From: Wr111am Brckenon Dam: January 12, 2018 an 114 41 AM EST 4: Harold Lan _>1v1nllram Roben Brckenon Subject: Re: Subpoena melm v. Mowbray 1 have a couple more 1ssues first, are mere any y1deo cameras In a 10 black radlus around UPMC Resolve Center localed a1333 Nonh Braddock Avenue P1ttsburgh PA 15205, wh1ch ls lacaled nearlhe Caumy Delecllves lnthe North Breeze secllon o1P111sburgh and adjacenl and me PDIN Breeze and Somh Homewood secllons blF111sburgh7 lnc1den1 a red Toyola Camry on December 17, 2017 I saw some cameras a1 me Intersecnon bl Penn Avenue and Nonh Braddock Avenue unronunalely, my second 1ssue clanhes hm 1 sun wanl documem 11 ll lnvalves my requesl for v1deb from me soulh S1de 1ncrdenl on December 10, 2017, and has several pans F1rsl, I called zone a a1 10 52 PM on Thursday, January 11, 2013, and spoke clncer Dusl1n Gal1ch 1 asked mm 11 he knew smre Ehonl sanders was on Easl Carson Slreel and whal roule she used lo go home aller leavrng lhe smre He dldn'l remember but sard he would ask her, 11 111lwasn'l already 1n repcn second, I asked rllhe knrle was submnled lorleshng He me 11 wasn't, and he menhoned abum lhe weather condrhons nav1ng some lype o1 1mpacl 1n dec1s1on 1 rnlormed Gal1ch lhal Ebonr changed and added dela1ls aboul case when Ebonr spoke lo omoer Mrchelle P1sc1le11a durlng the December 17th 1ncrdenl a1 UPMC Resolve on December 10, 2017, Ebon1lold Gal1ch lhal my clrenl "grabbed her around her neck, and she lell an obyecl her 1n her back On December 17, 2017, Ebonr dlflerenlly and lold P1sc1le11a lhal "he came lrom behrnd and pm hand aver her mumh He oul a kmre her back and lorced h1s way rnlo her home She sard lhal he kept her up and her 'Bnobs 1don'1 know rlomoer Galrch w1|| e1lher glve me more dela1ls orhle a supplemema1repan lo add charges, bul he d1d say lhal we could lusl handle at me orelrm1nary heanng that's scheduled for Thursday, January 13, 2013, at a on AM Thanks agaln 4311 Very lruly yours, v1n111am Blckerlon Allomey al Law Biokertun aickenon, LLP 1034 th Avenue Suite 400 Pittsburgh PA 15219 Phune- -- Weh' hug HBICkenoanaw com On Jan 11. 201E. at 10 37 AM VInllram Erokerton -- wrote Yes on the 4 cameras at 1E|h and East Carson. Officer Galrch was off last so I couldn't ask what store Ehonl went to and way she walked home (116 8, 1601 St) on December 10th It's a senous allegatton that my chem grabbed her trom behrnd and Iorced her rmo her apartment a knlfe. I'm not to be unreasonable but my chem spent 5 months lnjall because ofa he. II I wont have that vrdeo alrbr, he'd probably be a felon and a on the State Polrce Megan's Law websrte, Whrle I'm on Sublect' I want to follow through havrng Ebonr prosecuted. I spoke Mr Fodr last summer about thus and he had tha Sherry send me the form I gave It to my clrenl. but he wont follow through. unfortunately, I don't know what to tell you about weekend's vroeo I have the cellphone number Ior Ebom Sanders rt you want to call her or have someone else call her Itwe knew when she last check her marlbok. we could potentrally determrne a trmetrame Trust me. I'm not pleaseo that I have to look Ior neeoles In haystacks to prove my cltent's Innocence. agarn The polrce find Ehonl to be very but so rs Meryl Streep. Here's Ebonrs actmg profile. eproretaIent She's so the atfiant In the 3rd case tolo Elmnl to gel a PFA (she doesn't oualrty for one). ano the atfiant spoke Sex Detectrve Sellers ano was 90th to tax her report to Detectrve Sellers routmely requests that my cltems Suhmll to polygraphs, Maybe he coulo Elmnl Suhmll to a polygraph. Ehont also tolo the affiant In the 3rd case that Thomas kept unoer Ebonrs shut and was her boobs as he torced hermto her apartment on December 10th at knrtepornt, But that oetarl rs not In the December 10m amdavllI and Thomas rs not charged rndeoent assault. I've now spoken 3 of the 4 thams the new cases They ellher don't belreve me or don't care, So now I have to subpoena PAT records cellular records, and enough vrdeo to keep me busy umrl 2019, I don't know what to tell you. I'm trreo ofdealtng Ebom. ano I'm Irustrated, untortunately. I have to make broad requests because Ehonl changes her story ano blatantly hes. As a result. I have to rnconvenrenoe myselt ano everyone else. II you can of way that your office or the polrce can In provrng the or mnooenoe of my otrent baseo on objectlve evtdenoe and not soier on the of a known her, run all ears Otherwise, it is what It IS I do apprectate what yau've done 50 lar, and you've been very quick responde to my emaus and requests Thank yau again 43m Very truiy yaurs, William Blokenon Allomey a| Law Bunkenon Blokenon. LLP 1034 Fiflh Avenue Sulle 400 Pmsburgh PA 15219 Web HBickeflonsLaw corn swan1i2mesoaAMvAnwesthicnaei-- wrote i have no idea what you are \oaking for but at some of the intersections on Carson St there are 4 cameras, one for each direction, can we restrict the request to just 1 or 2 directions? To downioad the entire video reduested win take days From your emaii it sounds like we are iooking at someone ior multioie accessing a rnaiibox, how about iets see it the rnaiibox in question is shown on the video? As i was down the anaiysts trying to deterrmne number of cameras, amount ofvldea etc for the second subpoena we reaiized that 4 cameras at 18'" and East Carson had not written over for the dates on the subooena [the one for December a 3. do you want them7 Agam, there is one camera for each direction so let rrie know which ones you want. Sent: Thursday, January 11, 2018 1.06 AM Cc: Lanai Harold Subject: Re: Subpoena u. Mowbray From: WHIiam Bickerlon [malito So the affiant called me back at 12 05 AM I asked If he could find out when Ebonl Sanders last checked her mmlbox He didn't knovt, and he basically sald that It would probably be dtffieult to find out that mformatton [hlS ttme but would let me know when he found out later Anyhay we have a 4 TB drwe and 2 TB drtve our house eurrehtly But 111 go to Costco or Sam's Club to buy "hat I need to protect my elte 's We also have Amazon Prrme so we can quickly purchase 2 very large drtve to preserve even more vtdeo because 11': that Ebont hadn't checked her mall for days So vtho knows when these death threats "are place her matlbox Very truly yours Blokenon Allomey at Law Bunkenon Blokenon. LLP 1034 Fun Avenue Sutte 400 PA 15219 Phone -- Web hug l/Blekenoanaw com On Jan 10, 2018, 3 32 Ah h, Michael For the enttre 2 day penod we are looking at over a terabyte ot'mformatton, oVer SUI.) hours of Can we cut down the hours" Sent from my IPhone On Jan 10, 2018, 3 11 PM_er1tam Blekenon wrote I truly wish I could be more specific. I understand that I’m asking for a lot. The problem I am dealing with is that I’m trying to prove that something didn’t happen and my client is being held on almost a quarter of a million dollars in bail. In my past experience with the accuser in this case, I was able to prove that she was lying because I requested videos that went beyond the locations where she indicated the encounters took place. One of the complicating factors is that her story changes often. Her details about time and location are very fluid. If I hadn’t been broad in my previous requests, I would not have been able to show that she was untruthful. My client can’t afford to risk having potentially exculpatory video overwritten. Assistant District Attorney Doug Maloney prosecuted two cases against Mowbray in 2016. In the first case, Mowbray pleaded Nolo to summary offenses because we could not prove that the incident did not occur (​https://ujsportal.pacourts.us/DocketSheets/CPReport.ashx?docketNumber=CP-02-CR -0006681-2016​). In the second case, Mr. Maloney submitted a Nolle Prosse after Mowbray spent five months in the ACJ with a bail of $250,000.00 (​https://ujsportal.pacourts.us/DocketSheets/CPReport.ashx?docketNumber=CP-02-CR -0010524-2016​). I retrieved a large window of video from Wood Street Commons because I did not have a definite timeframe. Sanders’ testimony at the preliminary hearing was vague and inconsistent with the information in the criminal complaint. Fortunately, Sanders called 911. The 911 calls provided audio of Sanders sounding like she was in active distress and gave me a much narrower window. With that narrower window, we established a video alibi. Mowbray did not leave the building during the time of the alleged encounter and he was not even wearing the clothes that she described in the 911 call. The police took a copy of the video alibi to their Sergeant or Lieutenant to see if they were going to charge Sanders, but nothing happened. In my third dealing with Sanders, she tried to get a Protection of Victim of Sexual Violence or Intimidation (PVSVI) against Mowbray in 2017. In the paperwork, she said she got on a bus at 12 AM on Penn Avenue, that Mowbray saw her and ran through the alley and got on a bus behind her. Looking at the bus schedules, I determined that her story was implausible. Since the buses run 15 minutes apart at a minimum when it is that late, I determined that, if there was an encounter, Mowbray would have been on the same bus. When I spoke with Sanders in person, she changed the details and said that Mowbray didn’t get on a different bus, but that he actually got on the same bus as her. When we continued the hearing so she could get a lawyer, I used the extra time to get the proof that she was lying. I retrieved the video from the PAT bus and the PAT records showing the buses and times that Sanders and Mowbray rode because they both have registered accounts. When I told Sanders that I had the video, she asked me what it showed. I told her that neither she nor Mowbray was on a bus at that time. I still have everything that I have collected. Even though I have been able to prove that Eboni Sanders has lied under oath, the police keep charging my client without fully investigating the incidents. I have spoken with the affiants in two of his four new cases, but each officer has said that they find her persuasive, regardless of the fact that I was able to prove that she perjured herself and submitted false police reports in the past. Thanks.-Bill Very truly yours, William R. Bickerton Attorney at Law Bickerton & Bickerton, LLP 1034 Fifth Avenue Surte 400 PA 15219 Web We HBmkenaanaw com On Jan 10, 201x, at 11 36 AM, Ahwesh, Michael Can vou be any more Specific with your request? You are asking for 43 hours of yrdeo from mumple cameras, that's a '01. N50, redactmn of parts of the video may be necessary, to protect the prwacy of nonsmvolved partnes at a mrmmum. From: wmiam Bickerton [mamm-- Sent: Wednesday, January 10, 2013 11 18 AM Cc: Ahwesh. M'chael Subject: Re: Subpoena melth y. Mowbrav Sorry to bother you agam but hme another request msrde the tenth} mndou Here |s the subpoena request Thanks 713m Very (My your; tham Blckenan Auomey a| Law Blakenon Blckenan. LLP 1034 FM Avenue Suns 400 PA 15219 Web hug HBmkenaneLaw com On Jan 9, 2018, at 3 12 PM, Lane, Harold wrote HeHa Mr. chkerton, Attorney Mxke Ahwesh will be cantactmg you Lm'ess you have a'ready ta'ked rum-1e read over me Subpoena. Thankyou, Harold \nspector Harom c. Lane Branch/Superwsm AHegheny County Attorney's Office 1444 HIHsda\EA\/enue Pa 15215 - -Ax From: Wuham Bickenon [mailm-- Sem: Tuesday January 09 2018120 PM To: Lane, Harald Subject: Subpoena meM Mowbray Mr Lane: Here .5 a copy oflhe subpoena Thank you 73111 Very my your; Wilham Blokenon Allomey a| Law Bunkenon Blokenon. LLP 1034 Han Avenue Suns 400 PA 15219 Web hug HBmkenaanaw com