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RESPONDENT’S MEMORANDUM OF LEGAL AUTHORITIES

RESPONDENT’S MEMORANDUM OF LEGAL AUTHORITIES

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Published by: Circuit Media on Apr 04, 2011
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05/12/2014

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SUPREME
COURT,
STATE
OF
COLORADO
ORGtNAL
PROCEEDING
IN
DiSCWL[NE
BEFORE
THE
PRES1DNO
DISCIPLrNARY
JUDGE
1560
Broadway,
Ste.
675
Denver,
CO
80202
Complainant:
THE
PEOPLE
OF
THE
STATE
OF
COLORADO
Respondent:
PETER
B.
ALBANI.
Court
Use
Only
Respondent’s
Counsel
LeonardBerenato
and
David
Worstell
Case
No.
F
1626
Washington
Street
10-
PDJ
-095
Denver,
CO80203
Phone:(303)
831-1669
Fax:
(303)832-4515e-mail:
Iberenato(2gwestofflee.net
e-mail:
davidworstellgwestoffice.net
RESPONDENT’SMEMORANDUM
OF
LEGAL
AUTHORITIES
 
RESPONDENTS
MEMORANDUM
OF
LEGAL
AUTHORITIES
I..
BACKGROUNDPatriciaRagusa
first
contacted
Respondent
Peter
B.
Albani
around
August
2004
when
herhome
wasbeing
searched
by
!aw
enforcement
agentspursuant
to
a
search
warrant.
Mr.
Albani
talked
to
Tier
about
the
warrant
andtheneed
to
allow
the
search
to
occur.
He
spokewiththe
lead
officerexecuting
the
search.
The
officer
agreed
that
Ms.
Ragusa
wasfree
to
leave,
that
shewas
not
in
custodyand
that
he
would
questionher
nofurther.
Ms.
Ragusa
latercontacted
Mr.
Albani
when
shewasarrested.
Shewas
originally
charged
with
72
felony
counts.
36
related
to
theft
and
embezzlement
and
36
re)atedto
computer
crime.At
that
time
she
was
beingheld
on
$1,000,000
dollarsbond.She
signed
a
fee
agreement
with
defensecounselPeter
Aihaniand
Robert
Grossman.
The
fee
agreement
was
for
S25,000
for
theinitial
attempts
to
pleathecaseand
an
additional
$75,000
if
thecase
entered
a
trial
posture
andhad
to
be
prepared
fortrial.
Defense
counselappeared
at
theinitial
advisement.
JudgeDemlow
wasunsure
of
preciselyhow
to
advise
Ms.
Ragusa
given
the
overwhelmingnumber
of
charges.
He
advised
defense
counsel
that
he
believed
she
facedover
1000
years
in
DOC.
Defense
Counseldemanded
a
preliminaryhearing
andsought
a
bond
I
 
reduction.They
obtained
the
discoverywhich
was
massive,
and
includedapproximately
1400
pages
of
bankrecords
and
reports.
Ms.
Ragusa
was
charged
with
making
36
unlawful
wire
transfers
from
various
company
accounts
where
she
worked.
These
wire
transfers
weremade
into
fourbank
accounts:
(1)one
is
her
name;
(2)one
in
her
son
Jake’s
name;
(3)
one
inher
daughter
Jacqueline’s
name;
and
(4)
one
in
herformer
common-law
husband’s
name.
Defensecounselbegan
the
daunting
task
of
tracking
downthevarious
transactionswithin
the
discovery.
Thefelony
complaint
did
notlist
the
varioustransactions
ina
particular
order.Defense
counsel
thus
had
to
reconcile
thevariouschargeswiththe
particular
transactions.
The
paper
file
quicklycame
to
take
overdefensecounsel’s
conference
room.
It
was
spread
out
over
thetable,the
credenza
and
chairs.
Not
onlywas
it
difficult
to
track
the
various
transactions
on
paper,
it
wasvery
difficult
to
tracethe
allegations
made
as
to
howMs.
Ragusacovered
hertheft.Thiscase
involved
a
verycomplicated
white
collarscheme.
Ms.
Ragusa
was
accused
of
spreading
out
thestolen
money
overmany
accounts,
businesses,
and
realestate
transactions.
Ms.
Ragusa’s
companywasaudited
on
a
number
of
occasions
by
majoraccounting
firmsand
they
discovered
no
discrepancies.
Atthe
preliminary
hearing,Judge
Demlow
boundoverthe
case
to
the
DistrictCourt.
Atone
point
Judge
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