133HS GHOVALY wi 04819 1 a.aatfap Koc) ‘2xOge UeUT IUB:EUHP 31 Kuo aayduto-y uno nasty 30-4319 01, toy suonsesuesy, ayu0n29]3 Hosur aun UF poutjap saanpadoad Aaunaas/Buyy Jo a5n ANVUUVM HOUVS YOU LIAVGLAYnT peer ape ee sous az! i CGT) CV OFS6 2G sey = “AEP Iq aw a4oyaq o1 wOMs pue paquosqng 106 2 ERS easee “Hea Paw a8palmoury Au yo 15aq ayn 01 aresnaoe pu ann axe axage siuawiatels 24 quewypeny veg 2) 248 wos pauruuarap aq Seu papiroud uoneuzoyur a4p 0 4 01 worewojuy Hosted JOU}10 AJ0WW J0 240 Aq “Zed U! 40 ajoyNs ye JO pasiape sem | X BOLANY epUse SN U OH 12s Soe a j0 a8pa] mou feUOSIod anny | XX “9 “2sualJ0 Yons Jo uoyssturtu09 241 Jo 2oupiAa Se¥MIsuoD 40g payssees uosiad 10 # spalgo ay, 's weuyoeny 2g a" eu 39 prnoys yous aa wun asm aygegoud Busmmsuod sion ouatew au“605 East Nine Mile Road, Highland Springs, Virginia Section 3, Any and all digital devices capable of creating, storing, Scanning, sending, receiving and transmitting documents; to include, but not limited to, fax machines, computers, 3-in-1 copy machines and printers with storage capabilities, Based on your affiant’s Knowledge and experience, your affiant knows that the majority of digital devices are capable of creating, storing, scanning, sending, receiving, and/or {transmitting documents to and from each other. For example, a document can be created on one digital device, stored and scanned on a second device, and stored and transmitted on a third, Your affiant further knows that documents can be stored, physically or wirelessly, on multiple devices. Any and all documents, to include, but not limited to the original DE#1, related to commission of the crimes listed in reference to DE#1, Section 4. Your affiant respectfully requests the issuance of a search warrant for the stated law office to further investigate criminal allegations ofa fraud that was perpetrated on the Court, in the Henrico County Circuit Court, on December 12, 2014, On that date, Delegate Joseph Morrissey, through his legal defense team, offered a forged and fraudulent document into the court record as official evidence, The Your affiant obtained a copy of the Morrissey “Defendant Exhibit #1” from the Henrico County Circuit Court Clerk's Office (see attached) and found obvious irregularities with the document, to include the ‘ed stamping that would be normally associated with605 East Nine Mile Road, Highland Springs, Virginia these persons. There are no documents in any of those files that even resemble page two of the Morrissey Defendant Exhibit #1. Details of the Investigation into the Fraud upon the Court On December 12, 2014, your affiant, Detective C.A. Kelley, was present when Delegate Joseph Dee Morrissey entered an “Alford” plea and was found guilty of contributing to the delinquency of a minor. As part of his plea, Delegate Morrissey, acknowledged that the Commonwealth's evidence of his sexual relationship with a seventeen year-old female employee of his law firm would have likely led to his ion, had he gone to trial Delegate Morrissey was present at this hearing, accompanied by Ward Armstrong, Anthony “Tony” Troy, and James Maloney, three attorneys of his seven member legal defense team. Judge J. Martin Bass interviewed Delegate Morrissey about his “Alford” plea before accepting it when Judge Bass was satisfied that Delegate Morrissey understood what his plea entailed, The prosecution and defense agreed to allow their written stipulations in the signed plea agreement stand as their version of events for the record, and the defense was granted permission to call two witnesses to testify. The first defense witness was Deidre Warren, the mother of the juvenile victim in Delegate Morrissey's criminal case. Defense Attorney James Maloney conducted the direct examination of Ms. Warren which led to the following exchange, quoted from the trial transcript (made by Crane-Snead & Associates.) @ When the two of you split, did a Juvenile Domestic Relations District Court in Chesterfield County enter an order with respect to support? Yes Was that an order that you all made? Yes You reached an agreement and then presented it to the Court? Correct. He requested the Court enter it, as did you? Yes. What did that order call for with respect to his support obligation for Myrna? Dror O>Oy At this point, Special Prosecutor, William Neely, objected to the relevance of the line of questioning and said that he had not seen the arder that Maloney was referring to. Mr, Maloney produced a two-page document that was briefly shown to Mr. Neely prior to being accepted by the court as “Defendant Exhibit #1". (Referred to also in this document as “DEH1”. See attached two-page copy) Judge Bass overruled the objection and Mr. Neely withdrew his objection toward the use of the two-page document.605 East Nine Mile Road, Highland Springs, Virginia Mr. Maloney then began questioning Ms. Warren about the Order that ‘had just been entered and what it said. & What was your understanding, what does that order say? A Be order was about hin contributing $50 a week, and Chere a ne daughters at the tine, Myrna, and ay daughter, Shzjetina, and he was supposed to deposit $50 a ween each, account towards their college fund Q And were those deposits to be made specifically for college education? A Correct. Pages 17-22 of the hearing’s official transcript capture Mr. Maloney questioning Ms. Warren about the financial agreement contained in DEt1 and events that took place related to Mr. Pride's failure to live up to the conditions stated in that document, When the Delegate Morrissey’s plea hearing was over, Coleman Pride found Detective C.A. Kelley (your Affiant) and insisted that the document that was entered as DEH was fraudulent and that he had never signed any such agreement, After Delegate Morrissey was found guilty, and the evidence was retained by the court clerk, Mr, Pride obtained a copy of DEH1 from the Henrico County Circuit Court Clerk's office. Mr. Pride then visited the OR Cler’s office and requested thatthe clerk's office personnel search for any evidence in their files of the two-page DE#1. Chesterfield JOR employee, Bernadette Johnson located a three-page Consent Order that Mr. Pride and Ms, Warren had signed, along with theis mediator, on August 29, 2006. The first page of that document, identified at the bottom as “page 1 of 3" was identical to the first page of DEH. Ms. Johnson told Mr. Pride that she was unable to locate any paper in the files that resembled the second page of DEW1, Coleman Pride examined the signature, purported to be his, on the second page of DE#1 and recognized that it was a forgery. Mr. Pride contacted Detective Kelley and reiterated that DE#, the document entered into evidence by Delegate Morrissey, through his legal defense team, was fraudulent.605 East Nine Mile Road, Highland Springs, Virginia Detective Kelley obtained his own copy of DEI from the Henrico Circuit Court Clerks office and a copy of the August 29, 2006 Consent Order from the JOR Clerk's office. Detective Kelley noted numerous irregularities in DEM that supported Mr. Pride's assertion that the document was a fake and contained @ forgery of his signature. Detective Kelley met with Jennifer Jones, a supervisor in the JDR clerk's office, and asked for access to all of the court's files for Coleman Pride, Deidre Warren, Christina Pride, and Myrna Pride, in order to Search, personally, for an original version of DE#2. Detective Kelley examined each page of al four folders that were provided by Ms. Jones. There was no original document of DEM in any of the folders. ‘Ms. Jones examined the two-page document, referred to here as DE#1, and identified several irregularities that would cause her to believe that DE#1 was not a legitimate Consent Order from the JDR's files. One of the primary concerns Ms. Jones had was that the first page of DEH isan identical Copy of the first page of a three page Consent Order from August 29, 2006, that isin the court files, but the three page Order is not regarding Child Support (see attached copy). Another significant “red flag” about the second page of DEH! is that there is no Judge's signature or Mediator’s signature on the Signature page, nor are there spaces designated for those signatures. There are no ink stamps from the Chesterfield JOR that would show that it was a certified copy. Another obvious irregularity with the Second page of DEHZ is that there is no “Page _of_” at the bottom of the second and final page, although page one has “Page 1 of 3” printed at the bottom of it The glaring discrepancies listed in the previous paragraph, in conjunction with the other abnormalities listed in the attachment referenced above, and the complete absence of an original document in the Chesterfield JDR’s files, led Detective Kelley to conclude that DEH is certainly a fraudulent document, and that a fraud was perpetrated on the court when Delegate Morrissey presented that document ae evidence at his hearing through his attorney, James Maloney, Request to Search Particular Locations: ‘our affiant has thoroughly examined DEM1 (See attached copy of the two-page document) and knows the following about DEH to be true: 21), Both pages ofthe document contain a fax machine “header” that indicate that they were faxed from “Canfield Baer LLP” 2), Sherri Thaxton, the attorney that sent Coleman Pride the letter threatening legal action in April 2014, works at Canfield Baer and used Canfield Baer letterhead in several letters that Mr. Pride received from Ms. Thaxton, 3) Your affiant met with Sherri Thaxton at her office, which is located at 2201 Libbie Avenue Suite 200, the same address that is listed on the Canfield Baer letterhead from Ms. Thaxton’s letters to Mr. Pride.605 East Nine Mile Road, Highland Springs, Virginia 4) Inthe “to” portion ofthe fax header, on DEH, one page shows “7371671” and the other page shows “80473716711804737167". Your affiant recognizes those numbers as variants of a Phone number, 5) An open source public records search of "804-737-1671", reveals that number to be a “fax” ‘machine number that is listed for Joseph Mortissey's Law office, located at 605 East Nine Mile Road, in Highland Springs, VA. ©) Utlizing a law enforcement tool, a search conducted of “804-737-1671” reveals that number to be a fax machine number for Joseph Morrissey’s Law office, located at 605 East Nine Mile Road, in Highland Springs, VA. 7), The date listed in the fax header indicates that both pages of DEH were faxed from Canfield Baer to Joseph Morrissey’s law office fax machine on 05/07/2014 in what appear to be separate transmissions, eight minutes apart. Deidre Warren and Myrna Pride acknowledged to your affiant and other Henrico Detectives in an interview that they met with Delegate Morrissey and several of his attorneys in as early as September 2013, shortly after Mr. Morrssey's criminal activity with Myrna Pride was brought to the attention of ‘the Henrico Police, Ms. Warren and Ms. Pride said that Sherri Thaxton was with them at that meeting, representing Myrna’s interests, Throughout the investigation into Delegate Morrissey criminal behavior with Ms. Pride, Ms Warren and Ms. Pride have been staunch defenders of Delegate Morrissey to the police and to the public, ‘through various media events and'statement releases. Ms, Warren, as referenced above in the court transcript, testified for the defense even after Mr. Morrissey’ “Alford” plea acknowledged that the evidence would have been sufficient to convice him without his plea Conclusion Coleman Pride told Detective Kelley that he saw Delegate Morrissey hand DE#3 to James Maloney, just Prior to Mr. Maloney introducing the document as “Defendant Exhibit #1”. Detective Kelley observed ames Maloney introduce DEH and heard the judge accept the two-page document into evidence Det. Kelley witnessed how Mr. Maloney questioned Ms, Warren for several minutes about the Child Support information that is contained on the second page of the document. Detective Kelley heard Ms, Wereeg testify about the document, purporting it to be an actual Court Order from Chesterfield JOR. Det Kelley 'S now aware that the first page of DE#1 isa page from a legitimate Consent Order, but one that had nothing to do with Child Support, The use of that first page was apparently an effort to provide the ahpsarance of legitimacy to the completely fabricated second page of DE#1 that deals only with Child Support. ‘our Affiant believes that the evidence from the fax header on both pages of DEM, provides probable ‘ause that this fraudulent document that Delegate Morrissey submitted as “evidence” through his605 East Nine Mile Road, Highland Springs, Virginia The information contained on DEM, taken at face value, as wel as the letter sent to Mr. Pride, shows that Sherri Thaxton possessed a copy of DEM! as early as April 2014, ‘The fax header on DE#1 further Shows that both pages of DE#1 were faxed from Ms, Thaxton’s office, to Joseph Morrissey’s law office in May 2014. The defense team present in the courtroom on December 12, 2014, comprised of Ward Armstrong, Anthony “Tony” Troy, lames Maloney, and the defendant, Joseph Morrissey, have over 100 years of collective legal experience. The defense offered DE#1 as one of only two exhibits at Delegate Morrissey’s Plea Hearing and DE#1 is only two-pages long. lames Maloney, after introducing DEW1, spent Several minutes examining Ms. Warren under oath about the contents of DEH. Your affiant, knowledge and experience, knows that it would be improbable that Deidre Warren would have been able to perpetrate this fraud upon the court alon ant respectfully requests the issuance of a search warrant for the listed law office to search for lence ofthe source ofthis document, the identities of those who created it, who were aware of the intent to use it, and those who otherwise participated its use to perpetrate » “Fraud” upon the Henrico County Circuit Court Section 5, Your Affiant, Detective C.A Kelley, has been a Henrico County Police Officer for over 21 years, Fifteen of those years have been spent investigating a variety of criminal activity, to include, but not limited to, nercollcs violations, sexual assaults, malicious woundings, and homicides, in the course of his career, Your affiant requested and was granted search warrants to locate various types of evidence. These Search warrants led to the discovery of crucial evidence in many cases that led to numerous felony convictions, ant in that case, Mr. Pride told Det. Kelley specific information ence in this investigation, which Det. Kelley was able to corroborate through independent investigation,sey 605 East Nine Mile Road, Highland Springs, Virginia this case that enabled Det. Kelley to determin 'e that the document “questioned” in Section 4, was not a part of that court document referenced S file for Mr. Coleman Pride and Ms, Dek idre Warren. THUCHEY 2, 2os- 9s fur Mille ©. (Lalla ae We aan ca. Kay gedae OB UANEUELU BARE Le e To TaTtert a ae 19.17 W861 9, coz/003 VIRGINIA INTHE JUVENILE AND DOMESTIC RELATIONS DISTRICT COURT a OF CHESTERFIELD COUNTY CONSENT ORDER PURSUANT FO MEMORANDUM OF AGREEMENT ‘Name of Children Soc Sec. No Date of Birth Case Ghiristinia, et 46002 03/28/91 190§725%:01.04-02:01 yi E3301 03006 2 It OPSubitatiat fall his, Memorceitunp ofr ‘hadibis.agresmend so-reviewed bape We by WU parties this mediated Apreemant witt be submitted to the eonere~#CANETELD BAER LLP e To:80473716711804737167 a 10:08 mg80 P, coa/o03 respective savings accounts, August 29, 2006 Deidre’ Warren and Coleman Pride. agree that the father shall provide financial ‘support for their two children, Christina Pride and Myrna Pride according to the following: ‘The father agrees that he shall deposit $50 per week, per child, into their i | ‘The father agrees that he shall assist with expenses assosiated with the children’s clothing, public school expenses and other incidentals, ‘Name Date7 ‘VIRGINIA IN THE JUVENILE AND DOMESTIC RELATIONS DISTRICT court OF CHESTERFIELD COUNTY CONSENT ORDER PURSUANT TO MEMORANDUM OF AGREEMENT Inte: ‘Name of Children Soc. Sec, No. Date of Birth Case # 1 Christina Pride 449-6209, 03/28/91 313057258-01-01-02-01 2 Myrna Pride S#4 94-3301 03/20/96 319057259-01-01-02-01 3 4 5 Mediation Date: 08/29/06 Court Date: 10/25/06 Judge: HUB Mother Father Petitioner: Deidre’ Warren Respondent: Coleman Pride Address: 909 69th Avenue Address; 2963 Blendwell Road Philadelphia, PA 19126 Richmond, VA 23224 Phone #: 804-651-1996 Phone #: 804-421-0212 DOB: 05/20/63 DoB: 06/05/64 SS. t48#85759 SS. #: 88084466 Driver's License #: . PA 29-032-657 Driver's License #: N/A (itditterent fom $8 #) (Gt diterent from 8S #) custody and visitation, We, the undersigned parties, hereby agree that our Settlement, outlined in the "Terms and Conditions" below, is am accurate reflection of our resolution, ‘We agree that the terms and conditions set forth here are the result of substantial full disclosure of all relevant property and financial information. Once signed by all parties this mediated. Agreement will be submitted to the court. Page 1 of 3TERMS AND CONDITIONS CUSTODY: Deidre’ Warren (mother) and Coleman Pride (father) agree that the mother shall have sole physical custody of their daughters Christina Pride and Myrna Pride. Both parents also agree that they shall have joint legal custody of their children and shall share in making all major decisions regarding their upbringing and care, VISITATION: Both parents agree that they shall negotiate the children's time with their father on an open and liberal basis including on holidays, birthdays and other special days, Both parents agree that neither shall be denied access to the children's academic and ‘mother agrees that she shall initiate procedures with the children’s schools and medical facilit release of any records and information to the father. Page 2 of 3Both parties acknowledge that in wccordance with VA Code 20-124.6, neither parent, regardless of Whether such parent has custody, shall be denied access to academic, medical, hospital or other health records of that parent's minor child, unless otherwise provided in this order. Each party agrees that should they intend to move to another. location, they shall give thirty days advance writen notice of such change of address to the Court and to the ‘other party. The notice shall qatiain the child's full nume, the party's new telephone number, new street address and, if different, the party's new mailing address, The notice shall be mailed by first-class or delivered to the court and to the other party. 7 QQyHilbrw. Sxl hy ¥29 fog Petioner Bate Respondent Date WITNESS: Sell ad — 8749/06 (] Mediior Date Waiaior Dae IT IS SO ORDERED. enrer:_SEP 2 0/2006 Me. a de ve (CHESTERFIELD JUVEN & DOMESTIC Ea uct Lense Sa SESE Emir, yy) OMe 7 “Niucditgaeteasehetes etme Page 3 of 3 AO Oe / erage aut med Date: Fz Initials Ee