V. Case No. 96-64-CR-T-23(E)




The United States of America, through the undersigned Assistant United States Attorney, provides the following notice to the defendants in accordance with the standing discovery orders in this case.


Please find appended to this notice a list of one hundred seventy-four (174) unindicted co-conspirators. Some of the people in this large group represent individuals who have signed the various orders, warrants and intervenors which emanated from one or more of Defendant IPPOLITO’s counterfeit courts, and which have already been provided in Rule 16 discovery. Others in this group actively took part in meetings of the counterfeit courts or otherwise participated in advancing the goals of the conspiracy. Please note, the government also intends to use statements made by Larry Myers in accordance with Rule 801(d)(2)(E). Larry Myers was indicted on March 15, 1996, along with the defendants but is currently a fugitive from this prosecution.


The following information has already been provided in the evidence pool which the government disclosed to the defendants in accordance with Fed. R. Crim. Proc. 16(a). Moreover, the following information is res gestae of the offense, and is inextricably intertwined with the offenses charged in the Indictment. However, in an abundance of caution the government provides notice of the following facts which it intends to prove as part of its case-in-chief.

-EMILIO IPPOLITO, SUSAN MOKDAD and several other co-conspirators were involved in intense civil, quasi-criminal litigation with Hillsborough County and the City of Tampa for many years prior to IPPOLITO’s founding of his so-called courts. For the most part the litigation was resolved unfavorably to IPPOLITO, and by his own admissions he lost millions of dollars, and forfeited extensive land holdings.

-EMILIO IPPOLITO, SUSAN MOKDAD and other were enjoined by the Florida Supreme Court from the unlicensed practice of law, from holding themselves out to be judges and from aiding and abetting others in these practices.

-EMILIO IPPOLITO and SUSAN MOKDAD were held in contempt for violating the order of the Supreme Court of Florida, and, as a result, incarcerated for several months.

-In or about 1994, EMILIO IPPOLITO and SUSAN MOKDAD actively interfered with, and obstructed, a federal judicial, contempt proceeding in Denver, Colorado in the matter of Wilford Simpson.

-PHILIP MARSH and DOUGLAS CARPA participated in a tax fraud scheme which was known as the "Pilot Connection." As part of the scheme, MARSH marketed so-called untaxing packages which he alleged could shelter income from federal tax. MARSH, CARPA and several others were prosecuted for their activities in the PILOT CONNECTION in Case No. 93-0592-VRW, which is expressly identified in the Indictment in the above-captioned case, as part of the subject-matter of this prosecution.

-Defendants WARREN and MOORE were prosecuted for extortion in violation of the Hobb’s Act, Title 18, United States Code, Section 1951, in the Middle District of Florida, in Case No. 95-209-CR-ORL-22. WARREN, MOORE and others threatened local, state and federal officials with violence and economic reprisals regarding a civil dispute arising from WARREN’s failure to pay a special assessment generated by a condominium association.

-Unindicted Co-conspirator Karen Horning sold prodigious amounts of illegal drugs, including LSD, for which she was prosecuted in the Northern District of California, in Case No. 93-0450-THE. Defendants IPPOLITO and MOKDAD knew of the nature of the charges, and the fact that the Drug Enforcement Agency was the investigatory arm of the prosecution before they embarked upon their efforts to obstruct and tamper with the petit jury in Horning’s case.


Respectfully submitted


United States Attorney


By: Ernest F. Peluso
United States Attorney Number 054
Assistant United States Attorney
500 Zack Street, Suite 400
Tampa, Florida 33602
Telephone No. 813-274-6344
Facsimile No. 813-274-6178


[This list of unindicted coconspirators was attached to the above]


1. Ackerman, Dana 2. Adams, Sharon 3. Addleman, LeAnn
4. Addleman, Manfred 5. Adinson, Susan 6. Ambrosio, Ginger
7. Ball, Earl 8. Balsam, Howard 9. Becerra, Patricio
10. Bernier, Mike 11. Bilyue, Steve 12. Blake, Richard
13. Bradley, Jeffrey 14. Brandt, Bruce 15. Breneman, R.A.
16. Brill, Laura 17. Brodowski, Stephen 18. Brothers, Norris
19. Brown, Caroline 20. Brown, Mary E. 21. Brulo, Robert
22. Burke, William C. 23. Burkhart, Edward 24. Busby, Nancy L.
25. Busby, Terry E. 26. Carr, Christopher 27. Charboneau, Rose
28. Chavez, Fernando 29. Clayton, Albert 30. Cole, Benny W.
31. Corneilsen, Harry 32. Cosgrove, Kimberly 33. Cox, Steve
34. Cranwill, Patrick 35. Davidson, Larry 36. Davidson, Mike
37. Deeb, Ramond 38. Deming, Thomas 39. Diederich, William
40. DiSanto, Tami 41. Doty, Gregory 42. Dowire, Roy J.
43. Duff, Steve 44. Eidson, Charles 45. Eidson, Sandra
46. Fankhanel, Carolyn 47. Farquharson, Beulah 48. Ferguson, Tommi
49. Ferraro, Bobbi 50. Flinchbaugh, David 51. Fulks, John H.
52. Gaiman, Ken 53. Geidel, Jack 54. Geiger, Eve
55. Geiger, F.M. 56. Gewin, Barry 57. Gonzales, Jose
58. Gorton, Carl 59. Hall, Don 60. Hardy, Le
61. Head, Hanna 62. Hedberg, Dale 63. Hedbert, Patricia
64. Hester, Randy 65. Horning, Karen 66. Hughes, Jerry
67. Ippolito, Wilma 68. Jackson, Helena 69. Jackson, Ronn
70. Jenkins, Bobbi 71. Jennings, John 72. Jones, Bill
73. Jones, Frank 74. Jones, Ralph 75. Keasling, James
76, Kennedy, Joseph 77. Kenney, Christopher 78. Keseler, Clifford
79. Keseler, Janet 80. Kline, Martha 81. Kobres, Arthur
82. Kobres, Cheryl 83. Koontz, Harry 84. Krishak, John
85. Lamb, Rebecca 86. Leggett, William 87. Lewis, Evelyn
88. Lewis, Richard 89. Lopez, Jesus 90. Lower, Norman
91. Lyons, Kevin 92. Marsh, Marlene 93. Martin, Julia
94. Matisko, Robert 95. McMannus, Barbara 96. Merithew, James
97. Miller, Jim 98. Miller, Nova 99. Miller, Warren C.
100. Moore, Kathy 101. Morse, L.R. 102. Murillo, Alfonso
103. Murphree, Ruth 104. Nauman, Kent 105. Newby, David
106. Newby, Janene 107. Nuckois, Bill 108. Oakley, Dennis
109. Oakley, Lizabeth 110. Oscarson, Greg 111. Oscarson, Nathan
112. Patrick, Christine 113. Payne, Betty 114. Payne, Gerald
115. Perez, Jose 116. Perry, Laurie 117. Pirie, V.I.
118. Poe, Hubert 119. Pontojo, Raymondo 120. Reed, Charles
121. Reed, Rita 122. Resendiz, Jose 123. Riberg, Elazar
124. Riberg, Terry 125. Riddle, Richard C. 126. Riddle, Sandra S.
127. Ridgway, Linda 128. Ritter, Dan 129. Rogers, Kathy Ann
120. Rogers, Timothy 131. Rupe, David 132. Sammarco, Laura
133. Satterwhite, Allen 134. Saunders, Jack 135. Sayre, Sandra K.
136. Schardien, Donna 137. Schardien, J. Peter 138. Schnoebelen,JeromeA
139. Schutt, Charles 140. Shock, Francile 141. Shock, Lyndale
142. Shramek, Daniel 143. Simpson, Wilford 144. Slater, Susan
145 Sloan, Alan 146. Smith, Gary 147. Sneathan, George
148. Spencer, Dwight 149. Spenser, Randy 150. Spychalski, James
151. Stafford, Mabel 152. Stewart, Gene 153. Storm, Stella
154. Street, Earl 155. Strickland, Woody 156. Talbert, Patrick
157. Tarrant, Wayne 158. Than, Ernest 159. Timmons, Diane
160. Van Wormer, Robin 161. Vanderford, Robert L. 162. Veleazqueze,Alphonso
163. Warner, Richard 164. Warren, Barbara 165. Warren, Mark L.
166. Weeks, Rex 167. Williams, Mark 168. Wilson, Shawn D.
169. Wilson, T. Alan 170. Wintch, Betty 171. Wright, Arthur
172. Young, L. Jerome 173. Young, Larry 174. Zurwell, William

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