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Carl's Defence Exhibits



Carl’s List of Defense Exhibit numbers with a brief description of each exhibit and how they relate to each other. 


P-1    original St John’s County Sheriff Police Report (dated Dec. 30, 1998) and subsequent State Attorney’s/Court documents


P-2     same accusation originally made in P1 (Alexandria Virginia Federal court   Sept. 2001)  (contradicted by P-1 and P-93)

P-3      3rd attempt to extradite Alexandria Virginia City Court (with Judges May 25, 2000 dismissal order)



P-4     4th  attempt(s) to extradite (after may 25, 2000, compare p-1,  p-3,  P-8, P16, and P-76) US justice Dept  2002
Anything to do with extradition between June 2000 to 2003 go with P4


P-5      Federal court documents (Plea agreement and so-called statement of facts (which are disputed) dated Sept 2001  (contradicted by P-1 and P-93)


P-6       Docket sheets

P-7     Federal court judge’s disposition and sentencing documents dated Dec. 2001 

P-8     letter from Alexandria, VA judge Swersky verifying Florida charges (P-1, P-3) were dismissed May 25, 2000

P-9     Illegal warrant obtained June 2000 after the Alexandria court Judge Swersky had ordered the dismissal on May 25, 2000

P-10     Alexandria Federal Court Magistrate Poretz, Order of detention without bail, based on pretext the Florida fugitive warrant was still active.
(Compare P-3 and P-8)

P-11     July 10, 2000 Federal motion requesting psychiatric exam  (with the fabricated Secret Service story about dead body (paragraph 6) (Dead body story was used as pretext for search warrant P-20) Compare letter from lawyer denying dead body story P-77, P-78

P-12     Curriculum Vitae (CV/resume) Dr. Phillips showing he was employee of Secret Service and has ties to White House officials such as Bill Clinton and Al Gore

P-13     City Alexandria, VA Court (not federal Court) decision showing dismissal of Florida charges

P-14      Letter and USC 28, ‘2255’ traverse, federal motion to appeal

P-15     samples of some of the Bush cartoons, “carrot catchers” and flyers

P-16     2nd Attempt to extradite from Virginia to Florida, relating to charges in P-1 with Arlington County Judge Kelley’s disposition, dismissal order and release from jail order Sept 30, 1999  (5 or 6 pages)

P-17      Dr. Phillip’s psychiatric report contains false information, contradictions and misquoted sources Aug 2000  (15 pages)

P-18     Federal pre-sentence report, 22 pages, not including work sheets a, b, c, d (contains false information, contradictions and misquoted sources)  (compare P-1, P-8, P-19, P-21, P-22, P-23, P-24, P-70, P-74, P-84, P-89, P90, P-93, P-94, P-95, P-96, P-97, P-98, P-99)

P-19      Affidavit from Grandmother regarding Dawn, Grandmother’s eyewitness account of Dawn’s brother attack on Carl, threat to burn down house and threat against Carl and Grandmother  (compare P-89 Oct. 16,1998 police report)


P-20     June 2000 Secret Service  search warrant obtained based on false pretext  that Carl told Secret Service agent on June 12, 2000, while in the presence of Carl’s Lawyer, about a murder victim that Carl supposedly disposed of in Florida  related document P-20a (compare P-11 paragraph 6, compare P-77, P-78 Lawyer refuted )

P-21    Former employer Ken Zurk’s letter, Mr Zurk drove Dawn to Carl’s’ house Sept. 15, 1998   (this letter refutes paragraph 27 and other parts of the pre-sentence report P-18)

P-22     Kemper aviation letter, flight school Carl attended in Florida (refutes page 19 of pre-sentence report P-18)

P-23     various school records  from Florida and Virginia (refutes page 19 of pre-sentence report P-18)

P-24      Portions of Dawn’s  criminal record and aliases

P-25      Harper’s Magazine News article  March 2008, Vote Machine: How Republicans hacked the Justice Department

P-26 to P-58  news articles and other exhibits about Legal injustices and government
corruption related to Bush administration officials

P-50    Document filed by Carl while in prison disputing Pre-sentence report, Sept 23, 2002 relates to P-18

P-53   

P-54    Sentencing guidelines

P-55    Federal indictment June 2000, re: Carl’s comments about Bush

P-57    US District Court of Virginia jury instructions Aug 2001

P-58     US Marshal document

P-59    Government list of exhibits they planned to use at trial (2 days before plea agreement made)

P-60      September 2001, plea hearing transcript (approx 15-20 pages)

P-61     Federal court original unsigned waiver of indictment, (Carl never signed this) not dated  (contradicted by P-93)


P-62     Federal court modified waiver of indictment they changed the case number (Carl never signed this) (contradicted by P-93)

P-63      more USC title 28 sec 2255, appeal documents

P-64      more appeal documents

P-65      4th Circuit Court of Appeals Richmond Virginia (http://pacer.ca4.uscourts.gov/opinion.pdf/036636.U.pdf)

P-66      2241 writ of habeas corpus


P-67      various letters to and from various law enforcement agencies regarding false
accusations made in pre –sentence report P-18 and Dr. Phillip’s report P-17

P-68      letters  to and from Carl’s former Federal lawyer Peter Goldman, Carl’s Aunt Helen and other letters while incarcerated

P-69     Dawn’s use of alias names, stolen ID, use of other peoples driver’s licenses and Department of Motor Vehicle records (compliments P-24)

P-70     arrest report June 8, 1998, Carl was arrested for driving under suspension for not paying traffic tickets, Dawn was a passenger in Carl’s vehicle and gave alias name (she had warrants under real name), Dawn being with Carl’s at that time contradicts pre-sentence report P-18 paragraph 27 which alleges Dawn last saw Carl, when he allegedly broke into her home in January 1998 and also contradicts P-71 page 3


P-71       US Government version of facts and chronological time-line regarding Carl’s alleged conduct towards Dawn and her roommate. (Sentencing factors 5 pages)  this is refuted by P-19, P-21, P-70, P-74 and P-84  (contradicted by P-93)


P-72      letter from Private investigator

P-73      letter from Northern Virginia mediation service regarding Dawn

P-74    March 5, 1998   Orange Park Medical Center, hospital records, Carl and Dawn were ill and admitted to emergency room together (this contradicts Pre-sentence Report  P-18, paragraph 27 and P-71, which alleges Dawn last saw Carl, when he allegedly broke into her home in January 1998)

P-75     2002 letter and response from Private Investigator

P-76     1999 Attempt to extradite from Virginia to Florida with Judges dismissal order

P-77     Federal Court motion from Carl’s Lawyer disputing Secret Service murder victim story contained in exhibit P-11 paragraph 6, July 24, 2000  

P-78     another motion regarding Secret Service murder victim story and other false accusations made in government’s motion P-11, July 14-17, 2000

P-79     government’s ‘amended’ motion for mental health evaluation with Secret Service murder victim story and other false information removed, July 2000
 
P-80    more documents relating Secret Service murder victim story
             related document  P-80a

P-81     FBI results from crime lab denying Secret service accusation goes with P80

P-82     Judges original order form Alexandria Federal Court granting government’s mental health examination P-11 motion


P-83     Judges order form Alexandria Federal Court granting government’s amended
mental health examination P-79 motion, removing Secret Service murder victim story

P-84    Sept 11, 1998, Florida police report indicating Dawn had not filed any previous complaints against Carl, this contradicts allegations made in Pre-sentence report P-18 and government motion P-71

P-85     Florida police report concerning Dawn’s violent behavior

P-86      another Florida police report concerning Dawn’s violent behavior

P-87      Florida police report from 1997 concerning Dawn, drugs found in hotel room, vandalism of hotel room and Dawn’s assault on a pregnant woman that resulted in miscarriage

P-88     Florida police report Oct 1998, police question Dawn regarding burglary at Carl’s house, She told police Carl was making un-invited visits and phoning frequently (contradicts P-18 paragraph 27 and P-71)

P-89     West Palm Beach, Florida police report, Oct 16, 1998, regarding Dawn’s brother breaking in to Carl’s house an assaulting him and threatening his grandmother  (3 page report) relates to P-19 grandmother affidavit

P-90     

P-91    Palm Beach County Sheriff’s office, May 1997, Arrest report for Dawn arrested for DUI, report also references a report made earlier that day regarding Dawn assaulting her mother

P-92

P-93    Bell South and GTE phone records showing Carl made phone calls to Dawn and her roommate from Florida and not Virginia, contradicts P-2, P-5, P-18, P-61, P-62, P-71

P-94    affidavits relating to Dawn

P-95    multiple Federal Prison doctor’s reports stating Carl did not suffer from a mental illness

P-96    Letters from various schools stating there were no discipline problem with Carl, (contradicts accusations made in documents such as P-17, P-18)

P-97    reserved for grandma phone records

P-98    more school records

P-99     Affidavit form Carl’s Aunt refuting statement concerning her made in P-17 and other court documents

P-100    Canadian refugee claim document

P-101    transcripts of Canadian Immigration court documents

P-102      Carl’s PIF, filed with refugee claim

P-103     press release from Ken Fernandez

P-104     Letter to Jimmy Carter

P-105     Letter to Bernardo Avarez Herrera

P-106     Letter to Irwin Cotler

P-107     Letter to Olivia Chow

P-108    Letter to Gale Davidson

P-104 - P116  letters  to  various  people re:  Canadian immigration and detention


P-120    Canadian Immigration Court detention orders

P-121    Canadian Immigration Judge caught lying in court

P-122     more Canadian Immigration court records

P-123     July 2007 Court transcripts of Immigration Judge falsely denying that Carl made a refugee claim in May 2007

P-124     more Immigration court records

P-125      Government of Canada psychiatric report (in French)

P-126    David Woodbury letter to court and lawyer regarding Carl’s psychological evaluation

P-127    David Woodbury Carl’s psychological evaluation report

P-128

P-129    

P-130      Canada Immigration Minister document regarding refugee claim hearing

P-131     Carl’s lawyer observations regarding refugee hearings

P-132      March 2008 Canadian Immigration Judges response to P-130 P-131

P-133 to 139 Federal Appellate court documents

P178 - 199 unassigned

P-200    UCC financing statement

P-217    June 30 2002   letter from Aunt Helen regarding Dawn

P-218    2002 letter to and response from Boynton Beach Police Dept. regarding Dawn

P-219     1999 Jacksonville Florida Arrest report regarding Dawn stealing hospital supplies (compliments P-24, P-85, P-86, P-87, P-91, P-92)

P-240      Carl’s law suit filed 2003 in Federal Court in Washington DC for unlawful conviction and unlawful detention, unlawful plea agreement

P-241- 244  waiting for mental health, employment and school records

P-245     1998 Palm Beach County lawsuit Carl filed against Dawn

P-246     letters to Florida Courts and responses.

P-247- 269 various letters and affidavits

P-270    request to terminate Probation Dec. 2006 to March 2007

P-271    Arrest for probation violation and Judges order releasing Carl

P-272    Carl re-arrest Jan 2007

P-273    Probation termination, March 23 2007, sentenced to 90 days in Jail with credit for time served

P-274     May 16, 2007 warrant, the court alleges that Carl didn’t serve the entire 90-day sentence. Carl dispute this warrant because he was never given credit for other time served, approximately 10 months, regarding the original criminal case. By law this time should be applied toward the remainder of the 90-day sentence the government wants Carl to serve.

P-275    motion for dismissal of Warrant  (P-174) and credit for time served which he did not receive credit for 

P-276     US government response to Carl P-175 motion September 2007


P-277     Oct 4, 2007 motion filed with US Court contesting P-176 government response (court has not denied or granted this motion as of June 2008)