10: (02/14/23)

338 Agent Burke has been working on collecting any financial and cyber evidence that may
339 connect De la Porta to the Miller Tower heist for the past several months. Based on our
340 conversation, it is clear that Burke has substantial proof of a financial connection among De la
341 Porta, Cameron, and Raynes.
342 Based on this evidence, I have requested a warrant to arrest De la Porta and search De la
343 Porta’s Santa Ivo Heights home.

344 SUPPLEMENTAL REPORT 11: (02/15/23)

345 Agent Burke and I executed the warrant for De la Porta’s home. I’ve never been in a $10
346 million mansion before, but as one might expect, the search took quite a long time. At the home,
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347 we found a number of Morisot paintings on display in the downstairs areas. However, upon a
348 deeper search of the premises we found a number of cellar doors hidden by other pieces of
349 furniture or dense foliage. The cellar doors led to underground storage areas. In one of these
350 cellars, we found a number of items of interest. First, we found ten cell phones in a bag. Each
351 one was labeled with what appeared to be a name for the phone. One of the labels was “Miller
352 Tower.” In addition, we found a key fob matching the description given to us by Nova. This fob
353 was red (Exhibit 11). We also found all three Morisot paintings, Paysanne Nouvelle dans les
354 Terres, Halva Dans les Terres, and Dans les Terres du Milieu, that were stolen from the Miller
355 Tower vault during the heist. All these items were collected and stored in an evidence locker.
356 Upon making these findings, I arrested De la Porta for their involvement in the Miller
357 Tower heist. During the booking, a sample of De la Porta’s DNA and fingerprints were collected.
358 I have requested that the lab run these samples against all of the forensic evidence collected in
359 this case.

360 SUPPLEMENTAL REPORT 12: (02/24/23)

361 Received Midlands Forensic Analyst Nguyen’s Mass Spectrometry Report. As expected,
362 Nguyen’s report confirmed that the three Morisot paintings found at De la Porta’s residence were
363 not forgeries.

364 SUPPLEMENTAL REPORT 13: (03/03/23)

365 Forensic report for De la Porta’s DNA and fingerprints came back positive. Both De la
366 Porta’s DNA and fingerprints were found on items in the Ivy Lane apartment. Results were
367 forwarded to Agent Burke and the Charlotte County Attorney’s office.

368 SUPPLEMENTAL REPORT 14: (07/03/23)

369 The Charlotte County Attorney has asked that I identify any exhibits in the case that I am
370 familiar with and how I am familiar with them. Below is a list of all of the exhibits that I am
371 aware of as a result of this investigation:
372 Exhibit 1 is an invitation to the October 31, 2022 Sohi Children’s Hospital charity gala at
373 Miller Tower.

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374 Exhibit 2 is a brochure for the October 31, 2022 Sohi Children’s Hospital charity gala at
375 Miller Tower.
376 Exhibit 3 and 4 are accurate diagrams of the 40th floor and rooftop of the Miller Tower,
377 respectively.
378 Exhibit 5 is a picture of a security keycard for the Miller Tower in Santa Ivo City,
379 Midlands.
380 Exhibit 6 is a picture of the Poe Cameron’s receipt from Zarzycki & Co dated October 7,
381 2022 for a Halloween mask. It is a fair and accurate picture of the receipt.
382 Exhibit 7 is a picture of Poe Cameron’s ring that was found during a search of Cameron’s
383 residence pursuant to a search warrant. It is a fair and accurate picture of Cameron’s ring.
384 Exhibits 9, 10, and 11 are pictures of the key fobs for Ivy Lane unit 322.
385 Exhibit 12 is the lease agreement for Ivy Lane unit 322 between Ivy Lane apartment
386 complex and Memphis Raynes.
387 Exhibits 14, 15, and 16 are screenshots of call logs taken from the “Miller Tower” mobile
388 phone that was found in Berkley F. De la Porta’s home. Exhibit 14 identifies the call was to “Poe
389 Cameron.” Exhibit 15 identifies the call was to “Memphis Raynes.” Based on information
390 received from Agent Shar Burke, I know that Exhibit 16 is the same date and time as the FBI CI
391 call as part of Agent Burke’s Morisot Mastermind investigation.
392 Exhibit 17 is the confidential profile generated by the FBI for the Morisot Mastermind. I
393 reviewed it as a part of my investigation into the October 31, 2022 Miller Tower armed robbery.
394 Exhibits 18 and 19 are accurate copies of articles that I read as part of my investigation.
395 To the best of my knowledge, the statements attributed to De la Porta in the articles are accurate
396 statements. No corrections or redactions have been made.
397 Exhibit 20 and 21 are certified copies of the arrest records for Poe Cameron (Exhibit 20)
398 and Memphis Raynes (Exhibit 21).
399 Exhibit 22 is an accurate transcript of my August 16, 2023 interview.
400 Exhibit 23 is the mask that was found by in the alley next to the Miller Tower on October
401 31, 2022 by the Santa Ivo Police Department.
402 Exhibit 24 is a MSIG business card for Berkley F. De la Porta. A box of these cards was
403 found at De la Porta’s home during a search pursuant to a search warrant.
404 Exhibit 25 is an accurate photograph of Poe Cameron.
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405 Exhibit 26 is an accurate photograph of Memphis Raynes.

406 Exhibit 27 is the medical records of Emory Sands detailing the injuries that Sands
407 suffered during the armed robbery on October 31, 2022.
408 Exhibit 29 contains my notes I created while and after watching the Miller Tower
409 security video footage from October 31, 2022. They reflect my observations as I was
410 contemporaneously viewing the footage. I have not edited the notes since I created them.
411 Exhibit 30 is the text message report and declaration letter from Midlands Wireless for
412 Poe Cameron’s mobile phone. It has not been altered in any way since I received it and stored it
413 in an evidence locker.

414 AFFIRMATION
415 I swear or affirm the truthfulness of everything stated in this report. Before giving this
416 statement, I was told I should include everything that was relevant to my investigation. It is
417 impossible to include all steps and actions the SIPD took during this investigation. My team and
418 I conducted a thorough investigation and explored all possible leads and suspects. Some
419 investigative steps are omitted from this report because they revealed nothing of substance.
420 However, I found no evidence tending to incriminate or exonerate Poe Cameron, Memphis
421 Raynes, or B.F. De la Porta, except the evidence referenced in this report. I know that I can and
422 must update this report if anything new occurs to me until the moment before opening statements
423 begin in this case.
424 ____________________________________
425 /s/DET. KIT BAHMANI

426 Duly Subscribed and Sworn By Me:

427 ____________________________________
428 /s/J.R. BERNANS
429 Notary Public

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430 ADDENDUM TO OFFICIAL REPORT – SIPD-22-0099

431 Date: August 15, 2023

432 On August 1, 2023 cybercriminals attacked that SIPD’s evidence storage servers through
433 the malware DAS-SOLIS virus. The scheme was successful and still unknown cyber criminals
434 were able to execute a ransomware attack against SIPD’s major servers. After the ransom was
435 paid, the cybercriminals released the servers, but much of the information on those servers was
436 wiped with no backup copies available. Each detective is required to review the relevant
437 evidence for their cases and determine which pieces of evidence were lost as a result of the
438 attack. Thankfully, all evidence collected by SIPD that was physically stored in an evidence
439 locker was not affected by this attack. Only digital evidence stored in a virtual evidence locker
440 was lost.

441 I completed my review of this file today and make the following report as to the state of
442 the evidence that was lost:
443 o Photo of auction site received from Agt. Burke
444 o Photo of encrypted chatroom received from Agt. Burke
445 o Recording of Morisot Mastermind call with Informant received from Agt. Burke
446 o Financial records for Bern-Steel Ltd, Goodspeed Industries, and Matchstick & Sons
447 received from Agt. Burke
448 o All security footage from Miller Tower (10/31/22)
449 o Miller Tower M10T Vault security system access log (10/31/22)
450 o Miller Tower 40th floor security system access log (10/31/22)
451 o Miller Tower M10T Vault specification documents
452 o Pictures of Emory Sands’s injuries (10/31/22)
453 o Pictures of shredded paper scraps collected from Ivy Lane (12/3/22)

454 The following evidence that was in the custody of Santa Ivo Police Department was
455 unaffected by the attack: Previously identified Exhibits 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 14, 15,
456 16, 18, 19, 20, 21, 22, 23, 24, 25, 26, and 27.

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457 I have also read the affidavit of Berkley De la Porta as amended August 13, 2023. Further
458 I should clarify that I have read the Report of the Investigation of Agent Shar Burke (version
459 amended August 14, 2023). Agent Burke and I met regularly to discuss the case as it progressed.
460 By the end of the investigation, I was aware of everything Agent Burke stated in their report.
461
462 ____________________________________
463 /s/DET. KIT BAHMANI
464
465 Duly Subscribed and Sworn By Me:
466 ____________________________________
467 /s/ KONNOR ALLEM
468 Notary Public

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1 SANTA IVO POLICE DEPARTMENT

2 FORENSIC SCIENCE UNIT

3 DNA TESTING SECTION REPORT

4 CASE NO: SIPD00A1985

5 SIFU LAB REPORT: 2022112-A00613-1
6 DATE SUBMITTED: November 2, 2022 (initial submissions received)
7 DATE COMPLETED: February 19, 2023 (final submission received 2/16/23)
8 CRIMINALIST: M. NGUYEN

9 BACKGROUND

10 A request for DNA testing was initially submitted by Detective Kit Bahmani on November 2,
11 2022. Evidence collection was ongoing. The final DNA sample was received on February 16,
12 2023. Det. Bahmani requested return date of February 28, 2023. This report is the final report
13 generated based on all samples received from November 2, 2022 to February 16, 2023. This lab
14 performed nuclear DNA testing via standard methodology of sampling, amplification, typing,
15 and profile comparison. All results are reported within standard accepted margins of error and
16 following the field-wide procedures.

17 EVIDENCE COLLECTION AND EXAMINATION

18 On Octotber 31, 2022, I arrived at Miller Tower at the request of Detective Kit Bahmani around
19 10:30pm. The following samples were collected. These samples were identified as potentially
20 having forensic materials suitable for testing by myself and my team. I supervised the collection
21 of each sample.

22 SIF-1022-4-A: Samples of blood spatter evidence from the 40th Floor vault 10 feet from the
23 northeastern wall between vault cameras 2 and 3 at Miller Tower on October 31, 2022.

24 SIF-1022-4-B: Samples of blood spatter evidence from 40th Floor vault near northwestern wall
25 within 8 feet of vault camera 1 at Miller Tower on October 31, 2022.

26 SIF-1022-5-A: Cotton swab of surface skin, recovered from the hands of Emory Sands on
27 October 31, 2022.

28 SIF-1022-12-A: Swab of internal side of a mask (Evidence No: SIF-1022-9) [Exhibit 23]
29 recovered from the alley adjacent to Miller Tower on October 31, 2022.

30 SIF-1022-12-B: Samples of blood spatter evidence found on the outside of a mask (Evidence No:
31 SIF-1022-9) [Exhibit 23] recovered from the alley adjacent to Miller Tower on October 31,
32 2022.

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33 SIF-1022-13-A: Key card, white, labeled with the “Miller Tower” logo [Exhibit 5] recovered
34 from Miller Tower on October 31, 2022.

35 SIF-1022-23: Cotton swab of door handle, taken from Miller Tower on October 31, 2022.

36 As a part of the same investigation, I was requested by Det. Bahmani to help with the search and
37 evidence collection at an apartment complex called Ivy Lane Apartments. Upon arriving at Ivy
38 Lane Unit 322, there was little to no furniture in the apartment. My team dusted for fingerprints
39 and looked for any sources of DNA or other forensic materials. We had no luck until someone
40 mentioned something about dirty dishes. After that comment, I opened the dishwasher and found
41 there were a few dishes in the dishwasher that were still dirty. A detergent pod was in the
42 machine, but it had clearly not been run. I then decided to check the washing machine and found
43 several items there as well. Below is a list of samples collected from the Unit 322 of the Ivy Lane
44 Apartments.

45 SIF-1022-6-A: Cotton swab of a drinking glass (Evidence No: SIF-1022-6) recovered at Ivy
46 Lane on December 3, 2022.

47 SIF-1022-8-A: Cotton swab of the handle of a fork (Evidence No.: SIF-1022-8) recovered at Ivy
48 Lane on December 3, 2022.

49 SIF-1022-10-A: Swab of white shirt with blood stains (Evidence No.: SIF-1022-10) recovered
50 from laundry bin at Ivy Lane on December 3, 2022.

51 SIF-1022-10-B: Swab of grey shirt with blood stains (Evidence No.: SIF-1022-10) recovered
52 from laundry bin at Ivy Lane on December 3, 2022.

53 SIF-1022-19: Cotton swab from the door handle on entrance door to Ivy Lane Unit 322
54 (Evidence No.: SIF-1022-8) at Ivy Lane on December 3, 2022.

55 Det. Bahmani also asked me to be at the scene of the search of the home of Poe Cameron. I
56 collected the following samples for forensic examination.
57
58 SIF-1022-20-A: Cotton swab of face of class ring (Evidence No.: SIF-1022-20) [Exhibit 7] from
59 Poe Cameron’s residence on December 5, 2022.

60 SIF-1022-20-B: Cotton swab of interior of class ring (Evidence No.: SIF-1022-20) [Exhibit 7]
61 from Poe Cameron’s residence on December 5, 2022.

62 (Nuclear DNA does not allow us to assign a percentage or probability of DNA shared between
63 two people but siblings are expected to have, through random chance, approximately fifty
64 percent of the same DNA and statistical analysis indicated a chance of less than 1 in 15 billion
65 that they would share more than seventy-eight percent of the same DNA.)

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66 BACKGROUND OF PROCESS:

67 DNA profiling as a science was first fully developed and patented in 1981. DNA profiling is a
68 widely accepted process used around the world for, among other things, biological testing,
69 medicine, tracing out genealogical lines, anthropologic investigation into human (and animal)
70 remains, and forensic use. While the purpose of any given DNA profile generation may vary
71 greatly from application to application, the process and science remain consistent throughout.

72 The three most widely accepted DNA testing methods are: Short Tandem Repeat (STR), Y-STR
73 and mitochondrial (or mtDNA) typing. The first two types are also commonly referred to as
74 nuclear DNA testing.

75 Within the nucleus of each human cell there are two copies of chromosomes, one each from the
76 paternal and maternal line. STR testing provides for the greatest precision in testing because it is
77 capable of creating a full profile of the person the cell came from. However, it is also the most
78 likely to lead to entirely inconclusive results because it requires hundreds to tens of thousands of
79 cells with both chromosomes intact to get enough of a sample to properly sequence. Conversely,
80 Y-STR testing is significantly more likely to generate a usable sample because it focuses only on
81 one chromosome: the Y chromosome. In turn, it can profile DNA from cells where the X
82 chromosome has degraded or cannot be properly sequenced at all. It is almost as precise as a full
83 STR profile because it sequences the entirety of a Y chromosome. But this testing method also
84 has significant shortcomings. First, it can only be used to type those with Y chromosomes
85 (individuals assigned a male sex at birth.) Second, fathers, sons and brothers will sometimes
86 have functionally identical Y chromosomes since the Y chromosome is passed directly through
87 the paternal line to all assigned-male offspring, though this is far from guaranteed due to the high
88 propensity of mutations of the Y chromosome. Because of these issues, Y-STR testing is
89 generally limited only to analysis of semen, where the Y chromosome is present in
90 overwhelming numbers and assigned-male testing is presumed.

91 The third type of testing, mtDNA testing, analyzes an entirely different region of the cell. While
92 STR and Y-STR both focus on the DNA present in the nucleus of cells, mtDNA profiling tests
93 the DNA in the mitochondria, which are a sub-organelle inside the cells of all advanced life.
94 Thousands of mitochondria are present in each cell and, in turn, a single cell often has as many
95 as ten thousand mtDNA molecules. Additionally, certain common items of forensic interest,
96 such as hair follicles, fingernails, or items touched by a person, will contain little to no intact
97 cells. As a result, nuclear DNA is often not present at all or present in small enough quantities
98 that reliable amplification of it is impossible. In these instances, mtDNA provides for a much
99 more robust, and reliable, initial sample.

100 MtDNA, however, is limited in its own ways. There is no genetic correlation between the DNA
101 in a subject’s mitochondria and the nuclear DNA in their cells. This is because mitochondria are
102 distinct organelles within the cell and while each person’s cell is a result of the combination of
103 their maternal and paternal chromosomes, mitochondrial DNA is passed directly down the
104 maternal line. However, much like the Y chromosome’s propensity for mutation, mtDNA also,
105 not infrequently, mutates. As such, all of the limitations Y-STR places on the potentiality of
106 assigned-male members of the same paternal line to share profiles are essentially the same as the
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107 potential that a member (of either assigned sex type) will share a profile with another member of
108 the same maternal line. Siblings, most obviously, can be presumed to have the same mtDNA
109 because of this.

110 METHODS USED

111 All initial samples were reviewed with a microscope to determine the presence of cellular
112 material, including broken cells. While Evidence Items SIF-103122-4 through SIF-103122-23
113 were all submitted for examination, only the items listed above contained material likely to result
114 in an identifiable amount of nuclear DNA and, as such, were the only items tested.

115 Following that, the listed samples were submitted for extraction. Each sample was submitted to
116 a solution of phenol/chloroform to extract the nuclear DNA from other proteins. Subsequently,
117 the extract solution was placed in a centrifuge and run through standard DNA filtration methods
118 to isolate the DNA itself. This was done for each sample, independently, with sealed, fresh
119 extraction pipettes and centrifuge sterilization between each sample to reduce the rate of cross
120 contamination. While it is impossible to state that there is no chance of cross-contamination, this
121 laboratory has met every quality control certification continuously since its inception in 2002.

122 Once the nuclear DNA was isolated, it was subjected to PCR amplification. PCR (polymerase
123 chain reaction) is a method that introduces the DNA sample to a DNA polymerase primer that
124 then serves as a template for the DNA to split, recombine with the primer, then synthesize new
125 DNA molecules. This allows for an amplification of DNA samples by a factor of one million per
126 20 cycles, which is the standard employed per this lab’s certification.

127 Then the amplified DNA sample underwent STR sequencing that targeted 13 forensically-valued
128 loci that are amplified through the PCR process. Essentially, an STR sequence (a set of unique
129 protein chains) is identified for each of 13 different loci, or points, on a given sample’s
130 chromosomes. These 13 identified sequences form a “profile” of the evidentiary sample.
131 Oftentimes, multiple STR sequences will be detected at the same loci. Because of this we can
132 determine that there may be multiple contributors to a given evidentiary sample. For example, if
133 a given loci has two distinct sequences, we know at least two (though possibly more because two
134 people can have the same sequence at a particular, isolated loci) people contributed.

135 These 13 loci are used because, based on decades of research, they have been determined to form
136 a set from which no two people (except for monozygotic twins) would ever be expected to have
137 an identical profile through random chance. It should be noted, as we’ve sequenced the entirety
138 of the human genome, we have identified 7 more expected-unique loci and many labs have
139 transitioned to a 20 loci profile.

140 Finally, the same exact process was conducted on each reference sample (i.e. sample from a
141 known person) collected. Then the profile of each evidence sample collected was compared to
142 the known reference profiles. From that, a statistical determination was made as to the likelihood
143 that the reference profile was included in the given sample.

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144 REFERENCE SAMPLES EXAMINED:

145 AC4362: A profile stored in the NDIS (“National DNA Index System”) reportedly from
146 Memphis Raynes, taken on June 19, 2017, reference Charlotte Sheriff Case Number SC13876.

147 RS221191: Sample from buccal swab of Poe Cameron, reportedly taken on November 21, 2022.

148 RS221016: Sample from buccal swab of Emory Sands, reportedly taken on October 31, 2022.

149 Finally, a general run was conducted against the NDIS database for any unidentified samples
150 taken within Charlotte County in the last ten years.

151 CONCLUSIONS

152 All results were within expected ranges and no anomalies were observed during testing.

153 All probability results greater than 1 in 100 million are considered a NEAR CERTAINTY that
154 the contributor is included in that sample.

155 All probability results greater than 1 in 50 million but lower than 1 in 100 million are considered
156 a HIGH LIKELIHOOD that the contributor is included in that sample.

157 All probability results greater than 1 in 1 million but lower than 1 in 50 million are considered a
158 LIKELIHOOD that the contributor is included in that sample.

159 All probability results under 1 in 1 million are considered INCONCLUSIVE.

160 All Exclusions are made with at least a thirty percent confirmed variability in the two profiles
161 and are impossible, if both reported profiles are accurate, to have come from the same
162 contributor.

163 Note: “greater than” means that the denominator is larger the value provided. A larger
164 denominator value means that the statistical likelihood of a potential mismatch is lower.

165 RESULTS

166 SIF-1022-4-A contained one or more identifiable DNA types.

Potential Contributor: Probability:

AC4362 1 in 72 trillion
RS221191 1 in 10,460
RS221016 Excluded

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167 SIF-1022-4-B contained one or more identifiable DNA types.

Potential Contributor: Probability:

AC4362 Excluded
RS221191 Excluded
RS221016 1 in 72 trillion

168 SIF-1022-5-A contained four or more DNA types, though all but two types were too weak for
169 identification.

Potential Contributor: Probability:

AC4362 1 in 89 million
RS221191 1 in 60 million
RS221016 Assumed (Confirmed)

170 SIF-1022-6-A contained two or more identifiable DNA types.

Potential Contributor: Probability:

AC4362 Excluded
RS221191 1 in 60 billion
RS221016 Excluded

171 SIF-1022-8-A contained two or more identifiable DNA types but all reference samples were
172 excluded.

173 SIF-1022-10-A contained two or more identifiable DNA types.

Potential Contributor: Probability:

AC4362 1 in 4 trillion
RS221191 Excluded
RS221016 Excluded

174 SIF-1022-10-B contained three or more identifiable DNA types.

Potential Contributor: Probability:

AC4362 1 in 14 billion
RS221191 1 in 6 million
RS221016 1 in 7 billion

175 SIF-1022-12-A contained one or more DNA type.

Potential Contributor: Probability:

AC4362 1 in 950 thousand
RS221191 1 in 4 trillion
RS221016 Excluded
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176 SIF-1022-12-B contained one DNA type.

Potential Contributor: Probability:

AC4362 Excluded
RS221191 Excluded.
RS221016 1 in 250 billion

177 SIF-1022-13-A contained three or more DNA types.

Potential Contributor: Probability:

AC4362 1 in 55 million
RS221191 1 in 67 million
RS221016 1 in 12 thousand

178 SIF-1022-19 contained two or more identifiable DNA types.

Potential Contributor: Probability:

AC4362 Excluded
RS221191 Excluded
RS221016 Excluded

179 SIF-1022-20-A contained two or more identifiable DNA types.

Potential Contributor: Probability:

AC4362 Excluded
RS221191 1 in 47 million
RS221016 1 in 1.3 million

180 SIF-1022-20-B contained two or more identifiable DNA types but all reference samples were
181 excluded.

182 SIF-1022-23 contained four or more identifiable DNA types.

Potential Contributor: Probability:

AC4362 1 in 17,000
RS221191 1 in 4.7 million
RS221016 Excluded

183 SUPPLEMENTARY REPORT – ADDITIONAL PROFILES AND EVIDENCE

184 SIF-1022-8-A was matched to a profile of an evidentiary sample taken from a robbery on June 5,
185 2018 in Oxford, Mississippi. Contributor unknown.

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186 SIF-1022-23 was identified as containing DNA from Rory Shelton, taken as a reference sample
187 in BCPD Case No: BCPD148011 (obtained March 18, 2014.)

188 On February 17, 2023, a sample, reportedly taken from Berkley F. De la Porta on February 15,
189 2023, was sequenced and profiled. That generated profile was assigned Evidentiary No.:
190 RS230288

191 RS230288 was then compared and analyzed with SIF-1022-19 and determined to contain two or
192 more identifiable DNA types. Only RS230288 however was determined to match with any
193 probability and that probability was 1 in 6,207.

194 I was asked to test one of the items from the search of the home of Berkeley F. De la Porta. I was
195 not present for the search of the home. I obtained the piece of evidence (SIF-1022-14) [pictured
196 in Exhibit 11] out of the evidence locker following the standard chain of custody procedures. I
197 then swabbed the item and returned the evidence back to the locker following the standard
198 procedures. I labeled the sample that I took as SIF-1022-14-A and processed it for DNA
199 evidence.

200 SIF-1022-14-A contained five or more identifiable DNA types.

Potential Contributor: Probability:

AC4362 Excluded
RS221191 1 in 42 million
RS221016 Excluded
BCPD148011 1 in 6.7 million
RS230288 1 in 1.2 million

201 LAB STANDARDS AND NOTICES

202 This laboratory is certified by both the AAFTL (American Association of Forensic Testing
203 Laboratories) and the NICAGE (National Institute of Critical Analytical Group Evaluation.) It
204 has continuously maintained those certifications since its inception on April 1, 2002.

205 This analysis was conducted by M. Nguyen, who is certified to perform DNA analytical work by
206 the ILPT (Institute of Laboratory Personnel and Technicians) and has continuously maintained
207 that certification since September 21, 2012. M. Nguyen has been employed by the SIFU since
208 2011 and worked in the DNA section since obtaining ILPT certification. M. Nguyen has the
209 required bachelor’s degree in microbiology from Northern Arizona University, obtained in 2010.

210 All methods and procedures used conform to the current requirements and standards for both the
211 AAFTL and NICAGE and all notes and processes were reviewed by SIFU managing director
212 Ryanne George prior to publication of results.

213 NOTICE: Per AAFTL policy 4-349(b), this lab reports the following historical discrepancies
214 related to equipment used that were not severe enough to result in removal or reduction in
215 certification. On December 3, 2019, SIFU self-reported a centrifuge issue to AAFTL. In that
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216 instance, a centrifuge was not properly sterilized, with trace contamination identified in the
217 subsequent two sample sets. Both sets were re-analyzed following proper cleaning and remedial
218 measures were employed by replacing all detergents and remedial training of all technicians on
219 proper sterilization procedure.
220
221 ADDENDUM: August 30, 2023. In preparation for trial, I reviewed the numerated exhibits of
222 this case and compared to the testing conducted. SIF-1022-4-A, SIF-1022-4-B, SIF-1022-23
223 were all taken from the 40th floor of Miller tower, consistent with the diagram of locations in
224 Exhibit 3. SIF-1022-6-A, SIF-1022-8-A, SIF-1022-10-A, SIF-1022-10-B, SIF-1022-19 were all
225 taken from the Ivy Lane residence, consistent with the diagram of the locations in Exhibit 8.
226 SIF-1022-12-A was taken from the mask photographed in Exhibit 23. SIF-1022-13-A was taken
227 from the same key card photographed in Exhibit 5.

228 SUPPLEMENTAL STATEMENT – Review of Report of Analyst Amarii Ebi

229 I have reviewed the report of Amarii Ebi, who I understand may testify as an expert for the
230 defense in this case. I agree with the statements made by Analyst Ebi in the sections titled “The
231 Process of DNA Testing,” “DNA Mixtures,” “DNA Transfer,” “Primary Transfer,” “Secondary
232 and Subsequent Transfer,” and “Screening for Transfer.” However, I disagree with several of
233 Analyst Ebi’s findings regarding the forensic evidence in this case. First, while 20 loci
234 comparison testing can be more accurate, using 13 loci comparison is still acceptable and
235 standard in the field of forensics. I have been pushing the Santa Ivo Forensics Board to add 20
236 loci testing capabilities to the laboratory, but I have been unsuccessful. I have argued that a 20
237 loci comparison would be able to take our laboratory results from good to great.
238
239 Second, I have no concerns regarding DNA transfer in this case regarding the samples where the
240 probability results were in either the Near Certainty or High Likelihood categories of
241 comparison. For the lower levels of probability results, it is possible that such low levels were
242 achieved through primary, secondary, or other level of transfer. However, my job is not to
243 determine when or how someone’s DNA was placed onto an object. Rather, my job is to
244 determine whether there is any DNA evidence on the tested object and determine who the
245 contributor is. The other parts of the police force, like the detectives, determine what to do with
246 the DNA evidence once it is found.
247
248 Third, the possibility of DNA mixture is another limitation of DNA evidence, especially when
249 collecting it in real-world conditions rather than in laboratory conditions. Analyst Ebi rightly
250 points out that a mixture can result in unusable DNA if too many of the loci between subjects are
251 consistent. All of the loci being consistent between people is only possible in identical twins.
252 Based on the public records search, I was able to find the birth certificates of Memphis Raynes
253 and Poe Cameron. They are biological siblings, but they are not identical twins. It is worth
254 noting that neither Raynes nor Cameron have any twin siblings based on the Midlands birth
255 records (which would have noted the birth of any twin siblings on the records themselves).
256
257 However, I did not do a test to determine how many of the loci between Raynes and Cameron
258 were the same under the 13 loci test. While incredibly rare, a significant number of the 13 loci
259 could match up between Raynes and Cameron. Matching at all 13 (an especially all 20) loci
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260 however would be nearly impossible for non-identical siblings. Not many of the samples found
261 potential contributions from both Raynes and Cameron though. Such samples could have used
262 the 20 loci comparison for absolute certainty, but that was not needed here to reach a conclusion
263 regarding the DNA. Further, there were several samples where we were able to exclude Raynes
264 as a contributor where Cameron’s DNA was found with a high likelihood. Therefore, it is
265 unlikely that the 13 loci match was insufficient to apply even in the event of DNA mixtures in
266 this case.

267 Regarding the section titled “Fingerprint Analysis,” I agree with Analyst Ebi’s statements in the
268 first paragraph of that section. I do not disagree with Analyst Ebi’s statements in sentences 1-3 in
269 the third paragraph and certainly take no issue with Analyst Ebi’s fourth paragraph conclusion
270 that there was no evidence that the fingerprint evidence in this case was collected or preserved
271 improperly. However, the rest of the “Fingerprint Analysis” section is at best baseless conjecture
272 and I strongly disagree with the remainder of Analyst Ebi’s statements. I am unaware of any
273 request for information by Analyst Ebi regarding the Midlands Forensics Unit’s procedures or
274 policies. I strongly caution against reading Analyst Ebi’s “Fingerprint Analysis” section as
275 opinions with any relevance to the Midlands Forensic Unit or this case.

276 I have no opinions or thoughts on any sections of Analyst Ebi’s report regarding the
277 investigations of Det. Bahmani or Agent Shar Burke (this includes anything in sections between
278 and including “Analysis of the Investigation of Law Enforcement” and “Conclusions”). I have
279 not reviewed any evidence listed in Analyst Ebi’s report except for what I have otherwise noted
280 above. The attorneys in this case asked that I update this report with the exhibit numbers for the
281 exhibits that I took samples from. I have done so above. I am also familiar with Exhibits 3, 4,
282 and 8 as I have been to each of those locations and seen the buildings. I am only familiar with the
283 exhibits identified in this or the supplemental Fingerprint Testing Section Report below.

AFFIRMATION
284 I swear and affirm the truthfulness of everything stated in this report. Before writing this report, I
285 was told to include every relevant detail in my investigation. I have done so to the best of my
286 abilities. I know that I can and must update this report if anything new occurs to me, up until the
287 moment before opening statements begin at trial.
288
289 ____________________________________
290 /s/M. NGUYEN

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SANTA IVO POLICE DEPARTMENT

FORENSIC SCIENCE UNIT

FINGERPRINT TESTING SECTION REPORT

CASE NO: SIPD00A1985

SIFU LAB REPORT: 2022112-A00613-2
CRIMINALIST: M. NGUYEN

SIPD Crime: Date of Report:

Forensic Science Unit Burglary/Robbery 3/2/23

International Association of Identification

Accredited: 2002
Date Reported: Complaint Number: Case Number: Reporting Agency:
10/31/22 San Ivo PD

Analysis Date: Analysis Time:

3/2/23 4:56pm
Topic:
Latent Print Examination
Date(s) of Examination:
3/2/23 – 3/2/23

Number of Latent Prints

Type: Evidence No: # of Impressions: Recovered from:
Latent Print SIF-103122-10 4 “Glass Tumbler at
Ivy Lane Kitchen”
Type: Evidence No: # of Impressions: Recovered from:
Latent Print SIF-103122-11 2 “Small Plate in Ivy
Lane Kitchen”
Total Number oi Impression: 6
Latent Impressions Determined to be Count
No Value 2
Latent Impressions Determined to be Count
Of Value for Further Comparison and 4
Examination

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Suspect, Eliminations & Others

1 Person Last Name First Name DOB Ag Latent FBI
Role CAMERON POE 3/24/03 e Database ID Database No
Suspect 19 No N/A
#544781
2 Person Last Name First Name DOB Ag Latent FBI
Role RAYNES MEMPHIS 6/19/99 e Database ID Database No
Suspect 23 No 16MD4217
#349846
3 Person Last Name First Name DOB Ag Latent FBI
Role DE LA BERKLEY 1/22/84 e Database ID Database No
Suspect PORTA 38 No N/A
N/A

Latent # Recovered From

SIF-103122-10-A “Glass Tumbler at Ivy Lane Kitchen”
Latent Impression Determined Suspects Result
to be 1 EXCLUDED
Of Value for Further Comparison 2 EXCLUDED
and Examination 3 IDENTIFIED
SIF-103122-10-A – A latent impression, upon comparison and evaluation, it was
identified to be the #2 right index finger of Berkley F. De la Porta
Database Search? Reason? Result?
No No fingerprints from N/A
B.F. De la Porta in
system

Latent # Recovered From

SIF-103122-10-B “Glass Tumbler at Ivy Lane Kitchen”
Latent Impression Determined Suspects Result
to be
No Value
SIF-103122-10-B – Unable to determine finger or assess enough ridge data for
comparison
Database Search? Reason? Result?

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Latent # Recovered From

SIF-103122-10-C “Glass Tumbler at Ivy Lane Kitchen”
Latent Impression Determined Suspects Result
to be 1 EXCLUDED
Of Value for Further Comparison 2 EXCLUDED
and Examination 3 IDENTIFIED
SIF-103122-10-A – A latent impression, upon comparison and evaluation, it was
identified to be the #3 right middle finger of Berkley F. De la Porta
Database Search? Reason? Result?
No No fingerprints from N/A
B.F. De la Porta in
system

Latent # Recovered From

SIF-103122-10-D “Glass Tumbler at Ivy Lane Kitchen”
Latent Impression Determined Suspects Result
to be 1 EXCLUDED
Of Value for Further Comparison 2 INCONCLUSIVE
and Examination 3 INCONCLUSIVE
SIF-103122-10-A – A latent impression, upon comparison and evaluation, it was
identified to be a #1 thumb print but only three ridges were clear enough for analysis and
all three compared to both Berkley F. De la Porta and Memphis Raynes
Database Search? Reason? Result?
Yes Assess likelihood of 55% probability match
fingerprint belonging to
Raynes’ database sample

Latent # Recovered From

SIF-103122-11-A “Small Plate in Ivy Lane Kitchen”
Latent Impression Determined Suspects Result
to be
No Value

SIF-103122-11-A – Unable to determine finger or assess enough ridge data for

comparison
Database Search? Reason? Results

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Latent # Recovered From

SIF-103122-11-B “Small Plate in Ivy Lane Kitchen”
Latent Impression Determined Suspects Result
to be 1 EXCLUDED
Of Value for Further Comparison 2 EXCLUDED
and Examination 3 IDENTIFIED
SIF-103122-11-B – A latent impression, upon comparison and evaluation, it was
identified to be the #2 left index finger of Berkley F. De la Porta
Database Search? Reason? Result?
No No fingerprints from N/A
B.F. De la Porta in
system

Conclusion:
Latent prints SIF-103122-10-B and SIF-103122-11-A were not of strong enough resolvability
to make a matching determination.

Latent print SIF-103122-10-A was determined to have five resolvable ridges, three of which
were determined to match Berkley F. De la Porta and two of which could not be matched to a
high enough level of certainty. It is this evaluator’s opinion that print belongs to De la Porta.

Latent print SIF-103122-10-C was determined to have three resolvable ridges, three of which
were determined to match Berkley F. De la Porta. It is this evaluator’s opinion that print
belongs to De la Porta.

Latent print SIF-103122-10-D was determined to have four resolvable ridges, two of which
were determined to match Berkley F. De la Porta, one of which was determined to match
Memphis Raynes based on an ABIS search, and one of which could not be matched with a
high enough level of certainty. It is this evaluator’s opinion that the print is a result of a
conglomeration of two different prints or that there is a coincidental destruction in one ridge
that transformed its shape.

Latent print SIF-103122-11-B was determined to have three resolvable ridges, three of which
were determined to match Berkley F. De la Porta. It is this evaluator’s opinion that print
belongs to De la Porta.

NOTE: There was a non-determinative error in the process where the Peer Review and Tech
Reviews of this report were swapped, such that the assigned Peer Reviewer did the Tech
review and vice versa. Both reviews were conducted according to standard procedure, and this
was not determined to affect the outcomes of the report.

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Terminology
Identification – A conclusion that three friction ridge skin impressions originated from the
same source. A subjective determination is made that the probability of error is negligible.
Inconclusive – A conclusion that either the quality of the ridges makes determination whether
they are from the same source impossible without a significant probability of error or a
conclusion that at least two ridges are from the same source, but others are not.
Exclusion – A determination that no ridges are from the same source or that no more than one
is, with others that are determined not to be.

Methodology
Certification: All fingerprint evaluators are certified, every two years, by the International
Association for Identification (IAI.) Certification requires that the evaluator assess fifty
fingerprints for evidentiary value, then run ten blind comparisons between sample latent prints
and known reference prints. Each print must be determined to be Identified, Inconclusive, or
Excluded from the pool of reference prints. Evaluators must score at least a ninety percent.
Additionally, evaluators must score at least eighty-five percent on a 30-question refresher test
on fingerprint characteristics and collection process.

Method used here: This lab employs the ACE-V method. It is a four-step process.

Analysis – The evaluator reviews the latent print to determine if there is sufficient friction
ridge resolution to make a determination. While there is a lack of general defined criteria for
making this decision in the latent print community, this lab requires at least three ridges be
distinctly identified for a print to be IDENTIFIED so that is the minimum number of ridges
required for analysis.

Comparison and Evaluation – The latent print is then compared to all known sample prints.
If no ridges are identified as matching between the latent and sample print or if only one ridge
is considered a match and two or more are not, the analysis result is EXCLUDED. If either
two ridges match, but all other ridges are either inconclusive or determined to not be a match,
or three ridges match but additional ridges are determined to not be a match, the analysis result
is INCONCLUSIVE. If at least three ridges are determined to be a match, with no ridges
determined not to be a match, the analysis result is IDENTIFIED. This method of
quantification of specific ridge identification is not the standard within the field, as the
particular level and necessity of quantification of results vary greatly from agency to agency, it
is nonetheless widely accepted.

Additionally, the fingerprint is run through the ABIS database. While this does not directly
affect the results of the analysis, it is noted if either ABIS confirms the identification, ABIS
does not find the sample print in their system, or if ABIS returns a different identification.

Verification – The results are then given to a Peer Review Evaluator, who confirms the
identification. If there is confirmation, the results are published and sent to a Technical
Evaluator who reviews the report for inaccuracy or error. If there is no confirmation, the
results are not sent for technical review and a report documenting the discrepancy is published.

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Reviewed By
Peer Review:
SIPD Tech ID: Name: Rank: Review Date:
45671 Castor Troy FT3 3/2/23
Technical Review:
SIPD Tech ID: Name: Rank: Review Date:
33092 Archie Seans FT3 3/2/23

AFFIRMATION
I swear and affirm the truthfulness of everything stated in this report. Before writing this report, I
was told to include every relevant detail in my investigation. I have done so to the best of my
abilities. I know that I can and must update this report if anything new occurs to me, up until the
moment before opening statements begin at trial.

____________________________________
/s/M. NGUYEN

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1 SANTA IVO POLICE DEPARTMENT

2 FORENSIC SCIENCE UNIT

3 MASS SPECTROMETRY TESTING REPORT

4 CASE NO: SIPD00A1985

5 SIFU LAB REPORT: 2022112-A00613-3
6 DATE COMPLETED: February 23, 2023 (submissions received 2/16/23)
7 CRIMINALIST: M. NGUYEN

8 BACKGROUND

9 A request for a mass spectrometry test for the presence of Cesium-137 and Stronium-90 in three
10 paintings recovered from the home of Berkeley F. De la Porta. This lab performed gas
11 chromatography mass spectrometry testing via standard methodology of sampling, typing, and
12 profile comparison. All results are reported within standard accepted margins of error and
13 following the field-wide procedures.
14
15 SAMPLE COLLECTION AND EXAMINATION
16 On February 15, 2023, three paintings were collected from the home of Berkely F. De la Porta.
17 They are reported to be paintings in the style of Berthe Morisot and appear similar to the
18 paintings stolen from the Miller Tower Heist. Samples from each painting were taken for
19 analysis. Small samples were carefully extracted from inconspicuous areas of each painting
20 using a sterile scalpel. Sampling locations were chosen to minimize visual impact on the artwork.
21 All sample weights collected were within the proper range of such sampling of 3.5-5.0 mg of
22 paint. Less than 3.5 mg results in too small of a sample to provide a sufficient sampling. More
23 than 5.0 mg is likely to be too large of a sample because it may be noticeable in the paintings’
24 appearance.
25
26 SIF-1022-23: 4 mg paint sample from painting recovered from De la Porta residence known as
27 Paysanne Nouvelle dans les Terres.

28 SIF-1022-24: 3.8 mg paint sample from painting recovered from De la Porta residence known as
29 Halva Dans les Terres.

30 SIF-1022-25: 4.1 mg paint sample from painting recovered from De la Porta residence known as
31 Dans les Terres du Milieu.

32 BACKGROUND OF PROCESS:

33 Gas chromatography mass spectrometry (GCMS) is the gold standard in identifying unknown
34 substances. This method of analysis is generally used to identify the chemical components of a
35 particular substance. A small amount of the sample, which can be a gas, liquid, or solid, is
36 introduced into the system. Common samples include environmental pollutants, drugs, or organic
37 compounds. The sample is vaporized to convert it into a gaseous state. This is often achieved by
38 injecting the sample into a heated injector, turning it into vapor.

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39 The vaporized sample is then injected into a gas chromatograph. In the GC column, different
40 components of the sample travel at different rates based on their interactions with the stationary
41 phase inside the column. This separates the individual components of the sample. As each
42 separated component exits the GC column, it enters the mass spectrometer. Here, the molecules
43 are ionized, meaning they are given a positive or negative charge. The mass spectrometer then
44 accelerates these ions through a magnetic field, causing them to follow a curved path. The degree
45 of curvature is directly related to the mass-to-charge ratio (m/z) of the ions. The mass
46 spectrometer detects the ions and records the mass-to-charge ratios. This data is used to create a
47 mass spectrum, which is essentially a unique fingerprint for each compound present in the
48 sample.
49
50 The data from the mass spectrometer is sent to a computer, which interprets the mass spectrum.
51 By comparing the obtained mass spectrum with a database of known spectra, the system can
52 identify the compounds present in the sample.
53
54 In summary, GC-MS combines the separation capability of gas chromatography with the
55 detection and identification capabilities of mass spectrometry, making it a versatile tool for
56 chemical analysis in various fields, including environmental science, forensics, and
57 pharmaceuticals.
58
59 Testing for Cesium-137 and Strontium-90 in paintings and other antiquated works is utilized as a
60 tool to identify art forgeries. Cesium-137 and Stronium-90 are radioisotopes that are not found in
61 nature. These isotopes only appeared for the first time in July 1945 after the first atomic bomb
62 test in New Mexico. The fallout from the first atomic explosion spread throughout the globe and
63 took with it Cesium-137 and Stronium-90. Materials used to create artworks prior to 1945 do
64 not contain these elements. Forgers attempting to replicate historical artworks may overlook the
65 presence of these radioactive isotopes. The absence of Cesium-137 and Strontium-90 in an
66 artwork can be indicative of a potential forgery, especially when the claimed creation date
67 predates the nuclear age. Therefore, a relatively simple test to determine whether an antiquated
68 work may be a forgery is to sample the materials in the work for the presence of these isotopes.
69
70 Such testing was pioneered by art historian Elena Basner but was popularized in the investigative
71 and forensic world by the paper published by N. Caffrey. GCMS testing in general has been
72 extensively peer reviewed and is the method of testing utilized by virtually all law enforcement
73 criminologists to identify compounds or substances. Testing artworks for Cesium-137 and
74 Stronium-90 is also peer reviewed and found to be highly reliable in identifying art forgeries.
75
76 While the absence of Cesium-137 and Strontium-90 provides significant information, it is crucial
77 to note the limitations of this testing in isolation. Sophisticated forgers may intentionally use
78 materials pre-dating nuclear testing or employ meticulous methods to remove traces of
79 radioactive isotopes, complicating the detection process. The use of pre-nuclear materials
80 becomes less and less common as time goes on due to the dwindling stockpile of materials from
81 that time period.
82
83 Another limitation is the fact that the absence of Cesium-137 and Strontium-90, while an
84 incredibly strong indicator of authenticity, does not guarantee authenticity of the artwork. In a

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85 study of artworks tested using this methodology, 95.7% of the 254 known forged works tested
86 showed the presence of Cesium-137 and Stronium-90. However, 4.3% were able to pass the
87 Cesium-137 and Stronium-90 test and did not show the presence of these isotopes. Further, if the
88 forgery was made before 1945, then the test would be ineffective because both the original works
89 and the forgery would be utilizing pre-nuclear materials. While these limitations to Cesium-137
90 and Stronium-90 testing exist, the likelihood that an artwork could pass these isotope tests is
91 extremely low.
92
93 Here, the use of a Cesium-137 and Stronium-90 test was appropriate. All three Morisot paintings
94 were known to have originated in the late nineteenth century. Therefore, the paint from these
95 original works would have tested negative for these two isotopes.

96 RESULTS

97 SIF-1022-23: No Cesium-137 or Stronium-90 were detected in the sample.

98
99 SIF-1022-24: No Cesium-137 or Stronium-90 were detected in the sample.
100
101 SIF-1022-25: No Cesium-137 or Stronium-90 were detected in the sample.

102 CONCLUSIONS

103 Each of the samples tested showed no traces of Cesisum-137 or Stronium-90. Therefore, the
104 three paintings tested are, to a reasonable degree of scientific certainty, utilized materials that
105 were created prior to 1945. Based on the peer reviewed literature in the field and the results of
106 these tests, it is my conclusion that the paintings are authentic and match the paintings reported
107 stolen from the Miller Tower Heist.
108
109 This opinion is subject to the extremely unlikely limitations described above. To absolutely rule
110 out all doubt as to the originality of these works, other techniques could be utilized to confirm
111 the provenance of these pieces such as microscopy to examine the craquelure1 on the artwork
112 and infrared reflectography2 in paintings can be employed. I am not an expert in art forgery
113 detection or in utilizing techniques to examine craquelure or infrared reflectography. However,
114 my laboratory certifications are sufficient to opine on the results of the GCMS testing and its
115 interpretation based on the peer reviewed studies.

116 LAB STANDARDS AND NOTICES

117 This laboratory is certified by both the AAFTL (American Association of Forensic Testing
118 Laboratories) and the NICAGE (National Institute of Critical Analytical Group Evaluation.) It
119 has continuously maintained those certifications since its inception on April 1, 2002.

1
Small cracks that develop in artworks over time, which are as individual for each work of art as a fingerprint.
2
A process that uses infrared light to penetrate the layers of pigment to reveal the painting’s underdrawings on the
canvas. If the composition beneath the surface of a painting markedly diverges from the established preparatory
technique of the artist, investigators may infer that the artwork is probably counterfeit.

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120 This analysis was conducted by M. Nguyen, who is certified to perform DNA analytical work by
121 the ILPT (Institute of Laboratory Personnel and Technicians) and has continuously maintained
122 that certification since September 21, 2012. M. Nguyen has been employed by the SIFU since
123 2011 and worked in the DNA section since obtaining ILPT certification. M. Nguyen has the
124 required bachelor’s degree in microbiology from Northern Arizona University, obtained in 2010.

125 All methods and procedures used conform to the current requirements and standards for both the
126 AAFTL and NICAGE and all notes and processes were reviewed by SIFU managing director
127 Ryanne George prior to publication of results.

128 NOTICE: Per AAFTL policy 4-349(b), this lab reports the following historical discrepancies
129 related to equipment used that were not severe enough to result in removal or reduction in
130 certification. On December 3, 2019, SIFU self-reported a centrifuge issue to AAFTL. In that
131 instance, a centrifuge was not properly sterilized, with trace contamination identified in the
132 subsequent two sample sets. Both sets were re-analyzed following proper cleaning and remedial
133 measures were employed by replacing all detergents and remedial training of all technicians on
134 proper sterilization procedure. While this notice is mandatory to report, the equipment used is not
135 the type of equipment utilized for GCMS testing.

AFFIRMATION
136 I swear and affirm the truthfulness of everything stated in this report. Before writing this report, I
137 was told to include every relevant detail in my investigation. I have done so to the best of my
138 abilities. I know that I can and must update this report if anything new occurs to me, up until the
139 moment before opening statements begin at trial.
140
141 ____________________________________
142 /s/M. NGUYEN

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1 CON-ERROR FORENSIC SERVICES, LLC

2 123 Midlands Drive
3 Santa Ivo, Midlands 54321
4 Analyst Report of Amarii Ebi
5 Background
6 I am Amarii Ebi, forensic scientist, criminologist, former lab director, and former detective in
7 the State of Midlands. I’m the founder of Con-Error Forensic Services, LLC. Our company provides
8 aid to litigants requiring expertise in crime analytics and statistics, confession validity and technique
9 analysis, suspect profiling, DNA and forensic analysis, DNA testing, and investigative procedures. I
10 am a court-recognized expert in the fields of actuarial science, forensic psychology, forensic lab
11 procedures, DNA analysis, trace evidence examination, and latent fingerprint analysis. My educational
12 background is quite lengthy: I have Bachelor of Science degrees in actuarial science and criminology
13 from Midlands State College of Science and Agriculture. I have a master’s degree in forensic science
14 from Midlands State University, and a doctorate in clinical psychology also from Midlands State
15 University.
16 Prior to founding Con-Error Forensic Services in 2017, I worked for the Santa Ivo Forensic
17 Science Unit from 1997-2005 while I was in school for my master’s and doctorate degrees. While I
18 was there, I worked as a laboratory technician, and testified for the State of Midlands over 30 times.
19 Once I obtained my doctorate in clinical psychology, I left the forensic lab, and began working
20 for the State of Midlands in a dual role. My primary employment was as a clinician at the Midlands
21 State Forensic Hospital; I also served as an advisor for the State of Midlands Internal Affairs
22 Committee which oversaw reviews of complaints of police officer misconduct during investigations
23 and interrogations. The Midlands State Forensic Hospital is the only secure hospital in the State of
24 Midlands. There, my caseload was comprised of patients experiencing severe mental health crises in
25 our state jails or prisons, including convicted murderers and predatory offenders that needed
26 significant clinical intervention. Occasionally, I worked with inmates found not guilty by reason of
27 insanity.
28 This was hard work, and after 12 years, I needed a change. I saw a lot of people get convicted
29 by what I thought was bogus DNA evidence and watched for years as law enforcement targeted many
30 of my clients and patients simply because of who they were, or their background. I worked with several
31 people I believe were innocent, but were the victims of confirmation bias, a very serious problem in
32 the area of law enforcement.

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33 Con-Error Forensic Services, LLC provides aid to litigants requiring expertise in confession validity
34 analysis, investigation analysis, forensic analysis or psychological services. I am particularly interested
35 in the areas of DNA transfer, latent print collection techniques, false confessions, and confirmation
36 bias. I am a published author. My paper: “Transferred Guilt: How DNA Leads to Wrongful
37 Convictions,” was featured at the 2019 Midlands Association of Criminal Defense Lawyers annual
38 convention, where I was the keynote speaker. I have also done extensive research in the area of police
39 investigator confirmation bias and false confessions. Most famously, I testified for the defense in the
40 retrial of State of Midlands vs. Rock Goodspeed regarding the FBI’s rush to judgment about a former
41 inmate, ultimately leading to a full acquittal, freeing Goodspeed from prison. Besides that case, I have
42 testified in over 20 cases for the defense, almost always on the issues of DNA testing, confirmation
43 bias, or the occasional psychological opinion. I am a court-recognized expert in all these fields.
44 While DNA science is an excellent tool - one of the best - for solving crimes, it has some
45 noticeable limitations. These limitations have been widely publicized in recent years, particularly in
46 stories about wrongful convictions and exonerations due to DNA evidence. I believe it is important
47 to consider all DNA evidence in context for each case, and I strive as part of my practice to make sure
48 juries understand the strengths and weaknesses of modern DNA analysis. It is common for juries to
49 believe that DNA constitutes indisputable proof of guilt or innocence, but the reality is much more
50 complicated. These common misconceptions can lead to wrongful convictions; accordingly, “Con-
51 Error” was an apt name for my firm.
52 Additionally, even law enforcement themselves can be seduced by the power of DNA
53 evidence. In DNA cases, it can be common for officers to focus on a single suspect without taking
54 the time to examine other suspects, or other potential sources of DNA evidence. In the field, this is
55 known as “confirmation bias.” Confirmation bias can be deadly to an investigation. I would know –
56 during one of my cases as a detective, I was so certain I had the right suspect that I cut corners with
57 the investigation. I was cleared of any wrongdoing, but the suspect I arrested was set free, and the
58 crime was never solved. As a result, I’m particularly attuned to situations that may involve
59 confirmation bias.
60 In this case, I was hired by the defense. I charge my standard hourly rate of $500 an hour for
61 document review and analysis, $1000 an hour for secondary testing, and $1000 an hour to testify, or
62 prepare to testify in court. In this case, I did not do any secondary testing, but I did spend 30 hours
63 reviewing the file, plus 10 hours preparing to testify - not including the time I’m spending here today.

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64 So far, I have been paid $25,000 for my work on this file. This is standard in my field. I reviewed the
65 following documents:
66 M. Nguyen’s DNA Report no. 2022112-A00613-1
67 M. Nguyen’s Fingerprint Report no. 2022112-A00613-2
68 M. Nguyen’s Mass Spectrometry Report no. 2022112-A00613-33
69 Detective Kit Bahmani Report no. SIPD-22-0099
70 All evidence, exhibits and affidavits reviewed or collected by Detective Kit Bahmani. I was not
71 able to review the evidence that was lost during the cyberattack on SIPD.
72 Agent Shar Burke Report dated April 17 2022
73 All evidence, exhibits, and affidavits reviewed or collected by Agent Shar Burke. I was not able
74 to review the evidence that was lost during the cyberattack on the FBI servers.
75 SIPD Interrogations of Poe Cameron dated November 21, 2022 and December 5, 2022
76 Affidavit of Berkley F. De la Porta
77 Fingerprint Analysis
78 Latent fingerprints are created when our body’s natural oils or sweat are transferred from
79 our skin onto another surface. The skin of our palms, soles, fingers, and toes contains raised ridge
80 patterns. These patterns form in utero and do not change throughout a person’s life. Latent
81 fingerprint analysts classify the ridges based on their overall pattern.
82 In theory, fingerprint evidence should be the only evidence a prosecutor needs to connect to
83 particular person to a particular crime scene because everyone on the planet has a unique set of
84 prints. But it’s not that simple. Crime scene prints are usually smudged and typically only contain
85 about 20% of the fingertip pattern. This means that examiners are trying to link a partial print from
86 a crime scene to a whole print taken from the suspect at the police station.
87 Examiners compare the overall print pattern and ridge characteristics of the collected
88 fingerprints. They match points on both prints where ridges end, bifurcate, or change direction. It is
89 standard procedure for an examiner to conclude a crime scene print came from a particular suspect
90 after matching three and sixteen points in the patterns. Unfortunately, there is not a consensus in the
91 field on the minimum number of points that must be matched to conclude two fingerprints are from
92 the same person. Most people are shocked to learn that each lab, even each examiner, sets their own

3
I am not trained nor do I have experience in art authentication. I have no opinion to offer on the validty or
authenticity of the paintings that were tested. The science behind mass spectrometry tests is valid and peer reviewed.
I have no issues with the mass spectrometry test or related proecesses used by Analyst Nguyen that are described in
this report.

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93 minimum number of points that must match. There is a reason that Judge Pollak famously held that
94 fingerprint examiners do not constitute a “scientific community” and that fingerprint analysis is
95 merely the subjective opinion of a particular examiner.
96 Even though I found no evidence of that the fingerprint evidence in this case was collected or
97 preserved improperly, any conclusions offered about whether prints found at Ivy Lane or Miller
98 Tower belong to Poe Cameron or Berkley De la Porta should be dismissed as pure pseudo-science.
99 Fingerprint analysists are nothing more than modern-day soothsayers with fancy instruments and lab
100 coats.
101 The Process of DNA Testing
102 In order to understand the process of DNA testing, it is important to start with the history of
103 DNA profiling. DNA profiling began in the early 1980’s. By comparing a known DNA profile to a
104 questioned sample, a qualified analyst can determine the presence of DNA and calculate the likelihood
105 of unrelated individuals contributing to DNA. Before testing can be performed however, certain
106 specific areas of the DNA chain - called “loci” - need to be isolated. This is because well over 99% of
107 all human DNA is identical from one person to the next. Despite all the obvious human differences
108 that DNA contribute to - eye color, height, weight, skin color and hair color just to name a few - the
109 vast majority of the human body contains identical DNA. So merely testing any random portion of
110 the chain will not be scientifically helpful.
111 The gold standard for forensic DNA testing is Short Tandem Repeat (STR) testing. This is a
112 form of what is known as “nuclear DNA” testing. Among the millions of DNA that make up the
113 chain, there are 22 combinations of chromosomes that result in variable DNA that can be used to
114 distinguish one sample from another. Each of these 22 chromosomes are autosomal, meaning that
115 they are non-sex-specific, and that they have a direct contribution from the biological mother, and the
116 biological father. These are known as alleles.
117 In the forensic world, the most common way DNA is examined is by comparing a known
118 sample to an unknown, or question sample. Generally, law enforcement officers pull objects suspected
119 to have DNA on them from a crime scene, and either swab for DNA themselves or send the entire
120 item to the lab for further analysis. This becomes the unknown sample. Once received by the lab, the
121 analyst will subject each sample to a solution of phenol and chloroform to remove the other proteins
122 from the DNA. This entire mixture is sent through a centrifuge which spins rapidly and isolates the
123 DNA for analysis.

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124 Once the sample is isolated it is subjected to a polymerase chain reaction (PCR), which serves
125 to amplify the sample to comparable levels. The amplified DNA is then sent through a computer that
126 looks for 13 different loci within those chromosomes4. Each of these 13 loci have up to two alleles
127 per loci, for a maximum total of 26. This will be represented in a DNA report as two numbers, for
128 example 29, 30. This is the gold standard in the field and is based on years of research. No two people
129 would ever be expected to have an identical profile unless they are monozygotic (identical) twins. In
130 this case, although Memphis Raynes and Poe Cameron are siblings, they are definitely not identical
131 twins. This was confirmed both through analysis of the DNA reports of M. Nguyen, as well as the
132 work of Detective Bahmani, as well as a search of Midlands State birth records.
133 Once a DNA profile is produced for a question sample, it will be compared against known
134 samples. A known sample is usually a buccal swab of DNA taken directly from a specific person under
135 a court order, warrant, or voluntarily. The analyst will then compare the known sample to the unknown
136 sample. If an unknown sample has even a single allele from the known sample missing, then the
137 known sample can be excluded as a contributor. This is because a person’s DNA is always the same,
138 and it will always appear in the same way on any surface. This is a very efficient and scientifically
139 validated way of ruling a specific person out as a contributor. It does not mean the person was not
140 present at the crime scene, nor does it mean that a person was not involved in criminal activity - but
141 it does mean that the DNA evidence on a particular question sample cannot be used to link them to
142 the scene.
143 No reputable analyst would ever claim that any two samples of DNA “match,” or “are a
144 match.” This type of language has been phased out over a number of years. Instead, analysts will give
145 probabilities that a given sample is a “contributor” to a question sample. Often these probabilities are
146 astronomically high - far higher than the total world population in many cases. The persuasiveness of
147 these probabilities is left to juries to decide, and lawyers to argue.
148 DNA Mixtures
149 Sometimes, a question sample will have DNA from more than one contributor. This can easily
150 be identified without even needing a comparison sample, because the appearance of more than 2
151 alleles at a single loci constitutes conclusive proof that at least two people contributed to a sample.
152 While isolated solitary DNA profiles are preferred - and are obviously the easiest to test - much
153 forensic analysis involves taking samples of objects that are likely to be touched or handled by many

4
It should be noted that there are many laboratories that now use 20 loci as the threshold standard.

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154 different people. A doorknob for instance is touched by every person that uses the door. A doorknob
155 is a known source of transfer (which I will discuss below), but ignoring that for now, the doorknob is
156 also going to pick up a lot of DNA from a lot of different people. It would not be surprising to see
157 multiple sources of DNA on a question sample. This is called a DNA “mixture.” The more potential
158 contributors to a mixture, the more complicated it is. Eventually a question sample will become
159 unusable if there are too many contributors. Even a sample of two people can be misleading - because
160 it is easily possible for two unrelated people to share some alleles at a given loci, or to even be
161 homozygotic at a single loci, which could yield only a single allele.
162 DNA Transfer
163 Another area of concern and one of the biggest weaknesses in modern DNA science is the
164 prospect of DNA transfer. Modern testing cannot detect transfer any better than the old technology
165 could, so we are left to deal with the risk of it during trial. If transfer occurs, it could yield results that
166 make no sense to the analyst, or it could implicate a suspect when they are actually innocent. As such,
167 precautions must be taken as much as possible to rule out the prospect of DNA transfer. In order to
168 understand transfer, you first need to understand how nuclear DNA arrives on an object.
169 Our bodies expel DNA constantly. DNA gets expelled from sweat glands, saliva glands, and
170 any expulsion of bodily fluids like blood or urine. DNA is contained in each of our cells and those
171 cells get left behind on objects every day as we interact with them. Because of this, objects can often
172 be tested for DNA by taking sterilized swabs and examining them in a lab.
173 The primary limitation of this technique however, is that it cannot ever explain how an
174 individual’s DNA ended up on an object. Obviously, the most common way to deposit DNA on
175 something is to simply handle it yourself. DNA will transfer from your body, your skin cells, and your
176 sweat to the object, and remain on the object for a period of time after the interaction. Because DNA
177 lives for an indeterminate period of time on an object, it cannot be determined when an individual piece
178 of DNA was deposited on an object simply from a DNA analysis alone. It also cannot be determined
179 where the DNA came from - whether it was blood, touch DNA, sweat or saliva for instance. There are
180 other tests that may help narrow this down, but the DNA test itself is useless for this purpose.
181 Primary Transfer
182 Even knowing all of this, it wouldn’t be a problem for DNA analysts if it weren’t for the
183 possibility of transfer. DNA transfer occurs when DNA moves from one object to another object.
184 DNA does not move directly, so this only happens when the objects come into contact with each
185 other, or with a third object that touches both of them. For example, if I touch a coffee mug while

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186 drinking coffee, and then put the mug down on a table, it is likely I will leave DNA behind on the
187 coffee mug. This is called primary transfer. If another person were to come and pick up the coffee
188 cup, it is possible that my DNA would be picked up from the coffee mug and transferred to the hand
189 of the other person. Their hand might test positive for my DNA, despite the fact that I have never
190 touched their hand. This would be called secondary transfer.
191 Secondary and Subsequent Transfer
192 This can cause compounding problems. Now that my DNA is on the hands of another person,
193 if that person were to touch another object, my DNA could be transferred to that secondary object.
194 This would be called tertiary transfer. This would result in my DNA being placed directly onto an
195 object that I never came into any contact with at all. Nuclear DNA testing would be useless in
196 determining whether a transfer occurred - it would reflect that my DNA was on the secondary object.
197 While the likelihood of DNA being transferred to tertiary and quaternary objects is increasingly
198 unlikely, it is possible. One study done by the American Academy of Forensic Science in 2015
199 demonstrated secondary transfer in 85% of cases. While the realistic possibility of transfer in the world
200 is likely to be significantly lower than 85% - a number determined under flawless laboratory conditions
201 - it is still a non-negligible amount and must be accounted for.
202 Screening for Transfer
203 That said, there are many ways in which both analysts and investigators can limit the likelihood
204 of transfer. First and foremost, they can compare the quantity of DNA found. Transfer typically
205 deposits only minute amounts of DNA, because much of it is lost in the actual transfer process. An
206 analyst could compare the amounts of DNA left by a suspect on a known sample with amounts of
207 DNA left by a suspect on a questioned sample, and if the amount is significantly less, that may indicate
208 the possibility of transfer.
209 Secondly, investigators on the case will often be able to recreate the movements of a suspect
210 through witness statements, video recordings or confessions. This creates a more accurate picture of
211 where DNA might end up, and how it might get there. Finally, DNA should only be taken from places
212 likely to capture a suspect’s DNA. Nearly every surface you can touch has DNA on it, and
213 indiscriminately swabbing for DNA will yield so many results that it would render testing virtually
214 useless. Investigators should use a targeted approach to collecting DNA, so the analyst can provide
215 helpful results that further the investigation.

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216 DNA Analysis in State of Midlands v. B.F. De la Porta and Poe Cameron
217 The decision to run a nuclear DNA test was the appropriate decision in this case. As noted,
218 that is the gold standard in the field. However, as our technology develops we have the ability to run
219 a 20 loci comparison, rather than a 13. This technology is emerging, but is significantly stronger at
220 evaluating DNA, and significantly better at ruling out suspects. I do not believe the Santa Ivo
221 laboratory has the capabilities to do this testing on site, but there are at least two testing centers in
222 Midlands that would. Both the Garland Greene Forensic Laboratory in Cyrus, Midlands, and the
223 CHASE Forensic Laboratory have access to 20 loci testing. In a major case like this one, it would have
224 been helpful to get additional certainty.
225 A possible effect of this can be seen by examining the results. 4-A (blood spatter from Miller
226 Tower vault) yielded a mixture. It is uncommon to see a mixture in a blood sample. This should have
227 been a clue to the investigators to look for and attempt to rule out the possibility of DNA transfer.
228 Blood is one of the strongest sources of DNA. Often, a blood sample contains so much DNA that it
229 needs to be diluted in order to be properly tested. While I cannot find any direct evidence of tampering
230 or contamination by the lab, it is at a minimum concerning that a blood sample test resulted in a
231 finding of “mixture.” It is possible this is an interpretation issue. Increasing testing to 20 loci, rather
232 than 13 may have had an impact on determining whether this profile is a match to either suspect.
233 My second concern is that many of the objects examined for DNA are ripe for DNA transfer.
234 Any object that can be physically handled, such as a fork, drinking glass, or door handle is a possible
235 source of DNA transfer. However, even objects like a laundry bin, or an article of clothing could be
236 subject to DNA transfer. While there is no specific evidence of a transfer occurring in this case,
237 transfer can be sneaky, and show up even where an analyst does not expect.
238 As discussed above, there are no quantitation results in the forensic report here. It is unclear
239 whether or not quantitation was recorded and measured. Recording the amount of DNA present in
240 every object would allow the analyst to rule out the prospect of transfer to a reasonable degree of
241 scientific certainty. For some reason, that does not appear to have been done here, which raises
242 questions about the reliability of the underlying testing. However, I cannot say for certain whether a
243 quantitation would impact the results in any way.
244 Analysis of the Investigation of Law Enforcement
245 As I mentioned earlier, law enforcement officers have the potential to be seduced by the power
246 of DNA evidence. DNA is a powerful tool – but it is only a tool, and a skilled investigator needs to
247 take care to continue to follow appropriate procedures while investigating a case. This includes

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248 gathering evidence, interviewing witnesses, and exploring the possibility of additional suspects. Ideally,
249 this work should continue up until the time an arrest is made, because it does not look good for anyone
250 when an innocent suspect is detained.
251 Investigative errors most commonly occur when an investigator becomes so focused on a
252 single suspect that they become blind to other options and other explanations. This is what is known
253 as confirmation bias, and it can quickly send an investigation off the rails. When an investigator is
254 exhibiting confirmation bias, they will typically have a suspect in mind and will interpret all new
255 evidence as proof of that suspect’s guilt. It is easy to see how this can be dangerous when an
256 investigator is supposed to pursue the truth in an unbiased way. It puts up blinders, and keeps the
257 investigator focused on only one thing or one suspect, when other options exist and might even be
258 stronger ones.
259 Psychologically, confirmation bias is satisfying to the individual. When pressed with a situation
260 where you need to solve a puzzle, it is satisfying to know that you have the correct answer. Sometimes,
261 a gut feeling can be absolutely right, and it is plucky law enforcement officers following their gut that
262 are responsible for some of the most famous criminal takedowns of all time. That said, it can be
263 deceptively satisfying. That is why confirmation bias must so stringently be guarded against. Without
264 proper safeguards, individuals can be targeted for any number of reasons – some which may not even
265 be known to the officer targeting them.
266 Examination of the Investigation of Special Agent Shar Burke
267 In this case, I examined the report of Shar Burke, a federal law investigator, and Kit Bahmani,
268 a state investigator both of whom participated in the investigation in this case. Initially, I wanted to
269 review the investigative steps they took in this case and determine whether there were any issues with
270 chain of custody, or the handling of evidence. After reviewing both reports, I have no concerns
271 regarding chain of custody, or the handling of evidence. Both investigators are highly trained and
272 conducted this investigation to modern law enforcement standards.
273 However, after reviewing the report of Shar Burke, I became concerned that Agent Burke may
274 have inappropriately targeted Berkley De la Porta. The first concern is that Agent Burke indicates they
275 “knew immediately who the perpetrator was.” It’s not uncommon for an investigator to have a lead
276 on a suspect, especially in a small world like art crimes, but in this case Agent Burke’s statement
277 appears to be based on nothing but watching a video of the heist. This is in spite of Berkley De la
278 Porta having no criminal record, no known ties to organized crime, and no history of arrest or
279 investigation by other law enforcement agencies. Agent Burke was immediately convinced that this

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280 was the “Morisot Mastermind,” an alleged art thief that Burke admits to trying to pursue for 5 years.
281 From that point on in the investigation, the focus was only on this alleged Mastermind, without ever
282 looking into other suspects. In fact, the search for the mastermind was so extensive that at one point
283 Agent Burke notes they pulled in the resources of every other investigator in the art crimes unit to call
284 their sources and reach out to their contacts to attempt to track down this mastermind. Once Agent
285 Burke was able to determine to their satisfaction that Berkley De la Porta was this so-called
286 Mastermind, Agent Burke never stopped to consider alternative suspects, or potential alternative
287 explanations for what Agent Burke found.
288 Yet, alternative explanations existed. It is possible that Berkley De la Porta is simply an art
289 collector. It is possible that Berkley De la Porta purchased a single painting illegally but had nothing
290 to do with the violent heist that makes up the substance of this case. Questioning whether Berkley De
291 la Porta was involved is certainly no stretch – but making the leap that Berkley De la Porta “must” be
292 involved, and “must” be the mastermind is a dangerous investigatory leap. Such confirmatory thinking
293 leads to corners being cut and prevents other potential leads from being investigated. I’m very
294 concerned that Agent Burke’s behavior was influenced by an overwhelming desire to capture the
295 “Morisot Mastermind,” rather than solve the actual crime in front of them.
296 That said, it is difficult to conclude with certainty that there was confirmation bias here. In
297 most cases with confirmation bias, the target is a specific person, not an unknown person like in this
298 case. Additionally, Agent Burke served multiple warrants, and spent an extensive amount of time
299 hunting down De la Porta using plenty of common investigatory techniques. Usually in cases with
300 confirmation bias, I would expect to see corners cut and the investigation rushed. This does not mean
301 Agent Burke was free from confirmation bias, though it would be wrong to say with certainty either
302 that Berkley De la Porta is innocent, or that Agent Burke definitely was influenced by confirmation
303 bias. Best practices should have assigned this investigation to another investigator within the art crimes
304 division, for the new set of eyes and ideas, but that is certainly not a legal requirement. In the end, it
305 would be hard to argue that Agent Burke did not follow the evidence where it naturally led. Still, I am
306 concerned about the decision not to consider any other alternatives.
307 Examination of the Investigation of Kit Bahmani
308 I was also asked to look at the report of Kit Bahmani, a detective with the Santa Ivo Police
309 Department. As with Agent Burke, my primary concern was to find evidence of confirmation bias.
310 Detective Bahmani was likely even more susceptible to confirmation bias because their experience is

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311 not investigating art heists, and they appear to have relied on Agent Burke for much of the background
312 information on the primary suspect.
313 Detective Bahmani’s investigation was initially focused on the robbery and assault that
314 occurred at Miller Tower. This is natural, given that is where Detective Bahmani was asked to respond.
315 Detective Bahmani was only led to De la Porta because of the input from Agent Burke. While it is
316 possible that Detective Bahmani could have determined De la Porta’s alleged involvement without
317 Agent Burke, it appears unlikely, given that De la Porta’s DNA was not in the system, and Detective
318 Bahmani had no reason look into De la Porta specifically. If Agent Burke was acting on confirmation
319 bias, this would also have an impact on Detective Bahmani’s investigation, since it was so heavily
320 influenced by Agent Burke. However as noted, I can find no specific evidence that either Detective
321 Bahmani, or Agent Burke inappropriately targeted De la Porta.
322 Detective Bahmani also followed the leads that led to the arrest of Poe Cameron. It is unclear
323 from the report exactly what specific evidence led Bahmani to investigate Cameron in the first place.
324 Detective Bahmani notes that “evidence found in the stairway and in the hallway came from a person
325 named “Memphis Raynes.” Detective Bahmani goes on to note that Memphis Raynes and Poe
326 Cameron are siblings. It appears the only reason Detective Bahmani initially called Poe Cameron in
327 for questioning is to attempt to locate Raynes after a warrant was issued for Raynes’s arrest.
328 My primary concern with Detective Bahmani’s focusing on Memphis Raynes and Poe
329 Cameron is that it appears to be based off of prior contacts with the family. Detective Bahmani
330 expresses disappointment that Poe Cameron has a criminal record, and openly notes that Bahmani
331 previously arrested Raynes a number of times. Detective Bahmani was also concerned that Raynes’s
332 record got worse after Detective Bahmani’s interactions.
333 In any case with a violent assault, it is natural for law enforcement to want to try and solve it.
334 I’m always on the lookout for evidence that detectives cut corners, or honed in on a suspect far too
335 quickly. In this case, while it appears Detective Bahmani initially focused on Poe Cameron simply
336 because they could not find Memphis Raynes, there was eventually enough evidence to arrest Poe
337 Cameron for their involvement in the heist, including an eyewitness named Jun Cage that put Poe
338 Cameron at the scene and additional evidence Detective Bahmani found in Cameron’s home.
339 I also reviewed the interrogation of Poe Cameron by Detective Bahmani. To me, it appears
340 that Poe Cameron wanted to talk prior to invoking their right to remain silent. It is undisputed that
341 Memphis Raynes is Poe Cameron’s sibling, and that Memphis has a much more extensive, and violent
342 criminal record. I worked on a case years ago where an older sister convinced a younger brother to

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343 commit crimes with her, by threatening the younger brother’s partner if the younger brother didn’t
344 comply. Detective Bahmani’s interrogation of Poe Cameron reminded me of the younger brother in
345 that case.
346 I am concerned that Detective Bahmani pushed Poe Cameron too hard, causing Cameron to
347 invoke their right to remain silent. If Detective Bahmani had given Cameron breathing space to speak,
348 it is possible that Detective Bahmani would have learned more about Cameron. It would be interesting
349 to know whether Poe Cameron was threatened or coerced by Raynes. Cameron appears to suggest
350 that might have happened but is shut down by Detective Bahmani quickly and asks for a lawyer before
351 explaining. While suspects obviously have a right to remain silent, a good detective will usually know
352 how to keep them talking, especially when they are relatively unfamiliar with the criminal justice
353 system.
354 In this case, there is evidence pointing to Cameron being threatened by Memphis Raynes or
355 others5. At least one independent witness saw Cameron being threatened by Memphis Raynes during
356 a meeting. Such information does not appear to have been followed up on by law enforcement
357 generally, or Detective Bahmani specifically which is concerning.
358 There is other evidence that points to the possibility of duress. For one, Poe Cameron has no
359 history of violence. It is not uncommon for violent offenders to build up to the overwhelming violence
360 that comprises serious criminal charges. A history of small crimes of violence gradually getting more
361 serious is typical for a case like this. Yet here, we do not have that with Poe Cameron. This should
362 have raised at least a red flag for Detective Bahmani. Indeed, it seems to have done so judging from
363 the interrogation, considering that Detective Bahmani tried to question Cameron about being
364 threatened. However, I believe Detective Bahmani pushed the issue to hard, and too quickly, resulting
365 in Poe Cameron shutting down.
366 It also should be noted that there does not appear to be a clear motive for Poe Cameron to
367 be involved in this heist. Sure, there is some financial motive, but there doesn’t appear to have been
368 any investigation into Poe Cameron’s financial situation, and whether or not they were desperate for
369 money. Additionally, people desperate for money will not often resort to extreme violence, without a
370 history of violence to begin with. It is somewhat an out-of-character leap for Cameron to make
371 without something forcing Cameron’s hand. It is unusual for a complicated heist like this to involve

5
The Affidavit of Berkley F. De la Porta also indicates some history of violent behavior in that De la Porta identifies
themselves as being part of an underground mixed martial arts community. Though, De la Porta has no criminal
history of violence. Nor was I able to find other signs of violence outside the MMA-type fight club.

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372 relative amateurs to high-stakes criminal activity. Poe Cameron doesn’t have a history of being
373 involved in organized crime, plotting serious crimes, or committing serious crimes. Even as hired
374 muscle, Poe Cameron seems an odd choice.
375 While I cannot find any evidence of wrongdoing by Detective Bahmani in this case, I remain
376 concerned that there might be secondary confirmation bias as a result of Agent Burke’s insistence that
377 De la Porta is involved. And I remain concerned that Poe Cameron may have been forced into
378 committing this crime, though I acknowledge that Poe Cameron has never directly said that, and I did
379 not interview Poe Cameron myself.
380 Conclusions
381 Through my review of the case, it appears that the DNA laboratory followed the appropriate
382 procedures. I have no concerns with either the certifications of the forensic examiner, or those of
383 the laboratory. These tests appear to have been performed according to industry standards, in a lab
384 certified to conduct these results. While there are a few minor anomalies in the results, this is
385 common in the field of DNA testing and usually not indicative of invalid results. In theory it is
386 possible, but it is not a conclusion I would be willing to stake my professional reputation on.
387 Overall, it appears that the lab did appropriate work. They are certified by AAFTL, and
388 NICAGE and have been continuously since 2002. NICAGE is a very difficult certification to achieve
389 and requires an extensive amount of supporting documentation. It is rare to see such a nationally
390 treasured certification in a forensic laboratory. It is impressive and noteworthy that the laboratory has
391 maintained such a certification continuously for over 20 years.
392 I am not concerned that the lab had to undergo a recertification process. This is standard in
393 the field, and it is standard to shut down operations for a short time while that process occurs. This is
394 important to ensure the ongoing standards of DNA testing and forensic evaluation are met. Like any
395 science, forensic science is continuously evolving. This allows for the reliable and accurate testing of
396 ever smaller amounts of DNA. It also changes the standards by which evaluators examine evidence,
397 and the conclusions they are allowed to draw. It is important from time to time to check every lab -
398 even highly successful NICAGE certified ones - to make sure they are not violating best practices and
399 industry standards. My understanding is that the lab in this case was recertified two weeks after the
400 initial draft of this report was released and has maintained their certification ever since. Again, this is
401 normal in the field.
402 I am hesitant to speculate on the likelihood of transfer in this case. In general, the best
403 explanation for a source of DNA is that it was placed there by the person whose DNA it is. Transfer

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404 is always a possibility but does not occur in every case - or even the majority of cases. In this case,
405 there is very little evidence to suggest that transfer occurred. Some of this is due to testing limitations,
406 but there is nothing else in the materials I reviewed to suggest there is a significantly higher risk of
407 DNA transfer in this case. That being said, DNA transfer cannot be ruled out completely as a possible
408 explanation either.
409 Finally, after a thorough review of both Agent Burke’s investigation, and the work of Detective
410 Bahmani, I cannot conclude that either investigator acted inappropriately. There is a significant
411 amount of evidence pointing to the involvement of both De la Porta, and Poe Cameron. However, in
412 a major case like this, more investigation is never harmful, and it is always good to tie up loose ends.
413 I remain concerned about the possibility of confirmation bias. Though I understand why investigators
414 chose not to conduct additional investigations to determine if Poe Cameron was coerced or even
415 involved in the heist at all, I disagree with this decision, and I believe more investigation should have
416 been conducted. Confirmation bias can lead to investigators overlooking facts or missing evidence,
417 and the best way to ensure that doesn’t happen is to take more time.
418 I swear and affirm the truthfulness of everything stated in this report. Before writing this
419 report, I was told to include every relevant detail in my investigation. I have done so to the best of
420 my abilities. I know that I can and must update this report if anything new occurs to me, up until the
421 moment before opening statements begin at trial.
422
423 ____________________________________
424 /s/AMARII EBI

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1
1 INTERVIEW OF POE CAMERON
2 AT
3 SANTA IVO POLICE DEPARTMENT

4 DATE: 11/21/22
5 [START OF RECORDING]

6 Operator, this is Kit Bahmani, Badge Number 13692. I’m speaking

7 with Poe Cameron, P-O-E C-A-M-E-R-O-N. Cameron’s date of birth
8 is 03/24/03. Today’s date is November 21, 2022, the time is
9 12:15 pm. I’m here with Agent Shar Burke, speaking today with
10 Cameron about an ongoing investigation. Also present is
11 Detective Edward Malus, my partner in this investigation.

12 Cameron: Malus? The guy that singlehandedly took down the

13 Midlands Mafia last year?

14 Malus: That’s right.

15 Cameron: I saw that on BNN! Did you really take out every single
16 member of the mob?

17 Malus: Every last one. Midlands hasn’t had a mafia for more than
18 a year.

19 Cameron: Not bad.

20 Bahmani: We’re not here to talk about that. You know why you’re
21 here, I assume?

22 Cameron: Nope.

23 Bahmani: We’re here to talk about Memphis.

24 Cameron: The city? I hear it’s a great place for ribs and blues
25 music. But I’ve never been. Unless you’re talking about the one
26 in Egypt. But I got nothing for you there.

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27 Bahmani: Funny. I like a good sense of humor. I got jokes too.

28 You know full well I’m not talking about a city. I have a
29 history with Memphis too. Memphis is in trouble, and I want to
30 make sure nothing bad happens to Memphis, alright? We are on the
31 same team here.

32 Cameron: Same team? You’re right, you do have jokes.

33 Bahmani: Look Poe, we can do this the easy way where you walk
34 out the door you came in once you tell me what I need to know,
35 or we can book you into one of our nice 6x8 suites we have here,
36 and you can see if your cellmate finds your Egyptian trivia
37 interesting.

38 Cameron: What do you want to know about Memphis? We aren’t that

39 close these days. We have very different interests and mine
40 include not ending up with a prison number.

41 Bahmani: But you currently live with Memphis, right?

42 Cameron: No, I have my own place. We’re not the type of siblings
43 that hang out all the time.

44 Bahmani: We know Memphis was involved in something big, and we

45 know you were too.

46 Cameron: I don’t know what you’re talking about.

47 Bahmani: Of course, you do. We know Memphis was at the Miller

48 Tower during the heist.

49 Cameron: What heist?

50 Bahmani: Don’t do that. I want to be able to trust you. Everyone

51 has heard about the robbery during the Sohi Children’s Hospital
52 Gala.

53 Cameron: I mean, I might have seen something on the news about

54 it. Rich people sad about losing their diamonds and ugly
55 paintings doesn’t really interest me, you know?

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56 Bahmani: Yeah, I get that. I think most of Santa Ivo feels that
57 way too. But I got a job to do, ok? I just need your help so
58 those people that do care about those diamonds and ugly
59 paintings will get off my back, you feel me?

60 Cameron: Sure, I guess.

61 Bahmani: Memphis didn’t get involved in the biggest crime in

62 this city’s history without saying at least something to you.
63 C’mon. I don’t think you were involved, ok? Your history doesn’t
64 scream jewel and art thief, ok? But Memphis? Memphis has some
65 serious history. I think Memphis was involved and has angered
66 some really bad people. Help me find Memphis before they do, ok?

67 Cameron: Look, I don’t want Memphis to be in danger but I just

68 don’t know what you think I know.

69 Bahmani: You know Memphis was there.

70 Cameron: I don’t know anything about that.

71 Bahmani: You’re going to lie to me? We know Memphis was there.

72 I have mountains of evidence that put Memphis at Miller Tower
73 and on the 40th floor inside the vault. So, it’s not really a
74 question that Memphis was involved.

75 Cameron: Ok, so what do you need to talk to me for?

76 Bahmani: We know you were involved.

77 Cameron: I wasn’t involved in anything.

78 Bahmani: You’re saying you weren’t there?

79 Cameron: I don’t hang out with snobs. Wasn’t born with a silver
80 spoon, you know?

81 Bahmani: So you weren’t at Miller Tower on Halloween?

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82 Cameron: I wasn’t there, and I have no idea what you’re talking

83 about. I haven’t dressed up on Halloween in a long time. Go
84 shake down somebody else.

85 Bahmani: I know Memphis was involved. Rock solid evidence. I

86 know Memphis didn’t do this alone. Set up a whole crew and I
87 think you were part of it. I haven’t figured out why yet because
88 everyone we talk to says you’re practically a saint. But have a
89 gut feeling that you helped rob the place. If you help me now,
90 before the word gets to the prosecutor’s office, I can put in a
91 good word for you. Maybe you can still avoid that prison number?

92 Cameron: Don’t know what to tell you. Can I go?

93 Bahmani: Sure. But since you don’t know anything, you’ve got
94 nothing to hide, right?

95 Cameron: I guess so...

96 Bahmani: Cool. So you don’t mind giving us a DNA sample, right?

97 It’s a quick and painless swab inside your mouth, no big deal at
98 all.

99 Cameron: I don’t know…

100 Bahmani: Look Poe, if your DNA isn’t there, we’ll clear you
101 officially. Maybe that feeling in my gut is just some bad sushi.
102 Prove me wrong, Poe. Since you’ve got nothing to hide, it’s the
103 easiest thing to do.

104 Cameron: I guess.

105 Bahmani: Detective Malus, grab that kit so I can take the buccal
106 swab.

107 Cameron: Make it quick, would you?

108 Bahmani: I’m going to take this cotton swab out of the package
109 and run it alongside your inner cheek, ok? Both sides of the
110 swab for each cheek. Totally painless. Can you please open your
111 mouth and then you’ll be out of here before I can get these

4
 Revised 12/12/23

112 latex gloves off, ok? All done. Go ahead Poe, you’re free to go.
113 For now.

114 Cameron: Oooooooh, I’m terrified.

115 Bahmani: Poe Cameron has exited the room, and that will
116 terminate the interview. Cameron agreed to and did provide a
117 buccal swab sample before they left. Current time is 12:26 pm.

118 [END OF RECORDING]

119 C E R T I F I C A T E
120
121 STATE OF MIDLANDS :
122 : SS
123 COUNTY OF CHARLOTTE :
124 I, EMILY SPEARS, the undersigned, a duly qualified and
125 commissioned notary public within and for the State of Midlands,
126 do hereby certify that the foregoing is the interview given at
127 the date and place stated herein, that said interview was
128 transcribed with computer-aided transcription from an audio
129 recording; that I am neither a relative of nor attorney for any
130 of the parties to this cause, nor relative of nor employee for
131 any of their counsel, and have no interest whatever in the
132 result of the action.
133 IN WITNESS WHEREOF, I hereunto set my hand and official
134 seal of office at Midlands Center, Midlands this 10th day of
135 June 2023.
136 _________________________
137 /s/EMILY SPEARS

5
 INTERVIEW OF POE CAMERON
AT
SANTA IVO POLICE DEPARTMENT

DATE: 12/5/22
[START OF RECORDING]

Operator, this is Kit Bahmani, Badge Number 13692. I’m speaking

with Poe Cameron, P-O-E C-A-M-E-R-O-N. Cameron’s date of birth
is 3/24/03. Today’s date is December 5, 2022, the time is 1:42
pm. I’m here again with Detective Edward Malus, speaking today
with Cameron about an ongoing investigation.

Bahmani: Welcome back Poe. We’ve got some chatting to do.

Let’s get this out of the way: You have the right to remain
silent. Anything you say can be used against you in a court of
law. You have the right to consult with an attorney before
questioning. You have the right to the presence of an attorney
during questioning. If you cannot afford an attorney, one will
be provided for you before questioning. Do you understand these
rights?

Cameron: Yeah, I do. But this all a waste of time.

Bahmani: Well, let’s chat a bit and see. We’re here to talk more
about the Halloween heist you told us you know nothing about.

Cameron: I don’t know what else you want me to say.

Bahmani: You’re going to keep feeding us that malarky? Alright,

that’s fine. Let’s start simple. I want to talk about what you
know about Miller Tower.

Cameron: Nothing. Not my scene, you know?

Bahmani: So you told us. But we just caught you with a duffel
bag full of cash and a ticket to Canada.

Cameron: Something wrong with going ice fishing in January?

Bahmani: With a duffel bag of cash?

Cameron: I don’t use credit cards. Didn’t want to run out of

money, you know?

Bahmani: Fine. Let’s start with this instead. You know Jun Cage,
right?
 Revised 12/12/23

Cameron: I mean, yeah, not like we’re close or anything, but I

know them. Jun is from Walton Park too. Lives in the same
Pleasant Ridge neighborhood as my parents. Good kebab, Jun’s
falafel is a bit dry though.

Bahmani: Oh so you’re a food critic now too. Cage said something

similar about you. The same neighborhood part. We didn’t chat
about falafel. Thing is Poe, Cage told us in a sworn statement
that you were at Miller Tower.

Cameron: Interesting. Never took Jun for someone who would talk
to the cops. But whatever. So what, who hasn’t been to Miller
Tower? It’s the tallest building in the city. Everyone’s been
around there. There are some good bands at the street festival
nearby.

Bahmani: Cage saw you there on October 31, the night of the
robbery.

Cameron: I don’t know about that. I think Jun must have had some
bad kebabs. Must have confused the dates or me with somebody
else.

Bahmani: You calling Cage a liar?

Cameron: No. I just…I don’t know. I wasn’t there on Halloween.

Bahmani: Know of any reason Cage would lie about seeing you
taking videos on your phone of Miller Tower and seeing you exit
the security door by the alley on Halloween?

Cameron: No. Maybe it’s time Jun invested in some glasses? All
that smoke in those tiny carts can’t be good for your eyes.

Bahmani: Yeah, ok. Sure. How about Ivy Lane? Remember being
there?

Cameron: I’ve definitely never been there. Can’t afford that

rent.

Bahmani: So Cage is lying again, huh?

Cameron: No, now you are lying. Jun doesn’t work the Oakley
carts. Jun doesn’t like to go that far from Walton Park.

2
 Revised 12/12/23

Bahmani: Must be Cage’s mistake again, right? Even if Cage is

seeing your doppelgänger and it’s all a big misunderstanding. It
must be a perfect clone because your DNA is all over that place,
Poe.

Cameron: Come again?

Bahmani: We’ve got a 100% match on your DNA at Ivy Lane.

There’s no one it could be except you.

Cameron: That’s not possible.

Bahmani: I know you were in Memphis Raynes’s apartment, Poe.

Coming clean will help you later when the judge is deciding what
age you’ll be when you finally get parole.

Cameron: Yeah, ok. Fine. I’ve been to Memphis’s apartment

before. No crime to visit your sibling.

Bahmani: Thought you said those luxury places weren’t your

scene.

Cameron: Memphis’s apartment is a studio apartment dump in

Silverton. It’s like $500 a month. Nothing swanky.

Bahmani: You are so quick. Smart. Must be why they brought in

Memphis so they could also get you involved in this heist. I’m
not talking about Memphis’s apartment in Silverton. I’m talking
about the one at Ivy Lane.

Cameron: [laughing] As if Memphis could get a place at Ivy Lane!

Do they rent to felons? I imagine the moment Memphis set foot in
Oakley, you all were finding a reason to pull Memphis over and
search the car. Can I go? Those fish are calling my name.

Bahmani: Afraid not. When you all cleaned out Memphis’s

apartment, you forgot to look in the dishwasher.

Cameron: What are you talking about?

Bahmani: Dirty dishes had your prints and DNA all over them.
100% match. So you’ve definitely been in Memphis’s apartment at
Ivy Lane.

Cameron: My DNA on Memphis’s dishes isn’t a crime. We’re

siblings. Besides our mom is always making me take her
casseroles over to Memphis. If she doesn’t see food in front of

3
 Revised 12/12/23

you, she gets really worried, you know? Just ask her about it.
She’ll talk your ear off about her casseroles.

Bahmani: Look, Poe. You know we searched your place after we

arrested you, right?

Cameron: I assumed you would.

Bahmani: Didn’t find much.

Cameron: That’s because I didn’t do anything. You’re chasing

windmills.

Bahmani: [clanking noise of something hard set down on a hard

surface] Maybe I am. But I was just curious about this ring we
found in your apartment. This yours? (Exhibit 7)

Cameron: Let me see it. Yeah, that’s mine. Why?

Bahmani: It’s pretty unique.

Cameron: Did you want to buy it or something?

Bahmani: Just seems out of place that’s all.

Cameron: That wasn’t part of the loot taken from Miller Tower.
Are you for real? It’s just a ring I found on the internet and
thought looked cool.

Bahmani: And how would you know what items were taken from
Miller Tower, Poe?

Cameron: [pause] That’s not what I said. Look. you can have a
nice day...or not. I’ve got nothing to say to you. Unless you
are going to charge with me something serious, I’m leaving right
now.

Bahmani: Listen Poe, you and I got off on the wrong foot here.
That’s my bad. Let’s try this again. You want some water or food
or something?

Cameron: [exhales] Water would be nice, yeah.

Bahmani: Malus, can you get Poe some water? Thanks. Listen
Poe, I know how you grew up. I know about Memphis’s criminal
history, and how it wasn’t just in Memphis’s past. I’ve been
asking around and I know about how Memphis treated you. You

4
 Revised 12/12/23

didn’t want to be a part of this. I know that. Just let me help

you, alright?

Cameron: Memphis never did nothing to me.

Bahmani: You and I both know that’s not true. Memphis has been
awfully rough on you over the years, and you’ve played the good
sibling and never said a word about it.

Cameron: So?

Bahmani: So I think this isn’t who you are. I think you got
mixed up in something big, and someone got hurt, and you didn’t
know that was going to happen. I think Memphis made you do it.
I don’t think you’re the type of person that goes around robbing
and beating people up.

Cameron: I’m not.

Bahmani: Exactly. So let me help you here.

Cameron: [heavy sigh] Ok

Bahmani: Smart move. But Poe, listen, I can only help you if
you’re honest with me. I can’t help you if you’re protecting
Memphis. A life of crime isn’t who you are, and it isn’t who
you want to be.

Cameron: [Indecipherable]

Bahmani: Did you just say Memphis threatened you?

Cameron: [pause] I said I want my lawyer.

Bahmani: Don’t do that. Don’t protect Memphis. I can’t help you

if you lawyer up, Poe. I know Memphis put you up to this and I’m
trying to help you here.

[pause]

Bahmani: Poe, tell me more about Memphis threatening you. No one

wants to punish you if you were forced into this, Poe. Do the
right thing here.

5
 Revised 12/12/23

Cameron: [heavy sigh] Huh uh. Nope. I’m not saying anything.
We’re through here. You have to let me talk to my lawyer.

Bahmani: You’re making a mistake. But fine. We’ll end it here.

Time is 2:05 pm.

[END OF RECORDING]

C E R T I F I C A T E

STATE OF MIDLANDS :
: SS
COUNTY OF CHARLOTTE :
I, RIA DEBNATH, the undersigned, a duly qualified and
commissioned notary public within and for the State of Midlands,
do hereby certify that the foregoing is the interview given at
the date and place stated herein, that said interview was
transcribed with computer-aided transcription from an audio
recording; that I am neither a relative of nor attorney for any
of the parties to this cause, nor relative of nor employee for
any of their counsel, and have no interest whatever in the
result of the action.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal of office at Midlands Center, Midlands this 10th day of
June 2023.
_________________________
/s/RIA DEBNATH
MINOR ADDENDUM RE: EXHIBIT NUMBERS ADDED; NO
OTHER CHANGES.

IN WITNESS WHEREOF, I hereunto set my hand and official

seal of office at Midlands this 15th day of July 2023.
_________________________
/s/RIA DEBNATH

6
EXHIBITS
 Revised 8/27/23

Exhibit
1
Revised 8/27/23
 NOT FOR SALE, BUT GENEROUSLY
\� PRESENTED FOR LIMITED VIEWING

BERTHE MORISOT'S THREE TERRES DU MILIEU PAINTINGS

BROUGHT TOGETHER FOR THE FIRST TIME IN OVER A CENTURY

'PPay/.Jcvnne G2/Vo:uvdle dano. /eo. dT�

COURTESY OF BANCROFT ESTATES

dYt:dva rgz}and- /eo. dTerJJCe.<J.

COURTESY OF BANCROFT ESTATES COURTESY OF B. F. DE LA PORTA

r�-' �H�D�E�'S

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Exhibit
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11
 Exhibit
12

MIDLANDS RESIDENTIAL LEASE AGREEMENT

1. THE PARTIES. This Midlands Lease Agreement (the “Agreement”) made on 08/09/2022 is
between:

Landlord Name: Blaise Nova obo Ivy Lane Luxury Apartments (the “Landlord”)
Landlord Address: Ivy Lane Luxury Apartments, 2507 University Avenue, Santa Ivo City,
Midlands, 20231, AND

Tenant Name(s): Memphis Raynes (the “Tenant”).

The Landlord and Tenant are collectively referred to in this Agreement as the “Parties.”

HEREINAFTER, the Tenant agrees to lease the Premises from the Landlord under the
following terms and conditions:

2. PROPERTY. Landlord hereby leases the property located at

Ivy Lane, Unit 322, 2507 University Ave., Santa Ivo, ML 20231 to the Tenant (the
“Premises”).

3. LEASE TYPE. This lease shall be considered a: (check one)

☒ - Fixed Lease. The Tenant shall be allowed to occupy the Premises starting on
08/09/2022 and ending on 11/09/2022 (the “Lease Term”). At the end of the Lease Term,
the Tenant: (check one)
☒ - Can continue to lease the Premises on a month-to-month basis, under the same
terms as this Agreement.
☐ - Must vacate (leave) the Premises.

☐ - Month-to-Month Lease. The Tenant shall be permitted to occupy the Premises on a

month-to-month basis starting on [MM/DD/YYYY] and ending upon a notice of [#] days from
either party, in accordance with State law (the “Lease Term”).

4. RENT. The rent to be paid by the Tenant to the Landlord throughout the Lease Term is to be
made in monthly installments of $1500.00 (the “Rent”). The Rent shall be due on the 1st day
of each month (the “Due Date”). The Rent shall be paid via the following instructions: in-
person via check or via the Ivy Lane mobile app.
2
5. LATE FEE. If Rent is not paid by the Due Date: (check one)

☒ - The Tenant will be charged a fee of $$500. Rent is considered late if it has not been
paid within 7 day(s) after the Due Date.
☐ - There shall be NO Late Fee if the Rent is late.

6. PRORATION PERIOD. The Tenant: (check one)

☐ - Shall take possession of the Premises before the start of the Lease Term on
[MM/DD/YYYY] and agrees to pay a total of $[AMOUNT] for the proration period (the
“Proration Rent”). The Proration Rent shall be paid by the Tenant upon the execution of this
Agreement.
☒ - Shall NOT be taking possession of the Premises before the start of the Lease Term.

7. SECURITY DEPOSIT. As part of this Agreement: (check one)

☒ - The Landlord requires a payment of $1500 (the “Security Deposit”) for the faithful
performance of the Tenant under the terms and conditions of this Agreement. The Security
Deposit is required by the Tenant upon the execution of this Agreement. The Security
Deposit shall be returned to the Tenant within [#] days after the end of the Lease Term, less
any itemized deductions. This Security Deposit shall not be credited towards any Rent
unless the Landlord gives their written consent.
☐ - The Landlord does NOT require the Tenant to pay a Security Deposit as part of this
Agreement.

8. RETURNED CHECKS (NON-SUFFICIENT FUNDS). If the Tenant pays the Rent with a
check that bounces due to insufficient funds: (check one)

☒ - The Tenant will be required to pay a fee of $50 per incident.

☐ - The Tenant will NOT be required to pay a fee.

9. OCCUPANTS. The Premises is to be occupied strictly as a residential dwelling with the

following individual(s) in addition to the Tenant: (check one)

☐ - N/A (the “Occupant(s)”).

☒ - There are NO Occupant(s) in addition to the Tenant.

3
10. MOVE-IN INSPECTION. Before, at the time of, or shortly after move-in, the Landlord and
Tenant: (check one)

☐ - Agree to inspect the Premises and write any present damages or needed repairs on a
move-in checklist.
☒ - Shall NOT inspect the Premises or complete a move-in checklist.

11. FURNISHINGS. The Premises is: (check one)

☐ - Furnished (or will be furnished) with the following items:

[IF FURNISHED, LIST ALL ITEM(S) HERE].
☒ - NOT furnished.

12. UTILITIES. The Landlord shall pay for the following utilities and services to the Tenant, with
any absent being the responsibility of the Tenant:
Water and Garbage Collection.

13. PARKING. The Tenant (check one):

☐ - Is allotted [#] parking space(s):

☐ - Free of charge (included in the Rent).
☐ - At a cost of $[FEE] to be paid ☐ upon execution of this Agreement | ☐ monthly.
☒ - Is NOT provided parking.

14. PETS. The Tenant is: (check one)

☐ - Permitted to have [#] pet(s) on the Premises, ONLY consisting of (list pet types):
[LIST ALL PERMITTED PET TYPE(S)].
If permitted, the Landlord shall charge a refundable pet deposit of $[AMOUNT] to cover
potential damage to the Premises caused by the Tenant’s pet(s).
☒ - NOT permitted to have pets of any nature on the Premises.

15. SMOKING POLICY. Smoking on the Premises is: (check one)

☐ - Permitted ONLY in the following area(s): [PERMITTED AREA(S)].

☒ - Prohibited on the Premises and all Common Areas.

4
16. SALE OF PROPERTY. If the Premises is sold during the Lease Term, the Tenant is to be
notified of the contact details of the new Owner, and if there is a new Manager, their contact
details for repairs and maintenance also shall be forwarded to the Tenant. If the Premises is
conveyed to another party, the new owner: (check one)

☐ - Has the right to terminate this Agreement by providing [#] days’ notice to the Tenant.
☒ - Does NOT have the right to terminate this Agreement.

17. NOTICES. Any notice sent by the Landlord or the Tenant to each other shall use the
following addresses:

Landlord Mailing Address: 2507 University Ave. Unit 001, Santa Ivo, ML 20231
Tenant Mailing Address: 2507 University Ave. Unit 322, Santa Ivo, ML 20231

18. ACCESS. Upon the beginning of the proration period or the start of the Lease Term,
whichever is earlier, the Landlord agrees to give the Tenant access in the form of keys, fobs,
cards, or any type of keyless security entry as needed to enter the common areas and the
Premises. Duplicate copies of the access provided may only be authorized under the
consent of the Landlord and, if any replacements are needed, the Landlord may provide
them for a fee. At the end of this Agreement, all access provided to the Tenant shall be
returned to the Landlord or a fee will be charged to the Tenant or subtracted from the
Security Deposit.

19. RIGHT OF ENTRY. The Landlord shall have the right to enter the Premises during normal
working hours by providing at least twenty-four (24) hours’ notice to inspect and make
necessary repairs/alterations/improvements for any reasonable purpose. The Landlord may
exhibit the Premises to prospective purchasers, mortgagees, or lessees upon reasonable
notice.

20. ATTORNEYS' FEES. Should it become necessary for the Landlord to employ an attorney to
enforce any of the conditions or covenants hereof, including the collection of rentals or
gaining possession of the Premises, the Tenant agrees to pay all expenses so incurred,
including a reasonable attorneys' fee.

21. NOISE. The Tenant agrees not to cause or allow any noise or activity on the Premises
which might disturb the peace and quiet of another Tenant and/or neighbor. Said noise
and/or activity shall be a breach of this Agreement.

22. GUESTS. There shall be no other persons living on the Premises other than the Tenant and
any Occupant(s). Guests of the Tenant can stay on the Premises for periods not lasting for
more than forty-eight (48) hours, unless otherwise approved by the Landlord in writing.

5
23. EQUAL HOUSING. If the Tenant possesses any mental or physical impairment, the
Landlord shall provide reasonable modifications to the Premises unless the modifications
would be too difficult or expensive for the Landlord to provide. Any impairment(s) of the
Tenant are encouraged to be provided and presented to the Landlord in writing as to provide
the Landlord with ample time to seek the most appropriate route for providing said
modifications to the Premises.

24. WAIVER. No delay or failure of the Landlord to enforce any part of this Agreement shall be
deemed as a waiver thereof, nor shall any acceptance of any partial payment of Rent or any
other amount due be deemed a waiver of the Landlord’s right to the entire amount due.

25. MAINTENANCE, REPAIR, & ALTERATIONS. The Tenant will, at the Tenant’s sole
expense, keep and maintain the Premises in a good, clean, and sanitary condition and
repair during the Lease Term and any renewal thereof. The Tenant shall be responsible to
make all repairs to the Premises, fixtures, appliances, and equipment therein that may have
been damaged by the Tenant’s misuse, waste, or neglect, or that of the Tenant’s family,
agents, or visitors. The Tenant agrees that no painting or alterations will be performed on or
about the Premises without the prior written consent of the Landlord. The Tenant shall
promptly notify the Landlord of any damage, defect, or destruction of the Premises or in the
event of the failure of any of the appliances or equipment. The Landlord will use its best
efforts to repair or replace any such damaged or defective areas, appliances, or equipment.

26. PREMISES DEEMED UNINHABITABLE. If the Premises is deemed uninhabitable due to

damage beyond reasonable repair, the Tenant will be able to terminate this Agreement by
written notice to the Landlord. If said damage was due to the negligence of the Tenant, the
Tenant shall be liable to the Landlord for all repairs and for the loss of income due to
restoring the Premises back to a livable condition in addition to any other losses that can be
proved by the Landlord.

27. DEFAULT. If the Tenant fails to comply with any of the financial or material provisions of this
Agreement, or of any present rules and regulations or any that may be hereafter prescribed
by the Landlord, or materially fails to comply with any duties imposed on the Tenant by State
laws, within the time period after delivery of written notice by the Landlord specifying the
non-compliance and indicating the intention of the Landlord to terminate the Agreement by
reason thereof, the Landlord may terminate this Agreement. If the Tenant fails to pay the
Rent by the Due Date and the default continues for the time-period specified in the written
notice thereafter, the Landlord may exercise any and all rights and remedies available to the
Landlord at law or in equity and may immediately terminate this Agreement.
The Tenant will be in default if:
a. The Tenant does not pay the Rent or any other amounts as they are owed;
b. The Tenant, their guests, or the Occupant(s) violate this Agreement, or fire, safety,
health, and/or criminal laws, regardless of whether arrest or conviction occurs;
c. The Tenant abandons the Premises;
d. The Tenant gives incorrect or false information in the rental application;
6
 e. The Tenant, or any Occupant(s), are arrested, convicted, or given deferred
adjudication for a criminal offense involving actual or potential physical harm to a
person, or involving possession, manufacture, or delivery of a controlled substance,
marijuana, or drug paraphernalia under Midlands statute;
f. Any illegal drugs or paraphernalia are found in the Premises or on the person of the
Tenant, guests, or Occupant(s) while on the Premises; and/or
g. As otherwise allowed by law.

28. ABANDONMENT. Abandonment shall have occurred if, without notifying the Landlord, the
Tenant is absent from the Premises for the Midlands-mandated minimum time period, or
seven (7) days, whichever length of time is less. In the event of Abandonment, the Landlord
will have the right to immediately terminate the Agreement and remove the Tenant’s
personal possessions.

29. POSSESSION. The Tenant has examined the condition of the Premises, and by taking
possession acknowledges that they have accepted the Premises in good order and in its
current condition except as herein otherwise stated. Failure of the Landlord to deliver
possession of the Premises at the start of the Lease Term to the Tenant shall terminate this
Agreement at the option of the Tenant. Furthermore, under such failure to deliver
possession by the Landlord, and if the Tenant cancels this Agreement, the Security Deposit
(if any) shall be returned to the Tenant along with any other pre-paid rent and fees, including
any fee paid by the Tenant during the application process before the execution of this
Agreement.

30. ASSIGNMENT AND SUBLETTING. The Tenant shall not assign this Agreement or sublet
any portion of the Premises without prior written consent of the Landlord, which shall not be
unreasonably withheld.

31. JOINT AND SEVERAL. If the Tenant is comprised of more than one person, each person
shall be jointly and severally liable under this Agreement.

32. HAZARDOUS MATERIALS. The Tenant agrees to not possess any type of personal
property that could be considered a fire hazard such as a substance having flammable or
explosive characteristics on the Premises. Items that are prohibited to be brought into the
Premises other than for everyday cooking or the need of an appliance includes, but is not
limited to, gas (compressed), gasoline, fuel, propane, kerosene, motor oil, fireworks, or any
other related content in the form of a liquid, solid, or gas.

33. SEVERABILITY. If any provision of this Agreement or the application thereof shall, for any
reason and to any extent, be invalid or unenforceable, neither the remainder of this
Agreement nor the application of the provision to other persons, entities, or circumstances
shall be affected thereby, but instead shall be enforced to the maximum extent permitted by
law.

7
34. RETALIATION. The Landlord is prohibited from making any type of retaliatory acts against
the Tenant including, but not limited to, restricting access to the Premises, decreasing or
canceling services or utilities, failing to repair appliances or fixtures, or any other type of act
that could be considered unjustified.

35. INDEMNIFICATION. The Landlord shall not be liable for any damage or injury to the Tenant,
or any other person, or to any property, occurring on the Premises, or any part thereof, or in
common areas thereof, and the Tenant agrees to hold the Landlord harmless from any
claims or damages unless caused solely by the Landlord’s negligence. It is recommended
that renter’s insurance be purchased at the Tenant’s expense.

36. GOVERNING LAW. This Agreement shall be governed by the laws of the state of Midlands.

37. LEAD-BASED PAINT. The Premises (check one):

☐ - Was built prior to 1978. An attachment titled “Disclosure of Information on Lead-Based

Paint and/or Lead-Based Paint Hazards” has been affixed to the Agreement and must be
initialed and signed by the Parties.
☒ - Was NOT built prior to 1978.

38. ADDITIONAL PROVISIONS.

N/A.

39. ENTIRE AGREEMENT. This Agreement contains all the terms agreed to by the Parties and
may be modified or amended only by written agreement signed by the Landlord and Tenant.
This Agreement replaces all previous discussions, understandings, and oral agreements.
The Parties agree to the terms and conditions and shall be bound until the end of the Lease
Term.

IN WITNESS THEREOF, the Parties have caused this Agreement to be executed on the
day and year first above written.

Landlord’s Signature: __/s/Blaise Nova___________________ Date: 08/09/2022

Printed Name: Blaise Nova

---------------------------------------------------------------------

Tenant’s Signature: __/s/Memphis Raynes ________________ Date: 08/09/2022

Printed Name: Memphis Raynes

8
 Exhibit
13

302 FORM—RECORDED LINE

TRANSCRIPT

Date: December 23, 2022

Time: 3:31AM (Midlands Standard Time)
Duration: 5 min 32 sec

Note: Suspect utilized voice masking technology for the entire duration of the phone call.

*Start of conversation* 03:31:02

Suspect (S): Good evening, *NAME REDACTED* Congratulations on your winning bids for
“Portrait of Lady Georgia,” “Lord Felder,” and “Columbia River.” Are you available to talk?

Informant (I): Oh, hello! Yes, I'm here. I'm thrilled about winning the auction. Your reputation precedes
you, you know. Can I have your name?

S: What do you think?

I: Can’t blame a guy for trying.

S: Now, for the payment, I assume Bitcoin works for you?

I: Of course. I’m familiar with your work. I guess that’s why I received an invite for your little auction,
isn’t it?

S: Who exactly are you representing in this transaction? Everyone knows you’re a middleman.

I: Well, let's just say it’s a very influential and discerning individual who prefers to remain anonymous.
Friends of some of your prior clients out East.

S: I see. Well, I have my blockchain information ready to go.

I: Not so fast. My client is…uh…seeking certain assurances. You following me?

S: What kind of assurances?

I: Well, beyond the standard provenance and authentication stuff, they’re going to need proof of possession
and condition. Detailed, high-resolution photos. I wouldn’t normally do this, but I’m sure you can understand
given the…distressing nature of the reports surrounding the acquisition of the painting.
Not your cleanest job, was it?

S: (Silence)

I: Hello?

1
S: Is that really necessary?

I: That's precisely what my client insists upon. Plus, you’re not really in a position to negotiate here, are you?
What are you going to do, re-list it like they do on eBay?

S: (Silence)
S: Fine. I'll get those to you as soon as possible. Standby for an encrypted chatroom link. Tell your client to
have the funds ready.

I: Absolutely. My client is well-versed in handling transactions of this nature. We’re waiting on you.

*End of conversation* 03:36:34

2
Revised 8/27/23

Exhibit
14
Revised 8/27/23

Exhibit
15
Revised 8/27/23

Exhibit
16
 Exhibit
17

ESD312: CONFIDENTIAL
PROFILE
(for internal use only)

Subject:

Targeted Morisot Theft Scheme Perpetrated by Unknown “Morisot Mastermind”

Profile Summary: The unknown criminal behind the five heists involving high-value
paintings by the artist Morisot demonstrates an exceptional level of sophistication,
intelligence, access to significant resources, potentially possessing insider
information. This profile aims to provide a comprehensive understanding of the
subject's characteristics, motivations, and potential behavior patterns.

Characteristics:

High Degree of Sophistication: The mastermind criminal exhibits a high level

of sophistication in their operations. Their meticulous planning, attention to
detail, and ability to navigate complex security systems suggest a refined and
strategic mindset. This level of sophistication is consistent with individuals
who hold positions where strategic thinking and attention to detail are
paramount, like top-level business executives or high-ranking government
officials.

High Level of Intelligence: The subject's criminal activities reflect a high level
of intelligence and problem-solving acumen. Their ability to identify valuable
Morisot paintings, select suitable targets, and devise intricate plans to sell the
paintings within a 48-hour window points to someone capable of planning and
executing complex operations to the letter. These traits suggest the
mastermind potentially underwent extensive education and possesses
exceptional intellectual capabilities.

Access to Significant Resources: The mastermind has access to substantial

resources necessary to carry out their elaborate heists. The ability to assemble
a team of skilled professional criminals capable of bypassing high-tech
security systems, provide them with specialized equipment like signal
1
 jamming devices, and disappear without a trace within 48-hours is an
immense logistical feat. Coupled with the capability of the mastermind to
orchestrate thefts in 5 cities nationwide, the evidence suggests an
exceptionally wide-reaching criminal enterprise.

Potential Insider Information: The fact that the teams of thieves were able to
bypass security systems using forged security clearance documents suggests
the presence of potential insider information in the thefts. The mastermind
might potentially have connections within art world networks, such as art
dealers, collectors, or museum staff, who provide them with privileged
information on the targeted Morisot paintings. The criminals’ knowledge of
dark web ecosystems and secure cryptocurrency transactions also suggests
connections within the world of organized and cybercrime.

Behavioral Patterns:

Calculated Risks and Precision: The mastermind demonstrates a methodical

and calculated approach to their criminal activities. They carefully assess
risks, minimizing the chances of detection and maximizing the probability of
success. They display extensive knowledge of security systems of various
types, and the ability to outmaneuver or subdue security personnel.

Discretion and Secrecy: The subject maintains a highly discreet profile,

operating in secrecy to minimize the chances of detection. Review of security
footage from the 5 thefts suggests that the mastermind might have used
different crew members for each theft. Taking into consideration the
mastermind’s likely analytical and strategic acumen, it seems unlikely that
they would themselves be present at the scenes of the theft. The ability to
maintain and disappear a network of potentially dozens of criminals over a
course of 5 years is evidence of an enterprise held together by discretion and
secrecy. To communicate with his team on the ground, the mastermind
potentially employs sophisticated communication methods and
counterintelligence measures to ensure their identity remains concealed.

Selective Targets: The mastermind's focus on high-value Morisot paintings

indicates a personal interest beyond financial gain. This suggests a potential
appreciation for art or a hidden motive related to Morisot's work.
Investigative efforts should explore any personal connections, such as
personal collections, business relationships, or social affiliations, that may
link the subject to the artist or the art world. The mastermind may have
developed a deep admiration for Morisot's artwork and found personal
inspiration within her paintings. They could be captivated by her depictions
of femininity, the subtle play of light, and the delicate brushwork. This
personal connection might have motivated the criminal to target Morisot's
paintings specifically, driven by an intense desire to possess and appreciate
her works. The mastermind may be an avid art collector or an enthusiastic
2
follower of Morisot's work. They might possess an intricate knowledge of the
art market and recognize the significant value of Morisot's paintings. The
criminal's interest could stem from a desire to build a personal collection or
from the intention to sell the stolen paintings to other collectors or buyers
who share their appreciation for Morisot's art. Alternatively, the mastermind
could have a hidden agenda or personal vendetta related to Morisot or her
artwork. There might be a concealed history or past connection between the
criminal and the artist, such as a personal connection or a perceived injustice
involving Morisot's work or legacy. This hidden agenda might drive the
criminal's actions, seeking to gain control over her paintings as a form of
revenge or to manipulate the art market.

Evolving Tactics: Given the subject's high level of intelligence and

adaptability, it is likely they will evolve their tactics to outwit law
enforcement. This includes adjusting their modus operandi, targeting
different regions or countries, or diversifying their criminal activities to
different dark web marketplaces as more get shut down. In 2019, after the
mastermind’s preferred marketplace over the first two thefts, Dream Market,
was seized by the FBI, the Morisot sales moved to Apollon. The third stolen
Morisot was sold on Apollon in 2020. When Apollon closed that same year,
auctions moved to Hydra, a Russian marketplace, where the fourth and fifth
auctions took place in 2021. This adaptability suggests the mastermind might
further refine their tactics, adopting higher tier security measures and trace
proof encryption standards.

3
 So It Was Written March 15 2022

Exhibit
The latest news, hotspots, and social trends for Santa Ivo City, Midlands
18

OTHER BREAKING
MIDLANDS NEWS:
__

RISING PHOENIX?
Could recent Midlands
Center ash pile Chuggie’s
be making a triumphant
return to downtown?
__

SLING-A-BLADE FUN
New City hotspot Al’s Axe
World Emporium opens
this weekend to mixed
reviews and minor injuries!
__

SWIPE LEFT
Former king of dating
apps, Tender, will shut
down for good after a
billion-dollar verdict
against Tender for privacy
violations was announced

A harbinger of doom?
By Abby Chase

MSIG’s newest security installation for Miller Tower could spell danger for Santa
Ivo City residents.

B.F. De la Porta’s security technologies firm, MSIG, recently purchased the naming
rights for Miller Tower’s renovated event hall space. Apparently, De la Porta wasn’t
satisfied with just having MSIG’s name on wall because today De la Porta announced
that MSIG has just finished installing a state-of-the-art MSIG Mach 10 Titanium
(“M10T”) vault on the 40th floor of Miller Tower.

While De la Porta is no stranger to showing off MSIG’s high tech toys (remember that
wild treasure hunt for Midlands’ original draft Constitution that went viral on Tikchat?),
the question remains “why?” Why would Miller Tower need such a high-level security
item like the M10T vault? Everyone knows that City’s crime rates are extremely low,
almost nonexistent, when compared to our Midlands sister city Midlands Center. What
even is the M10T vault going to protect? Who is going to use the vault?
Anonymous sources within the Miller Tower security office have openly discussed
concerns of Tower security’s ability to adequately protect whatever it is that De la Porta
believes justifies installing the vault. While millions were spent to build the high-rise
vault, the security guard union members wondered aloud why that money couldn’t
have been used for adequate staffing and security equipment.

SIWW was able to gain exclusive access to the blueprints for the M10T vault, though
we obviously cannot post them here without facing serious legal action from MSIG.
Whatever De la Porta expects people to secure in the M10T vault will be well-
protected—even if the security guards on the outside may be scarce and undertrained.
The M10T vault is a state-of-the-art design complete with advanced identification
features to limit access to the vault. For example, the identification system has a
double verification system that requires retinal and biometric scans of anyone that
tries to enter the vault.

Hopefully, De la Porta’s shiny new toy doesn’t attract unwanted attention from the
criminal minds that keep dominating the headlines in Polk and Breckinridge counties.
We won’t have to wait for too long to find out. During the news conference to unveil
the M10T vault at Miller Tower, De la Porta shocked Santa Ivo City’s 1%’ers by
announcing De la Porta’s annual charity gala would move from its traditional home at
Harper Country Club in Santa Ivo Heights to downtown Santa Ivo in the MSIG Event
Hall at Miller Tower. De la Porta promised “this year’s charity gala will bring more
money and more attention to Santa Ivo than ever before! I’m not above robbing every
one of our gala’s guests myself if it means more money for the Sohi Children’s
Hospital!”

De la Porta promised that invitations for the charity gala would be sent out soon and
boasted that “the good people of Santa Ivo will be shocked at the items that I have
managed to get donated for this year’s silent auction.” All eyes will be on Miller Tower
and its new M10T vault on Halloween night.
 “ SEPTEMBER 2022

Santa Ivo Tech Talk Exhibit

Alumni Newsletter for Santa Ivo City’s Nationally Ranked 19
Business and Trade School

IN THIS ISSUE

“Managing Executive Egos”

Our review of Skye Martin’s
newest bestseller

Never too old for attention

Kirby Doolittle’s “good vibes”
home delivery service for eldery
citizens begins in Santa Ivo next
month

Peaking at the right time

Extreme Tikchat star Prof. Billi
Johnson discusses new study
abroad program in Nepal

1 minute sales Fresh off the set of another successful season of “Investment
Mavens,” Santa Ivo City’s own self-made mega-millionaire,
pitches: Berkley F. De la Porta, sat down with S.I.T. Talk to discuss the
best way to win over capital investors. Luckily, De la Porta
De la Porta’s gave us longer than the startups pitches get on “Investment
Mavens.”
winning tips on
As the President & CEO of MSIG, De la Porta travels the globe
finding capital making deals with heads of state and security firms for MSIG’s

investors latest military-grade surveillance technology. No stranger to

the art of negotiation, De la Porta credits, “my ability to think
By Francis Leo, II. on my feet and quick wit” in getting MSIG off the ground.
S.I.T. Class of ‘20
“You need to be thinking four steps ahead. It’s chess, not
checkers out there,” De la Porta quipped. “I always make
sure I know everything, everything, about everyone and
everything involved in whatever I’m doing. No detail is
unimportant. You never know when an obstacle will pop up.
So you have to carry an axe with you at all times.” Note, De la
Porta later clarified that the “axe” is your wit and not to be
taken literally. “Unless of course MSIG makes axes, then you
should all carry one around,” De la Porta joked.

De la Porta offered the following advice for all of S.I.T.’s

entrepreneurial students: “Most of the time you have, maybe,
a few minutes to get someone interested in your product. Find
a way to be clear and consise. Get in and out in. Gone! In
about 60 sec. That’s my best advice.”

De la Porta’s parting advice was to make sure you take the

time to find other activities and interests outside of your
professional life. “It’s silly but I love online auctions. The thrill of
going up against unknown bidders is fun to me. But most of
all, I love paintings by Berthe Morisot and hard to find
historical documents. Find out what moves you and never
stop doing it. I will stop at nothing until all of Morisot’s paintings
are hanging on my wall!”

De la Porta’s annual charity gala will be held at Miller Tower

this Halloween. It is a change of venue for De la Porta’s
charity gala which had been hosted at Harper’s Country Club
for the last few years. De la Porta promised that the event and
silent auction items would be talked about for years to come!

If you’re unable to attend the charity gala, but are interested

in donating to Sohi Children’s Hospital, the MSIG web site has
a donation page ready to take your payment information.
Every dollar raised helps a child heal!
 Exhibit
20

PUBLIC RECORDS REQUEST

Search Results:
JURISDICTION: <<Midlands, USA>>
NAME: CAMERON, POE
DOB: 3/24/2003
ADDRESS: 1734 Halcon Rojo Drive, Santa Ivo City, Midlands
Records Found: 01

Search Results:
JURISDICTION: <<ALL OTHER DOMESTIC U.S. STATES>>
NAME: CAMERON, POE
DOB: 3/24/2003
ADDRESS: 1734 Halcon Rojo Drive, Santa Ivo City, Midlands
Records Found: 00
Record Name: CAMERON, POE
Jurisdiction: <<Midlands, USA>>
Source: Charlotte County Circuit Court
Type: Criminal
DOB: 3/24/2003
Address: 1734 Halcon Rojo Drive, Santa Ivo City, Midlands
Case #: 21CRB-10-050

Description: Petty Theft Case Type: Misd-1

Court: Charl Co. Disposition: G Plea
Filing Date: 6/17/21 Amended Disposition: N/A
Disposition Date: 7/28/21 Sentencing: 50 hours CS;
$250 fine +
costs; stay away

Summary of case: Defendant was caught shoplifting from art

museum gift shop. Defendant was stopped by security after last
point of sale. Defendant told LEO that Defendant’s sibling
(known felon RAYNES, MEMPHIS DOB 6/19/99) made Defendant steal
from the museum.

Defendant was sentenced to complete 50 hours of community

service. $250 fine imposed. Costs of prosecution charged to
defendant. Defendant ordered to stay away from victim business
location. No appeal was filed.
 CHARLOTTE COUNTY CLERK OF COURTS
CERTIFICATE
I, Douglass Allrick, Director of the Criminal Records Division, of the Charlotte County Clerk of
Courts, do hereby certify that I am the custodian of the records of Criminal Records Division and
that the Criminal Records Division is responsible for maintaining records of criminal convictions
in Charlotte County, Midlands. I further certify that the attached
Conviction of CAMERON, POE Case #: 21CRB-10-050

is a true and accurate copy.

IN TESTIMONY WHEREOF, I have subscribed my name and affixed the seal of the State of
Midlands, this August 15, 2023.

D. Allrick
 Exhibit
21

PUBLIC RECORDS REQUEST

Search Results:
JURISDICTION: <<Midlands, USA>>
NAME: RAYNES, MEMPHIS
DOB: 6/19/1999
ADDRESS: 1734 Halcon Rojo Drive, Santa Ivo City, Midlands
Records Found: 02

Search Results:
JURISDICTION: <<ALL OTHER DOMESTIC U.S. STATES>>
NAME: RAYNES, MEMPHIS
DOB: 6/19/1999
ADDRESS: 1734 Halcon Rojo Drive, Santa Ivo City, Midlands
Records Found: 00
Record Name: RAYNES, MEMPHIS
Jurisdiction: <<Midlands, USA>>
Source: Charlotte County Circuit Court
Type: Criminal
DOB: 6/19/1999
Address: 1734 Halcon Rojo Drive, Santa Ivo City, Midlands
Case #: 17CRB-06-0613

Description: B&E Case Type: Felony-5

Court: Charl Co. Disposition: G Plea
Filing Date: 6/19/2017 Amended Disposition: N/A
Disposition Date: 8/25/2017 Sentencing: 5yr Basic Sup;
$2000 fine +
costs; stay away

Summary of case: Defendant gained entry to a high-end antique

business through the use of force while the business was closed.
Security alarm system notified LEO of trespass. Defendant was
arrested attempting to flee scene.

Defendant was sentenced to 5 years basic community control

supervision. $2000 fine imposed. Costs of prosecution charged to
defendant. Defendant ordered to stay away from victim business
location. No appeal was filed.

Case #: 19CRB-03-0872

Description: Agg Safe Case Type: Felony-4

Cracking
Court: Charl Co. Disposition: G Plea
Filing Date: 3/15/2019 Amended Disposition: Nolle Burg (F2)
Disposition Date: 11/18/2019 Sentencing: 18m MDRC sent;
costs; stay away

Summary of case: Defendant gained entry to a jewelry business

through the use of force while the business was closed.
Defendant used physical harm against security guard to gain
entry. Defendant broke into the safe and fled with cash and
jewels. Defendant was arrested by LEO after an extended pursuit.

Defendant was ordered to serve 18 months in the Midlands Dept of

Correction. Credit 28 days. Costs of prosecution charged to
defendant. Defendant ordered to stay away from victim business.
No appeal was filed. Defendant was released at 80% time
completed.
 CHARLOTTE COUNTY CLERK OF COURTS
CERTIFICATE
I, Douglass Allrick, Director of the Criminal Records Division, of the Charlotte County Clerk of
Courts, do hereby certify that I am the custodian of the records of Criminal Records Division and
that the Criminal Records Division is responsible for maintaining records of criminal convictions
in Charlotte County, Midlands. I further certify that the attached
Convictions of RAYNES, MEMPHIS Case #: 17CRB-06-0613 & 19CRB-03-0872

is a true and accurate copy.

IN TESTIMONY WHEREOF, I have subscribed my name and affixed the seal of the State of
Midlands, this August 15, 2023.

D. Allrick
 Revised 12/12/23

Exhibit
22

Interview of Detective Kit Bahmani Transcript

1 Rao: Good morning. It’s August 15, 2023. My name is Maloney Rao and I am an attorney
2 from Spears, Debnath & Nickson LLC representing Berkley F. De la Porta in this
3 case. We are joined by Ali Blaine-Soucar from the Public Defender’s office, who is
4 representing Poe Cameron. We are here to ask you some questions regarding the
5 Miller Tower heist and your investigation of it. This is being recorded via iPhone
6 voice memo recorder. We will be having a transcription of the recording made for
7 both sides.
8 Almonte: Thank you, we appreciate that. This is Anant Almonte from the Charlotte County
9 DA’s office. I will be present throughout the interview.
10 Rao: Could you please state your name.
11 Bahmani: Kit Bahmani
12 Rao: What do you do for a living?
13 Bahmani: I’m a detective with the Santa Ivo Police Department.
14 Rao: How long had you been a detective?
15 Bahmani: Since April 2021.
16 Rao: Before the Miller Tower heist, what types of cases had you been a detective on?
17 Bahmani: I have worked a number of cases. I would say close to 85 before the heist as a
18 detective. Before that, I assisted other detectives on a number of other cases when I
19 was working the beat.
20 Rao: What is your work history before you were a detective?
21 Bahmani: Before I was on the force? Well, I was actually a dancer with the Santa Ivo City
22 Ballet for about three--
23 Rao: I don’t care about what you did before you joined the police force. I’m just asking
24 what is your history as a police officer and/or detective.
25 Bahmani: I have an interesting back story. It’s a shame you don’t want to get into it now. I’ll
26 save the rest of it for the trial.

1
 Revised 12/12/23

27 Rao: I look forward to hearing it then. What’s your work history on the force?
28 Bahmani: Well, I started out as a police officer in SIPD in 2010. I worked on patrol for 4 years
29 before being promoted to Sergeant in 2014. As a Sergeant I did field operation
30 supervision. That I did for about three years. Then starting in February of 2018, I
31 began working in the advance tactical training squadron, which included duties such
32 as SWAT. In late 2020, I decided to try for detective. I passed the exam and
33 completed all of the qualifications, including the interview and other evaluations, in
34 February of 2021. I completed all the necessary training and then was a detective as
35 of April 29, 2021.
36 Rao: What sorts of training did you have before you began training to be a detective?
37 Bahmani: I did the standard training at the Santa Ivo Police Academy. It was a 6-month course
38 that covered training in a number of areas including search and seizure, evidence
39 collection, crimes scenes and forensics, de-escalation techniques, patrol techniques,
40 traffic crimes, ethics, firearms training, report writing. That’s not a complete list, but
41 that’s a general list of the types of things we covered.
42 Rao: Do you have any other training from your job?
43 Bahmani: Yes. When I moved to the advance tactical training squadron, I had to do another
44 round of training on advanced tactical techniques. That was approximately three
45 months. Before that though, I also obtained a degree in Criminology from Santa Ivo
46 University. I then got a master’s degree in Forensic Science also from SIU.
47 Rao: What training did you have to become a detective?
48 Bahmani: The detective training course was just under three months long. This included
49 training in witness and suspect interviewing, evidence processing and crime scene
50 preservation, investigative operations—for things like surveillance, operational
51 planning, report writing, processing information request forms. And then we also did
52 some specific types of investigative training, like for identifying clandestine drug
53 labs, driving accidents, cyber crimes, fraud or financial crimes, etc.
54 Rao: You said that you had done about 85 cases as a detective. What types of cases were
55 you investigating?
56 Bahmani: Well, there isn’t a lot of major crimes in Santa Ivo. So – uh – uh most of the crimes
57 that I investigated had to do with property crimes or domestic violence. There were

2
 Revised 12/12/23

58 some drug tracking cases that I worked on that lead to the drug rings centering
59 outside our jurisdiction. For a few months I worked over in Polk County—there are
60 some real great prosecutors over there. If you ever get a chance to work with them—
61 they’re great—
62 Rao: What exactly did you do in Polk county?
63 Bahmani: There I worked on about 10 larger cases. There were three murders, a couple home
64 robberies and then a handful of assault and battery cases. Polk county does have it
65 rough in terms of the crime rate. We just don’t have that here in Charlotte.
66 Rao: So, the Miller Tower heist, that was a pretty big case, wasn’t it?
67 Bahmani: I would certainly characterize that as a big case. It had the most forensics and the
68 most evidence that I have ever had to deal with in a case before.
69 Rao: It had a lot of officers involved in it too, didn’t it?
70 Bahmani: Yeah. It was a large operation. I think there were about 20 officers at the scene itself.
71 Then about 3-5 crime scene technicians plus the forensic investigator overseeing the
72 forensic evidence.
73 Rao: It’s safe to say that you have never handled an investigation that large before?
74 Bahmani: That’s correct. Those types of large crimes are much more common in Polk County
75 than over here.
76 Rao: In fact, this is the first case that you were in charge of where you had to delegate
77 responsibilities to patrol officers?
78 Bahmani: Yes. This is the first investigation of it’s kind that I have done. I have great officers
79 who work under my command though, so I have little to no worries about the work
80 they did.
81 Rao: But you would agree with me that delegating investigative work to patrol officer’s is
82 not ideal, right?
83 Bahmani: I’m not sure what you mean by that. All patrol officers are trained on evidence
84 collection and scene handling.
85 Rao: But none of the patrol officers you were commanding were trained as detectives?
86 Bahmani: That is correct.
87 Rao: None of them were trained as detectives?
88 Bahmani: Correct.

3
 Revised 12/12/23

89 Rao: None of them were trained in witness interviewing?

90 Bahmani: No. The basic police academy that all patrol officers go through does not train
91 officers in in-depth witness interviewing.
92 Rao: You yourself did not have the ability to talk to every single person at the scene that
93 night?
94 Bahmani: No. I delegated some of the work to the patrol officers, like Officer Rodrigo and
95 Officer Schaefer.
96 Rao: Despite the fact that you were only a detective for about 18 months before you began
97 investigating this case, you were the one called out to investigate the Miller Tower
98 heist?
99 Bahmani: Yes.
100 Rao: Why was that?
101 Bahmani: To be honest, it was Halloween. Policing on Halloween gets pretty crazy. I just
102 happened to be the only detective at the station when everything got called in.
103 Rao: So there are detectives more senior than you who could have handled this case?
104 Bahmani: There are.
105 Rao: And yet even after learning about the size and scope of this investigation, you didn’t
106 call up your department and say “hey this is a huge case, someone with more
107 experience than me should be handling it”, did you?
108 Bahmani: No. I didn’t.
109 Rao: After the night of, you didn’t go talk to any of the more experienced detectives and
110 ask them for help in dealing with a case this size?
111 Bahmani: No.
112 Rao: Now this investigation lasted for several months right?
113 Bahmani: Yes. I don’t remember the exact months, you will have to look at my report for that.
114 Rao: Throughout that entire time, you alone were the only detective assigned to this case?
115 Bahmani: The only one assigned from my department, yes. But I was also working with Agent
116 Shar Burke from the FBI.
117 Rao: You know that Agent Burke has had it out for my client for many years don’t you?

4
 Revised 12/12/23

118 Bahmani: No. I’m not aware of that. From what I have seen Agent Burke is a thorough and
119 thoughtful agent. I have seen nothing in the FBI work or Agent Burke’s work that
120 suggests that Agent Burke “has it out” for De la Porta.
121 Rao: Sure Detective. We’ll just take your word for it.
122 Almonte: Are you going to ask another question?
123 Rao: Now, the real reason we are here today is to talk about the cyber-attack on the SIPD
124 evidence servers. You submitted an addendum to your report alerting us to the loss
125 of data, right?
126 Bahmani: Yes. Everything I have to say about that is in my report.
127 Rao: Yes. Your report is somewhat light on the details, so I want to ask you some
128 questions about it now. In that report, you mention several times about notes from
129 witness interviews that had been stored online. Do you still have copies of those
130 notes?
131 Bahmani: No. Those were also lost in the cyber-attack. Anything that was stored in our
132 evidence server and within the portal was lost.
133 Rao: So how do we have any copies of your reports or the notes from your viewing of the
134 security footage?
135 Bahmani: Those were all sent to Charlotte County DA’s office many months before the attack
136 happened. Anything that we sent to the DA’s office or that was physically stored in
137 our storage lockers were unaffected by the cyber-attack.
138 Rao: So you have no notes from your interviews with the witnesses from this case?
139 Bahmani: I wouldn’t agree with that.
140 Rao: Why not?
141 Bahmani: There are some notations within my report of the information provided during many
142 of the interviews. I also have transcripts of the interviews with Poe Cameron. In
143 addition, I have read through the witness statements of Orlov, Cosmos, Nova, and
144 Sands. All of those statements accurately describe what they told me during their
145 various interviews.
146 Rao: And how do you know those witness statements match your notes?
147 Bahmani: I didn’t say they match my notes, just that when I read those statements I recalled the
148 witnesses telling me those same things.

5
 Revised 12/12/23

149 Rao: Your memory is just that good?

150 Bahmani: It was a pretty memorable event with pretty memorable people that I was talking to.
151 So, yes.
152 Rao: I don’t have any other questions right now.
153 Almonte: I have a couple. Detective, did the loss of notes from the cyber-attack impact the
154 accuracy of your report?
155 Bahmani: No, it did not.
156 Almonte: Why not?
157 Bahmani: Because I wrote the report and came to my conclusions about the investigation while
158 I had the notes with me. The notes from the conversations were not absolutely
159 critical to my investigation. If there was something important to the investigation—
160 meaning that it would help me find the true perpetrators—then I noted it in my
161 report. I only lost access to the notes after the investigation was complete.
162 Almonte: You were asked a lot about your experience level. Did you ever feel like you needed
163 to ask for assistance on this case from other more experienced detectives?
164 Bahmani: No.
165 Almonte: If something had come up where you needed assistance would you have asked for it?
166 Bahmani: Of course. While this was a big case, it wasn’t so big that it was unmanageable.
167 Aside from the scene of the crime where there were about 200 people, there weren’t
168 any other parts of the case that were overly complex. The forensic folks handled
169 most of that stuff, so there was no time where I ever felt in over my head.
170 Almonte: Alright, I don’t have any other questions. Ali?
171 Blaine-Soucar: For once, I don’t have much to say. I want to save my questions for cross
172 examination.
173 Bahmani: That sounds ominous.
174 Blaine-Soucar: It should.
175 Rao: And with that, we will wrap this up. The interview is now concluded. I am turning
176 off the recording device now.
177 **End of Recording**
178
179

6
 Exhibit
23

[TEAM SUPPLIED MASK]

Exhibit
24
 Exhibit
25

[TEAM SUPPLIED PHOTO OF POE CAMERON]

 Exhibit
26

[TEAM SUPPLIED PHOTO OF MEMPHIS

RAYNES]
 Revised 12/12/23

Heisman Memorial Teaching Hospital

1432 N. Alcatraz Way
Santa Ivo, ML Exhibit
27
Sands, Emory
Emergency Room Admission: 10/31/22 11:17pm AIending Physician: Vincent Larkyn, MD

Primary Diagnosis: Concussion/Hemorrhage,

internal bleeding, broken ribs

Intake Notes

PaQent presents with mulQple injuries. Per reporQng law enforcement, paQent suffered acute trauma
from assault by mulQple assailants. PaQent was unconscious upon arrival and could not complete
standard admission quesQons. PaQent appears to have been struck in the head, torso, and arms.

Vitals
BP 145/97
Pulse 72
Temp 36.8°C (98.2°F)

Physical Examina5on
ConsQtuQonal:
PaQent appears pale, unconscious, and with mulQple abrasions and laceraQons. Clothes are
disheveled and spoIed with blood.
Head and Face:
Head: PaQent’s hair has some blood caking but no clear trauma to the scalp area. PaQent has
three disQnct areas of abrasion on their face. The first is the leb temple, which shows mulQple
laceraQons, the longest of which is approximately 11 cm and reflects a gouging, ragged cut,
consistent with being struck by a dull, hardened object. The second is paQent’s jaw, which has
apparent ecchymosis. Finally, paQent’s face around their nose exhibits both apparent
ecchymosis and hematoma.
Right Ear: Tympanic membrane and ear canal are normal. External ear has several light
abrasions, consistent with fricQon injury.
Leb Ear: Tympanic membrane and ear canal are normal. External ear appears to have light
edema at the base.
Nose: Nose exhibits extensive hematoma, but septum appears intact and non-deviated.
Mouth: Mucous membranes are moist. Apparent laceraQons on inside of lower lip. Some blood
in saliva.
Throat: Normal and atraumaQc.
Eyes:
ConjuncQva/sclera: Sclera appears mildly inflamed, with reddening and clear vasodilaQon.
ConjuncQva normal.
Pupils: Pupils are of uneven size. Leb pupil appears more dilated and slower to respond to light.
Right pupil reacts to light normally.
 Revised 12/12/23

Cardiovascular:
Rate and rhythm: Normal rate and regular rhythm.
Heart sounds: Normal heart sounds.
Pulmonary:
Effort: Pulmonary effort is extremely labored and breathing is shortened.
Breath sounds: Slight rhonchi, indicaQons that paQent may have inhaled either blood or vomit
from their mouth.
Chest and back:
General: Chest sounds normal but paQent is significantly restricted in diaphragm movements.
External examinaQon reveals mild contusions in three spots along collar bone and severe
hematoma along the paQent’s leb side at the T10 and T11 ribs.
PalpaQons: PalpaQons of T10 and T11 ribs on leb side indicates some slight movement of the T10
rib and a full dislocaQon of the T11 rib. The T11 rib appears parQally sunken into the abdominal
cavity and dislocated from the T11 vertebrae.
Abdomen:
General: Abdomen exhibits ecchymosis throughout as well as apparent edema.
PalpaQons: Abdomen is firm and difficult to palpate.
Upper limbs:
General: PaQent exhibits mild contusions to the right upper arm, near the shoulder, and leb
lower arm, along the ulna.
Musculoskeletal: No signs of fracture of any bones in either arm. No swelling or signs of
muscular trauma.
Lower limbs:
General: PaQent exhibits mild contusions to the right upper thigh and gluteus.
Musculoskeletal: No signs of fracture of any bones in either leg.
Neurological:
General: PaQent is unconscious. AIempts to revive were largely unsuccessful and halted due to
concerns of intracerebral hemorrhage. Midazolam was administered accordingly to sedate
paQent. Uneven dilaQon of pupils and abnormal response indicates potenQal cerebral trauma.

PotenQal IniQal Diagnoses and AcQons:

PaQent appears to have some degree of intracerebral hemorrhage, fractured rib, and potenQal
internal hemorrhage of abdominal cavity.

Further sedaQon was ordered out of concern for cerebral damage.

PaQent was sent to imaging for X-Rays of abdominal cavity and MRI of cranium.

Radiology Report

Radiologist: Shen Garvee

Time and Date: 10/31/22 11:32pm
Imaging Conducted:
Ventral and dorsal X-ray images of the T6 through T12 region of the rib cage and vertebrae were
conducted. Further ventral images were taken of paQent’s abdomen.

MRI was conducted on paQent’s cranium.

Radiologist Impressions:
 Revised 12/12/23

X-Ray: PaQent has clear fracture and dislocaQon of T11 rib on leb side. T6-T9 ribs appear normal.
T10 rib appear to be slightly dislocated from sternum with associated carQlage rupture. T12 rib
appears normal. Cloudiness indicated T11 rib may have lacerated internal organs.
MRI: Significant bleeding is present on paQent’s leb temporal and occipital lobes. Leb side of
brain appears intact.

Progress Notes

AIending Physician: V. Larkyn

Time: 11:41pm

AIending physician has reviewed Radiology Report. ConQnued sedaQon is ordered. PaQent is referred
to surgical for craniectomy determinaQon and for abdominal surgery to address internal bleeding.

Neurosurgery Notes

Surgeon: Milosh Babbavoich

Time: 11:46pm

PaQent assessed for potenQal craniectomy. Review of MRI and examinaQon of paQent’s eyes and
autonomic responses indicated some improvement in funcQon. Craniectomy not advised at this Qme.
SedaQon ordered to conQnue with addiQonal propofol IV to begin medically induced coma.

Abdominothoracic Surgery Notes

Surgeon: Herbert East

Time: 12:22am

PaQent was admiIed for thoracic surgery. Three transverse incisions were made for the purposes of an
exploratory laparotomy. Extensive laceraQons were found on the paQent’s stomach and colon, though
no penetraQon or rupture was present. PaQent’s spleen was fully ruptured. T11 rib on let side was
dislocated. PaQent also had several deep laceraQons to their diaphragm. EmbolizaQon of the diaphragm
was conducted, as well as a complete splenectomy. Incisions were closed and paQent was monitored for
further bleeding. External adjustment was effecQve in relocaQon T11 rib. Follow up image revealed
subsiding of internal hemorrhaging.

Progress Notes

AIending Physician: V. Larkyn

Time: 2:11am

Vitals
BP 126/81
Pulse 65
Temp 36.8°C (98.2°F)

Follow-up diagnosis: PaQent suffered from severe intracranial hemorrhaging, as well as

abdominothoracic hemorrhaging and splenorrhexis. All abdominal bleeding appears resolved following
 Revised 12/12/23

complete splenectomy and embolizaQon. Intracranial hemorrhaging appears to have significantly

subsided, though cerebral damage is difficult to assess at this point.

Treatment AcQon: PaQent is in intensive care following abdominothoracic surgery. PaQent appears
stable, however, conQnued propofol IV is ordered, along with broad spectrum anQbioQcs and ketorolac.
Surgical venQlaQon is also ordered conQnued as injuries to paQent’s diaphragm appear to have
compromised normal breathing.

Follow-Up Notes

Date: 11/12/22 2:21pm

AIending Physician: Larry Ward, MD

Vitals
BP 122/84
Pulse 71
Temp 37.1°C (98.7°F)

PaQent was iniQally brought into ER with mulQple injuries. PaQent has been in and out of consciousness
the last eight days. PaQent regained somewhat full consciousness late yesterday abernoon and has
become more and more responsive. This morning, basic neurological assessments were conducted.

Level of Consciousness (Glasgow Coma Scale):

Eye Response: 4/4
Verbal Response: 5/6. PaQent conQnued to exhibit significant, though intermiIent, confusion.
Motor Response: 6/6
Overall assessment: 14/15
Spine:
Spine and spinal cord fully intact.
Mobility:
Full mobility assessment is difficult due to conQnued use of venQlator. PaQent is able to parQally
sit up on own, move all extremiQes, and responds to commands for moQon appropriately.
Physical percepQon:
PaQent’s percepQon of touch, pain, and extremity locaQon are all normal.
Reflexes:
PaQent’s eyes dilate appropriately and paQent exhibits full response of muscular reflexes.
CogniQon:
Full cogniQve assessment not conducted due to paQent’s conQnued use of venQlator but paQent
exhibits some confusion about surroundings and request at Qmes. Overall cogniQon seems to be
improving, and paQent is able to recognize people, respond with non-verbal communicaQon, and
understands some, though not all, informaQon relayed to them.

Prognosis: Full recovery of cogniQve ability is anQcipated.

Exhibit
28
 Revised 8/27/23

Miller Tower Security Footage Notes Exhibit

Det. Kit Bahmani (Notes made and footage reviewed on 11/2/22) 29

6pm to 9:09pm - Nothing of note occurs in footage from 40th floor. Security follows the
procedures as discussed in the security protocol for the evening. All security members seen on
tape matched the pictures in their personnel files. Vault door was securely closed aOer protocol
complete.

9:10pm –
Roof Cameras 2, 4, 5, 6, 7: Helicopter lands on Miller Tower roof helipad. Two people exit the
helicopter and approach the door. One appears to have an axe, the other a crow bar. Helicopter
pilot remains in the helicopter.
Roof Camera 3: One person approaches stairway door to roof. This suspect is wearing a mask
similar to the one found in the alley of Miller Tower (“alley mask suspect”). They a[empt to use
a key card at the electronic access panel. They try to open the door, but it does not open. The
person appears to be typing something into phone.

9:11pm –
Roof Camera 2: The one with the axe outside on the roof, checks phone. Gestures to other
person. They both begin working on the door to dismantle it with the axe and the crow bar.
Roof Camera 3: Alley mask suspect steps back out of camera range. The footage shows the door
being dismantled from the inside.

9:12pm –
Roof Camera 2: Hole in door created, two outside force their way inside. Leave camera range.
Roof Camera 3: Hole in door created, two outside force their way inside. Looks like one of the
two gets leO shoulder stuck a bit on the door. Appears to have cut themselves on hole in door.
Leave Camera range.
Secured Area Cameras 2, 3: All three exit roof stairs and move toward security office. Appear to
have an item with them that looks the approximate size for cell jammer later found in security
room (brand name: MSIG).

9:13pm –
Secured Area Camera 2: All three reach security office and enter. (No camera in the security
office, so no details of what occurred once entered office.)

9:14pm –
Secured Area Camera 2: All three suspects exit security office, two of them dragging guard
Emory Sands (“ES”). ES appears unconscious. All head towards vault.
Secured Area Camera 4: All arrive at vault door. Alley mask suspect pulls ES’s keycard from belt,
then all three work together to hold ES’s thumb to fingerprint scanner and open ES’s leO eye for
the biometric eye scanner. All enter vault.
 Revised 8/27/23

9:15pm to 9:17pm –
Vault Cameras 1, 2, 3: All drag ES inside. Suspects use what looks like ES’s key chain and master
key to open vault lockers/interior storage. Suspects removing items from security lockers and
place them on moving cart. ES appears unconscious during endre period.
Secured Area Camera 1: Parker Orlov (“PO”) enters North Staging Area walks to kitchen and
then back to North Stadng Area again. Appears to be trying to make a phone call. Cyprus
Cosmos (“CC”) then enters North Staging Area from Cocktail Room door. They appear to start
arguing. CC eventually leaves towards cocktail area. PO remains in North Staging Area.

9:18pm –
Secured Area Camera 4: Two of the suspects (including alley mask suspect) leave vault with
loaded cart. Items are packed, so cannot disdnguish which items are which. Third suspect leO in
vault. Appears to be the injured suspect described earlier.
Vault Camera 2: Injured suspect condnues to open lockers inside. ES appears to wake up and
begins to slowly move into a posidon to jump onto injured suspect.
Secured Area Camera 1: PO walks towards kitchen again.
Secured Area Camera 2: Two suspects load freight elevator. Appear to use ES’s key card to make
elevator work. PO passed by freight elevator on way to kitchen. Pauses. Appears to interact with
suspects briefly. Then quickly shuffles into the kitchen.

9:19pm –
Roof Cameras 5, 6, 7: Two suspects load items into the sdll running helicopter. Move back
towards freight elevator once loaded.
Vault Camera 2: ES appears to jump towards injured suspect. Only manages to bump into
injured suspect. Gun appears to fall from injured suspect’s waist. ES tries to go for the gun.
Secured Area Camera 2 then 1: PO exits kitchen and eventually exists secured area through
Cocktail Room door.

9:20pm –
Secured Area Cameras 2, 4: Two suspects arrive back on floor and move towards vault again.
Vault Cameras 2, 1, 3: Injured suspect a[acks ES. ES doesn’t really fight back aOer first hit by
injured suspect. Two other suspects arrive in vault again. Can’t really make out what happens.
Two suspects appear to jump into the fight between injured suspect and ES. Unclear whether
the two other suspects are trying to break up the fight or help injured suspect in a[acking
guard. Alley mask suspect can be seen kicking ES at least once and punching ES at least once
though.

9:21pm –
Vault Camera 2: Eventually three suspects separated from ES’s unmoving body. First suspect
returns to removing items from lockers in vault. Alley mask suspect appears to talk to injured
suspect for several seconds. Very enthusiasdc hand gestures are happening. But then injured
suspect collapses. Alley mask suspect catches injured suspect and calls to first suspect.
 Revised 8/27/23

Secured Area Camera 1: CC returns to North Staging Area followed closely by PO. CC begins,
again, yelling at PO. CC throws plate of food at PO, PO ducks. Picks up food from ground and
acts like they are going to throw it back towards CC. CC appears shocked and then runs back
towards Cocktail Room. PO drops food, wipes off hands, and then also returns to cocktail room.

9:22pm –
Vault Camera 2: Other two suspects help injured suspect. Injured suspect appears to be
conscious but lethargic in movements. Remains leaning against wall on the ground. Other two
suspects return to emptying vault.

9:23pm to 9:25pm –
Vault Cameras 1, 2, 3: Suspects finish loading cart. First suspect pushes cart out of vault again.
Alley mask suspect helps injured suspect to their feet. Injured suspect drapes arm around alley
mask suspect and they walk out of vault together. ES sdll unconscious, has been since injured
suspect a[acked.

9:26pm –
Secured Area Camera 4: First suspect pushes cart towards freight elevator. Alley mask suspect
and injured suspect also exit vault. Alley mask suspect tries to close vault door, but unable to
while helping injured suspect. Door remains open.
Secured Area Camera 2: First suspects starts to load freight elevator.

9:27pm –
Secured Area Camera 2: All suspects enter freight elevator.
Roof Cameras 4, 5, 6, 7: All suspects exit freight elevator. First pushes cart towards helicopter
and begins loading items to helicopter. Alley mask suspect helps injured suspect to other side of
helicopter. Alley mask suspect loads injured suspect into helicopter. Alley mask suspect comes
back to other side of helicopter to finish loading. All items loaded and two suspects outside
helicopter back away.

9:28pm –
Roof Cameras 6, 7: Two remaining suspects return to freight elevator. Helicopter takes off.
Secured Area Camera 2: Two suspects exit elevator on Floor 40. Head towards North Staging
Area.
Secured Area Camera 1: Two suspects alter their oujits so that the all black now looks like fairly
generic Halloween costumes. Masks they have been wearing stay the same though. Two
suspects exit North Staging Area through Cocktail Room doors.

9:29pm –
Secured Area Camera 1: CC and PO enter North Staging Area and head towards kitchen. Appear
to be arguing again by their demeanor and expressive hand gestures.
 Revised 8/27/23

9:30pm –
Secured Area Camera 2: CC and PO stop at security office. CC knocks on door. Then they both
look down hallway towards vault door. Then start running towards vault door.
Secured Area Camera 4 and Vault Cameras 1, 2, 3: Both CC and PO enter the vault.

9:31pm –
Vault Cameras 1, 2, 3: PO bends down to examine ES. CC stands a few feet away. Yet another
argument appears to break out. ES sdll unconscious. CC eventually leaves vault.

9:32pm –
Secured Area Cameras 2, 4, 1: CC leaves vault and heads towards North Staging Area. Eventually
exits to the Entryway near the public elevators.

9:36pm to 9:48pm –
Secured Area Cameras 1, 2, 3, 4 and Vault Cameras 1, 2, 3: Show police entering the area and
EMTs arriving and a[ending to ES. ES removed and taken to freight elevator for eventual
placement in ambulance once on ground floor.

9:49pm and onwards –

Nothing of note occurs. Only people on the security footage are police officers, invesdgators,
and building personnel.

Other notes:
- Faces of suspects are never visible on the camera feed. Suspects all managed to posidon
themselves away from the camera and wear masks while inside the vault.
- Unable to idendfy the genders of any of the suspects. Clothing they were wearing make
idendficadon of that impossible.
- Any cameras not discussed at any point in the above notes did not show any people
during the above discussed dme period.
- Due to the lighdng from the event, no cameras in the public area of Floor 40 had any
useful footage aOer the dinner concluded at 8:30pm.
 Revised 8/27/23

Type of Report: All text records between specified accounts Exhibit

Date of Report: 01/03/23 9:10am 30
Search Parameters:
Date(s): 01-SEPT-2022 to 15-DEC-2022
Accounts: 654-555-5323 [subscriber name: Raynes, Memphis]
654-555-5324 [subscriber name: Cameron, Poe]

From Date Time Content

Cameron, Poe 09/12/22 19:08 Hey. That big job you mentioned. Any way I can still get in on that? I could use the
money.
Raynes, Memphis 09/12/22 19:09 You sure you want in on something like this? It’s pretty big
Cameron, Poe 09/12/22 19:11 I’m sure.
Cameron, Poe 09/12/22 19:13 Getting a 9-5 hasn’t worked out. I’d rather get in on your big paydays.
Raynes, Memphis 09/12/22 19:25 I’ll check with the boss. If I do this though, there is no backing out.
Cameron, Poe 09/12/22 19:25 I’m sure. Won’t let you down.
Cameron, Poe 09/13/22 10:02 Any news?
Raynes, Memphis 09/13/22 12:29 You’re in.
Raynes, Memphis 09/13/22 12:29 Meet me at Ivy Lane at 6. Rm 322.
Raynes, Memphis 09/13/22 12:30 Don’t be late.
Cameron, Poe 09/13/22 13:47 Really?? You won’t regret this.
Cameron, Poe 09/13/22 13:52 Am I meeting anyone?
Raynes, Memphis 09/13/22 13:52 Yeah. The boss.
Cameron, Poe 09/13/22 13:53 Anyone I know?
Raynes, Memphis 09/13/22 13:55 They’re high profile but you haven’t met them.
Cameron, Poe 09/13/22 13:57 Should I be scared?
Raynes, Memphis 09/13/22 13:57 Depends.
Raynes, Memphis 09/13/22 13:57 How do you feel about helicopters?
Cameron, Poe 09/13/22 14:03 ??
Raynes, Memphis 09/13/22 14:04 Just wait til you learn what the target is.
Cameron, Poe 09/13/22 15:22 How much?
Raynes, Memphis 09/13/22 15:27 Can’t say here, but definitely $$$$
Raynes, Memphis 09/13/22 16:49 Oh also, make sure you do Halloween shopping. You’ll need a mask.
 Revised 8/27/23

Cameron, Poe 09/14/22 16:50 👍

Cameron, Poe 11/01/22 12:03 Hey. How you feeling?
Cameron, Poe 11/01/22 23:17 Hello?? Anyone there?
Raynes, Memphis 11/02/22 03:57 The rumors of my death have greatly been exaggerated.
Cameron, Poe 11/02/22 07:40 Funny. I’ll come check on you later today.
Cameron, Poe 11/21/22 20:11 Cops are breathing down my neck about you.
Cameron, Poe 11/21/22 20:19 I’ll come up with a story to make it all go away.
Cameron, Poe 12/01/22 11:38 Really? You pull me into this job and now you ghost?
Cameron, Poe 12/02/22 13:09 So much for family first
 Revised 8/27/23

DECLARATION OF JO BASSETT

My name is Jo Bassett, and, under penalty of perjury, I declare that:

1. I am the Chief Database Administrator for Midlands Wireless, which offers cell phone and
text messaging services throughout the greater Midlands area. I have held that job since November 8,
2019.
2. As part of my duties, and in the regular course of Midlands Wireless’s business, I manage
and maintain a computer database (“database”) that tracks all call and text message information among
Midlands Wireless customers. The database is used to generate monthly bills (which can vary depending
on the terms of the customer’s subscription, as well as the number, type, duration of calls, and the number
of text messages), as well as various purely internal purposes.
3. When a subscriber registers for a new account, a record is automatically generated in the
database that links the subscriber’s name, the subscriber’s billing address, and a telephone number.
4. When a subscriber sends or receives a text message, the database electronically and without
human intervention generates a record of that text message that memorializes the sending and receiving
telephone number, the date and time at which the text message was sent, and the full content of the text
message (“content information”). The database also flags without human intervention whenever a text
message fails to deliver for any reason.
5. We support a variety of billing plans that include set numbers of text messages for a base
charge and charge various fees for text messages beyond those covered in the subscriber’s plan. Because
of this, we maintain records of when texts are sent or received by Midlands Wireless customers, including
the phone number of both parties and the date and time at which the message was sent, as well as content
information. The database is programmed to store all such information for at least two years.
6. The database is programmed to generate reports about activity between two particular
telephone/account numbers. To generate the attached report, I personally entered five pieces of
information into the database. First, in a field labeled “Type of Information Requested,” I clicked a box
labeled “All Text Records Between Specified Accounts.” Second, in a field labeled “From,” I manually
entered “01-SEPT-2022.” Third, in a field labeled “To,” I manually entered “15-DEC-2022.” Fourth, in a
field labeled “Subscriber 1,” I entered “6545555323.” Fifth, in a field labeled “Subscriber 2,” I entered
“6545555324.” I then clicked a button labeled “Submit.” At that point, the database automatically and
without any additional action by me generated the report dated “01/03/23 9:10am,” sent a copy to my
attached printer, and saved a copy of the report itself in the database.
I swear under penalty of perjury that the foregoing is true, accurate, and complete to the best of
my knowledge.
Jo Bassett
Jo Bassett

Signed before me on January 3, 2023

Be#y James
Betty James
Notary Public