IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND


KERI L. BORZILLERI, -

Plaintiff, Case N0.: 24-C-18-000010



v. 



3

THE STATE OF MARYLAND 

Defendant. 



 

Declaration of Michelle K. Wilson
1, Michelle K. Wilson, declare as follows:

1. Based 011 my personal experience and knowledge, I have personal knowledge of
the facts set forth in this Declaration and, if called to testify, could and-would testify competently
to those facts under oath.

2. I am currently an Assistant Attorney General in the Of?ce of the Maryland
Attorney General, a position that I have held since December 23, 2015. As an Assistant 
Attorney General, I am the legal advisor for the Maryland Police and Correctional Training
Commissions and handle civil litigation related to the correctional matters for the Maryland
Department of Public Safety and Correctional Services.

3. Prior to working for the Maryland Attorney General, from September 21, 2005
until December 19, 2015, I was an Assistant State?s Attorney in the Baltimore City State?s
Attorney?s Office. I first met Marilyn Mosby when she was elevated to the misdemeanor unit
(exact year unknown) and I was in the general felony unit.

4. On the evening of May 1, 2014, I attended an event at Westminster Hall at the

University of Maryland School of Law. The purpose of event was the celebration of the 359?

1

 

anniversary of the Alliance of Black Women Attorneys, Inc. I, along with other employees of
the Baltimore City State?s Attorney?s Of?ce sat at a table that then-State?s Attorney Gregg
Bernstein purchased. One of the other employees at the table was Syeetah Hampton-EL, who
was also an Assistant State?s Attorney in the of?ce. We were seated at a round table and Ms.
Hampton~EL was seated in front of me and at my table. During the evening, I saw Marilyn
Mosby come in to room. She sat down at a table to my left. At that time, Marilyn Mosby was
then. a candidate for State?s Attorney for Baltimore City.

5. I was facing the stage when I saw Ms. Hampton?EL looking at Mrs. Mosby with a
shocked expression. Ms. Hampton-EL looked behind her and then looked back at Mrs. Mosby.
Other attorneys seated at my table immediately reacted and said with disbelief that Mrs. Mosby .
made a throat slitting gesture toward Ms. Hampton-EL.

6. As the event drew to a close, Noelle Winder (now Noelle Winder Newman), who
was also at the table when the incident occurred, sent a text to Mrs. Mosby to ?nd out why Mrs.
Mosby made the gesture towards Ms. Hampton-EL. After Mrs. Newman sent the text, Mrs.
Newman, read the text response aloud which stating that Mrs. Mosby said Ms. Hampton-EL
would be gone, which was an acknowledgment of the throat slitting gesture Ms. Mosby made to
Ms. Hampton-EL at the dinner.

I solemnly af?rm under the penalties of perjury and upon personal knowledge that the

contents of the foregoing are true and accurate to the best of my recollection.

i.
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i-
I


April 2, 2019 

 

 

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