Assistant Attorney General
Civil Rights Division
Criminal Section
950 Pennsylvania Avenue, Northwest
Washington, DC 20530
March 3, 2014

Re: Complaint:- Court Case#: CR10-1721-002-PHX-PGR

Dear Assistant Attorney General;
I hope you're doing well.
My name is Willie Gene Woodard, I am co-defendant in a case which is set to commence being heard in
the court of Honorable Judge Rosenblatt, in Phoenix, March 25, 2014. I realize you're a busy. I will purpose
not take up much of your time with this letter. I've included for your review, supportive correspondence
which will help give clarity to the case related concerns briefly addressed herein.
I kindly ask, and pray, that once you've read this letter and reviewed the accompanying related
correspondence, you would look into the matters addressed. I'm making this request because I have
significant reason to believe my right to due process and fair trial is being continuously violated.
I've given this contact with you careful consideration and have done a significant amount of law research,
which includes consulting with a number of reputable law firms. I've also sought the assistance of well
known justice advocacy and civil rights organizations. In short, I've been purposely mindful to not be
presumptuous and not be over-reactive. It's after much observation and disturbing realization that I've
decided to communicate these concerns to you, the administration level of the justice system. This
correspondence with you, in it's entire, will convey my verifiable experience pertaining to my case. I'll just
address events as per the manner they occurred.
The following are a few reasons I believe my right to due process and fair trial are being violated:
• About mid August 2011, I was arraigned on an initial indictment before Honorable Judge
Duncan and at that time was provided court-appointed legal counsel, Mr. Roger T. Margolis. I pleaded not
guilty to the charges. While during the hearing was still in process, my appointed counsel commenced to
suggest to me that I should consider taking a plea deal. There was no inquiry from him as to my guilt or
innocence. No inquiry as to evidence I had to substantiate my innocence. No indication from him as to any
plan to discuss my case. My reply was that I was not guilty of the charges. He responded by indicating; that
he and I was already getting off to a bad start. That was a very disturbing moment.

• On September 13, 2011; I appeared in court for a detention release hearing before Honorable
Judge Duncan and he granted release on my own recognizance. At that time I indicated to Mr. Margolis
that upon my arrival in Michigan I would send him the evidence supporting my innocence. Again, Mr.
Margolis expressed that I consider taking a plea deal and to hold-off on sending him any information until
he instructed me to do so. With Trial scheduled for July 2012, it was not until mid-March 2012, that Mr.
Margolis agreed to me sending him my exculpatory evidence files. I provided Mr. Margolis approximately
two hundred evidence documents, some directly contradicting the indictment claims against me. Along with
the evidence documents, I provided a ten person witness list. After sending my evidence and witness list, I
inquired a number of times with Mr. Margolis as to the status of his review and witness contact. His
response was he'd not had time and/or staff to yet complete a review.
•

In May 2012, Mr. Margolis presented me a plea offer. He warned me there would be a superseding
indictment if I declined. I declined the offer. And on June 5, 2012, I appeared before Honorable
Judge Burns for arraignment on a superseding indictment, which turned out to also be a settlement
hearing. Prior to the hearing, while in private conference with Margolis, he informed me that a
particular business associate was going to be a government witness and what the party would
testify to. Immediately I presented Mr. Margolis documents that contradicted the intended
testimony. Mr. Margolis responded with the question; “were these documents among the those you
sent me?” I replied yes they were. I pleaded not guilty and again declined the plea offer. I also
expressed to Judge Burns that I no longer wanted to be represented by Mr. Margolis. In short; after
sending a letter to Judge Rosenblatt expressing concerns about my defense representation, I was
allowed to become Pro Se as I'd requested. Upon Judge Rosenblatt granting Pro Se
representation, he assigned me advisory counsel, Mr. David L. Lockhart. Trial date was continued
to 11/2012. I returned to Michigan.
•

October 1, 2012, after having consultation with two reputable law firms, I filed motion Pro Se for;
“Court to conduct an in camera inspection of the Grand Jury minutes and certain Grand Jury
materials. On October 15, 2012, I appeared telephonic-ally for a status hearing. That day I'd just
been discharged from a Michigan hospital after several days of hospitalization. Judge Rosenblatt
during the “status hearing”, indicated that my motion for “In Camera Inspection of Grand Jury
Minutes” was improperly filed, when in fact I'd followed explicitly the filing instruction provided to me
by the Court's Clerk office. I need add; that prior to filing motion for Inspection of Grand Jury
Minutes, I'd filed two other motions which Judge Rosenblatt granted. In short; during the October
15 status hearing, Judge Rosenblatt insisted that the attorney who'd been assigned as my advisory
counsel, David L. Lockhart, be appointed my defense counsel. Furthermore, Judge Rosenblatt
suggested to Mr. Lockhart that as my newly appointed counsel he withdraw my motion for “In
Camera Inspection of Grand Jury Minutes.” In short, Judge Rosenblatt denied me the right to
continue as Pro Se representation and had my motion for “Inspection of Grand Jury Minutes”
withdrawn. Trail was continued until May 2013.

•

Mr. Lockhart sent me an email on December 30, 2012. I viewed the email about January 5, 2013
and replied to him with the attached letter dated January 9, 2013. Mr. Lockhart didn't reply until
February 2nd, when making me aware of a February 6th status hearing. I had to attend the hearing
telephonic-ally due to recent hospitalization. On March 22nd Mr. Lockhart met with me in Michigan
for about a five hour meeting. It was during the meeting that I was informed for the first time that the
trail date was scheduled for May 7, 2013. Mr. Lockhart gave me a disc of discovery evidence that
he'd just days before received from the prosecutor. He instructed me to review and select
documents from the disc that I wanted to use in my defense. After reviewing the disc I discovered
that only several of the two hundred plus documents I'd provided to the prosecutor August 31,
2012, when I was Pro Se, were on the disc. The documents that I'd provided the prosecutor that
directly contradicted the conspiracy claim were not on the disc. I made Mr. Lockhart aware that the
reciprocal discovery I'd provided the prosecutor wasn't on the disc. On March 23 2013, I
commenced emailing Mr. Lockhart the information I'd previously provided Mr. Margolis, Mr. Rapp
and him. Mr. Lockhart did not reply to my emails until March 28, with the following question; “Good
morning Mr. Woodard. Have you ever given this information to Mr. Margolis or Mr. Rapp previously,
including your witness list and the qualifications of any potential expert witness?” My March 28
reply to Mr. Lockhart was as follows: “Hi David, I've given Mr. Rapp and Mr. Margolis the same
evidence I've given you. Mr. Margolis was also given the witness list, with exception of expert
witness.” To date, none of my witnesses have been subpenaed, and there's been no further
response to my inquiries about the undisclosed evidence.

• On May 5, 2013, while at the airport to board a flight to Arizona and attend a status hearing the
following day, I experienced a Gand mal seizure. Later learned, I'd had several smaller seizures
after the ambulance service was called. I was hospitalized for about five days. Before being
discharged I was visited by my local pretrial supervisor, Mr. Stuart Chavis. After being discharged I
was advised by my attorney that I needed to provide hospital documents confirming I'd been
hospitalized and why. I provided the information as required, which included ambulance report, plus
emergency room and extended stay treatment records. Several days after the initial May
hospitalization, I experienced another series of seizures and was hospitalized again for about a
week. On about May 28, 2013, the day following my hospital discharge, I was arrested by the U.S.
Marshall Service at my residence per court order issued by Judge Rosenblatt. The order my arrest
was issued for not being present for the May 6th hearing, though I'd provided ample documentation
confirming I'd had a seizure at the airport and was hospitalized. It was the beginning of about a
three week prisoner transport back to Arizona. I was hospitalized again for one week while awaiting
transport from Oklahoma to Arizona. After arriving to Arizona, about June 19th, I was admitted to
the detention center hospital were I was treated for about two weeks. In short; on about July 16,
2013, I appeared before Judge Duncan. He'd ascertained and determined that I'd not been in
violation in any way. Demonstrated by him ordering my release and allowing me to return back to
Michigan. He also removed a previous stipulation for house arrest and GPS monitoring, which I
perceived to be a gesture of apology, as well as an acknowledgment of trust. I continue to greatly
appreciate Judge Duncan's “just” assessment and ruling. Trial was continued until December 19,
2013. There was a subsequent continuance until March 25, 2014.
•

On January 4, 2014, I ask my attorney to file a motion with Judge Duncan requesting modification
of my release order transaction amount from $500 to $1,500 or more. In part, so that I could
prepare financially for trail travel to Arizona and lodging during trial. I provided him the names and
contact information of two financial services entities allowing me opportunity to earn income. In
short, on January 6, 2014, I received an email from my attorney conveying that the prosecutor
objects to me working in the financial services industry. He further suggested that I consider other
options. Fact is; there is no stipulation in my release order restricting me from earning an income in
the financial services industry. In short, on January 29, 2014, a motion hearing took place which I
attended telephonically before Judge Rosenblatt. He denied the motion, and accelerated a status
hearing from March 9, 2014 to March 4, 2014, giving me one week less time to raise funds for
travel to Arizona financially prepared for lodging during an estimated three week trial. Judge
Rosenblatt made it clear, that should I appear without the ability to pay for lodging, my release
order would be revoked and I'd be taken into custody.

• I was unable to appear for the March 4, 2014 hearing under doctor recommendation that I not travel
until having a follow-up spinal examination. The examination took place today. Prior to today's
appointment, the doctor provided me a letter recommending that I not travel, which I provided to the
court via my pre-tial supervisors. However, I've just learned tonight, March 4, 2014, that Judge
Rosenblatt issued a warrant for my arrest, in spite of the no travel letter I provided.
In closing; to date; none of the ten plus witnesses I provided have been subpenaed. Some who've
expressed their willingness to testify in my behalf. Likewise, none of the two hundred plus documents I
provided to my initial attorney, the prosecutor and my current attorney that directly contradict allegations
against me were included in discovery. To date, nothing has changed. Still, none of my witnesses have
been subpenaed, and my evidence not disclosed by the prosecutor in discovery remains, to any effect,
unaddressed. Going to trial with no witnesses subpenaed and evidence substantiating my innocence
excluded for discovery, I feel like a sheep headed to slaughter. Proclaiming my innocence is not the
purpose of this letter. I'm just making you aware of events I believe have been violations of my right for due
process and fair trial. I'm reaching out for help.
I trust God for my vindication and future of my family. However, I'm deeply concerned as to the journey prior
to the expected outcome in the absence of due process. For a more complete picture, at your convenience,
please review this correspondence in it's entire. I would gladly allow authentication of emails and letters by
any means you may deem necessary. Much of what I've conveyed herein is a matter of court records.
Thank you in advance for your consideration.
Blessed regards,
[Will G. Woodard]
7425 Chapel Hill Dr. #101
Lansing, Michigan 48917
willgwoodard@gmail.com
Phone: (517) 853-8133
Assistant Attorney General
Civil Rights Division
Criminal Section
950 Pennsylvania Avenue, Northwest
Washington, DC 20530
March 3, 2014

Re: Complaint:- Court Case#: CR10-1721-002-PHX-PGR

Dear Assistant Attorney General;
I hope you're doing well.
As a supplement to the letter conveying concerns about my overall judicial experience, I've included for
your review, this letter and accompanying registered email confirmation documents. This additional
correspondence is to convey concerns specifically pertaining to prosecutor conduct.
I kindly ask, and pray, that once you've read this letter and reviewed the accompanying related
correspondence and any other evidence you may deem necessary, you would look into the matters
addressed herein. I'm making this request because I have significant reason to believe my constitutional
right to due process is being continuously violated by your assistant U.S. Attorneys, Mr. Kevin Rapp and
Ms. Monica Klapper.
To properly chronicle my experience as it pertains to the pre-trial process, I'll first reiterate that Judge
Rosenblatt granted me Pro Se representation, about July 15, 2012. He also assigned attorney David L.
Lockhart to act as my “advisory” counsel. About October 12, 2012 Mr. Lockhart was appointed my attorney.
Pertaining to the reasons I believe my constitutional right to due process have been violated multiple times
since July 2012, I'll address the violations pursuant to the manner I believe they have occurred.
•

On August 31, 2012; in response to Mr. Rapp's request (via Mr. Lockhart) for me to provide my
“reciprocal discovery”, I sent by registered email direct to Mr. Rapp and Ms. Klapper a cover letter
and download links to about five zip files collectively containing about two hundred exculpatory
evidence files. I never received an acknowledgment from Mr. Rapp nor Ms. Klapper that they
received the email. However, as aforesaid, I'd sent the email via a registered email service and
have verifiable confirmation that both Mr. Rapp and Ms. Klapper received the email. See cover
letter & registered email receipt attached.

•

From July 2012 thru about October 12, 2012, for the duration of my Pro Se representation, I was
never provided discovery by Mr. Rapp. Ms. Klapper nor otherwise. This with there being a trial date
scheduled at the time, for November 2012. In short, for about a four month period of time, as I was
Pro Se, I was not provided discovery. Therefore, exculpatory evidence was never disclosed to me.

•

On about October 1, 2012, while I was Pro Se representation, Mr. Rapp/Ms. Klapper filed a Motion
In Limine, which I received no notification of. In short, the motion was filed and I was never allowed
opportunity to review it, object to it, nor otherwise address the motion. See attached Motion In
Limine Mr. Rapp/Ms. Klapper filed April 2013, which addresses Limine motion filed October 2012.

•

On about October 12, 2012, Judge Rosenblatt appointed Mr. Lockhart to act as my defense
counsel. On March 22, 2013 Mr. Lockhart met with me in Michigan. Upon the conclusion of our
meeting, Mr. Lockhart gave me a CD disc he said was discovery that Mr. Rapp or Mr. Klapper had
provided him about a day prior to him meeting with me on March 22, 2013. Mr. Lockhart instructed
me to review the discovery for documents to use for trial. I discovered, that with exception of just
several documents, none of the (200+-) exculpatory evidence files I'd provided to Mr. Rapp/Ms.
Kappler on August 31, 2012 were on the disc. A file titled Woodard's Exculpatory Evidence,
consisted of only about seven documents. About four of the documents did not even pertain to the
case transactions. The exculpatory evidence I'd provided to Mr. Rapp/Ms. Klapper was not entirely
disclosed to my attorney. In short, there was failure to disclose exculpatory evidence to me as Pro
Se July 2012 to October 2012. Subsequently, there was nondisclosure of exculpatory evidence to
my attorney that Mr. Rapp/Ms. Klapper had in their possession. See aforesaid verification receipt.
•

To date, Mr. Rapp and Ms. Kappler have not provided a witness list as per “in a timely manner”.
Thus, I've not been allowed my right to review the list. Likewise, not allowed my right to be
provided information as to deals/concessions made with witnesses in exchange for testimony. In
particular, this is pertaining to witnesses that were directly involved in the case related transactions.

In Brady v. Maryland, 373 U.S. 83 (1963), the United States Supreme Court held that due process requires
the prosecution to disclose evidence favorable to an accused when such evidence is material to guilt or
punishment. The government’s obligation to disclose “Brady” evidence covers not only exculpatory
evidence but also information that could be used to impeach government witnesses. Giglio v. United
States, 405 U.S. 150 (1972). In particular, any agreement made with a government witness for testimony
in exchange for a “deal” or other “favorable” treatment regarding criminal charges must be disclosed. As
stated in United States v. Mitchell, 886 F.2d. 667, 670 (4th Cir. 1989).
I trust God for truth and justice to prevail. Thereby, the assured good well-being of my family. However, I'm
deeply concerned as to the journey prior to that outcome in the absence of due process. Pursuant to the
Fourteenth and Fifth Amendments of the United State Constitution; I'm convinced my right to due process
have been continuously violated. I am prepared to formally present to the national media, evidence of the
violations. Likewise, present exculpatory evidence not disclosed by the prosecution, which contradicts
allegations made by the prosecution in indictments and court proceeding. In conjunction with the media
engagement, there would be legal action taken under the “Color of Law” provision of the U.S. Constitution.
I want to emphasis; that this correspondence with you is not in any way intended to be a conveying of
ultimatum. However, I am urgently purposing to not become another “wrongfully convicted” statistic. I trust
you are not aware of the violations I've addressed herein. Thus, I'm informing you of my experience in hope
you would conduct an investigation to determine if violations have occurred. Also, I'm requesting that you
review my exculpatory evidence in it's entire, in conjunction, with review of the discovery Mr. Rapp/Ms.
Klapper provided to my attorney about March 21, 2013. I have CD copy of the discovery in my possession.
I kindly ask that you would review this correspondence in it's entire. Upon receiving notification from your
office, I will provide you website links to download the exculpatory evidence zip files I provided to Mr. Rapp
and Ms. Klapper on August 31, 2012. Please be advised; I will gladly allow authentication of all emails and
documents by any means you may deem necessary. Thanks in advance, for your anticipated honorable
consideration.
Blessed regards,
[Will G. Woodard]
7425 Chapel Hill Dr. #101
Lansing, Michigan 48917
willgwoodard@gmail.com
Phone: (517) 853-8133
JOHN S. LEONARDO
United States Attorney
Two Renaissance Square
40 N. Central Ave., Suite 1200
Phoenix, Arizona 85004
February 22, 2014

Re: Complaint:- Court Case#: CR10-1721-002-PHX-PGR

Dear U.S. Attorney Leonardo;
I hope you're doing well.
My name is Willie Gene Woodard, I am co-defendant in a case which is set to commence being heard in
the court of Honorable Judge Rosenblatt, in Phoenix, March 25, 2014. I realize you're a busy man. I will
purpose not take up much of your time with this letter. I've included for your review, supportive
correspondence which will help give clarity to pre-trial process related concerns briefly addressed herein.
I kindly ask, and pray, that once you've read this letter and reviewed the accompanying related
correspondence and any other evidence you may deem necessary, you would look into the matters
addressed herein. I'm making this request because I have significant reason to believe my constitutional
right to due process is being continuously violated by your assistant U.S. Attorneys, Mr. Rapp/Ms. Klapper.
I've given this contact with you careful consideration and have done a significant amount of law research,
which includes consulting with multiple reputable law firms. I have also sought the assistance of well known
justice advocacy and civil rights organizations. In short, I've been purposely mindful to not be
presumptuous nor over-reactive. It's after much observation, disturbing realization, and bringing my
concerns to the attention of multiplle judicial authorities, that I've decided to communicate these concerns
to you, the head U.S. Attorney. This correspondence, in it's entire, will convey my verifiable experience
pertaining to the ongoing conduct of your assistant attorneys, Mr. Rapp and Ms. Klapper.
To properly chronicle my experience as it pertains to the pre-trial process, I'll first establish that Judge
Rosenblatt granted me Pro Se representation, about July 15, 2012. He also assigned attorney David L.
Lockhart to act as my “advisory” counsel. About October 12, 2012 Mr. Lockhart was appointed my attorney.
Pertaining to the reasons I believe my constitutional right to due process have been violated multiple times
since July 2012, I'll address the violations pursuant to the manner I believe they have occurred.
•

On August 31, 2012; in response to Mr. Rapp's request (via Mr. Lockhart) for me to provide my
“reciprocal discovery”, I sent by registered email direct to Mr. Rapp and Ms. Klapper a cover letter
and download links to about five zip files collectively containing about two hundred exculpatory
evidence files. I never received an acknowledgment from Mr. Rapp nor Ms. Klapper that they
received the email. However, as aforesaid, I'd sent the email via a registered email service and
have verifiable confirmation that both Mr. Rapp and Ms. Klapper received the email. See cover
letter & registered email receipt attached.

•

From July 2012 thru about October 12, 2012, for the duration of my Pro Se representation, I was
never provided discovery by Mr. Rapp. Ms. Klapper nor otherwise. This with there being a trial date
scheduled at the time, for November 2012. In short, for about a four month period of time, as I was
Pro Se, I was not provided discovery. Therefore, exculpatory evidence was never disclosed to me.

•

On about October 1, 2012, while I was Pro Se representation, Mr. Rapp/Ms. Klapper filed a Motion
In Limine, which I received no notification of. In short, the motion was filed and I was never allowed
opportunity to review it, object to it, nor otherwise address the motion. See attached Motion In
Limine Mr. Rapp/Ms. Klapper filed April 2013, which addresses Limine motion filed October 2012.
•

On about October 12, 2012, Judge Rosenblatt appointed Mr. Lockhart to act as my defense
counsel. On March 22, 2013 Mr. Lockhart met with me in Michigan. Upon the conclusion of our
meeting, Mr. Lockhart gave me a CD disc he said was discovery that Mr. Rapp or Mr. Klapper had
provided him about a day prior to him meeting with me on March 22, 2013. Mr. Lockhart instructed
me to review the discovery for documents to use for trial. I discovered, that with exception of just
several documents, none of the (200+-) exculpatory evidence files I'd provided to Mr. Rapp/Ms.
Kappler on August 31, 2012 were on the disc. A file titled Woodard's Exculpatory Evidence,
consisted of only about seven documents. About four of the documents did not even pertain to the
case transactions. The exculpatory evidence I'd provided to Mr. Rapp/Ms. Klapper was not entirely
disclosed to my attorney. In short, there was failure to disclose exculpatory evidence to me as Pro
Se July 2012 to October 2012. Subsequently, there was nondisclosure of exculpatory evidence to
my attorney that Mr. Rapp/Ms. Klapper had in their possession. See aforesaid verification receipt.

•

To date, Mr. Rapp and Ms. Kappler have not provided a witness list as per “in a timely manner”.
Thus, I've not been allowed my right to review the list. Likewise, not allowed my right to be
provided information as to deals/concessions made with witnesses in exchange for testimony. In
particular, this is pertaining to witnesses that were directly involved in the case related transactions.

In Brady v. Maryland, 373 U.S. 83 (1963), the United States Supreme Court held that due process requires
the prosecution to disclose evidence favorable to an accused when such evidence is material to guilt or
punishment. The government’s obligation to disclose “Brady” evidence covers not only exculpatory
evidence but also information that could be used to impeach government witnesses. Giglio v. United
States, 405 U.S. 150 (1972). In particular, any agreement made with a government witness for testimony
in exchange for a “deal” or other “favorable” treatment regarding criminal charges must be disclosed. As
stated in United States v. Mitchell, 886 F.2d. 667, 670 (4th Cir. 1989).
I trust God for truth and justice to prevail. Thereby, the assured good well-being of my family. However, I'm
deeply concerned as to the journey prior to that outcome in the absence of due process. Pursuant to the
Fourteenth and Fifth Amendments of the United State Constitution; I'm convinced my right to due process
have been continuously violated. I am prepared to formally present to the national media, evidence of the
violations. Likewise, present exculpatory evidence not disclosed by the prosecution, which contradicts
allegations made by the prosecution in indictments and court proceeding. In conjunction with the media
engagement, there would be legal action taken under the “Color of Law” provision of the U.S. Constitution.
I want to emphasis; that this correspondence with you is not in any way intended to be a conveying of
ultimatum. However, I am urgently purposing to not become another “wrongfully convicted” statistic. I trust
you are not aware of the violations I've addressed herein. Thus, I'm informing you of my experience in hope
you would conduct an investigation to determine if violations have occurred. Also, I'm requesting that you
review my exculpatory evidence in it's entire, in conjunction, with review of the discovery Mr. Rapp/Ms.
Klapper provided to my attorney about March 21, 2013. I have CD copy of the discovery in my possession.
I kindly ask that you would review this correspondence in it's entire. Upon receiving notification from your
office, I will provide you website links to download the exculpatory evidence zip files I provided to Mr. Rapp
and Ms. Klapper on August 31, 2012. Please be advised; I will gladly allow authentication of all emails and
documents by any means you may deem necessary. In closing; it's essential, and I kindly ask, to have a
reply from your office by March 3, 2014. Thanks in advance, for your anticipated honorable consideration.
Blessed regards,
[Will G. Woodard]
7425 Chapel Hill Dr. #101
Lansing, Michigan 48917
willgwoodard@gmail.com
Phone: (517) 853-8133
P.S. Sir, you can learn more about the REAL Will G. Woodard at; willgwoodard.com. willgwoodard.org,
ministerofjustice.info & selfgrowth.com/articles/user/1266196 - God bless.
HONORABLE CHIEF JUDGE COLLINS
United States District Court
405 W. Congress, Suite 1500
Tucson, Arizona 85701
February 5, 2014

Regarding Court Case#: CR10-1721-002-PHX-PGR

Dear Honorable Chief Judge Collins;
I hope you're doing well.
My name is Willie Gene Woodard, I am co-defendant in a case which is set to commence being heard
in the court of Honorable Judge Rosenblatt, in Phoenix, March 25, 2014. I realize you're a busy man. I
will purpose not take up much of your time with this letter. I've included for your review, supportive
correspondence which will help give clarity to the case related concerns briefly addressed herein.
I kindly ask, and pray, that once you've read this letter and reviewed the accompanying related
correspondence, you would look into the matters addressed. I'm making this request because I have
significant reason to believe my right to due process and fair trial is being continuously violated.
I've given this contact with you careful consideration and have done a significant amount of law
research, which includes consulting with a number of reputable law firms. I've also sought the
assistance of well known justice advocacy and civil rights organizations. In short, I've been purposely
mindful to not be presumptuous and not be over-reactive. It's after much observation and disturbing
realization that I've decided to communicate these concerns to you, a higher level of the court. This
correspondence with you, in it's entire, will convey my verifiable experience pertaining to my case. I'll
just address events as per the manner they occurred.
The following are a few reasons I believe my right to due process and fair trial are being violated:
 About mid August 2011, I was arraigned on an initial indictment before Honorable Judge
Duncan and at that time was provided court-appointed legal counsel, Mr. Roger T. Margolis. I pleaded
not guilty to the charges. While during the hearing was still in process, my appointed counsel
commenced to suggest to me that I should consider taking a plea deal. There was no inquiry from him
as to my guilt or innocence. No inquiry as to evidence I had to substantiate my innocence. No
indication from him as to any plan to discuss my case. My reply was that I was not guilty of the
charges. He responded by indicating; that he and I was already getting off to a bad start. That was a
very disturbing moment.

 On September 13, 2011; I appeared in court for a detention release hearing before Honorable
Judge Duncan and he granted release on my own recognizance. At that time I indicated to Mr.
Margolis that upon my arrival in Michigan I would send him the evidence supporting my innocence.
Again, Mr. Margolis expressed that I consider taking a plea deal and to hold-off on sending him any
information until he instructed me to do so. With Trial scheduled for July 2012, it was not until midMarch 2012, that Mr. Margolis agreed to me sending him my exculpatory evidence files. I provided Mr.
Margolis approximately two hundred evidence documents, some directly contradicting the indictment
claims against me. Along with the evidence documents, I provided a ten person witness list. After
sending my evidence and witness list, I inquired a number of times with Mr. Margolis as to the status
of his review and witness contact. His response was he'd not had time and/or staff to yet complete a
review.
 In May 2012, Mr. Margolis presented me a plea offer. He warned me there would be a
superseding indictment if I declined. I declined the offer. And on June 5, 2012, I appeared
before Honorable Judge Burns for arraignment on a superseding indictment, which turned out
to also be a settlement hearing. Prior to the hearing, while in private conference with Margolis,
he informed me that a particular business associate was going to be a government witness
and what the party would testify to. Immediately I presented Mr. Margolis documents that
contradicted the intended testimony. Mr. Margolis responded with the question; “were these
documents among the those you sent me?” I replied yes they were. I pleaded not guilty and
again declined the plea offer. I also expressed to Judge Burns that I no longer wanted to be
represented by Mr. Margolis. In short; after sending a letter to Judge Rosenblatt expressing
concerns about my defense representation, I was allowed to become Pro Se as I'd requested.
Upon Judge Rosenblatt granting Pro Se representation, he assigned me advisory counsel, Mr.
David L. Lockhart. Trial date was continued to 11/2012. I returned to Michigan.


October 1, 2012, after having consultation with two reputable law firms, I filed motion Pro Se
for; “Court to conduct an in camera inspection of the Grand Jury minutes and certain Grand
Jury materials. On October 15, 2012, I appeared telephonic-ally for a status hearing. That day
I'd just been discharged from a Michigan hospital after several days of hospitalization. Judge
Rosenblatt during the “status hearing”, indicated that my motion for “In Camera Inspection of
Grand Jury Minutes” was improperly filed, when in fact I'd followed explicitly the filing
instruction provided to me by the Court's Clerk office. I need add; that prior to filing motion for
Inspection of Grand Jury Minutes, I'd filed two other motions which Judge Rosenblatt granted.
In short; during the October 15 status hearing, Judge Rosenblatt insisted that the attorney
who'd been assigned as my advisory counsel, David L. Lockhart, be appointed my defense
counsel. Furthermore, Judge Rosenblatt suggested to Mr. Lockhart that as my newly appointed
counsel he withdraw my motion for “In Camera Inspection of Grand Jury Minutes.” In short,
Judge Rosenblatt denied me the right to continue as Pro Se representation and had my motion
for “Inspection of Grand Jury Minutes” withdrawn. Trail was continued until May 2013.



Mr. Lockhart sent me an email on December 30, 2012. I viewed the email about January 5,
2013 and replied to him with the attached letter dated January 9, 2013. Mr. Lockhart didn't
reply until February 2nd, when making me aware of a February 6th status hearing. I had to
attend the hearing telephonic-ally due to recent hospitalization. On March 22nd Mr. Lockhart
met with me in Michigan for about a five hour meeting. It was during the meeting that I was
informed for the first time that the trail date was scheduled for May 7, 2013. Mr. Lockhart gave
me a disc of discovery evidence that he'd just days before received from the prosecutor. He
instructed me to review and select documents from the disc that I wanted to use in my
defense. After reviewing the disc I discovered that only several of the two hundred plus
documents I'd provided to the prosecutor August 31, 2012, when I was Pro Se, were on the
disc. The documents that I'd provided the prosecutor that directly contradicted the conspiracy
claim were not on the disc. I made Mr. Lockhart aware that the reciprocal discovery I'd
provided the prosecutor wasn't on the disc. On March 23 2013, I commenced emailing Mr.
Lockhart the information I'd previously provided Mr. Margolis, Mr. Rapp and him. Mr. Lockhart
did not reply to my emails until March 28, with the following question; “Good morning Mr.
Woodard. Have you ever given this information to Mr. Margolis or Mr. Rapp previously,
including your witness list and the qualifications of any potential expert witness?” My March 28
reply to Mr. Lockhart was as follows: “Hi David, I've given Mr. Rapp and Mr. Margolis the same
evidence I've given you. Mr. Margolis was also given the witness list, with exception of expert
witness.” To date, none of my witnesses have been subpenaed, and there's been no further
response to my inquiries about the undisclosed evidence.



On May 5, 2013, while at the airport to board a flight to Arizona and attend a status hearing the
following day, I experienced a Gand mal seizure. Later learned, I'd had several smaller
seizures after the ambulance service was called. I was hospitalized for about five days. Before
being discharged I was visited by my local pretrial supervisor, Mr. Stuart Chavis. After being
discharged I was advised by my attorney that I needed to provide hospital documents
confirming I'd been hospitalized and why. I provided the information as required, which
included ambulance report, plus emergency room and extended stay treatment records.
Several days after the initial May hospitalization, I experienced another series of seizures and
was hospitalized again for about a week. On about May 28, 2013, the day following my
hospital discharge, I was arrested by the U.S. Marshall Service at my residence per court order
issued by Judge Rosenblatt. The order my arrest was issued for not being present for the May
6th hearing, though I'd provided ample documentation confirming I'd had a seizure at the airport
and was hospitalized. It was the beginning of about a three week prisoner transport back to
Arizona. I was hospitalized again for one week while awaiting transport from Oklahoma to
Arizona. After arriving to Arizona, about June 19 th, I was admitted to the detention center
hospital were I was treated for about two weeks. In short; on about July 16, 2013, I appeared
before Judge Duncan. He'd ascertained and determined that I'd not been in violation in any
way. Demonstrated by him ordering my release and allowing me to return back to Michigan. He
also removed a previous stipulation for house arrest and GPS monitoring, which I perceived to
be a gesture of apology, as well as an acknowledgment of trust. I continue to greatly
appreciate Judge Duncan's “just” assessment and ruling. Trial was continued until December
19, 2013. There was a subsequent continuance until March 25, 2014.


On January 4, 2014, I ask my attorney to file a motion with Judge Duncan requesting
modification of my release order transaction amount from $500 to $1,500 or more. In part, so
that I could prepare financially for trail travel to Arizona and lodging during trial. I provided him
the names and contact information of two financial services entities allowing me opportunity to
earn income. In short, on January 6, 2014, I received an email from my attorney conveying that
the prosecutor objects to me working in the financial services industry. He further suggested
that I consider other options. Fact is; there is no stipulation in my release order restricting me
from earning an income in the financial services industry. In short, on January 29, 2014, a
motion hearing took place which I attended telephonically before Judge Rosenblatt. He denied
the motion, and accelerated a status hearing from March 9, 2014 to March 4, 2014, giving me
one week less time to raise funds for travel to Arizona financially prepared for lodging during an
estimated three week trial. Judge Rosenblatt made it clear, that should I appear without the
ability to pay for lodging, my release order would be revoked and I'd be taken into custody.

In closing; to date; none of the ten plus witnesses I provided have been subpenaed. Some who've
expressed their willingness to testify in my behalf. Likewise, none of the two hundred plus documents I
provided to my initial attorney, the prosecutor and my current attorney that directly contradict
allegations against me were included in discovery. And disappointingly, my current attorney, from time
he was assigned until after the 01/29/14 hearing, had avoided every request I'd made for him to
address these concerns. To date, nothing has changed. Still, none of my witnesses have been
subpenaed, and my evidence not disclosed by the prosecutor in discovery remains unaddressed.
Going to trial with no witnesses subpenaed and evidence substantiating my innocence excluded for
discovery, I feel like a sheep headed to slaughter. Proclaiming my innocence is not the purpose of this
letter. I'm just making you aware of events I believe have been violations of my right for due process
and fair trial. I'm reaching out for help. I have a prepared media package, for in the event all else fails.
I trust God for my vindication and future of my family. But, I'm deeply concerned as to the outcome,
with the absence of fairness, due process. For a more complete picture, at your convenience, please
review this correspondence in it's entire. I would gladly allow authentication of emails and letters by
any means you may deem necessary. Much of what I've conveyed herein is a matter of court records.
Thank you in advance for your consideration.
Blessed regards,
[Will G. Woodard]
(517) 853-8133
Robin C. Ashton, Counsel
Office of Professional Responsibility
950 Pennsylvania Avenue, N.W., Suite 3266
Washington, DC 20530-0001
February 5, 2014

Re: Complaint:- Court Case#: CR10-1721-002-PHX-PGR

Dear Ms. Ashton;
I hope you're doing well. This my second to request help.
My name is Willie Gene Woodard, I am co-defendant in a case which is set to commence being heard
in the court of Honorable Judge Rosenblatt, in Phoenix, March 25, 2014. I realize you're a busy. I will
purpose not take up much of your time with this letter. I've included for your review, supportive
correspondence which will help give clarity to the case related concerns briefly addressed herein.
I kindly ask, and pray, that once you've read this letter and reviewed the accompanying related
correspondence, you would look into the matters addressed. I'm making this request because I have
significant reason to believe my right to due process and fair trial is being continuously violated.
I've given this contact with you careful consideration and have done a significant amount of law
research, which includes consulting with a number of reputable law firms. I've also sought the
assistance of well known justice advocacy and civil rights organizations. In short, I've been purposely
mindful to not be presumptuous and not be over-reactive. It's after much observation and disturbing
realization that I've decided to communicate these concerns to you, a higher level of the court. This
correspondence with you, in it's entire, will convey my verifiable experience pertaining to my case. I'll
just address events as per the manner they occurred.
The following are a few reasons I believe my right to due process and fair trial are being violated:
 About mid August 2011, I was arraigned on an initial indictment before Honorable Judge
Duncan and at that time was provided court-appointed legal counsel, Mr. Roger T. Margolis. I pleaded
not guilty to the charges. While during the hearing was still in process, my appointed counsel
commenced to suggest to me that I should consider taking a plea deal. There was no inquiry from him
as to my guilt or innocence. No inquiry as to evidence I had to substantiate my innocence. No
indication from him as to any plan to discuss my case. My reply was that I was not guilty of the
charges. He responded by indicating; that he and I was already getting off to a bad start. That was a
very disturbing moment.

 On September 13, 2011; I appeared in court for a detention release hearing before Honorable
Judge Duncan and he granted release on my own recognizance. At that time I indicated to Mr.
Margolis that upon my arrival in Michigan I would send him the evidence supporting my innocence.
Again, Mr. Margolis expressed that I consider taking a plea deal and to hold-off on sending him any
information until he instructed me to do so. With Trial scheduled for July 2012, it was not until midMarch 2012, that Mr. Margolis agreed to me sending him my exculpatory evidence files. I provided Mr.
Margolis approximately two hundred evidence documents, some directly contradicting the indictment
claims against me. Along with the evidence documents, I provided a ten person witness list. After
sending my evidence and witness list, I inquired a number of times with Mr. Margolis as to the status
of his review and witness contact. His response was he'd not had time and/or staff to yet complete a
review.
 In May 2012, Mr. Margolis presented me a plea offer. He warned me there would be a
superseding indictment if I declined. I declined the offer. And on June 5, 2012, I appeared
before Honorable Judge Burns for arraignment on a superseding indictment, which turned out
to also be a settlement hearing. Prior to the hearing, while in private conference with Margolis,
he informed me that a particular business associate was going to be a government witness
and what the party would testify to. Immediately I presented Mr. Margolis documents that
contradicted the intended testimony. Mr. Margolis responded with the question; “were these
documents among the those you sent me?” I replied yes they were. I pleaded not guilty and
again declined the plea offer. I also expressed to Judge Burns that I no longer wanted to be
represented by Mr. Margolis. In short; after sending a letter to Judge Rosenblatt expressing
concerns about my defense representation, I was allowed to become Pro Se as I'd requested.
Upon Judge Rosenblatt granting Pro Se representation, he assigned me advisory counsel, Mr.
David L. Lockhart. Trial date was continued to 11/2012. I returned to Michigan.


October 1, 2012, after having consultation with two reputable law firms, I filed motion Pro Se
for; “Court to conduct an in camera inspection of the Grand Jury minutes and certain Grand
Jury materials. On October 15, 2012, I appeared telephonic-ally for a status hearing. That day
I'd just been discharged from a Michigan hospital after several days of hospitalization. Judge
Rosenblatt during the “status hearing”, indicated that my motion for “In Camera Inspection of
Grand Jury Minutes” was improperly filed, when in fact I'd followed explicitly the filing
instruction provided to me by the Court's Clerk office. I need add; that prior to filing motion for
Inspection of Grand Jury Minutes, I'd filed two other motions which Judge Rosenblatt granted.
In short; during the October 15 status hearing, Judge Rosenblatt insisted that the attorney
who'd been assigned as my advisory counsel, David L. Lockhart, be appointed my defense
counsel. Furthermore, Judge Rosenblatt suggested to Mr. Lockhart that as my newly appointed
counsel he withdraw my motion for “In Camera Inspection of Grand Jury Minutes.” In short,
Judge Rosenblatt denied me the right to continue as Pro Se representation and had my motion
for “Inspection of Grand Jury Minutes” withdrawn. Trail was continued until May 2013.



Mr. Lockhart sent me an email on December 30, 2012. I viewed the email about January 5,
2013 and replied to him with the attached letter dated January 9, 2013. Mr. Lockhart didn't
reply until February 2nd, when making me aware of a February 6th status hearing. I had to
attend the hearing telephonic-ally due to recent hospitalization. On March 22nd Mr. Lockhart
met with me in Michigan for about a five hour meeting. It was during the meeting that I was
informed for the first time that the trail date was scheduled for May 7, 2013. Mr. Lockhart gave
me a disc of discovery evidence that he'd just days before received from the prosecutor. He
instructed me to review and select documents from the disc that I wanted to use in my
defense. After reviewing the disc I discovered that only several of the two hundred plus
documents I'd provided to the prosecutor August 31, 2012, when I was Pro Se, were on the
disc. The documents that I'd provided the prosecutor that directly contradicted the conspiracy
claim were not on the disc. I made Mr. Lockhart aware that the reciprocal discovery I'd
provided the prosecutor wasn't on the disc. On March 23 2013, I commenced emailing Mr.
Lockhart the information I'd previously provided Mr. Margolis, Mr. Rapp and him. Mr. Lockhart
did not reply to my emails until March 28, with the following question; “Good morning Mr.
Woodard. Have you ever given this information to Mr. Margolis or Mr. Rapp previously,
including your witness list and the qualifications of any potential expert witness?” My March 28
reply to Mr. Lockhart was as follows: “Hi David, I've given Mr. Rapp and Mr. Margolis the same
evidence I've given you. Mr. Margolis was also given the witness list, with exception of expert
witness.” To date, none of my witnesses have been subpenaed, and there's been no further
response to my inquiries about the undisclosed evidence.



On May 5, 2013, while at the airport to board a flight to Arizona and attend a status hearing the
following day, I experienced a Gand mal seizure. Later learned, I'd had several smaller
seizures after the ambulance service was called. I was hospitalized for about five days. Before
being discharged I was visited by my local pretrial supervisor, Mr. Stuart Chavis. After being
discharged I was advised by my attorney that I needed to provide hospital documents
confirming I'd been hospitalized and why. I provided the information as required, which
included ambulance report, plus emergency room and extended stay treatment records.
Several days after the initial May hospitalization, I experienced another series of seizures and
was hospitalized again for about a week. On about May 28, 2013, the day following my
hospital discharge, I was arrested by the U.S. Marshall Service at my residence per court order
issued by Judge Rosenblatt. The order my arrest was issued for not being present for the May
6th hearing, though I'd provided ample documentation confirming I'd had a seizure at the airport
and was hospitalized. It was the beginning of about a three week prisoner transport back to
Arizona. I was hospitalized again for one week while awaiting transport from Oklahoma to
Arizona. After arriving to Arizona, about June 19 th, I was admitted to the detention center
hospital were I was treated for about two weeks. In short; on about July 16, 2013, I appeared
before Judge Duncan. He'd ascertained and determined that I'd not been in violation in any
way. Demonstrated by him ordering my release and allowing me to return back to Michigan. He
also removed a previous stipulation for house arrest and GPS monitoring, which I perceived to
be a gesture of apology, as well as an acknowledgment of trust. I continue to greatly
appreciate Judge Duncan's “just” assessment and ruling. Trial was continued until December
19, 2013. There was a subsequent continuance until March 25, 2014.


On January 4, 2014, I ask my attorney to file a motion with Judge Duncan requesting
modification of my release order transaction amount from $500 to $1,500 or more. In part, so
that I could prepare financially for trail travel to Arizona and lodging during trial. I provided him
the names and contact information of two financial services entities allowing me opportunity to
earn income. In short, on January 6, 2014, I received an email from my attorney conveying that
the prosecutor objects to me working in the financial services industry. He further suggested
that I consider other options. Fact is; there is no stipulation in my release order restricting me
from earning an income in the financial services industry. In short, on January 29, 2014, a
motion hearing took place which I attended telephonically before Judge Rosenblatt. He denied
the motion, and accelerated a status hearing from March 9, 2014 to March 4, 2014, giving me
one week less time to raise funds for travel to Arizona financially prepared for lodging during an
estimated three week trial. Judge Rosenblatt made it clear, that should I appear without the
ability to pay for lodging, my release order would be revoked and I'd be taken into custody.

In closing; to date; none of the ten plus witnesses I provided have been subpenaed. Some who've
expressed their willingness to testify in my behalf. Likewise, none of the two hundred plus documents I
provided to my initial attorney, the prosecutor and my current attorney that directly contradict
allegations against me were included in discovery. And disappointingly, my current attorney, from time
he was assigned until after the 01/29/14 hearing, had avoided every request I'd made for him to
address these concerns. To date, nothing has changed. Still, none of my witnesses have been
subpenaed, and my evidence not disclosed by the prosecutor in discovery remains unaddressed.
Going to trial with no witnesses subpenaed and evidence substantiating my innocence excluded for
discovery, I feel like a sheep headed to slaughter. Proclaiming my innocence is not the purpose of this
letter. I'm just making you aware of events I believe have been violations of my right for due process
and fair trial. I'm reaching out for help. I have a prepared media package, for in the event all else fails.
I trust God for my vindication and future of my family. But, I'm deeply concerned as to the outcome,
with the absence of fairness, due process. For a more complete picture, at your convenience, please
review this correspondence in it's entire. I would gladly allow authentication of emails and letters by
any means you may deem necessary. Much of what I've conveyed herein is a matter of court records.
Thank you in advance for your consideration.
Blessed regards,
[Will G. Woodard]
(517) 853-8133
HONORABLE PAUL G. ROSENBLATT
United States District Court
Sandra Day O’Connor U.S. Courthouse, Suite 621
401 West Washington Street, SPC 56
Phoenix, AZ 85003-2156
April 14, 2013
Dear Honorable Judge Rosenblatt,
Hope you're doing well.
I'm convinced it's necessary that I have this communication with you. I'll get right to the point as to not take
up much of your time.
For multiple reasons, I have had increasing concern regarding the defense representation of my court
appointed legal counsel, Mr. David Lockhart. I've lost all confidence and trust that he is committal and
adequately representing. This will not be lengthy letter of me passing judgment in that regards. I will note
the following in order to establish a basis for my request to express my concerns during the coming hearing:
1) During the hearing on March 6, Mr. Lockhart gave the court the impression that evaluating my case was
some how delayed or hindered by my residing outside of Arizona. Fact is, when he was appointed as my
counsel October 2012, he advised me that he had existing cases to complete and would notify me as when
we could discus my case. Mr. Lockhart next communicated with me by email on December 30, 2012.
2) After viewing Mr. Lockharts email about January 5, 2013, I replied to him with the attached letter. I
received no reply after sending the letter and leaving phone messages. Mr. Lockhart didn't communicate
with me again until February 2nd, when making me aware of the February 6th status hearing.
3) Mr. Lockhart met with me in Michigan on March 22 for about a five hour meeting. The meeting, as
expected consisted mostly of conversation pertaining to the case, and we had a meal. There was no more
done at the meeting than what could have been accomplished by a couple phone calls. I was provided no
documentation, and I've yet to receive promised copies of documents Mr. Lockhart had with him at time of
the meeting. Also, at the March 22 meeting that I was informed for the first time that the trail date was
scheduled for May 7. I appreciated Mr. Lockhart coming to Michigan to meet with me, but there little
accomplished.
4) Near conclusion of the March 22 meeting, Mr. Lockhart advised me that the government had provided
him a disc with all discovery evidence for trial just few days prior to him leaving Arizona to come to
Michigan Mr. Lockhart instructed me to review and select documents from the disc that I wanted to use in
my defense. After reviewing the disc I discovered that only few of the 300 plus documents I'd provided to
the government August 31, 2012, when I was Pro Se, were on the disc. The documents I'd provided the
government that directly contradicted the governments conspiracy claim were not on the disc. I made Mr.
Lockhart aware that this reciprocal (exculpatory evidence) I'd provided the government wasn't on the disc.
5) On March 23, I commenced emailing Mr. Lockhart the exculpatory evidence I'd provided the
government and to Mr. Margolis as well. Mr. Lockhart did not reply to my emails until March 28, with the
following question: “Good morning Mr. Woodard. Have you ever given this information to Mr. Margolis or
Mr. Rapp previously, including your witness list and the qualifications of any potential expert witness?” My
March 28 reply to Mr. Lockhart was as follows: “Hi David, I've given Mr. Rapp and Mr. Margolis the same
evidence I've given you. Mr. Margolis was also given the witness list, with the exception of expert witness.”
6) Mr. Lockhart did not communicate with me again until April 2, with the following message: “Good
afternoon Mr. Woodard. Please see attached. Thank you.”
Attached were the following two government motion documents filed April 1: “Supplemental MOTION in
Limine to Determine Admissibility of Evidence” and “Motion to Dismiss Counts”. Mr. Lockhart gave me
no explanation as to the meaning of the government motions. I literally had to contact a friend who's an
attorney to explain the motions to me. Mr. Lockhart has yet to address the motions.
7) After Mr. Lockhart's and my April 2 exchange of emails, Mr. Lockhart did not communicate with me
again until April 10. He made no mention of my exculpatory evidence nor my witness list in that
communication. Just a long explanation about research he was supposedly doing. His message on the April
10 was as follows:
“Good morning Mr. Woodard. Please be advised that I have passed on your witness list to DK and he will
be following up with these individuals and attempt to evaluate what, if anything of value they can offer to
assist you at trial. Be advised that Mr. Rapp intends to call Mr. Olivas and Mr. Sizemore as witnesses at
trial. Because of some of the responses that I have been receiving from you regarding questions I have
recently asked you, I think this would be an appropriate time to discuss trial strategy/defense.
It is my opinion and intention to put forth a defense that you too were “duped.” This means that you were
unaware of the fact that the Greek Trust (GT) did not exist and all the steps you took as the POF facilitator
were appropriate as you received much of your direction from the ultimate fraud schemer, Louis Pihatkis
aka Michael Louis. It was not until you realized/discovered that the GT did not exist, that you began to
remove yourself from your role as the POF facilitator and attempted to refund the victims their monies.
If I am mistaken, please let me know immediately. However, be advised that the attorney, I get to decide
trial strategy, not the client. I obviously have to remain in contact with you and be able to communicate
with you, but the final decision as to what defense we are going to put forth, is mine to make with your
input. Thank you. David L. Lockhart, Esq.”
I believe Mr. Lockhart was sincere in this communication, but something happen to that brought about an
adverse change his subsequent email communication.
8) On April 11, I was informed by my pretrial supervisor hear in Michigan, that there was a scheduled
hearing for Monday April 15. Mr. Lockhart had not made made me aware of the hearing, and when I
inquired with him about it, I received the following two emails on the April 11:
A) “Good evening Mr. Woodard. Regarding the Court date, I will confirm tomorrow with you.
Also, I need to know exactly where you will be staying in AZ when you arrive in May. Please be advised
that I can secure funds for your flight from Michigan to Arizona. However, the Court will not authorize
payment for lodging, transportation or food. Thus, you will be responsible for all of the aforementioned.
Thank you.”
B) “Regarding the "exculpatory" evidence you disclosed to Mr. Rapp, be advised that the government
has acknowledged their receipt of what you have provided to them to me.”
9) On April 12, Mr. Lockhart sent me the following email:
“Good morning Mr. Woodard. Please be advised that a Final Trial Management Conference is scheduled
for this Monday, April 15, 2013 at 10:30 a.m. before Judge Rosenblatt. You will need to call in. A Final
Trial Management Conference is exactly what it says. We will be discussing final issues regarding our
preparedness for trial. You will need to be ready to tell the Court where you will be residing while you are
in AZ. Further, if you have medical issues that require hospitalization, you will need to be prepared to
provide documentation to the court. Will follow up with you throughout the day and weekend. Thank you.”
I've yet to receive any further communication from Mr. Lockhart, as of sending this letter to you.
Your Honor, I believe that Mr. Lockhart had no intention of making me aware of the April 15 hearing so
that I would not have opportunity to voice what I've expressed in this letter. Both, what I've expressed about
how he's handled my case, and the government's non disclosure of exculpatory evidence I provided. Mr.
Lockhart not addressing the undisclosed exculpatory evidence until after I'd become aware of the April 15
hearing is particularly disturbing, as well as convincing it was intended that I not be aware of the hearing.
Also, Mr. Lockhart has indicated that he'd made effort to contact certain parties on the ten person witness
list I provided him. But parties have expressed that they've talk with no one nor have had a message left
from anyone concerning my case. I've also provided Mr. Lockhart contact information for an expert witness
with over ten years in the “proof of funds” industry and has a very credible reputation. But Mr. Lockhart
expressed that if I don't know the expert witness personally he would not subpena him as a witness. Since
when must a defendant know an expert witness personally for them to give expert testimony?
I could go on Your Honor, but hopefully I've shared enough for you to see why I'm concerned about my
defense representation. The concern causes a disturbing question; how could I have a fair trial if the
government prevents the admitting of my exculpatory evidence and my defense counsel not subpena
witnesses to testify in my behalf?
In closing; all that I've expressed herein can be authenticated in my email account. I will allow
authentication by any means you may deem necessary. I've provided you this summation letter and the
accompanying aforementioned letters of communication with Mr. Lockhart and the government for your
consideration. And, I kindly ask that I have opportunity to express my concerns during the forthcoming
hearing
Thanks for your time, and blessed regards,
Will G. Woodard
(517) 853-8133
HONORABLE PAUL G. ROSENBLATT
United States District Court
Sandra Day O’Connor U.S. Courthouse, Suite 621
401 West Washington Street, SPC 56
Phoenix, AZ 85003-2156
June 12, 2012
Dear Honorable Judge Rosenblatt;
My name is Willie Gene Woodard, I am co-defendant in a case, which is set to be heard in your court. I
realize you are a busy man, therefore, I will not take up much of your time with this letter.
The purpose of this communication is to make you aware of concerns I have regarding the defense
representation of my court appointed legal counsel, Mr. Roger T. Margolis. I'd like to also request a
Marsdens Hearing as well in this matter. I'm making this request because I have significant reasons to
believe that I am not being competently or adequately represented by my current legal counsel.
I am writing this letter after careful consideration. I've been purposely mindful to not prematurely
express my concerns to the court and not over-react as well. It's after much observation and disturbing
discovery that I've decided to communicate these concerns to you.
Until the “Settlement Conference” you ordered, which was conducted on June 5, 2012, I'd given my
court-appointed attorney extended benefit of the doubt. However, he and I had a brief meeting prior to
the Settlement Conference. In that meeting my doubt about not having competent or adequate legal
defense representation was confirmed. Consequently, I expressed my concerns to Honorable Judge
Burns during the Settlement Conference. She indicated I had the options of making the motion for
another court-appointed attorney, hiring an attorney or representing myself.
The following are few of the reasons that I am certain that I have not been competently or adequately
represented by my current court-appointed legal counsel:
•

About late August 2011, I was arraigned on the initial indictment before Honorable Judge
Duncan and my current legal counsel was appointed. While in that hearing my counsel
commenced to suggest to me that I should consider taking a Plea Deal. There was no inquiry
from him as to my guilt or innocence. No inquiry as to evidence I have to substantiate my
innocence. No indication from him as to any plan to discuss my case. My reply was that I'm not
guilty of the charges. He responded by indicating; that he and I was already getting off to a bad
start. That was a disturbing moment.

•

On September 13, 2011; I appeared in court for a detention release hearing before Honorable
Judge Duncan and he granted release on my own recognizance. To that date, still there had been
no defense discussion about my case and no indication as to when there would be. Before
leaving the court room I indicated to my legal counsel that upon my arrival in Michigan I would
send him the evidence supporting my innocence. He indicated that I hold-off on sending him
any information until he instructed me to do so. Suggesting again that I consider a Plea Deal.
•

A condition of my September 13, 2011 release from detention, was that I contact my legal
counsel every Friday, which I've diligently complied with. From the first Friday of my release
to date, my legal counsel and I have had about seven phone conversations. In short, of about
forty calls I've made to my legal counsel, thirty plus calls were not answered and not returned.

•

Of the several phone conversations I've had with my counsel since September 13, 2011, my
counsel initiated about three calls. One call was between last Christmas and New Years. On that
call I again inquired as to when I could send him my evidence for his review. He expressed he
would seek court funding to meet with me in Michigan. My counsel initiated a second call to
me about March 30, 2012. He requested my email address so that he could email me the
Prosecutor's Plea Offer. He initiated a third call in May 2012 to inform me of the hearing in
your court regarding his motion for funding so he could hire an investigator and a paralegal.

•

My legal counsel, since September 13, 2011 has returned about four phone calls; first returned
call was about September 30, 2011 and he inquired as to my health. Again I asked him about
sending my evidence and again he suggested I hold-off sending it. Also, again he suggested I
consider accepting a Plea Offer. Second returned call was March 16, 2012. In this conversation
I insisted adamantly that he focus on defending me and review my evidence information. He
provided me his email address and warned that a second indictment could be the consequence
of me not accepting a Plea Offer. My legal counsel also returned a call last week of May 2012.
He inform me of the Settlement Conference and the Prosecutor's second indictment filing.

•

About four days after my counsel made me aware of the second indictment, I received a copy of
it from him via postal mail. I called my counsel and pointed out that the co-defendant's
activities prior to my acquaintance with him was included in the second indictment against me.
Likewise, was the co-defendant's release violation activities indicated in the second indictment
against me. On that call my counsel informed me that he wasn't aware that the allegations were
in the indictment and frustrated by my inquiring as how and why the inclusion. I (again), had to
resort to getting free telephone consultation from other attorneys, in order to get a better
understanding of certain particular aspects of my case.

•

On June 5, 2012, in a brief meeting prior to the Settlement and arraignment hearings, my
counsel indicated that the Prosecutor was not accounting the aforementioned alleged release
violation activities of the co-defendant against me. And again my counsel adamantly resumed
his insistence that I accept the Plea Offer. Warning me; that if I go to trial I would face “a jury
of twelve retired Arizonians”. I will not elaborate on what I perceived him to be implying. I
presented evidence to my counsel for discussion. He didn't recognize the evidence as being
among the information I'd sent him previously. In short, in that meeting my concern about not
being competently or adequately represented by my legal counsel was undoubtedly solidified. I
expressed this concern in the hearing before Honorable Judge Burns.
Your Honor, I would also like to express; that I'm concerned that should I have a trial jointly with the
co-defendant, I would likely not receive a fair trial. I have no criminal history and have complied with
every aspect of my September 13, 2011 release order. The co-defendant has alleged criminal activities
prior to my acquaintance with him and has alleged activities thru April 2012. These allegations were
included in the superseding indictment against me. Therefore, even if the Prosecutor provided jury
instructions to not account these allegations against me, I would still be subject to a jury being
inadvertently prejudiced against me because of the co-defendant's alleged activities. In short, I'm
concerned that me not having a fair trial would be inevitably, if I have joint trial with the co-defendant.
I have asked my legal counsel to file a motion for a separate trial. However, as far as I know, still this
motion has not been filed. And I believe that Mr. Margolis would not have likely filed this motion since
I've expressed my concerns about being represented by him before Honorable Judge Burns. If he has
filed motion for separate trial, then my apology for taking up your time and thoughts with this
particular concern.
I would like to also express, that I'm willing to take a Polygraph Test regarding the content of this letter.
Likewise, I'm willing to take a Polygraph with regards to my being innocent of the “Conspiracy” and
thereby the related charges against me. However, should I have to go to trial, I would do so prayerfully
trusting that the truth would prevail and I'd be vindicated. I'm hoping to have not only my freedom
back, but my good name as well. Most importantly, I'm trusting that the agonizing separation from my
wife and two young kids in the Philippines will come to an end.
Your Honor, in closing; I can not afford to hire an attorney and would rather represent myself than have
another appointed counsel. Therefore, if I am to go to trial, I would like to exercise the option presented
by Honorable Judge Burns- to represent myself. I could arrange with relatives to relocate in Phoenix so
that I not have to travel from Michigan to adequately comply with any court appearance obligations.
I'd greatly appreciate your time and consideration of the concerns addressed herein.
Thank you and blessed regards,

Will G. Woodard
7425 Chapel Hill Dr.
Lansing, MI 48917
(517) 853-8133
cc:
Mr. Roger T. Margolis (Attorney)
Mr. Kevin Rapp (USAAZ)
David L. Lockhart, Esq.
2601 N. 16th Street
Phoenix, Arizona 85006
February 3, 2014

Good day, Mr. Lockhart, this letter is in reply to your 01/30/14 email.
Anthony Laxen facilitated/arranged my leasing of client POF accounts. He was aware I paid nearly one
million dollars in initial cost and that there was ongoing cost to keep the accounts active. Mr. Laxen
earned a $25K commission for the Barclays POF and $10K or more for each of the three Bank of
America POFs. Estimated $55K in commissions was paid to Mr. Laxen by the POF providers.
The prosecutor claims I was aware the clients POFs were fake and fees paid to me was spent for
personal use. Wouldn't Mr. Laxen's testimony potentially cause "reasonable doubt" in the minds jurors
that I was aware the clients POFs were fake and paid no money for client POFs? I'd think reasonable
thinking people would ask themselves; why would the defendant pay nearly one million dollars to have
fake documents that could be created on a computer for nearly free? How could think say Mr. Laxen's
testimony would not assist me?
The client processors/referrers on my witness list had known Mr. Pahakis for five years plus and knew
him as "Micheal Louis", "Senior Trustee of a private Trust. They believed Mr. Pahakis was who he said
he was and referred their clients to the Trust for project funding. Likewise based on that belief, they
referred their clients to me to spend $400K to lease POF for the Trust funding. Wouldn't stand to reason
that if these client processors/referrers, could have been mislead by Mr. Pahakis, that the defendant
could have also been mislead?
The two client prospects on my witness list, Mr. Javraj and Mr. Lee, whom I turned away February
2010, can testify that they were prepared to pay me $400K each to lease POF for Trust Funding. They
can alos testify that I advised them to wait until after funding had commenced for existing clients
before spending money to lease POF. Don't you think jurors would wonder why the defendant would
turn away two prospects ready to pay him $400K each if the defendant's intent was to defraud?
In closing; everyone on the witness list I've provided you has testimony that would cause "reasonable
doubt" in the minds of jurors. All would testify to the truth if subpenaed knowing their expenses would
be covered. I kindly ask that you make a motion for the cost and expenses of these witnesses, as per
Federal Rule 17(b), as previously addressed. As it now stands, I have no witnesses subpenaed. Even
having reluctant witnesses testifying to the facts, would be better than having no witnesses at all to
testify.
Thanks in advance. Blessed regards.
[Will G. Woodard]
(517) 853-8133
P.S. I've filed a complaint with Miami FBI against JPierce Investments (James Pierce) in regards to me
being provided fake POF and a rigged authentication procedure. I'm expecting to have face to face
interview with local FBI agent, at which time I will provide them my transaction evidence.
David L. Lockhart, Esq.
2601 N. 16th Street
Phoenix, Arizona 85006
Mr. Lockhart, this letter is in reply to your email, 02/10/14.

February 10, 2014

The first two clients to receive POFs and pay a sublease allocation fee direct to my company, were ATL Holdings
and Mecca Construction. Both clients received their "Bank of America" POFs January 29, 2009. One year to
when I stopped accepting clients in February 2010. What do mean about the three years referenced in your
email? How could you be so off base about that after all this time? I will forward you the email in which the
clients POF documents were delivered. Both the email and the documents are dated January 29, 2009.
As to me having discussed law enforcement with a client; I never had conversation with any client trying to
dissuade them from contacting law enforcement. Law enforcement had in no way entered my mind until I
learned there was an investigation into the “Trust” late October 2010. It was a client that made me aware.
With regards to refunded clients; they were refunded from profit earned subleasing POFs. Should the clients had
placed monies with me for investment into an investment platform, i.e. stocks, bonds etc, then of course it would
have been improper for those funds to be used otherwise. But the clients made "payment" to me for the leasing
of a credit facility product- a POF allocation. Once the POF was confirmed, the payment was earned funds as
per contract. When an attorney is "paid" money for legal services, can't they use the money as they please?
As to my telling clients the project funding was imminent, it would have been a conveying of what was told to me
by the funding the Trust, (Mr. Louis). Fact is; clients, referrers and I received our funding updates from Mr. Louis.
I wanted the project funding to commence just as much or more than the clients did. The commencement of the
funding would have removed any refund liability. Secondly, the higher earnings for me would have been the
back-end POF management commissions to be earned from the project funding proceeds. I was to be paid an
average of about $10K per month, per client as the monthly project funding disbursements occurred for each
client over a twelve month funding period. A $120K per client annually per funded client.
Please see the attached two documents from a client transaction, Mr. Patrick Sizemore. The attached Allocation
Agreement confirms in the "escrow" section that when my company's contract requirements were met, the POF
“payment” was remitted from client's escrow to my company as a "fee payment". The attached letter confirms
Mr. Sizemore advised his client that my company had met it's requirements and the fee payment should be paid.
The allocation agreement also confirms that the clients were aware there was ongoing cost to keep their POFs
active. Likewise, it confirms that should there be request for refund, my company would "cause" the refund to
take place. That meant providing the clients written request to the Trust, (Mr. Louis).The same pertained to each
client transaction as to when the "fee payment" was earned as well as the refund policy. And as I've previously
expressed; Mr. Sizemore, a registered securities broker, authored the "Allocation Agreement". He also had Mr.
Louis to provide him a signed letter confirming the "Trust" was responsible for making refund of client POF fee.
Frankly, your email in part reads as though it come from the prosecutor given the exaggerated time-line and
false stories. How can you help me if what you believe is based on what's conveyed to you by the prosecutor?
What about the evidence I provided to the prosecutor that at the time you gave me their discovery the prosecutor
had not disclosed that evidence to you? This was evident by the email you sent me asking if I'd provided the
evidence I provided you to Mr. Margolis and Mr. Rapp. I informed you that I had, and you subsequently sent me
another email indicating Mr. Rapp said he had the documents in a file. To date, you've never addressed why my
evidence was in a “file” and excluded from discovery the prosecutor gave you and you gave me. Nonetheless,
God is causing the whole-truth to come into the light. This case is not just about me, it's more so about “Justice”.
Blessed regards,
[Will G. Woodard]
(517) 853-8133
David L. Lockhart, Esq.
2601 N. 16th Street
Phoenix, Arizona 85006
April 18, 2013
Mr. Lockhart,
This is a reply to your April 17, 2013 email.
Mr. Roman was Mr. Pihakis's banker and mine. He was the Paymaster for Marco Olivas's and
my joint venture. He was the Paymaster for client refunds I was generating. He is also aware
that Mr. Pihakis continued to use the POF documents with my company name after I'd
terminated business relationship with Mr Pihakis June 6, 2010. Mr. Roman altered me to what
Mr. Pihakis was doing with the documents. How would his testimony to be hearsay?
Mr. Lee was a prospective Greek Trust funding client that I urged not to pay monies for POF
and wait until after the Trust funding commence to proceed. I urged him of the same multiple
times. He continued to discuss funding with Mr. Pihakis up until the time Mr Pihakis was
arrested. I made him aware of Mr. Pihakis's arrest. How would his testimony to be hearsay?
If what these two witnesses could testify to would only be hearsay, then what the government
witnesses would testify to would also be hearsay. Most of the people on the government's
witness are people who have never communicated with me. In short, I don't know them and
they don't know me.
With regards to me coming to Arizona for the April 23 hearing; it was established in court that I
did not have funds to pay for airfare and that you would motion the court for those funds. Now
you tell me I have to pay my own airfare. If not for my daughter's tax refund money she just
received, which she desperately needs herself, me paying for airfare and lodging by April 23
would have been impossible- as what was previously established.
I will be there on the 23rd for the hearing. Likewise, will certain parties from two civil rights
organizations and certain investigative journalists from the following media list who have
already had attorneys to evaluated my evidence. They have concluded as you did, that I had
no criminal intentions in the client transactions. In short, the other attorneys concluded just as
you have expressed- I was "duped". http://theministerofjustice.blogspot.com/p/media-emailaddresses-this-page-of.html#.UW_ZGUo99Ko .
Mr. Lockhart, I've been deeply damaged and hurt by the prosecutors' violation of my right to
due process by not disclosing my exculpatory evidence and the continued false accusations
in court. However, the damage and hurt that I'm experiencing from you, supposedly my
defense representation, has taken the damage and hurt to a much higher level.
I can tell you now; that every time I’ve emailed you and the prosecutor "exculpatory"
information, it was also blind copied to certain organizations and investigative media parties.
Now I see why God has led me to do so, and immediately after the April 23 hearing, every
news agency in the U.S. will have the same information regardless of what happens to me at
the hearing this coming April 23.
It will be established (undoubtedly proven); the only "conspiracy" that has taken place, is the
collaboration of the prosecution and my defense representation to “rail-road” me into prison
for a crime both have evidence I didn't commit. You attested to my innocence in a previous
email communication. What happen? Why did you suddenly change from advocate to
adversary?
I "trusted" you, just as I trusted Mr. Pihakis. However, it's very clear now that I have again
misplaced my trust. But, as I've expressed to you and Mr. Rapp; God knows the whole truth,
and god will cause the whole truth to be exposed. Also, as I've expressed; ultimately the
battle is the Lord's- and TRUST HIM. He will never lose a battle. The truth has already made
me free, and it will soon be declared by the court.
Please be advised; should there be an appeal necessary to gain my freedom; the appeal is
already prepared and my defense representation already established. As far as I'm
concerned, you are already dismissed.
I will conclude with the following:
"No weapon that is formed against you will succeed; And every tongue that accuses you in
judgment through you will be condemned. This is the heritage of the servants of the LORD,
And their vindication is from Me, declares the LORD." --Isaiah 54:17
I believe this a promise from God that apples to all born again believers facing injustice who
TRUST in God. I believe God is faithful to watch over his word to perform it. What side of the
table will you be on when this happens? Regardless; I forgive you Mr. Lockhart, just as I've
forgiven Mr. Louis and Mr. Rapp. God's judgment however, is of course between God & you.
Blessed regards, Mr. Lockhart. [Will G. Woodard]
Mr. Lockhart email communication of April 17, 2013:
“Spoke with Mr. Roman and Mr. Lee. Both indicate that although you appear to be a good
man they cannot offer any information at trial that would be of assistance to you because
much of what they would have to offer would be hearsay.
As you may already know, hearsay, unless it falls under some exception, is not allowed into
evidence at trial.
Thank you.”
Mr. David L. Lockhart, Esq.
2601 N. 16th Street
Phoenix, Arizona 85006
January 9, 2013
Dear Mr. Lockhart,
Hope you and family are doing well- and also happy new year to you and your family.
As what was established in our last conversation, you had immediate cases to attend to before you'd have
opportunity to review my case. Therefore, I've been waiting to hear back from you. Thanks for the update.
However, the best way to reach me is by phone or by postal mail, still my vision is impaired from the last
series of seizures I've had. I check my email when my daughter comes over, which may be once a week.
Wish I could say that I've been rapidly recovering from my recent health challenges. But, fact is I haven't
regained full use of the left side of my body. I'm still receiving treatment for seizures and stroke. Getting
around is a challenge, consequently the state is finalizing medicaid approval for me to start receiving in
home health care. I anticipate the start of home medical service in January. As much as possible, I try not to
elaborate on negatives of my health condition. So hopefully, I've shared enough for you to get the picture.
In regards to the case; as I have briefly expressed in previous conversation, I've filed a complaint against
Mr. Rapp (the prosecutor) with the Department of Justice (DOJ). I've since been advised that my case is
being assigned to a DOJ investigator. The official investigation may commence in January. For your review,
I'll forward to you in a subsequent email, the files I've forwarded to the DOJ. BTW; I've been informed
there have been other party(s) to file complaint(s) with the DOJ against the prosecutor regarding this case.
I kindly ask that a thorough review of the information I will forward to you be where you start your review
of my case. Particularly, review of the indictment and my motion for in camera inspection of the Grand Jury
information. In doing so, you'd get right to the points with regards to documented information that
contradicts accusations the prosecutor made against me in the indictment. Much of it is exculpatory
information the prosecutor had in his possession at the time of the Grand Jury proceedings. You would also
be on the same page with the DOJ investigator, whom I'm certain will contact you during his investigation.
Mr. Lockhart; other attorneys have reviewed my case and concluded that there should be a motion for
inspection of the Grand Jury information, as what I'd filed. It's was expressed that I would likely not receive
aggressive defense representation from any local Phoenix attorney, particularly a court-appointed attorney.
That a local attorney may be more mindful of their future negotiation relationship with the prosecutor and
reluctant to cut to the chase. A motion inspection of Grand Jury information is warranted because there is
obvious defect of the indictment. The indictment specifically indicates, in terms of time frame, that I was a
co-conspirator with Mr. Pihakis from April 2006 thru April 2012. Documented fact is; the first POF client to
pay me for POF facilitation was not until December 2008. The indictment also implies that I violated my
10/13/11 pretrial release order, in that it specifically states Mr. Pihakis's and I conspired from “April 2006 to
April 2012”. If this statement was known to be true, then certainly my pretrial release would have been
revoked. Point is; the prosecutor knew it wasn't true when he made the accusation and the purpose of the
accusation was to influence the Grand Jury to indicate. How could such accusations not negatively
influence and prejudice a Grand Jury? There are other false statements noted in my Grand Jury motion,
that's also contradicted by information the prosecutor had in his possession during Grand Jury proceedings.
Likewise, filing of a motion for severing of defendants is warranted, because Mr. Pihakis has a three decade
criminal history and I have none. Mr. Pihakis allegedly engaged in criminal activities after his pretrial
release, December 2010 thru April 2012, which is in part why his release was revoked. It's quite obvious
that the prosecutor's intention is to use Mr. Pihakis's criminal activities against me. To overwhelm the Jury
with circumstantial transaction information and most of it has nothing to do with me. This fact is
demonstrated in the indictment itself and the witness list. Mr. Pihakis's history would unavoidably prejudice
any jury against me. There's little question that I would not receive a fair trial joined with Mr. Pihakis. And,
I'm convinced the prosecutor is more concerned about getting a conviction than he is about truth and justice.
Any attorney that can't see that after reviewing the aforesaid information, is one who's chosen not to. I don't
mean to be offensive nor imply anything about you or your intentions. I'm just being straight forward.
Mr. Lockhart, for almost two years I haven't had my freedom and have been separated from your wife and
kids. I've missed wedding anniversaries, birthdays of wife and kids, Christmas holidays, etc.. I've had to
endure extreme financial hardship that's caused significant suffering of my family.-- And, I didn't even
commit the crime I'm accused of- and the prosecutor has evidence of my innocence in his possession. This
unjust case has taken a significant toll on my health and my family. But, we will receive recompense for all.
In closing; my book that I've briefly told you about will be released in six to eight weeks, and, I’ve been
blessed with a movie deal- presently in the making. I want to establish a trust for client refunds and I'd like
to know if it should be something done in conjunction with the court. BTW, as you review the information I
will send you, you'll learn that at the time of my arrest I was in the process of facilitating the close of
transactions to pay me commissions, intended to cover the about $3.5 million dollars remaining in client
refunds. It would have been the successful conclusion of about an eleven month effort. The prosecutor is
aware of the transactions. Likewise, he's aware of my effort to facilitate alternative funding for the clients.
Furthermore, the prosecutor knows I accepted the last Trust Funding client February 2010, and turned away
all subsequent prospective clients. He knows I terminated business relationship with Mr. Pihakis June 2010.
He knows I've had no contact with Mr. Pihakis since December 2010. He knows that I was just as deceived
about the “Greek Trust” as the clients, their attorneys, their bankers and the other five finance professionals
facilitating and processing clients for the “Greek Trust” funding. He knows that I had no criminal intention
in the transactions. In short, Mr. Rapp had documented evidence of my innocence before he filed charges.
Whether it is, or is not, a common practice of Mr. Rapp, this case is much like P.A. misconduct occurrences
I've studied. The statistics of “Prosecutorial Misconduct” is saddening- and scary. I trust that God is using
my case to somehow help make a difference. Only on this premise, do I have any peace about it all. My
objective is not just to clear my name and regain freedom. I'll upload the aforesaid evidence files and send
you the download link in my following email. Meanwhile, please see the attached files for your review.
Thanks and blessed regards,
[Will G. Woodard]
7425 Chapel Hill Dr., #101
Lansing, Michigan 48917
Land line: (517) 853-8133
P.S. Mr. Lockhart, just so you know; I've forgiven Mr. Rapp, and Mr. Pihakis- I have no malice. I've placed
the case and all the related adversities on God's altar. Ultimately, the battle is the Lord's, and my confidence
is because of my trust in God. I know the financial blessings to be derived from my book and movie deals
are a part of God's provided recompense. And it regards to the case; how do we best defend against a well
funded “created case”? As what's been suggested by other law professionals, we cut to the chase regarding
defects of the indictment. Before we talk, I kindly ask that you study the evidence that I'll have to you
shortly. Also, I've made two ignored requests for a Polygraph, once to Mr. Margolis, and once in a letter to
Judge Rosenblatt. I am letting you know I want to take a polygraph. However, preferably NOT in Arizona.
God bless.
Mr. Kevin M. Rapp
40 N Central Ave Ste 1200
Phoenix, AZ 85004
Good day Mr. Rapp;

August 30, 2012

Hope you’re doing well.
Accompanying this cover letter is a partial provision of my Exculpatory Evidence information. There is
other of this information to be subpoenaed along with some intended witnesses. The attached information
consists of transaction documents and email communication exchanged between the clients and me. Some
of this information is said to have been provided to the investigating authorities by clients and thereby
should already be in your possession.
Other pertinent attached information is email and letter communication between Mr. Pihakis, others and me.
There is also email communication as well as contracts that were executed between multiple Proof of Funds
providers and me. This is Proof of Funds transaction information that you may or may not have depending
upon the extent of the investigation conducted by the authorities.
I will not take up your time or mine extensively reiterating my innocence of the conspiracy and related
charges. I'm inclined to believe you already suspect I was just as mislead and deceived about the “Trust” as
all other involved parties. The clients and Trust funding administrators. Regardless; I've got truth, innocence
and a trustworthy God on my side and no lies or wrong assumptions will prevail against my life, my family.
It's my hope and prayerful expectation that the information I'm providing you will answer any unanswered
questions you have and thereby eradicate any wrong assumptions you have made. I'm trusting you're a man
who has the integrity to concede to the truth of innocence when you have information that establishes
reasonable doubt of guilt. Regardless, my vindication will be publicly realized and my good reputation
duly restored. What your reputation will become in the process is subject to your integrity in the process.
I can't help but wonder how many fatherless homes there are in America because innocent men could not
afford adequate defense representation. And how many kids are fatherless because of prosecutors being
more determined to “get the conviction” than “get to the truth”. Over the past several weeks I've read about
families unjustly separated and thereby the kids made fatherless. It's sad to think that people entrusted to
uphold justice in society contributes to the injustice that's in society. No implication or disrespect intended.
Please note: I utilized software that converts web pages to PDF file when copying the attached email
communications. However, after I’d copied the majority of emails with the PDF software, I discovered JPG
software that rendered better quality. I recopied some of the email communication with the JPG software
that obviously needed recopying. However, should you come across PDF files that are difficult to read
please advise and I’ll gladly resend as JPG file. Also, I’d like to acknowledge that I’m willing to comply
with any process that may be deemed necessary to authenticate the attached email communications.
Should you have any questions and/or comments, please feel free to contact me direct by phone at (517)
853-8133, or by you may contact me by email at willgwoodard@gmail.com.
Thank you and blessed regards,
[Will G. Woodard]
Gmail - (Sent Registered) Willie Gene Woodard: Exculpatory Evidence Files https://mail.google.com/mail/u/0/?ui=2&ik=618d092be1&view=pt&q=rp...

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Will G. Woodard <willgwoodard@gmail.com>

(Sent Registered) Willie Gene Woodard: Exculpatory Evidence Files
3 messages
RPost Copy <DoNotReply@rpost.net>
To: willgwoodard@gmail.com

Fri, Aug 31, 2012 at 7:04 PM

THIS IS A COPY OF THE MESSAGE YOU SENT USING THE RMAIL SERVICE. YOU WILL RECEIVE A
REGISTERED RECEIPT EMAIL WITHIN TWO HOURS TO SERVE AS YOUR COMPLETE, VERIFIABLE
RECORD OF MESSAGE DELIVERY, CONTENT, AND TIME.

Good day Mr. Rapp;
The following links are collectively to a provision of my Exculpatory Evidenceinformation. Please click on each link to
download the individually titled zip files:
COVER LETTER: https://legaltrac.egnyte.com/h-s/20120831/537e52dafaf1429a
1) Mr.Pihakis: https://legaltrac.egnyte.com/h-s/20120831/d74dbd7c58ac4a07
2) JPierceE: https://legaltrac.egnyte.com/h-s/20120831/df1c02c3f24044b9
3) Master POF: https://legaltrac.egnyte.com/h-s/20120831/7cd652735804484e
4) Client Refunds: https://legaltrac.egnyte.com/h-s/20120831/10f4a4283aa44017
5) Other Related: https://legaltrac.egnyte.com/h-s/20120831/04c217332ea1430b
Shouldyou have any questions and/or comments, please feel free to contactme direct by phone at (517) 853-8133,
or by you may contact me byemail at willgwoodard@gmail.com.
Thankyou and blessed regards,
[WillG. Woodard]

MrRAPP.COVERLETTER.pdf
58K
RPost Copy <DoNotReply@rpost.net>
To: willgwoodard@gmail.com

Fri, Aug 31, 2012 at 7:23 PM

2/25/2014 2:38 AM
Gmail - (Sent Registered) Willie Gene Woodard: Exculpatory Evidence Files https://mail.google.com/mail/u/0/?ui=2&ik=618d092be1&view=pt&q=rp...

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[Quoted text hidden]

RPost Copy <DoNotReply@rpost.net>
To: willgwoodard@gmail.com

Fri, Aug 31, 2012 at 8:51 PM

THIS IS A COPY OF THE MESSAGE YOU SENT USING THE RMAIL SERVICE. YOU WILL RECEIVE A
REGISTERED RECEIPT EMAIL WITHIN TWO HOURS TO SERVE AS YOUR COMPLETE, VERIFIABLE
RECORD OF MESSAGE DELIVERY, CONTENT, AND TIME.

Good day Mr. Rapp;
The following links are collectively to a provision of my Exculpatory Evidence information. Please click on each link
to or copy and paste URL in browser to download the individually titled zip files:
COVER LETTER: https://legaltrac.egnyte.com/h-s/20120831/537e52dafaf1429a
1) Mr.Pihakis: https://legaltrac.egnyte.com/h-s/20120831/d74dbd7c58ac4a07
2) JPierceE: https://legaltrac.egnyte.com/h-s/20120831/df1c02c3f24044b9
3) Master POF: https://legaltrac.egnyte.com/h-s/20120831/7cd652735804484e
4) Client Refunds: https://legaltrac.egnyte.com/h-s/20120831/10f4a4283aa44017
5) Other Related: https://legaltrac.egnyte.com/h-s/20120831/04c217332ea1430b
Should you have any questions and/or comments, please feel free to contact me direct by phone at (517)
853-8133, or by you may contact me by email at willgwoodard@gmail.com.
Thank you and blessed regards,
[Will G. Woodard]

2/25/2014 2:38 AM
Gmail - Ack: Willie Gene Woodard: Exculpatory Evidence Files

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Will G. Woodard <willgwoodard@gmail.com>

Ack: Willie Gene Woodard: Exculpatory Evidence Files
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Fri, Aug 31, 2012 at 7:07 PM

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Willie Gene Woodard: Exculpatory Evidence Files

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  • 1.
    Assistant Attorney General CivilRights Division Criminal Section 950 Pennsylvania Avenue, Northwest Washington, DC 20530 March 3, 2014 Re: Complaint:- Court Case#: CR10-1721-002-PHX-PGR Dear Assistant Attorney General; I hope you're doing well. My name is Willie Gene Woodard, I am co-defendant in a case which is set to commence being heard in the court of Honorable Judge Rosenblatt, in Phoenix, March 25, 2014. I realize you're a busy. I will purpose not take up much of your time with this letter. I've included for your review, supportive correspondence which will help give clarity to the case related concerns briefly addressed herein. I kindly ask, and pray, that once you've read this letter and reviewed the accompanying related correspondence, you would look into the matters addressed. I'm making this request because I have significant reason to believe my right to due process and fair trial is being continuously violated. I've given this contact with you careful consideration and have done a significant amount of law research, which includes consulting with a number of reputable law firms. I've also sought the assistance of well known justice advocacy and civil rights organizations. In short, I've been purposely mindful to not be presumptuous and not be over-reactive. It's after much observation and disturbing realization that I've decided to communicate these concerns to you, the administration level of the justice system. This correspondence with you, in it's entire, will convey my verifiable experience pertaining to my case. I'll just address events as per the manner they occurred. The following are a few reasons I believe my right to due process and fair trial are being violated: • About mid August 2011, I was arraigned on an initial indictment before Honorable Judge Duncan and at that time was provided court-appointed legal counsel, Mr. Roger T. Margolis. I pleaded not guilty to the charges. While during the hearing was still in process, my appointed counsel commenced to suggest to me that I should consider taking a plea deal. There was no inquiry from him as to my guilt or innocence. No inquiry as to evidence I had to substantiate my innocence. No indication from him as to any plan to discuss my case. My reply was that I was not guilty of the charges. He responded by indicating; that he and I was already getting off to a bad start. That was a very disturbing moment. • On September 13, 2011; I appeared in court for a detention release hearing before Honorable Judge Duncan and he granted release on my own recognizance. At that time I indicated to Mr. Margolis that upon my arrival in Michigan I would send him the evidence supporting my innocence. Again, Mr. Margolis expressed that I consider taking a plea deal and to hold-off on sending him any information until he instructed me to do so. With Trial scheduled for July 2012, it was not until mid-March 2012, that Mr. Margolis agreed to me sending him my exculpatory evidence files. I provided Mr. Margolis approximately two hundred evidence documents, some directly contradicting the indictment claims against me. Along with the evidence documents, I provided a ten person witness list. After sending my evidence and witness list, I inquired a number of times with Mr. Margolis as to the status of his review and witness contact. His response was he'd not had time and/or staff to yet complete a review. • In May 2012, Mr. Margolis presented me a plea offer. He warned me there would be a superseding indictment if I declined. I declined the offer. And on June 5, 2012, I appeared before Honorable Judge Burns for arraignment on a superseding indictment, which turned out to also be a settlement hearing. Prior to the hearing, while in private conference with Margolis, he informed me that a particular business associate was going to be a government witness and what the party would
  • 2.
    testify to. ImmediatelyI presented Mr. Margolis documents that contradicted the intended testimony. Mr. Margolis responded with the question; “were these documents among the those you sent me?” I replied yes they were. I pleaded not guilty and again declined the plea offer. I also expressed to Judge Burns that I no longer wanted to be represented by Mr. Margolis. In short; after sending a letter to Judge Rosenblatt expressing concerns about my defense representation, I was allowed to become Pro Se as I'd requested. Upon Judge Rosenblatt granting Pro Se representation, he assigned me advisory counsel, Mr. David L. Lockhart. Trial date was continued to 11/2012. I returned to Michigan. • October 1, 2012, after having consultation with two reputable law firms, I filed motion Pro Se for; “Court to conduct an in camera inspection of the Grand Jury minutes and certain Grand Jury materials. On October 15, 2012, I appeared telephonic-ally for a status hearing. That day I'd just been discharged from a Michigan hospital after several days of hospitalization. Judge Rosenblatt during the “status hearing”, indicated that my motion for “In Camera Inspection of Grand Jury Minutes” was improperly filed, when in fact I'd followed explicitly the filing instruction provided to me by the Court's Clerk office. I need add; that prior to filing motion for Inspection of Grand Jury Minutes, I'd filed two other motions which Judge Rosenblatt granted. In short; during the October 15 status hearing, Judge Rosenblatt insisted that the attorney who'd been assigned as my advisory counsel, David L. Lockhart, be appointed my defense counsel. Furthermore, Judge Rosenblatt suggested to Mr. Lockhart that as my newly appointed counsel he withdraw my motion for “In Camera Inspection of Grand Jury Minutes.” In short, Judge Rosenblatt denied me the right to continue as Pro Se representation and had my motion for “Inspection of Grand Jury Minutes” withdrawn. Trail was continued until May 2013. • Mr. Lockhart sent me an email on December 30, 2012. I viewed the email about January 5, 2013 and replied to him with the attached letter dated January 9, 2013. Mr. Lockhart didn't reply until February 2nd, when making me aware of a February 6th status hearing. I had to attend the hearing telephonic-ally due to recent hospitalization. On March 22nd Mr. Lockhart met with me in Michigan for about a five hour meeting. It was during the meeting that I was informed for the first time that the trail date was scheduled for May 7, 2013. Mr. Lockhart gave me a disc of discovery evidence that he'd just days before received from the prosecutor. He instructed me to review and select documents from the disc that I wanted to use in my defense. After reviewing the disc I discovered that only several of the two hundred plus documents I'd provided to the prosecutor August 31, 2012, when I was Pro Se, were on the disc. The documents that I'd provided the prosecutor that directly contradicted the conspiracy claim were not on the disc. I made Mr. Lockhart aware that the reciprocal discovery I'd provided the prosecutor wasn't on the disc. On March 23 2013, I commenced emailing Mr. Lockhart the information I'd previously provided Mr. Margolis, Mr. Rapp and him. Mr. Lockhart did not reply to my emails until March 28, with the following question; “Good morning Mr. Woodard. Have you ever given this information to Mr. Margolis or Mr. Rapp previously, including your witness list and the qualifications of any potential expert witness?” My March 28 reply to Mr. Lockhart was as follows: “Hi David, I've given Mr. Rapp and Mr. Margolis the same evidence I've given you. Mr. Margolis was also given the witness list, with exception of expert witness.” To date, none of my witnesses have been subpenaed, and there's been no further response to my inquiries about the undisclosed evidence. • On May 5, 2013, while at the airport to board a flight to Arizona and attend a status hearing the following day, I experienced a Gand mal seizure. Later learned, I'd had several smaller seizures after the ambulance service was called. I was hospitalized for about five days. Before being discharged I was visited by my local pretrial supervisor, Mr. Stuart Chavis. After being discharged I was advised by my attorney that I needed to provide hospital documents confirming I'd been hospitalized and why. I provided the information as required, which included ambulance report, plus emergency room and extended stay treatment records. Several days after the initial May hospitalization, I experienced another series of seizures and was hospitalized again for about a week. On about May 28, 2013, the day following my hospital discharge, I was arrested by the U.S. Marshall Service at my residence per court order issued by Judge Rosenblatt. The order my arrest
  • 3.
    was issued fornot being present for the May 6th hearing, though I'd provided ample documentation confirming I'd had a seizure at the airport and was hospitalized. It was the beginning of about a three week prisoner transport back to Arizona. I was hospitalized again for one week while awaiting transport from Oklahoma to Arizona. After arriving to Arizona, about June 19th, I was admitted to the detention center hospital were I was treated for about two weeks. In short; on about July 16, 2013, I appeared before Judge Duncan. He'd ascertained and determined that I'd not been in violation in any way. Demonstrated by him ordering my release and allowing me to return back to Michigan. He also removed a previous stipulation for house arrest and GPS monitoring, which I perceived to be a gesture of apology, as well as an acknowledgment of trust. I continue to greatly appreciate Judge Duncan's “just” assessment and ruling. Trial was continued until December 19, 2013. There was a subsequent continuance until March 25, 2014. • On January 4, 2014, I ask my attorney to file a motion with Judge Duncan requesting modification of my release order transaction amount from $500 to $1,500 or more. In part, so that I could prepare financially for trail travel to Arizona and lodging during trial. I provided him the names and contact information of two financial services entities allowing me opportunity to earn income. In short, on January 6, 2014, I received an email from my attorney conveying that the prosecutor objects to me working in the financial services industry. He further suggested that I consider other options. Fact is; there is no stipulation in my release order restricting me from earning an income in the financial services industry. In short, on January 29, 2014, a motion hearing took place which I attended telephonically before Judge Rosenblatt. He denied the motion, and accelerated a status hearing from March 9, 2014 to March 4, 2014, giving me one week less time to raise funds for travel to Arizona financially prepared for lodging during an estimated three week trial. Judge Rosenblatt made it clear, that should I appear without the ability to pay for lodging, my release order would be revoked and I'd be taken into custody. • I was unable to appear for the March 4, 2014 hearing under doctor recommendation that I not travel until having a follow-up spinal examination. The examination took place today. Prior to today's appointment, the doctor provided me a letter recommending that I not travel, which I provided to the court via my pre-tial supervisors. However, I've just learned tonight, March 4, 2014, that Judge Rosenblatt issued a warrant for my arrest, in spite of the no travel letter I provided. In closing; to date; none of the ten plus witnesses I provided have been subpenaed. Some who've expressed their willingness to testify in my behalf. Likewise, none of the two hundred plus documents I provided to my initial attorney, the prosecutor and my current attorney that directly contradict allegations against me were included in discovery. To date, nothing has changed. Still, none of my witnesses have been subpenaed, and my evidence not disclosed by the prosecutor in discovery remains, to any effect, unaddressed. Going to trial with no witnesses subpenaed and evidence substantiating my innocence excluded for discovery, I feel like a sheep headed to slaughter. Proclaiming my innocence is not the purpose of this letter. I'm just making you aware of events I believe have been violations of my right for due process and fair trial. I'm reaching out for help. I trust God for my vindication and future of my family. However, I'm deeply concerned as to the journey prior to the expected outcome in the absence of due process. For a more complete picture, at your convenience, please review this correspondence in it's entire. I would gladly allow authentication of emails and letters by any means you may deem necessary. Much of what I've conveyed herein is a matter of court records. Thank you in advance for your consideration. Blessed regards, [Will G. Woodard] 7425 Chapel Hill Dr. #101 Lansing, Michigan 48917 willgwoodard@gmail.com Phone: (517) 853-8133
  • 4.
    Assistant Attorney General CivilRights Division Criminal Section 950 Pennsylvania Avenue, Northwest Washington, DC 20530 March 3, 2014 Re: Complaint:- Court Case#: CR10-1721-002-PHX-PGR Dear Assistant Attorney General; I hope you're doing well. As a supplement to the letter conveying concerns about my overall judicial experience, I've included for your review, this letter and accompanying registered email confirmation documents. This additional correspondence is to convey concerns specifically pertaining to prosecutor conduct. I kindly ask, and pray, that once you've read this letter and reviewed the accompanying related correspondence and any other evidence you may deem necessary, you would look into the matters addressed herein. I'm making this request because I have significant reason to believe my constitutional right to due process is being continuously violated by your assistant U.S. Attorneys, Mr. Kevin Rapp and Ms. Monica Klapper. To properly chronicle my experience as it pertains to the pre-trial process, I'll first reiterate that Judge Rosenblatt granted me Pro Se representation, about July 15, 2012. He also assigned attorney David L. Lockhart to act as my “advisory” counsel. About October 12, 2012 Mr. Lockhart was appointed my attorney. Pertaining to the reasons I believe my constitutional right to due process have been violated multiple times since July 2012, I'll address the violations pursuant to the manner I believe they have occurred. • On August 31, 2012; in response to Mr. Rapp's request (via Mr. Lockhart) for me to provide my “reciprocal discovery”, I sent by registered email direct to Mr. Rapp and Ms. Klapper a cover letter and download links to about five zip files collectively containing about two hundred exculpatory evidence files. I never received an acknowledgment from Mr. Rapp nor Ms. Klapper that they received the email. However, as aforesaid, I'd sent the email via a registered email service and have verifiable confirmation that both Mr. Rapp and Ms. Klapper received the email. See cover letter & registered email receipt attached. • From July 2012 thru about October 12, 2012, for the duration of my Pro Se representation, I was never provided discovery by Mr. Rapp. Ms. Klapper nor otherwise. This with there being a trial date scheduled at the time, for November 2012. In short, for about a four month period of time, as I was Pro Se, I was not provided discovery. Therefore, exculpatory evidence was never disclosed to me. • On about October 1, 2012, while I was Pro Se representation, Mr. Rapp/Ms. Klapper filed a Motion In Limine, which I received no notification of. In short, the motion was filed and I was never allowed opportunity to review it, object to it, nor otherwise address the motion. See attached Motion In Limine Mr. Rapp/Ms. Klapper filed April 2013, which addresses Limine motion filed October 2012. • On about October 12, 2012, Judge Rosenblatt appointed Mr. Lockhart to act as my defense counsel. On March 22, 2013 Mr. Lockhart met with me in Michigan. Upon the conclusion of our meeting, Mr. Lockhart gave me a CD disc he said was discovery that Mr. Rapp or Mr. Klapper had provided him about a day prior to him meeting with me on March 22, 2013. Mr. Lockhart instructed me to review the discovery for documents to use for trial. I discovered, that with exception of just several documents, none of the (200+-) exculpatory evidence files I'd provided to Mr. Rapp/Ms. Kappler on August 31, 2012 were on the disc. A file titled Woodard's Exculpatory Evidence, consisted of only about seven documents. About four of the documents did not even pertain to the
  • 5.
    case transactions. Theexculpatory evidence I'd provided to Mr. Rapp/Ms. Klapper was not entirely disclosed to my attorney. In short, there was failure to disclose exculpatory evidence to me as Pro Se July 2012 to October 2012. Subsequently, there was nondisclosure of exculpatory evidence to my attorney that Mr. Rapp/Ms. Klapper had in their possession. See aforesaid verification receipt. • To date, Mr. Rapp and Ms. Kappler have not provided a witness list as per “in a timely manner”. Thus, I've not been allowed my right to review the list. Likewise, not allowed my right to be provided information as to deals/concessions made with witnesses in exchange for testimony. In particular, this is pertaining to witnesses that were directly involved in the case related transactions. In Brady v. Maryland, 373 U.S. 83 (1963), the United States Supreme Court held that due process requires the prosecution to disclose evidence favorable to an accused when such evidence is material to guilt or punishment. The government’s obligation to disclose “Brady” evidence covers not only exculpatory evidence but also information that could be used to impeach government witnesses. Giglio v. United States, 405 U.S. 150 (1972). In particular, any agreement made with a government witness for testimony in exchange for a “deal” or other “favorable” treatment regarding criminal charges must be disclosed. As stated in United States v. Mitchell, 886 F.2d. 667, 670 (4th Cir. 1989). I trust God for truth and justice to prevail. Thereby, the assured good well-being of my family. However, I'm deeply concerned as to the journey prior to that outcome in the absence of due process. Pursuant to the Fourteenth and Fifth Amendments of the United State Constitution; I'm convinced my right to due process have been continuously violated. I am prepared to formally present to the national media, evidence of the violations. Likewise, present exculpatory evidence not disclosed by the prosecution, which contradicts allegations made by the prosecution in indictments and court proceeding. In conjunction with the media engagement, there would be legal action taken under the “Color of Law” provision of the U.S. Constitution. I want to emphasis; that this correspondence with you is not in any way intended to be a conveying of ultimatum. However, I am urgently purposing to not become another “wrongfully convicted” statistic. I trust you are not aware of the violations I've addressed herein. Thus, I'm informing you of my experience in hope you would conduct an investigation to determine if violations have occurred. Also, I'm requesting that you review my exculpatory evidence in it's entire, in conjunction, with review of the discovery Mr. Rapp/Ms. Klapper provided to my attorney about March 21, 2013. I have CD copy of the discovery in my possession. I kindly ask that you would review this correspondence in it's entire. Upon receiving notification from your office, I will provide you website links to download the exculpatory evidence zip files I provided to Mr. Rapp and Ms. Klapper on August 31, 2012. Please be advised; I will gladly allow authentication of all emails and documents by any means you may deem necessary. Thanks in advance, for your anticipated honorable consideration. Blessed regards, [Will G. Woodard] 7425 Chapel Hill Dr. #101 Lansing, Michigan 48917 willgwoodard@gmail.com Phone: (517) 853-8133
  • 6.
    JOHN S. LEONARDO UnitedStates Attorney Two Renaissance Square 40 N. Central Ave., Suite 1200 Phoenix, Arizona 85004 February 22, 2014 Re: Complaint:- Court Case#: CR10-1721-002-PHX-PGR Dear U.S. Attorney Leonardo; I hope you're doing well. My name is Willie Gene Woodard, I am co-defendant in a case which is set to commence being heard in the court of Honorable Judge Rosenblatt, in Phoenix, March 25, 2014. I realize you're a busy man. I will purpose not take up much of your time with this letter. I've included for your review, supportive correspondence which will help give clarity to pre-trial process related concerns briefly addressed herein. I kindly ask, and pray, that once you've read this letter and reviewed the accompanying related correspondence and any other evidence you may deem necessary, you would look into the matters addressed herein. I'm making this request because I have significant reason to believe my constitutional right to due process is being continuously violated by your assistant U.S. Attorneys, Mr. Rapp/Ms. Klapper. I've given this contact with you careful consideration and have done a significant amount of law research, which includes consulting with multiple reputable law firms. I have also sought the assistance of well known justice advocacy and civil rights organizations. In short, I've been purposely mindful to not be presumptuous nor over-reactive. It's after much observation, disturbing realization, and bringing my concerns to the attention of multiplle judicial authorities, that I've decided to communicate these concerns to you, the head U.S. Attorney. This correspondence, in it's entire, will convey my verifiable experience pertaining to the ongoing conduct of your assistant attorneys, Mr. Rapp and Ms. Klapper. To properly chronicle my experience as it pertains to the pre-trial process, I'll first establish that Judge Rosenblatt granted me Pro Se representation, about July 15, 2012. He also assigned attorney David L. Lockhart to act as my “advisory” counsel. About October 12, 2012 Mr. Lockhart was appointed my attorney. Pertaining to the reasons I believe my constitutional right to due process have been violated multiple times since July 2012, I'll address the violations pursuant to the manner I believe they have occurred. • On August 31, 2012; in response to Mr. Rapp's request (via Mr. Lockhart) for me to provide my “reciprocal discovery”, I sent by registered email direct to Mr. Rapp and Ms. Klapper a cover letter and download links to about five zip files collectively containing about two hundred exculpatory evidence files. I never received an acknowledgment from Mr. Rapp nor Ms. Klapper that they received the email. However, as aforesaid, I'd sent the email via a registered email service and have verifiable confirmation that both Mr. Rapp and Ms. Klapper received the email. See cover letter & registered email receipt attached. • From July 2012 thru about October 12, 2012, for the duration of my Pro Se representation, I was never provided discovery by Mr. Rapp. Ms. Klapper nor otherwise. This with there being a trial date scheduled at the time, for November 2012. In short, for about a four month period of time, as I was Pro Se, I was not provided discovery. Therefore, exculpatory evidence was never disclosed to me. • On about October 1, 2012, while I was Pro Se representation, Mr. Rapp/Ms. Klapper filed a Motion In Limine, which I received no notification of. In short, the motion was filed and I was never allowed opportunity to review it, object to it, nor otherwise address the motion. See attached Motion In Limine Mr. Rapp/Ms. Klapper filed April 2013, which addresses Limine motion filed October 2012.
  • 7.
    • On about October12, 2012, Judge Rosenblatt appointed Mr. Lockhart to act as my defense counsel. On March 22, 2013 Mr. Lockhart met with me in Michigan. Upon the conclusion of our meeting, Mr. Lockhart gave me a CD disc he said was discovery that Mr. Rapp or Mr. Klapper had provided him about a day prior to him meeting with me on March 22, 2013. Mr. Lockhart instructed me to review the discovery for documents to use for trial. I discovered, that with exception of just several documents, none of the (200+-) exculpatory evidence files I'd provided to Mr. Rapp/Ms. Kappler on August 31, 2012 were on the disc. A file titled Woodard's Exculpatory Evidence, consisted of only about seven documents. About four of the documents did not even pertain to the case transactions. The exculpatory evidence I'd provided to Mr. Rapp/Ms. Klapper was not entirely disclosed to my attorney. In short, there was failure to disclose exculpatory evidence to me as Pro Se July 2012 to October 2012. Subsequently, there was nondisclosure of exculpatory evidence to my attorney that Mr. Rapp/Ms. Klapper had in their possession. See aforesaid verification receipt. • To date, Mr. Rapp and Ms. Kappler have not provided a witness list as per “in a timely manner”. Thus, I've not been allowed my right to review the list. Likewise, not allowed my right to be provided information as to deals/concessions made with witnesses in exchange for testimony. In particular, this is pertaining to witnesses that were directly involved in the case related transactions. In Brady v. Maryland, 373 U.S. 83 (1963), the United States Supreme Court held that due process requires the prosecution to disclose evidence favorable to an accused when such evidence is material to guilt or punishment. The government’s obligation to disclose “Brady” evidence covers not only exculpatory evidence but also information that could be used to impeach government witnesses. Giglio v. United States, 405 U.S. 150 (1972). In particular, any agreement made with a government witness for testimony in exchange for a “deal” or other “favorable” treatment regarding criminal charges must be disclosed. As stated in United States v. Mitchell, 886 F.2d. 667, 670 (4th Cir. 1989). I trust God for truth and justice to prevail. Thereby, the assured good well-being of my family. However, I'm deeply concerned as to the journey prior to that outcome in the absence of due process. Pursuant to the Fourteenth and Fifth Amendments of the United State Constitution; I'm convinced my right to due process have been continuously violated. I am prepared to formally present to the national media, evidence of the violations. Likewise, present exculpatory evidence not disclosed by the prosecution, which contradicts allegations made by the prosecution in indictments and court proceeding. In conjunction with the media engagement, there would be legal action taken under the “Color of Law” provision of the U.S. Constitution. I want to emphasis; that this correspondence with you is not in any way intended to be a conveying of ultimatum. However, I am urgently purposing to not become another “wrongfully convicted” statistic. I trust you are not aware of the violations I've addressed herein. Thus, I'm informing you of my experience in hope you would conduct an investigation to determine if violations have occurred. Also, I'm requesting that you review my exculpatory evidence in it's entire, in conjunction, with review of the discovery Mr. Rapp/Ms. Klapper provided to my attorney about March 21, 2013. I have CD copy of the discovery in my possession. I kindly ask that you would review this correspondence in it's entire. Upon receiving notification from your office, I will provide you website links to download the exculpatory evidence zip files I provided to Mr. Rapp and Ms. Klapper on August 31, 2012. Please be advised; I will gladly allow authentication of all emails and documents by any means you may deem necessary. In closing; it's essential, and I kindly ask, to have a reply from your office by March 3, 2014. Thanks in advance, for your anticipated honorable consideration. Blessed regards, [Will G. Woodard] 7425 Chapel Hill Dr. #101 Lansing, Michigan 48917 willgwoodard@gmail.com Phone: (517) 853-8133 P.S. Sir, you can learn more about the REAL Will G. Woodard at; willgwoodard.com. willgwoodard.org, ministerofjustice.info & selfgrowth.com/articles/user/1266196 - God bless.
  • 8.
    HONORABLE CHIEF JUDGECOLLINS United States District Court 405 W. Congress, Suite 1500 Tucson, Arizona 85701 February 5, 2014 Regarding Court Case#: CR10-1721-002-PHX-PGR Dear Honorable Chief Judge Collins; I hope you're doing well. My name is Willie Gene Woodard, I am co-defendant in a case which is set to commence being heard in the court of Honorable Judge Rosenblatt, in Phoenix, March 25, 2014. I realize you're a busy man. I will purpose not take up much of your time with this letter. I've included for your review, supportive correspondence which will help give clarity to the case related concerns briefly addressed herein. I kindly ask, and pray, that once you've read this letter and reviewed the accompanying related correspondence, you would look into the matters addressed. I'm making this request because I have significant reason to believe my right to due process and fair trial is being continuously violated. I've given this contact with you careful consideration and have done a significant amount of law research, which includes consulting with a number of reputable law firms. I've also sought the assistance of well known justice advocacy and civil rights organizations. In short, I've been purposely mindful to not be presumptuous and not be over-reactive. It's after much observation and disturbing realization that I've decided to communicate these concerns to you, a higher level of the court. This correspondence with you, in it's entire, will convey my verifiable experience pertaining to my case. I'll just address events as per the manner they occurred. The following are a few reasons I believe my right to due process and fair trial are being violated:  About mid August 2011, I was arraigned on an initial indictment before Honorable Judge Duncan and at that time was provided court-appointed legal counsel, Mr. Roger T. Margolis. I pleaded not guilty to the charges. While during the hearing was still in process, my appointed counsel commenced to suggest to me that I should consider taking a plea deal. There was no inquiry from him as to my guilt or innocence. No inquiry as to evidence I had to substantiate my innocence. No indication from him as to any plan to discuss my case. My reply was that I was not guilty of the charges. He responded by indicating; that he and I was already getting off to a bad start. That was a very disturbing moment.  On September 13, 2011; I appeared in court for a detention release hearing before Honorable Judge Duncan and he granted release on my own recognizance. At that time I indicated to Mr. Margolis that upon my arrival in Michigan I would send him the evidence supporting my innocence. Again, Mr. Margolis expressed that I consider taking a plea deal and to hold-off on sending him any information until he instructed me to do so. With Trial scheduled for July 2012, it was not until midMarch 2012, that Mr. Margolis agreed to me sending him my exculpatory evidence files. I provided Mr. Margolis approximately two hundred evidence documents, some directly contradicting the indictment claims against me. Along with the evidence documents, I provided a ten person witness list. After sending my evidence and witness list, I inquired a number of times with Mr. Margolis as to the status of his review and witness contact. His response was he'd not had time and/or staff to yet complete a review.  In May 2012, Mr. Margolis presented me a plea offer. He warned me there would be a superseding indictment if I declined. I declined the offer. And on June 5, 2012, I appeared before Honorable Judge Burns for arraignment on a superseding indictment, which turned out
  • 9.
    to also bea settlement hearing. Prior to the hearing, while in private conference with Margolis, he informed me that a particular business associate was going to be a government witness and what the party would testify to. Immediately I presented Mr. Margolis documents that contradicted the intended testimony. Mr. Margolis responded with the question; “were these documents among the those you sent me?” I replied yes they were. I pleaded not guilty and again declined the plea offer. I also expressed to Judge Burns that I no longer wanted to be represented by Mr. Margolis. In short; after sending a letter to Judge Rosenblatt expressing concerns about my defense representation, I was allowed to become Pro Se as I'd requested. Upon Judge Rosenblatt granting Pro Se representation, he assigned me advisory counsel, Mr. David L. Lockhart. Trial date was continued to 11/2012. I returned to Michigan.  October 1, 2012, after having consultation with two reputable law firms, I filed motion Pro Se for; “Court to conduct an in camera inspection of the Grand Jury minutes and certain Grand Jury materials. On October 15, 2012, I appeared telephonic-ally for a status hearing. That day I'd just been discharged from a Michigan hospital after several days of hospitalization. Judge Rosenblatt during the “status hearing”, indicated that my motion for “In Camera Inspection of Grand Jury Minutes” was improperly filed, when in fact I'd followed explicitly the filing instruction provided to me by the Court's Clerk office. I need add; that prior to filing motion for Inspection of Grand Jury Minutes, I'd filed two other motions which Judge Rosenblatt granted. In short; during the October 15 status hearing, Judge Rosenblatt insisted that the attorney who'd been assigned as my advisory counsel, David L. Lockhart, be appointed my defense counsel. Furthermore, Judge Rosenblatt suggested to Mr. Lockhart that as my newly appointed counsel he withdraw my motion for “In Camera Inspection of Grand Jury Minutes.” In short, Judge Rosenblatt denied me the right to continue as Pro Se representation and had my motion for “Inspection of Grand Jury Minutes” withdrawn. Trail was continued until May 2013.  Mr. Lockhart sent me an email on December 30, 2012. I viewed the email about January 5, 2013 and replied to him with the attached letter dated January 9, 2013. Mr. Lockhart didn't reply until February 2nd, when making me aware of a February 6th status hearing. I had to attend the hearing telephonic-ally due to recent hospitalization. On March 22nd Mr. Lockhart met with me in Michigan for about a five hour meeting. It was during the meeting that I was informed for the first time that the trail date was scheduled for May 7, 2013. Mr. Lockhart gave me a disc of discovery evidence that he'd just days before received from the prosecutor. He instructed me to review and select documents from the disc that I wanted to use in my defense. After reviewing the disc I discovered that only several of the two hundred plus documents I'd provided to the prosecutor August 31, 2012, when I was Pro Se, were on the disc. The documents that I'd provided the prosecutor that directly contradicted the conspiracy claim were not on the disc. I made Mr. Lockhart aware that the reciprocal discovery I'd provided the prosecutor wasn't on the disc. On March 23 2013, I commenced emailing Mr. Lockhart the information I'd previously provided Mr. Margolis, Mr. Rapp and him. Mr. Lockhart did not reply to my emails until March 28, with the following question; “Good morning Mr. Woodard. Have you ever given this information to Mr. Margolis or Mr. Rapp previously, including your witness list and the qualifications of any potential expert witness?” My March 28 reply to Mr. Lockhart was as follows: “Hi David, I've given Mr. Rapp and Mr. Margolis the same evidence I've given you. Mr. Margolis was also given the witness list, with exception of expert witness.” To date, none of my witnesses have been subpenaed, and there's been no further response to my inquiries about the undisclosed evidence.  On May 5, 2013, while at the airport to board a flight to Arizona and attend a status hearing the following day, I experienced a Gand mal seizure. Later learned, I'd had several smaller seizures after the ambulance service was called. I was hospitalized for about five days. Before being discharged I was visited by my local pretrial supervisor, Mr. Stuart Chavis. After being discharged I was advised by my attorney that I needed to provide hospital documents
  • 10.
    confirming I'd beenhospitalized and why. I provided the information as required, which included ambulance report, plus emergency room and extended stay treatment records. Several days after the initial May hospitalization, I experienced another series of seizures and was hospitalized again for about a week. On about May 28, 2013, the day following my hospital discharge, I was arrested by the U.S. Marshall Service at my residence per court order issued by Judge Rosenblatt. The order my arrest was issued for not being present for the May 6th hearing, though I'd provided ample documentation confirming I'd had a seizure at the airport and was hospitalized. It was the beginning of about a three week prisoner transport back to Arizona. I was hospitalized again for one week while awaiting transport from Oklahoma to Arizona. After arriving to Arizona, about June 19 th, I was admitted to the detention center hospital were I was treated for about two weeks. In short; on about July 16, 2013, I appeared before Judge Duncan. He'd ascertained and determined that I'd not been in violation in any way. Demonstrated by him ordering my release and allowing me to return back to Michigan. He also removed a previous stipulation for house arrest and GPS monitoring, which I perceived to be a gesture of apology, as well as an acknowledgment of trust. I continue to greatly appreciate Judge Duncan's “just” assessment and ruling. Trial was continued until December 19, 2013. There was a subsequent continuance until March 25, 2014.  On January 4, 2014, I ask my attorney to file a motion with Judge Duncan requesting modification of my release order transaction amount from $500 to $1,500 or more. In part, so that I could prepare financially for trail travel to Arizona and lodging during trial. I provided him the names and contact information of two financial services entities allowing me opportunity to earn income. In short, on January 6, 2014, I received an email from my attorney conveying that the prosecutor objects to me working in the financial services industry. He further suggested that I consider other options. Fact is; there is no stipulation in my release order restricting me from earning an income in the financial services industry. In short, on January 29, 2014, a motion hearing took place which I attended telephonically before Judge Rosenblatt. He denied the motion, and accelerated a status hearing from March 9, 2014 to March 4, 2014, giving me one week less time to raise funds for travel to Arizona financially prepared for lodging during an estimated three week trial. Judge Rosenblatt made it clear, that should I appear without the ability to pay for lodging, my release order would be revoked and I'd be taken into custody. In closing; to date; none of the ten plus witnesses I provided have been subpenaed. Some who've expressed their willingness to testify in my behalf. Likewise, none of the two hundred plus documents I provided to my initial attorney, the prosecutor and my current attorney that directly contradict allegations against me were included in discovery. And disappointingly, my current attorney, from time he was assigned until after the 01/29/14 hearing, had avoided every request I'd made for him to address these concerns. To date, nothing has changed. Still, none of my witnesses have been subpenaed, and my evidence not disclosed by the prosecutor in discovery remains unaddressed. Going to trial with no witnesses subpenaed and evidence substantiating my innocence excluded for discovery, I feel like a sheep headed to slaughter. Proclaiming my innocence is not the purpose of this letter. I'm just making you aware of events I believe have been violations of my right for due process and fair trial. I'm reaching out for help. I have a prepared media package, for in the event all else fails. I trust God for my vindication and future of my family. But, I'm deeply concerned as to the outcome, with the absence of fairness, due process. For a more complete picture, at your convenience, please review this correspondence in it's entire. I would gladly allow authentication of emails and letters by any means you may deem necessary. Much of what I've conveyed herein is a matter of court records. Thank you in advance for your consideration. Blessed regards, [Will G. Woodard] (517) 853-8133
  • 11.
    Robin C. Ashton,Counsel Office of Professional Responsibility 950 Pennsylvania Avenue, N.W., Suite 3266 Washington, DC 20530-0001 February 5, 2014 Re: Complaint:- Court Case#: CR10-1721-002-PHX-PGR Dear Ms. Ashton; I hope you're doing well. This my second to request help. My name is Willie Gene Woodard, I am co-defendant in a case which is set to commence being heard in the court of Honorable Judge Rosenblatt, in Phoenix, March 25, 2014. I realize you're a busy. I will purpose not take up much of your time with this letter. I've included for your review, supportive correspondence which will help give clarity to the case related concerns briefly addressed herein. I kindly ask, and pray, that once you've read this letter and reviewed the accompanying related correspondence, you would look into the matters addressed. I'm making this request because I have significant reason to believe my right to due process and fair trial is being continuously violated. I've given this contact with you careful consideration and have done a significant amount of law research, which includes consulting with a number of reputable law firms. I've also sought the assistance of well known justice advocacy and civil rights organizations. In short, I've been purposely mindful to not be presumptuous and not be over-reactive. It's after much observation and disturbing realization that I've decided to communicate these concerns to you, a higher level of the court. This correspondence with you, in it's entire, will convey my verifiable experience pertaining to my case. I'll just address events as per the manner they occurred. The following are a few reasons I believe my right to due process and fair trial are being violated:  About mid August 2011, I was arraigned on an initial indictment before Honorable Judge Duncan and at that time was provided court-appointed legal counsel, Mr. Roger T. Margolis. I pleaded not guilty to the charges. While during the hearing was still in process, my appointed counsel commenced to suggest to me that I should consider taking a plea deal. There was no inquiry from him as to my guilt or innocence. No inquiry as to evidence I had to substantiate my innocence. No indication from him as to any plan to discuss my case. My reply was that I was not guilty of the charges. He responded by indicating; that he and I was already getting off to a bad start. That was a very disturbing moment.  On September 13, 2011; I appeared in court for a detention release hearing before Honorable Judge Duncan and he granted release on my own recognizance. At that time I indicated to Mr. Margolis that upon my arrival in Michigan I would send him the evidence supporting my innocence. Again, Mr. Margolis expressed that I consider taking a plea deal and to hold-off on sending him any information until he instructed me to do so. With Trial scheduled for July 2012, it was not until midMarch 2012, that Mr. Margolis agreed to me sending him my exculpatory evidence files. I provided Mr. Margolis approximately two hundred evidence documents, some directly contradicting the indictment claims against me. Along with the evidence documents, I provided a ten person witness list. After sending my evidence and witness list, I inquired a number of times with Mr. Margolis as to the status of his review and witness contact. His response was he'd not had time and/or staff to yet complete a review.  In May 2012, Mr. Margolis presented me a plea offer. He warned me there would be a superseding indictment if I declined. I declined the offer. And on June 5, 2012, I appeared before Honorable Judge Burns for arraignment on a superseding indictment, which turned out
  • 12.
    to also bea settlement hearing. Prior to the hearing, while in private conference with Margolis, he informed me that a particular business associate was going to be a government witness and what the party would testify to. Immediately I presented Mr. Margolis documents that contradicted the intended testimony. Mr. Margolis responded with the question; “were these documents among the those you sent me?” I replied yes they were. I pleaded not guilty and again declined the plea offer. I also expressed to Judge Burns that I no longer wanted to be represented by Mr. Margolis. In short; after sending a letter to Judge Rosenblatt expressing concerns about my defense representation, I was allowed to become Pro Se as I'd requested. Upon Judge Rosenblatt granting Pro Se representation, he assigned me advisory counsel, Mr. David L. Lockhart. Trial date was continued to 11/2012. I returned to Michigan.  October 1, 2012, after having consultation with two reputable law firms, I filed motion Pro Se for; “Court to conduct an in camera inspection of the Grand Jury minutes and certain Grand Jury materials. On October 15, 2012, I appeared telephonic-ally for a status hearing. That day I'd just been discharged from a Michigan hospital after several days of hospitalization. Judge Rosenblatt during the “status hearing”, indicated that my motion for “In Camera Inspection of Grand Jury Minutes” was improperly filed, when in fact I'd followed explicitly the filing instruction provided to me by the Court's Clerk office. I need add; that prior to filing motion for Inspection of Grand Jury Minutes, I'd filed two other motions which Judge Rosenblatt granted. In short; during the October 15 status hearing, Judge Rosenblatt insisted that the attorney who'd been assigned as my advisory counsel, David L. Lockhart, be appointed my defense counsel. Furthermore, Judge Rosenblatt suggested to Mr. Lockhart that as my newly appointed counsel he withdraw my motion for “In Camera Inspection of Grand Jury Minutes.” In short, Judge Rosenblatt denied me the right to continue as Pro Se representation and had my motion for “Inspection of Grand Jury Minutes” withdrawn. Trail was continued until May 2013.  Mr. Lockhart sent me an email on December 30, 2012. I viewed the email about January 5, 2013 and replied to him with the attached letter dated January 9, 2013. Mr. Lockhart didn't reply until February 2nd, when making me aware of a February 6th status hearing. I had to attend the hearing telephonic-ally due to recent hospitalization. On March 22nd Mr. Lockhart met with me in Michigan for about a five hour meeting. It was during the meeting that I was informed for the first time that the trail date was scheduled for May 7, 2013. Mr. Lockhart gave me a disc of discovery evidence that he'd just days before received from the prosecutor. He instructed me to review and select documents from the disc that I wanted to use in my defense. After reviewing the disc I discovered that only several of the two hundred plus documents I'd provided to the prosecutor August 31, 2012, when I was Pro Se, were on the disc. The documents that I'd provided the prosecutor that directly contradicted the conspiracy claim were not on the disc. I made Mr. Lockhart aware that the reciprocal discovery I'd provided the prosecutor wasn't on the disc. On March 23 2013, I commenced emailing Mr. Lockhart the information I'd previously provided Mr. Margolis, Mr. Rapp and him. Mr. Lockhart did not reply to my emails until March 28, with the following question; “Good morning Mr. Woodard. Have you ever given this information to Mr. Margolis or Mr. Rapp previously, including your witness list and the qualifications of any potential expert witness?” My March 28 reply to Mr. Lockhart was as follows: “Hi David, I've given Mr. Rapp and Mr. Margolis the same evidence I've given you. Mr. Margolis was also given the witness list, with exception of expert witness.” To date, none of my witnesses have been subpenaed, and there's been no further response to my inquiries about the undisclosed evidence.  On May 5, 2013, while at the airport to board a flight to Arizona and attend a status hearing the following day, I experienced a Gand mal seizure. Later learned, I'd had several smaller seizures after the ambulance service was called. I was hospitalized for about five days. Before being discharged I was visited by my local pretrial supervisor, Mr. Stuart Chavis. After being discharged I was advised by my attorney that I needed to provide hospital documents
  • 13.
    confirming I'd beenhospitalized and why. I provided the information as required, which included ambulance report, plus emergency room and extended stay treatment records. Several days after the initial May hospitalization, I experienced another series of seizures and was hospitalized again for about a week. On about May 28, 2013, the day following my hospital discharge, I was arrested by the U.S. Marshall Service at my residence per court order issued by Judge Rosenblatt. The order my arrest was issued for not being present for the May 6th hearing, though I'd provided ample documentation confirming I'd had a seizure at the airport and was hospitalized. It was the beginning of about a three week prisoner transport back to Arizona. I was hospitalized again for one week while awaiting transport from Oklahoma to Arizona. After arriving to Arizona, about June 19 th, I was admitted to the detention center hospital were I was treated for about two weeks. In short; on about July 16, 2013, I appeared before Judge Duncan. He'd ascertained and determined that I'd not been in violation in any way. Demonstrated by him ordering my release and allowing me to return back to Michigan. He also removed a previous stipulation for house arrest and GPS monitoring, which I perceived to be a gesture of apology, as well as an acknowledgment of trust. I continue to greatly appreciate Judge Duncan's “just” assessment and ruling. Trial was continued until December 19, 2013. There was a subsequent continuance until March 25, 2014.  On January 4, 2014, I ask my attorney to file a motion with Judge Duncan requesting modification of my release order transaction amount from $500 to $1,500 or more. In part, so that I could prepare financially for trail travel to Arizona and lodging during trial. I provided him the names and contact information of two financial services entities allowing me opportunity to earn income. In short, on January 6, 2014, I received an email from my attorney conveying that the prosecutor objects to me working in the financial services industry. He further suggested that I consider other options. Fact is; there is no stipulation in my release order restricting me from earning an income in the financial services industry. In short, on January 29, 2014, a motion hearing took place which I attended telephonically before Judge Rosenblatt. He denied the motion, and accelerated a status hearing from March 9, 2014 to March 4, 2014, giving me one week less time to raise funds for travel to Arizona financially prepared for lodging during an estimated three week trial. Judge Rosenblatt made it clear, that should I appear without the ability to pay for lodging, my release order would be revoked and I'd be taken into custody. In closing; to date; none of the ten plus witnesses I provided have been subpenaed. Some who've expressed their willingness to testify in my behalf. Likewise, none of the two hundred plus documents I provided to my initial attorney, the prosecutor and my current attorney that directly contradict allegations against me were included in discovery. And disappointingly, my current attorney, from time he was assigned until after the 01/29/14 hearing, had avoided every request I'd made for him to address these concerns. To date, nothing has changed. Still, none of my witnesses have been subpenaed, and my evidence not disclosed by the prosecutor in discovery remains unaddressed. Going to trial with no witnesses subpenaed and evidence substantiating my innocence excluded for discovery, I feel like a sheep headed to slaughter. Proclaiming my innocence is not the purpose of this letter. I'm just making you aware of events I believe have been violations of my right for due process and fair trial. I'm reaching out for help. I have a prepared media package, for in the event all else fails. I trust God for my vindication and future of my family. But, I'm deeply concerned as to the outcome, with the absence of fairness, due process. For a more complete picture, at your convenience, please review this correspondence in it's entire. I would gladly allow authentication of emails and letters by any means you may deem necessary. Much of what I've conveyed herein is a matter of court records. Thank you in advance for your consideration. Blessed regards, [Will G. Woodard] (517) 853-8133
  • 14.
    HONORABLE PAUL G.ROSENBLATT United States District Court Sandra Day O’Connor U.S. Courthouse, Suite 621 401 West Washington Street, SPC 56 Phoenix, AZ 85003-2156 April 14, 2013 Dear Honorable Judge Rosenblatt, Hope you're doing well. I'm convinced it's necessary that I have this communication with you. I'll get right to the point as to not take up much of your time. For multiple reasons, I have had increasing concern regarding the defense representation of my court appointed legal counsel, Mr. David Lockhart. I've lost all confidence and trust that he is committal and adequately representing. This will not be lengthy letter of me passing judgment in that regards. I will note the following in order to establish a basis for my request to express my concerns during the coming hearing: 1) During the hearing on March 6, Mr. Lockhart gave the court the impression that evaluating my case was some how delayed or hindered by my residing outside of Arizona. Fact is, when he was appointed as my counsel October 2012, he advised me that he had existing cases to complete and would notify me as when we could discus my case. Mr. Lockhart next communicated with me by email on December 30, 2012. 2) After viewing Mr. Lockharts email about January 5, 2013, I replied to him with the attached letter. I received no reply after sending the letter and leaving phone messages. Mr. Lockhart didn't communicate with me again until February 2nd, when making me aware of the February 6th status hearing. 3) Mr. Lockhart met with me in Michigan on March 22 for about a five hour meeting. The meeting, as expected consisted mostly of conversation pertaining to the case, and we had a meal. There was no more done at the meeting than what could have been accomplished by a couple phone calls. I was provided no documentation, and I've yet to receive promised copies of documents Mr. Lockhart had with him at time of the meeting. Also, at the March 22 meeting that I was informed for the first time that the trail date was scheduled for May 7. I appreciated Mr. Lockhart coming to Michigan to meet with me, but there little accomplished. 4) Near conclusion of the March 22 meeting, Mr. Lockhart advised me that the government had provided him a disc with all discovery evidence for trial just few days prior to him leaving Arizona to come to Michigan Mr. Lockhart instructed me to review and select documents from the disc that I wanted to use in my defense. After reviewing the disc I discovered that only few of the 300 plus documents I'd provided to the government August 31, 2012, when I was Pro Se, were on the disc. The documents I'd provided the government that directly contradicted the governments conspiracy claim were not on the disc. I made Mr. Lockhart aware that this reciprocal (exculpatory evidence) I'd provided the government wasn't on the disc. 5) On March 23, I commenced emailing Mr. Lockhart the exculpatory evidence I'd provided the government and to Mr. Margolis as well. Mr. Lockhart did not reply to my emails until March 28, with the following question: “Good morning Mr. Woodard. Have you ever given this information to Mr. Margolis or Mr. Rapp previously, including your witness list and the qualifications of any potential expert witness?” My March 28 reply to Mr. Lockhart was as follows: “Hi David, I've given Mr. Rapp and Mr. Margolis the same evidence I've given you. Mr. Margolis was also given the witness list, with the exception of expert witness.”
  • 15.
    6) Mr. Lockhartdid not communicate with me again until April 2, with the following message: “Good afternoon Mr. Woodard. Please see attached. Thank you.” Attached were the following two government motion documents filed April 1: “Supplemental MOTION in Limine to Determine Admissibility of Evidence” and “Motion to Dismiss Counts”. Mr. Lockhart gave me no explanation as to the meaning of the government motions. I literally had to contact a friend who's an attorney to explain the motions to me. Mr. Lockhart has yet to address the motions. 7) After Mr. Lockhart's and my April 2 exchange of emails, Mr. Lockhart did not communicate with me again until April 10. He made no mention of my exculpatory evidence nor my witness list in that communication. Just a long explanation about research he was supposedly doing. His message on the April 10 was as follows: “Good morning Mr. Woodard. Please be advised that I have passed on your witness list to DK and he will be following up with these individuals and attempt to evaluate what, if anything of value they can offer to assist you at trial. Be advised that Mr. Rapp intends to call Mr. Olivas and Mr. Sizemore as witnesses at trial. Because of some of the responses that I have been receiving from you regarding questions I have recently asked you, I think this would be an appropriate time to discuss trial strategy/defense. It is my opinion and intention to put forth a defense that you too were “duped.” This means that you were unaware of the fact that the Greek Trust (GT) did not exist and all the steps you took as the POF facilitator were appropriate as you received much of your direction from the ultimate fraud schemer, Louis Pihatkis aka Michael Louis. It was not until you realized/discovered that the GT did not exist, that you began to remove yourself from your role as the POF facilitator and attempted to refund the victims their monies. If I am mistaken, please let me know immediately. However, be advised that the attorney, I get to decide trial strategy, not the client. I obviously have to remain in contact with you and be able to communicate with you, but the final decision as to what defense we are going to put forth, is mine to make with your input. Thank you. David L. Lockhart, Esq.” I believe Mr. Lockhart was sincere in this communication, but something happen to that brought about an adverse change his subsequent email communication. 8) On April 11, I was informed by my pretrial supervisor hear in Michigan, that there was a scheduled hearing for Monday April 15. Mr. Lockhart had not made made me aware of the hearing, and when I inquired with him about it, I received the following two emails on the April 11: A) “Good evening Mr. Woodard. Regarding the Court date, I will confirm tomorrow with you. Also, I need to know exactly where you will be staying in AZ when you arrive in May. Please be advised that I can secure funds for your flight from Michigan to Arizona. However, the Court will not authorize payment for lodging, transportation or food. Thus, you will be responsible for all of the aforementioned. Thank you.” B) “Regarding the "exculpatory" evidence you disclosed to Mr. Rapp, be advised that the government has acknowledged their receipt of what you have provided to them to me.”
  • 16.
    9) On April12, Mr. Lockhart sent me the following email: “Good morning Mr. Woodard. Please be advised that a Final Trial Management Conference is scheduled for this Monday, April 15, 2013 at 10:30 a.m. before Judge Rosenblatt. You will need to call in. A Final Trial Management Conference is exactly what it says. We will be discussing final issues regarding our preparedness for trial. You will need to be ready to tell the Court where you will be residing while you are in AZ. Further, if you have medical issues that require hospitalization, you will need to be prepared to provide documentation to the court. Will follow up with you throughout the day and weekend. Thank you.” I've yet to receive any further communication from Mr. Lockhart, as of sending this letter to you. Your Honor, I believe that Mr. Lockhart had no intention of making me aware of the April 15 hearing so that I would not have opportunity to voice what I've expressed in this letter. Both, what I've expressed about how he's handled my case, and the government's non disclosure of exculpatory evidence I provided. Mr. Lockhart not addressing the undisclosed exculpatory evidence until after I'd become aware of the April 15 hearing is particularly disturbing, as well as convincing it was intended that I not be aware of the hearing. Also, Mr. Lockhart has indicated that he'd made effort to contact certain parties on the ten person witness list I provided him. But parties have expressed that they've talk with no one nor have had a message left from anyone concerning my case. I've also provided Mr. Lockhart contact information for an expert witness with over ten years in the “proof of funds” industry and has a very credible reputation. But Mr. Lockhart expressed that if I don't know the expert witness personally he would not subpena him as a witness. Since when must a defendant know an expert witness personally for them to give expert testimony? I could go on Your Honor, but hopefully I've shared enough for you to see why I'm concerned about my defense representation. The concern causes a disturbing question; how could I have a fair trial if the government prevents the admitting of my exculpatory evidence and my defense counsel not subpena witnesses to testify in my behalf? In closing; all that I've expressed herein can be authenticated in my email account. I will allow authentication by any means you may deem necessary. I've provided you this summation letter and the accompanying aforementioned letters of communication with Mr. Lockhart and the government for your consideration. And, I kindly ask that I have opportunity to express my concerns during the forthcoming hearing Thanks for your time, and blessed regards, Will G. Woodard (517) 853-8133
  • 17.
    HONORABLE PAUL G.ROSENBLATT United States District Court Sandra Day O’Connor U.S. Courthouse, Suite 621 401 West Washington Street, SPC 56 Phoenix, AZ 85003-2156 June 12, 2012 Dear Honorable Judge Rosenblatt; My name is Willie Gene Woodard, I am co-defendant in a case, which is set to be heard in your court. I realize you are a busy man, therefore, I will not take up much of your time with this letter. The purpose of this communication is to make you aware of concerns I have regarding the defense representation of my court appointed legal counsel, Mr. Roger T. Margolis. I'd like to also request a Marsdens Hearing as well in this matter. I'm making this request because I have significant reasons to believe that I am not being competently or adequately represented by my current legal counsel. I am writing this letter after careful consideration. I've been purposely mindful to not prematurely express my concerns to the court and not over-react as well. It's after much observation and disturbing discovery that I've decided to communicate these concerns to you. Until the “Settlement Conference” you ordered, which was conducted on June 5, 2012, I'd given my court-appointed attorney extended benefit of the doubt. However, he and I had a brief meeting prior to the Settlement Conference. In that meeting my doubt about not having competent or adequate legal defense representation was confirmed. Consequently, I expressed my concerns to Honorable Judge Burns during the Settlement Conference. She indicated I had the options of making the motion for another court-appointed attorney, hiring an attorney or representing myself. The following are few of the reasons that I am certain that I have not been competently or adequately represented by my current court-appointed legal counsel: • About late August 2011, I was arraigned on the initial indictment before Honorable Judge Duncan and my current legal counsel was appointed. While in that hearing my counsel commenced to suggest to me that I should consider taking a Plea Deal. There was no inquiry from him as to my guilt or innocence. No inquiry as to evidence I have to substantiate my innocence. No indication from him as to any plan to discuss my case. My reply was that I'm not guilty of the charges. He responded by indicating; that he and I was already getting off to a bad start. That was a disturbing moment. • On September 13, 2011; I appeared in court for a detention release hearing before Honorable Judge Duncan and he granted release on my own recognizance. To that date, still there had been no defense discussion about my case and no indication as to when there would be. Before leaving the court room I indicated to my legal counsel that upon my arrival in Michigan I would send him the evidence supporting my innocence. He indicated that I hold-off on sending him any information until he instructed me to do so. Suggesting again that I consider a Plea Deal.
  • 18.
    • A condition ofmy September 13, 2011 release from detention, was that I contact my legal counsel every Friday, which I've diligently complied with. From the first Friday of my release to date, my legal counsel and I have had about seven phone conversations. In short, of about forty calls I've made to my legal counsel, thirty plus calls were not answered and not returned. • Of the several phone conversations I've had with my counsel since September 13, 2011, my counsel initiated about three calls. One call was between last Christmas and New Years. On that call I again inquired as to when I could send him my evidence for his review. He expressed he would seek court funding to meet with me in Michigan. My counsel initiated a second call to me about March 30, 2012. He requested my email address so that he could email me the Prosecutor's Plea Offer. He initiated a third call in May 2012 to inform me of the hearing in your court regarding his motion for funding so he could hire an investigator and a paralegal. • My legal counsel, since September 13, 2011 has returned about four phone calls; first returned call was about September 30, 2011 and he inquired as to my health. Again I asked him about sending my evidence and again he suggested I hold-off sending it. Also, again he suggested I consider accepting a Plea Offer. Second returned call was March 16, 2012. In this conversation I insisted adamantly that he focus on defending me and review my evidence information. He provided me his email address and warned that a second indictment could be the consequence of me not accepting a Plea Offer. My legal counsel also returned a call last week of May 2012. He inform me of the Settlement Conference and the Prosecutor's second indictment filing. • About four days after my counsel made me aware of the second indictment, I received a copy of it from him via postal mail. I called my counsel and pointed out that the co-defendant's activities prior to my acquaintance with him was included in the second indictment against me. Likewise, was the co-defendant's release violation activities indicated in the second indictment against me. On that call my counsel informed me that he wasn't aware that the allegations were in the indictment and frustrated by my inquiring as how and why the inclusion. I (again), had to resort to getting free telephone consultation from other attorneys, in order to get a better understanding of certain particular aspects of my case. • On June 5, 2012, in a brief meeting prior to the Settlement and arraignment hearings, my counsel indicated that the Prosecutor was not accounting the aforementioned alleged release violation activities of the co-defendant against me. And again my counsel adamantly resumed his insistence that I accept the Plea Offer. Warning me; that if I go to trial I would face “a jury of twelve retired Arizonians”. I will not elaborate on what I perceived him to be implying. I presented evidence to my counsel for discussion. He didn't recognize the evidence as being among the information I'd sent him previously. In short, in that meeting my concern about not being competently or adequately represented by my legal counsel was undoubtedly solidified. I expressed this concern in the hearing before Honorable Judge Burns.
  • 19.
    Your Honor, Iwould also like to express; that I'm concerned that should I have a trial jointly with the co-defendant, I would likely not receive a fair trial. I have no criminal history and have complied with every aspect of my September 13, 2011 release order. The co-defendant has alleged criminal activities prior to my acquaintance with him and has alleged activities thru April 2012. These allegations were included in the superseding indictment against me. Therefore, even if the Prosecutor provided jury instructions to not account these allegations against me, I would still be subject to a jury being inadvertently prejudiced against me because of the co-defendant's alleged activities. In short, I'm concerned that me not having a fair trial would be inevitably, if I have joint trial with the co-defendant. I have asked my legal counsel to file a motion for a separate trial. However, as far as I know, still this motion has not been filed. And I believe that Mr. Margolis would not have likely filed this motion since I've expressed my concerns about being represented by him before Honorable Judge Burns. If he has filed motion for separate trial, then my apology for taking up your time and thoughts with this particular concern. I would like to also express, that I'm willing to take a Polygraph Test regarding the content of this letter. Likewise, I'm willing to take a Polygraph with regards to my being innocent of the “Conspiracy” and thereby the related charges against me. However, should I have to go to trial, I would do so prayerfully trusting that the truth would prevail and I'd be vindicated. I'm hoping to have not only my freedom back, but my good name as well. Most importantly, I'm trusting that the agonizing separation from my wife and two young kids in the Philippines will come to an end. Your Honor, in closing; I can not afford to hire an attorney and would rather represent myself than have another appointed counsel. Therefore, if I am to go to trial, I would like to exercise the option presented by Honorable Judge Burns- to represent myself. I could arrange with relatives to relocate in Phoenix so that I not have to travel from Michigan to adequately comply with any court appearance obligations. I'd greatly appreciate your time and consideration of the concerns addressed herein. Thank you and blessed regards, Will G. Woodard 7425 Chapel Hill Dr. Lansing, MI 48917 (517) 853-8133 cc: Mr. Roger T. Margolis (Attorney) Mr. Kevin Rapp (USAAZ)
  • 20.
    David L. Lockhart,Esq. 2601 N. 16th Street Phoenix, Arizona 85006 February 3, 2014 Good day, Mr. Lockhart, this letter is in reply to your 01/30/14 email. Anthony Laxen facilitated/arranged my leasing of client POF accounts. He was aware I paid nearly one million dollars in initial cost and that there was ongoing cost to keep the accounts active. Mr. Laxen earned a $25K commission for the Barclays POF and $10K or more for each of the three Bank of America POFs. Estimated $55K in commissions was paid to Mr. Laxen by the POF providers. The prosecutor claims I was aware the clients POFs were fake and fees paid to me was spent for personal use. Wouldn't Mr. Laxen's testimony potentially cause "reasonable doubt" in the minds jurors that I was aware the clients POFs were fake and paid no money for client POFs? I'd think reasonable thinking people would ask themselves; why would the defendant pay nearly one million dollars to have fake documents that could be created on a computer for nearly free? How could think say Mr. Laxen's testimony would not assist me? The client processors/referrers on my witness list had known Mr. Pahakis for five years plus and knew him as "Micheal Louis", "Senior Trustee of a private Trust. They believed Mr. Pahakis was who he said he was and referred their clients to the Trust for project funding. Likewise based on that belief, they referred their clients to me to spend $400K to lease POF for the Trust funding. Wouldn't stand to reason that if these client processors/referrers, could have been mislead by Mr. Pahakis, that the defendant could have also been mislead? The two client prospects on my witness list, Mr. Javraj and Mr. Lee, whom I turned away February 2010, can testify that they were prepared to pay me $400K each to lease POF for Trust Funding. They can alos testify that I advised them to wait until after funding had commenced for existing clients before spending money to lease POF. Don't you think jurors would wonder why the defendant would turn away two prospects ready to pay him $400K each if the defendant's intent was to defraud? In closing; everyone on the witness list I've provided you has testimony that would cause "reasonable doubt" in the minds of jurors. All would testify to the truth if subpenaed knowing their expenses would be covered. I kindly ask that you make a motion for the cost and expenses of these witnesses, as per Federal Rule 17(b), as previously addressed. As it now stands, I have no witnesses subpenaed. Even having reluctant witnesses testifying to the facts, would be better than having no witnesses at all to testify. Thanks in advance. Blessed regards. [Will G. Woodard] (517) 853-8133 P.S. I've filed a complaint with Miami FBI against JPierce Investments (James Pierce) in regards to me being provided fake POF and a rigged authentication procedure. I'm expecting to have face to face interview with local FBI agent, at which time I will provide them my transaction evidence.
  • 21.
    David L. Lockhart,Esq. 2601 N. 16th Street Phoenix, Arizona 85006 Mr. Lockhart, this letter is in reply to your email, 02/10/14. February 10, 2014 The first two clients to receive POFs and pay a sublease allocation fee direct to my company, were ATL Holdings and Mecca Construction. Both clients received their "Bank of America" POFs January 29, 2009. One year to when I stopped accepting clients in February 2010. What do mean about the three years referenced in your email? How could you be so off base about that after all this time? I will forward you the email in which the clients POF documents were delivered. Both the email and the documents are dated January 29, 2009. As to me having discussed law enforcement with a client; I never had conversation with any client trying to dissuade them from contacting law enforcement. Law enforcement had in no way entered my mind until I learned there was an investigation into the “Trust” late October 2010. It was a client that made me aware. With regards to refunded clients; they were refunded from profit earned subleasing POFs. Should the clients had placed monies with me for investment into an investment platform, i.e. stocks, bonds etc, then of course it would have been improper for those funds to be used otherwise. But the clients made "payment" to me for the leasing of a credit facility product- a POF allocation. Once the POF was confirmed, the payment was earned funds as per contract. When an attorney is "paid" money for legal services, can't they use the money as they please? As to my telling clients the project funding was imminent, it would have been a conveying of what was told to me by the funding the Trust, (Mr. Louis). Fact is; clients, referrers and I received our funding updates from Mr. Louis. I wanted the project funding to commence just as much or more than the clients did. The commencement of the funding would have removed any refund liability. Secondly, the higher earnings for me would have been the back-end POF management commissions to be earned from the project funding proceeds. I was to be paid an average of about $10K per month, per client as the monthly project funding disbursements occurred for each client over a twelve month funding period. A $120K per client annually per funded client. Please see the attached two documents from a client transaction, Mr. Patrick Sizemore. The attached Allocation Agreement confirms in the "escrow" section that when my company's contract requirements were met, the POF “payment” was remitted from client's escrow to my company as a "fee payment". The attached letter confirms Mr. Sizemore advised his client that my company had met it's requirements and the fee payment should be paid. The allocation agreement also confirms that the clients were aware there was ongoing cost to keep their POFs active. Likewise, it confirms that should there be request for refund, my company would "cause" the refund to take place. That meant providing the clients written request to the Trust, (Mr. Louis).The same pertained to each client transaction as to when the "fee payment" was earned as well as the refund policy. And as I've previously expressed; Mr. Sizemore, a registered securities broker, authored the "Allocation Agreement". He also had Mr. Louis to provide him a signed letter confirming the "Trust" was responsible for making refund of client POF fee. Frankly, your email in part reads as though it come from the prosecutor given the exaggerated time-line and false stories. How can you help me if what you believe is based on what's conveyed to you by the prosecutor? What about the evidence I provided to the prosecutor that at the time you gave me their discovery the prosecutor had not disclosed that evidence to you? This was evident by the email you sent me asking if I'd provided the evidence I provided you to Mr. Margolis and Mr. Rapp. I informed you that I had, and you subsequently sent me another email indicating Mr. Rapp said he had the documents in a file. To date, you've never addressed why my evidence was in a “file” and excluded from discovery the prosecutor gave you and you gave me. Nonetheless, God is causing the whole-truth to come into the light. This case is not just about me, it's more so about “Justice”. Blessed regards, [Will G. Woodard] (517) 853-8133
  • 22.
    David L. Lockhart,Esq. 2601 N. 16th Street Phoenix, Arizona 85006 April 18, 2013 Mr. Lockhart, This is a reply to your April 17, 2013 email. Mr. Roman was Mr. Pihakis's banker and mine. He was the Paymaster for Marco Olivas's and my joint venture. He was the Paymaster for client refunds I was generating. He is also aware that Mr. Pihakis continued to use the POF documents with my company name after I'd terminated business relationship with Mr Pihakis June 6, 2010. Mr. Roman altered me to what Mr. Pihakis was doing with the documents. How would his testimony to be hearsay? Mr. Lee was a prospective Greek Trust funding client that I urged not to pay monies for POF and wait until after the Trust funding commence to proceed. I urged him of the same multiple times. He continued to discuss funding with Mr. Pihakis up until the time Mr Pihakis was arrested. I made him aware of Mr. Pihakis's arrest. How would his testimony to be hearsay? If what these two witnesses could testify to would only be hearsay, then what the government witnesses would testify to would also be hearsay. Most of the people on the government's witness are people who have never communicated with me. In short, I don't know them and they don't know me. With regards to me coming to Arizona for the April 23 hearing; it was established in court that I did not have funds to pay for airfare and that you would motion the court for those funds. Now you tell me I have to pay my own airfare. If not for my daughter's tax refund money she just received, which she desperately needs herself, me paying for airfare and lodging by April 23 would have been impossible- as what was previously established. I will be there on the 23rd for the hearing. Likewise, will certain parties from two civil rights organizations and certain investigative journalists from the following media list who have already had attorneys to evaluated my evidence. They have concluded as you did, that I had no criminal intentions in the client transactions. In short, the other attorneys concluded just as you have expressed- I was "duped". http://theministerofjustice.blogspot.com/p/media-emailaddresses-this-page-of.html#.UW_ZGUo99Ko . Mr. Lockhart, I've been deeply damaged and hurt by the prosecutors' violation of my right to due process by not disclosing my exculpatory evidence and the continued false accusations in court. However, the damage and hurt that I'm experiencing from you, supposedly my defense representation, has taken the damage and hurt to a much higher level. I can tell you now; that every time I’ve emailed you and the prosecutor "exculpatory" information, it was also blind copied to certain organizations and investigative media parties. Now I see why God has led me to do so, and immediately after the April 23 hearing, every news agency in the U.S. will have the same information regardless of what happens to me at the hearing this coming April 23.
  • 23.
    It will beestablished (undoubtedly proven); the only "conspiracy" that has taken place, is the collaboration of the prosecution and my defense representation to “rail-road” me into prison for a crime both have evidence I didn't commit. You attested to my innocence in a previous email communication. What happen? Why did you suddenly change from advocate to adversary? I "trusted" you, just as I trusted Mr. Pihakis. However, it's very clear now that I have again misplaced my trust. But, as I've expressed to you and Mr. Rapp; God knows the whole truth, and god will cause the whole truth to be exposed. Also, as I've expressed; ultimately the battle is the Lord's- and TRUST HIM. He will never lose a battle. The truth has already made me free, and it will soon be declared by the court. Please be advised; should there be an appeal necessary to gain my freedom; the appeal is already prepared and my defense representation already established. As far as I'm concerned, you are already dismissed. I will conclude with the following: "No weapon that is formed against you will succeed; And every tongue that accuses you in judgment through you will be condemned. This is the heritage of the servants of the LORD, And their vindication is from Me, declares the LORD." --Isaiah 54:17 I believe this a promise from God that apples to all born again believers facing injustice who TRUST in God. I believe God is faithful to watch over his word to perform it. What side of the table will you be on when this happens? Regardless; I forgive you Mr. Lockhart, just as I've forgiven Mr. Louis and Mr. Rapp. God's judgment however, is of course between God & you. Blessed regards, Mr. Lockhart. [Will G. Woodard] Mr. Lockhart email communication of April 17, 2013: “Spoke with Mr. Roman and Mr. Lee. Both indicate that although you appear to be a good man they cannot offer any information at trial that would be of assistance to you because much of what they would have to offer would be hearsay. As you may already know, hearsay, unless it falls under some exception, is not allowed into evidence at trial. Thank you.”
  • 24.
    Mr. David L.Lockhart, Esq. 2601 N. 16th Street Phoenix, Arizona 85006 January 9, 2013 Dear Mr. Lockhart, Hope you and family are doing well- and also happy new year to you and your family. As what was established in our last conversation, you had immediate cases to attend to before you'd have opportunity to review my case. Therefore, I've been waiting to hear back from you. Thanks for the update. However, the best way to reach me is by phone or by postal mail, still my vision is impaired from the last series of seizures I've had. I check my email when my daughter comes over, which may be once a week. Wish I could say that I've been rapidly recovering from my recent health challenges. But, fact is I haven't regained full use of the left side of my body. I'm still receiving treatment for seizures and stroke. Getting around is a challenge, consequently the state is finalizing medicaid approval for me to start receiving in home health care. I anticipate the start of home medical service in January. As much as possible, I try not to elaborate on negatives of my health condition. So hopefully, I've shared enough for you to get the picture. In regards to the case; as I have briefly expressed in previous conversation, I've filed a complaint against Mr. Rapp (the prosecutor) with the Department of Justice (DOJ). I've since been advised that my case is being assigned to a DOJ investigator. The official investigation may commence in January. For your review, I'll forward to you in a subsequent email, the files I've forwarded to the DOJ. BTW; I've been informed there have been other party(s) to file complaint(s) with the DOJ against the prosecutor regarding this case. I kindly ask that a thorough review of the information I will forward to you be where you start your review of my case. Particularly, review of the indictment and my motion for in camera inspection of the Grand Jury information. In doing so, you'd get right to the points with regards to documented information that contradicts accusations the prosecutor made against me in the indictment. Much of it is exculpatory information the prosecutor had in his possession at the time of the Grand Jury proceedings. You would also be on the same page with the DOJ investigator, whom I'm certain will contact you during his investigation. Mr. Lockhart; other attorneys have reviewed my case and concluded that there should be a motion for inspection of the Grand Jury information, as what I'd filed. It's was expressed that I would likely not receive aggressive defense representation from any local Phoenix attorney, particularly a court-appointed attorney. That a local attorney may be more mindful of their future negotiation relationship with the prosecutor and reluctant to cut to the chase. A motion inspection of Grand Jury information is warranted because there is obvious defect of the indictment. The indictment specifically indicates, in terms of time frame, that I was a co-conspirator with Mr. Pihakis from April 2006 thru April 2012. Documented fact is; the first POF client to pay me for POF facilitation was not until December 2008. The indictment also implies that I violated my 10/13/11 pretrial release order, in that it specifically states Mr. Pihakis's and I conspired from “April 2006 to April 2012”. If this statement was known to be true, then certainly my pretrial release would have been revoked. Point is; the prosecutor knew it wasn't true when he made the accusation and the purpose of the accusation was to influence the Grand Jury to indicate. How could such accusations not negatively influence and prejudice a Grand Jury? There are other false statements noted in my Grand Jury motion, that's also contradicted by information the prosecutor had in his possession during Grand Jury proceedings. Likewise, filing of a motion for severing of defendants is warranted, because Mr. Pihakis has a three decade criminal history and I have none. Mr. Pihakis allegedly engaged in criminal activities after his pretrial
  • 25.
    release, December 2010thru April 2012, which is in part why his release was revoked. It's quite obvious that the prosecutor's intention is to use Mr. Pihakis's criminal activities against me. To overwhelm the Jury with circumstantial transaction information and most of it has nothing to do with me. This fact is demonstrated in the indictment itself and the witness list. Mr. Pihakis's history would unavoidably prejudice any jury against me. There's little question that I would not receive a fair trial joined with Mr. Pihakis. And, I'm convinced the prosecutor is more concerned about getting a conviction than he is about truth and justice. Any attorney that can't see that after reviewing the aforesaid information, is one who's chosen not to. I don't mean to be offensive nor imply anything about you or your intentions. I'm just being straight forward. Mr. Lockhart, for almost two years I haven't had my freedom and have been separated from your wife and kids. I've missed wedding anniversaries, birthdays of wife and kids, Christmas holidays, etc.. I've had to endure extreme financial hardship that's caused significant suffering of my family.-- And, I didn't even commit the crime I'm accused of- and the prosecutor has evidence of my innocence in his possession. This unjust case has taken a significant toll on my health and my family. But, we will receive recompense for all. In closing; my book that I've briefly told you about will be released in six to eight weeks, and, I’ve been blessed with a movie deal- presently in the making. I want to establish a trust for client refunds and I'd like to know if it should be something done in conjunction with the court. BTW, as you review the information I will send you, you'll learn that at the time of my arrest I was in the process of facilitating the close of transactions to pay me commissions, intended to cover the about $3.5 million dollars remaining in client refunds. It would have been the successful conclusion of about an eleven month effort. The prosecutor is aware of the transactions. Likewise, he's aware of my effort to facilitate alternative funding for the clients. Furthermore, the prosecutor knows I accepted the last Trust Funding client February 2010, and turned away all subsequent prospective clients. He knows I terminated business relationship with Mr. Pihakis June 2010. He knows I've had no contact with Mr. Pihakis since December 2010. He knows that I was just as deceived about the “Greek Trust” as the clients, their attorneys, their bankers and the other five finance professionals facilitating and processing clients for the “Greek Trust” funding. He knows that I had no criminal intention in the transactions. In short, Mr. Rapp had documented evidence of my innocence before he filed charges. Whether it is, or is not, a common practice of Mr. Rapp, this case is much like P.A. misconduct occurrences I've studied. The statistics of “Prosecutorial Misconduct” is saddening- and scary. I trust that God is using my case to somehow help make a difference. Only on this premise, do I have any peace about it all. My objective is not just to clear my name and regain freedom. I'll upload the aforesaid evidence files and send you the download link in my following email. Meanwhile, please see the attached files for your review. Thanks and blessed regards, [Will G. Woodard] 7425 Chapel Hill Dr., #101 Lansing, Michigan 48917 Land line: (517) 853-8133 P.S. Mr. Lockhart, just so you know; I've forgiven Mr. Rapp, and Mr. Pihakis- I have no malice. I've placed the case and all the related adversities on God's altar. Ultimately, the battle is the Lord's, and my confidence is because of my trust in God. I know the financial blessings to be derived from my book and movie deals are a part of God's provided recompense. And it regards to the case; how do we best defend against a well funded “created case”? As what's been suggested by other law professionals, we cut to the chase regarding defects of the indictment. Before we talk, I kindly ask that you study the evidence that I'll have to you shortly. Also, I've made two ignored requests for a Polygraph, once to Mr. Margolis, and once in a letter to Judge Rosenblatt. I am letting you know I want to take a polygraph. However, preferably NOT in Arizona. God bless.
  • 26.
    Mr. Kevin M.Rapp 40 N Central Ave Ste 1200 Phoenix, AZ 85004 Good day Mr. Rapp; August 30, 2012 Hope you’re doing well. Accompanying this cover letter is a partial provision of my Exculpatory Evidence information. There is other of this information to be subpoenaed along with some intended witnesses. The attached information consists of transaction documents and email communication exchanged between the clients and me. Some of this information is said to have been provided to the investigating authorities by clients and thereby should already be in your possession. Other pertinent attached information is email and letter communication between Mr. Pihakis, others and me. There is also email communication as well as contracts that were executed between multiple Proof of Funds providers and me. This is Proof of Funds transaction information that you may or may not have depending upon the extent of the investigation conducted by the authorities. I will not take up your time or mine extensively reiterating my innocence of the conspiracy and related charges. I'm inclined to believe you already suspect I was just as mislead and deceived about the “Trust” as all other involved parties. The clients and Trust funding administrators. Regardless; I've got truth, innocence and a trustworthy God on my side and no lies or wrong assumptions will prevail against my life, my family. It's my hope and prayerful expectation that the information I'm providing you will answer any unanswered questions you have and thereby eradicate any wrong assumptions you have made. I'm trusting you're a man who has the integrity to concede to the truth of innocence when you have information that establishes reasonable doubt of guilt. Regardless, my vindication will be publicly realized and my good reputation duly restored. What your reputation will become in the process is subject to your integrity in the process. I can't help but wonder how many fatherless homes there are in America because innocent men could not afford adequate defense representation. And how many kids are fatherless because of prosecutors being more determined to “get the conviction” than “get to the truth”. Over the past several weeks I've read about families unjustly separated and thereby the kids made fatherless. It's sad to think that people entrusted to uphold justice in society contributes to the injustice that's in society. No implication or disrespect intended. Please note: I utilized software that converts web pages to PDF file when copying the attached email communications. However, after I’d copied the majority of emails with the PDF software, I discovered JPG software that rendered better quality. I recopied some of the email communication with the JPG software that obviously needed recopying. However, should you come across PDF files that are difficult to read please advise and I’ll gladly resend as JPG file. Also, I’d like to acknowledge that I’m willing to comply with any process that may be deemed necessary to authenticate the attached email communications. Should you have any questions and/or comments, please feel free to contact me direct by phone at (517) 853-8133, or by you may contact me by email at willgwoodard@gmail.com. Thank you and blessed regards, [Will G. Woodard]
  • 27.
    Gmail - (SentRegistered) Willie Gene Woodard: Exculpatory Evidence Files https://mail.google.com/mail/u/0/?ui=2&ik=618d092be1&view=pt&q=rp... 1 of 2 Will G. Woodard <willgwoodard@gmail.com> (Sent Registered) Willie Gene Woodard: Exculpatory Evidence Files 3 messages RPost Copy <DoNotReply@rpost.net> To: willgwoodard@gmail.com Fri, Aug 31, 2012 at 7:04 PM THIS IS A COPY OF THE MESSAGE YOU SENT USING THE RMAIL SERVICE. YOU WILL RECEIVE A REGISTERED RECEIPT EMAIL WITHIN TWO HOURS TO SERVE AS YOUR COMPLETE, VERIFIABLE RECORD OF MESSAGE DELIVERY, CONTENT, AND TIME. Good day Mr. Rapp; The following links are collectively to a provision of my Exculpatory Evidenceinformation. Please click on each link to download the individually titled zip files: COVER LETTER: https://legaltrac.egnyte.com/h-s/20120831/537e52dafaf1429a 1) Mr.Pihakis: https://legaltrac.egnyte.com/h-s/20120831/d74dbd7c58ac4a07 2) JPierceE: https://legaltrac.egnyte.com/h-s/20120831/df1c02c3f24044b9 3) Master POF: https://legaltrac.egnyte.com/h-s/20120831/7cd652735804484e 4) Client Refunds: https://legaltrac.egnyte.com/h-s/20120831/10f4a4283aa44017 5) Other Related: https://legaltrac.egnyte.com/h-s/20120831/04c217332ea1430b Shouldyou have any questions and/or comments, please feel free to contactme direct by phone at (517) 853-8133, or by you may contact me byemail at willgwoodard@gmail.com. Thankyou and blessed regards, [WillG. Woodard] MrRAPP.COVERLETTER.pdf 58K RPost Copy <DoNotReply@rpost.net> To: willgwoodard@gmail.com Fri, Aug 31, 2012 at 7:23 PM 2/25/2014 2:38 AM
  • 28.
    Gmail - (SentRegistered) Willie Gene Woodard: Exculpatory Evidence Files https://mail.google.com/mail/u/0/?ui=2&ik=618d092be1&view=pt&q=rp... 2 of 2 [Quoted text hidden] RPost Copy <DoNotReply@rpost.net> To: willgwoodard@gmail.com Fri, Aug 31, 2012 at 8:51 PM THIS IS A COPY OF THE MESSAGE YOU SENT USING THE RMAIL SERVICE. YOU WILL RECEIVE A REGISTERED RECEIPT EMAIL WITHIN TWO HOURS TO SERVE AS YOUR COMPLETE, VERIFIABLE RECORD OF MESSAGE DELIVERY, CONTENT, AND TIME. Good day Mr. Rapp; The following links are collectively to a provision of my Exculpatory Evidence information. Please click on each link to or copy and paste URL in browser to download the individually titled zip files: COVER LETTER: https://legaltrac.egnyte.com/h-s/20120831/537e52dafaf1429a 1) Mr.Pihakis: https://legaltrac.egnyte.com/h-s/20120831/d74dbd7c58ac4a07 2) JPierceE: https://legaltrac.egnyte.com/h-s/20120831/df1c02c3f24044b9 3) Master POF: https://legaltrac.egnyte.com/h-s/20120831/7cd652735804484e 4) Client Refunds: https://legaltrac.egnyte.com/h-s/20120831/10f4a4283aa44017 5) Other Related: https://legaltrac.egnyte.com/h-s/20120831/04c217332ea1430b Should you have any questions and/or comments, please feel free to contact me direct by phone at (517) 853-8133, or by you may contact me by email at willgwoodard@gmail.com. Thank you and blessed regards, [Will G. Woodard] 2/25/2014 2:38 AM
  • 29.
    Gmail - Ack:Willie Gene Woodard: Exculpatory Evidence Files 1 of 3 https://mail.google.com/mail/u/0/?ui=2&ik=618d092be1&view=pt&q=A... Will G. Woodard <willgwoodard@gmail.com> Ack: Willie Gene Woodard: Exculpatory Evidence Files 4 messages RPost <acknowledge@rpost.net> To: Will Woodard <willgwoodard@gmail.com> Fri, Aug 31, 2012 at 7:07 PM Acknowledgement: Your message has been sent RPost will send a Registered ReceiptTM record within two hours as your proof of delivery, content, and official time. You have 10 messages left in your free account this month. If you are using a free account, your limit is 10 Messages per month. To continue using RPost services after you reach your monthly limit, you may either: 1. Wait until your account usage resets to zero on the first day of the next month, or 2. Purchase a service plan. To purchase a plan, please visit www.rpost.com/signupnow. This message certifies that: Your message (subject): Willie Gene Woodard: Exculpatory Evidence Files To: kevin.rapp@usdoj.gov Cc: monica.klapper@usdoj.gov, court@dlockhartlaw.com Was received by the registration service at: 8/31/2012 11:07:04 PM (UTC)* 8/31/2012 4:07:04 PM (Local) Message ID: 03D87D7511343CC1CABBBFAFBA99A52368B172B5 Network ID: <A3602CDA4F4C6D10F9D7904A4DF823CFC4C1DB37@mailplus2.la1.rpos Client Code: * UTC represents Coordinated Universal Time. Note: Bcc addresses will be included in your Registered Receipt email. Messages will have been only transmitted to recipient addresses indicated in the Registered Receipt email. Service Language Preference: English Française Deutsch Note: The service does not translate your message or attachments. Español Português For more information about RPost services, visit www.rpost.com. Nederlands P?æ ???æ ??æ æ ææ Indonesian An RPost Service RPAUTH:9FB4A71FABA89E200AAD12B71679F23FED54EDD1 RPACCOUNT:RPOST_ACCOUNT . 2/22/2014 10:01 AM
  • 30.
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  • 31.
    Gmail - Ack:Willie Gene Woodard: Exculpatory Evidence Files 3 of 3 https://mail.google.com/mail/u/0/?ui=2&ik=618d092be1&view=pt&q=A... If you are using a free account, your limit is 10 Messages per month. To continue using RPost services after you reach your monthly limit, you may either: 1. Wait until your account usage resets to zero on the first day of the next month, or 2. Purchase a service plan. To purchase a plan, please visit www.rpost.com/signupnow. This message certifies that: Your message (subject): Willie Gene Woodard: Exculpatory Evidence Files To: kevin.rapp@usdoj.gov Cc: monica.klapper@usdoj.gov, court@dlockhartlaw.com Was received by the registration service at: 9/1/2012 12:51:23 AM (UTC)* 8/31/2012 5:51:23 PM (Local) Message ID: 0E68A6092B7EFBEBC946C58D68ACCEA632793154 Network ID: <1DB17E98462EEC5F6568D1CEDDE61677280706A0@mailplus2.la1.rpos Client Code: WGWRAPP08312012 * UTC represents Coordinated Universal Time. Note: Bcc addresses will be included in your Registered Receipt email. Messages will have been only transmitted to recipient addresses indicated in the Registered Receipt email. Service Language Preference: English Française Deutsch Note: The service does not translate your message or attachments. Español Português For more information about RPost services, visit www.rpost.com. Nederlands P?????? Indonesian An RPost Service RPAUTH:9FB4A71FABA89E200AAD12B71679F23FED54EDD1 RPACCOUNT:RPOST_ACCOUNT . Will G. Woodard <willgwoodard@gmail.com> Thu, Feb 20, 2014 at 6:08 AM To: "Will G. Woodard" <willgwoodard@gmail.com>, willgw@hotmail.com, wgwoodard@yahoo.com [Quoted text hidden] 2/22/2014 10:01 AM
  • 32.
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  • 33.
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