THE STATE OF TEXAS SEARCH WARRANT COUNTY OF HARRIS TO THE SHERIFF, ANY PEACE OFFICER OR SPECIAL INVESTIGATOR OF HARRIS COUNTY, TEXAS GREETINGS: WHEREAS, I am a Magistrate in and for Harris County, Texas, and WHEREAS Bryan Vaclavik, a fraud examiner employed by the Harris County District Attorney?s Of?ce, hereafter called Af?ant, came before me this day with a sworn af?davit (which is attached hereto and is speci?cally incorporated by reference for all purposes), requesting a warrant; and WHEREAS, I have made inquiry of the basis of said beliefs of the Af?ant and ?nd that; the af?davit sets forth substantial facts establishing that probable cause does exist for the issuance of a warrant, that the person, place or thing to be searched is not one which is prohibited nor beyond the authorization of this magistrate and that the search is requested upon proper grounds. THEREFORE, YOU ARE COMMANDED to go straightaway to the of?ces of the Wood?ll Law Firm, P.C., located at Three Riverway, Suite 750, Houston, Harris County, Texas 77056 for the purpose of searching for, seizing, and searching within when necessary, property constituting evidence used to commit the felony offenses of misapplication of ?duciary property, theft and money laundering as well as property or items, except the personal writings by the accused, constituting evidence of an offense or constituting evidence tending to show that a particular person committed an offense. These implements, instruments, property and evidence alleged in the attached af?davit include but are not limited to: 1. Any and all ?nancial, legal ?les, documents, records, books, ledgers and correspondence(s) containing the names of Amy Holsworth Castillo and Teresa L. Ribelin Cook; 2. Any and all documents and records pertaining to the transfer of currency via ?nancial instruments, automatic clearing house (ACH) or wires of United States or foreign currency, funds for the above individuals identi?ed in Item 1; 3. Any and all the computer hardware, software, and peripherals that are believed to potentially contain some or all of the items described in this warrant; computers, central processing units, computer disks, disk drives, monitors, computer printers, modems, digital cameras, any memory devices that work with a digital camera, scanners, computer photographs, and any electronic data storage device, including but not limited to ?ash memory devices, and other storage media; any input/output peripheral devices, including but not limited to data security devices and related documentation; any and all cellphones, telephones, communication devices that are capable of storing pictures, video, text, caller identi?cation devices and telephone recording equipment, including the stored data of such devices for the purpose of conducting an art-site or off-site search of these computer materials by any qualified forensic facility for imaging and analysis by experts and to retain all such computer materials within the forensic facility; and 4. Any logins and passwords for computers, software, ?le sharing access, telephones, communication devices owned by Jared Ryker Wood?ll and or the Wood?ll Law Firm, PC. HEREIN FAIL NOT, as the peace of?cer to whom this warrant is delivered, you shall execute it without delay and within three whole days and due return make by faithfully completing the form attached hereto designated for said purpose. IN THE NAME AND BY THE AUTHORITY OF THE STATE OF TEXAS. ovember 2013, EN ERED and ORDERED this the 12m at cloc .M., to attest to which I subzribe name Judge, istri Court '5 Co Texas We Printed Name FILED Chris Daniel District Clerk NOV 1 3 2018 11mo:__ Harris County: By Deputy THE STATE OF TEXAS COUNTY OF HARRIS AFFIDAVIT FOR SEARCH WARRANT Af?ant is Bryan Vaclavik, a Certi?ed Fraud Examiner, is currently the Chief Fraud Examiner, employed by the Harris County District Attorney?s Of?ce. Af?ant is assigned to the Financial Crimes Division of the Special Crimes Bureau. Af?ant has been employed as a Fraud Examiner for approximately 25 years; has investigated over two hundred criminal cases involving theft, misapplication of ?duciary property, forgery, money laundering, false statement to obtain property or credit, or engaging in organized criminal activity. Af?ant has further testi?ed as an expert witness in over 50 ?nancial related criminal cases in state court. Af?ant has reason to believe and does believe the of?ces of the Wood?ll Law Firm, P.C., are located at Three Riverway, Suite 750, Houston, Harris County, Texas 77056, more particularly described as a 20-story masonry and glass structure with a sign ?Three Riverway? af?xed to the building. Suite 750 is on the seventh ?oor having a name plate on the outside wall next to the glass doors identi?ed as the of?ces of Wood?ll Law Firm. Based on his experience and his investigation in this case, Af?ant has reason to believe and does believe that within the Wood?ll Law Firm, PC. offices there is property constituting evidence used to commit the felony offenses of misapplication of ?duciary prOperty, theft and money laundering as well as property or items, except the personal writings by the accused, constituting evidence of an offense or constituting evidence tending to show that a particular person committed an offense. Af?ant requests the Court?s permission to search the above described location, to seize, and to search within when necessary, for implements, instruments, property and evidence alleged in this af?davit include but are not limited to the following items which: 1. Any and all ?nancial, legal ?les, documents, records, books, ledgers and correspondence(s) containing the names of Amy Holsworth Castillo and Teresa L. Ribelin Cook; 2. Any and all documents and records pertaining to the transfer of currency via ?nancial instruments, automatic clearing house (ACH) or wires of United States or foreign currency, funds for the above individuals identi?ed in Item 1; 3. Any and all the computer hardware, software, and peripherals that are believed to potentially contain some or all of the items described in this warrant; computers, central processing units, computer disks, disk drives, monitors, computer printers, modems, digital cameras, any memory devices that work with a digital camera, scanners, computer photographs, and any electronic data storage device, including but not limited to flash memory devices, and other storage media; any input/output peripheral devices, including but not limited to data security devices and related documentation; any and all cellphones, telephones, communication devices that are capable of storing pictures, video, text, caller identi?cation devices and telephone recording equipment, including the stored data of such devices for the purpose of conducting an Oil-Site or o?lsite search of these computer materials by any quali?ed forensic facility for imaging and analysis by experts and to retain all such computer materials within the forensic facility; and 4. Any logins and passwords for computers, software, ?le sharing access, telephones, communication devices owned by Jared Ryker Wood?ll and or the Wood?ll Law Firm, PC. MY BELIEF IS BASED UPON THE FOLLOWING FACTS: Af?ant is Bryan Vaclavik, a Certi?ed Fraud Examiner, is currently the Chief Fraud Examiner, employed by the Harris County District Attorney?s Of?ce. Af?ant is assigned to the Financial Crimes Division of the Special Crimes Bureau. Af?ant has been employed as a Fraud Examiner for approximately 25 years; has investigated over two hundred criminal cases involving theft, misapplication of ?duciary property, forgery, money laundering, false statement to obtain property or credit, or engaging in organized criminal activity. Af?ant has further testi?ed as an expert witness in over 50 ?nancial related criminal cases in state court. Af?ant believes based on his investigation in this case that Jared Ryker Wood?ll engaged in the commission of Felony Misapplication of Fiduciary Property, Felony Theft and Felony Money Laundering and that evidence of such is located at the Wood?ll Law Firm, P.C., Three Riverway, Suite 750, Houston, Harris County, Texas 77056. In February of 201 7 an investigator for the Harris County District Attorney?s Of?ce talked to Amy Holsworth (Castillo), hereafter called Complainant, a former client of Jared Wood?ll V, hereafter Wood?ll. She alleged that Wood?ll had illegally misapplied funds from her divorce. The Complainant alleged Wood?ll misapplied funds by applying funds he had not yet earned and by applying funds for the bene?t of third parties for services that were not rendered on her behalf, but on the behalf of other clients. Af?ant began to investigate the allegation. Af?ant?s reviewed public records which indicate that Jared Ryker Wood?ll is a licensed attorney in the State of Texas representing clients with family related litigation. Af?ant spoke to I-Iolsworth (Castillo), hereafter called Complainant. Complainant told Af?ant that she ?led for divorce from her husband of 19 years, Juan Castillo, in 2012. Complainant said she changed attorneys during the divorce, hiring Jared Wood?ll in December 2013. She said that during the divorce Mr. Castillo entered in to bankruptcy. Af?ant spoke to Juan Castillo as part of the investigation. Af?ant learned from Mr. Castillo that part of the reason he ?led for bankruptcy was to protect his assets from the large purported legal fees he was having to pay out of the marital estate on behalf of the Complainant to Wood?ll. Af?ant reviewed public records, court orders, transcripts, ?nding and other documents from the bankruptcy proceedings. From these documents and speaking to Mr. Castillo and the Complainant, Af?ant learned that there was a bankruptcy hearing in which signi?cant attention was given to claims for payment by Wood?ll and the resulting payments made to Wood?ll for his representation, from the marital estate by Mr. Castillo. Af?ant noted from the court documents that particular attention was paid to a $225,000 payment made to Wood?ll for his representation of Complainant in her divorce case. Affiant learned from bankruptcy documents and speaking to Ronald Sommers, the Federal Bankruptcy Trustee that Wood?ll was forced to return the $225,000 to the bankruptcy estate but in the end negotiated the return of a lessor amount. Based, in part, on the above events Af?ant obtained and reviewed the Wood?ll Law Firm, PC IOLTA bank account records from the Bank of River Oaks. The bank records showed an account which is controlled solely by Mr. Wood?ll, his name being the only name on the account. The records showed that the $225,000.00 payment to Wood?ll for services as described above was deposited into his IOLTA account on or about September 8, 2014 leaving the IOLTA account balance at $236,807.07. In reviewing the account activity after the deposit Af?ant found the following: The $225,000 was commingled with other client funds deposited into the 0 From September 8lh through September 30?? approximately $77,231.16 in third-party payments not associated with the Castillo matter were made. All but one of the payments indicated the payments were made for other cases showing ?Holdback release? and ?Avandia settlement? notations on the checks. 0 Transfers to Wood?ll?s operating account totaled $181,500.00 during the period September 8?'1 through September The September 30, 2014 ending balance was $78,570.80; $66,763.73 more than the ending balance on September 5, 2014 after $226,500.00 in Castillo related and $109,004.89 in third-party related deposits. 0 The records through October 2014 identifies one known payment made on behalf of the Complainant for $6,500.00 on October The check was payable to The Andresen Firm, PLLC for RE: Amy Castillo. - At the end of October 2014 the IOLTA account only had a balance of $10,298.48, essentially having used the entire $225,000 payment made on behalf of Castillo. Af?ant spoke to Complainant about what the bank records showed and she said at no time did she know or authorize either funds to any third party not associated with her litigation or to another Wood?ll Law Firm account for unearned legal fees or expenditures. During the course of Af?ant?s investigation and review of Mr. Wood?ll?s Bank of River Oaks? IOLTA account another client?s funds appeared to be used contrary to a signed attomey-client agreement. Af?ant reviewed a ?divorce agreement? date June 6, 2013 showing that Ms. Teresa Louise Ribelin Cook hired Wood?ll, Wood?ll Law Firm, PC. to represent her in a divorce. The agreement outlined how Wood?ll, Wood?ll Law Firm, PC. would be compensated for work done and expenses incurred. The agreement called for an initial retainer, $75,000.00, to be paid by Ms. Ribelin Cook. Af?ant reviewed bank documents indicating the $75,000.00 retainer, paid by check, was deposited into Wood?ll?s IOLTA account on June 13, 2013. Affiant reviewed the IOLTA account and discovered it was overdrawn and had a negative balance of on June 12, 2013, the day before the $75,000.00 Ribelin Cook check was deposited. Based on Af?ant?s training, experience and review of Wood?ll?s bank records, Ms. Ribelin Cook?s funds were used to offset the $49,679.18 negative balance and used to cover a check payable to a third party not related to Ms. Ribelin Cook?s representation and litigation. Further, Af?ant reviewed Mr. Wood?ll?s, Wood?ll Law Firm, billing invoice to Ms. Ribelin Cook for the period June 6, 2013 through June 12, 2013 the day before the Ribelin Cook check was deposited. Per the billing invoice, Mr. Wood?ll, Wood?ll Law Firm, PC. only earned and expended $1,313.29 of the Ribelin Cook retainer. However. the IOLTA account?s ending balance on June 13, 2016 was only 825.320.82 indicating Wood?ll had used more than $45,000 of Ribelin Cook?s retainer for purposes not related to her case. On or about September 26, 2018, October 8, 2018 and October 9, 2018 Af?ant spoke with Kenneth Kennedy who was the Controller for Wood?ll and the Wood?ll Law Firm, P.C. Kennedy said he had worked for Wood?ll for approximate 15 years keeping the books for the ?rm. Kennedy advised Af?ant that Wood?ll directed him daily regarding the deposits and disbursements from all banking accounts for Wood?ll personally and the Wood?ll Law Firm, PC. Kennedy advised Af?ant Wood?ll would require him to transfer funds from the IOLTA account which had not been earned by Mr. Wood?ll or Wood?ll Law Firm, P.C. on numerous occasions. Kennedy said that Wood?ll uses his IOLTA account as if it was his personal bank account and described how Wood?ll ?robbed Peter to pay Paul? using the funds from the IOLTA account. Kennedy also said that sometimes Wood?ll would have him transfer {?nds from the ?rms OPERATING account the IOLTA account, something that Af?ant saw several times in the bank records. Kennedy told Af?ant that Woodfill, Wood?ll Law Firm, PC. preserves the ?nancial documents, general ledgers, ?nancial statements on a desk top computer located at the of?ces of Wood?ll Law Firm at Three Riverway, Suite 750, Houston, Harris County, Texas 77056. He also said the firm?s client ?les are saved and preserved on a ?le hosting business called Dropbox Inc.; to which the Wood?ll Law Firm, PC. subscribes. Additionally, Mr. Kennedy advised Af?ant there is an external hard drive within the of?ces of Law Firm, P.C. which contains both the Castillo and Cook client ?les. Complainant told Affiant that she has tried several times to get her case ?le from Wood?ll but has been unsuccessful. Kennedy advised Af?ant he has periodically provided temporary personal loans to Wood?ll and the Wood?ll Law Firm, PC. during his employment. He said these loans were used to assist Wood?ll and the Wood?ll Law Firm, P.C. in meeting both personal and ?rm ?nancial obligations. Affiant spoke with Shannon Sauceda, Assistant Disciplinary Counsel for the Of?ce of the Chief Disciplinary Counsel for the State Bar of Texas (SBOT). Sauceda has been employed by SBOT for the last 13 years. She oversees the investigation of attorneys who have been accused of violating SBOT rules and procedures. Af?ant showed Sauceda several summaries of source documents related to the representation of Complainant and Teresa Ribelin Cook by Wood?ll and the Wood?ll Law Firm, PC. Based on these summaries, Sauceda said she believes Wood?ll has a ?duciary responsibility to his clients. She further stated, based on the summaries, ?Jnds deposited into Wood?ll?s IOLTA account were misapplied thus causing misapplication of fiduciary property and that the Complainant?s and Cook?s funds were put at great risk of loss. Sauceda also said that if an attorney transfers ?mds ?'om an IOLTA account for attorney?s fees not yet earned, she believes this would constitute theft. Af?ant believes based on his experience and training the money obtain in this scheme was obtained in violation of Texas Penal Code Section 32.45 Misapplication of Fiduciary Property with a value of $100,000.00 or more but less than $200,000.00; Texas Penal Code Section 31.03 Felony Theft with a value of $100,000.00 or more but less than $200,000.00 and as Penal Code Section 34.01 Money Laundering with a value of $100,00 ore but less than $200,000.00. A??x?t Sworn to and Subscribed before me on this the Li. of er hilfgri??irate Harris Count Tex FILED Chris Daniel District Clerk NOV 1 3 2018 Time: Harris County. 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