DOJ-OGR-00033214.tif

and "can't wait to buy some weed!!!... I can't wait!!!... (Hold on: let me
say that again) I can't wait to buy some weed!!!... I also want to get a
vaporizer so I can smoke in my room because apparently there are 'narcs'
everywhere".
also posted a photograph of a marijuana signature and
labeled it "what heaven looks like to me". This information and supporting
documentation was provided by the defense to the PBPD, was not included in
the Police Report or probable cause affidavit and never released to the public
(although there is both a fleeting reference in the Police Report to
use
of marijuana with her boyfriend (at page 67) and in the probable cause
affidavit to
marijuana
(at pages 10-11)).
17.
Lies. Alleging Defense Investigators Impersonated Police
Officers. During the course of the investigation by the PBPD and the State's
Attorneys Office, the defense was notified that a witness claimed that defense
investigators had impersonated police officers in an effort to get her statement.
The defense subsequently concluded that these accusations were made by
(A reference to this accusation was included in the Police Report (at page 67)
and the probable cause affidavit). Defense counsel immediately questioned
the investigators and learned the accusation was baseless. The investigators'
notes, which describe the investigators' conversation with refute any
claims of police impersonation. These notes, which were freely reproduced
for the PBPD, demonstrate that the investigators gave a business card
clearly identifying them as private investigators. The notes provide
contemporaneous evidence that
initially declined to speak to the
investigators because she said she "does not speak to cops", to which the
investigators responded they were not "cops". Despite having this
information from defense counsel, the PBPD failed to include it in the Police
fantastic, and false,
Report or probable cause affidavit, including only
claims and that defense counsel was investigating the allegations.
IV.
18.
Home.
Police Contacts – Drugs, Alcohol. Running Away From
has a history of running away/turning up missing
from her parents' various homes; of using drugs and alcohol; and of
associating with unsavory individuals. For example, a
Report details how shortly after returning to Florida from
to live with her father, on
police were called to the
home after her father reported that
and her
were missing.
As it turned out, the
had voluntarily absented themselves. They stayed
out all night and were returned home, drunk and high, by a helpful "drug
dealer". This event coincided by a few days with
having been found
at an "inappropriate location" by
police who this time were called by
mother because of yet another unexplained absence. Although this
information, material to determining credibility, was provided by the defense
7
Public Records Request No. 19-372
DOJ-OGR-00033214