UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION

UNITED STATES OF AMERICA

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

EMILIO IPPOLITO, et al.

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NOTICE TO DEFENDANTS OF UNINDICTED CO-CONSPIRATORS
AND FEDERAL RULE OF EVIDENCE 404(b)

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.

UNINDICTED CO-CONSPIRATORS

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.

FEDERAL RULE OF EVIDENCE 404(b)

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

-s-

CHARLES R. WILSON
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]

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