Case # 10-042631 0112512010 Homicide Location: 5732 Hwy. 60.

Plant City, Fl 33567 Victim:

Abraham Shakespeare Arrested:

Dorice "Dee Dee" Moore

Volume 4

..

Hillsborough County Sheriff's Office Waiver/Affidavit

CONSENT TO SEARCHIW AIVER OF SEARCH WARRANT

I, [ ], do hereby consent and authorize that t e c~ ... uter equipment located at

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searched by any Hillsborough County Sheriff's Office Law Enf9rcement Official or any other Law Enforcement Agency Officialf on and off premises) . 6 t["U- :2/vf;i014.,./

!/Nl:_JSt.~lltk IF- IYZ;)U_ )t!.!Jf!_.4 w_/ ~d4j/l!'&-- ) This consent includes all computer equipment (i.e. hard drives, diskettes,' external drives, video tapes, Cds, and zip drives, any closed or locked containers, online computer accounts, and magnetic or electronic storage media). I understand that the computer equipment may be removed from the premises in order to conduct a thorough search. I further agree that anything or any article that may be found in the search of the computer equipment may be used at trial in any manner of which I may stand accused. I fully understand my constitutional rights in regard to the search and it is my intention to fully and completely waive such rights by this consent. I give this consent freely and voluntarily, without compulsion or threat of any kind.

Signed this

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Witness: _

Witness: _

Hillsborough County Sheriff's Office Waiver/Affidavit

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CONSENT TO SEARCHIW AIVER OF SEARCH WARRANT

I, [ ~ ], do hereby co~ent and aU~,horize ~l;Iat the computer eq~ipment located at

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searched by any Hillsborough County Sheriff's Office Law Enforcement Official or any other Law EnforcementAgency Official(on and off premises) , EcOAC_&,v£__

/11b42-L S)qf/t..JSy 1tt!.t;vJ)£_1 ,¥tv t7JI,vI/ ) This consent includes all computer

equipment (i.e. hard drives, diskettes, external drives, video tapes, Cds, and zip drives, any closed or locked containers, online computer accounts, and magnetic or electronic storage media). I understand that the computer equipment may be removed from the premises in order to conduct a thorough search. I further agree that anything or any article that may be found in the search of the computer equipment may be used at trial in any manner of which I may stand accused. I fully understand my constitutional rights in regard to the search and it is my intention to fully and completely waive such rights by this consent. I give this consent freely and voluntarily, without compulsion or threat of any kind.

Signed this --,-1-,,8 __ Day of !j~

20~ at _ ___,./,,-/,-/..J_'---=_':::_~ hours.

Witness: _

Witness: _

on or about November 9, 2009, stated she paid him over $500,000 in cash. In a subsequent statement given to Polk Sheriff's Detectives on January 25, 2010, Ms. Moore stated that she had not paid Abraham Shakespeare because Shakespeare had a drug problem and she felt that he would use it to buy drugs. In a statement given to detectives on January 29, 2010, Ms. Moore stated that she had not paid Abraham Shakespeare because he did not want to pay the gift tax owed on the amount. A review of Dorice (Dee Dee) Moore's bank records has not revealed corresponding withdrawals, checks, or transfers indicating payment for the home, to date.

After receiving his lottery winnings, Abraham Shakespeare made multiple loans to individuals to buy homes and recorded mortgages documenting the loans. On January 11, 2009, Mr. Shakespeare signed Quitclaim Deeds to American Medical Professionals, LLC for

properties located at 1418 West Lake Parker Drive, Lakeland, Florida and 409 Pearl Street, Lake Hamilton, Florida. Each deed was recorded on 02-11-09.

On January 15, 2009, Mr. Shakespeare signed an "]1.sset Purchase Agreement" which sold all of his un-enumerated "assets" to American Medical Professionals LLC for the price of $185,000. The value of outstanding loans purchase in the "Assets Purchase Agreement" plus the value of real estate separately purchased total over $3.5 million worth of assets for less than 5 cents on the dollar. Although a copy of the Asset Purchase agreement has been obtained by investigators, the "Addendum" to the agreement has not been located. The "un-enumerated assets" sold by Mr. Shakespeare to American Medical Professionals were purportedly

to be listed in the addendum. (A copy of the "Assets Purchase Agreement" is attached here to as Exhibit "C")

On both the 15th, and 16th of January 2009, Mr. Shakespeare signed paperwork documenting the fact that the following

AFFIDAVIT

FOR SEARCH WARRANT

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

STATE OF FLORIDA

COUNTY OF HILLSBOROUGn-j,

BEFORE ME, HONORABLE, liJm- ~ C5?: CIRCUIT COURT JUDGE, THIRTEENTH JUDICIAL CIRCUIT , in and for Hillsborough County, Florida, personally came affiant Detective Greg Thomas, Hillsborough County Sheriff's Office and co-affiant Detective Christopher Lynn, Polk County Sheriff's Office being first duly sworn, deposes and says: That affiant and co-affiant are reputable Deputies of said Hillsborough County and Polk County, State of Florida, and that they have reason to believe and do believe that certain certain computer equipment located in Hillsborough County, Florida, described as follows, to-wit:

SEE ATTACHED EXHIBIT "A" WHICH IS HEREBY INCORPORATED BY

REFERENCE AND MADE A PART HEREOF

and there is now being kept within said computer equipment certain evidence of criminal activity including but not limited to computer equipment, computer programs, computer storage devices, to include but not limited to CDs, removable drives, thumb drives, pen drives, removable secure storage devices, graphic files, and any other media that can store digital files and/or digital media. Phone records, records of Internet Service Providers, E-mails and other computer data, including but not limited to encryption, passwords telephone numbers,Emails, Instant messages, computer images, computer programs and system documentation; documents files or any other computer data relating to encryption, passwords, and/or access to or ownership of the computer and Internet Service Provider, documentation used in violation of the laws of the State of Florida to-wit: law prohibiting, F.S.S. 782.04 Murder

being the premises occupied by or under the control of

WHITE MALE, DAVID HOWARD STITZEL D.O.B. 03/04/1964 AND ANY OTHER UNKOWN NAMES

Physical Evidence: eMachine central processing unit with a serial number of GCJ7A20000438, used in violations of laws of the State of Florida, to-wit: 782.04 Murder

It will become necessary for reasons of practicality to remove

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the hardware and conduct a search off-site. Your affiant and co-

affiant believe that, in this case, the computer hardware is a

container for evidence, a container for contraband, and also

itself an instrumentality of the crime under investigation.

That the facts tending to establish the grounds for this application and the probable cause of affiant believing that such facts exist are as follows:

The affiant Greg Thomas, a Detective of the Hillsborough County Sheriff's Office being sworn states:

1. Your affiant is an Investigative Law Enforcement Officer as defined in Florida State Statute 934.02, and is making this application pursuant to my official duties.

2. Your affiant is authorized to do so by the Honorable Mark Ober, State Attorney for the Thirteenth Judicial Circuit, Hillsborough County, Florida, pursuant to the authority conferred upon him by F.S.S. 934.07 .

3. That the affiant is a member of the Hillsborough County Sheriff's Office and has been so employed since October 2000. Your affiant has been assigned to the Criminal Investigations Division as a Detective since August, 2003. Your affiant has been a participant in the execution of numerous Search Warrants.

The co-affiant Christopher Lynn, a Detective of the Polk County Sheriff's Office also being sworn. The co-affiant has been employed with the Polk County Sheriff's Office since July of 2002.

Your co-affiant has been assigned to the CID as a Detective for approximately 3 1/2 years. Your co-affiant has been a participant in the execution of numerous Search Warrants.

Abraham Shakespeare won $31 million in the Florida lottery.

Shakespeare elected the lump sum payout and collected approximately $12.7 million after taxes. Shakespeare was sued by a co-worker who made claim to the winning ticket. Ultimately the court ruled in the favor of Shakespeare in 2007.

Between winning the lottery in 2006 and meeting Dee Dee Moore in 2008, Mr. Shakespeare spent, gave away or loaned the majority of

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his winnings and was left with approximately $1.5 million in cash and assets totaling approximately $3 million. Shakespeare utilized several financial institutions, seemingly one after another on the whim of various advisors: from Wachovia, along with various Annuity holdings, to Community Bank and eventually to Bank of America. Mr. Shakespeare did not invest heavily and was reported to be unimpressed with annuities to the point of pulling all of his money out and using the money to seed accounts accessed by Dee Dee Moore.

In December of 2008, Mr. Shakespeare liquidated an annuities account worth approximately $250K. In January 2009, this money was transferred to the business account of American Medical Professionals, a business owned by Dee Dee Moore since 2004. In her interviews, Ms. Moore stated this money was provided to her for the purposes of paying taxes on behalf of Shakespeare. This money was tracked to several recipients including Ms. Moore's boyfriend, Shar Krasniqi, and Real Time Services, American Medical Professionals' payroll and accounting service. Additionally, a review of bank statements of American Medical Professionals and accounts related to Dee Dee Moore has shown that Moore utilized the American Medical Professionals checking account as her primary account including personal charges. Any personal accounts of Dee Dee Moore that have been located have minimal activity. Investigation has not revealed any records of these funds having been used to pay any tax debt of Abraham Shakespeare.

Land Transfers

On January 9th, 2009, Mr. Shakespeare signed a Quitclaim Deed to American Medical Professionals LLC on his primary residence, 9340 Redhawk Bend Drive. The deed was recorded on 01-13-09. Abraham Shakespeare paid $1.07 Million in 2007 for the home, and Dee Dee Moore, in a statement given to Polk County Sheriff's detectives

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mortgages were hereby ASSUMED by American Medical Professionals LLC.

Property Loan Amount Mortgage Assignment Date
Address Dated Dated Assignment
Recorded
648 West 4th $14,752.00 March 13, January May 6,
Street, 2007 15, 2009 2009
Lakeland
727 East $63,000.00 February January May 6,
McDonald 23, 2007 15, 2009 2009
Street,
Plant City
1103 Neville $69,000.00 May 14, January April 1,
Avenue, 2007 16, 2009 2009
Lakeland
3075 Sire $185,000.00 April 4, January April 1,
Trail, 2007 16, 2009 2009
Lakeland
Rodman $52,000.00 December January April 1,
Development, 17, 2007 16, 2009 2009
Inc. All of these transactions have been recorded by either the Clerk of the Courts or the Polk County property Appraiser's Office. Also, all of these transactions were prepared by Howard Stitzel. This fact was noted via the header on the top left of the front pages of all of these documents. Further, Howard Stitzel, maintains a law office at 5802 State Road 60 East, Plant City. The Law offices of David Howard Stitzel shall be among the locations with that address that shall be searched pursuant to this warrant. The property is titled in the name of Shar Krasniqi.

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ABRAHAM SHAKESPEARE, LLC

On February 5, 2009, a faxed request form for surrender of the Prudential Annuities Account in the name of Abraham Shakespeare, purportedly with Shakespeare's signature, was faxed from Staples in Lakeland, Florida. The surrender form requested the full amount contained in the account, $1.095 million, to be paid in the form of a check made payable to Abraham Shakespeare and sent via mail to his address.

On Feb. 9, 2009, Ms. Moore registered the business Abraham Shakespeare LLC, with the Department of State, Division of Corporations, where she is listed as the registered agent and director.

On Feb. 10, 2009, Ms. Moore opened an account at Bank of America in the name of Abraham Shakespeare LLC with $100 cash. Ms. Moore was the only signor on the account at that time.

On February 11, 2009, Dee Dee Moore provided the bank Articles of Incorporation along with papers purporting to be "meeting minutes" of the "board" of Abraham Shakespeare LLC. Contained among the meeting minutes were minutes of a "meeting" which was purported to be "attended" by Dee Dee Moore, Judith Haggins and Abraham Shakespeare. The documented discussion was about adding Abraham Shakespeare's name as an authorized signer. Further, the $1.095 million check from Abraham Shakespeare's Prudential Annuities account was then deposited into the Bank of America account in the name of Abraham Shakespeare, LLC. on February a i" 2009. Judith Haggins is a longtime friend of Abraham Shakespeare.

She met Dee Dee Moore through Abraham Shakespeare and soon became a business associate of Dee Dee Moore. Judith Haggins acted as Abraham Shakespeare's paid driver and personal assistant.

No activity occured in the Bank of America account until Feb. 17th, when the bank was again provided with "meeting minutes" of Abraham Shakespeare LLC. by Dee Dee Moore. Ms. Moore was the only person listed in attendance. These "minutes" describe the discovery of "criminal activity" on the part of Shakespeare, which may result in criminal charges. Therefore, Shakespeare was to be removed as an authorized signer of the account. Bank of America therefore removed Shakespeare as an authorized signatory.

From February 10, 2009 to February 17, 2009 the account shows no activity. On February.18, 2009, a cashiers check for $250,000 drawn on the Abraham Shakespeare LLC. Account was made payable to ASTAT and was deposited to Navy Federal Credit Union account. ASTAT and Supply, LLC was a business registered with the Department of State Division of Corporations and was reinstated as an active corporation on October 15, 2008. Shar Krasniqi was listed as CEO. Additionally, the account holder of the Navy Federal Credit Union account is Shar Krasniqi. Further, on February 18, 2009, a cashiers check for the sum of $250,000 was drawn on the Abraham Shakespeare LLC. Account made payable to the Internal Revenue Service. This check was endorsed by D. Moore. Notated on the check, in the endorsement section, were the hand written words "not needed for intended purpose". This $250,000 check is then deposited into the business account of American Medical Professionals LLC. By the use of the endorsement "not needed for intended purpose" Dee Dee Moore was able to divert the sum of $250,000 from its intended purpose to her own control and benefit. On February 19, 2009 and February 23, 2009, cashiers check for $200,000 and $250,000 respectively, were drawn on the account of Abraham Shakespeare LLC and were made payable to American Medical Professionals.

During the month of February 2009, Judy Haggins and D. Howard

...

Stitzel received approximately $20,000 each from the account of Abraham Shakespeare LLC. An electronic debit check made payable to the Internal Revenue Service in the amount of $30,000 was issued from the same account. The balance of the Abraham Shakespeare LLC account as of Feb 28, 2009 was $44,296.

Transactions from the Abraham Shakespeare LLC, Bank of America account show funds were transferred to the account of American Medical Professionals (Dee Dee Moore), ASTAT and Supply (Shar Krasniqi) just two months before the purchase of a residence located at 5802 Hwy. 60 East for approximately $253,000 in April, titled to Shar Krasniqi. Richard Land, the former owner of the property, stated to detectives that Dee Dee Moore paid him with a check from the account of American Medical Professionals.

CONTROLLED PHONE CALL CONCERNING HOWARD STITZEL

On 11/12/2009, Detective David Clark and Detective David Wallace responded to the law office of D. Howard Stitzel located at 5802 Highway 60 in plant City, Florida. Detectives Clark and Wallace then interviewed Mr. Stitzel in reference to the investigation. During the interview, Mr. Stitzel advised that he could not comment about the details of the conversation, but would confirm that he spoke to Mr. Shakespeare on the cellular telephone of Ms. Moore on October 6, 2009. When asked how he knew that he was speaking to Mr. Shakespeare, D. Howard Stitzel advised that Mr. Shakespeare was his client and that he was familiar with the voice of Mr. Shakespeare and that was who he was speaking to on the telephone.

During a December 3rd, 2009 interview with Polk County Sheriff's Detectives David Clark and David Wallace Dee Dee Moore stated that Shakespeare's telephone was part of the plan that Mr. Shakespeare had made to leave town. Ms. Moore advised that Mr. Shakespeare advised her to text message people after he left

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using his phone that he left with Dee Dee Moore so the police could not track him. Ms. Moore was then asked to confirm that she had Mr. Shakespeare's cellular telephone in her possession at the time that she had originally advised tha~ both she and D. Howard Stitzel had spoken to Mr. Stitzel on 10/06/2009. Ms. Moore confirmed that she was in possession of Mr. Shakespeare's telephone at that time and that neither she (Moore) or D. Howard Stitzel had spoken to Mr. Shakespeare on that date (10/06/2009). Ms. Moore was then asked why D. Howard Stitzel had told Detectives Clark and Wallace that he had spoken to Mr. Shakespeare. Ms. Moore advised that she asked Mr. Stitzel to say that to Law Enforcement and he (Stitzel) had agreed to lie to Law Enforcement to assist Ms. Moore. Ms. Moore then placed a controlled (taped) telephone call to Mr. Stitzel's cellular telephone. During the call, Ms. Moore advised Mr. Stitzel that Law Enforcement was asking her questions about the telephone call in which both she and Mr. Stitzel had allegedly spoke to Mr.

• Shakespeare on 10/06/2009. Ms. Moore conveyed to Mr. Stitzel that she was concerned that Law Enforcement would find out that they

had not spoken to Mr. Shakespeare on that date and wanted to confirm that he (Stitzel) had told Law Enforcement that he (Stitzel) had spoke to Mr. Shakespeare on that date. Mr. Stitzel advised that he had told Law Enforcement that he had spoken to

Mr. Shakespeare on that date. Ms. Moore then asked Mr. Stitzel what would happen if she told Law Enforcement that she had possession of Mr. Shakespeare's cellular telephone. Mr. Stitzel then began telling Ms. Moore that she needed to stop talking to Law Enforcement. Although Mr. Stitzel made no direct admissions that he had in fact lied to Law Enforcement, it was apparent that Mr. Stitzel was aware that Ms. Moore had Mr. Shakespeare's cellular telephone and had not spoken to Mr. Shakespeare on 10/06/2009, as he had told Law Enforcement on 11/12/2009.

HOWARD STITZEL

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During an interview on December 3, 2009 with Dee Dee Moore by Polk County Sheriff Detectives Wallace and Clark, when questioned about the above described money and property transfers she explained, she and Abraham Shakespeare, with the intent to avoid paying any child support, intentionally transferred all money and assets out of his name into the name of American Medical Associates. As stated above, Howard Stitzel's name appeared on the deed transfers. Additionally, Howard Stitzel was the Attorney of record representing Shakespeare in the child support enforcement action. This action commenced January 14, 2009. Howard Stitzel filed his response as Abraham Shakespeare's attorney on March 6, 2009. Abraham disappeared in April 2009. As mentioned in the above section with the controlled phone call, Howard Stitzel made an implicit admission confirming his misrepresentation to police during the Polk County Sheriffs missing person's investigation. According to records on file with the Polk County Clerk of Courts, Howard Stitzel appeared in person in a Polk County Court in August 11,2009 in the above mentioned Child Support Enforcement Action, and told the Judge that Abraham Shakespeare wasout of the country receiving treatment as an explanation for his client's nonpresence. Howard Stitzel was also interviewed for a Ledger newspaper article which appeared on Decemberl, 2009. Stitzel was quoted as saying ''that the last time he talked with his client was in October when they discussed child support issues ... Stitzel said Shakespeare did not sound distressed during his phone conversation in October."

David Howard Stitzel represented Abraham Shakespeare in child support proceedings and drew up numerous document related to a variety of transactions described herein, including an assets purchase agreement with addendum, property deeds, Quitclaim deeds, contracts, mortgages and power(s) of attorney. David Howard Stitzel received three separate checks in February of2009 totaling $17,500 from Abraham Shakespeare LLC. All of these checks bore the signature of "Dee Dee Moore". During an interview with Detective Chris Lynn (Polk County Sheriffs Office) in November 2009, Dee Dee Moore stated that these checks were compensation for legal services rendered by David Howard Stitzel.

OVERVIEW OF HISTORICAL PURCHASES OF ASSETS

On 03/06/2007 Shakespeare purchased a BMW for approximately $100,000 -.~~==~~==~~~~======~

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01/29/09 Dee Dee Moore bought a 2009 Lincoln MKS and titled it in the name of Abraham Shakespeare LLC. The same day she traded the Lincoln to Abraham for his BMW. She then titled BMW in the name of Shar Krasniqi

04/14/09 Dee Dee Moore traded the 2009 Lincoln MKS for a 2009 Chevy Silverado. $31,000.00 was allowed for the Lincoln and Dee Dee paid $13,302.60 in cash for the remaining balance on the vehicle

11/03/09 Dee Dee Moore took the BMW to Stingray Chevrolet and sold it to them for $37,000.00.

Shakespeare purchased a Ford 500 on 7/9/07

In Early April 2009, Dee Dee Moore called Sentorria Butler and told her Abraham left his Ford 500 for Butler and it was at Moore's house. Sentorria Butler lS the mother of Abraham Shakespeare's infant child, Jeremiah. In 2009, she initiated child support proceedings on behalf of her son against Abraham Shakespeare. After the aforementioned telephone call, Dee Dee Moore picked Sentorrria Butler up and took her to pick the car up. Sometime around 5/10/09 Judy Haggins took the vehicle back from Sentorria Butler using the power of attorney as authority to take the car back.

• On 6/18/09, Dee Dee Moore took the 07 Ford 500 registered to

Shakespeare and Associates to Stingray Chevrolet and sold it outright to them for $9,000.00. She presented the dealership with paperwork from the Florida Division of Corporations which showed her as the Manager of Abraham Shakespeare LLC, a completely different corporation. She signed the title as "CEO" of Shakespeare and Associates, which had been inactive since September 2008. Shakespeare and Associates LLC. was incorporated in 2007 by Abraham Shakespeare and an attorney,

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Cedric Lewis, as a business entity to store Shakespeare's assets. Dee Dee Moore was never listed as an officer or director of Shakespeare & Associates LLC.

On or about February 21, 2009, Dee Moore bought a 2008 Chevrolet Corvette from Stingray Chevrolet for her boyfriend, Shar Krasniqi. She paid $70,390.86 for the vehicle with a cashier's check from American Medical Professionals LLC.

On March 2, 2009, Dee Dee Moore purchased a 2009 Hummer for approximately $90,000. On December 5, 2009, Dee Dee Moore took this vehicle to Stingray Chevrolet and told them she needed cash quickly and attempted to sell it to them for $49,000.00. They told her they were not interested due to the economy. William Smith, a friend of the owner of Stingray Chevrolet was present and offered to buy the Hummer himself. Dee Dee Moore agreed to sell it to him and requested that Mr. Smith call his bank so that

• she could cash the checks immediately. She also requested 3 separate checks from Mr Smith, one for $5,000.00 in the name of Dee Dee Moore, one for $4,000.00 in the name of Linda Donegan (Dee Dee Moore's mother) and one for $40,000.00 in the name of

Dee Dee Moore.

Power of Attorney

Notary Ambrose E. Austin was interviewed by Detective David Cavanaugh of Polk County Sheriff's Office, during the week of November 9, 2009. Mr. Austin told Detective Cavanaugh that on April 3, 2009, Shakespeare signed a Power of Attorney designating Judy Haggins as his POA. Notary Ambrose E. Austin stated Haggins was present during signing and advised Shakespeare was present. On November 13, 2009, Ms. Haggins told Detectives Wallace and Clark that this was the last time that she saw Shakespeare alive.

Haggins has, in fact, used the power of attorney to close bank accounts belonging to Abraham Shakespeare and sign court

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pleadings on Abraham's behalf. Proceeds of closed accounts have been deposited into accounts controlled Dee Dee Moore.

On or about December 11, 2009, in a recorded conversation with Gregory T. Smith acting in the capacity as an informant with the Polk County Sheriff's Office, Judy Haggins stated that, in or around March 2009, Abraham Shakespeare approached her about concerns regarding Dee Dee Moore and his money. Haggins talked to Dee Dee Moore around the same time and Moore told Haggins not to let Shakespeare go to the bank because some of the money was not there. In all subsequent law enforcement interviews with Ms. Haggins, she has not admitted that this conversation had occurred. Gregory T. Smith became an informant with the Polk County Sheriff's Office as a result of a series of events, which

are described later in this affidavit. Abraham Shakespeare from Lakeland, Fl.

Mr. Smith was a friend of On February 23, 2007

Shakespeare and Associates LLC. obtained the mortgage to the

• house of Gregory Smith's mother. On January 15, 2009 Shakespeare and Associates LLC. assigned this mortgage to American Medical Professionals.

Additional Information

On or about November 9, 2009, Detective Chris Lynn began subpoenaing financial records of Mr. Shakespeare as well as those of Ms. Moore to include numerous Limited Liability Corporations (LLC) associated with Ms. Moore and her boyfriend Shar Anthony Krasniqi. It should be noted that numerous financial documents

were also voluntarily turned over to the Polk County Sheriff's Office by Ms. Moore during this investigation and numerous public record documents have been obtained related to the involved parties in this investigation. To date all subpoenaed financial information has not been received; however, upon an analysis of the received subpoenaed financial document and financial documents turned over by Ms. Moore there are numerous

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discrepancies between the factual information and information provided by Ms. Moore during several non-custodial interviews with Law Enforcement.

During several non-custodial interviews with Polk County Sheriff's Office detectives during the week of November 9, 2009, Ms. Moore provided the following information: She advised that she was introduced to Mr. Shakespeare in October of 2008. She advised that she initially met Mr. Shakespeare with the intention of writing a book about his life story. She advised that shortly after meeting Mr. Shakespeare, she noticed that he (Shakespeare) was being taken advantage of by numerous individuals and she offered her assistance to Mr. Shakespeare with his financial affairs. She advised that she did this out of "the goodness of her heart" not for any financial gain. She advised that Mr. Shakespeare had become disgruntled with everyone in his life

asking for money. She advised that Mr. Shakespeare then began to devise a plan to leave the Lakeland area and never be heard from again. She advised that, in January of 2009, Mr. Shakespeare sold

his residence located at 9340 Redhawk Bend Drive in Lakeland, Florida, to her for a price of $655,000.00. She advised at the same time, Mr. Shakespeare sold to her (Moore) all of the debt owed to him for a total of $185,000.00. Ms. Moore could not provide any documented proof of payment of the $840,000.00 to Mr. Shakespeare for the purchases, and advised that she had given him over $500,000.00 in cash as part of the payment. InJanuary 2009, Ms. Moore admitted to detectives that she had not in fact paid Mr. Shakespeare any monies for his home or the purchase of his assets. She advised that, in February of 2009, she set up Abraham Shakespeare LLC for the sole purpose of keeping track of the money collected on the debts she had purchased from Mr. Shakespeare. Numerous times throughout the interviews with Ms. Moore she advised that she did not understand why we were asking her about her financial dealing with Mr. Shakespeare. She advised

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that all financial dealings done between her and Mr. Shakespeare were completely legal and that she, unlike numerous others, was only trying to help Mr. Shakespeare with his finances. She advised that she was a millionaire prior to meeting Mr. Shakespeare and did not need any of his (Shakespeare's) money.

Financial and accounting records of American Medical Professionals were also subpoenaed and received. Accounting records for the years 2005 through 2009, inclusive, show that during that period of time, American Medical Professionals received profit distributions from their payroll service totaling approximately $720,000 over 5 calendar years. Those profit distributions were deposited primarily to the Bank of America American Medical Professionals account (for the period for which records have been received) and spent on a variety of activity including restaurants, travel, and jewelry.

• Investigators have prepared a timeline of real estate transactions and monetary transfers. These timelines are attached as Exhibits A and B.

By the month of April 2009, bank records and public records reveal that Dee Dee Moore was in virtually complete control of all Abraham Shakespeare's assets and accounts. Further, Shakespeare had not received payment for those assets as agreed.

Shakespeare had begun to ask questions about his money and express concern about his dealings with Dee Dee Moore.

Abraham Shakespeare was last seen alive in the Lakeland, Florida area by Courtney Daniels during the first week of April 2009. Ms. Daniels knew Abraham Shakespeare for several years and periodically lived with Shakespeare at 9340 Red Hawk Bend Dr. Lakeland, Fl 33810. This statement was provided to Detectives Lynn and Wallace on January 16, 2010. On 11/09/2009, the victim was reported to the Polk County Sheriff's Office as a missing adult by his cousin, Cedric Edom and was subsequently entered into the NCIC

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Early within the Polk County Investigation, Dee Dee Moore was identified as an associate of the victim, Abraham Shakespeare and was living at the last known address of the victim at the time of his disappearance. During initial interviews with Polk County Sheriff's Office detectives, Dee Dee Moore claimed that the victim was missing of his own free will in an attempt to elude payments regarding upcoming court proceedings. Ms. Moore advised during these initial interviews that she had been in contact with the victim several times since April, 2009 in person as well as by telephone.

During an interview with Detectives Wallace and C lark on November 25, 2009, Dee Dee Moore admitted that she sent text messages in the summer of 2009, to Mr. Shakespeare's friends and family in an attempt to convince them that Mr. Shakespeare was still alive.

During the course of the Polk County Sheriff's Office Investigation it was learned Ms. Moore had gained possession of all of the victim's known assets to include currency, vehicles and property beginning around January 2009. As a result, the mentioned property located at 5802 Highway 60 Plant City, Florida was purchased with approximately $350,000 dollars of the victims currency .

During the investigation, it was learned by Polk County Sheriff's Office Detectives that the mother of the victim had possibly received a telephone call from the victim on December 27, 2009. Polk County Sheriff Office Detectives then made contact with the victim's mother and learned that she had received a telephone call from a subject who had identified himself as Abraham Shakespeare. The victim's mother further advised that she had received the telephone call while she was eating dinner at a restaurant with Dee Dee Moore. The victim's mother advised that she was unsure if the subject who placed the telephone call was in fact the victim. Polk County Sheriff's Office Detectives were able to obtain the telephone number that the call had been placed from and were able to determine that the telephone was registered to Gregory Todd Smith.

On December 28, 2009, Polk County Sheriff's Office Detectives were attempting to locate Mr. Smith when they observed Mr. Smith meeting with Dee Dee Moore in Lakeland, Florida. After the meeting

between Mr. Smith and Ms. Moore was concluded, Detectives made contact with Mr. Smith and interviewed him. During the interview it was learned that Mr. Smith had been solicited by Ms. Moore to make several telephone calls. These telephone calls included one call to a Polk County Sheriff's Office Detective claiming to have seen the victim within the past couple of days in Miami, Florida, and also a

I ~F======t==e=l=e=p=h=o=n~e==c=a==l=l==t==o==t=h==e==v==i=c=t=i=m=='s=-_m_o_t_h __ e_r~p~u_r~p_o_r-=t=i=n~g~=t=o==b==e==Ab==r==a=h=a=m==========

16

Shakespeare himself. Mr. Smith advised that he had made these telephone calls for Ms. Moore in exchange for being paid several hundred dollars by Ms. Moore. Mr. Smith advised that Ms. Moore had already approached him about doing other acts involving the investigation of the missing victim. Mr. Smith agreed to co-operate fully with Law Enforcement at that time.

During the following weeks, Mr. Smith met with Ms. Moore on several occasions. During each of these meetings Mr. Srni th was equipped with a digital audio recorder to record the meetings and the meetings were observed by Law Enforcement personnel. During these meetings Ms. Moore would solicit Mr. Smith to do various acts that would make it appear that the victim was alive and was missing on his own free will. On January 6, 2010, Ms. Moore actually typed a letter under the auspices of being from the victim and wanted Mr. Smith to deliver the letter to the mailbox of the victim's mother. In this letter Ms. Moore writing as the victim told the victim's mother that he was fine and was staying out of the area because the police were going to arrest him. The letter also referred to the aforementioned telephone call that Mr. Smith had placed to the victim's mother on 12/27/2009, and questioned how she (victim's mother) could not recognize the voice of her own son.

After several weeks of having Mr. Smith do acts trying to make it appear as though the victim was alive and missing on his own free will, Ms. Moore approached Mr. Smith and asked him if he knew anyone that would be willing to tell Law Enforcement that they had killed the victim. It was determined that Mr. Smith would introduce an Undercover Detective to Ms. Moore under the illusion that the Undercover Detective was a subject already facing a lengthy prison term and would be willing to admit to killing the victim for monetary compensation.

On January 21, 2010, Officer Mike Smith of the Lake Wales Police Department working in an undercover capacity was introduced to Ms. Moore by Mr. G. Smith. During the meeting Ms. Moore agreed to pay Officer Smith $50,000.00 u.s. Currency if he would tell Law Enforcement that he had killed the victim. Officer Smith advised that he would do this ,but that he needed details of where the victim's body was in order for Law Enforcement to believe his confession. Ms. Moore advised that she would provide that information to Mr. G. Smith at a later time. After the meeting between Ms. Moore and Officer Smith was completed, Mr. G. Smith drove Ms. Moore back to her vehicle that was parked at a different location. During the ride Ms. Moore advised Mr. G. Smith that she would tell him the location of the victim's body and that she also had possession of the firearm that killed the victim. A plan was then devised between Ms. Moore and Mr. G. Smith, that Mr. G. Smith along with Officer Smith would dig up the body of the victim and move it to a different location so that Officer Smith could then advise Law Enforcement where the body was located. It was further

17

planned that Ms. Moore would give possession of the firearm used to kill the victim to Mr. G. Smith so it could be turned over to Law Enforcement to solidify the confession of Officer Smith.

On January 25, 2010, Ms. Moore contacted Mr. G. Smith and advised that she needed to meet with him. Mr. G. Smith then met with Ms. Moore in Lakeland, Florida. During the meeting Ms. Moore advised that she would be getting the firearm later in the day to turn over to him (G. Smith). It was also planned that she would take Mr. G. Smith to the location where the body of the victim was located.

Later in the day of January 25, 2010, Ms. Moore again met with Mr. G. Smith, this time at a location in Plant City, Florida. At this time Ms. Moore gave Mr. G. Smith a .38 Caliber Smith and Wesson Revolver (Serial Number DBU2414/642-2). During this meeting Ms. Moore advised that she would meet with Mr. G. Smith later in the day and take him to the location where the victim's body was buried.

Approximately two (2) hours later still on January 25, 2010, Ms. Moore again met with Mr. G. Smith in Plant City, Florida. Mr. G. Smith then got in to Ms. Moore's vehicle. Ms. Moore then drove Mr. G. Smith to 5802 Highway 60 in Plant City, Florida. Ms. Moore then showed Mr. G. Smith a 30' x 30' concrete slab (poured on 4/13/2009) located in a wooded area approximately 30 yards north of the residence on the property. Ms. Moore advised that the victim was buried beneath the concrete slab. Ms. Moore had previously parked a white Ford Truck with an attached utility trailer blocking view of the concrete slab from the roadway. Ms. Moore told Mr. G. Smith to look inside the trailer. Mr. G. Smith looked in the trailer and observed several gallons of fuel, gallons of bleach, gloves, and a metal tub/trough. Ms. Moore advised Mr. G. Smith that after digging up the victim's body he could place the body in the tub/trough and transport it in the trailer. Ms. Moore then provided Mr. G. Smith with keys to the Ford Truck. Ms. Moore further advised that the victim had been killed in her office and pointed to the residence located at 5732 Highway 60, which is located directly to the west of the residence where the victim's body is buried.

On 01/26/2010, affiant along with co-affiant and members of both Hillsborough and Polk County Sheriff's Offices served two separate search warrants upon the said property of this warrant and the residence located at 5732 Highway 60 Plant City, Florida. A subsequent interview was conducted by affiant and Polk County Detective David Wallace, with David Howard Stitzel at his attorneys office in Brandon, being Patrick Courtney and Glen Lansky. David Howard Stitzel arrived at the crimescenes with his attorney Glen Lansky. Stitzel then traveled to their (Courtney and Lansky) law office for an interview, due to his own law practice office being within a room contained within the two-story brown in color

18

residential structure at the physical address plant City, Florida) being then searched.

(5802 Highway 60

During the interview of David Howard Stitzel, he stated to affiant and Detective David Wallace that he last physically saw the victim, Abraham Shakespeare sometime between April or May 2009 at his prior office location, 607 S. Alexander St. Plant City, Florida. Dorice (Dee Dee) Moore, became a client of Mr. Stitzel in late 2008. Mr. Stitzel proceeded to advise the alleged phone call supposedly made in the presence of Dee Dee Moore wherein he earlier claimed to have last heard from Shakespeare on October 6, 2009, could have been the victim or could have not been the victim. Mr. Stitzel stated he moved to the property located at 5732 Highway 60 Plant City, Florida temporarily, on ar about May i s". 2009 to early June 2009. Upon completion of the renovation within the structure located at 5802 Highway 60 Plant City, Florida, Mr. Stitzel then moved in setting up office space for his practice. Sometime last week, being the third week of January, Mr. Stitzel along with his assistant/girlfriend Michelle Findley, observed Dee Dee Moore sitting at his computer, utilizing it within his office space in which he rents from her (Dee Dee Moore). Mr. Stitzel admits to preparing the document in which Judith Haggins signed as Power of Attorney for Abraham Shakespeare, although Ms. Moore and Ms. Haggins filed it at the Clerk of the Court on their own.

Mr. Stitzel had previously discussed with Polk Detectives D .

Wallace and D. Clark that he knew Abraham Shakespeare was the other person on the other end of the phone call because he knew his clients voice. Polk detectives later conducted a controlled phone call as previously mentioned. It was apparent based on the controlled phone, that Mr. Stitzel was aware Dee Dee Moore was in possession of his clients cellular telephone and purporting he

(Abraham Shakespeare) was alive and well, just missing on his own free will. Thus, transactions and later court appearances in Polk County on behalf of Abraham Shakespeare which were made by Mr. sti tzel are of a fraudulent nature and indicating his possible involvement and/or knowledge of the murder of Abraham Shakespeare. Certain files, transactions and legal documentation are believed to be in possession by Mr. Stitzel within his office at the mentioned location, and are believed to clarify his involvement with the disappearance and/or murder of Abraham Shakespeare.

On 01/27/2010, affiant along with Detective David Wallace of Polk County, conducted an interview with Judith Haggins (power of attorney for Abraham Shakespeare) at her attorneys office, being Larry Hardaway in Lakeland, Florida. Ms. Haggins stated Abraham Shakespeare asked her to be his power of attorney which was notarized and filed on 04/03/2009 with the Clerk of the Court in Polk County. Before Abraham Shakespeare was noted as missing, Ms. Haggins noted Dee Dee Moore would embellish how serious Abraham Shakespeare's child support proceedings were, and would encourage

~.~~~====~~--~====~~~~~

19

him to move money wi thin his various accounts in an attempt to protect it from the biological mother of his (Abraham Shakespeare) child. Ms. Haggins advised she would tell Abraham Shakespeare that his child support case was not as serious as Dee Dee Moore made it out to be. In 2009, at an unknown time frame, Ms. Haggins admi tted she was instructed by Dee Dee Moore to withdraw the remaining funds from some of Abraham Shakespeares bank accounts which totaled in her opinion, less than $2000. The money, in the form of cashiers checks, were then given to Dee Dee Moore.

On January 28, 2010, Detective Thomas of the Hillsborough County Sheriff's Office and Detective Wallace of the Polk County Sheriff's Office conducted an interview with Dee Dee Moore's exhusband, James Moore. Mr. Moore stated that Dee Dee Moore asked him to recommend the type of equipment to clear her land at 5802 Hwy. 60 Plant City, Florida. He suggested a tractor with attachments, however she purchased a Case Backhoe on April 3, 2009 at a Lakeland Auction. Dee Dee Moore paid James Moore approximately $100 to pick-up the backhoe and deliver the same to her property on highway 60, utilizing his family's flat bed trailer. Dee Dee Moore called James Moore during the first two weeks of April, 2009, and requested that he come to her property at 5802 Highway 60 and utilize the purchased Case backhoe to dig a hole for concrete and trash. James Moore stated that originally Dee Dee Moore asked the hole to be dug directly behind the rear door of 5732 Highway 60. However, James Moore suggested to not dig there due to the close proximity to the house, therefore Dee Dee Moore pointed out the location behind 5802 Highway 60 and directed him where to dig as well as how large of a hole. James Moore stated that he left after digging the hole. He was called by Dee Dee Moore 1 to 2 hours later to fill the hole in. James Moore stated it was getting dark and he did not see a body in the hole, but rather assumed it was chunks of concrete due to there being a lack of light and having dug previous holes on her property before. During interviews conducted with Dee Dee Moore on January 29 and 30, 2009, by Detectives Thomas and Wallace, she admitted having contacted James Moore to dig a hole for trash at a location behind the residence at 5802 Highway 60. She further admitted that the body of Abraham Shakespeare was buried in hole dug by James Moore.

However, she was adamant that James Moore did not know there was a body placed in the hole when he returned to fill it in.

On 01/28/2010, the remains of a human body were found at 5802 Highway 60 Plant City, Florida after extensive crimescene process by both Hillsborough and Polk County Sheriff's Offices. The remains were positively identified as Abraham Shakespeare. The body of Abraham Shakespeare was found at the precise location under the concrete slab that Dee Dee Moore personally showed to Gregory Smith.

Beginning on 01/29/2010, affiant and Detective David Wallace

20

of Polk County, interviewed Dee Dee Moore, who initiated contact herself. Ms. Moore has provided several accounts of how Abraham Shakespeare was murdered to date, to include an unknown drug dealer named Ronald, herself in self-defense, Mr. Shakespeare's cousin Cedric Edom and finally her 14 year old son R.J. On 01/30/2010, Ms. Moore re-initiated contact with affiant and Polk County Detectives yet again. During this particular interview, Ms. Moore alleged David Stitzel shot the victim Abraham Shakespeare and helped to arrange his burial on her property. In all of these versions, Dee Dee Moore consistently told investigators that two shots were fired at Abraham Shakespeare. During the course of an autopsy conducted by Hillsborough County Medical Examiners Office, upon the body of Abraham Shakespeare, two projectiles were recovered from the victims body. Based on several interviews with Ms. Moore to date, and her statements of preparing a letter to the victims mother stating he was alive after 04/06/2009 as well as the continued text messages and financial transactions via the Power of Attorney, it is affiant's and co-affiant's belief that items of evidentiary value noted in the evidence to wit are to be contained within an office in the north east corner of 5802 Highway 60. This office is also utilized by Dee Dee Moore and is next to the office utilized by Mr. Stitzel.

Abraham Shakespeare was functionally illiterate and unsophisticated in financial matters. The investigation of the relationship between Mr. Shakespeare and Dee Dee Moore supports the conclusion that in the months prior to Abraham Shakespeare's death,

Dee Dee Moore conducted a series of ostensibly legal financial transactions with Mr. Shakespeare, which were designed to, and did, transfer the vast majority of the remainder of his cash, real property and intangible assets to her control, or to the control of her associates or entities controlled be her. By her own admission, Dee Dee Moore never paid Abraham Shakespeare for the $1.2 million dollar home that he deeded to her, or for the intangible assets that he transferred to her. The true, one-sided nature of these financial transactions provide the motive for the murder of Abraham Shakespeare. Some of these ostensibly legal financial transactions were conducted with the legal assistance of Attorney David Howard sti tzel. Based on the investigation conducted to this point, investigators have reason to believe that a search of the residence at 5802 Highway 60 in Plant City, including the law office of David Howard Stitzel, will produce records pertaining to the financial relationships and financial transactions among Abraham Shakespeare, Dee Dee Moore, p~erican Medical Professionals LLC, which is Ms. Moore's business, her boyfriend, Shar Krasniqi, Shakespeare and Associates LLC, Abraham Shakespeare LLC, and David Howard Stitzel. Based on the foregoing investigation, it is further anticipated that a search of this two-story residence shall reveal legal files, legal documents, legal memorandums and legal communications which

• shall comprise documentary evidence of the financial transactions

- ~~~~====~======~----------

21

which led to the transfer of Mr. Shakespeare's wealth and his ultimate death.

On 02/02/2010 at approximately 1750 hour, execution of a search warrant was completed and the listed evidence, being an eMachine central processing unit with a serial number of GCJ7A20000438 was collected. Affiant and co-affiant believe evidence of the listed offense as well as documentation and evidence pertaining to Dee Dee Moore, Abraham Shakespeare, Abraham Shakespeare LLC, and Shakespeare and Associates LLC are contained upon this computer. The eMachine CPU noted as inventory #520362 item #18 will be transported to FDLE for mirror imaging and copies will be properly forwarded per the Execution of Search Warrant and Preservation Privileges.

Refer to attached exhibit A.

EXECUTION OF SEARCH WARRANT AND PRESERVATION OF PRIVILEGES

To assure the preservation of any privilege attached to any legal file, document, memorandum or communication, these items shall be sealed irmnediately upon seizure without law enforcement inspection or review, except to the limited extent necessary to prepare the statutorily required inventory to the search warrant return. Mr. David Howard Stitzel shall be allowed, if he chooses, to prepare his own inventory of any legal files, documents, memorandums or communications seized pursuant to this warrant, prior to their removal from the premises.

Following the seizure and sealing of any legal files, documents, memorandum or communications, Hillsborough County Sheriff's office shall deliver the sealed items to an independent commercial copying business for the reproduction and pagination of these items within three working days. At the completion of the copying and pagination the seized legal items shall be sealed and the originals of all seized legal documents, except those related to Abraham Shakespeare, Dee Dee Moore, Abraham Shakespeare LLC, Shakespeare and Associates LLC, and Shar Krasniqi shall be returned to Mr. David Howard Stitzel. The copies shall be sealed and returned, without law enforcement review, to the secure property/evidence section of the Hillsborough County Sheriff's Office.

All copies of legal files, documents memorandum and communications made pursuant to this warrant shall be submitted for in camera judicial inspection and review prior to unsealing for review to law enforcement investigation.

Electronic data containing legal files, documents, memorandums

• or communications shall be copied by the Florida Department of

- ~~~======----~======~~~

22

Law Enforcement and sealed without inspection or review prior to investigations.

Electronic data seized pursuant to this warrant shall be reviewed in camera in accordance with those procedures applicable to documentary evidence.

Based on the aforementioned information detailing the financial documentation as well as legal documentation prepared and filed, affiant and co-affiant believe evidence of the Murder will be located upon the property.

WHEREOF, affiant makes this affidavit and prays the issuance of a search warrant in due form of law for the search of the above described premises for the said property, heretofore described, and

for the seizure and safe keeping reof, subject to the order of

thi Honor le cO~S/~ the 1 n titu e ~~rs of the law.

Sworn to and s AD, 201.0.

County, Florida

23

SEARCH WARRANT

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

IN THE NAME OF THE STATE OF FLORIDA:

TO: THE SHERIFF OF HILLSBOROUGH COUNTY, FLORIDA, AND/OR ANY OF HIS LAWFUL DEPUTIES:

WHEREAS, complaint on oath and in writing, supported by affidavit has been made before me, the undersigned

HONORABLE, CIRCUIT COURT JUDGE, THIRTEENTH JUDICIAL CIRCUIT in and for the Hillsborough County, Florida, by Detective Greg Thomas, Hillsborough County Sheriff's Office and Detective Chris Lynn, Polk County Sheriff's Office.

The affiant and co-affiant have reason to believe and do believe certain computer equipment located in Hillsborough County, Florida, described as follows, to-wit:

SEE ATTACHED EXHIBIT "A" WHICH IS HEREBY INCORPORATED BY

REFERENCE AND MADE A PART HEREOF

and there is now being kept within said computer equipment certain evidence of criminal activity including but not limited to computer equipment, computer programs, computer storage devices, to include but not limited to CDs, removable drives, thumb drives, pen drives, removable secure storage devices, graphic files, and any other media that can store digital files and/or digital media. Phone records, records of Internet Service Providers, E-mails and other computer data, including but not limited to encryption, passwords telephone numbers, Emails, Instant messages, computer images, computer programs and system documentation; documents files or any other computer data relating to encryption, passwords, and/or access to or ownership of the computer and Internet Service Provider, documentation used in violation of the laws of the State of Florida to-wit: law prohibiting, F.S.S. 782.04 Murder

and there is now being kept on said premises certain

Physical Evidence: eMachine central processing unit with a serial number of GCJ7A20000438, used in violations of laws of the State of Florida, to-wit:

It will become necessary for reasons of practicality to remove

the hardware and conduct a search off-site. Your affiant and co-

In this case, the

uter hardware is a

24

container for evidence, a container for contraband, and also

itself an instrumentality of the crime under investigation.

That the facts tending to establish the grounds for this application and the probable cause of affiant believing that such facts exist are contained in an AFFIDAVIT FOR SEARCH WARRANT, sworn to before me on this date by Detective Greg Thomas and Detective Chris Lynn.

And it appears to the Court that the affiant is a reputable deputies of Hillsborough County and Polk County, State of Florida, and that the facts set forth in said affidavit show and constitute probable cause for the issuance of this warrant and the Court being satisfied of the existence of said grounds set forth in said application, or that there is probable cause to believe in their existence.

NOW THEREFORE, you are commanded with such proper and necessary assistance as may be necessary, in the day-time or in the nighttime, or on Sunday, as the exigencies of the occasion may demand or require, to enter and search the aforesaid computer equipment, described but not limited to hard drives, zip drives, thumb drives, pen drives, CDs, for the property described in this warrant: and if the same or any part thereof be found, you are hereby authorized to seize and secure same, giving proper receipt therefore and delivering a duplicate copy on said computer equipment to the said WHITE MALE KNOWN AS DAVID HOWARD STITZEL AND ANY, JOHN OR JANE DOE WHOSE NAMES ARE UNKNOWN TO YOUR AFFIANT or any other person or persons, and by making a return of your doings under this warrant within ten (10) days of the date hereof, and you are further directed to bring said property so found before any County and/or Circuit Judge having jurisdiction of this offense to be disposed of according to law.

Further, you are commanded to search the property seized and the contents of same using such technology as may be necessary, performing such search at such locations and with such specialized personnel as may be appropriate, in order to obtain any relevant evidence of the felony crimes noted herein.

Qt

.~

of ~A{2010.

day

illsborough County, Florida

~.F~~====~---=====~~~~====

25

Exhibit A

A central processing unit with a name brand of eMacnine and a serial number of GCJ7A20000438, located at 2316 Falkenburg Rd. Tampa, Fl 33619 within Hillsborough County. This item is noted as item #18, inventory # 520362 under case # 10-42631 .

~.~~~======~----~======~~

26

INVENTORY AND RECEIPT OF PROPERTY SEIZED UNDER THE WITHIN SEARCH WARRANT

EXHIBIT

NT.

!

TYPEOFlTEM

i 15dayOf~

.A.D., 20/1J.

RETURN

LOCATION FOUND

FOUND BY

STATE OF FLORIDA

COUNTY OF HIllSBOROUGH:

Received-the within search warrant on the '/_~daY of "-n'"JUV'U&"'fJ A.D.,20lt! and executed the

same in Hillsborough County, FLorida, on th~-day of A.D. 20!.!J by searching the

premises described herein and by taking into my custody possessio the following described property, to-wit:

SEE ABOVE USTED INVENTORY

And ljurther executed the said warrant by arre~tinb..7t-;--;"'; .. ::-;;-i-,.h-+~-,It-:_----::;ot--::;: __'

and by delivering a duplicate co. 'PY of this warrant t ~7 tiZ .. ~

and by making and delivering to the said,:- __ ... {..:;=..;;-"iJL:==-_""'-~MJ.. __(J~.~,",,~:;='I-- __'

a true inventory of the above described property.

Officer

~~ .

I, rftd.~~/ ~ :/6.S the officer by whom the foregoing warrant was executed, do swear the above inventory

co "ns a £e and detail d account of all property take e on sa' ant.

My commission expireshwM!h'{ mmI,20/().

3050 Rev. 7/05

I Notary Public, State of Florida

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA IN AND FOR HILLSBOROUGH COUNTY CRIMINAL JUSTICE DIVISION

STATE OF FLORIDA

H.C.S.O CASE NO.: 2010-42631

VS

JOHN DOE OR JANE DOE

PETITION TO SEAL SEARCH WARRANT AND RELATED DOCUMENTS

COMES NOW THE STATE OF FLORIDA by and through the undersigned Assistant

State Attorney pursuant to Florida Rule of Judicial Administration 2.420 and

move this Honorable Court to enter an order sealing the search warrants and

related documents described below from public inspection until the release of

the discovery to the defense (upon request) or until further order of this

Court, and would show in support as follows:

1)

Abraham Shakespeare, D.D.B. 4/23/66, was last confirmed to be

alive on, or about, April 6, 2009. Information obtained during

the investigations conducted by members of the Polk and

Hillsborough County Sheriff's Offices support the conclusion that

Mr. Shakespeare's disappearance was the result of foul play.

2)

The body of Abraham Shakespeare was recovered from its burial

3 )

site under a concrete slab located behind tt~. .. story residen .... ce.

located at 5802 State Road 60 in Plant City. r ~J __

On February ~~2010, the Honorable Judge l ~·~!?tt'"I2a.-

Issued search warrants, which authorized the search of property

and structures located at 5802 State Road 60 in Plant City and

5732 State Road 60 in Plant City. During the execution of these

search warrants computer hardware was found described as "a

central

cessing unit with a name brand of eMachine and a

serial number of GCJ7A20000438, located at 2316 Falkenburg Rd.,

Page 1 of 3

4)

Tampa, FI 33619 within Hillsborough County, Item is noted as item #18, inventory #520362 under case #10-42631/1.

The affidavit in support of the search warrant set forth facts and interviews learned and obtained during the course of the ongoing investigation into the disappearance of Abraham Shakespeare.

5) The search warrants and related documents contain sensitive and/or

confidential information that is part of an ongoing investigation. The continued confidentiality until release of the discovery to the defense is required to:

a. Prevent a serious and imminent threat to the fair, impartial and orderly administration of justice, or

b. Protect a compelling governmental interest; or

c. Avoid substantial injury to an innocent third party .

There are no less restrictive measures available to protect the interests of law enforcement, the ongoing investigation or the safety of the third party.

7) The motion and order to seal this search warrant and related

6)

documents will not be sealed and will be filed with the Clerk's office.

8) The need for confidentiality will only continue until the discovery is released.

9) The warrant, affidavit and attached exhibits have been filed with the Clerk of the Circuit Court.

Wherefore, the State of Florida moves this Honorable court to Seal the Search Warrant and Related Documents.

~.p===~--~====~~~~=======

Page 2 of 3

I HEREBY CERTIFY that a true and correct copy of the foregoing Motion and Order will be furnished to the Clerk of the 13th Judicial Court, this __E day

of February, 2010.

Respectfully submitted,

MARK A. OBER

~EY

ASSISTANT STATE ATTORNEY FLORIDA BAR# 559415

JP/als

Page 3 of 3

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICI~~ CIRCUIT OF THE STATE OF FLORIDA IN AND FOR HILLSBOROUGH COUNTY CRIMINAL JUSTICE DIVISION

STATE OF FLORIDA

H.C.S.O. CASE NO.: 20~O-42631

VS

JOHN DOE OR JANE DOE

ORDER

THIS CAUSE having come on to be heard and the Court being fully

advised in the premises, it is hereby

ORDERED AND ADJUDGED that the Motion to Seal Search Warrant,

attached exhibits and related documents pertaining to the computer hardware

described as "a central processing unit with a name brand of eMachine and a

serial number of GCJ7A20000438, located at 2316 Falkenburg Rd., Tampa, Fl

33619 within Hillsborough County, Item is noted as item #18, inventory

#520362 under case #10-42631" is granted and that the Clerk of the 13th

Judicial Circuit is ordered to prevent the release of these documents to the

public until the release of the discovery to the defense (upon request) or

until further order of this Court.

~~DONE AND ORDERED in Court at Tampa, Hillsborough County, Florida,

this day of February, 2010.

THIRTEENTH JUDICIAL CIRCUIT HILLSBOROUGH COUNTY, FLORIDA

lals

AFFIDAVIT

FOR SEARCH WARRANT

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

STATE OF FLORIDA :.2 COUNTY OF HILLSBOROUGH r

BEFORE ME, HONORABLE l . b~ I CIRCUIT COURT

JUDGE, THIRTEENTH JUDICIAL CIRCUIT , in nd for Hillsborough

County, Florida, personally came affiant Detective Greg Thomas, Hillsborough County Sheriff's Office and co-affiant Detective Christopher Lynn, Polk County Sheriff's Office being first duly sworn, deposes and says: That affiant and co-affiant are reputable Deputies of said Hillsborough County and Polk County, State of Florida, and that they have reason to believe and do believe that certain certain computer equipment located in Hillsborough County, Florida, described as follows, to-wit:

SEE ATTACHED EXHIBIT "A" WHICH IS HEREBY INCORPORATED BY

REFERENCE AND MADE A PART HEREOF

and there is now being kept within said computer equipment certain evidence of criminal activity including but not limited to computer equipment, computer programs, computer storage devices, to include but not limited to CDs, removable drives, thumb drives, pen drives, removable secure storage devices, graphic files, and any other media that can store digital files and/or digital media. Phone records, records of Internet Service Providers, E-mails and other computer data, including but not limited to encryption, passwords telephone numbers, Emails, Instant messages, computer images, computer programs and system documentation; documents files or any other computer data relating to encryption, passwords, and/or access to or ownership of the computer and Internet Service Provider, documentation used in violation of the laws of the State of Florida to-wit: law prohibiting, F.S.S. 782.04 Murder

being the premises occupied by or under the control of

WHITE MALE, DAVID HOWARD STITZEL D.O.B. 03/04/1964 AND ANY OTHER UNKOWN NAMES

Physical Evidence: HP central processing unit serial number 2UA9040QWI, used in violations of laws of the State of Florida, towit: 782.04 Murder

It will become necessary for reasons of practicality to remove

the hardware and conduct a search off-site. Your affiant and co-

affiant believe thatr in this caser the computer hardware is a

container for evidencer a container for contrabandr and also

itself an instrumentality of the crime under investigation.

That the facts tending to establish the grounds for this application and the probable cause of affiant believing that such facts exist are as follows:

The affiant Greg Thomasr a Detective of the Hillsborough County Sheriff's Office being sworn states:

1. Your affiant is an Investigative Law Enforcement Officer as defined in Florida State Statute 934.02 r and is making this application pursuant to my official duties.

2. Your affiant is authorized to do so by the Honorable Mark Oberr State Attorney for the Thirteenth Judicial Circuitr Hillsborough CountYr Floridar pursuant to the authority conferred upon him by F.S.S. 934.07.

3. That the affiant is a member of the Hillsborough County Sheriff's Office and has been so employed since October 2000. Your affiant has been assigned to the Criminal Investigations Division as a Detective since Auqu s t., 2003. Your affiant has been a participant in the execution of numerous Search Warrants.

The co-affiant Christopher Lyrin , a Detective of the Polk County Sheriffrs Office also being sworn. The co-affiant has been employed with the Polk County Sheriffrs Office since July of 2002.

Your co-affiant has been assigned to the CID as a Detective for approximately 3 1/2 years. Your co-affiant has been a participant in the execution of numerous Search Warrants.

Abraham Shakespeare won $31 million in the Florida lottery.

Shakespeare elected the lump sum payout and collected approximately $12.7 million after taxes. Shakespeare was sued by a co-worker who made claim to the winning ticket. Ultimately the court ruled in the favor of Shakespeare in 2007.

Between winning the lottery in 2006 and meeting Dee Dee Moore in 2008r Mr. Shakespeare spentr gave away or loaned the majority of

his winnings and was left with approximately $1.5 million in cash and assets totaling approximately $3 million. Shakespeare utilized several financial institutions, seemingly one after another on the whim of various advisors: from Wachovia, along with various Annuity holdings, to Community Bank and eventually to Bank of America. Mr. Shakespeare did not invest heavily and was reported to be unimpressed with annuities to the point of pulling all of his money out and using the money to seed accounts accessed by Dee Dee Moore.

In December of 2008, Mr. Shakespeare liquidated an annuities account worth approximately $250K. In January 2009, this money was transferred to the business account of American Medical Professionals, a business owned by Dee Dee Moore since 2004. In her interviews, Ms. Moore stated this money was provided to her for the purposes of paying taxes on behalf of Shakespeare. This money was tracked to several recipients including Ms. Moore's boyfriend, Shar Krasniqi, and Real Time Services, American Medical Professionals' payroll and accounting service. Additionally, a review of bank statements of American Medical Professionals and accounts related to Dee Dee Moore has shown that Moore utilized the American Medical Professionals checking account as her primary account including personal charges. Any personal accounts of Dee Dee Moore that have been located have minimal activity. Investigation has not revealed any records of these funds having been used to pay any tax debt of Abraham Shakespeare.

Land Transfers

On January 9th, 2009, Mr. Shakespeare signed a Quitclaim Deed to American Medical Professionals LLC on his primary residence, 9340 Redhawk Bend Drive. The deed was recorded on 01-13-09. Abraham Shakespeare paid $1.07 Million in 2007 for the home, and Dee Dee Moore, in a statement given to Polk County Sheriff's detectives

3

on or about November 9, 2009, stated she paid him over $500,000 in cash. In a subsequent statement given to Polk Sheriff's Detectives on January 25, 2010, Ms. Moore stated that she had not paid Abraham Shakespeare because Shakespeare had a drug problem and she felt that he would use it to buy drugs. In a statement given to detectives on January 29, 2010, Ms. Moore stated that she had not paid Abraham Shakespeare because he did not want to pay the gift tax owed on the amount. A review of Dorice (Dee Dee) Moore's bank records has not revealed corresponding withdrawals, checks, or transfers indicating payment for the horne, to date.

After receiving his lottery winnings, Abraham Shakespeare made mUltiple loans to individuals to buy homes and recorded mortgages documenting the loans. On January 11, 2009, Mr. Shakespeare signed Quitclaim Deeds to American Medical Professionals, LLC for

properties located at 1418 West Lake Parker Drive, Lakeland, Florida and 409 Pearl Street, Lake Hamilton, Florida. Each deed was recorded on 02-11-09.

On January 15, 2009, Mr. Shakespeare signed an UAsset Purchase Agreement" which sold all of his un-enumerated Uassets" to American Medical Professionals LLC for the price of $185,000. The value of outstanding loans purchase in the UAssets Purchase Agreement" plus the value of real estate separately purchased total over $3.5 million worth of assets for less than 5 cents on the dollar. Although a copy of the Asset Purchase agreement has been obtained by investigators, the uAddendum" to the agreement has not been located. The uun-enumerated assets" sold by Mr. Shakespeare to American Medical Professionals were purportedly

to be listed in the addendum. (A copy of the UAssets Purchase Agreement" is attached here to as Exhibit "e")

On both the 15th, and 16th of January 2009, Mr. Shakespeare signed paperwork documenting the fact that the following

mortgages were hereby ASSUMED by American Medical Professionals

• LLC.

Property Loan Amount Mortgage Assignment Date
Address Dated Dated Assignment
Recorded
648 West 4th $14,752.00 March 13, January May 6,
Street, 2007 15, 2009 2009
Lakeland
727 East $63,000.00 February January May 6,
McDonald 23, 2007 15, 2009 2009
Street,
plant City
1103 Neville $69,000.00 May 14, January April I,
Avenue, 2007 16, 2009 2009
Lakeland
3075 Sire $185,000.00 April 4, January April I,
Trail, 2007 16, 2009 2009
Lakeland
Rodman $52,000.00 December January April 1,
Development, 17, 2007 16, 2009 2009
Inc. All of these transactions have been recorded by either the Clerk of the Courts or the Polk County Property Appraiser's Office. Also, all of these transactions were prepared by Howard Stitzel. This fact was noted via the header on the top left of the front pages of all of these documents. Further, Howard Stitzel, maintains a law office at 5802 State Road 60 East, Plant City. The Law offices of David Howard Stitzel shall be among the locations with that address that shall be searched pursuant to this warrant. The property is titled in the name of Shar Krasniqi.

-.~====================5 ======================

ABRAHAM SHAKESPEARE, LLC

On February 5, 2009, a faxed request form for surrender of the Prudential Annuities Account in the name of Abraham Shakespeare { purportedly with Shakespeare's signature, was faxed from Staples in Lakeland{ Florida. The surrender form requested the full amount contained in the account { $1.095 million, to be paid in the form of a check made payable to Abraham Shakespeare and sent via mail to his address.

On Feb. 9{ 2009{ Ms. Moore registered the business Abraham Shakespeare LLC, with the Department of State, Division of Corporations, where she is listed as the registered agent and director.

On Feb. 10, 2009, Ms. Moore opened an account at Bank of America in the name of Abraham Shakespeare LLC with $100 cash. Ms. Moore was the only signor on the account at that time .

On February 11, 2009, Dee Dee Moore provided the bank Articles of Incorporation along with papers purporting to be ~meeting minutes" of the "boardll of Abraham Shakespeare LLC. Contained among the meeting minutes were minutes of a ~meetingll which was purported to be ~attendedll by Dee Dee Moore{ Judith Haggins and Abraham Shakespeare. The documented discussion was about adding Abraham Shakespeare's name as an authorized signer. Further { the $1.095 million check from Abraham Shakespeare's Prudential Annuities account was then deposited into the Bank of America account in the name of Abraham Shakespeare { LLC. on February 11th 2009. Judith Haggins is a longtime friend of Abraham Shakespeare.

She met Dee Dee Hoore through Abraham Shakespeare and soon became a business associate of Dee Dee Moore. Judith Haggins acted as Abraham Shakespeare{s paid driver and personal assistant.

• No activity occured in the Bank of America account until Feb. 17th, when the bank was again provided with "meeting minutes" of Abraham Shakespeare LLC. by Dee Dee Moore. Ms. Moore was the only person listed in attendance. These "minutes" describe the discovery of "criminal activity" on the part of Shakespeare, which may result In criminal charges. Therefore, Shakespeare was to be removed as an authorized signer of the account. Bank of America therefore removed Shakespeare as an authorized signatory.

From February 10, 2009 to February 17, 2009 the account shows no activity. On February 18, 2009, a cashiers check for $250,000 drawn on the Abraham Shakespeare LLC. Account was made payable to ASTAT and was deposited to Navy Federal Credit Union account. ASTAT and Supply, LLC was a business registered with the Department of State Division of Corporations and was reinstated as an active corporation on October 15, 2008. Shar Krasniqi was listed as CEO. Additionally, the account holder of the Navy Federal Credit union account is Shar Krasniqi. Further, on February 18, 2009, a cashiers check for the sum of $250,000 was drawn on the Abraham Shakespeare LLC. Account made payable to the Internal Revenue Service. This check was endorsed by D. Moore. Notated on the check, in the endorsement section, were the hand written words "not needed for intended purpose". This $250,000 check is then deposited into the business account of American Medical Professionals LLC. By the use of the endorsement "not needed for intended purpose" Dee Dee Moore was able to divert the sum of $250,000 from its intended purpose to her own control and benefit. On February 19, 2009 and February 23, 2009, cashiers check for $200,000 and $250,000 respectively, were drawn on the account of Abraham Shakespeare LLC and were made payable to American Medical Professionals.

During the month of February 2009, Judy Haggins and D. Howard

~.======~~~~7~~~=========

Stitzel received approximately $20,000 each from the account of Abraham Shakespeare LLC. An electronic debit check made payable to the Internal Revenue Service in the amount of $30,000 was issued from the same account. The balance of the Abraham Shakespeare LLC account as of Feb 28, 2009 was $44,296.

Transactions from the Abraham Shakespeare LLC, Bank of America account show funds were transferred to the account of American Medical Professionals (Dee Dee Moore), ASTAT and Supply (Shar Krasniqi) just two months before the purchase of a residence located at 5802 Hwy. 60 East for approximately $253,000 in April, titled to Shar Krasniqi. Richard Land, the former owner of the property, stated to detectives that Dee Dee Moore paid him with a check from the account of American Medical Professionals.

CONTROLLED PHONE CALL CONCERNING HOWARD STITZEL

On 11/12/2009, Detective David Clark and Detective David Wallace responded to the law office of D. Howard Stitzel located at 5802 Highway 60 in Plant City, Florida. Detectives Clark and Wallace then interviewed Mr. Stitzel in reference to the investigation. During the interview, Mr. Stitzel advised that he could not comment about the details of the conversation, but would confirm that he spoke to Mr. Shakespeare on the cellular telephone of Ms. Moore on October 6, 2009. When asked how he knew that he was speaking to Mr. Shakespeare, D. Howard Stitzel advised that Mr. Shakespeare was his client and that he was familiar with the voice of Mr. Shakespeare and that was who he was speaking to on the telephone.

During a December 3rd, 2009 interview with Polk County Sheriff's Detectives David Clark and David Wallace Dee Dee Moore stated that Shakespeare's telephone was part of the plan that Mr. Shakespeare had made to leave town. Ms. Moore advised that Mr. Shakespeare advised her to text message people after he left

1I~--========~~~8~~~==============

using his phone that he left with Dee Dee Moore so the police could not track him. Ms. Moore was then asked to confirm that she had Mr. Shakespeare's cellular telephone in her possession at the time that she had originally advised that both she and D. Howard Stitzel had spoken to Mr. Stitzel on 10/06/2009. Ms. Moore confirmed that she was In possession of Mr. Shakespeare's telephone at that time and that neither she (Moore) or D. Howard Stitzel had spoken to Mr. Shakespeare on that date (10/06/2009). Ms. Moore was then asked why D. Howard Stitzel had told Detectives Clark and Wallace that he had spoken to Mr. Shakespeare. Ms. Moore advised that she asked Mr. Stitzel to say that to Law Enforcement and he (Stitzel) had agreed to lie to Law Enforcement to assist Ms. Moore. Ms. Moore then placed a controlled (taped) telephone call to Mr. Stitzel's cellular "telephone. During the call, Ms. Moore advised Mr. Stitzel that Law Enforcement was asking her questions about the telephone call in which both she and Mr. Stitzel had allegedly spoke to Mr. Shakespeare on 10/06/2009. Ms. Moore conveyed to Mr. Stitzel that she was concerned that Law Enforcement would find out that they had not spoken to Mr. Shakespeare on that date and wanted to confirm that he (Stitzel) had told Law Enforcement that he (Stitzel) had spoke to Mr. Shakespeare on that date. Mr. Stitzel advised that he had told Law Enforcement that he had spoken to Mr. Shakespeare on that date. Ms. Moore then asked Mr. Stitzel what would happen if she told Law Enforcement that she had possession of Mr. Shakespeare's cellular telephone. Mr. Stitzel then began telling Ms. Moore that she needed to stop talking to Law Enforcement. Although Mr. Stitzel made no direct admissions that he had in fact lied to Law Enforcement, it was apparent that Mr. Stitzel was aware that Ms. Moore had Mr. Shakespeare's cellular telephone and had not spoken to Mr. Shakespeare on 10/06/2009, as he had told Law Enforcement on 11/12/2009.

HOWARD STITZEL

During an interview on December 3, 2009 with Dee Dee Moore by Polk County Sheriff Detectives Wallace and Clark, when questioned about the above described money and property transfers she explained, she and Abraham Shakespeare, with the intent to avoid paying any child support, intentionally transferred all money and assets out of his name into the name of American Medical Associates. As stated above, Howard Stitzel's name appeared on the deed transfers. Additionally, Howard Stitzel was the Attorney of record representing Shakespeare in the child support enforcement action. This action commenced January 14, 2009. Howard Stitzel filed his response as Abraham Shakespeare's attorney on March 6, 2009. Abraham disappeared in April 2009. As mentioned in the above section with the controlled phone call, Howard Stitzel made an implicit admission confirming his misrepresentation to police during the Polk County Sheriff's missing person's investigation. According to records on file with the Polk County Clerk of Courts, Howard Stitzel appeared in person in a Polk County Court in August 11, 2009 in the above mentioned Child Support Enforcement Action, and told the Judge that Abraham Shakespeare was out of the country receiving treatment as an explanation for his client's nonpresence. Howard Stitzel was also interviewed for a Ledger newspaper article which appeared

• on December 1,2009. Stitzel was quoted as saying "that the last time he talked with his client was in October when they discussed child support issues ... Stitzel said Shakespeare did not

sound distressed during his phone conversation in October."

David Howard Stitzel represented Abraham Shakespeare in child support proceedings and drew up numerous document related to a variety of transactions described herein, including an assets purchase agreement with addendum, property deeds, Quitclaim deeds, contracts, mortgages and power(s) ofattorney. David Howard Stitzel received three separate checks in February of 2009 totaling $17,500 from Abraham Shakespeare LLC. All of these checks bore the signature of "Dee Dee Moore". During an interview with Detective Chris Lynn (Polk County Sheriff's Office) in November 2009, Dee Dee Moore stated that these checks were compensation for legal services rendered by David Howard Stitzel.

OVERVIEW OF HISTORICAL PURCHASES OF ASSETS

On 03/06/2007 Shakespeare purchased a BMW for approximately $100,000

~.. I··· ====~~~~~~~========= 10

01/29/09 Dee Dee Moore bought a 2009 Lincoln MKS and titled it in the name of Abraham Shakespeare LLC. The same day she traded the Lincoln to Abraham for his BMW. She then titled BMW in the name of Shar Krasniqi

04/14/09 Dee Dee Moore traded the 2009 Lincoln MKS for a 2009 Chevy Silverado. $31,000.00 was allowed for the Lincoln and Dee Dee paid $13,302.60 in cash for the remaining balance on the vehicle

11/03/09 Dee Dee Moore took the BMW to Stingray Chevrolet and sold it to them for $37,000.00.

Shakespeare purchased a Ford 500 on 7/9/07

In Early April 2009, Dee Dee Moore called Sentorria Butler and told her Abraham left his Ford 500 for Butler and it was at Moore's house. Sentorria Butler is the mother of Abraham Shakespeare's infant child, Jeremiah. In 2009, she initiated child support proceedings on behalf of her son against Abraham Shakespeare. After the aforementioned telephone call, Dee Dee Moore picked Sentorrria Butler up and took her to pick the car up. Sometime around 5/10/09 Judy Haggins took the vehicle back from Sentorria Butler USlng the power of attorney as authority to take the car back.

• On 6/18/09, Dee Dee Moore took the 07 Ford 500 registered to

Shakespeare and Associates to Stingray Chevrolet and sold it outright to them for $9,000.00. She presented the dealership with paperwork from the Florida Division of Corporations which showed her as the Manager of Abraham Shakespeare LLC, a completely different corporation. She signed the title as "CEO" of Shakespeare and Associates, which had been inactive since September 2008. Shakespeare and Associates LLC. was incorporated in 2007 by Abraham Shakespeare and an attorney,

-=.r~""""""'_====:::=::::::::::::::========:=l::=l ===================

Cedric Lewis, as a business entity to store Shakespeare's assets. Dee Dee Moore was never listed as an officer or director of Shakespeare & Associates LLC.

On or about February 21, 2009, Dee Moore bought a 2008 Chevrolet Corvette from Stingray Chevrolet for her boyfriend, Shar Krasniqi. She paid $70,390.86 for the vehicle with a cashier's check from American Medical Professionals LLC.

On March 2, 2009, Dee Dee Moore purchased a 2009 Hummer for approximately $90,000. On December 5, 2009, Dee Dee Moore took this vehicle to Stingray Chevrolet and told them she needed cash quickly and attempted to sell it to them for $49,000.00. They told her they were not interested due to the economy. William Smith, a friend of the owner of Stingray Chevrolet was present and offered to buy the Hummer himself. Dee Dee Moore agreed to sell it to him and requested that Mr. Smith call his bank so that she could cash the checks immediately. She also requested 3 separate checks from Mr Smith, one for $5,000.00 in the name of Dee Dee Moore, one for $4,000.00 in the name of Linda Donegan

(Dee Dee Moore's mother) and one for $40,000.00 in the name of Dee Dee Moore.

Power of Attorney

Notary Ambrose E. Austin was interviewed by Detective David Cavanaugh of Polk County Sheriff's Office, during the week of November 9, 2009. Mr. Austin told Detective Cavanaugh that on April 3, 2009, Shakespeare signed a Power of Attorney designating Judy Haggins as his POA. Notary Ambrose E. Austin stated Haggins was present during signing and advised Shakespeare was present. On November 13, 2009, Ms. Haggins told Detectives Wallace and Clark that this was the last time that she saw Shakespeare alive.

Haggins has, in fact, used the power of attorney to close bank accounts belonging to Abraham Shakespeare and sign court

pleadings on Abraham's behalf. Proceeds of closed accounts have been deposited into accounts controlled Dee Dee Moore.

On or about December 11, 2009, in a recorded conversation with Gregory T. Smith acting in the capacity as an informant with the Polk County Sheriff's Office, Judy Haggins stated that, in or around March 2009, Abraham Shakespeare approached her about concerns regarding Dee Dee Moore and his money. Haggins talked to Dee Dee Moore around the same time and Moore told Haggins not to let Shakespeare go to the bank because some of the money was not there. In all subsequent law enforcement interviews with Ms. Haggins, she has not admitted that this conversation had occurred. Gregory T. Smith became an informant with the Polk County Sheriff's Office as a result of a series of events, which are described later in this affidavit. Mr. Smith was a friend of Abraham Shakespeare from Lakeland, Fl. On February 23, 2007 Shakespeare and Associates LLC. obtained the mortgage to the house of Gregory Smith's mother. On January 15, 2009 Shakespeare and Associates LLC. assigned this mortgage to American Medical Professionals.

Additional Information

On or about November 9, 2009, Detective Chris Lynn began subpoenaing financial records of Mr. Shakespeare as well as those of Ms. Moore to include numerous Limited Liability Corporations (LLC) associated with Ms. Moore and her boyfriend Shar Anthony

Krasniqi. It should be noted that numerous financial documents were also voluntarily turned over to the Polk County Sheriff's Office by Ms. Moore during this investigation and numerous public record documents have been obtained related to the involved parties in this investigation. To date all subpoenaed financial information has not been received; however, upon an analysis of the received subpoenaed financial document and financial documents turned over by Ms. Moore there are numerous

~.F~~~~~-=====~~~~~~~ 13

discrepancies between the factual information and information provided by Ms. Moore during several non-custodial interviews with Law Enforcement.

During several non-custodial interviews with Polk County Sheriff's Office detectives during the week of November 9, 2009, Ms. Moore provided the following information: She advised that she was introduced to Mr. Shakespeare in October of 2008. She advised that she initially met Mr. Shakespeare with the intention of writing a book about his life story. She advised that shortly after meeting Mr. Shakespeare, she noticed that he (Shakespeare) was being taken advantage of by numerous individuals and she offered her assistance to Mr. Shakespeare with his financial affairs. She advised that she did this out of "the goodness of her heart" not for any financial gain. She advised that Mr. Shakespeare had become disgruntled with everyone in his life asking for money. She advised that Mr. Shakespeare then began to devise a plan to leave the Lakeland area and never be heard from again. She advised that, in January of 2009, Mr. Shakespeare sold his residence located at 9340 Redhawk Bend Drive in Lakeland, Florida, to her for a price of $655,000.00. She advised at the same time, Mr. Shakespeare sold to her (Moore) all of the debt owed to him for a total of $185,000.00. Ms. Moore could not provide any documented proof of payment of the $840,000.00 to Mr. Shakespeare for the purchases, and advised that she had given him over $500,000.00 in cash as part of the payment. In January 2009, Ms. Moore admitted to detectives that she had not in fact paid Mr. Shakespeare any monies for his home or the purchase of his assets. She advised that, in February of 2009, she set up Abraham Shakespeare LLC for the sole purpose of keeping track of the money collected on the debts she had purchased from Mr. Shakespeare. Numerous times throughout the interviews with Ms. Moore she advised that she did not understand why we were asking her about her financial dealing with Mr. Shakespeare. She advised

that all financial dealings done between her and Mr. Shakespeare were completely legal and that she, unlike numerous others, was only trying to help Mr. Shakespeare with his finances. She advised that she was a millionaire prior to meeting Mr. Shakespeare and did not need any of his (Shakespeare's) money.

Financial and accounting records of American Medical Professionals were also subpoenaed and received. Accounting records for the years 2005 through 2009, inclusive, show that during that period of time, American Medical Professionals received profit distributions from their payroll service totaling approximately $720,000 over 5 calendar years. Those profit distributions were deposited primarily to the Bank of America American Medical Professionals account (for the period for which records have been received) and spent on a variety of activity including restaurants, travel, and jewelry.

Investigators have prepared a timeline of real estate transactions and monetary transfers. These timelines are attached as Exhibits A and B.

By the month of April 2009, bank records and public records reveal that Dee Dee Moore was in virtually complete control of all Abraham Shakespeare's assets and accounts. Further, Shakespeare had not received payment for those assets as agreed.

Shakespeare had begun to ask questions about his money and express concern about his dealings with Dee Dee Moore.

Abraham Shakespeare was last seen alive in the Lakeland, Florida area by Courtney Daniels during the first week of April 2009. Ms. Daniels knew Abraham Shakespeare for several years and periodically lived with Shakespeare at 9340 Red Hawk Bend Dr. Lakeland, Fl 33810. This statement was provided to Detectives Lynn and Wallace on January 16, 2010. On 11/09/2009, the victim was reported to the Polk County Sheriff's Office as a missing adult by his cousin, Cedric Edom and was subsequently entered into the NCIC database under Polk County case number 09-112920.

~.r=~~~-=====~~~~~~~=== 15

Early within the Polk County Investigation, Dee Dee Moore was identified as an associate of the victim, Abraham Shakespeare and was living at the last known address of the victim at the time of his disappearance. During initial interviews with Polk County Sheriff's Office detectives, Dee Dee Moore claimed that the victim was missing of his own free will in an attempt to elude payments regarding upcoming court proceedings. Ms. Moore advised during these initial interviews that she had been in contact with the victim several times since April, 2009 in person as well as by telephone.

During an interview with Detectives Wallace and Clark on November 25, 2009, Dee Dee Moore admitted that she sent text messages in the summer of 2009, to Mr. Shakespeare's friends and family in an attempt to convince them that Mr. Shakespeare was still alive.

During the course of the Polk County Sheriff's Office Investigation it was learned Ms. Moore had gained possession of all of the victim's known assets to include currency, vehicles and property beginning around January 2009. As a result, the mentioned property located at 5802 Highway 60 Plant City, Florida was purchased with approximately $350, 000 dollars of the victims currency .

During the investigation, it was learned by Polk County Sheriff's Office Detectives that the mother of the victim had possibly received a telephone call from the victim on December 27, 2009. Polk County Sheriff Office Detectives then made contact with the victim's mother and learned that she had received a telephone call from a subject who had identified himself as Abraham Shakespeare. The victim's mother further advised that she had received the telephone call while she was eating dinner at a restaurant with Dee Dee Moore. The victim's mother advised that she was unsure if the subject who placed the telephone call was in fact the victim. Polk County Sheriff's Office Detectives were able to obtain the telephone number that the call had been placed from and were able to determine that the telephone was registered to Gregory Todd Smith.

On December 28, 2009, Polk County Sheriff's Office Detectives were attempting to locate Mr. Smith when they observed Mr. Smith meeting with Dee Dee Moore in Lakeland, Florida. After the meeting

between Mr. Smith and Ms. Moore was concluded, Detectives made contact with Mr. Smith and interviewed him. During the interview it was learned that Mr. Smith had been solicited by Ms. Moore to make several telephone calls. These telephone calls included one call to a Polk County Sheriff's Office Detective claiming to have seen the victim within the past couple of days in Miami, Florida, and also a telephone call to the victim's mother purporting to be Abraham

Shakespeare himself. Mr. Smith advised that he had made these telephone calls for Ms. Moore in exchange for being paid several hundred dollars by Ms. Moore. Mr. Smith advised that Ms. Moore had already approached him about doing other acts involving the investigation of the missing victim. Mr. Smith agreed to co-operate fully with Law Enforcement at that time.

During the following weeks, Mr. Smith met with Ms. Moore on several occasions. During each of these meetings Mr. Srni th was equipped with a digital audio recorder to record the meetings and the meetings were observed by Law Enforcement personnel. During these meetings Ms. Moore would solicit Mr. Smith to do various acts that would make it appear that the victim was alive and was missing on his own free will. On January 6, 2010, Ms. Moore actually typed a letter under the auspices of being from the victim and wanted Mr. Smith to deliver the letter to the mailbox of the victim's mother. In this letter Ms. Moore writing as the victim told the victim's mother that he was fine and was staying out of the area because the police were going to arrest him. The letter also referred to the aforementioned telephone call that Mr. Smith had placed to the victim's mother on 12/27/2009, and questioned how she (victim's mother) could not recognize the voice of her own son.

After several weeks of having Mr. Smith do acts trying to make it appear as though the victim was alive and missing on his own free will, Ms. Moore approached Mr. Smith and asked him if he knew anyone that would be willing to tell Law Enforcement that they had killed the victim. It was determined that Mr. Smith would introduce an Undercover Detective to Ms. Moore under the illusion that the Undercover Detective was a subject already facing a lengthy prison term and would be willing to ad.mi t to killing the victim for monetary compensation.

On January 21, 2010, Officer Mike Smith of the Lake Wales Police Department working in an undercover capacity was introduced to Ms. Moore by Mr. G. Smith. During the meeting Ms. Moore agreed to pay Officer Smith $50,000.00 U.S. Currency if he would tell Law Enforcement that he had killed the victim. Officer Smith advised that he would do this ,butthat he needed details of where the victim's body was in order for Law Enforcement to believe his confession. Ms. Moore advised that she would provide that information to Mr. G. Smith at a later time. After the meeting between Ms. Moore and Officer Smith was completed, Mr. G. Smith drove Ms. Moore back to her vehicle that was parked at a different location. During the ride Ms. Moore advised Mr. G. Smith that she would tell him the location of the victim's body and that she also had possession of the firearm that killed the victim. A plan was then devised between Ms. Moore and Mr. G. Smith, that Mr. G. Smith along with Officer Smith would dig up the body of the victim and move it to a different location so that Officer Smith could then advise Law Enforcement where the body was located. It was further

planned that Ms. Moore would give possession of the firearm used to kill the victim to Mr. G. Smith so it could be turned over to Law Enforcement to solidify the confession of Officer Smith.

On January 25, 2010, Ms. Moore contacted Mr. G. SIDi th and advised that she needed to meet with him. Mr. G. Smith then met with Ms. Moore in Lakeland, Florida. During the meeting Ms. Moore advised that she would be getting the firearm later in the day to turn over to him (G. Smith). It was also planned that she would take Mr. G. Smith to the location where the body of the victim was located.

Later in the day of January 25, 2010, Ms. Moore again met with Mr. G. Smith, this time at a location in plant City, Florida. At this time Ms. Moore gave Mr. G. Smith a .38 Caliber Smith and Wesson Revolver (Serial Number DBU2414/642-2). During this meeting Ms. Moore advised that she would meet with Mr. G. Smith later in the day and take him to the location where the victim's body was buried.

Approximately two (2) hours later still on January 25, 2010, Ms. Moore again met with Mr. G. Smith in Plant City, Florida. Mr. G. Smith then got in to Ms. Moore's vehicle. Ms. Moore then drove Mr. G. Smith to 5802 Highway 60 in Plant City, Florida. Ms. Moore then showed Mr. G. Smith a 30' x 30' concrete slab (poured on 4/13/2009) located in a wooded area approximately 30 yards north of the residence on the property. Ms. Moore advised that the victim was buried beneath the concrete slab. Ms. Moore had previously parked a white Ford Truck with an attached utility trailer blocking view of the concrete slab from the roadway. Ms. Moore told Mr. G. Smi th to look inside the trailer. Mr. G. Smith looked in the trailer and observed several gallons of fuel, gallons of bleach, gloves, and a metal tub/trough. Ms. Moore advised Mr. G. Smith that after digging up the victim's body he could place the body in the tub/trough and transport it in the trailer. Ms. Moore then provided Mr. G. Smith with keys to the Ford Truck. Ms. Moore further advised that the victim had been killed in her office and pointed to the residence located at 5732 Highway 60, which is located directly to the west of the residence where the victim's body is buried.

On 01/26/2010, affiant along with co-affiant and members of both Hillsborough and Polk County Sheriff's Offices served two separate search warrants upon the said property of this warrant and the residence located at 5732 Highway 60 Plant City, Florida. A subsequent interview was conducted by affiant and Polk County Detective David vvallace, with David Howard Stitzel at his attorneys office in Brandon, being Patrick Courtney and Glen Lansky. David Howard Stitzel arrived at the crimescenes with his attorney Glen Lansky. Stitzel then traveled to their (Courtney and Lansky) law office for an interview, due to his own law practice office being within a room contained within the two-story brown in color

residential structure at the physical address plant City, Florida) being then searched.

(5802 Highway 60

During the interview of David Howard Stitzel, he stated to affiant and Detective David Wallace that he last physically saw the victim, Abraham Shakespeare sometime between April or May 2009 at his prior office location, 607 S. Alexander St. Plant City, Florida. Dorice (Dee Dee) Moore, became a client of Mr. Stitzel in late 2008. Mr. Stitzel proceeded to advise the alleged phone call supposedly made in the presence of Dee Dee Moore wherein he earlier claimed to have last heard from Shakespeare on October 6, 2009, could have been the victim or could have not been the victim. Mr. Stitzel stated he moved to the property located at 5732 Highway 60 Plant City, Florida temporarily, on ar about May 15th, 2009 to early June 2009. Upon completion of the renovation within the structure located at 5802 Highway 60 Plant City, Florida, Mr. Stitzel then moved in setting up office space for his practice. Sometime last week, being the third week of January, Mr. Stitzel along with his assistant/girlfriend Michelle Findley, observed Dee Dee Moore sitting at his computer, utilizing it within his office space in which he rents from her (Dee Dee Moore). Mr. Stitzel admits to preparing the document in which Judith Haggins signed as Power of Attorney for Abraham Shakespeare, although Ms. Moore and Ms. Haggins filed it at the Clerk of the court on their own.

Mr. Stitzel had previously discussed with Polk Detectives D .

Wallace and D. Clark that he knew Abraham Shakespeare was the other person on the other end of the phone call because he knew his clients voice. Polk detectives later conducted a controlled phone call as previously mentioned. It was apparent based on the controlled phone, that Mr. Stitzel was aware Dee Dee Moore was in possession of his clients cellular telephone and purporting he

(Abraham Shakespeare) was alive and well, just missing on his own free will. Thus, transactions and later court appearances in Polk County on behalf of Abraham Shakespeare which were made by Mr. Stitzel are of a fraudulent nature and indicating his possible involvement and/or knowledge of the murder of Abraham Shakespeare. Certain files, transactions and legal documentation are believed to be in possession by Mr. Stitzel within his office at the mentioned location, and are believed to clarify his involvement with the disappearance and/or murder of Abraham Shakespeare.

On 01/27/2010, affiant along with Detective David Wallace of Polk County, conducted an interview with Judith Haggins (power of attorney for Abraham Shakespeare) at her attorneys office, being Larry Hardaway in Lakeland, Florida. Ms. Haggins stated Abraham Shakespeare asked her to be his power of attorney which was notarized and filed on 04/03/2009 with the Clerk of the Court in Polk County. Before Abraham Shakespeare was noted as missing, Ms. Haggins noted Dee Dee Moore would embellish how serious Abraham Shakespeare's child support proceedings were, and would encourage

him to move money wi thin his various accounts in an at tempt to protect it from the biological mother of his (Abraham Shakespeare) child. Ms. Haggins advised she would tell Abraham Shakespeare that his child support case was not as serious as Dee Dee Moore made it out to be. In 2009, at an unknown time frame, Ms. Haggins admitted she was instructed by Dee Dee Moore to withdraw the remaining funds from some of Abraham Shakespeares bank accounts which totaled in her opinion, less than $2000. The money, in the form of cashiers checks, were then given to Dee Dee Moore.

On January 28, 2010, Detective Thomas of the Hillsborough County Sheriff's Office and Detective Wallace of the Polk County Sheriff's Office conducted an interview with Dee Dee Moore's exhusband, James Moore. Mr. Moore stated that Dee Dee Moore asked him to recommend the type of equipment to clear her land at 5802 Hwy. 60 Plant City, Florida. He suggested a tractor with attachments, however she purchased a Case Backhoe on April 3, 2009 at a Lakeland Auction. Dee Dee Moore paid James Moore approximately $100 to pick-up the backhoe and deliver the same to her property on highway 60, utilizing his family's flat bed trailer. Dee Dee Moore called James Moore during the first two weeks of April, 2009, and requested that he come to her property at 5802 Highway 60 and utilize the purchased Case backhoe to dig a hole for concrete and trash. James Moore stated that originally Dee Dee Moore asked the hole to be dug directly behind the rear door of 5732 Highway 60. However, James Moore suggested to not dig there due to the close proximity to the house, therefore Dee Dee Moore pointed out the location behind 5802 Highway 60 and directed him where to dig as well as how large of a hole. James Moore stated that he left after digging the hole. He was called by Dee Dee Moore 1 to 2 hours later to fill the hole in. James Moore stated it was getting dark and he did not see a body in the hole, but rather assumed it was chunks of concrete due to there being a lack of light and having dug previous holes on her property before. During interviews conducted with Dee Dee Moore on January 29 and 30, 2009, by Detectives Thomas and Wallace, she admitted having contacted James Moore to dig a hole for trash at a location behind the residence at 5802 Highway 60. She further admitted that the body of Abraham Shakespeare was buried in hole dug by James Moore.

However, she was adamant that James Moore did not know there was a body placed in the hole when he returned to fill it in.

On 01/28/2010, the remains of a human body were found at 5802 Highway 60 Plant City, Florida after extensive crimescene process by both Hillsborough and Polk County Sheriff's Offices. The remains were positively identified as Abraham Shakespeare. The body of Abraham Shakespeare was found at the precise location under the concrete slab that Dee Dee Moore personally showed to Gregory Smith.

Beginning on 01/29/2010, affiant and Detective David Wallace

~4I~~~========~~~2~O~===================

of Polk County, interviewed Dee Dee Moore, who initiated contact herself. Ms. Moore has provided several accounts of how Abraham Shakespeare was murdered to date, to include an unknown drug dealer named Ronald, herself in self-defense, Mr. Shakespeare's cousin Cedric Edom and finally her 14 year old son R.J. On 01/30/2010, Ms. Moore re-initiated contact with affiant and Polk County Detectives yet again. During this particular interview, Ms. Moore alleged David Stitzel shot the victim Abraham Shakespeare and helped to arrange his burial on her property. In all of these versions, Dee Dee Moore consistently told investigators that two shots were fired at Abraham Shakespeare. During the course of an autopsy conducted by Hillsborough County Medical Examiners Office, upon the body of Abraham Shakespeare, two projectiles were recovered from the victims body. Based on several interviews with Ms. Moore to date, and her statements of preparing a letter to the victims mother stating he was alive after 04/06/2009 as well as the continued text messages and financial transactions via the Power of Attorney, it is affiant's and co-affiant's belief that items of evidentiary value noted in the evidence to wit are to be contained within an office in the north east corner of 5802 Highway 60. This office is also utilized by Dee Dee Moore and is next to the office utilized by Mr. Stitzel.

Abraham Shakespeare was functionally illiterate and unsophisticated in financial matters. The investigation of the relationship between Mr. Shakespeare and Dee Dee Moore supports the conclusion that in the months prior to Abraham Shakespeare's death, Dee Dee Moore conducted a series of ostensibly legal financial transactions with Mr. Shakespeare, which were designed to, and did, transfer the vast majority of the remainder of his cash, real property and intangible assets to her control, or to the control of her associates or entities controlled be her. By her own admission, Dee Dee Moore never paid Abraham Shakespeare for the $1.2 million dollar home that he deeded to her, or for the intangible assets that he transferred to her. The true, one-sided nature of these financial transactions provide the motive for the murder of Abraham Shakespeare. Some of these ostensibly legal financial transactions were conducted with the legal assistance of Attorney David Howard Stitzel. Based on the investigation conducted to this point, investigators have reason to believe that a search of the residence at 5802 Highway 60 in Plant City, including the law office of David Howard Stitzel, will produce records pertaining to the financial relationships and financial transactions among Abraham Shakespeare, Dee Dee Moore, American Medical Professionals LLC, which is Ms. Moore's business, her boyfriend, Shar Krasniqi, Shakespeare and Associates LLC, Abraham Shakespeare LLC, and David Howard Stitzel. Based on the foregoing investigation, it is further anticipated that a search of this two-story residence shall reveal legal files, legal documents, legal memorandums and legal communications which shall comprise documentary evidence of the financial transactions

~.r--~"'_""_~============2==1 ==============================

which led to the transfer of Mr. ultimate death.

Shakespeare's weal th and his

On 02/02/2010 at approximately 1750 hour, execution of a search warrant was completed and the listed evidence, being an eMachine central processing unit with a serial number of GCJ7A20000438 was collected. Affiant and co-affiant believe evidence of the listed offense as well as documentation and evidence pertaining to Dee Dee Moore, Abraham Shakespeare, Abraham Shakespeare LLC, and Shakespeare and Associates LLC are contained upon this computer. The HP CPU noted as inventory #520364 item #36 will be transported to FDLE for mirror imaging and copies will be properly forwarded per the Execution of Search warrant and Preservation Privileges.

Refer to attached exhibit A.

EXECUTION OF SEARCH WARRANT AND PRESERVATION OF PRIVILEGES

To assure the preservation of any privilege attached to any legal file, document, memorandum or communication, these items shall be sealed immediately upon seizure without law enforcement inspection or review, except to the limited extent necessary to prepare the statutorily required inventory to the search warrant return. Mr. David Howard Stitzel shall be allowed, if he chooses, to prepare his own inventory of any legal files, documents, memorandums or communications seized pursuant to this warrant, prior to their removal from the premises.

Following the seizure and sealing of any legal files, documents, memorandum or communications, Hillsborough County Sheriff's office shall deliver the sealed items to an independent commercial copying business for the reproduction and pagination of these items within three working days. At the completion of the copying and pagination the seized legal items shall be sealed and the originals of all seized legal documents, except those related to Abraham Shakespeare, Dee Dee Moore, Abraham ShakespeareLLC, Shakespeare and AssociatesLLC, and Shar Krasniqi shall be returned to Mr. David Howard Stitzel. The copies shall be sealed and returned, without law enforcement review, to the secure property/evidence section of the Hillsborough County Sheriff's Office.

All copies of legal files, documents memorandum and communications made pursuant to this warrant shall be submitted for in camera judicial inspection and review prior to unsealing for review to law enforcement investigation.

Electronic data containing legal files, documents, memorandums or communications shall be copied by the Florida Department of

22

Law Enforcement and sealed without inspection or review prior to investigations.

Electronic data seized pursuant to this warrant shall be reviewed in camera in accordance with those procedures applicable to documentary evidence.

Based on the aforementioned information detailing the financial documentation as well as legal documentation prepared and filed, affiant and co-affiant believe evidence of the Murder will be located upon the property.

WHEREOF, affiant makes this affidavit and prays the issuance of a search warrant in due form of law for the search of the above described premises for the said property, heretofore described, and for the seizure and safe keeping theref, subject to the order of this Honor le Court, by the u y d officers of the law.

~~,

~~~~~~~~~~--

Sworn to and~d before this

AD. 201-0• £f.:.::J;}_

Judge in anfi~sbOrOUgh County, Florida

~4I~====~~=--========2=3~~~================

SEARCH WARRANT

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

IN THE NAME OF THE STATE OF FLORIDA:

TO: THE SHERIFF OF HILLSBOROUGH COUNTY, FLORIDA, AND/OR ANY OF HIS LAWFUL DEPUTIES:

WHEREAS, complaint on oath and in writing, supported by affidavit has been made before me, the undersigned

HONORABLE, CIRCUIT COURT JUDGE, THIRTEENTH JUDICIAL CIRCUIT in and for the Hillsborough County, Florida, by Detective Greg Thomas, Hillsborough County Sheriff's Office and Detective Chris Lynn, Polk County Sheriff's Office.

The affiant and co-affiant have reason to believe and do believe certain computer equipment located in Hillsborough County, Florida, described as follows, to-wit:

SEE ATTACHED EXHIBIT "A" WHICH IS HEREBY INCORPORATED BY

REFERENCE AND MADE A PART HEREOF

and there is now being kept within said computer equipment certain evidence of criminal activity including but not limited to computer equipment, computer programs, computer storage devices, to include but not limited to CDs, removable drives, thumb drives, pen drives, removable secure storage devices, graphic files, and any other media that can store digital files and/or digital media. Phone records, records of Internet Service Providers, E-mails and other computer data, including but not limited to encryption, passwords telephone numbers, Emails, Instant messages, computer images, computer programs and system documentation; documents files or any other computer data relating to encryption, passwords, and/or access to or ownership of the computer and Internet Service Provider, documentation used in violation of the laws of the State of Florida to-wit: law prohibiting, F.S.S. 782.04 Murder

and there is now being kept on said premises certain

Physical Evidence: HP central processing unit serial number 2UA9040QWI, used in violations of laws of the State of Florida, towit:

It will become necessary for reasons of practicality to remove

the hardware and conduct a search off-site. Your affiant and co-

• affiant believe that, in this case, the computer hardware is a

~ ~~~~~====~~~~~===== 24

container for evidence, a container for contraband, and also

itself an instrumentality of the crime under investigation.

That the facts tending to establish the grounds for this application and the probable cause of affiant believing that such facts exist are contained in an AFFIDAVIT FOR SEARCH WARRANT, sworn to before me on this date by Detective Greg Thomas and Detective Chris Lynn.

And it appears to the Court that the affiant is a reputable deputies of Hillsborough County and Polk County, State of Florida, and that the facts set forth in said affidavit show and constitute probable cause for the issuance of this warrant and the Court being satisfied of the existence of said grounds set forth in said application, or that there is probable cause to believe in their existence.

NOW THEREFORE, you are commanded with such proper and necessary assistance as may be necessary, in the day-time or in the nighttime, or on Sunday, as the exigencies of the occasion may demand or require, to enter and search the aforesaid computer equipment, described but not limited to hard drives, zip drives, thumb drives, pen drives, CDs, for the property described in this warrant: and if the same or any part thereof be found, you are hereby authorized to seize and secure same, giving proper receipt therefore and delivering a duplicate copy on said computer equipment to the said WHITE MALE KN01il1I:J AS DAVID HOWARD STITZEL AND ANY, JOfIN OR JANE DOE WHOSE NAMES ARE UNKNOWN TO YOUR AFFIANT or any other person or persons, and by making a return of your doings under this warrant within ten (10) days of the date hereof, and you are further directed to bring said property so found before any County and/or Circuit Judge having jurisdiction of this offense to be disposed of according to law.

Further, you are commanded to search the property seized and the contents of same using such technology as may be necessary, performing such search at such locations and with such specialized personnel as may be appropriate, in order to obtain

any relevant 'dence of the felony crimes noted herein.

WITNESS ~ day of ~AA-( ,2010.

County, Florida

Exhibit A

A central processing unit with a name brand of HP and a serial number of 2UA9040QWI, located at 2316 Falkenburg Rd. Tampa, Fl 33619 within Hillsborough County. This item is noted as item #36, invento~ # 520364 under case # 10-42631 .

"""" .• r--~"_""""""-~===================================

26

EXHIBIT

~

I

INVENTORY AND RECEIPT OF PROPERTY SEIZED UNDER THE WITHIN SEARCH WARRANT

TYPE OF ITEM

This I)' dsy 01 u,_J

r I

.A.D., 20)0.

RETURN

LOCATION FOUND

FOUND BY

;g6r~

STATE OF FLORIDA

COUNTY OF HILLSBOROUGH:

Received 11K within searcn warrant on the ~daY of-,....,'-:...,,>'C·~'~r-..:;_r-----L A.D.,20 It:; and executed the

same in Hillsborough County, Florida, on the~-iJay 01. v A.D. 20/9 by searching the

premises described herein and by taking into ",ycustody and possession e following described property, to-wit:

SEE ABOVE USTED INVENTORY

And Ifurther executed the Said.' warrant by.arreSti~~ __ .. ...,.._;~-'!i~'J4...:._--.."r-----::: ........ ----------' and by delivering a duplicate copy of this warrant to ~ ~ {,~

and by making and delivering to the said t:;.Ltv4:.- ~ ~

a true inventory of the above described property.

Officer

I, .da-~ ;;J}/'~. officer by whom the foregoing warrant wa.< executed, do swear the above inventory

contains a true nd detailed account of all prop'rty tok?-[jJ~' L._ ,

C'''''orn to and subscribed before me .:5{! r ;:: Co.sa..1 3&cPfI' ! Notary Public, State of Florida

- • ff diiy 01 ££iJ. A.D.20z1!..

My commission expiresfAidE/)W(V1'ft!?120&'

3050 Rev 7/05

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA IN AND FOR HILLSBOROUGH COUNTY CRIMINAL JUSTICE DIVISION

STATE OF FLORIDA

H.C.S.O CASE NO.: 2010-42631

VS

JOHN DOE OR JANE DOE

PETITION TO SEAL SEARCH WARRANT AND RELATED DOCUMENTS

COMES NOW THE STATE OF FLORIDA by and through the undersigned Assistant

State Attorney pursuant to Florida Rule of Judicial Administration 2.420 and

move this Honorable Court to enter an order sealing the search warrants and

related documents described below from public inspection until the release of

the discovery to the defense (upon request) or until further order of this

Court, and would show in support as follows:

1)

Abraham Shakespeare, D.O.B. 4/23/66, was last confirmed to be

alive on, or about, April 6, 2009. Information obtained during

the investigations conducted by members of the Polk and

Hillsborough County Sheriff's Offices support the conclusion that

Mr. Shakespeare's disappearance was the result of foul play.

2) The body of Abraham Shakespeare was recovered from its burial

3 )

site under a concrete slab located behind the two story residence

located at 5802 State Road 60 in plant City.') ~ --- ~CS2

On February {:!f_ , 2010, the Honorable Judge f'b~ k w

Issued search warrants, which authorized the search of property

and structures located at 5802 State Road 60 in Plant City and

5732 State Road 60 in Plant City. During the execution of these

search warrants computer hardware was found described as "a

==4IIIf=================~c~e~n~t~r~akJb:p~r~Q~c~e~s~s~i~n~g~u~n~l~·~t~w~i~tdhLJa~n~a~m~e~b~r~a~n~d~o~f~H~p~a~n~d~a~~s~e~r~i~a~l~================~

number of 2UA9040QWI, located at 2316 Falkenburg Rd., Tampa, Fl

Page 1 of 3

4)

33619 within Hillsborough County, Item is noted as item #36, inventory #520364 under case #10-42631".

The affidavit in support of the search warrant set forth facts and interviews learned and obtained during the course of the ongoing investigation into the disappearance of Abraham Shakespeare.

5) The search warrants and related documents contain sensitive and/or

6 )

confidential information that is part of an ongoing investigation. The continued confidentiality until release of the discovery to the defense is required to;

a. Prevent a serious and imminent threat to the fair, impartial and orderly administration of justice, or

b. Protect a compelling governmental interest; or

c. Avoid substantial injury to an innocent third party .

There are no less restrictive measures available to protect the interests of law enforcement, the ongoing investigation or the safety of the third party.

7) The motion and order to seal this search warrant and related

documents will not be sealed and will be filed with the Clerk's office.

8) The need for confidentiality will only continue until the discovery is released.

9) The warrant, affidavit and attached exhibits have been filed with the Clerk of the Circuit Court.

Wherefore, the State of Florida moves this Honorable court to Seal the Search Warrant and Related Documents.

=.~==~--------==========~~~~~

Page 2 of 3

I HEREBY CERTIFY that a true and correct copy of the foregoing Motion and L.i,r{....

Order will be furnished to the Clerk of the 13th Judicial Court, this day

of February, 2010.

Respectfully submitted,

MARK A. OBER

S:D:::Y

~ER

ASSISTANT STATE ATTORNEY FLORIDA BAR# 559415

JP/als

-.r-------~======================~~

Page 3 of 3

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA IN AND FOR HILLSBOROUGH COUNTY CRIMINAL JUSTICE DIVISION

STATE OF FLORIDA

H.C.S.O. CASE NO.: 2010-42631

VS

JOHN DOE OR JANE DOE

ORDER

THIS CAUSE having come on to be heard and the Court being fully

advised in the premises, it is hereby

ORDERED AND ADJUDGED that the Motion to Seal Search Warrant,

attached exhibits and related documents pertaining to the computer hardware

described as "a central processing unit with a name brand of HP and a serial

number of 2UA9040QWI, located at 2316 Falkenburg Rd., Tampa, Fl 33619 within

#10-42631" is granted and that the Clerk of the 13th Judicial Circuit is

Hillsborough County, Item is noted as item #36, inventory #520364 under case

ordered to prevent the release of these documents to the public until the

of this Court.

release of the discovery to the defense (upon request) or until further order

~DONE AND ORDERED in this ~ day of February, 2010.

CIRCUIT COURT JUDGE THIRTEENTH JUDICIAL CIRCUIT HILLSBOROUGH COUNTY, FLORIDA

lals

AFFIDAVIT

FOR SEARCH WARRANT

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

STATE OF FLORIDA :4

COUNTY OF HILLSBOROUG· r-' r _ ... ~ AJ

BEFORE ME, HONORABLE, t :ettr ~ \(:7L.(_)L--cricUIT COURT

JUDGE, THIRTEENTH JUDICIAL CIRCUIT , in and for Hillsborough County, Florida, personally came affiant Detective Greg Thomas, Hillsborough County Sheriff I s Office and co-affiant Detective Christopher Lynn, Polk County Sheriff's Office being first duly sworn, deposes and says: That affiant and co-affiant are reputable Deputies of said Hillsborough County and Polk County, State of Florida, and that they have reason to believe and do believe that certain certain computer equipment located in Hillsborough County, Florida, described as follows, to-wit:

SEE ATTACHED EXHIBIT "A" WHICH IS HEREBY INCORPORATED BY

REFERENCE AND MADE A PART HEREOF

and there is now being kept within said computer equipment certain evidence of criminal activity including but not limited to computer equipment, computer programs, computer storage devices, to include but not limited to CDs, removable drives, thumb drives, pen drives, removable secure storage devices, graphic files, and any other media that can store digital files and/or digital media. Phone records, records of Internet Service Providers, E-mails and other computer data, including but not limited to encryption, passwords telephone numbers, Emails, Instant messages, computer images, computer programs and system documentation; documents files or any other computer data relating to encryption, passwords, and/or access to or ownership of the computer and Internet Service Provider, documentation used in violation of the laws of the State of Florida to-wit: law prohibiting, F.S.S. 782.04 Murder

being the premises occupied by or under the control of

WHITE MALE, DAVID HOWARD STITZEL D.O.B. 03/04/1964 AND ANY OTHER UNKOWN NAMES

Physical Evidence: Ativa thumb drive, used in violations of laws of the State of Florida, to-wit: 782.04 Murder

It will become necessary for reasons of practicality to remove

the hardware and conduct a search off-site. Your affiant and co-

affiant believe that, in this case, the computer hardware is a

container for evidence, a container for contraband, and also

itself an instrumentality of the crime under investigation.

That the facts tending to establish the grounds for this application and the probable cause of affiant believing that such facts exist are as follows:

The affiant Greg Thomas, a Detective of the Hillsborough County Sheriff's Office being sworn states:

1. Your affiant is an Investigative Law Enforcement Officer as defined in Florida State Statute 934.02, and is making this application pursuant to my official duties.

2. Your affiant is authorized to do so by the Honorable Mark Ober, State Attorney for the Thirteenth Judicial Circuit, Hillsborough County, Florida, pursuant to the authority conferred upon him by F.S.S. 934.07 .

3. That the affiant is a member of the Hillsborough County Sheriff's Office and has been so employed since October 2000. Your affiant has been assigned to the Criminal Investigations Division as a Detective since August, 2003. Your affiant has been a participant in the execution of numerous Search Warrants.

The co-affiant Christopher Lynn, a Detective of the Polk County Sheriff's Office also being sworn. The co-affiant has been employed with the Polk County Sheriff's Office since July of 2002.

Your co-affiant has been assigned to the CID as a Detective for approximately 3 1/2 years. Your co-affiant has been a participant in the execution of numerous Search Warrants.

Abraham Shakespeare won $31 million in the Florida lottery.

Shakespeare elected the lump sum payout and collected approximately $12.7 million after taxes. Shakespeare was sued by a co-worker who made claim to the winning ticket. Ultimately the court ruled in the favor of Shakespeare in 2007.

Between winning the lottery in 2006 and meeting Dee Dee Moore in 2008, Mr. Shakespeare spent, gave away or loaned the majority of

his winnings and was left with approximately $1.5 million in cash and assets totaling approximately $3 million. Shakespeare utilized several financial institutions, seemingly one after another on the whim of various advisors: from Wachovia, along with various Annuity holdings, to Community Bank and eventually to Bank of America. Mr. Shakespeare did not invest heavily and was reported to be unimpressed with annuities to the point of pulling all of his money out and using the money to seed accounts accessed by Dee Dee Moore.

In December of 2008, Mr. Shakespeare liquidated an annuities account worth approximately $250K. In January 2009, this money was transferred to the business account of American Medical Professionals, a business owned by Dee Dee Moore since 2004. In her interviews, Ms. Moore stated this money was provided to her for the purposes of paying taxes on behalf of Shakespeare. This money was tracked to several recipients including Ms. Moore's

~ boyfriend, Shar Krasniqi, and Real Time Services, American Medical Professionals' payroll and accounting service. Additionally, a review of bank statements of American Medical Professionals and accounts related to Dee Dee Moore has shown that Moore utilized the American Medical Professionals checking account as her primary account including personal charges. Any personal accounts of Dee Dee Moore that have been located have

minimal activity. these funds having Shakespeare.

Investigation has not revealed any records of been used to pay any tax debt of Abraham

Land Transfers

On January 9th, 2009, Mr. Shakespeare signed a Quitclaim Deed to American Medical Professionals LLC on his primary residence, 9340 Redhawk Bend Drive. The deed was recorded on 01-13-09. Abraham Shakespeare paid $1.07 Million in 2007 for the home, and Dee Dee Moore, in a statement given to Polk County Sheriff's detectives

3

on or about November 9, 2009, stated she paid him over $500,000 in cash. In a subsequent statement given to Polk Sheriff's Detectives on January 25, 2010, Ms. Moore stated that she had not paid Abraham Shakespeare because Shakespeare had a drug problem and she felt that he would use it to buy drugs. In a statement given to detectives on January 29, 2010, Ms. Moore stated that she had not paid Abraham Shakespeare because he did not want to pay the gift tax owed on the amount. A review of Dorice (Dee Dee) Moore's bank records has not revealed corresponding withdrawals, checks, or transfers indicating payment for the home, to date.

After receiving his lottery winnings, Abraham Shakespeare made mUltiple loans to individuals to buy homes and recorded mortgages documenting the loans. On January 11, 2009, Mr. Shakespeare signed Quitclaim Deeds to American Medical Professionals, LLC for

properties located at 1418 West Lake Parker Drive, Lakeland,

• Florida and 409 Pearl Street, Lake Hamilton, Florida. Each deed was recorded on 02-11-09.

On January 15, 2009, Mr. Shakespeare signed an "Asset Purchase Agreement" which sold all of his un-enumerated "assets" to American Medical Professionals LLC for the price of $185,000. The value of outstanding loans purchase in the "Assets Purchase Agreement" plus the value of real estate separately purchased total over $3.5 million worth of assets for less than 5 cents on the dollar. Although a copy of the Asset Purchase agreement has been obtained by investigators, the "Addendum" to the agreement has not been located. The "un-enumerated assets" sold by Mr. Shakespeare to American Medical Professionals were purportedly to be listed in the addendum. (A copy of the "Assets Purchase Agreement" is attached here to as Exhibit "C")

On both the 15th, and 16th of January 2009, Mr. Shakespeare signed paperwork documenting the fact that the following

4

mortgages were hereby ASSUMED by American Medical Professionals LLC.

Property Loan Amount Mortgage Assignment Date
Address Dated Dated Assignment
Recorded
648 West 4th $14,752.00 March 13, January May 6,
Street, 2007 15, 2009 2009
Lakeland
727 East $63,000.00 February January May 6,
McDonald 23, 2007 15, 2009 2009
Street,
plant City
1103 Neville $69,000.00 May 14, January April 1,
Avenue, 2007 16, 2009 2009
Lakeland
3075 Sire $185,000.00 April 4, January April 1,
Trail, 2007 16, 2009 2009
Lakeland
Rodman $52,000.00 December January April 1,
Development, 17, 2007 16, 2009 2009
Inc. All of these transactions have been recorded by either the Clerk of the Courts or the Polk County Property Appraiser's Office. Also, all of these transactions were prepared by Howard Stitzel. This fact was noted via the header on the top left of the front pages of all of these documents. Further, Howard Stitzel, maintains a law office at 5802 State Road 60 East, Plant City. The Law offices of David Howard Stitzel shall be among the locations with that address that shall be searched pursuant to this warrant. The property is titled in the name of Shar Krasniqi.

~.~~~~~~~==========~~~~

5

ABRAHAM SHAKESPEARE, LLC

On February 5, 2009, a faxed request form for surrender of the Prudential Annuities Account in the name of Abraham Shakespeare, purportedly with Shakespeare's signature, was faxed from Staples in Lakeland, Florida. The surrender form requested the full amount contained in the account, $1.095 million, to be paid in the form of a check made payable to Abraham Shakespeare and sent via mail to his address.

On Feb. 9, 2009, Ms. Moore registered the business Abraham Shakespeare LLC, with the Department of State, Division of Corporations, where she is listed as the registered agent and director.

On Feb. 10, 2009, Ms. Moore opened an account at Bank of America in the name of Abraham Shakespeare LLC with $100 cash. Ms. Moore

• was the only signor on the account at that time.

On February 11, 2009, Dee Dee Moore provided the bank Articles of Incorporation along with papers purporting to be "meeting minutes" of the "board" of Abraham Shakespeare LLC. Contained among the meeting minutes were minutes of a "meeting" which was purported to be "attended" by Dee Dee Moore, Judith Haggins and Abraham Shakespeare. The documented discussion was about adding Abraham Shakespeare's name as an authorized signer. Further, the $1.095 million check from Abraham Shakespeare's Prudential Annuities account was then deposited into the Bank of America account in the name of Abraham Shakespeare, LLC. on February 11th 2009. Judith Haggins is a longtime friend of Abraham Shakespeare.

She met Dee Dee Moore through Abraham Shakespeare and soon became a business associate of Dee Dee Moore. Judith Haggins acted as Abraham Shakespeare's paid driver and personal assistant.

11~==~~~~~~--~=============

6

No activity occured in the Bank of America account until Feb. 17th, when the bank was again provided with "meeting minutes" of Abraham Shakespeare LLC. by Dee Dee Moore. Ms. Moore was the only person listed in attendance. These "minutes" describe the discovery of "criminal activity" on the part of Shakespeare, which may result In criminal charges. Therefore, Shakespeare was to be removed as an authorized signer of the account. Bank of America therefore removed Shakespeare as an authorized signatory.

From February 10, 2009 to February 17, 2009 the account shows no activity. On February 18, 2009, a cashiers check for $250,000 drawn on the Abraham Shakespeare LLC. Account was made payable to ASTAT and was deposited to Navy Federal Credit Union account. ASTAT and Supply, LLC was a business registered with the Department of State Division of Corporations and was reinstated

as an active corporation on October 15, 2008. Shar Krasniqi was

listed as CEO. Additionally, the account holder of the Navy Federal Credit Union account is Shar Krasniqi. Further, on February 18, 2009, a cashiers check for the sum of $250,000 was drawn on the Abraham Shakespeare LLC. Account made payable to the Internal Revenue Service. This check was endorsed by D. Moore. Notated on the check, in the endorsement section, were the hand written words "not needed for intended purpose". This $250,000 check is then deposited into the business account of American Medical Professionals LLC. By the use of the endorsement "not needed for intended purpose" Dee Dee Moore was able to divert the sum of $250,000 from its intended purpose to her own control and benefit. On February 19, 2009 and February 23, 2009, cashiers check for $200,000 and $250,000 respectively, were drawn on the account of Abraham Shakespeare LLC and were made payable to American Medical Professionals.

During the month of February 2009, Judy Haggins and D. Howard

7

Stitzel received approximately $20,000 each from the account of Abraham Shakespeare LLC. An electronic debit check made payable to the Internal Revenue Service in the amount of $30,000 was issued from the same account. The balance of the Abraham Shakespeare LLC account as of Feb 28, 2009 was $44,296.

Transactions from the Abraham Shakespeare LLC, Bank of America account show funds were transferred to the account of American Medical Professionals (Dee Dee Moore), ASTAT and Supply (Shar Krasniqi) just two months before the purchase of a residence located at 5802 Hwy. 60 East for approximately $253,000 in April, titled to Shar Krasniqi. Richard Land, the former owner of the property, stated to detectives that Dee Dee Moore paid him with a check from the account of American Medical Professionals.

CONTROLLED PHONE CALL CONCERNING HOWARD STITZEL

On 11/12/2009, Detective David Clark and Detective David Wallace responded to the law office of D. Howard Stitzel located at 5802 Highway 60 in Plant City, Florida. Detectives Clark and Wallace then interviewed Mr. Stitzel in reference to the investigation. During the interview, Mr. Stitzel advised that he could not comment about the details of the conversation, but would confirm that he spoke to Mr. Shakespeare on the cellular telephone of Ms. Moore on October 6, 2009. When asked how he knew that he was speaking to Mr. Shakespeare, D. Howard Stitzel advised that Mr. Shakespeare was his client and that he was familiar with the voice of Mr. Shakespeare and that was who he was speaking to on the telephone.

During a December 3rd, 2009 interview with Polk County Sheriff's Detectives David Clark and David Wallace Dee Dee Moore stated that Shakespeare's telephone was part of the plan that Mr. Shakespeare had made to leave town. Ms. Moore advised that Mr. Shakespeare advised her to text message people after he left

using his phone that he left with Dee Dee Moore so the police could not track him. Ms. Moore was then asked to confirm that she had Mr. Shakespeare's cellular telephone in her possession at the time that she had originally advised that both she and D. Howard Stitzel had spoken to Mr. Stitzel on 10/06/2009. Ms. Moore confirmed that she was in possession of Mr. Shakespeare's telephone at that time and that neither she (Moore) or D. Howard Stitzel had spoken to Mr. Shakespeare on that date (10/06/2009). Ms. Moore was then asked why D. Howard Stitzel had told Detectives Clark and Wallace that he had spoken to Mr. Shakespeare. Ms. Moore advised that she asked Mr. Stitzel to say that to Law Enforcement and he (Stitzel) had agreed to lie to Law Enforcement to assist Ms. Moore. Ms. Moore then placed a controlled (taped) telephone call to Mr. Stitzel's cellular telephone. During the call, Ms. Moore advised Mr. Stitzel that Law Enforcement was asking her questions about the telephone call in which both she and Mr. Stitzel had allegedly spoke to Mr . Shakespeare on 10/06/2009. Ms. Moore conveyed to Mr. Stitzel that she was concerned that Law Enforcement would find out that they had not spoken to Mr. Shakespeare on that date and wanted to confirm that he (Stitzel) had told Law Enforcement that he (Stitzel) had spoke to Mr. Shakespeare on that date. Mr. Stitzel advised that he had told Law Enforcement that he had spoken to

Mr. Shakespeare on that date. Ms. Moore then asked Mr. Stitzel what would happen if she told Law Enforcement that she had possession of Mr. Shakespeare's cellular telephone. Mr. Stitzel then began telling Ms. Moore that she needed to stop talking to Law Enforcement. Although Mr. Stitzel made no direct admissions that he had in fact lied to Law Enforcement, it was apparent that Mr. Stitzel was aware that Ms. Moore had Mr. Shakespeare's cellular telephone and had not spoken to Mr. Shakespeare on 10/06/2009, as he had told Law Enforcement on 11/12/2009.

HOWARD STITZEL

During an interview on December 3, 2009 with Dee Dee Moore by Polk County Sheriff Detectives Wallace and Clark, when questioned about the above described money and property transfers she explained, she and Abraham Shakespeare, with the intent to avoid paying any child support, intentionally transferred all money and assets out of his name into the name of American Medical Associates. As stated above, Howard Stitzel's name appeared on the deed transfers. Additionally, Howard Stitzel was the Attorney of record representing Shakespeare in the child support enforcement action. This action commenced January 14, 2009. Howard Stitzel filed his response as Abraham Shakespeare's attorney on March 6,2009. Abraham disappeared in April 2009. As mentioned in the above section with the controlled phone call, Howard Stitzel made an implicit admission confirming his misrepresentation to police during the Polk County Sheriff s missing person's investigation. According to records on file with the Polk County Clerk of Courts, Howard Stitzel appeared in person in a Polk County Court in August 11, 2009 in the above mentioned Child Support Enforcement Action, and told the Judge that Abraham Shakespeare was out of the country receiving treatment as an explanation for his client's nonpresence. Howard Stitzel was also interviewed for a Ledger newspaper article which appeared on December 1,2009. Stitzel was quoted as saying "that the last time he talked with his client was in October when they discussed child support issues ... Stitzel said Shakespeare did not sound distressed during his phone conversation in October."

David Howard Stitzel represented Abraham Shakespeare in child support proceedings and drew up numerous document related to a variety of transactions described herein, including an assets purchase agreement with addendum, property deeds, Quitclaim deeds, contracts, mortgages and power(s)of attorney. David Howard Stitzel received three separate checks in February of2009 totaling $17,500 from Abraham Shakespeare LLC. All of these checks bore the signature of "Dee Dee Moore". During an interview with Detective Chris Lynn (Polk County Sheriffs Office) in November 2009, Dee Dee Moore stated that these checks were compensation for legal services rendered by David Howard Stitzel.

OVERVIEW OF HISTORICAL PURCHASES OF ASSETS

On 03/06/2007 Shakespeare purchased a BMW for approximately $100,000

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01/29/09 Dee Dee Moore bought a 2009 Lincoln MKS and titled it in the name of Abraham Shakespeare LLC. The same day she traded the Lincoln to Abraham for his BMW. She then titled BMW in the name of Shar Krasniqi

• 04/14/09 Dee Dee Moore traded the 2009 Lincoln MKS for a

2009 Chevy Silverado. $31,000.00 was allowed for the Lincoln and Dee Dee paid $13,302.60 in cash for the remaining balance on the vehicle

11/03/09 Dee Dee Moore took the BMW to Stingray Chevrolet and sold it to them for $37,000.00.

Shakespeare purchased a Ford 500 on 7/9/07

• In Early April 2009, Dee Dee Moore called Sentorria Butler and told her Abraham left his Ford 500 for Butler and it was at Moore's house. Sentorria Butler is the mother of Abraham Shakespeare's infant child, Jeremiah. In 2009, she initiated child support proceedings on behalf of her son against Abraham Shakespeare. After the aforementioned telephone call, Dee Dee Moore picked Sentorrria Butler up and took her to pick the car up. Sometime around 5/10/09 Judy Haggins took the vehicle back from Sentorria Butler using the power of attorney as authority to take the car back.

On 6/18/09, Dee Dee Moore took the 07 Ford 500 registered to Shakespeare and Associates to Stingray Chevrolet and sold it outright to them for $9,000.00. She presented the dealership with paperwork from the Florida Division of Corporations which showed her as the Manager of Abraham Shakespeare LLC, a completely different corporation. She signed the title as "CEO" of Shakespeare and Associates, which had been inactive since September 2008. Shakespeare and Associates LLC. was incorporated in 2007 by Abraham Shakespeare and an attorney,

11

Cedric Lewis, as a business entity to store Shakespeare's assets. Dee Dee Moore was never listed as an officer or director of Shakespeare & Associates LLC.

On or about February 21, 2009, Dee Moore bought a 2008 Chevrolet Corvette from Stingray Chevrolet for her boyfriend, Shar Krasniqi. She paid $70,390.86 for the vehicle with a cashier's check from American Medical Professionals LLC.

On March 2, 2009, Dee Dee Moore purchased a 2009 Hummer for approximately $90,000. On December 5, 2009, Dee Dee Moore took this vehicle to Stingray Chevrolet and told them she needed cash quickly and attempted to sell it to them for $49,000.00. They told her they were not interested due to the economy. William Smith, a friend of the owner of Stingray Chevrolet was present and offered to buy the Hummer himself. Dee Dee Moore agreed to sell it to him and requested that Mr. Smith call his bank so that she could cash the checks immediately. She also requested 3 separate checks from Mr Smith, one for $5,000.00 in the name of Dee Dee Moore, one for $4,000.00 in the name of Linda Donegan

(Dee Dee Moore's mother) and one for $40,000.00 in the name of Dee Dee Moore.

Power of Attorney

Notary Ambrose E. Austin was interviewed by Detective David Cavanaugh of Polk County Sheriff's Office, during the week of November 9, 2009. Mr. Austin told Detective Cavanaugh that on April 3, 2009, Shakespeare signed a Power of Attorney designating Judy Haggins as his POA. Notary Ambrose E. Austin stated Haggins was present during signing and advised Shakespeare was present. On November 13, 2009, Ms. Haggins told Detectives Wallace and Clark that this was the last time that she saw Shakespeare alive.

Haggins has, in fact, used the power of attorney to close bank accounts belonging to Abraham Shakespeare and sign court

pleadings on Abraham's behalf. Proceeds of closed accounts have been deposited into accounts controlled Dee Dee Moore.

On or about December 11, 2009, in a recorded conversation with Gregory T. Smith acting in the capacity as an informant with the Polk County Sheriff's Office, Judy Haggins stated that, in or around March 2009, Abraham Shakespeare approached her about concerns regarding Dee Dee Moore and his money. Haggins talked to Dee Dee Moore around the same time and Moore told Haggins not to let Shakespeare go to the bank because some of the money was not there. In all subsequent law enforcement interviews with Ms. Haggins, she has not admitted that this conversation had occurred. Gregory T. Smith became an informant with the Polk County Sheriff's Office as a result of a series of events, which are described later in this affidavit. Mr. Smith was a friend of Abraham Shakespeare from Lakeland, Fl. On February 23, 2007 Shakespeare and Associates LLC. obtained the mortgage to the house of Gregory Smith's mother. On January 15, 2009 Shakespeare and Associates LLC. assigned this mortgage to American Medical Professionals.

Additional Information

On or about November 9, 2009, Detective Chris Lynn began subpoenaing financial records of Mr. Shakespeare as well as those of Ms. Moore to include numerous Limited Liability Corporations (LLC) associated with Ms. Moore and her boyfriend Shar Anthony

Krasniqi. It should be noted that numerous financial documents were also voluntarily turned over to the Polk County Sheriff's Office by Ms. Moore during this investigation and numerous public record documents have been obtained related to the involved parties in this investigation. To date all subpoenaed financial information has not been received; however, upon an analysis of the received subpoenaed financial document and financial documents turned over by Ms. Moore there are numerous

'1I~~----~==================~~~~

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discrepancies between the factual information and information provided by Ms. Moore during several non-custodial interviews with Law Enforcement.

During several non-custodial interviews with Polk County Sheriff's Office detectives during the week of November 9, 2009, Ms. Moore provided the following information: She advised that she was introduced to Mr. Shakespeare in October of 2008. She advised that she initially met Mr. Shakespeare with the intention of writing a book about his life story. She advised that shortly after meeting Mr. Shakespeare, she noticed that he (Shakespeare) was being taken advantage of by numerous individuals and she offered her assistance to Mr. Shakespeare with his financial affairs. She advised that she did this out of "the goodness of her heart" not for any financial gain. She advised that Mr. Shakespeare had become disgruntled with everyone in his life asking for money. She advised that Mr. Shakespeare then began to devise a plan to leave the Lakeland area and never be heard from again. She advised that, in January of 2009, Mr. Shakespeare sold his residence located at 9340 Redhawk Bend Drive in Lakeland, Florida, to her for a price of $655,000.00. She advised at the same time, Mr. Shakespeare sold to her (Moore) all of the debt owed to him for a total of $185,000.00. Ms. Moore could not provide any documented proof of payment of the $840,000.00 to Mr. Shakespeare for the purchases, and advised that she had given him over $500,000.00 in cash as part of the payment. In January 2009, Ms. Moore admitted to detectives that she had not in fact paid Mr. Shakespeare any monies for his home or the purchase of his assets. She advised that, in February of 2009, she set up Abraham Shakespeare LLC for the sole purpose of keeping track of the money collected on the debts she had purchased from Mr. Shakespeare. Numerous times throughout the interviews with Ms. Moore she advised that she did not understand why we were asking her about her financial dealing with Mr. Shakespeare. She advised

that all financial dealings done between her and Mr. Shakespeare were completely legal and that she, unlike numerous others, was only trying to help Mr. Shakespeare with his finances. She advised that she was a millionaire prior to meeting Mr. Shakespeare and did not need any of his (Shakespeare's) money.

Financial and accounting records of American Medical Professionals were also subpoenaed and received. Accounting records for the years 2005 through 2009, inclusive, show that during that period of time, American Medical Professionals received profit distributions from their payroll service totaling approximately $720,000 over 5 calendar years. Those profit distributions were deposited primarily to the Bank of America American Medical Professionals account (for the period for which records have been received) and spent on a variety of activity including restaurants, travel, and jewelry .

Investigators have prepared a timeline of real estate transactions and monetary transfers. These timelines are attached as Exhibits A and B.

By the month of April 2009, bank records and public records reveal that Dee Dee Moore was in virtually complete control of all Abraham Shakespeare's assets and accounts. Further, Shakespeare had not received payment for those assets as agreed.

Shakespeare had begun to ask questions about his money and express concern about his dealings with Dee Dee Moore.

Abraham Shakespeare was last seen alive in the Lakeland, Florida area by Courtney Daniels during the first week of April 2009. Ms. Daniels knew Abraham Shakespeare for several years and periodically lived with Shakespeare at 9340 Red Hawk Bend Dr. Lakeland, Fl 33810. This statement was provided to Detectives Lyrill and Wallace on January 16, 2010. On 11/09/2009, the victim was reported to the Polk County Sheriff's Office as a missing adult by his cousin, Cedric Edom and was subsequently entered into the NCIC database under Polk County case number 09-112920.

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Early within the Polk County Investigation, Dee Dee Moore was identified as an associate of the victim, Abraham Shakespeare and was living at the last known address of the victim at the time of his disappearance. During ini tial interviews with Polk County Sheriff's Office detectives, Dee Dee Moore claimed that the victim was missing of his own free will in an attempt to elude payments regarding upcoming court proceedings. Ms. Moore advised during these initial interviews that she had been in contact with the victim several times since April, 2009 in person as well as by telephone.

During an interview wi th Detectives Wallace and Clark on November 25, 2009, Dee Dee Moore admitted that she sent text messages in the summer of 2009, to Mr. Shakespeare's friends and family in an attempt to convince them that Mr. Shakespeare was still alive.

During the course of the Polk County Sheriff's Office Investigation it was learned Ms. Moore had gained possession of all of the victim's known assets to include currency, vehicles and property beginning around January 2009. As a result, the mentioned property located at 5802 Highway 60 Plant City, Florida was purchased with approximately $350,000 dollars of the victims currency .

During the investigation, it was learned by Polk County Sheriff's Office Detectives that the mother of the victim had possibly received a telephone call from the victim on December 27, 2009. Polk County Sheriff Office Detectives then made contact with the victim's mother and learned that she had received a telephone call from a subject who had identified himself as Abraham Shakespeare. The victim's mother further advised that she had received the telephone call while she was eating dinner at a restaurant with Dee Dee Moore. The victim's mother advised that she was unsure if the subject who placed the telephone call was in fact the victim. Polk County Sheriff's Office Detectives were able to obtain the telephone number that the call had been placed from and were able to determine that the telephone was registered to Gregory Todd Smith.

On December 28, 2009, Polk County Sheriff's Office Detectives were attempting to locate Mr. Smith when they observed Mr. Smith meeting with Dee Dee Moore in Lakeland, Florida. After the meeting

between Mr. Smith and Ms. Moore was concluded, Detectives made contact with Mr. Smith and interviewed him. During the interview it was learned that Mr. Smith had been solicited by Ms. Moore to make several telephone calls. These telephone calls included one call to a Polk County Sheriff's Office Detective claiming to have seen the victim within the past couple of days in Miami, Florida, and also a telephone call to the victim's mother purporting to be Abraham

1IF=~~~~~~============~~~~

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Shakespeare himself. Mr. Smith advised that he had made these telephone calls for Ms. Moore in exchange for being paid several hundred dollars by Ms. Moore. Mr. Smith advised that Ms. Moore had already approached him about doing other acts involving the investigation of the missing victim. Mr. Smith agreed to co-operate fully with Law Enforcement at that time.

During the following weeks, Mr. Smith met with Ms. Moore on several occasions. During each of these meetings Mr. Smith was equipped with a digital audio recorder to record the meetings and the meetings were observed by Law Enforcement personnel. During these meetings Ms. Moore would solicit Mr. Smith to do various acts that would make it appear that the victim was alive and was missing on his own free will. On January 6, 2010, Ms. Moore actually typed a letter under the auspices of being from the victim and wanted Mr. Smith to deliver the letter to the mailbox of the victim's mother. In this letter Ms. Moore writing as the victim told the victim's mother that he was fine and was staying out of the area because the police were going to arrest him. The letter also referred to the aforementioned telephone call that Mr. Smith had placed to the victim's mother on 12/27/2009, and questioned how she (victim's mother) could not recognize the voice of her own son.

After several weeks of having Mr. Smith do acts trying to make it appear as though the victim was alive and missing on his own free will, Ms. Moore approached Mr. Smith and asked him if he knew anyone that would be willing to tell Law Enforcement that they had killed the victim. It was determined that Mr. Smith would introduce an Undercover Detective to Ms. Moore under the illusion that the Undercover Detective was a subject already facing a lengthy prison term and would be willing to admi t to killing the victim for monetary compensation.

On January 21, 2010, Officer Mike Smith of the Lake Wales Police Department working in an undercover capacity was introduced to Ms. Moore by Mr. G. Smith. During the meeting Ms. Moore agreed to pay Officer Smith $50,000.00 U.S. Currency if he would tell Law Enforcement that he had killed the victim. Officer Smith advised that he would do this, but that he needed details of where the victim's body was in order for Law Enforcement to believe his confession. Ms. Moore advised that she would provide that information to Mr. G. Smith at a later time. After the meeting between Ms. Moore and Officer Smith was completed, Mr. G. Smith drove Ms. Moore back to her vehicle that was parked at a different location. During the ride Ms. Moore advised Mr. G. Smith that she would tell him the location of the victim's body and that she also had possession of the firearm that killed the victim. A plan was then devised between Ms. Moore and Mr. G. Smith, that Mr. G. Smith along with Officer Smith would dig up the body of the victim and move it to a different location so that Officer Smith could then advise Law Enforcement where the body was located. It was further

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planned that Ms. Moore would give possession of the firearm used to kill the victim to Mr. G. Smith so it could be turned over to Law Enforcement to solidify the confession of Officer Smith.

On January 25, 2010, Ms. Moore contacted Mr. G. Smith and advised that she needed to meet with him. Mr. G. Smith then met with Ms. Moore in Lakeland, Florida. During the meeting Ms. Moore advised that she would be getting the firearm later in the day to turn over to him (G. Smith). It was also planned that she would take Mr. G. Smith to the location where the body of the victim was located.

Later in the day of January 25, 2010, Ms. Moore again met with Mr. G. Smith, this time at a location in Plant City, Florida. At thi s time Ms. Moore gave Mr. G. Smith a .38 Cal iber Srni th and Wesson Revolver (Serial Number DBU2414/642-2). During this meeting Ms. Moore advised that she would meet with Mr. G. Smith later in the day and take him to the location where the victim's body was buried.

Approximately two (2) hours later still on January 25, 2010, Ms. Moore again met with Mr. G. Smith in Plant City, Florida. Mr. G. Smith then got in to Ms. Moore's vehicle. Ms. Moore then drove Mr. G. Smith to 5802 Highway 60 in Plant City, Florida. Ms. Moore then showed Mr. G. Smith a 30' x 30' concrete slab (poured on 4/13/2009) located in a wooded area approximately 30 yards north of the residence on the property. Ms. Moore advised that the victim was buried beneath the concrete slab. Ms. Moore had previously parked a white Ford Truck with an attached utility trailer blocking view of the concrete slab from the roadway. Ms. Moore told Mr. G. Smi th to look inside the trailer. Mr. G. Smith looked in the trailer and observed several gallons of fuel, gallons of bleach, gloves, and a metal tub/trough. Ms. Moore advised Mr. G.Smith that after digging up the victim's body he could place the body in the tub/trough and transport it in the trailer. Ms. Moore then provided Mr. G. Smith with keys to the Ford Truck. Ms. Moore further advised that the victim had been killed in her office and pointed to the residence located at 5732 Highway 60, which is located directly to the west of the residence where the victim's body is buried.

On 01/26/2010, affiant along with co-affiant and members of both Hillsborough and Polk County Sheriff's Offices served two separate search warrants upon the said property of this warrant and the residence located at 5732 Highway 60 Plant City, Florida. A subsequent interview was conducted by affiant and Polk County Detective David Wallace, with David Howard Stitzel at his attorneys office in Brandon, being Patrick Courtney and Glen Lansky. David Howard Stitzel arrived at the crimescenes with his attorney Glen Lansky. Stitzel then traveled to their (Courtney and Lansky) law office for an interview, due to his own law practice office being wi thin a room contained wi thin the two-story brown in color

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residential structure at the physical address Plant City, Florida) being then searched.

(5802 Highway 60

During the interview of David Howard Stitzel, he stated to affiant and Detective David Wallace that he last physically saw the victim, Abraham Shakespeare sometime between April or May 2009 at his prior office location, 607 S. Alexander St. Plant City, Florida. Dorice (Dee Dee) Moore, became a client of Mr. Stitzel in late 2008. Mr. Stitzel proceeded to advise the alleged phone call supposedly made in the presence of Dee Dee Moore wherein he earlier claimed to have last heard from Shakespeare on October 6, 2009, could have been the victim or could have not been the victim. Mr. Stitzel stated he moved to the property located at 5732 Highway 60 Plant City, Florida temporarily, on ar about May 15th, 2009 to early June 2009. Upon completion of the renovation within the structure located at 5802 Highway 60 Plant City, Florida, Mr. Stitzel then moved in setting up office space for his practice. Sometime last week, being the third week of January, Mr. Stitzel along with his assistant/girlfriend Michelle Findley, observed Dee Dee Moore sitting at his computer, utilizing it within his office space in which he rents from her (Dee Dee Moore). Mr. Stitzel admits to preparing the document in which Judith Haggins signed as Power of At torney for Abraham Shakespeare, al though Ms. Moore and Ms. Haggins filed it at the Clerk of the Court on their own.

Mr. Stitzel had previously discussed with Polk Detectives D .

Wallace and D. Clark that he knew Abraham Shakespeare was the other person on the other end of the phone call because he knew his clients voice. Polk detectives later conducted a controlled phone call as previously mentioned. It was apparent based on the controlled phone, that Mr. Stitzel was aware Dee Dee Moore was in possession of his clients cellular telephone and purporting he

(Abraham Shakespeare) was alive and well, just missing on his own free will. Thus, transactions and later court appearances in Polk County on behalf of Abraham Shakespeare which were made by Mr. sti tzel are of a fraudulent nature and indicating his possible involvement and/or knowledge of the murder of Abraham Shakespeare. Certain files, transactions and legal documentation are believed to be in possession by Mr. Stitzel within his office at the mentioned location, and are believed to clarify his involvement with the disappearance and/or murder of Abraham Shakespeare.

On 01/27/2010, affiant along with Detective David Wallace of Polk County, conducted an interview with Judith Haggins (power of attorney for Abraham Shakespeare) at her attorneys office, being Larry Hardaway in Lakeland, Florida. Ms. Haggins stated Abraham Shakespeare asked her to be his power of attorney which was notarized and filed on 04/03/2009 with the Clerk of the court in Polk County. Before Abraham Shakespeare was noted as missing, Ms. Haggins noted Dee Dee Moore would embellish how serious Abraham Shakespeare's child support proceedings were, and would encourage

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him to move money within his various accounts in an attempt to protect it from the biological mother of his (Abraham Shakespeare) child. Ms. Haggins advised she would tell Abraham Shakespeare that his child support case was not as serious as Dee Dee Moore made it out to be. In 2009, at an unknown time frame, Ms. Haggins admi tted she was instructed by Dee Dee Moore to withdraw the remaining funds from some of Abraham Shakespeares bank accounts which totaled in her opinion, less than $2000. The money, in the form of cashiers checks, were then given to Dee Dee Moore.

On January 28, 2010, Detective Thomas of the Hillsborough County Sheriff's Office and Detective Wallace of the Polk County Sheriff's Office conducted an interview with Dee Dee Moore's exhusband, James Moore. Mr. Moore stated that Dee Dee Moore asked him to recommend the type of equipment to clear her land at 5802 Hwy. 60 Plant City, Florida. He suggested a tractor with attachments, however she purchased a Case Backhoe on April 3, 2009 at a Lakeland Auction. Dee Dee Moore paid James Moore approximately $100 to pick-up the backhoe and deliver the same to her property on highway 60, utilizing his family's flat bed trailer. Dee Dee Moore called James Moore during the first two weeks of April, 2009, and requested that he come to her property at 5802 Highway 60 and utilize the purchased Case backhoe to dig a hole for concrete and trash. James Moore stated that originally Dee Dee Moore asked the hole to be dug directly behind the rear door of 5732 Highway 60. However, James Moore suggested to not dig there due to the close proximity to the house, therefore Dee Dee Moore pointed out the location behind 5802 Highway 60 and directed him where to dig as well as how large of a hole. James Moore stated that he left after digging the hole. He was called by Dee Dee Moore 1 to 2 hours later to fill the hole in. James Moore stated it was getting dark and he did not see a body in the hole, but rather assumed it was chunks of concrete due to there being a lack of light and having dug previous holes on her property before. During interviews conducted with Dee Dee Moore on January 29 and 30, 2009, by Detectives Thomas and Wallace, she admitted having contacted James Moore to dig a hole for trash at a location behind the residence at 5802 Highway 60. She further admitted that the body 6f Abraham Shakespeare was buried in hole dug by James Moore.

However, she was adamant that James Moore did not know there was a body placed in the hole when he returned to fill it in.

On 01/28/2010, the remains of a human body were found at 5802 Highway 60 Plant City, Florida after extensive crimescene process by both Hillsborough and Polk County Sheriff's Offices. The remains were positively identified as Abraham Shakespeare. The body of Abraham Shakespeare was found at the precise location under the concrete slab that Dee Dee Moore personally showed to Gregory Smith.

Beginning on 01/29/2010, affiant and Detective David Wallace

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of Polk County, interviewed Dee Dee Moore, who initiated contact herself. Ms. Moore has provided several accounts of how Abraham Shakespeare was murdered to date, to include an unknown drug dealer named Ronald, herself in self-defense, Mr. Shakespeare's cousin Cedric Edom and finally her 14 year old son R.J. On 01/30/2010, Ms. Moore re-initiated contact with affiant and Polk County Detectives yet again. During this particular interview, Ms. Moore alleged David Stitzel shot the victim Abraham Shakespeare and helped to arrange his burial on her property. In all of these versions, Dee Dee Moore consistently told investigators that two shots were fired at Abraham Shakespeare. During the course of an autopsy conducted by Hillsborough County Medical Examiners Office, upon the body of Abraham Shakespeare, two projectiles were recovered from the victims body. Based on several interviews with Ms. Moore to date, and her statements of preparing a letter to the victims mother stating he was alive after 04/06/2009 as well as the continued text messages and financial transactions via the Power of Attorney, it is affiant's and co-affiant's belief that items of evidentiary value noted in the evidence to wit are to be contained within an office in the north east corner of 5802 Highway 60. This office is also utilized by Dee Dee Moore and is next to the office utilized by Mr. Stitzel.

Abraham Shakespeare was functionally illiterate and unsophisticated in financial matters. The investigation of the relationship between Mr. Shakespeare and Dee Dee Moore supports the conclusion that in the months prior to Abraham Shakespeare's death,

Dee Dee Moore conducted a series of ostensibly legal financial transactions with Mr. Shakespeare, which were designed to, and did, transfer the vast majority of the remainder of his cash, real property and intangible assets to her control, or to the control of her associates or entities controlled be her. By her own admission, Dee Dee Moore never paid Abraham Shakespeare for the $1.2 million dollar home that he deeded to her, or for the intangible assets that he transferred to her. The true, one-sided nature of these financial transactions provide the motive for the murder of Abraham Shakespeare. Some of these ostensibly legal financial transactions were conducted with the legal assistance of Attorney David Howard Sti tzel. Based on the investigation conducted to this point, investigators have reason to believe that a search of the residence at 5802 Highway 60 in Plant City, including the law office of David Howard Stitzel, will produce records pertaining to the financial relationships and financial transactions among Abraham Shakespeare, Dee Dee Moore, American Medical Professionals LLC, which is Ms. Moore's business, her boyfriend, Shar Krasniqi, Shakespeare and Associates LLC, Abraham Shakespeare LLC, and David Howard Stitzel. Based on the foregoing investigation, it is further anticipated that a search of this two-story residence shall reveal legal files, legal documents, legal memorandums and legal communications which shall comprise documentary evidence of the financial transactions

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which led to the transfer of Mr. Shakespeare's wealth and his ultimate death.

On 02/02/2010 at approximately 1750 hour, execution of a search warrant was completed and the listed evidence, being an eMachine central processing unit with a serial number of GCJ7A20000438 was collected. Affiant and co-affiant believe evidence of the listed offense as well as documentation and evidence pertaining to Dee Dee Moore, Abraham Shakespeare, Abraham Shakespeare LLC, and Shakespeare and Associates LLC are contained upon this computer. The Ativa thumb drive noted as inventory #520364 item #38 will be transported to FDLE for mirror imaging and copies will be properly forwarded per the Execution of Search Warrant and Preservation Privileges.

Refer to attached exhibit A.

EXECUTION OF SEARCH WARRANT AND PRESERVATION OF PRIVILEGES

To assure the preservation of any privilege attached to any legal file, document, memorandum or communication, these items shall be sealed immediately upon seizure without law enforcement inspection or review, except to the limited extent necessary to prepare the statutorily required inventory to the search warrant return. Mr. David Howard Stitzel shall be allowed, if he chooses, to prepare his own inventory of any legal files, documents, memorandums or communications seized pursuant to this warrant, prior to their removal from the premises.

Following the seizure and sealing of any legal files, documents, memorandum or communications, Hillsborough County Sheriff's office shall deliver the sealed items to an independent commercial copying business for the reproduction and pagination of these items within three working days. At the completion of the copying and pagination the seized legal items shall be sealed and the originals of all seized legal documents, except those related to Abraham Shakespeare, Dee Dee Moore, Abraham Shakespeare LLC, Shakespeare and Associates LLC, and Shar Krasniqi shall be returned to Mr. David Howard Stitzel. The copies shall be sealed and returned, without law enforcement review, to the secure property/evidence section of the Hillsborough County Sheriff's Office.

All copies of legal files, documents memorandum and communications made pursuant to this warrant shall be submitted for in camera judicial inspection and review prior to unsealing for review to law enforcement investigation.

Electronic data containing legal files, documents, memorandums or communications shall be copied by the Florida Department of

Law Enforcement and sealed without inspection or review prior to investigations.

Electronic data seized pursuant to this warrant shall be reviewed in camera in accordance with those procedures applicable to documentary evidence.

Based on the aforementioned information detailing the financial documentation as well as legal documentation prepared and filed, affiant and co-affiant believe evidence of the Murder will be located upon the property.

WHEREOF, affiant makes this affidavit and prays the issuance of a search warrant in due form of law for the search of the above described premises for the said property, heretofore described, and for the seizure and safe keeping ~hereof, ubject to the order of this Honor Ie Cour , ~~he d 1 i u ed officers of the law.

Sworn to and subs AD, 20~O.

Judge

SEARCH WARRANT

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

IN THE NAME OF THE STATE OF FLORIDA:

TO: THE SHERIFF OF HILLSBOROUGH COUNTY, FLORIDA, AND/OR ANY OF HIS LAWFUL DEPUTIES:

WHE complaint on oath and in writing, supported by

affidavit een m~~~~re me the undersigned

HONORABLE ~~~ IRCUIT COURT JUDGE THIRTEENTH

JUDICIAL CIRCUIT in and for tHe Hillsborough County, Florida, by Detective Greg Thomas, Hillsborough County Sheriff's Office and Detective Chris Lynn, Polk County Sheriff's Office.

The affiant and co-affiant have reason to believe and do believe certain computer equipment located in Hillsborough County, Florida, described as follows, to-wit:

SEE ATTACHED EXHIBIT "AI' WHICH IS HEREBY INCORPORATED BY

REFERENCE AND MADE A PART HEREOF

and there is now being kept within said computer equipment certain evidence of criminal activity including but not limited to computer equipment, computer programs, computer storage devices, to include but not limited to CDs, removable drives, thumb drives, pen drives, removable secure storage devices, graphic files, and any other media that can store digital files and/or digital media. Phone records, records of Internet Service Providers, E-mails and other computer data, including but not limited to encryption, passwords telephone numbers, Emails, Instant messages, computer images, computer programs and system documentation; documents files or any other computer data relating to encryption, passwords, and/or access to or ownership of the computer and Internet Service Provider, documentation used in violation of the laws of the State of Florida to-'wit: law prohibiting, F.S.S. 782.04 Murder

and there is now being kept on said premises certain

Physical Evidence: Ativa thumb drive, used in violations of laws of the State of Florida, to-wit:

It will become necessary for reasons of practicality to remove

the hardware and conduct a search off-site. Your affiant and co-

affiant believe that, in this case, the computer hardware is a

24

container for evidence, a container for contraband, and also

itself an instrumentality of the crime under investigation.

That the facts tending to establish the grounds for this application and the probable cause of affiant believing that such facts exist are contained in an AFFIDAVIT FOR SEARCH WARRANT, sworn to before me on this date by Detective Greg Thomas and Detective Chris Lynn.

And it appears to the Court that the affiant is a reputable deputies of Hillsborough County and Polk County, State of Florida, and that the facts set forth in said affidavit show and constitute probable cause for the issuance of this warrant and the Court being satisfied of the existence of said grounds set forth in said application, or that there is probable cause to believe in their existence.

NOW THEREFORE, you are commanded with such proper and necessary assistance as may be necessary, in the day-time or in the nighttime, or on Sunday, as the exigencies of the occasion may demand or require, to enter and search the aforesaid computer equipment, described but not limited to hard drives, zip drives, thumb drives, pen drives, CDs, for the property described in this warrant: and if the same or any part thereof be found, you are hereby authorized to seize and secure same, giving proper receipt therefore and delivering a duplicate copy on said computer equipment to the said WHITE MALE KNOWN AS DAVID HOWARD STITZEL AND ANY, JOHN OR JANE DOE WHOSE NAMES ARE UNKNOWN TO YOUR AFFIANT or any other person or persons, and by making a return of your doings under this warrant within ten (10) days of the date hereof, and you are further directed to bring said property so found before any County and/or Circuit Judge having jurisdiction of this offense to be disposed 6f according to law.

Further, you are commanded to search the property seized and the contents of same using such technology as may be necessary, performing such search at such locations and with such specialized personnel as may be appropriate, in order to obtain any relevant evidence of the felony crimes noted herein.

WITNESS my ~ y Of~L(2010.

l

Judge

or Hillsborough County, Florida

25

Exhibit A

An Ativa thumb drive, located at 2316 Falkenburg Rd. Tampa, Fl 33619 within Hillsborough County. This item is noted as item #38, inventory # 520364 under case # 10-42631 .

~~!!:. ~

I

INVENTORY AND RECEIPT OF PROPERTY SEIZED UNDER THE WITHIN SEARCH WARRANT

TYPE OF ITEM

This

~ day Of_-¥M~~~-=--f--_.-J.A.D ..• 20/Q

/ RETURN

LOCATION FOUND

FOUND BY

STATE OF FLORIDA

COUNTY OF HILLSBOROUGH:

Re.cei"'_'i the within search warrant on the ~ ~1 ~ ,A.D.,20IQand execut.,ed the

same In Hillsborough County, Florida, on th~~ 01 ' , A.D, 2019 by searching the

premises described herein and by taking into my custody and possession e following described property, to-wit:

SEE ABOVE USTED INVENTORY

And [further executed the said warrant by arrestin;.b--7r-_I'i::...,T.'- J J,~ __ -_-ri-_-==- ~

and by delivering a dUPlicate. copy of this warrant to]!ilrC o.c- ~

and by making and delivering to the said!...- __ ...Jt!:....'-'-:s.&_.:!.~~~tJP=:l- :;:___...!:~~~~ -4

a true inventory of the above described property.

Officer

I, Jq: {;'. ~'V'A£ ~ 16S- the officer by whom the foregoing warrant was executed, do swear the above inventory

conuuns a true tkd detailed account of oil property ~e~ ~~. ant. ....

~/Z ,

me,,5£r E kfJ1tc-I(f{;lRY

3050 Rev. 7/05

J Notary Public, State of Florida

My commission erpiresi.l1iVMW L'e tJl!l/J!;20 ID,

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA IN AND FOR HILLSBOROUGH COUNTY CRIMINAL JUSTICE DIVISION

STATE OF FLORIDA

H.C.S.O CASE NO.: 20l0-42631

VS

JOHN DOE OR JANE DOE

PETITION TO SEAL SEARCH WARRANT AND RELATED DOCUMENTS

COMES NOW THE STATE OF FLORIDA by and through the undersigned Assistant

State Attorney pursuant to Florida Rule of Judicial Administration 2.420 and

move this Honorable Court to enter an order sealing the search warrants and

related documents described below from public inspection until the release of

the discovery to the defense (upon request) or until further order of this

Court, and would show in support as follows:

1)

Abraham Shakespeare, D.O.B. 4/23/66, was last confirmed to be

alive on, or about, April 6, 2009. Information obtained during

the investigations conducted by members of the Polk and

Hillsborough County Sheriff's Offices support the conclusion that

Mr. Shakespeare's disappearance was the result of foul play.

2) The body of Abraham Shakespeare was recovered from its burial

3)

site under a concrete slab located behind the two story residence located at 5802 State Road 60 in Plant Cit~ (

On February ~~ 2010, the Honorable Judge Kot>enr~~

Issued search warrants, which authorized the search of property

and structures located at 5802 State Road 60 in Plant City and

5732 State Road 60 in Plant City. During the execution of these

search warrants computer hardware was found described as "an

Ativa thumb drive, located at 2316 Falkenburg Rd., Tampa, Fl

33619 within Hillsborough County, Item is noted as item #38,

Page 1 of 3

inventory #520364 under case #10-42631".

The affidavit in support of the search warrant set forth facts and interviews learned and obtained during the course of the ongoing investigation into the disappearance of Abraham Shakespeare.

5) The search warrants and related documents contain sensitive and/or

4)

confidential information that is part of an ongoing investigation. The continued confidentiality until release of the discovery to the defense is required to:

a. Prevent a serious and imminent threat to the fair, impartial and orderly administration of justice, or

b. Protect a compelling governmental interest; or

c. Avoid substantial injury to an innocent third party.

6) There are no less restrictive measures available to protect the interests of law enforcement, the ongoing investigation or the safety of the third party.

7) The motion and order to seal this search warrant and related documents will not be sealed and will be filed with the Clerk's office.

8) The need for confidentiality will only continue until the discovery is released.

9) The warrant, affidavit and attached exhibits have been filed with the Clerk of the Circuit Court.

Wherefore, the State of Florida moves this Honorable court to Seal the Search Warrant and Related Documents.

Page 2 of 3

I HEREBY CERTIFY that a true and correct copy of the foregoing Motion and Order will be furnished to the Clerk of the 13th Judicial Court, this ~day

of February, 2010.

Respectfully submitted,

MARK A. OBER

~=Y ~~ER

ASSISTANT STATE ATTORNEY FLORIDA BAR# 559415

JP/als

~.I========------------===============

Page 3 of 3

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA IN AND FOR HILLSBOROUGH COUNTY CRIMINAL JUSTICE DIVISION

STATE OF FLORIDA

H.C.S.O. CASE NO.: 2010-42631

VS

JOHN DOE OR JANE DOE

ORDER

THIS CAUSE having come on to be heard and the Court being fully

advised in the premises, it is hereby

ORDERED AND ADJUDGED that the Motion to Seal Search Warrant,

attached exhibits and related documents pertaining to the computer hardware

described as "an Ativa thumb drive, located at 2316 Falkenburg Rd., Tampa, Fl

33619 within Hillsborough County, Item is noted as item #38, inventory

#520364 under case #10-42631" is granted and that the Clerk of the 13th

Judicial Circuit is ordered to prevent the release of these documents to the

public until the release of the discovery to the defense (upon request) or

until further order of this Court.

~ DONE AND ORDERED in Court this .£ day of February, 2010.

at Tampa, Hillsborough County, Florida,

CIRCUIT COURT JUDGE THIRTEENTH JUDICIAL CIRCUIT HILLSBOROUGH COUNTY, FLORIDA

lals

1Ir---~====~~~~~~===========

l.:.,ttt'f I

AFFIDAVIT

FOR SEARCH WARRANT

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

STATE OF FLORIDA ~~

COUNTY OF HILLSBOROUGH i ) r .. .. ",-,-._ ... l. "-

BEFORE ME, HONORABLE, ~ O?L)'Z:t lJt 1L~ ~fc1Z_S~ CIRCUIT COURT JUDGE, THIRTEENTH JUDICIAL CIRCUIT , in and for Hillsborough County, Florida, personally came affiant Detective Greg Thomas, Hillsborough County Sheriff's Office and co-affiant Detective Christopher Lynn, Polk County Sheriff's Office being first duly sworn, deposes and says: That affiant and co-affiant are reputable Deputies of said Hillsborough County and Polk County, State of Florida, and that they have reason to believe and do believe that those certain premises located in Hillsborough County, Florida, described as follows, to-wit:

Property located at 5802 Highway 60, plant City, HILLSBOROUGH COUNTY, FLORIDA with a two-story residential structure, tan and brown brick in color with a white front door and a balcony on the west side. The residential structure includes the law office of David Howard Stitzel. A sign is located at the front of the property depicting the physical location of the property.

THIS WARRANT IS TO INCLUDE OR UNDER THE CONTROL OF THE OCCUPANTS OF THE

AFOREMENTIONED RESIDENCE, AND ANY PERSON ON SAID PREMISES.

being the premises occupied by or under the control of

WHITE MALE, DAVID HOWARD STITZEL D.O.B. 03/04/1964 AND WHITE FEMALE, DORICE MOORE D.O.B. 07/25/1972, WHITE MALE, SHAR KRASNIQI D.O.B. 05/01/1983 AND ANY OTHER··UNKOWN·NAMES

Physical Evidence:

Your affiant and co-affiant know that computer hardware, software, electronic files and Handwritten notes/paper files pertaining to Dorice Moore, Abraham Shakespeare, Abraham Shakespeare LLC., Shakespeare and Associates LLC., and American Medical Professionals LLC., may be important to a criminal investigation in two distinct ways: (1) the obj ects themselves may be contraband, evidence, instrumentalities, or fruits of crime, and/or (2) the objects may be used as storage devices that contain contraband, evidence, instrumentalities, or fruits of crime in the form of electronic

~. __ ._. ._:~:~ __ ~_: .. _.~~.~: __ .~.~s ~ .. _:~: __ ~~r::~:~~~.~_~~i~~_ .. ~.~::_s_~: ~_~~:~:~o_:_ ~.:_ . _ .

1

search and seize computers, computer storage devices, electronic storage devices, credit card numbers, checking account numbers, CDs, tapes, Phone books, phone registers, journals, address books, legal files, legal documents including but not limited to an assets purchase agreement with addendum, property deeds, Quitclaim deeds, contracts, mortgages and power (s) of attorney, legal communications or legal memorandums, computer files, computer data, Emails and other computer data, including but not limited to encryption, passwords computer print outs relating to on-line Internet Service, computer software, computer programs and applications, computer manuals and system documentation; notes, writings, or computer data relating to documentation used in violations of laws of the State of Florida, to-wit: 782.04 Murder

It will become necessary for reasons of practicality to remove

the hardware and conduct a search off-site. Your affiant and co-

affiant believe that, in this case, the computer hardware is a

container for evidence, a container for contraband, and also

itself an instrumentality of the crime under investigation .

That the facts tending to establish the grounds for this application and the probable cause of affiant believing that such facts exist are as follows:

The affiant Greg Thomas, a Detective of the Hillsborough County Sheriff's Office being sworn states:

1. Your affiant is an Investigative Law Enforcement Officer as defined in Florida State Statute 934.02, and is making this application pursuant to my official duties.

2. Your affiant is authorized to do so by the Honorable Mark Ober, State Attorney for the Thirteenth Judicial Circuit, Hillsborough County, Florida, pursuant to the authority conferred upon him by F.S.S. 934.07.

3. That the affiant is a member of the Hillsborough County Sheriff's Office and has been so employed since October 2000. Your affiant has been assigned to the Criminal Investigations Division as a Detective since August, 2003. Your affiant has been a participant in the execution of numerous Search Warrants.

The co-affiant Christopher Lynn, a Detective of the Polk

~. ~:~.~ __ ~_~~~~~~'~~_~~~_~_~~:_~ __ ~~_~ng swor~.~ _.~~e c_~ ~_a~_~_~_a~_~_~as been

2

employed with the Polk County Sheriff's Office since July of 2002.

Your co-affiant has been assigned to the CID as a Detective for approximately 3 1/2 years. Your co-affiant has been a participant in the execution of numerous Search Warrants.

Abraham Shakespeare won $31 million in the Florida lottery.

Shakespeare elected the lump sum payout and collected approximately $12.7 million after taxes. Shakespeare was sued by a co-worker who made claim to the winning ticket. Ultimately the court ruled in the favor of Shakespeare in 2007.

Between winning the lottery in 2006 and meeting Dee Dee Moore In 2008, Mr. Shakespeare spent, gave away or loaned the majority of his winnings and was left with approximately $1.5 million in cash and assets totaling approximately $3 million. Shakespeare utilized several financial institutions, seemingly one after another on the whim of various advisors: fromWachovia, along with various Annuity holdings, to Community Bank and eventually to Bank of America. Mr. Shakespeare did not invest heavily and was reported to be unimpressed with annuities to the point of pulling all of his money out and using the money to seed accounts accessed by Dee Dee Moore.

In December of 2008, Mr. Shakespeare liquidated an annuities account worth approximately $250K. In January 2009, this money was transferred to the business account of American Medical Professionals, a business owned by Dee Dee Moore since 2004. In her interviews, Ms. Moore stated this money was provided to her for the purposes of paying taxes on behalf of Shakespeare. This money was tracked to several recipients including Ms. Moore's boyfriend, Shar Krasniqi, and Real Time Services, American Medical Professionals' payroll and accounting service. Additionally, a review of bank statements of American Medical Professionals and accounts related to Dee Dee Moore has shown that Moore utilized the American Medical Professionals checking account including personal charges. Any

3

personal accounts minimal activity. these funds having Shakespeare.

of Dee Dee Moore that have been located have Investigation has not revealed any records of been used to pay any tax debt of Abraham

Land Transfers

On January 9th, 2009, Mr. Shakespeare signed a Quitclaim Deed to American Medical Professionals LLC on his primary residence, 9340 Redhawk Bend Drive. The deed was recorded on 01-13-09. Abraham Shakespeare paid $1.07 Million in 2007 for the horne, and Dee Dee Moore, in a statement given to Polk County Sheriff's detectives on or about November 9, 2009, stated she paid him over $500,000 in cash. In a subsequent statement given to Polk Sheriff's Detectives on January 25, 2010, Ms. Moore stated that she had not paid Abraham Shakespeare because Shakespeare had a drug problem and she felt that he would use it to buy drugs. In a statement given to detectives on January 29, 2010, Ms. Moore stated that

• she had not paid Abraham Shakespeare because he did not want to pay the gift tax owed on the amount. A review of Dorice (Dee Dee) Moore's bank records has not revealed corresponding withdrawals, checks, or transfers indicating payment for the home, to date.

After receiving his lottery winnings, Abraham Shakespeare made multiple loans to individuals to buy homes and recorded mortgages documenting the loans. On January 11, 2009, Mr. Shakespeare signed Quitclaim Deeds to American Medical Professionals, LLC for

properties located at 1418 West Lake Parker Drive, Lakeland, Florida and 409 Pearl Street, Lake Hamilton, Flarida. Each deed was recorded on 02-11-09.

On January 15, 2009, Mr. Shakespeare signed an "Asset Purchase Agreement" which sold all of his un-enumerated "assets" to American Medical Professionals LLC for the price of $185,000. The

value of outstanding loans purchase in the "Assets Purchase ~---------------------------

4

L _