Putin wants Media help against terrorism, but ignores Human Rights abuse!

Welcome to Texas!

Keller Iglesias

I don’t like P.R.

I don’t like B.S.

That’s why

I like Texas

Got plenty of both

But there’s an antidote

Called a free people and a

Free press

Texas bad one,

Well, yes, I street race

Driving that car

Is a girl with a pretty face

Hiding down the block is a

Motorcycle cop

With his motor cycle cop clock

Ready for a ready chase (smile on his face)

Real men love Jesus and

True Love Waits and

Drive too close I’ll flick a booger in your face!

You can drive an old truck

Cadillac or a Lexus

Welcome to Texas!

Texas to me

Is a margarita and a slow dance

Least ya feel

Like you might have a fighting chance

It’s the

Last free place

In these United States

California’s too PC for me

Got to B free!!!!!!!!!!!!!!!!!

Welcome to Texas!

CRIMINAL AFFIDAVIT SUPPLEMENT

Keller Iglesias

Dedication

We should like to dedicate Welcome to Texas!, the first Current Constitutional Applications Project, to Hayden Covington, son of a Texas Ranger, who contributed greatly to freedom of conscience in America, and to all law enforcement officers who hurry to come when called when citizens are being attacked, to protect their fellow humans, at great cost to their own safety, and sometimes lives, true Good Samaritans.

Special Thanks

To my father, whom I so dearly love, for the idea, and to the ideal elder brother, who sticks up for his kid sister, and to persons of conscience, like Peter Black, of the United States Holocaust Memorial Museum. Thanks to our son Ethan and daughter Israel (Sascha), and to John and Naomi, Rick and Candy, Juana y Lalo, Redmond Zulu, Mary Helen, Dee and Jeff, Kharis and Brian, Bro Ro, Domingo, Phyllis Smith, and the other friends, too many to mention, but you know who you are, without whom this project would have been unendurable.

Welcome to Texas!

CRIMINAL AFFIDAVIT SUPPLEMENT

Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances. - The First Amendment to the U.S. Constitution

"Beloved, never avenge yourselves, but leave room for the wrath of God; for it is written, "Vengeance is mine, I will repay, says the Lord." 20 No, "if your enemies are hungry, feed them; if they are thirsty, give them something to drink; for by doing this you will heap burning coals on their heads." 21 Do not be overcome by evil, but overcome evil with good." (Romans 12:19 NRSV)

The scripture quotation in this passage comes from Deuteronomy 32:35... In translating "I will take revenge” [KJV: "vengeance is mine”] it is important to indicate that God takes revenge for what others have done, but not necessarily to himself. In other words, God is not being vengeful in the sense that he retaliates for what people do to him. Rather, he exercises judgment upon those who harm others. Therefore, one may translate "I will take revenge on the evil that has been done” or "I will take revenge on those who have done evil.” In some languages the closest equivalent may be "to pay back” -- for example, "I will pay them back for how they have caused others to suffer.” In other languages one may translate as "I will cause them to suffer in return.” In Greek it is not the noun form of revenge that is used in Rom 12:19; rather, it is a verb form, antapodoso <Strong's Greek word # 467>, that is used, and is translatable as, "I will give back again.”

Barclay Newman and Eugene Nida, Translator's Handbook on Paul's Letter to the Romans (New York: United Bible Societies, 1973, page 242)

STATE OF MISSISSIPPI

COUNTY OF LEE

CRIMINAL AFFIDAVIT SUPPLEMENT

Come now, Eric Hoggatt, DDS, Ethan Hoggatt, and Victoria Hoggatt, Attorney at Law, Mississippi Bar #2497 and licensed federally in the Eastern District of Texas, all adult residents of Pontotoc County, Mississippi, who state on his/her information and belief that Vivian Brown-Toussaint has violated Texas, New York, Mississippi, and Federal criminal statues, including U.S.C. § 18 Section 241, 18 U.S.C. § 371, and 18 U.S.C. § 1951 by effecting a ruthless deprivation of Dr. Eric Hoggatt’s family's rights secured by the United States Constitution and the Constitution and statutes of the states of Texas, New York, Virginia, Louisiana, and Mississippi under color of law, and has acted in concert with Philip LeTard of Vidalia, Louisiana; Wilton Hoggatt of Wisner, Louisiana; Craig Johnson of Danville, Virginia; Warren Johnson of Fancy Gap, Virginia and his wife, Dorothy Johnson of Virginia; Isaiah Hoggatt, believed to be currently residing in Baton Rouge, Louisiana; and others, including M. L. “Binky” Vines, Circuit Clerk of Adams County Mississippi, Adams County Mississippi County Judge John N. Hudson, Mississippi Department of Human Services employees Raymond Holeman, Ashley Junkin, Eileen Anderson, and Edrena Smith, and in concert with FBI Special Agent Nathan Songer of Monroe, Louisiana and his superiors, Officer Carl Houston of the Natchez, Mississippi Police Department, and Manfred Eidt of Adams County, Mississippi to interfere with the Orderly Administration of Justice. Their concerted criminal activity has a common nucleus of operative fact, and form part of the same constitutional case, a distinct prosecutable event, which is a Conspiracy Against Rights.

Article 14 of the Bill of Rights to the Mississippi Constitution comports with the 14^th Amendment to the United States Constitution, and guarantees “ No person shall be deprived of life, liberty, or property except by due process of law”. The United States Supreme Court has consistently held that “Choices about marriage, family life, and the upbringing of children are among associational rights this Court has ranked as “of basic importance in our society”, Boddie, 401 U.S. at 376, “rights sheltered by the Fourteenth Amendment against the State’s unwarranted usurpation, disregard, or disrespect.” In M.L.B. v. S. L. J., individually and as next friend of the minor children, S. L. J. and M. L. J., 519 US 102 (1996), the Court was unanimously of the view that "the interest of parents in their relationship with their children is sufficiently fundamental to come within the finite class of liberty interests protected by the Fourteenth Amendment," Santosky, 455 U.S., at 774 (Rehnquist, J., dissenting), and that "[f]ew consequences of judicial action are so grave as the severance of natural family ties".

Vivian Brown-Toussaint’s actions have been illegally interposed for egregious harassment of Dr. Hoggatt's family, and to initiate, delay, and to expand illegal court proceedings. Toussaint’s improper, intentional, egregious, and continuing obstruction of justice and denial of due process of law and equal protection of the law was prosecuted in bad faith and for improper purpose, viz., to cover criminal conduct committed by Andrew J. Allbritton, Jr., prosecutor Toussaint, Manfred Eidt, Judge John Hudson, Wilton Hoggatt, Philip LeTard, FBI Agent Nathan Songer, Warren Johnson, Craig Johnson, Dorothy Johnson, Tessa Hoggatt Allbritton, Ronnie Rombs, Donna Hoggatt Rombs, Franklin Parish, Louisiana Sheriff’s Deputy Tim Pylant, and others.

Brown-Toussaint and co-conspirators have subjected the family of Dr. Eric Hoggatt to six years of meritless, unwarranted, and unnecessary proceedings that Toussaint always knew to be illegal, at horrific cost emotionally, financially, and time resource-wise to Dr. Hoggatt and his family, and to the injury to the morals, welfare, and safety of Dr. and Mrs. Hoggatt’s children, and which criminal acts had a near fatal result to Erin Allbritton*, a victim of aggravated incest. Toussaint’s intentional criminal acts, and the actions of those with whom she acted in concert, have proven “irrevocably destructive” of what the Mississippi Supreme Court has deemed “the most fundamental human relationship”, that of a child with his parents.

Toussaint is guilty of CONSPIRACY AGAINST RIGHTS. For those unfamiliar with the statute, United States Criminal Code Section 241 of Title 18 is the civil rights conspiracy statute that makes it unlawful for two or more persons to agree together to injure, threaten, or intimidate a person in any state, territory or district in the free exercise or enjoyment of any right or privilege secured to him/her by the Constitution or the laws of the Unites States, (or because of his/her having exercised the same). Unlike most conspiracy statutes, Section 241 does not require that one of the conspirators commit an overt act prior to the conspiracy becoming a crime.

U.S. Department of Justice, Civil Rights Division, Criminal Section

The offense is punishable by a range of imprisonment up to a life term or the death penalty, depending upon the circumstances of the crime, and the resulting injury.

If two or more persons conspire to injure, oppress, threaten, or intimidate any person in any State, Territory, Commonwealth, Possession, or District in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States, or because of his having so exercised the same;...

They shall be fined under this title or imprisoned not more than ten years, or both; and if death results from the acts committed in violation of this section or if such acts include kidnapping or an attempt to kidnap, aggravated sexual abuse or an attempt to commit aggravated sexual abuse, or an attempt to kill, they shall be fined under this title or imprisoned for any term of years or for life, or both, or may be sentenced to death.

TITLE 18, U.S.C., SECTION 241

The 18 USC 241 Conspiracy of which Brown-Toussaint’s criminal acts are a component include kidnapping or an attempt to kidnap and aggravated sexual abuse. Toussaint’s individual criminal acts include but not limited to , Filing False Affidavit, Making False Statement to Court, Conspiracy to Commit Extortion, Conspiracy to Receive Products of Extortion, Removing and Concealing Official Court Records, Destruction of Court Documents, Substituting Fraudulent Court Records, Interstate Wire Fraud, Mail Fraud, Frustration of Service of Process, Obstruction of Justice, Conspiracy to Aid and Abet Interstate Kidnapping after the Fact, and Deprivation of Rights under Color of Law. In order to understand the activity of Brown-Toussaint, criminal activity of those persons with whom she has acted in concert are touched upon briefly in this affidavit. The list of offenses underlying Conspiracy is by no means comprehensive. Code sections to the offenses as listed in the Mississippi Code are to give a starting point to any law enforcement agency or prosecutor considering the materials. The fact situation is very complicated, spanning seven years and six states, and is incomprehensible without some connecting of the dots. The timeline and back story that show the interrelation between the actors is given in the larger comprehensive Criminal Affidavit.

As to Toussaint, the law of criminal conspiracy in Mississippi is that “Once a defendant is established as being a conspirator, he remains part of the conspiracy until he has extricated himself therefrom by making a full disclosure of his involvement and cessation of his activity therein, or by communicating his abandonment thereof in a manner reasonably expected to reach his co-conspirators.” Additionally, 18 U.S.C. § 1513 (b) (2) provides that “Whoever conspires to commit any offense under section (e) shall be subject to the same penalties as those prescribed for the offense the commission of which was the object of the conspiracy”. The rule at common law is that “an act of any conspirator is the act of all conspirators”.

Additionally, prosecutor Vivian Toussaint was the attorney of record for the Adams County Court in the appellate proceedings before the Mississippi Supreme Court from their commencement on or about April 7, 2003, prior to entry of any appearance by the Mississippi Attorney General’s office, on or about November 11, 2003. Toussaint has never withdrawn as attorney of record in Cause P00-137, as to the appeal on Petition for a Writ of Certiorari to the United States Supreme Court.

This affidavit is supplemental to evidence of concerted criminal action by extended family members committed in the Eastern District of Texas, in New York, Louisiana, and Virginia, and by state and federal law enforcement officers, and by public officials in the State of Mississippi contained in bound materials submitted Friday, May 12, 2006, to the United States Attorney’s office for the Eastern District of Texas in Tyler, Texas, and to Matt Bingham, the District Attorney for Smith County, Texas, where some of the criminal conduct occurred. That document is referred to as “Criminal Affidavit” or hereinafter “CA”. This document is hereinafter referred to as “Criminal Affidavit Supplement”, or “CAS”, and contains supplementary materials of continuing criminal activity and exhibits, as evidence of continued and concerted criminal activity which furthered and continued the criminal activity documented in the Criminal Affidavit, which was not discoverable until transfer of the appellate record from the Mississippi Supreme Court on or about January 9, 2006. The Criminal Affidavit left with Texas prosecutors is hereby deemed to incorporate the supplementary material contained herein. This Criminal Affidavit Supplement will be amended as well, to include continuing criminal conduct as it occurs. Exhibits to this Criminal Affidavit Supplement are labeled Exhibits CAS 1 through CAS 18.

Additional exhibits, labeled USDOJ/MAG 1/29/2003 Exhibit A-N, represent those document exhibits sent accompanied by sworn affidavits executed by Shari Johnson of Virginia, Marisa Allbritton of Louisiana, and Eric, Ethan, and Victoria Hoggatt of Texas to both the Mississippi Attorney General and to Assistant United States Attorney for the Eastern District of Texas prior to January 29, 2003. All audio exhibits and video exhibits of criminal conduct of Mississippi public officials and law enforcement officials that were made prior to January of 2004 were in the possession of Mississippi Special Assistant Attorney General Mary Jo Woods on or about February 17, 2004.

Toussaint’s federal and state felony offenses and violation of Mississippi statute include, but are not limited to, the following:

(1) Conspiracy MCA § 91-1-1, Making False Affidavit MCA § 97-9-19, Making False Entries § 97-11-1, Making False Statement to Government MCA § 95-5-39, MCA § 43-18-1 et seq. Compact on the Interstate Placement of Children;

18 U.S.C. § 242 Deprivation of Rights Under Color of Official Right; MCA § 93 – 23 – 33 Certified copies of custody decrees; MCA § 93 – 23 – 7 Notice and opportunity to be heard; MCA § 97 – 11 – 37 Failure to perform any duty

On or about September 7, 2000, Vivian Brown-Toussaint, under color of official right as Adams County Prosecutor/Youth Court Division, fraudulently executed a sworn affidavit which purports to be a petition in the County Court of Adams County, Youth Court Division concerning the Eric Hoggatt family, in which she stated under sworn oath that Dr. Eric Hoggatt, his wife Victoria Hoggatt, and their son Warren Noah Hoggatt (hereinafter Noah) were all residents of Adams County, Mississippi, and that Noah resided in Adams County Mississippi in the custody of his parents. Toussaint was fully aware that Eric Hoggatt, his wife Victoria Hoggatt, and their sons Noah Hoggatt and Ethan Hoggatt, and daughter Sascha were all residents since October 31, 1997 of New York, residing at 172 Cornwall Hill Road, Patterson, New York, and had never lived in Adams County, Mississippi. (See USDOJ/MAG 1/29/2003 Exhibit A) Toussaint was fully aware that Noah Hoggatt, age 16, after his sophomore year of high school, had been illegally transported across state lines by one Manfred Eidt, an adult resident of Natchez, Mississippi, acting in concert with Craig, Dorothy, and Warren Johnson of Virginia, Wilton Hoggatt of Wisner, Louisiana and Donna Hoggatt Rombs of Alvin, Texas, on or about August 22, 2000, and was at the time of Toussaint's fraudulent sworn affidavit, then harbored illegally in Franklin Parish, Louisiana, with Eric Hoggatt’s parents, Wilton Hoggatt and Mamae Hoggatt.

Prosecutor Toussaint was fully aware that New York residents Eric and Victoria Hoggatt and two of their children, Ethan and Sascha Hoggatt, had been staying in fact in St. Francisville, Louisiana, having filed criminal charges with the Natchez (Mississippi) Police Department on or about August 20, 2000 against extended family members for crimes committed and/or continued in Mississippi, including, but not limited to interstate kidnapping, contributing to the delinquency of a minor, breaking and entering, grand larceny, interstate threatening phone calls, conspiracy, and other acts, committed in New York, Virginia, Louisiana, Mississippi, and Texas against the family of Eric Hoggatt from the year 1997. (See Audio Criminal Affidavit 12, former Natchez City Prosecutor Eileen Maher)

The criminal conspiracy against rights by extended family members and the Adams County Court in Natchez, Mississippi has continued until the date of this affidavit. Prosecutor Toussaint, Eidt, Clerk Vines, Judge Hudson, the office of the Mississippi Attorney General, and Eileen Anderson, Ashley Junkin and Ginger Johnson of the Mississippi Department of Human Services were all made aware at first contact with each of them of extended family members’ (in Virginia, Texas, and Louisiana) conspiracy to commit interstate kidnapping of Noah Hoggatt at age 16.

Mississippi public officials and law enforcement personnel were also aware of the already then accomplished kidnapping of the Hoggatts' 17 year old son, Micah Hoggatt, from the family home in Patterson, New York on or about August 20, 1999, and of Micah's illegal transportation by Isaiah Hoggatt, then age 19, to the residence of Craig Johnson in Danville, Virginia, to the residence of Victoria Hoggatt’s parents, Warren and Dorothy Johnson of Fancy Gap, Virginia, to the residence of Wilton Hoggatt in Franklin Parish, Louisiana, and of Micah’s illegal transportation by unknown person(s) to the residence of Wilton Hoggatt 's daughter and son in law, Donna Hoggatt Rombs and Ronnie Rombs, of Alvin, Texas, from August to November of 1999.

On or about June 3, 2003 in appellate proceedings wherein the Hoggatts were asserting Mississippi’s lack of jurisdiction to issue any ‘custody’ decree, issued by a Mississippi court that sought to legitimate an unlawful transfer of a non-resident minor child of fit, New York parents to Louisiana, as well as denial of access to records, the Mississippi Supreme Court Clerk, Betty Sephton, requested from Adams County (Mississippi) Circuit Clerk M. L. Vines “a certified copy of the civil filing or criminal disposition form”, as it is odd to have an appeal with only orders, and no initiating civil or criminal petition or police report or other initiating complaint. (See Exhibit CAS 1, Sephton/Vines, June 2, 2003).

The appellate record transferred by United States mail from Natchez to Jackson, Mississippi had no civil, criminal, nor youth court petition, for two reasons. First, because the Mississippi trial judge, Adams County Judge John Hudson, had directed his clerk to not transmit the record as designated by the appealing party, Eric and Victoria Hoggatt, the appellants. Secondly, because there was neither criminal nor civil complaint ever filed. The court file does not now contain the original police report filed on or about August 20, 2000 with the Natchez Police Department by Eric Hoggatt, DDS. (See Exhibit USDOJ/MAG 1/29/2003 B, NPD police Report)

Although the Adams County court docket (See second entry on Exhibit CAS 2, “Docket 1”, 2 pages) lists “Petition Filed” on September 8, 2000, the fraudulent document that prosecutor Toussaint and Clerk Vines now allege to be that filing has no file stamp at all, as to date of filing by the Circuit Clerk, and thus has never been officially filed, though Toussaint’s signature was notarized by an Adams County Deputy Circuit Clerk on or about September 7, 2000. (See CAS 3, 2 pages). At some date after January 31, 2003, some person in the office of Adams County Circuit Clerk M.L. Vines entered an intentionally fraudulent entry on the official electronic docket, “Petition Filed”, on “September 8, 2000”, though “cause number” POO-137 contains nothing filed on that date.

The Mississippi Supreme Court Clerk requested that the certified copy of civil filing or criminal disposition form be sent to her office by June 9, 2003, and it took Toussaint, the attorney of record for Adams County on appeal, and Adams County Circuit Clerk M. L. Vines until July 23, 2003 to produce something to send in.

Additionally, since the first entry on the docket (See Exhibit CAS 2, “Docket 1”) is Eric and Victoria Hoggatt’s Petition for Disclosure that was filed on or about January 31, 2003, there may have actually been no docket, indicating that the Adams County (Mississippi) Court officials may have constructed a docket and/or court file, at some time after a Petition for Disclosure was filed January 31, 2003, in which egregious criminal conduct by officers of the County Court of Adams County committed from August 20, 2000 was alleged, documented, and transmitted to the Mississippi Attorney General and to Jim Nobles, Assistant United States Attorney for the United States Department of Justice, Eastern District of Texas, Tyler Division. For a certainty the Mississippi court file contains no “Petition Filed” on September 8, 2000. At what time Adams County Circuit Clerk M.L. “Binky” Vines acted in concert with prosecutor Toussaint to falsify that entry on the docket is unknown.

The sworn Petition for Disclosure filed by Eric and Victoria Hoggatt with the office of Adams County, Mississippi, Circuit Clerk M.L. Vines on or about January 31, 2003, stated that Judge John Hudson, his clerk, and others were “refusing access to records because records contain egregious violations of Constitutionally protected rights of Due Process and Equal Protection, Privacy, Right to face your accuser, prohibitions against establishment of religion, First Amendment protections that guarantee freedom of worship…”. The stated purpose of the petition and its being sent to the office of the Mississippi Attorney General in January 2003, was “so that the Honorable Mike Moore, Attorney General for the State of Mississippi may make a ruling” for state officials then illegally denying access to records on the verbal order of County Judge John “Newt” Hudson. (See disposition of an Opinions Request from Circuit Clerk M.L. Vines to the Opinions Division of the Mississippi Attorney General, Section 4, below).

Additionally, criminal conduct by Monroe, Louisiana FBI Agent Nathan Songer of the Federal Bureau of Investigation, and his superiors , some of which was committed in concert with Wilton and Mamae Hoggatt of Franklin Parish, Louisiana and the Franklin Parish Sheriff’s office, along with officers of the County Court of Adams County Mississippi was alleged, documented, and hand carried to Assistant United States Attorney Jim Nobles, for the United States Department of Justice, Eastern District of Texas, Tyler Division, requesting investigation and prosecution. Those materials are hereinafter referred to as USDOJ/MAG 1/29/2003. Individual exhibits to the materials sent with sworn affidavits executed by Marisa Allbritton, mother of the incest victim, by Victoria and Eric Hoggatt and their adult son Ethan Hoggatt, and by Shari Johnson of Virginia of criminal conduct committed in seven states against their three families are hereinafter referred to as USDOJ/MAG 1/29/2003 Exhibits A through N, so that the reader will be able to easily ascertain what materials were available to the Justice Department and to the Mississippi Attorney General on or before January 29, 2003.

The audio exhibits of telephone conversations of Agent Songer and his superiors, and of Tim Pylant of the Franklin Parish Sheriff’s office, and of Wilton and Tessa Hoggatt as to Wilton Hoggatt’s assistance to the fugitive, and Agent Songer’s assistance to Wilton Hoggatt, were supplied to the USDOJ, reporting criminal conduct by both the Franklin Parish (Louisiana) sheriff’s deputy Tim Pylant, who is the Franklin Parish sheriff’s brother, and FBI Agent Nathan Songer. Those same audio exhibits were later included in a group of 41 audio exhibits to a Petition for an Emergency Writ of Special Assistance and other Extraordinary Collateral Relief sent to the Mississippi Supreme Court on or about November 17, 2003, asking for supplementation of the appellate record, and asking for discipline and sanctions against Prosecutor Toussaint, Circuit Clerk M.L. Vines, Judge John Hudson, and Court Appointed Attorney Philip LeTard.

On or about July 24, 2003, Clerk M. L. Vines transmitted to the Mississippi Supreme Court Clerk a copy of Youth Court Prosecutor Vivian Brown-Toussaint’s fraudulent petition styled as “State of Mississippi County of Adams In the Youth Court Division of the County Court”, dated September 7, 2000, wherein she had sworn under oath that “the above named child [Warren Noah Hoggatt, hereinafter “Noah”] … resides within the said county and under the care, custody, and control of his parents, Eric and Victoria Hoggatt”. (See CAS Exhibit 4, Letter from Circuit Clerk M.L. Vines to Mississippi Supreme Court, dated July 23, 2003) As to the issue of the statute of limitations for criminal prosecution, such intentionally fraudulent document was not discoverable until the Mississippi Supreme Court Clerk in Jackson, Mississippi sent the official court record by United States mail to attorney Victoria Hoggatt to Sherman, Mississippi, on or about January 9, 2006, for preparation of a Petition for a Writ of Certiorari to the United States Supreme Court. (See CAS Exhibit 5, Supreme Court of Mississippi mailing notice and invoice, two pages). Nor was the fact discoverable before January of 1996, that indeed no initiating petition by the Youth Court of Adams County has ever been filed, and thus no court case has ever existed.

In the same fraudulent document sworn to by Prosecutor Toussaint, Adams County (Mississippi) Judge John Hudson signed a directive that process issue to New York residents Eric and Victoria Hoggatt, and is returnable by “10:30 a.m.” the same day, in violation of MCA § 93 – 23 –7 Requirement of Notice and Opportunity to be Heard, that states that “Before making a decree under this chapter, reasonable notice and opportunity to be heard shall be given to the contestants”. The fraudulent petition wasn’t even alleged as filed on the fraudulent docket until September 8, 2000 (See CAS Exhibit 2, 1st Docket, ), yet the Mississippi court may have issued an alleged temporary custody order based upon on Toussaint fraudulent affidavit, never filed, dated September 7, 2000, that stated that “the child would be removed from the custody of his parents”, and that “Said Wilton and May Hoggatt shall immediately enroll the child in school”, though Hudson and Toussaint were well aware of the prior August 20-22, 2000 illegal transfer of the child to Franklin Parish, Louisiana, and that such transfer violated state and federal criminal laws.

The Mississippi judge thereby purported to assert jurisdiction over custody of a New York minor then currently in Louisiana, who was the child of fit New York parents, over 1000 miles from the family home, with no allegation of harm to the child, nor with any provision for visitation with Noah Hoggatt’s natural parents, at a place where Wilton and Mamae Hoggatt had extreme animosity towards the child’s mother and elder brother. In concert with Warren Johnson of Virginia, Wilton Hoggatt of Louisiana, and Donna Hoggatt Rombs of Texas, et al, Mississippi Judge John “Newt” Hudson decided he was going to assist the kidnapping of Noah Hoggatt, and to effect a de facto termination of parental rights of New York residents without due process of law, and proceeded to do so under color of official right.

On or about September 7, 2000, Adams County Court Judge John Hudson may have executed a fraudulent order styled “ADJUDICATORY ORDER”, stating that a hearing had been held on “petition, answer, oral, and documentary evidence”, when in fact no answer had been filed, no youth court petition had been filed, and all oral and documentary evidence proffered to the court and its officers by the parents, Eric and Victoria Hoggatt, and by Noah’s school counselors, ministers, friends of the Hoggatt family and friends of Noah Hoggatt, then 16 years of age, was not allowed. (See CAS Exhibit 6, Adjudicatory Order) The New York parents weren’t even allowed to testify, though they were only in the County Court in Mississippi, because Judge John Hudson had directed the responding Natchez police officer at 3 a.m. August 19/20, 2000 that they must be, in order to invoke the police protection of the state of Mississippi. (See USDOJ/MAG 1/29/2003 Exhibit B, police report NPD, August 20, 2000)

Like prosecutor Toussaint, Judge Hudson knew that by law, Curtis v. Curtis, (Miss.1990) 574 So.2d 24, that two days in the state of Mississippi does not constitute “a significant connection” with the state of Mississippi for purposes of child custody jurisdiction, and that he was thus forbidden by Mississippi Law, namely the Uniform Child Custody Jurisdiction Act and the Compact for the Interstate Placement of Minors, as well as by the United States Constitution, from issuing a custody decree over a non-resident child, and further that he had no legal authority to judicially validate the prior illegal transfer of such child out of the state of Mississippi. Hudson knew that the transfer had been made illegally, pursuant to no court order whatsoever, on or about August 20, 2000 to Wilton and Mamae Hoggatt, and knew why Wilton and Mamae Hoggatt had terrific animosity against their son, Eric Hoggatt, and his wife, Victoria Hoggatt. Judge Hudson told attorney Victoria Hoggatt in front of Mississippi Department of Human Services workers Ashley Junkin and Ginger Johnson, CASA worker Manfred Eidt, court appointed attorney Leslie Martin, and other court personnel, on or about September 25, 2000 when discussing Eric and Victoria Hoggatt’s offer of assistance to FBI Agent Nathan Songer as federal witnesses against Mamae and Wilton Hoggatt, that “It is none of your business!” Apparently FBI Agent Nathan Songer thought so, also, and had been busy acting on his opinion. (See Sections 2 and 3, below)

Like prosecutor Toussaint, Judge Hudson knew of the residence of all parties, and yet alleged in his fraudulent order that his court had “jurisdiction of said child”, when in fact Judge Hudson was well aware that no party to the sham proceedings had ever been a resident of Adams County Mississippi, nor was at the time of his issuance of the fraudulent order, nor ever was a resident of the state of Mississippi the entire three years that Hudson purported to issue decrees, some without notice to, nor attendance of Eric and Victoria Hoggatt, concerning their family, and to deny access to the ‘court file’.

Though fully aware of the law, and that bias and interest of a witness is admissible as to the veracity of the witness, and that parents Eric and Victoria Hoggatt, pursuant to MCA 43 – 21 – 203 (9) had a right to subpoena witnesses and examine anyone who gave a report in the proceedings, and to introduce evidence controverting the contents of the report, Hudson acted illegally with prosecutor Toussaint to interfere with issuance of service of process, by ordering Clerk Vines to not issue subpoenas duly requested by attorney Victoria Hoggatt to over 30 witnesses in the course of the three years that the Hoggatt family attempted to access records for criminal prosecution of Mississippi court officials and extended family members. The Criminal Affidavit documents at length Toussaint acting in concert with Eidt, Hudson, and MDHS workers to cancel set hearings without notice when witnesses came from Virginia and New York to testify, interference with service of process, and all sorts of other machinations.

Hudson’s purpose of not allowing the parents to testify in hearings in September of 2000, was to make sure that no factual material incriminating him, FBI Agent Songer, Manfred Eidt, Toussaint, Wilton Hoggatt, Warren Johnson, Craig Johnson, or Mississippi court officials was entered on the court record.

The purported Adjudicatory Order may have been signed by Mississippi Judge Hudson on September 7, 2000, and Dispositional Order on September 25, 2000. Judge Hudson’s directive of September 25, 2000, entered on the Circuit Court electronic docket at some time after January 29, 2003, allegedly contained directions to CASA worker Eidt and MDHS employees to initiate counseling for the reunification of the family, though Noah Hoggatt stated on the court record he would not participate in any such counseling if so ordered. Attorney Victoria Hoggatt was astonished when first allowed access to view that document on or about July 10, 2003 under duress (See Video Exhibit 1), and understood why access was denied to all parts of the file, as both MDHS worker Junkin and CASA worker Eidt testified that no counseling of any kind was offered to nor received by any party.

Victoria and Eric Hoggatt with two of their children, Ethan and Sascha, waited in St. Francisville, Louisiana until the end of November, 2000, and returned to New York. The Mississippi “Adjudicatory Order” allegedly signed on or about September 7, 2000, with the file stamp unsigned by Clerk Vines, and the Dispositional Order allegedly signed on or about September 25, 2000, but with unsigned file stamp were not ‘filed’ until on or about December 5, 2000, after extended family members and Mississippi public officials knew that the Hoggatt family had finally left St. Francisville, Louisiana, to return home to New York, (See CAS Exhibit 2,1st Docket, two pages). At all stages of the sham proceedings, Judge Hudson repeatedly directed his clerk, Vines, that no appeal may be prosecuted until the order is filed. (See Criminal Affidavit)

On the express verbal order of County Judge John Hudson, (See USDOJ/MAG 1/29/2003 Exhibit Y, emails from Assistant Attorney General Gloria Green, dated March 13, 14, 19, 2003, 4 pages), Eric and Victoria Hoggatt were denied access to view Toussaint’s fraudulent petition which attempted to legitimate the interstate kidnapping, because no court petition was ever filed, and thus no legal case ever existed in the Youth Court of Adams County, a fact presumed always known by the Mississippi Attorney General and all MDHS, CASA, and other Mississippi public officials. Before that fact was discoverable, all Mississippi court officers stated on either videotape or audiotape (See Audio Exhibits 1, 2, 3, and 26) that they knew the Hoggatts had a right to view the entire youth court file, as both fit parents, and Victoria Hoggatt, as an attorney licensed in Mississippi for 25 years, including Judge John Hudson, who so stated on legally recorded telephone conversation from Natchez, Mississippi to Tyler, Texas on or about December 28, 2001.

Even though all parties, including the Mississippi Attorney General’s office, were aware that MCA 11–49–7 (Right to inspect papers), states that ‘Every attorney or counselor at law, practicing in any court in this state, shall be allowed, at all reasonable times, to inspect the papers and records relating to any suit in such court in which he may be concerned as attorney or counsel, without being compelled to take copies thereof’, at all times subsequent to its ‘filing’ September 7, 2000, the Mississippi County Court Judge, John Hudson, ordered Circuit Clerk M.L. Vines, Manfred Eidt, Mississippi Department of Human Services Workers, and/or Toussaint not to notify Noah’s parents of entry of any order or document filed, in violation of law, nor allow the parents or any attorney for them to inspect anything, including prosecutor Toussaint’s fraudulent document that purported to initiate the cause, nor the police report filed by the Hoggatts, though all court officers knew that parents were to be served with a copy of any initiating youth court petition, pursuant to statute, at its filing.

From the period from August 23, 2000 until September 25, 2000 Toussaint, Eidt, Hudson, and Junkin conspired to cancel hearings without notice when eyewitnesses from New York and Virginia came to Mississippi to testify of concerted criminal conduct of extended family members, including Breaking and Entering, Grand Larceny, Obscene and Threatening Interstate Phone Calls, Conspiracy to Commit Interstate Kidnapping of Micah Hoggatt from the family home in Patterson, New York in August of 1999, as well as of Conspiracy to Commit Interstate Kidnapping of Noah Hoggatt from Natchez, Mississippi.

After prosecutor Toussaint executed her fraudulent affidavit approximately 20 days after the interstate kidnapping of Noah Hoggatt, the 16 year old New York resident minor child of Eric and Victoria Hoggatt to Louisiana, Clerk M. L. Vines filed the September 2000 intentionally fraudulent orders which Judge Hudson allegedly based on Toussaint’s never filed affidavit in December of 2000. Thereafter, the Mississippi court held hearings without notice to parents in April, May, or June of 2001, and without their presence, in violation of MCA § 93–23–7. Circuit Clerk Vines wouldn’t even allow the Hoggatts or any attorney for them to inspect orders setting hearings, presumably directed to Eric and Victoria Hoggatt, at least one of which, dated March 7, 2003 was filed after the hearing, in violation of 43– 21–201 (3). (See CAS Exhibit 2, Docket 1, entry “Order Setting Hearing”, cf. Criminal Affidavit)

Parents of the sexual assault victim sought criminal prosecution of Andrew Allbritton, Jr., federally and in Louisiana and Texas from date of the sexual assault committed in Franklin Parish, Louisiana in January of 1996, and Eric and Victoria Hoggatt sought criminal prosecution of extended family members, federally and in Mississippi, Louisiana, and Texas from date of the kidnapping on or about August 20, 2000 in Natchez, Mississippi. Literally six years of concerted citizen effort resulted in the apprehension, extradition, conviction, and incarceration of the sex offender, Andrew J. Allbritton. ¹Eric, Ethan, and Victoria Hoggatt are still seeking prosecution of extended family members, as of the date of this affidavit, as well as prosecution of public officials who knowingly assisted them under color of official right.

Evidence and exhibits of the Mississippi court’s years of egregious criminal conduct, which included denial of access to the Mississippi Adams County Court ‘file’ is contained in the Criminal Affidavit. At the first inspection allowed of only a very limited part of the court file by attorney Victoria Hoggatt, on or about March 7, 2003, Toussaint’s intentionally fraudulent petition had been removed and concealed from the court file by Toussaint and those who acted in concert with her, Eidt, Vines, Hudson, and/or the Mississippi Department of Human Services workers Adrena Smith and Ashley Junkin. It is known by affiants that the Toussaint’s fraudulent and never filed September 7, 2000 sworn “petition” was not in the official court record in the office of Circuit Clerk M.L. Vines on July 10, 2003.

Whether transmission of the intentionally fraudulent petition and an intentionally fraudulent docket to the Mississippi Supreme Court clerk constitutes mail fraud or wire fraud may be determined by investigators. The Hoggatts documented on videotape that Toussaint’s intentionally fraudulent September 7, 2000 document had been (re?)inserted in the court file as of May 3, 2006. (See video exhibit of Circuit Clerk M.L. Vines, filmed May 3, 2006, attached to the criminal affidavit left with Smith County, Texas, District Attorney and the Office of the United States Attorney for the Eastern District of Texas in Tyler, Texas, on May 11, 2006, hereafter designated Video Exhibit 6).

In the May 3, 2006 video enclosed with the Criminal Affidavit, after speaking with Mississippi Circuit Judge Forrest Johnson, Circuit Clerk Vines allows inspection of the court file, as mandated by MCA § 43-21-261, as to disclosure of records, the pertinent part of which reads, Upon request, the parent, guardian or custodian of the child who is the subject of a youth court cause or any attorney for such parent, guardian or custodian, shall have the right to inspect any record, report or investigation which is to be considered by the youth court at a hearing, showing that both Circuit Judge Forrest Johnson and his Clerk, Vines, always knew that Vines’ repeated denial of access to the court file had no legal justification, and in fact constituted a criminal act, MCA § 97–11–37 (Failure to perform any duty) as well as Conspiracy and Obstruction of Justice.

In the May 3, 2006 video exhibit, Vines directs copies made of all ‘custody’ orders contained therein, demonstrating that Clerk Vines, Judge Johnson, Eidt, prosecutor Toussaint, and Adams County Judge Hudson were always aware that a Mississippi attorney has an right by statute to inspect papers, and that parents are entitled to receive certified copies of custody decrees, by law, pursuant to MCA § 93–23–33 from any court in the state that may issue one. Vines’ direction to Deputy Circuit Clerk Helen Flowers to copy the ‘custody’ orders and give a copy of any of them to Eric Hoggatt, Noah’s dad, on May 3, 2006, demonstrates that M.L. Vines both knew the law, and would comply with it, if Judge John Hudson were not there ordering him to break the law, and if his other judge for whom Vines serves as clerk, Circuit Judge Forrest Johnson, would not protect him. Note Clerk Vines’ statement on the video, “I’m going to go get my judge”, meaning Circuit Judge Forrest Johnson. (See Criminal Affidavit and its Exhibits Z and AA, as to Circuit Judge Forrest ‘Al’ Johnson’s actions to shield his clerk Vines, Prosecutor Toussaint, Manfred Eidt, Judge Hudson, and MDHS officers from criminal prosecution pursuant to sworn criminal affidavits filed in Adams County Mississippi on or about July 18, 2003)

Video Exhibit 6 documents Vines’ fraudulent assertion that the letter that Circuit Judge Forrest Johnson wrote disposing of criminal affidavits filed against his own clerk, Vines’, without notice to victims, is not contained in the court file. (Compare Exhibit CAS 2, 1^st Docket) Note also, Deputy Clerk Helen Flowers fraudulent assertion that the file contains no custody decrees or orders.

On or about March 6, 2003, on the court record, Judge Hudson both admitted and denied the directive to break the law, namely Mississippi Code, Section 93–23–33, to his Clerk, Vines, in the following exchange,

MRS. HOGGATT: OK…. the statute that was cited, Mississippi Code, Section 93–23–33, states as follows - - I’m sure you’re aware of it - - certified copies of custody decrees - - would you like me to read it ….?

Judge John Hudson: That’s under another provision, it does not circumvent youth court statues.

MRS. HOGGATT: Uh, well, “The clerk of the court of this state, at the request of another state or at the request of any person who is affected by or has a legitimate interest in a custody decree, shall certify and forward a copy of the decree to that court or person,” and Binky [Adams County Circuit Clerk] told me that he would not give it to me because you had ordered him not to; is that true?

Judge John Hudson: Do you - - I - - I ordered - - I didn’t - - I’m not going to answer your questions…

Toussaint’s fraudulent affidavit now included in the court file was not filed September 8, 2000, or any other date. Indeed, no petition was in fact ever filed by Toussaint or others, which fact can be ascertained by examination of the court file and documents contained in MDHS and CASA files. A document that is believed to have perhaps been what was intended to become the actual originating petition, ostensibly prepared to have been filed in Natchez, Mississippi, is a document on legal length paper, that also has no file stamp, prepared at the Natchez Police Department with aid of its officers on or about August 20, 2000, styled “In the Youth Court of Adams County”, which gives the actual cause for Eric and Victoria Hoggatt contacting the Natchez Police Department on August 20, 2000, that that Noah “was threatening to run away”. At the time of execution of her fraudulent affidavit, Toussaint was fully aware of the actions of extended family members as designated on the official police report that stated that “Eric and his wife Victoria (Noah’s) parents first requested the aid of N.P.D at 0341 this morning, and was contacted by Sgt. Mc Gehee.” “Noah’s grandfather, who is in Virginia, arranged by credit card for Noah to have a separate room, #243. Eric said he did not approve”, that “Eric is worried that Noah’s two older brothers may arrive to take Noah away”, and that Noah “was threatening to run away”, and that “A request for detention was not signed by Eric because Noah had not yet made an attempt to flee”.

That Toussaint’s fraudulent affidavit now contained in the court file has no file stamp is significant. All documents filed in the proceedings by Eric and Victoria Hoggatt have a signed file stamp executed by Adams County Mississippi Circuit Clerk M.L. Vines or his deputies. All documents filed by Toussaint that are believed to be fraudulent and/or substitutions for originally filed documents, have file stamps that are unsigned by the receiving clerk, or which have been documented as to fraudulent as to date of filing. All of the file stamps on court documents filed by the Hoggatts are signed and legible. Most of Toussaint’s documents have file stamps that are either illegible, documented as inaccurate as to date, unsigned, or a combination of the above. Only prosecutor Toussaint’s recently discoverable fraudulent sworn affidavit, which purports to be notarized by Circuit Clerk M.L. Vines’ staff, now inserted in the file, and alleged to have been in the trial court file since on or about September 8, 2000, has no file stamp at all.

Lack of any file stamp on the alleged originating document indicates that there was never a criminal or civil complaint, nor youth court petition, ever actually filed in the Youth Court of Adams County, thus, there never was a legal case in Mississippi. The fact that the prosecutor, Toussaint, always knew that she was forcing fit non-resident parents to participate in a nonexistent bogus legal “proceeding”, would certainly explain prosecutor Toussaint, the Mississippi Department of Human Services, Circuit Clerk M.L. Vines, and Judge John Hudson’s concerted actions to ensure denial of access to inspect the court file and to subpoena witnesses.

It doesn’t explain the Mississippi Attorney General’s office’s actions, as although the Attorney General is the state’s lawyer, he is expressly prohibited from defending criminal conduct by public officials. The office of Attorney General was in fact established to facilitate prosecution of criminal conduct and to advise public officials in the state of Mississippi how to follow the laws and statutes promulgated by the legislature. The Mississippi Attorney General’s office’s is most certainly not supposed to protect and participate in criminal conduct by public officials, nor to advise state and county employees to break the law. (See Criminal Affidavit as to role of Mississippi Attorney General from on or about January 15, 2003 until present).

(2) Federal Kidnapping Act 18 USC § 1201(a)(1);

MCA § 97–5–39 Contributing to the neglect or delinquency of a child; MCA § 43-18-1 et seq. Interstate Compact on the Placement of Children; MCA § 93–23–5 Jurisdiction; 18 U.S.C. § 241--conspiracy to injure or intimidate any citizen on account of his or her exercise or possibility of exercise of Federal right (overlap with 18 U.S.C. §§ 1503, 1510, 1512, and 1513).

Under 18 U.S.C. § 241, it is a Federal offense to conspire to injure a citizen for having exercised a Federal right or to conspire to intimidate a citizen from exercising a Federal right. One such right is the right to be a witness in a Federal court, United States v. Dinome, 954 F.2d 839, 845, "So is the right to inform Federal officials of violations of Federal laws." Id.

Toussaint's intentionally fraudulent sworn statement, in the form of a never filed petition, to the Adams County Court furthered the criminal conspiracy of Agent Nathan Songer of Monroe, Louisiana, acting in concert with extended family members in Virginia, Louisiana, and Texas, namely Craig Johnson, Warren and Dorothy Johnson, Wilton Hoggatt, Donna Hoggatt Rombs and Ronnie Rombs, acting in concert with Manfred Eidt, John Hudson, and the Mississippi Department of Human Services, who all knew that Eidt's transfer of the Hoggatts' minor child on or about August 20, 2000 to Wisner, Louisiana to Wilton Hoggatt and Donna Hoggatt Rombs, the very persons that the parents had called the Natchez Police Department to protect their family from, constituted both contributing to the delinquency of a minor under Mississippi statute, witness intimidation, retaliating against a federal witness, and interstate kidnapping under the federal kidnapping statute. Both Prosecutor Toussaint and Judge Hudson issued fraudulent documents and then concealed them, because they were aware that such transfer was specifically prohibited by many Mississippi statutes, including but not limited to the Compact for the Interstate Placement of Children, specific direction from the Mississippi Attorney General's office in an opinion published May 26, 1999 to Judge Hudson, (See Exhibit CAS 7, Mississippi Attorney General's May 26, 1999 opinion to Judge Hudson, 2 pages), the Juvenile Jurisdiction Act, and the Uniform Child Custody Jurisdiction Act.

For a certainty, the FBI agent and Mississippi judge with whom Wilton Hoggatt in Louisiana, Donna Hoggatt Rombs and Ronnie Rombs of Alvin, Texas, and Toussaint and Eidt in Mississippi acted in concert were aware that the County Court of Adams County, Mississippi had no legal authority to transport a New York resident minor, Noah Hoggatt to Louisiana, from fit non-resident parents, nor to issue any subsequent ‘custody’ decree almost three weeks later in an attempt to legitimate such kidnapping, nor to file decrees three months later, nor to later 'terminate’ custody after listening to audiotapes of interstate telephone conversations with Wilton Hoggatt, Tessa Hoggatt Albritton, and Craig Johnson discussing Wilton Hoggatt’s assistance to the fugitive, as evidence prepared to show Wilton Hoggatt, Tessa Hoggatt Allbritton , and Craig Johnson’s outrage at Eric Hoggatt and Victoria Hoggatt’s offer to assist state and federal law enforcement officials’ apprehension of the fugitive, and which audiotapes contained the actors discussing FBI Agent Nathan Songer’s assistance to Wilton Hoggatt’s illegal activity. (See Audio Exhibit 8 of Tessa Hoggatt December 3, 2001 , Tyler, Texas to Haughton, Louisiana,; See also Audio Exhibit 11, Craig Johnson January 13, 2002 Virginia to Tyler, Texas); See also Audio Exhibit 4, Wilton Hoggatt, January 17, 2002, Wisner, Louisiana to Tyler, Texas, all of which were also hand delivered to the USDOJ/EDTX on or about January 15, 2003)

At the Hoggatt's first meeting with Toussaint, and at the Hoggatt's first meeting with Eidt and Mississippi Department of Human Services workers Ashley Junkin, Eileen Anderson, and Ginger Johnson, all were apprised by two credible witnesses, both professionally licensed in Mississippi for over 20 years, that the conspiracy to commit interstate kidnapping by extended family members was motivated by the fact that

both Eric Hoggatt and Victoria Hoggatt, while residents of New York, had written Wilton and Mamae Hoggatt from December of 1998 until August of 2000, that they should cease and desist from the criminal activity of harboring the criminal Andrew J. Allbritton for profit by continuing to assist Allbritton’s interstate flight to avoid prosecution for profit.

Additionally, prosecutor Toussaint, Eidt, Judge Hudson, and Mississippi

Department of Human Services workers Ashley Junkin, Eileen Anderson, and Ginger Johnson, all were apprised by three credible adult witnesses that on or about August 21, 2000, Eric and Victoria Hoggatt had by interstate telephone offered information to FBI Agent Nathan Songer and to the Franklin Parish Sheriff’s Office to serve as state and federal witnesses against the parents of Eric Hoggatt, Mamae and Wilton Hoggatt, who were then, and had been for years, assisting one Andrew J. Allbritton's Interstate Flight to Avoid Prosecution for Aggravated Incest committed in Franklin Parish, Louisiana in January of 1996. Such assistance was for profit, in exchange June 27, 1996, for 80 acres of real property in Franklin Parish, Louisiana. (See Criminal Affidavit Exhibit J, Deed from Andrew J. Allbritton to Wilton and Mamae Hoggatt) The sexual assault was committed by Mamae Hoggatt's brother. Mamae Hoggatt, now deceased, was Eric Hoggatt’s mother. Andrew Allbritton died incarcerated in Louisiana in 2005, having pled guilty to Aggravated Incest committed against his eight year old granddaughter.

(3) Witness Intimidation MCA 97-9-55;

18 U.S.C. § 1001--false statements and concealment of material facts before Federal departments and agencies;

18 U.S.C. § 241--conspiracy to injure or intimidate any citizen on account of his or her exercise or possibility of exercise of Federal right, which includes the right to inform Federal officials of violations of Federal laws.

18 U.S.C. ( ,) § 1513

Retaliating against a witness, victim, or an informant

According to Donna Hoggatt Rombs of Alvin, Texas, after New York residents, Eric Hoggatt and his wife attorney Victoria Hoggatt, each called both FBI Agent Songer and Franklin Parish Louisiana Deputy Sheriff Tim Pylant on or about August 21, 2000 to protect their family, Special Agent Nathan Songer of Monroe, Louisiana responded by traveling to Wisner, Louisiana, and warning the perpetrators then assisting the fugitive that Eric and Victoria Hoggatt had offered to serve as federal witnesses against them!

Rombs said "the FBI agent sat in my parents' living room", (Franklin Parish, Louisiana) and was told everything Mamae and Wilton Hoggatt had done to finance and assist Allbritton's then continuing Interstate Flight to Avoid Prosecution for Aggravated Incest committed against an eight year old child. Both Donna Hoggatt Rombs and Pharmacist Tessa Hoggatt Albritton of Haughton, Louisiana, state that “the FBI agent” assured Mamae and Wilton Hoggatt that they wouldn't get in any trouble whatsoever, though "they told the FBI everything".

After Eric and Victoria Hoggatt’s interstate call to FBI Agent Songer, Donna Hoggatt Rombs of Alvin, Texas, and Mamae and Wilton Hoggatt of Wisner, Louisiana subsequently acted in concert with Craig Johnson, Warren Johnson, and Manfred Eidt to transport and illegally harbor Noah Hoggatt, age 16, across state lines. Vivian Brown-Toussaint subsequently conspired to act in concert with Manfred Eidt and Adams County Judge John Hudson to arrange several sham Mississippi youth court ‘hearings’ wherein Eric Hoggatt and his wife weren’t allowed to speak, in violation of law. Both Mamae and Wilton Hoggatt perjured themselves on the Adams County (Mississippi) Court record, first at the hearing perhaps set on Toussaint’s fraudulent and never filed petition, denying any knowledge of or assistance to Andrew Allbritton. Wilton Hoggatt continued to perjure himself, and to give false information to law enforcement officers, perjuring himself as late as April 1, 2003. Along with their daughter, Donna Hoggatt Rombs of Alvin, Texas, both Mamae and Wilton Hoggatt acted in concert with Warren Johnson of Virginia, and Isaiah Hoggatt to give, by interstate telephone wire and/or in person, egregious and intentionally defamatory false ‘information’ concerning the character of the Aggravated Incest victim, her parents, and Eric and Victoria Hoggatt to court officials and others.

As late as April 1, 2003, Wilton Hoggatt committed interstate wire fraud when he intentionally perjured himself as he testified to material facts in a court hearing by telephone, from Wisner, Louisiana to Natchez, Mississippi on the court record, though Judge Hudson repeatedly directed Wilton Hoggatt, “Don’t answer that question!” after the Mississippi judge and court officers had listened to and illegally copied at least three separate recordings made for the United States Department of Justice, Eastern District of Texas, of Wilton Hoggatt, Craig Johnson, and Tessa Hoggatt Allbritton discussing Wilton Hoggatt’s assistance to Andrew Allbritton, and their outrage at Eric and Victoria Hoggatt for having offered to serve as federal witnesses. (See Criminal Affidavit Exhibit Z, Page 7, Sworn Criminal Affidavit for Perjury committed by Wilton Hoggatt by interstate telephone wire on court record, on or about July 10, 2003, which Circuit Judge Forrest Johnson also secretly disposed of, without notice to victims)

On or about April 1, 2003, Noah Hoggatt, then a 19 year old resident of Louisiana, committed perjury on the court record, as to a religiously motivated assault committed on or about April 23, 2001 on Ethan Hoggatt on property owned by Wilton Hoggatt in Franklin Parish, Louisiana. On or about April 1, 2003, Adams County Court/Youth Court Division court appointed attorney Philip LeTard and Isaiah Hoggatt committed perjury as to the illegal transfer of court documents to Craig Johnson in Virginia.

Prosecutor Toussaint, Judge Hudson, and Eidt knew that Mississippi statute required the judge or someone appointed by him to have Wilton Hoggatt present in person for several hearings that he was not present for, at least one of which Toussaint, Eidt, and Hudson had illegally interfered with service of process of Eric and Victoria Hoggatt’s subpoena to Wilton Hoggatt. (See Criminal Affidavit)

Eidt stated under oath on the record on or about April 1, 2003, that Agent Songer stated to him that “the Agency” [ FBI] was never going to charge Wilton Hoggatt with anything”. Eidt’s statement further corroborated Donna Hoggatt Rombs earlier allegations that "the FBI agent sat in my parents' [Wilton Hoggatt of Wisner, Louisiana] living room, and said ‘What kind of son would turn his own father in to the FBI!’".

FBI Monroe, Louisiana Agent in Charge, Cal Seig, states that Agent Songer was the FBI agent assigned to the Allbritton unlawful flight to avoid prosecution warrant at the time that Rombs attributed the criminal activity to him. Subsequent to Eric and Victoria Hoggatt providing information to assist the apprehension of the fugitive to Agent Songer on or about August 21, 2000 by interstate telephone, Agent Songer told Marisa Allbritton, the mother of the sexual assault victim, that Mamae and/or Wilton Hoggatt told him that they had sent money to Allbritton, the fugitive, “in New York”.

Agent Songer later confirmed to attorney Victoria Hoggatt, that Mamae and/or Wilton Hoggatt told him that they had sent money to Allbritton, the fugitive, in New York. Eric and Victoria Hoggatt and their children Ethan and Sascha lived in Patterson, New York, from 1997 until September of 2001.

Agent Songer later stated to the mother of the assault victim, Marisa Allbritton, who was an affiant to the Hoggatt’s January 28, 2003 Petition for Disclosure (See USDOJ/MAG 1/29/2003 Exhibit N-2), that both Wilton Hoggatt and Daphne Allbritton Woods, the fugitive’s sister through whom Wilton Hoggatt funneled the money to the fugitive in Texas and Mexico from 1997 until 2000, had both stated to him that Mamae and Wilton Hoggatt had “gone to court” to get Eric and Victoria Hoggatt’s children “because they were unfit parents“, and that Agent Songer wouldn’t seek bank records of Daphne Allbritton Woods of Monroe, Louisiana nor of Wilton Hoggatt of Wisner, Louisiana, because the issue of ‘custody’ would cloud any testimony that Eric and Victoria Hoggatt could offer, statements which Agent Songer knew to be both false and intentionally defamatory.

While Mike Allbritton, father of the sexual assault survivor, and the son of the fugitive Andrew J. Allbritton, felt like law enforcement was assisting Andrew J. Allbritton from the time of Allbritton’s arrest for Aggravated Incest, and communicated those suspicions and the reasons for them to the United States Department of Justice for the Eastern District of Texas, Tyler Division (See Audio Exhibit 5, Mike Allbritton, made November 2, 2001), the fact that FBI Agent Songer warned those then currently aiding and abetting Allbritton’s Interstate Flight to Avoid Prosecution, namely Wilton Hoggatt, Daphne Allbritton Woods, and Mamae Allbritton Hoggatt, of New York residents Eric and Victoria Hoggatt’s offer to serve as state and federal witnesses against Mamae and Wilton Hoggatt, prior to Toussaint’s intentionally fraudulent sworn statement of September 7, 2000, was not discoverable until Donna Hoggatt Rombs of Alvin, Texas and Tessa Hoggatt Allbritton of Haughton, Louisiana, so stated in 2001 and 2002. (See Criminal Affidavit)

Agent Songer’s assistance to the fugitive, Andrew J. Allbritton, acting in concert with law enforcement in Louisiana, had begun years earlier. Andrew J. Allbritton, Jr. was an Angola maximum-security prison guard at the time of the aggravated sexual assault, who had been disciplined for prisoner abuse said to have involved “unnatural sex acts”, in what had been known as America’s Bloodiest Prison. Nonetheless, he was listed as to occupation by Agent Songer on the FBI wanted poster as a “former farmer/rancher”, though Songer knew that Allbritton was in fact a long-term prison guard at the time of the assault. Prosecutor and/or law enforcement officials informed Allbritton prior to his unlawful flight, that should he ever be sentenced, that he would not be placed in the general prison population, but would be placed in penitentiary facilities where convicted judges and policemen were incarcerated.

While seeking disclosure of Mississippi records, as well as seeking access to bond and arrest records on the fugitive, and investigating law enforcement involvement in the matter of assistance to the fugitive and to those aiding and abetting Allbritton, Eric and Victoria Hoggatt and their children Ethan and Sascha had a tire punctured in St. Francisville, Louisiana, in the parish where Angola Prison is located, which they reported to the St. Francisville Police Department on or about January 10, 2003. The family of Eric Hoggatt had their van rear side window bashed out in broad daylight on or about October 28, 2004, in Jourdanton, Texas. In March of 2005, the family of Eric Hoggatt had two tires of their van slashed in their driveway in Jourdanton, Texas. Both incidents were reported to the Jourdanton Police Department.

At some date between January 28, 2003 and April 1, 2003, either prosecutor Toussaint, someone in the office of the Mississippi Attorney General, Mississippi Judge John Hudson, Manfred Eidt, court appointed attorney Philip LeTard, or Judge John Hudson 's court clerk M.L. Vines or some other person directed by one of them, illegally copied the original Petition for Disclosure and Release of Records that was filed on legal length paper, and transmitted either that document, or its later replacement, of over one hundred pages of a Petition for Disclosure and exhibits of criminal conduct to court appointed attorney Philip LeTard, knowing that such file constituted protected and privileged juvenile records in Mississippi. At some date after the original filing on or about January 29, 2003, LeTard, an attorney in Vidalia, Louisiana transmitted the records to Isaiah Hoggatt of Louisiana, who was designated by the judge as a hostile witnesses upon Judge Hudson's own motion. Isaiah Hoggatt was then staying at the home of Wilton Hoggatt in Wisner, Louisiana, and the fugitive was still loose in Texas and/or Mexico.

Isaiah Hoggatt thereafter transmitted over one hundred pages of a Petition for Disclosure illegally supplied to him by court appointed attorney Philip LeTard, CASA worker Manfred Eidt, Hudson, or some other person, to Craig Johnson in Danville, Virginia, a copy of which had been filed with the Mississippi Attorney General, containing exhibits and documentation of concerted criminal activity of Craig Johnson, FBI Agent Songer, Isaiah Hoggatt, Wilton Hoggatt, the Adams County court and its officers, Warren Johnson, Dorothy Johnson, Donna Hoggatt Rombs, and Ronnie Rombs.

Philip LeTard was well aware that Craig Johnson, Isaiah Hoggatt, Warren Johnson and Dorothy Johnson, acting in concert with Wilton Hoggatt and Donna Hoggatt Rombs, were the persons alleged in the pleadings to have kidnapped Micah Hoggatt from Patterson, New York in 1999, at age 17, and to have transported him to the residence of Donna Hoggatt Rombs and Ronnie Rombs in Alvin, Texas, after his junior year of high school, as well those person who were alleged to have acted in concert in Texas, Virginia, Mississippi, and Louisiana to kidnap Noah Hoggatt, then age 16, on or about August 19, 2000, in retaliation for Eric Hoggatt and Victoria Hoggatt offering to serve as federal witnesses. LeTard, Eidt, and Hudson were also aware of the allegations made by Donna Hoggatt Rombs and Tessa Hoggatt Allbritton as to Agent Songer’s assistance to those then assisting the fugitive. Toussaint, LeTard, Eidt, and Hudson were also aware, as well, that the parents of both children, Erin Allbritton and Noah Hoggatt, had requested criminal investigation and prosecution of extended family members, the fugitive, and Mississippi public officials.

After such illegal distribution by Philip LeTard and Clerk M.L. Vines, Craig Johnson called Tyler, Texas from Virginia on or about March 28, 2003 and threatened attorney Victoria Hoggatt, "I'm going to rack your ass". Eidt, Toussaint, Hudson, and Vines criminal interference with service of a subpoena to Craig Johnson to appear April 1, 2003 in Natchez, Mississippi for a hearing on the Petition for Disclosure which was illegally transmitted to him, is documented in the Criminal Affidavit with audio and video exhibits.

After reading the protected youth court filing illegally supplied to him by Adams County Court officers Vines, Judge Hudson, LeTard, and/or Manfred Eidt, Isaiah Hoggatt stated by interstate wire from Louisiana that he "hoped to watch you [attorney Victoria Hoggatt] get electroshock treatment". As recent as May 26, 2006, Isaiah Hoggatt communicated by interstate wire, Louisiana to Mississippi, that “it would give me some comfort, as I watch my loving grandparents die and near death, if hell was hot, so I could imagine you'd get even a fraction of what you deserve” to his mother, attorney Victoria Hoggatt.

Not to mention, that the fugitive Allbritton was at times in Texas, billing medical treatment to his son, where the Eric Hoggatt family lived from 2001 until 2005, and the fugitive, Eric Hoggatt's maternal uncle, was armed and extremely dangerous, had been in mail and telephone contact with Wilton and Mamae Hoggatt and perhaps Agent Songer, and had threatened to kill the eight year old child if she told her parents of the sexual assault.

After years of campaigning by the parents of the sexual assault victim, Allbritton was featured on America’s Most Wanted television program. With Franklin Parish Sheriff’s Deputy, Tim Pylant, Assistant District Attorney John Boothe, the Louisiana Fifth Judicial District Assistant District Attorney for Franklin Parish, Louisiana, listened to the audiotapes recorded in 2001, of Wilton Hoggatt and Tessa Hoggatt Allbritton, wherein both Wilton Hoggatt and Tessa Hoggatt Allbritton discussed Wilton Hoggatt’s assistance to the fugitive and allegations of Agent Songer assuring and warning Wilton Hoggatt, while Allbritton was still on the loose, yet Sheriff’s Deputy Tim Pylant, who is the brother of the Franklin Parish Sheriff Steve Pylant, filmed on the May 3, 2006 Video Exhibit 6, stated that no one in the Franklin Parish Sheriff’s office ever spoke with Wilton Hoggatt in the entire five years the FPSO was charged with the investigation for the apprehension of Andrew J. Allbritton. Contrariwise, Assistant District Attorney John Boothe, the Louisiana Fifth Judicial District Assistant District Attorney for Franklin Parish, Louisiana, stated on or about May 3, 2006, that to his knowledge that Allbritton had never been used as a drug informer by the FBI or any other law enforcement agency, nor was in any witness protection program, and contradicted FPSO Investigator Pylant’s assertion, stating that the FPSO had indeed spoken with Mamae and Wilton Hoggatt.

Assistance by law enforcement and prosecutors to Andrew J. Allbritton began years earlier than the assistance of Agent Songer. Andrew J. Allbritton was bonded out on a DWI 2^nd in September of 1997, a month before his trial on Aggravated Incest, when he had at least 4 DWI’s in Franklin Parish alone, although he worked in West Feliciana Parish, and partied mainly out of town and out of Franklin Parish, most often in Monroe, Louisiana. Andrew J. Allbritton was said by his sister Mamae Hoggatt to additionally have been arrested for drugged driving. The judge who signed the DWI 2^nd bond in September of 1997 was Judge Rudy Mc Intyre, husband of Wilton Hoggatt’s attorney, Judge Ann Mc Intyre. Allbritton jumped both the DWI 2^nd bond, and the $75,000 bond on the Aggravated Incest charge and fled to Texas, prior to his trial scheduled in October of 1997. That local prosecutors and law enforcement knew that Allbritton should have at least have been charged with at least DWI 3^rd is reflected by Franklin Parish Sheriff Steve Pylant and/or Assistant District Attorney Boothe’s possession of prior arrest and conviction records, and the fact that the FBI wanted poster states such a DWI 3^rd charge. Allbritton is believed to have later pled guilty to DWI 3^rd in June of 2003. The Franklin Parish Sheriff states on videotape that the decision to so charge Allbritton with DWI 2^nd was the prosecutor’s, although the Sheriff earlier stated on audiotape that the lesser charge was because of the length of the reporting period between offenses.

Craig Johnson, attorney Victoria Johnson Hoggatt’s brother, the one that bought Noah Hoggatt’s hotel room after encouraging Noah to leave the custody of his parents on or about August 19, 2000, and who subsequently threatened by interstate wire, ‘I’m going to rack your ass’ after being requested subpoenaed to a hearing scheduled in Mississippi on April 1, 2003, has been arrested for manufacture of a controlled substance with intent to sell in Mississippi, and possession in Virginia. Craig Johnson boasted that his goal was to be “the meanest son of a bitch to ever come down the pike” on the audiotape supplied to the Adams County Court, which Judge Hudson order illegally copied and distributed to Eidt, MDHS workers, and/or Toussaint and LeTard, prior to distributing the Petition for Disclosure to Isaiah Hoggatt and/or Noah Hoggatt or some other person, who sent Craig Johnson in Virginia the entire Petition for Disclosure with exhibits, presumably by interstate wire (fax) or by U.S. mail.

At the time that the Hoggatts lived in Tyler, Texas, and protected court records alleging gross criminal misconduct were sent to Craig Johnson in Virginia by Isaiah Hoggatt, received illegally through the Adams County Court appointed attorney Philip LeTard and Clerk Vines, Craig Johnson had an adult son living in Tyler, Texas, who has been convicted in Tyler, Texas several times for Resisting Arrest, Possession, and who was arrested for an assault with a knife and believed charged with Aggravated Assault with a Deadly Weapon, and who had served six months in the Smith County, Tyler, Texas jail for parole/probation drug violations. (See CAS Exhibit 18, Arrest Records from Tyler, Texas, 17 pages)

Craig Johnson thereby retaliated against a witness, victim, and an informant

by knowingly threatening to engage in conduct causing bodily injury to another person or damage the tangible property of another person, or to do so, with intent to retaliate against any person for—

(1) the attendance of a witness or party at an official proceeding, or any testimony given or any record, document, or other object produced by a witness in an official proceeding; or, in violation of 18 U.S.C. § 1513 (b) (1) .

Isaiah Hoggatt, Wilton Hoggatt, Donna Hoggatt Rombs, Tessa Hoggatt Allbritton, Warren Johnson, Craig Johnson, and Dorothy Johnson retaliated against Dr. Eric Hoggatt and his wife for offering to serve as state and federal witness, by acting in concert with Mississippi public officials and Craig Johnson of Virginia, who was knowingly threatening to engage in conduct causes bodily injury to another person or damage the tangible property of another person, or to do so, with intent to retaliate against any person for— “providing information relating to the commission or possible commission of a Federal offense or a violation of conditions of …release pending judicial proceedings”, given by Eric and Victoria Hoggatt to law enforcement officers Franklin Parish Sheriff’s investigator Tim Pylant, Assistant District Attorney Boothe, and FBI Agent Nathan Songer and his supervisors.

Because 18 U.S.C. § 1513 (b) (2) provides that “Whoever conspires to commit any offense under section (e) shall be subject to the same penalties as those prescribed for the offense the commission of which was the object of the conspiracy”, Adams County Circuit Clerk M.L. Vines and whoever advised him in the Mississippi Attorney General’s office to illegally deny access to court records and to act in concert with Adams County Judge John Hudson to remove, conceal and destroy the public official request from the Opinion’s Division of the Mississippi Attorney General’s office, “knowingly, with the intent to retaliate”, took action harmful to many persons, including interference with the lawful employment or livelihood of many persons, “for providing to a law enforcement officer any truthful information relating to the commission or possible commission of any Federal offense”, in violation of 18 U.S.C. § 1513.

Adams County Circuit Clerk M.L. Vines, Adams County Judge John Hudson, Philip LeTard, Agent Nathan Songer and his superiors retaliated, and Donna Hoggatt Rombs, Wilton Hoggatt, Tessa Hoggatt Allbritton, Warren and Craig Johnson knowingly, with the intent to retaliate, took action harmful to many persons, including interference with the lawful employment or livelihood of many persons, “for providing to a law enforcement officer any truthful information relating to the commission or possible commission of any Federal offense”, in violation of 18 U.S.C. § 1513.

Dr. Eric Hoggatt and his wife were ashamed to live in Mississippi as long as intentionally defamatory information was being spread by extended family members, as well as fearful for the health, welfare, and safety of their two children yet at home. Not to mention the effect it has on your livelihood to spend a total of six months in the vicinity of Natchez, Mississippi over a three-year period documenting denial of access to public records by the Franklin Parish Louisiana Sheriff’s office and court records in the office of Adams County Mississippi Circuit Clerk, M.L. Vines. Eric, Victoria, Ethan, and Sascha Hoggatt expended enormous resources, both material and emotional resources, documenting the interrelation of criminal activity of Mississippi public officials with state and federal law enforcement officers in Louisiana and Mississippi.

The expense of years of investigation and litigation to prevent further assault on the integrity of the three families, including having to ultimately file a Petition for a Writ of Certiorari to the United States Supreme Court before finally being able to discover that there was no originating petition ever filed by Toussaint in Mississippi, was enormous. That the Mississippi Attorney General’s office knew of the criminal assault, and of the complete illegality of conduct of state officials and law enforcement officers, and assisted and directed them to interfere with the subpoena power to cover their conduct for years is awful. That it took six years to discover the complete magnitude of the duplicity and complicity of Mississippi pubic officials, acting in concert with federal and state law enforcement officials, should give the average American citizen pause to consider the meaning of “Police state”.

Mississippi Judge John Hudson’s threats, about any disclosure of criminal activity documented on the youth court record being against the law, after knowing that Eric and Victoria and Ethan Hoggatt had filed allegations of criminal conduct against him with the Mississippi Attorney General, and with state and federal law enforcement officers, while Hudson was in full knowledge that no court case ever actually had been filed in Mississippi, constitute “action harmful to any person, including interference with the lawful employment or livelihood of any person, for providing to a law enforcement officer any truthful information relating to the commission or possible commission of any Federal offense”. Certainly missing two or three months of work, twice, from August to November of 2000, as well as January through April of 2003, as outlined in the criminal affidavit, interfered “with the lawful employment or livelihood” of Eric and Victoria Hoggatt. As Victoria Hoggatt stated in her Petition for Disclosure,

“Attorney [Victoria Hoggatt] would be acting as Adjunct Instructor for Tyler Junior College, Tyler, Texas, teaching the American Government course required by Texas statute that requires all students in Institutions of Higher Learning in Texas to take a course that teaches the United States Constitution, like she did last semester, if she were not having to stay in the vicinity of Natchez, Mississippi, seeking to preserve her own Constitutional Rights and those of her family.

Attorney Victoria Hoggatt was forced to decline employment, because she could not be available to teach American Government and/or the Criminal Justice course for law enforcement officers at Tyler Junior College for the spring semester of 2003.

(4) Conspiracy MCA 91-1-1, Obstruction of the Orderly Administration of Justice, MCA 97-9-75 Interference with Service of Process, Federal Hobbs Act, Conspiracy to Receive Products of Extortion Under Color of Official Right

Under the Federal Hobbs Act , the United States Supreme Court held that "the Government need only show that a public official has obtained a payment to which he was not entitled, knowing that the payment was made in return for official acts." While the definition of extortion under the Hobbs Act with regard to force, violence or fear requires the obtaining of property from another with his consent induced by these means, the under color of official right provision does not require that the public official take steps to induce the extortionate payment: It can be said that "the coercive element is provided by the public office itself." Evans v. United States, 504 U.S. 255 (1992); see United States v. Margiotta, 688 F.2d 108, 130 (2d Cir. 1982), cert. denied, 461 U.S. 913 (1983) ("[t]he public officer's misuse of his office supplies the necessary element of coercion . . . .").

As outlined in the Criminal Affidavit with its attached exhibits and documents, on or about March 27, 2003, Toussaint directed Adams County Mississippi Deputy Circuit Clerk Melody Bradley to call interstate to Tyler, Texas to state that Dr. and Mrs. Hoggatt must overnight in excess of $500 before subpoenas would be issued by Circuit Clerk M. L Vines in cause number POO-137 in Adams County, Mississippi. Subpoenas were duly requested served on Agent Songer, Clerk Vines, extended family members and others. Documentation with the Criminal Affidavit demonstrates that all parties were fully aware that such information transmitted by Adams County Deputy Circuit Clerk Melody Bradley, at the direction of both prosecutor Toussaint and Adams County Judge Hudson, as to expense of youth court subpoenas was false, and that such demand for funds was prohibited by youth court statute, namely MCA 43–21–205. Adams County Sheriff’s Deputy Jack Smith acted in concert with Toussaint, Hudson, Vines, and Bradley to corroborate the false representations made by the office of Adams County Circuit Clerk M.L. Vines, Toussaint, and Judge Hudson, that monies must be paid immediately, or process wouldn’t issue, though Adams County Sheriff’s Deputy Jack Smith knows, as the Adams County Sheriff’s office said, that “they’ve never charged for youth court subpoenas.” (See Criminal Affidavit, Audio Exhibits 32, 33, 34)

Additionally, upon another request, for a hearing held in Natchez, Mississippi on or about July 10, 2003, moneys requested for subpoenas were received by Circuit Clerk M. L. Vines under color of official right through the United States mail on or about July 6, 2003, $150.00 paid by check from Tyler, Texas. Deputy Circuit Clerk Melody Bradley stated that Judge Hudson told her to charge for the subpoenas to his clerk, Vines, and other Mississippi court personnel, to extended family members including Wilton Hoggatt, Donna Hoggatt Rombs, and Warren Johnson, and to a witness to whom Eidt had alleged on the court record that he had spoken with concerning the Hoggatt family in August or September 2000, attorney Barrett Clisby in Oxford, Mississippi, who categorically denies having ever spoken with Eidt or other court officers. (See Video Exhibit 5, with office of Circuit Clerk M. L. Vines returning the Texas check requested)

A subpoena to Agent Songer was not issued, though Eric and Victoria Hoggatt repeatedly requested same issued. Agent Songer had listened to the audiotapes of Pharmacist Tessa Hoggatt Allbritton and of Wilton Hoggatt discussing Wilton Hoggatt’s assistance to the fugitive in the year 2001, along with a tape made between Mike Allbritton, the father of the sexual assault victim, and Wilton Hoggatt, wherein Wilton Hoggatt intimates that the fugitive is dead (he wasn’t). The tapes were sent to Agent Songer before the parents of the assault victim and attorney Victoria Hoggatt realized that Agent Songer was playing for the other side, with another tape made of Pharmacist Tessa Hoggatt Albritton, wherein Tessa Albritton alleges that her parents told the FBI “everything”, and that he [Wilton Hoggatt] wasn’t going to get in “any trouble at all”.

Neither did the office of Circuit Clerk M. L. Vines subpoena Sheriff’s Deputy Tim Pylant, who is the brother of the sheriff of Franklin Parish, Louisiana, Steve Pylant, seen on the May 3, 2006 videotape. The USDOJ for the Eastern District of Texas had the formal presentation made by the parents of the sexual assault victim and attorney Victoria Hoggatt hand delivered in Tyler, Texas by no later January 31, 2003. The USDOJ/EDTX presentation had recordings of Agent Songer, his supervisor Agent Ken Kaiser, and Franklin Parish Sheriff’s deputy Tim Pylant. Agent Songer and/or his supervisors may have listened to audiotaped recordings of Franklin Parish Sheriff’s deputy Tim Pylant falsely alleging that the land had been sold by Andrew J. Allbritton to Wilton Hoggatt prior to the sexual assault in 1996, when in fact Franklin Parish Deputy Tim Pylant had in his hand copies of the deed that showed otherwise.

Agent Songer’s supervisor, FBI Agent in Charge of the Monroe, Louisiana office, Cal Seig, declined investigation of both Agent Songer’s role of assistance to Wilton Hoggatt and of the Franklin Parish Louisiana Sheriff’s office’s refusal to allow inspection of public records, viz. bond and arrest records of then fugitive Andrew J. Allbritton, Jr., by legal assistant Ethan Hoggatt on or about December 27, 2002.

Instead of assisting investigation or prosecution of criminal activity, or facilitating Agent Songer’s attendance at the April 1, 2003 Natchez, Mississippi hearing on the Hoggatt’s Petition for Disclosure to which Agent Songer was subpoenaed, FBI supervisory personnel are believed to have acted in concert with Manfred Eidt, and to have advised Agent Songer not to attend the hearing held in Natchez, Mississippi April 1, 2003, after Agent Songer spoke by interstate telephone from Monroe, Louisiana with court officer Manfred Eidt in Natchez, Mississippi. FBI Assistant Chief Division Counsel Daniel J. Wehr acknowledged that he told both Agent Seig and Agent Nathan Songer to no longer speak to or receive or return calls from attorney Victoria Hoggatt.

After attorney Victoria Hoggatt requested assistance from Monroe, Louisiana Agent in Charge Cal Seig when Franklin Parish Louisiana Sheriff Pylant was denying access to public records, someone warned Franklin Parish Sheriff Steve Pylant that attorney Victoria Hoggatt or her legal assistant Ethan Hoggatt would be coming the next day to check land transaction and criminal bond records, because the Franklin Parish, Louisiana Sheriff came and watched Tyler, Texas paralegal Ethan Hoggatt copy deeds in the Franklin Parish Clerk’s office, and then refused access to public bond and arrest records when Ethan Hoggatt went to the Franklin Parish Sheriff Steve Pylant’s office, where the Franklin Parish Clerk represented that bond and arrest records on Andrew J. Allbritton were.

As seen in the May 3, 2006 video, Franklin Parish Sheriff Steve Pylant says that attorney Victoria Hoggatt should go through ‘due process’ if she wants to see the records. Cal Seig, FBI Agent in Charge of the Monroe, Louisiana office also suggested a Freedom of Information Act request, when both law enforcement officials are resumed to be aware that public records are accessible by the public. (See Audio Exhibit 31) Sheriff Pylant demonstrated that he knew that he must make public records available for inspection, when his office relented and sent copies of the arrest and bond records, after paralegal Ethan Hoggatt had been denied access. Sheriff Pylant’s office staff said that Sheriff Pylant told them to tell legal assistant Ethan Hoggatt that he would have to go see the Assistant District Attorney, John Boothe, if he wanted bond and arrest record information.

May 3, 2006, District Attorney John Boothe in Winnsboro, Louisiana, demonstrated that he knew no FOIA request was necessary, when he showed attorney Victoria Hoggatt bond and arrest records that demonstrated that the Franklin Parish Sheriff’s office knew that Allbritton had at least one prior DWI2^nd conviction, and four DWI arrests, in Franklin Parish alone, at the time that Allbritton was bonded out on DWI 2^nd, approximately one month before his trial was to begin for Aggravated Incest.

Agents Songer and Seig’s supervisor, FBI Agent Kenneth Kaiser, then believed to be the director of the New Orleans FBI office, instead of assisting investigation or prosecution of criminal activity when contacted by attorney Victoria Hoggatt to report the conduct of federal officers and Agent Songer’s alleged assistance to Wilton Hoggatt, and thus to the then fugitive sex offender, Andrew Allbritton, fraudulently represented to attorney Victoria Hoggatt that she was committing a federal offense by recording conversations with FBI agents, including the interstate recording then being made of her conversation with Agent Kaiser, indicating contemplated retaliation “for providing to a law enforcement officer any truthful information relating to the commission or possible commission of any Federal offense“, in violation of 18 U.S.C. § 1513.

It would intimidate the average whistleblower if an FBI area director alleged that an informant could be charged with a criminal offense for providing to a law enforcement officer any truthful information relating to the commission or possible commission of any Federal offense by an FBI agent and for documenting such reporting on audiotape. That attempt to intimidate a potential witness giving information to a law enforcement officer of the criminal conduct of a fellow FBI officer indicates a pattern of conduct that implicates Agent Kaiser in the criminal conspiracy. For purposes of telephone recording, both Texas and Louisiana are single party consent states, a fact which one would presume that the FBI supervisor would know. Agent Kaiser is believed now to be the Agent in Charge of the Boston, Massachusetts FBI office.

On or about January 17, 2003, at the direction of a state Mississippi Department of Human Services supervisor, Clarence Powell, who serves as Community Services Director for the Division of Youth Services, Eric and Victoria Hoggatt sent a sworn complaint with affiant Marisa Allbritton, mother of the sexual assault victim, and Shari Johnson, ex-wife of Craig Johnson who was an eyewitness to the conspiracy to commit kidnapping in New York and Virginia, almost one hundred pages of documentation to the Mississippi Attorney General’s office, to the attention of Patricia Marshall, with exhibits, of criminal conduct of Circuit Clerk Vines, Texas resident Donna Hoggatt Rombs, CASA employee Eidt, Adams County Judge Hudson, FBI Agent Nathan Songer, prosecutor Toussaint, Wilton Hoggatt, Warren Johnson, Craig Johnson, and other extended family members, so that the Mississippi Attorney General could render an opinion to Mississippi public officials who were illegally denying access to the Mississippi Court file, who were employed by the Mississippi Department of Human Services, namely Eileen Anderson and Ashley Junkin, as well as to Vines and Eidt, after Judge Hudson directed court officers to deny attorney Victoria Hoggatt access to the file.

Circuit Clerk M.L. Vines stated on audiotape that he also had mailed a written request for an opinion from the Opinions Division of the Mississippi Attorney General’s office, as to whether he should follow the judge’s direction to not even let attorney Victoria Hoggatt inspect the court file, including the alleged custody order that may have emanated from Toussaint’s fraudulent sworn but not filed petition. Vines repeatedly refused to reveal what response he received from the Mississippi Attorney General’s Opinion’s Division, as late as May 3, 2006, as recorded on the enclosed video. No opinion request is recorded in the Mississippi Attorney General’s office from Vines concerning the matter. Vines later stated on audiotape that “Judge Hudson took care of it”. An opinion’s request is a public record in Mississippi, and is docketed and preserved even if the request is withdrawn. Vines’ request is believed to have been removed, concealed, and destroyed from the public records of the Mississippi Attorney General’s office. Vines is seen calling the Mississippi Attorney General’s office on May 3, 2006 in the Video Exhibit 6.

Ann Wise of the Mississippi Attorney General’s office stated on audiotape on or about January 17, 2003, that inspection was mandated by Mississippi statute.

On or about January 10, 2003, prior to the transmission of the evidence to the Mississippi Attorney General’s office, Eric and Victoria Hoggatt also delivered a presentation to Mr. Jim Nobles, of the office of the United States Attorney with the Department of Justice in Tyler, Texas, accompanied by audiotaped presentations from the parents of the sexual assault victim, the recordings of the FBI agents involved, and the recording of Haughton, Louisiana pharmacist Tessa Hoggatt Allbritton , the fugitive’s niece, stating that her parents, Wilton and Mamae Hoggatt, told the FBI agent “everything”, and that they weren’t going to get “in any trouble at all.” Tessa Albritton stated this in November and December of 2001, after Wilton Hoggatt had sent annual payments to the fugitive for years, after agreeing to assist the fugitive’s interstate flight to avoid prosecution, in exchange for transfer of 80 acres in Franklin Parish (See Criminal Affidavit Exhibit J) in June of 1996. Donna Hoggatt Rombs’ allegations of knowledge of Agent Songer’s warning to and protection of Wilton and Mamae Hoggatt were made on or about November 20, 2002, in Alvin, Texas.

Prior to his extradition from Texas to Louisiana, Andrew J. Allbritton, Jr. himself stated on audiotape on or about April 6, 2003, that he needed the rest of the money that “Wilton owed” him. It is believed that Wilton Hoggatt suspended annual payments to the fugitive when warned by FBI Agent Songer at some date shortly after August 22, 2000. (See Criminal Affidavit Audio Exhibit 13, Andrew J. Allbritton, Jr. April 6, 2003)

By no later than January 31, 2003, the Mississippi Attorney General was in possession of the sworn allegations made against the Mississippi court system and the Mississippi Department of Human Services that constituted years of concerted criminal activity, which was sworn to by Eric, Ethan, and Victoria Hoggatt of Tyler, Texas, by Marisa Allbritton of Denham Springs, Louisiana, the mother of the sexual assault victim, and by Shari Johnson of Virginia, an eyewitness to Conspiracy to Commit Interstate Kidnapping. According to Raymond Holeman, Natchez area supervisor for the Mississippi Department of Human Services, on or about July 8, 2003, John Gadow of the Mississippi Attorney General’s office directed that Holeman instruct MDHS caseworker Ashley Junkin to not attend the July 10, 2003 hearing in Natchez to which the Hoggatts had subpoenaed her, though monies were paid in response to Clerk Vines’ illegal request for monies to be sent him from Tyler, Texas to Natchez, Mississippi to issue a subpoena to both MDHS employee Junkin and to court official Manfred Eidt in his capacity as court appointed guardian ad litem.

MDHS employee Adams County supervisor Raymond Holeman stated that he spoke also with Judge John Hudson concerning the subpoenas, prior to the hearing. After denying that MDHS worker Ashley Junkin knew about the possibility of being subpoenaed, her supervisor Holeman admits that he and subordinate Ashley Junkin discussed her attendance and issuance of the subpoenas prior to the hearing. As presented in the attached criminal affidavit, Junkin denies knowledge of both the hearing and subpoenas. Mississippi Assistant Attorney General John Gadow additionally states that he spoke with Judge Hudson’s court administrator.(See Audio Exhibits 38, 39, and 40, of MDHS supervisor Holeman, MDHS employee Junkin, and John Gadow and Patricia Marshall of the Mississippi Attorney General’s office)

On or about July 8, 2003, Eidt stated he was going to attend the hearing scheduled for July 10, 2003. After speaking with Judge Hudson, who asked him if he received a subpoena, Eidt did not attend. .(See Audio Exhibit 36)

Manfred Eidt in his capacity as a court officer stated that subpoena requests should be sent to him, and that he would convey them to Circuit Clerk Vines for issuance for the April 1, 2003 court hearing. On or about March 27, 2003 Eidt stated that he spoke by telephone to Agent Songer. On April 1, 2003 Eidt stated on the record under oath that he had spoken with Agent Songer prior to the hearing, who was never served with a subpoena, at the direction of Clerk Vines, Judge Hudson, and prosecutor Vivian Toussaint.

Agent Songer did not attend the April 1, 2003 hearing where he would have been examined under oath, but oddly enough, after Eidt’s interstate conversation with Agent Songer, seven years after the aggravated sexual assault was committed against an eight year old little girl in Wisner, Louisiana, the fugitive was apprehended when he just happened, according to FBI sources, to walk across the border from Mexico in the vicinity of McAllen, Texas, and give border officials his correct social security number, and the border officials just happened to check it and found out that Andrew Allbritton was wanted for interstate flight to avoid prosecution for aggravated incest, about three days prior to the hearing where Agent Songer and Deputy Pylant and a host of other folks, including Circuit Clerk M.L. Vines himself, would have been served with subpoenas, had they not interfered with service of process.

Additionally, because attorney Victoria Hoggatt could not get an answer from Clerk Vines as to whether he had gotten a return on service of process, or a response from prosecutor Vivian Toussaint, Victoria Hoggatt asked both Toussaint and Louisiana attorney Philip LeTard to assist in moving for a continuance for the July 10, 2003 Natchez, Mississippi hearing set on prosecutor Toussaint’s ***Amended*** Motion Objecting to Designation of Record and to Designate Record, not knowing that the amended motion had been removed, concealed and destroyed by Vines, Toussaint, and/or Judge Hudson. (See Criminal Affidavit Audio Exhibit 38, Toussaint) On or about July 8, 2003, Judge John Hudson told his court docketing secretary Janine Wickham, to call Tyler, Texas, and relate to Victoria Hoggatt that there would be no continuance, but that the hearing would be an evidentiary hearing, and that he would tell the Adams County Circuit Clerk to issue the subpoenas. Both before and after the call, Judge Hudson in fact told the Adams County Circuit Clerk’s office not to issue the subpoenas. (See Criminal Affidavit Audio Exhibit 36 of Manfred Eidt, and Video Exhibits 4 and 5)

Court personnel, MDHS caseworker Ashley Junkin and CASA employee Manfred Eidt, who had been subpoenaed, are believed to have been counseled by the Mississippi Attorney General’s office, MDHS supervisor Raymond Holeman, and/or by Adams County Judge John Hudson not to attend the July 10, 2003 hearing.

Mississippi Court orders purporting to legitimate the August 20, 2000 interstate transfer of Noah Hoggatt, a non-resident minor child of non-resident fit natural parents, under color of official right, were alleged to have been filed from September 15, 2000 until May 2, 2003, the constitutionality as to jurisdiction and denial of due process and equal protection of the laws of all of which were timely assailed on appeal, as jurisdiction cannot be waived, and may be asserted at any point in the proceedings, and even collaterally. Notice of Appeal of the Mississippi court’s denial to inspect court records was timely filed on April 7, 2003.

Since Prosecutor Toussaint and Mississippi Adams County Judge Hudson did not like the Hoggatts’, as appellants, Designation of Record for appeal, Judge Hudson wrote his own Order Designating Record on July 10, 2003, which was not entered on the docket as required by law. When and if the July 10, 2003 Order Designating Record was in fact ever actually filed in the office of Circuit Clerk M.L. Vines is unknown. The Order Designating Record from Judge Hudson signed July 10, 2003 was fraudulently file stamped as to date. The file stamp looks like either July 10, 2003 or July 18, 2003, but the Hoggatts videotaped that an order that purported to be the July 10, 2003 Order Designating Record was brought to the office of the Circuit Clerk on July 11, 2003, and had not been filed prior to that date.

Hoggatts timely designated as necessary for appeal the entire content of the youth court record as defined by statute, MCA 43– 21–251, using the Mississippi Supreme Court website standard designation when all records are requested.

The Criminal Affidavit (CA) relates in detail and documents by audio and document exhibits that Toussaint sent to Tyler, Texas by interstate wire, notice that she had filed a pleading in Natchez, MS styled “Motion to Object to Designation of Record and to Designate Record”, when in fact the docket sent to the Mississippi Supreme Court on or about August 5, 2003 by the Adams County Clerk contains no such entry for the month of June. Toussaint later sent to Tyler, Texas by interstate wire notice that she had filed another pleading in Natchez, MS styled “***AMENDED*** Motion to Object to Designation of Record and to Designate Record”, which is not listed at all on either docket sent to the Mississippi Supreme Court by the Adams County Clerk. Toussaint asked that Tyler, Texas residents, Eric and Victoria Hoggatt, enter into an agreed order on the fraudulent “***AMENDED*** Motion to Object to Designation of Record and to Designate Record”.

Prosecutor Toussaint further stated in the email ***Amended*** motion cover letter transmitted to attorney Victoria Hoggatt by interstate wire to Texas, that certain Mississippi Department of Human Services and CASA Records in the cause were in the court file, and had been included in the Amended Motion, and would be sent to the Mississippi Supreme Court for the appeal.

Thereafter, Clerk Vines, Prosecutor Toussaint and Judge Hudson set a hearing on prosecutor Toussaint’s “***AMENDED*** Motion”. By no later than July 10, 2003, Clerk Vines, Prosecutor Toussaint and/or Judge Hudson removed, concealed and destroyed the fraudulent “***AMENDED*** Motion” document and any order which may have be issued setting any hearing on the “***AMENDED*** Motion” .

By some date after July 10, 2003, Hudson, Vines and / or Toussaint acted in concert to substitute another document for Toussaint’s ***Amended*** motion , styled “Motion Objecting to Designation of Record and to Designate Record”, that did not include the Mississippi Department of Human Services and CASA Records, without notice to the Hoggatts. Both motions by Toussaint had been removed and concealed from the court file by 11:00 a.m. July 10, 2003. CASA and MDHS records that are also required by statute to be in the youth court file had also been removed and concealed.

At the July 10, 2003 hearing, attorney Victoria Hoggatt’s request to view the court file, including CASA and MDHS records, was denied, though the hearing was ostensibly on Toussaint’s ***Amended*** motion as to designation of the record for appeal, and Toussaint had represented in writings transmitted by interstate wire that certain CASA and MDHS records prepared by MDHS worker Ashley Junkin and CASA worker Manfred Eidt were included in her Amended Motion, and that Toussaint’s Amended Motion asked that such records prepared by MDHS worker Ashley Junkin and CASA worker Manfred Eidt be included in the appellate record. The record reveals that on July 10, 2003, attorney Victoria Hoggatt still believed and relied on Toussaint’s written statement sent by interstate wire, that prosecutor Toussaint had moved the court to include MDHS and CASA reports, when in fact Toussaint had acted in concert with Clerk Vines and Judge Hudson to remove, conceal and destroy her “***Amended*** Motion” document from the court file.

The second substituted document is file stamped June 10, 2003, but listed on the docket as filed by Toussaint on July 10, 2003, the same date Toussaint could not attend her own hearing, saying she was out of town.

At a hearing held July 10, 2003, in direct violation of M. R. A. P. RULE 10 (b) which statutorily sets how the content of an appellate record is to be determined, Judge John Hudson issued an order stating that he would decide what part of the court record that the Mississippi Supreme Court would review on appeal to determine if Mississippi ever had jurisdiction to do what it did, and that Judge Hudson would choose the appellate record himself, eliminating Toussaint’s fraudulent September 7, 2000 never filed originating petition, transcripts of the first three and interim hearings, all CASA and MDHS records, an order setting a hearing filed a day after the hearing on or about March 7, 2003, and even the original police report.

M. R. A. P. RULE 10 (b) Determining the Content of the Record, reads as follows:

“(1) Designation of Record. Within seven (7) days after filing the notice of appeal, the appellant shall file with the clerk of the trial court and serve both on the court reporter or reporters and on the appellee a written designation describing those parts of the record necessary for the appeal.”

Toussaint, as prosecutor, and the Adams County Judge John Hudson both knew that their acting in concert to decide, under color of official right, what the appellate record would contain for appeal, was illegal. Citing privacy rights of minors as to youth court records, no trial judge can, consistent with the Due Process and Equal Protection Clauses of the Fourteenth Amendment, deny a fit non-resident parent his right to choose the content of the record for appeal as provided by M.R.A.P. 10 (b) (1), and then the trial court judge himself designate the record for appeal, as he is not “a party” to the proceeding, illegally omitting the police report, the originating youth court petition, transcripts of the initial and two subsequent hearings, and even all CASA and Mississippi Department of Human Services records that were, per the court, “documents, reports, and…investigations which are to be considered by this court, at this hearing”, in clear violation of M.R.A.P. 10 (f) which reads as follows:

Limit on Authority to Add to or Subtract From the Record. Nothing in this rule shall be construed as empowering the parties or any court to add to or subtract from the record except insofar as may be necessary to convey a fair, accurate, and complete account of what transpired in the trial court with respect to those issues that are the bases of appeal.

The Mississippi trial judge even purported to eliminate the docket from the appellate record, in violation of M. R. A. P. RULE 10.

CONTENT OF THE RECORD ON APPEAL “(a) Content of the Record. The parties shall designate the content of the record pursuant to this rule, and the record shall consist of designated papers and exhibits filed in the trial court, the transcript of proceedings, if any, and in all cases a certified copy of the docket entries prepared by the clerk of the trial court“.

Prosecutor Toussaint conspired with Clerk Vines and Judge Hudson to not file such July 10, 2003 “Order Designating the Record”, which was not entered on the docket sent to the Mississippi Supreme Court on or about July 23, 2003 by Clerk Vines, even though Victoria Hoggatt videotaped Mr. Vines purportedly bringing the order to his office to be filed on July 11, 2003. Additionally, on or about July 18, 2003, attorney Victoria Hoggatt videotaped M.L. Vines’ staff reading from the computerized docket in the cause, and M.L. Vines’ staff stating that Judge Hudson’s “Order Designating the Record” was on the docket. Thus at some date after July 18, 2003, Adams County Mississippi Circuit Clerk M.L. Vines altered the docket to eliminate the entry of Judge Hudson’s illegal “Order Designating the Record”.

A letter from Circuit Clerk M.L. Vines to the Mississippi Supreme court dated July 23, 2003, lists the certified orders and documents sent to the Mississippi Supreme Court for the Hoggatts’ appeal. Not listed in Circuit Clerk M.L. Vines’ letter is the July 10, 2003 Order Designating the Record. Also not included in the list of documents sent on appeal is Eric and Victoria Hoggatt’s July 18, 2003 Notice of Appeal of that order, which was timely filed by the Hoggatts. See CAS Exhibit 4. It is believed that Judge Hudson’s illegal order styled Order Designating the Record , which issued in response to Toussaint’s fraudulent ***Amended*** Motion which had been removed, concealed, and is believed to have been destroyed by Mississippi court officials, was not sent to the Mississippi Supreme Court until on or about September 1, 2004, as there was a notation of a facsimile transmission from the Circuit Clerk’s office to the Mississippi Supreme Court on that date, with “Order Designating Record” on the facsimile cover sheet, attached to the Order Designating Record, which is also stamped by Circuit M.L. Vines facsimile machine as September 2, 2004, as to date of transmission, and file stamped by the Mississippi Supreme Court clerk as received and “filed” that day, (CAS Exhibit 12, three pages) though no such filing appears on the Mississippi Supreme Court Clerk’s certified docket. (CAS Exhibit 9, three pages) Judge Hudson’s Order Designating the Record appears to have been inserted in the appellate court file with the other documents, as if it had been sent with them by Circuit Clerk Vines on or about July 23, 2003.

Likewise, the Hoggatt’s July 18, 2003 Notice of Appeal of the Mississippi trial court’s Order Designating the Record was timely filed with Circuit Clerk M.L. Vines, but not conveyed by the trial court to the Mississippi Supreme Court for over a year, on or about September 1, 2004, by facsimile, at which time the Mississippi Supreme Court Clerk obligingly file stamped the Notice of Appeal of the Mississippi trial court’s Order Designating the Record July 18, 2003, as if it had been transmitted to the appellate court the day the Notice of Appeal was filed in the trial court, and had been filed in the Mississippi Supreme Court on July 18, 2003, a fact not discoverable until the Mississippi Supreme Court Clerk transmitted the youth court record by U. S. Mail in January of 2006 for attorney Victoria Hoggatt to prepare a Petition for Writ of Certiorari to the United States Supreme Court.

The Notice of Appeal of the July 10, 2003 Order Designating the Record is clearly stamped by Circuit Clerk M.L. Vines facsimile machine as September 1, 2004, as to date of transmission, though file stamped by the Mississippi Supreme Court on the same document as filed “July 18, 2003”. (CAS Exhibit 13, Notice of Appeal and facsimile cover sheet, 4 pages)

The certified docket of the Mississippi Supreme Court doesn’t list the Hoggatts’ Notice of Appeal of the trial court’s Order Designating Record as filed on either July 18, 2003, September 1, 2004, or on any other date, though it is stamped “Filed Office of the Supreme Court Clerk July 18, 2003”.

It thus appears that after the Adams County Circuit Clerk sent in the July 18, 2003 Notice of Appeal on September 1, 2004,that he and/or Toussaint and Judge Hudson decided it would be best to send in the Order Designating the Record, since the Notice of Appeal referred to the illegal order that had been entered and then removed from the docket.

The certified docket of the Mississippi Supreme Court doesn’t list the trial court’s Order Designating Record as filed the Mississippi Supreme Court on either July 10, 2003, September 2, 2004, or on any other date, though it is stamped “Filed Office of the Supreme Court Clerk September 2, 2004”.

On the court record, attorney Victoria Hoggatt asked Judge Hudson to request of the court reporter timely transcription of the July 10, 2003 court record, that she might appeal Judge Hudson’s Order Designating the Record. Judge Hudson tells her on the record not to do that. She reiterates that she is not going to the Mississippi Supreme Court without a record. Judge Hudson reiterates that she shouldn’t appeal the July 10, 2003 Order Designating the Record, but continue with the earlier appeal. This whole discussion of attorney Victoria Hoggatt’s determination to appeal Judge Hudson’s illegal designation of the record is now entirely missing from the official court transcript prepared by court reporter Shelley Dearing, which was sent by United States Mail to the Mississippi Supreme Court.

How the official appellate record came to be tampered with could only be ascertained by subpoenaing court reporter Shelley Dearing’s audiotapes of the hearings.

That the Hoggatt’s Notice of Appeal of the trial court’s Order Designating Record was not timely conveyed to the Mississippi Supreme Court, and that it was later intentionally fraudulently file stamped by the Mississippi Supreme Court Clerk was not discoverable until the Mississippi Supreme Court Clerk sent the official court record by United States mail to the Hoggatts in Sherman, Mississippi, on or about January 9, 2006, for preparation of their Petition for a Writ of Certiorari to the United States Supreme Court. Thus the statute of limitations for criminal prosecution of Mississippi public officials for Conspiracy has not run, and venue lies in the Eastern District of Texas and Northern District of Mississippi for federal prosecution, as well as in other jurisdictions.

(5) 18 USC Sec. 371 CONSPIRACY Conspiracy to commit offense or to defraud United States

Agent Nathan Songer repeatedly told Marisa Allbritton, mother of the sexual assault victim, that he would not subpoena bank records of Wilton Hoggatt or Daphne Allbritton Woods when she asked him to “follow the money, Nathan”, because both Wilton Hoggatt or Daphne Allbritton Woods had told Agent Songer that they ‘ had gone to court to get custody of Eric and Victoria Hoggatt’s children because they were unfit parents’, had been successful, and that Eric Hoggatt subsequently made up lies about Wilton and Mamae Hoggatt, falsely alleging that Wilton and Mamae Hoggatt were then assisting Andrew Allbritton’s unlawful flight to avoid prosecution, in order to get back at Wilton Hoggatt for successfully “going to court to get custody of Eric and Victoria Hoggatt’s children because they were unfit parents”. Agent Songer confirmed this scenario to attorney Victoria Hoggatt on legally recorded audiotape while the fugitive was still at large, and after Agent Songer had been apprised by the parents of the sexual assault victim that the child victim of aggravated incest, then 14, had attempted suicide.

If Wilton Hoggatt and Daphne Allbritton Woods did in fact act in concert to state such intentionally fraudulent statement to Agent Songer, then two or more persons conspired to defraud an agency of the United States, and Wilton Hoggatt acted to effect the object of the conspiracy, to assist the fugitive and to avoid federal prosecution himself.

Daphne Allbritton Woods, now deceased, was recorded stating that she never spoke to Agent Songer concerning Eric and Victoria Hoggatt, and had no idea how Noah Hoggatt came to be living with Wilton and Mamae Hoggatt at age 16.

If Agent Songer is lying, and Donna Hoggatt Rombs of Alvin, Texas and Pharmacist Tessa Hoggatt Albritton are telling the truth, and Agent Songer did in fact assist and warn Wilton Hoggatt after being apprised, not only by New York residents Eric and Victoria Hoggatt, but also by Wilton Hoggatt and Mamae Allbritton Hoggatt themselves of Daphne Allbritton Woods, Mamae Allbritton Hoggatt, and Wilton Hoggatt’s then current assistance to the fugitive, then I don’t think its against the law for an FBI agent to lie to private attorneys or to the parents of an aggravated incest victim. It is most certainly against the law to assist persons then illegally harboring a 16 year old New York minor, to act in concert with a Mississippi court system to act under color of official right to assist those who would kidnap a New York resident minor child and transport him illegally to Louisiana.

It may well be against the law for FBI Agent Songer to know of Wilton and Mamae Hoggatt’s knowledge of the fugitive’s whereabouts and of Wilton and Mamae Hoggatt’s mail and phone contact with him, and of Wilton and Mamae Hoggatt’s then current assistance to the fugitive, and to assist them to avoid prosecution for Conspiracy to Aid Interstate Flight to Avoid Prosecution, and may constitute Misprision of Felony. I am sure its not nice for an FBI agent to alert folks who are in mail and phone contact with someone on America’s Most Wanted for Aggravated Incest committed against an eight year old child, that the fugitive’s nephew and his wife have offered to serve as federal witness to aid in his apprehension. Prior to his interstate flight to avoid prosecution, Allbritton boasted to his son that should he ever get ‘in trouble’, that he would never be caught , because he “had a lot of friends”.

The fugitive was known to be armed, dangerous, and vindictive. The child was afraid to play outside for two years after the assault, because Allbritton threatened that he would come back and hurt her if she told, and had terrorized the family prior to his interstate flight to avoid prosecution. (See statements prepared in November 2001 by child’s mother and father for USDOJEDTX presentation , Audio Exhibits 5 and 6, Mike Allbritton and Marisa Allbritton)

In any case, at some date on or about March 28, 2003, the fugitive Andrew J. Allbritton, Jr., over seven years after the offense, ostensibly walked across the border and gave his real social security number, at the very same time that Youth Court Division of Adams County Court of Natchez, Mississippi officer Manfred Eidt has stated under oath on the court record that had he contacted and spoken with Agent Songer by interstate wire, and at the very same time that Vivian Brown-Toussaint was violating Texas, Mississippi, and Federal criminal statues, in concert with Manfred Eidt, M. L. “Binky” Vines, Circuit Clerk of Adams County Mississippi, Adams County Judge John N. Hudson, and other officers of the Youth Court Division of Adams County Court of Natchez, Mississippi by interfering with the Orderly Administration of Justice by refusing to issue subpoenas as required by law to Agent Songer, extended family members, and to Clerk Vines and his staff, who were all then committing Conspiracy to Receive Products of Extortion Under Color of Official Right.

On or about September 2, 2003, FBI Assistant Chief Division Counsel in New Orleans, Louisiana, Daniel J. Wehr, stated that a search for any notes or records of Agent Songer speaking to Mississippi Court officer Eidt came up “negative”. Agent Songer also had no documentation of Eric and Victoria Hoggatt’s offering to serve as federal witnesses in August of 2000. (See Criminal Affidavit Audio Exhibit 21, compare Criminal Affidavit Exhibits K and L, letters from Agent Wehr)

Prior to Allbritton’s extradition from Texas to Louisiana, Marisa Allbritton, mother of the assault victim, stated that an FBI agent told her that if she or her husband spoke to Andrew J. Allbritton, Jr. by telephone after his apprehension in Texas, to not let on that he was still wanted in Louisiana, because the FBI had talked to him, and knew where he had been hiding in Mexico, and would know where to get him , if he went BACK! He was admitted to the Mc Allen, Texas Heart hospital, allegedly with no guard posted until Victoria Hoggatt contacted the FBI about that. Allbritton was recorded on or about April 6, 2003 in Mc Allen, Texas, thinking he was going to be out of the hospital in a couple days, and was worried about nothing more than paying his hospital bill.(See Criminal Affidavit Audio Exhibit 13)

According to Daphne Allbritton Woods, who was Andrew Allbritton’s sister in Monroe, Louisiana who had funneled the payments for the real property from Wilton Hoggatt to the fugitive in Texas and Mexico, a federal judge came to the Mc Allen, Texas Heart Hospital, and signed a bond for Allbritton to be released on his own recognizance, though he had jumped a $75,000 Aggravated Incest Bond, as well as the $2750 2nd Offense DWI bond ( listed as 3rd Offense DWI on the FBI Wanted Poster), issued 19 months apart.

Such actions do not seem to comport at first impression with 18 U.S.C. § § 3141 et seq, as to federal guidelines as to Release and Detention Pending Judicial Proceedings, but then, I was just a police intern with the Grenada, Mississippi Police Department, and the only criminal defense I’ve done except what I had to, pro bono, was represent a one-armed bootlegger in Water Valley, Mississippi, and he lost. In my defense, the judge later acknowledged that the charge wasn’t proven, but said, “Vicky, people are getting killed at the Blue Moon Café, and we needed to shut it down”.

All extended family members and Mississippi court personnel knew of Eric Hoggatt family’s reputation in the community, both in Patterson, New York, and in Oxford, Mississippi, where the family lived since Victoria Hoggatt was in law school at Ole Miss there in 1974, and where Eric Hoggatt practiced General Dentistry until October of 1997, when the family moved to New York. The Eric Hoggatt family lived in Patterson, New York from October 31, 1997 until September of 2001, where Dr. Hoggatt served as a charitable volunteer for medical missions.

Judge Hudson stated on or about September 25, 2000 on the court record that Jackie Pegues, an MDHS social services worker from Oxford, had given a complimentary and favorable report on the whole family. Additionally, testimony in the court file shows that the Natchez officials had never met the family, but were apprised of the character and reputation of the family, but refused to speak with school counselors and family friends when court officials were contacted by them in August and September of 2000, while Noah was illegally harbored in Louisiana. (See USDOJ/MAG 1/29/2003 Exhibits I 1-3, given to Mississippi court officers in August and September of 2000) Mississippi court officers were also given extensive documentation on reputation of professional character and competence of Eric Hoggatt, DDS, in August and September of 2000, while Noah was illegally harbored in Louisiana (See USDOJ/MAG 1/29/2003 Exhibits C -1 through C-5)

Additionally in August and September of 2000, Mississippi court officers were also given extensive documentation on the destructive influence of Warren and Dorothy Johnson and Craig Johnson, from Millsaps College, concerning Isaiah Hoggatt’s social and disciplinary probation. (See USDOJ/MAG 1/29/2003 Exhibits D 1 through 7)

Never the less, in August and September of 2000, Adams County Judge John Hudson, MDHS officials, and prosecutor Toussaint and Eidt conspired to cancel without notice the hearings scheduled when an eyewitness to the Conspiracy to Commit Kidnapping in August of 1999 in Patterson, New York committed by Isaiah Hoggatt and Warren, Dorothy, and Craig Johnson in Virginia came to Mississippi to testify .

Shari Johnson, Craig Johnson’s wife, flew at her own expense from Virginia to testify at the hearing cancelled after her arrival by Toussaint, Eidt, and Hudson. Since MDHS employees Ginger Johnson and Ashley Junkin told Johnson “they didn’t want to hear anything bad”, she was unable to testify of witnessing both the plans cobbled together in Virginia to get Micah Hoggatt, and the execution of kidnapping of Micah Hoggatt from Patterson, New York, in August of 1999, and of Micah’s subsequent interstate transportation to Wilton Hoggatt in Franklin Parish, Louisiana, and to the Alvin, Texas residence of Ronnie Rombs and Donna Hoggatt Rombs, in October and November of 1999, in retaliation for Eric and Victoria Hoggatt encouraging Wilton and Mamae Hoggatt to cease and desist assisting the fugitive, and in retaliation for Victoria and Eric Hoggatt restricting family members’ association with their children when they were drunk, drugged, and nasty.

Ethan Hoggatt, the Hoggatt’s adult son, was present to testify as a witness to the kidnapping in New York, until an August 2000 hearing was cancelled. Ethan Hoggatt additionally had been present in Natchez on August 19/20, and was an eyewitness to extended family members in Virginia and Texas encouraging Noah that if his parents called the police, he ‘should run’. After those two witnesses, Shari Johnson, who was then Craig Johnson’s wife, and Ethan Hoggatt, the Hoggatt’s adult son, had returned to Virginia and New York, respectively, the Natchez court held the sham hearings, allowing Eidt, MDHS worker Ashley Junkin, Wilton and Mamae Hoggatt, and Isaiah Hoggatt to testify at length, but forbidding the parents to speak, except for allowing two questions on cross examination, to avoid testimony being entered on the court record concerning the criminal activity of Eidt, Toussaint, Hudson, Wilton Hoggatt, Mamae Hoggatt, Donna Hoggatt Rombs and Andrew J. Allbritton.

The following letters, contained in the court file, from school counselor Selma Green and others, are typical of many such communications sent to Natchez from New York and Mississippi in behalf of the Hoggatt family to the court prosecutor, Toussaint, Manfred Eidt, and social services personnel of the Mississippi Department of Human Services, Eileen Anderson, Ashley Junkin, and Ginger Johnson.

415 Washington Avenue

Oxford, MS 38655

August 25, 2000

[sent to MDHS workers Ashley Junkin and Ginger Johnson]

150 East Scott Drive

Natchez, MS 39121

Dear Ms. [sent to Ashley Junkin and Ginger Johnson]:

I am writing this letter in reference to the Hoggatt family. I have known them for the last seventeen years and have found them to be loving and caring people. It was after the home schooling of the children that I got to work with the three oldest children as their counselor. [There] was no doubt in my mind that the children were ready for middle school, for when we gave the achievement tests, they were on target with the rest of the children their age level. Therefore, they were placed with their chronological grade level.

During that year, Ethan, the eldest, was in the 8^th grade and won Woodmen of the World Award. This award was given to the person who had the highest score on the history test. The next year, Isaiah, the second son, only missed receiving the same award by one point. All three children seemed to have been well adjusted socially and intellectually. Micah, the third child, was an average student and a real boy.

As we followed the two oldest boys through high school, they received many academic honors. Ethan received the Construction TECH 1 Award, and he and Isaiah both were placed in the top 10% in the national Spanish Exam for 3^rd-year Spanish. Isaiah received honors in French as well.

As Jehovah’s Witnesses, they did not appear to be deprived of what was needed to be well-adjusted children. Their travels during the summer included visits to Portugal, Spain, Belize, and France. Their religion exposed them to many cultures and people from all around the world. In my opinion their religion made them socially, emotionally, and morally sound. Their family was well spoken of in our community as well as respected.

Sincerely,

/s/ Selma J. Green

Selma J. Green

Retired Counselor

2 Lakeview Drive

Katonah, NY 10536

Re: Ashley Junkin [MDHS caseworker]

Dear Mrs. Junkin,

I am writing this letter as a friend of Dr. and Mrs. Eric Hoggatt. The Hoggatts are good friends of our family and we’ve had the opportunity over the last couple of years to spend much time together, including spending our vacation together last summer. While I could relate in detail about the excellent reputation that Eric and Vicki have in the local community, I’ll confine this letter to a few personal comments.

My wife and I have two children, our daughter is married and our son is 17. As concerned parents, we have always been seeking out the best association for our children. Thus, when we first met the Hoggatt family, we were very excited to find a family that worked together, shared many of the same values as we did, and were involved in their children’s lives. Since we have many common interests, it has been very easy to do things together as families. Since both Eric and Noah play basketball very well, my son and I, along with other mutual friends, have played basketball at the Hoggatt’s home, in local gyms and at an exercise club where the Hoggatt family has a membership, on many, many occasions. For a period of several weeks last summer, we met every week at the Hoggatt’s home for a weekly ball game. During this time, I’ve been impressed with the excellent standard that the Hoggatt’s have set. Whether it was playing ball, socializing afterward, or in any other circumstance, Eric and Vicki have always been consistent in handling issues that came up, moving to resolve any problems, and looking for a good and fair solution for everyone involved. This standard, added to their outstanding hospitality and loyalty as friends, has really helped deepen out relationship as families.

Noah has always been a full participant in the activities we’ve been involved in. In fact, it was often Noah that would bake cookies, or make dessert for us to enjoy after the ball game. He can best be described as simply an integral part of the family, working together, playing together, laughing together, eating together, and so on. Noah and I have had several occasions to talk personally together and I have always found him to be extremely courteous and involved in the conversation. Since I have a 17-year old son, I’m well aware of the challenges that youths face today, and I know that Noah has had his fair share. To his and his family’s credit, I have seen problem’s arise, problems addressed and resolved, and the family continuing to work together. In this day and age, that is no small task and I appreciate the effort of all involved to accomplish that.

I’m providing this letter as a very brief summary of our family’s relationship with the Hoggatts. In looking at Noah’s welfare, I am of the strongest opinion that he will achieve his best and rise to the caliber of person that he is, by continuing to work alongside his father and mother in the nurturing atmosphere that they provide. I have no doubt that Noah will continue to thrive alongside his family. He is not a rebellious son but rather an intelligent and sensitive individual who is being influenced by those who are not looking out for his best long-term interests. Eric and Vicki understand their son and do know what is in his best interest. Any course of action other than having Noah at home with is parents is, at best, a guess with unknown outcome.

If I can be of any further assistance, please don’t hesitate to contact me. I can be reached at (203) 486-2571.

Sincerely,

/s/ J. D. Morris

Intentional Defamation of Character for the purpose of witness intimidation and obstruction of justice has continued by both extended family members and the Adams County Court Personnel. On or about September 25, 2000, Judge John Hudson declared loudly in front of court personnel and others, “I’m a United Methodist, and if Isaiah had done half of the things you said in there, he would have been thrown out of Millsaps a long time ago”, thus publicly insulting an attorney licensed in Mississippi for over 25 years by intimating she had just committed perjury. The bound Criminal Affidavit gives the account of Judge Hudson on or about January 17, 2003, telling his clerk, Vines, that he had not stated to attorney Victoria Hoggatt that the law was that she could come to Natchez and view the whole court file, including CASA and MDHS records. On or about January 17, 2003, Circuit Clerk M.L. Vines stated to Marisa Allbritton and her daughter, the sexual assault survivor, as well as Ethan Hoggatt a legal assistant from Tyler, Texas, and to the Circuit Court staff that Victoria Hoggatt had lied to court personnel. The continuing defamation of character by the Mississippi Judge and Clerk, recorded on the video attached to the Criminal Affidavit, Video 6, filmed on May 3, 2006 shows Circuit Clerk M.L. Vines publishing to Eric Hoggatt, to Sascha Hoggatt, to the camera man, to Clerk M.L. Vines’ staff, and to bystanders in the Circuit Clerk‘s office, that Vines had threatened ‘to call the sheriff to have you removed’ because attorney Victoria Hoggatt had attempted to “remove the court file” from his office, which Vines knows is both a patent lie and intentionally defamatory, and a criminal allegation of wrong conduct to intimidate a court officer. Intentional fraudulent allegation of criminal activity also constitutes defamation per se for civil prosecution in Mississippi.

Marisa Allbritton and her daughter, the sexual assault survivor, as well as Ethan Hoggatt a legal assistant from Tyler, Texas, and Circuit Clerk M.L. Vines and his staff were all witnesses to the fact, recorded on audiotape, that on or about January 29, 2000, M.L. Vines offered to ‘call the sheriff to have you removed’ when Marisa Allbritton, mother of the sexual assault victim was in his office to swear out an affidavit to the Petition for Disclosure, accompanied by her daughter, the sexual assault survivor then age 15, and that the court file was neither requested nor proffered on that date.

Vines was upset January 29, 2000, and was excitedly stating false and defamatory accusations at attorney Victoria Hoggatt, viz. , “You lied to me”, “You misrepresented who you were“, “Are you even an attorney?”, and “You lied to my deputy”. Victoria Hoggatt assured him that she had not lied to him, but that Judge John Hudson had in fact stated on legally recorded audiotape (Mississippi to Tyler, Texas) on or about December 28, 2001 that she had a legal right to view all court records, including MDHS and CASA files. When she further offered to let Vines listen to the audiotaped conversation with his deputy clerk made on or about January 14, 2003, so that Vines could ascertain that she had never lied to him or to his deputy, Vines began asserting he was about to “call the sheriff to have you removed”. On or about January 14, 2000, Judge John Hudson fraudulently stated to Clerk Vines that he had not stated to attorney Victoria Hoggatt that she could come to Natchez, Mississippi from her home in Tyler, Texas and view all court records, including MDHS and CASA records. Judge Hudson further stated to all court personnel to allow no inspection of any records, knowing that such denial of inspection was illegal.

On or about July 11, 2003, someone in the Adams County Circuit Clerk’s office sent Vines’ Deputy Circuit Clerk Melody Bradley running to tell persons believed to be Mississippi Department of Human Services officials across the street to call the police to “take the camera away from her”. A very large and intimidating Natchez City Police officer, believed to be Carl Houston, responded to the request of the Mississippi Department of Human Services person in the video, that “they need to come take the camera away from her”, and did jerk the camera Victoria Hoggatt had just used to film Circuit Clerk Vines and his staff, off of her neck outside a public building, which was recorded on video. Circuit Clerk Vines is documented on the May 3, 2006 video denying that he directed Deputy Circuit Clerk Melody Bradley to run across the street to the offices of the Mississippi Department of Human Services on July 11, 2003, but Deputy Circuit Clerk Melody Bradley didn’t think it up herself.

One thing that can be said for Natchez, Mississippi, is that they have SOME HUGE policemen! Hey, Manferd!

Isaiah Hoggatt, believed to currently be a resident of Baton Rouge, Louisiana, is still spreading false and defamatory information with the intention of damaging his parents’ reputation, professional and otherwise, such as most recently, by interstate wire on or about May 25, 2006, that his mom, attorney Victoria Hoggatt, had “siphoned” and “stolen” trust funds, “stolen money”, “who disobey[ed] civil officers” and “west[ed] court assets with your stupidity”, and publishing the same defamation that Wilton Hoggatt and Daphne Woods Allbritton may or may not have stated to Agent Songer, and that Agent Songer had stated to Marisa Allbritton, that “the state of Mississippi found [Victoria Hoggatt] unfit to take care of Noah [Hoggatt]”.

A person could say nothing more defamatory about a parent. Even the Mississippi Judge commended Eric and Victoria Hoggatt for raising exceptional children who had ‘everything going for them’ on the court record that he instructed his clerk, M.L. Vines, not to send to the Mississippi Supreme Court on appeal. Under Mississippi law, a person's parental rights cannot be terminated absent clear and convincing evidence that the parent either abandoned or abused the child or is so unfit as to warrant termination. But no party to the Mississippi proceedings was a resident of the state of Mississippi, a fact known to Mississippi officials. Toussaint, Eidt, and Judge Hudson always knew that Mississippi had no standing to abrogate constitutionally protected rights of New York parents over their New York resident child, and that all their actions to assist Louisiana resident Wilton Hoggatt, Virginia residents Warren, Dorothy, and Craig Johnson, and Texas residents Ronnie and Donna Rombs were illegal. The disgrace and grief intentionally inflicted by Mississippi officials by their egregious assistance to Warren Johnson and Wilton Hoggatt to accomplish their admitted threat to “pluck those children from Vik one by one” and to defame the character and reputation of Eric and Victoria Hoggatt in retaliation for conscientious parents trying to protect their own children, and for assisting the sexual assault victim, had absolutely no legal authority whatsoever, but was intentionally cruel and malicious.

Defamation of the year for the year 2004, transmitted by interstate wire by Isaiah and Noah Hoggatt to anyone willing to listen, was that the parents of the aggravated incest victim had tried to extort monies from Wilton Hoggatt, stating that Mike and Marisa Allbritton would “call off the prosecution” if paid off. Isaiah Hoggatt related the intentional lies defaming the reputation of the sexual assault victim’s parents, as early as 2001, by alleging attempted extortion of funds by interstate wire to Donna Hoggatt Rombs of Alvin, Texas, who may have believed them, but who in any case was publishing them to others by telephone from Alvin, Texas by December of 2002.

Defamation of the year for the year 2005 published by Isaiah Hoggatt, was that Isaiah and/ or Noah Hoggatt used to drug their mother, Victoria Hoggatt’s, coffee, or Dr. Pepper, for her “violent mood swings” which was the only time that she “acted like a real mother”.

On or about April 1, 2003, Isaiah Hoggatt, stated under oath in Natchez, Mississippi that he believed that the child’s parents, Mike and Marisa Allbritton, had made up and falsely reported the aggravated incest sexual assault to commit extortion against Allbritton, having been so told by his grandfather, Wilton Hoggatt, which is as vile and false a thing as one could think up to say about a parent. Except for Donna Hoggatt Rombs intimation, “Do you think one time with A.J. caused all these problems? Have you ever considered that maybe her father is doing something to cause her to commit suicide?” relayed by telephone from Alvin, Texas. Rombs published intentionally false statements about the sexual assault survivor’s parents, Mike and Marisa Allbritton, of Denham Springs, Louisiana, wanting money, to Victoria Hoggatt and to others. On the May 3, 2006 video, Franklin Parish Louisiana Sheriff Steve Pylant asserts, “So this is about money.”

Warren Johnson, in concert with other extended family members, has spread since at least the year 1999 intentional and egregious defamation to court officers, law enforcement personnel, and private citizens, intentionally false allegations that Eric Hoggatt had “thrown his son Isaiah through a plate glass window” in New York, that Warren Johnson had “in my hand a police report from the Oxford Police” who had come, “with sirens wailing” because he had “beaten the hell out of Ethan”, that Eric Hoggatt couldn’t work for the federal government because he had a criminal record, said to have originated and been told to Warren Johnson of Virginia by Pharmacist Tessa Hoggatt Allbritton of Haughton, Louisiana. Tessa Hoggatt Albritton additionally spread intentional defamation of character through Warren and Dorothy Johnson and Wilton Hoggatt, that perhaps Eric and Victoria Hoggatt had participated in anti-war protests, which all parties knew to be patently false.

Wilton Hoggatt, on the September 2000 court record that Judge Hudson directed his clerk M.L. Vines not to send to the Mississippi Supreme Court, admitted that he had indeed been spreading about that he had seen Victoria Hoggatt “kiss Micah on the mouth and acted all sexy around him“, enough to make Wilton Hoggatt “sick to his stomach”. Craig Johnson has stated by interstate wire that Warren Johnson has been spreading about that he had been contacted because attorney Victoria Hoggatt had not paid back federal school loans, which Warren Johnson knew to be false and intentionally defamatory. Noah Hoggatt asserted to MDHS employee Eileen Anderson that his father Eric Hoggatt had called him a “Goddamned bastard”, which he later admitted was not true, as far back as August or September of 2000, and has continued to be more creative. As of July 25, 2006, he stated on recorded audiotape that he saw his father Eric Hoggatt, throw Micah [Hoggatt] “into a window”.

Wilton Hoggatt, Isaiah Hoggatt, Noah Hoggatt , Craig Johnson, Warren Johnson, and Tessa Hoggatt Allbritton knew the falsity of such defamation and uttered it for the express purpose of witness intimidation and as retaliation for exercising a federal right, to ‘punish’ Eric and Victoria Hoggatt for trying to keep their kids away from folks that were really violent, crude, dishonest, drug addicted, and nasty. The Constitutionally protected right to provide for, protect, and direct the upbringing of one’s own, is one of the most fundamental rights, subject to strict scrutiny, in the history of American jurisprudence.

As an interesting aside, Warren Johnson and Craig Johnson can be much more creative, such as when Craig Johnson presented himself to the Danville, Virginia police department four days after his wife left him, charging her with attempted murder by poisoning, saying it ‘tasted like arsenic’, and demanding his blood be sampled. All after Warren Johnson and Craig Johnson vowing, way before the alleged incident, that they would do whatever it takes, and spend whatever it takes, to “See the bitch buried under the jail”.

(7) Conspiracy MCA 97-1-1, Wire Fraud, Mail Fraud, Federal Sarbanes-Oxley Act of 2002, Material Alteration of the Docket

Vivian Brown-Toussaint violated Texas, Mississippi, and Federal criminal statues, including Section 1102 of the Sarbanes-Oxley Act, which amends the existing federal criminal obstruction of justice statute, making it a crime to corruptly alter, destroy or conceal a document with the intent to impair the object's integrity or availability for use in an official proceeding or otherwise obstruct any official proceeding. In November of 2001, Manfred Eidt had been warned by attorney Victoria Hoggatt by interstate wire from Tyler, Texas to Natchez, Mississippi that the parents of the Aggravated Incest victim and Eric and Victoria Hoggatt were in the process of collecting and submitting evidence of criminal conduct by the officers of the youth court of Adams County Mississippi, Wilton Hoggatt, and others, to the Justice Department, so that Eidt might opt out of the criminal conspiracy.

On or about December 28, 2001, Judge John Hudson was apprised of the likelihood of a civil rights lawsuit, to which he replied on audiotape, “Go ahead. You’ll lose.” Hudson, Eidt, and/or MDHS officials acted in concert to purportedly ‘file’ a grossly fraudulent interim order allegedly from some earlier hearing, held without the parents attendance, which is file stamped but not signed by the receiving clerk, on the same date, December 28, 2001 that Judge Hudson said, “Go ahead. You’ll lose.”

By January 29, 2003, Toussaint, Circuit Clerk Vines, County Judge John N. Hudson, MDHS workers Ashley Junkin, Ginger Junkin, and Eileen Anderson, and CASA worker Manfred Eidt had all been advised in writing through the United States mails, orally by interstate telephone, by facsimile by interstate wire, and in court pleadings, that their criminal activity had been reported in writing as a formal presentation to the United States Department of Justice, viz., the U.S. Attorney’s office in Tyler, Texas in January of 2003, prepared in conjunction with the parents of the Aggravated Incest victim, as well as concurrently submitted to the Mississippi Attorney General.

Toussaint, acting in concert with M. L. “Binky” Vines, Circuit Clerk of Adams County Mississippi, and Adams County Judge John N. Hudson, Manfred Eidt, and others knew that their removal and secreting of Toussaint’s fraudulent September 7, 2000 sworn affidavit from the court file, as well as their removal and destruction of a fraudulent ***Amended Motion*** authored and sent by Toussaint through the interstate mails to Victoria Hoggatt in Texas, on or about June 27, 2003, and additionally later removing, concealing, and destroying Eric and Victoria Hoggatt’s required “Qualified Certificate as to the Accuracy of the Record”, and “Proposed Corrections to the Record” from the court file, and substituting a fraudulent document labeled “Appellant’s Proposed Corrections to the Record”, and “Certificate as to the Accuracy of the Record”, prepared by Toussaint, who was the Appellee in an appeal before the Mississippi Supreme Court, intentionally impaired each of the official documents' integrity or availability for use in an official proceeding .

Prosecutor Toussaint, acting in concert with other Mississippi public officials, additionally intentionally impaired an official document’s integrity or availability for use in an official proceeding when they acted in concert with Adams County Circuit Clerk Helen Flowers to alter the docket to eliminate subpoena requests, and to later issue another fraudulent docket to make it appear that the trial judge’s illegal Order as to designation of the record had been timely filed and entered on the docket. Court officers corruptly altered the official docket repeatedly to hide their criminal activity, beyond not even listing the Hoggatts’ subpoenas. Compare the First Docket (CAS Exhibit 2) sent through the United States mails from Clerk Vines to the Mississippi Supreme Court on or about August 5, 2003, and the 2^nd Docket (CAS Exhibit 9) dated September 1, 2004 from Clerk Vines, sent to Victoria Hoggatt in Jourdanton, Texas by interstate wire and by mail on or about September 2, 2004.

Circuit Clerk of Adams County Mississippi Vines’ office staff advised attorney Victoria Hoggatt in Texas by interstate wire on or about September 2, 2004 that the “second docket” (CAS Exhibit 8, second fraudulent docket composed by Circuit Clerk of Adams County Mississippi Vines or his office staff)had been sent by them to the Mississippi Supreme Court. The Mississippi Supreme Court docket contains no such filing of the second trial court docket, which for the first time listed subpoena requests.

Years of criminal conduct of the Mississippi youth court as to notice, opportunity to be heard, and right to subpoena witnesses, is documented in the Petition for Disclosure, and on the court transcript record proper. Continuing criminal conduct was documented and sent to the Mississippi Supreme Court in a Petition for a Writ of Emergency Assistance and Other Extraordinary Collateral Relief, asking for supplementation of the record and discipline of prosecutor Toussaint, the Mississippi judge, Circuit Clerk M.L. Vines, as attorneys that were continuing to frustrate appeal.

At the time of filing their Petition for a Writ of Emergency Assistance and Other Extraordinary Collateral Relief on or about November 17, 2003, Eric and Victoria Hoggatt had no idea that documents to which they were referring were not in fact even in the possession of the Mississippi Supreme Court as part of the appellate record.

Special Assistant Attorney General Mary Jo Woods kept objecting that information submitted was “outside the record”. Perhaps Mary Jo Woods was aware that the July 18, 2003 Notice of Appeal of the trial judge’s Order Designating the Record, and the Order Designating the Record itself were not in the appellate file? Special Assistant Attorney General Mary Jo Woods repeatedly referred to Judge Hudson’s Order Designating the Record, and to Toussaint’s fraudulent replacement motion that was substituted for Toussaint’s ***Amended*** Motion that contained MHDS and CASA records.

At such date that the Mississippi Attorney General knew of the existence in the appellate court file of prosecutor Toussaint’s fraudulent sworn ‘petition’ of September 7, 2000, and of its egregiously fraudulent nature as to basis for jurisdiction, and additionally knew that such ‘petition’ had never been actually filed in the youth court division of the Adams County Court, then on that date, the Mississippi Attorney General knew that no cause had in reality ever been initiated in Mississippi, and yet continued to put the Hoggatt family through over three years of appellate proceedings, in order to protect the criminal conduct of Judge Hudson, Clerk Vines, Manfred Eidt, and prosecutor Toussaint, as well as to protect Assistant Attorney Generals Patricia Marshall and John Gadow from criminal prosecution for directing denial of access to the court file, and for interference with service of process and obstruction of justice.

Special Assistant Attorney General Mary Jo Woods studiously avoided referring to Toussaint’s fraudulent affidavit in the appellate court file, referring only to the sham orders of Judge John Hudson of September 2000 that allegedly resulted from the fraudulent never filed petition. In her Appellee’s Brief filed November 15, 2004, Mary Jo Woods states “This case originates in proceedings in the Adams County Youth Court”, though she knew of the existence of Toussaint’s fraudulent September 7, 2000 sworn document in the appellate file. The Mississippi Attorney General was well aware of the non-residence of all parties, of Mississippi’s lack of jurisdiction, and of the non-existence of any petition ever having been filed in the Youth Court of Adams County Mississippi.

The address for the Office of the Clerk of the Mississippi Supreme Court is the same address as the Mississippi Attorney General, viz., 450 High Street, Jackson, Mississippi, 39205.

At such date no later than September 2, 2004, that the Mississippi Attorney General had possession of Circuit Clerk M.L. Vines’ two patently fraudulent “True and Certified” dockets, Mary Jo Woods had irrefutable evidence of the criminal conduct of Vines, FBI Agent Songer, Eidt, and Judge John Hudson, as to their concerted illegal interference with the subpoena power. Woods cannot claim ignorance, as she was the Special Assistant Attorney General who wrote the response in opposition to the Hoggatts’ Petition for an Emergency Writ of Special Assistance and other Extraordinary Collateral Relief, filed November 17, 2003, after receipt of 42 audio exhibits of Mississippi Court personnel, MDHS workers, the sex offender himself, Wilton and Tessa Hoggatt discussing Wilton Hoggatt and Daphne Allbritton Woods assistance to the fugitive, and audio files of Adams County Sheriff, the Mississippi sheriff’s deputy who knowingly misrepresented the charge for the youth court summons, and video files of Eidt, Vines, MDHS officials and the Mississippi police officer jerking the camera off an attorney’s neck at the direction of those who had just been filmed to document obstruction of justice, ad nauseum.

Special Assistant Attorney General Mary Jo Woods was guilty of Misprision of Felony and joined the criminal Conspiracy against Rights for a certainty when she had knowledge of the egregious criminal conduct of the Mississippi public officials that Special Assistant Attorney General Mary Jo Woods noted by comparison of the two “True and Accurate Certified” “dockets”, one of which may or may not have been ever filed with the Mississippi Supreme Court by the trial court . The September 2, 2004 2^nd or 3^rd Docket may actually never have been filed with the Mississippi Supreme Court, as represented by Clerk Vines by interstate wire on or about September 2, 2004, to attorney Victoria Hoggatt in Texas, as the September 2, 2004 2^nd or 3^rd Docket is not listed as ever filed on the certified Mississippi Supreme Court docket for the case. (See CAS Exhibit 9, Mississippi Supreme Court certified docket, three pages) Whether or not the Mississippi Attorney General directed the Mississippi Supreme Court Clerk not to file the amended docket, and/or directed the Mississippi Supreme Court Clerk not to deliver the amended docket to the Mississippi Supreme Court Justices as part of the official record for appeal, as required by law, may be ascertained by investigation.

The Mississippi Attorney General had constructive and actual knowledge of the first fraudulent docket sent to the Mississippi Supreme Court on the appeal of an order entered May 2, 2003, and that such fraudulent ‘docket’ had no subpoena requests from the parents listed. (See CAS Exhibit 2, 1st Docket), as well as no entry of the trial court’s Order Designating the Record. The docket composed by the office of Circuit Clerk M.L. Vines over one year later revealed clearly to the Mississippi Attorney General that subpoenas were twice requested by the parents, but no issuance of the subpoenas nor return of subpoenas was noted on the second docket for those subpoenas.

4/27/2003 REQUEST FROM ATTY VICTORIA HOGGATT FOR SUBPOENAS TO BE ISSUED FOR HEARING ON APIRL [sic] 1 at 9:00 (See CAS Exhibit 8, 2^nd Docket, Page 1, entry 21)

7/05/2003 LETTER FROM ATTY HOGGATT ADVISING THAT T.K. WATSON IS GOING TO REVIEW THE FILE AND ASSIST IN ARGUING OF MOTION OBJECTING TO DESIGNATION OF RECORD WITH LIST OF WITNESSES TO BE SUBPOENED. (See CAS Exhibit 8, 2^nd Docket)

Pointedly, the certified court record that was read and referred to by Special Assistant Attorney General Mary Jo Woods in her appellate pleadings explained the variance between the two “True and Accurate Certified” dockets, one of which has 44 entries, the second of which has 76 entries. Prosecutor Toussaint, Eidt, and Judge John Hudson directed Adams County Circuit Clerk M. L. Vines and his deputies not to issue Dr. Eric Hoggatt and his wife, attorney Victoria Hoggatt’s subpoenas to all hearings to which they subpoenaed witnesses in the cause, canceled scheduled hearings when out of state witnesses showed up, acted in concert with others to make sure the would-be subpoenaed witnesses did not attend the hearings, and then acted in concert to falsify the docket.

The July 10, 2003 record reads:

MRS. HOGGATT: Oh. Well, anyway, so you’re - - well, we aren’t going to talk about what your secretary said. In the court file I have a – a – um, legal request for witnesses that could come into this courtroom, this lady being one of them, Manfred Eidt being one of them, and one person told me that you told, called - -

MR. LETARD: - - Objection, your Honor, to the hearsay.

MRS. HOGGATT: - - the Circuit Clerk and told them to go ahead - -

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: - - Sustain the objection.

MRS. HOGGATT: Why were my subpoenas - - and then I was told that you said not to issue my subpoenas.

MR. LETARD: - - Objection, your Honor, to the hearsay.

MRS. TOUSSAINT: Objection.

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: Sustain the objection. And that’s not true. Go ahead.

MRS. HOGGATT: Why were they not issued?

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: I sustained the objection. (R 204)

Even the second fraudulent trial court docket also omits the Hoggatts’ Qualified Certificate as to the Accuracy of the Record and Proposed Corrections to the Record, which were sent to Toussaint per Clerk Vines interstate request on or about August 27, 2003 from Texas, as required by the Mississippi Rules of Appellate Procedure. The second trial court docket does include an intentionally fraudulent entry, entered as “Appellant’s Proposed Corrections to the Record”, filed by Appellee Toussaint, after she acted in concert with Vines and Hudson to remove and conceal the true Appellants, Eric and Victoria Hoggatts’ bona fide required court documents from the court file. The Hoggatts’ Qualified Certificate as to the Accuracy of the Record and Proposed Corrections to the Record, official court documents, last known to be in the possession of prosecutor Toussaint, are presumed destroyed by court officers. (See Criminal Affidavit Exhibit G)

Toussaint called interstate to Texas on some date after August 27, 2003, to state that Judge Hudson had set a specific hearing date on the Hoggatts’ Qualified Certificate as to the Accuracy of the Record and Proposed Corrections to the Record, as required by Mississippi Rules of Appellate Procedure. Toussaint later called interstate to Texas to say that Judge Hudson said such hearing would not be held, because it would be held in the Mississippi Supreme Court. Both Toussaint and Hudson knew that such assertion was contrary to the Mississippi Rules of Appellate Procedure . Any Order Setting Hearing on the Hoggatts’ Qualified Certificate as to the Accuracy of the Record and Proposed Corrections to the Record, if one did in fact ever exist, has been removed, and concealed, and is presumed destroyed by court officers.

During the course of the prosecution of the appeal, the Mississippi Supreme Court clerk was repeatedly contacted by attorney Victoria Hoggatt to see if the Hoggatts’ Qualified Certificate as to the Accuracy of the Record and Proposed Corrections to the Record might have somehow migrated to Jackson, Mississippi, but was given no reply from the Mississippi Supreme Court Clerk. Whether or not the Mississippi Attorney General directed such response, or lack thereof, for the purpose of obstruction of justice is not known, but may be reasonably inferred.

While still living in Texas, attorney Victoria Hoggatt asked by written request that the Mississippi Supreme Court Clerk Betty Sephton mail her the record to prepare the appeal. The Mississippi Supreme Court had specifically directed attorney Victoria Hoggatt to provide designated record excerpts, as required by the Mississippi Rules of Appellate Procedure, which is impossible to do, if you can’t copy anything in the file without risking contempt of court from the trial judge. At that time, Eric and Victoria Hoggatt did not know that Judge Hudson had conspired with Vines and Toussaint to not file Hudson’s July 10, 2003 Order Designating the Record, and to remove its entry from the docket sent the Mississippi Supreme Court. Attorney Victoria Hoggatt believed, as intended by Hudson and Toussaint, that she was operating under the constraints contained in Hudson’s July 10, 2003 Order Designating the Record.

Mississippi Supreme Court Clerk Sephton and/or her deputies stated by interstate telephone wire to Texas that they could mail the record to her if Victoria Hoggatt were an attorney then living in Mississippi, but couldn’t mail it to Texas. Whether or not the Mississippi Supreme Court Clerk’s office personnel were so advised to relay this message by Mississippi Assistant Attorney General Mary Jo Woods or other persons in the Mississippi Attorney General’s office is not known, but doesn’t sound like something a deputy clerk would make up on her own, without asking advice from the state’s attorney.

So the Hoggatts moved back to Mississippi in April of 2005, and requested the appellate file from the Mississippi Supreme Court Clerk, Betty Sephton again, which was again refused to prepare record excerpts. On or about November 5, 2004, Mississippi Special Assistant Attorney General Mary Jo Woods specifically objected to the file being sent to attorney Victoria Hoggatt as requested, in Woods’ Response in opposition to the Hoggatts’ Motion to Compel Production of Documents and to Compel Amendment of the Docket. It is presumed that the Mississippi Attorney General was aware of Toussaint’s fraudulent and never filed September 7, 2000 ‘petition’ then contained in the appellate file, and was also aware that attorney Victoria Hoggatt had by that time been unable to view the document. It may also be reasonably be inferred that the Mississippi Attorney General may have had something to do with the Mississippi Supreme Court Clerk ‘filing’ Clerk M.L. Vines second fraudulent docket that listed the subpoena requests, but not entering such the second fraudulent docket as having been filed on the official Mississippi Supreme Court docket, since MDHS official Raymond Holeman states on audiotape that he was directed by Mississippi Assistant Attorney General John Gadow to direct the subpoenaed MDHS employee, Ashley Junkin, not to attend the July 10, 2003 hearing.

On or about December 31, 2005 Attorney Victoria Hoggatt asked by written request of Supreme Court Clerk Betty Sephton that she itemize the seven orders listed on a certified copy of the Mississippi Supreme Court Docket as filed with the Supreme Court on or about July 24, 2003. (See CAS Exhibit 11)

The Mississippi Supreme Court docket lists each of the seven entries identically, as only “Trial Court Order received - Hon. M.L. Binkey Vines”. Such listings made it impossible to ascertain if Judge Hudson’s Order Designating the Record was among the seven July 24, 2003 entries generically listed on the official Mississippi Supreme Court Docket as only “Trial Court Orders received”. Though no response was ever forthcoming from the Mississippi Supreme Court clerk as to identification of those entries, the letter contained in the appellate record from Adams County Clerk Vines to Mrs. Sephton did answer the question, that the July 10, 2003 Order Designating the Record was not among the orders listed as filed with the Mississippi Supreme court on July 24, 2003, a fact not discoverable until January of 2006, when the appellate record was received through the United States mails from the Mississippi Supreme Court to prepare the Petition for a Writ of Certiorari to the United States Supreme Court.

There is no separate entry, ever, on the Mississippi Supreme Court Docket for the filing of Hudson’s Order Designating the Record, though it has now been inserted in the appellate file as timely filed. The first five entries on the Mississippi Supreme Court Docket cannot be the July 10, 2003 Order Designating the Record, as the filing dates predate the alleged time of execution of the fraudulently file stamped Order Designating the Record .

The sixth entry on the certified Mississippi Supreme Court Docket is the Court Reporters acknowledgement letter, and the next seven entries are those listed generically, as above, “Trial Court Order received - Hon. M.L. Binkey Vines”, sent under the cover letter which designated each document sent on or about July 24, 2003 from M.L. Binky Vines. It is therefore assumed that Hudson, Vines, and Helen Flowers had not by the date July 24, 2003 decided to file the July 10, 2003 Order Designating the Record, though Vines and his deputies had sent by interstate mail a purported copy of that order to Texas by interstate mail, on or about July 22, 2003, that contained a fraudulently dated file stamp, unsigned by Vines and his deputies. Receiving such a document would have led a reasonable person to believe that it had indeed been filed in the court record. Creating such an impression was the intention of Clerk Vines and Judge Hudson.

Additionally, Adams County Circuit Clerk Vines’ deputy clerk Helen Flowers sent to attorney Victoria Hoggatt in Texas, by interstate mail, a copy of what she represented to be the court file that was to be transmitted to the Mississippi Supreme Court, which contained the fraudulently file stamped Order Designating the Record. If the July 23, 2003 letter from Vines to the Mississippi Supreme Court is in fact correct as to itemization of items sent for the record, then Helen Flowers did not at that time transmit the Order Designating the Record in the appellate court file, and it most probably had not been ‘filed’ by Clerk Vines by that date, as the fraudulently file stamped Order Designating the Record was not included in the “True Certified” August 3, 2003 docket filed with the appeal by Clerk Vines.

Judge John Hudson and prosecutor Toussaint thus solved the problem of prosecutor Toussaint’s ***Amended *** motion containing MDHS and CASA records, and Judge John Hudson’s not wanting Victoria Hoggatt to appeal his Order Designating the Record, by concealing and removing the Order Designating the Record, or perhaps never filing it at all.

If in fact Special Assistant Attorney General Mary Jo Woods knew that Hudson’s Order Designating the Record was not in fact contained in the Mississippi Supreme Court appellate file, and fraudulently constructed pleadings referring to it as if it were in the appellate record, or if Mary Jo Woods knew that the Notice of Appeal of that fraudulently file stamped July 10, 2003 order had been not sent up on appeal as required by law, and acted in concert with Vines, Hudson, and Toussaint to conceal the July 18, 2003 Notice of Appeal, Assistant Attorney General Mary Jo Woods thereby entered, continued, and furthered the criminal conspiracy against rights.

If in fact Special Assistant Attorney General Mary Jo Woods knew that Adams County Circuit Clerk Vines’ second docket that he sent through the interstate mails to Victoria Hoggatt in Texas on or about September 2, 2004, and which Vines represented had been sent to the Mississippi Supreme Court, had never in fact been filed with the Mississippi Supreme Court, or if the Mississippi Attorney General advised the Mississippi Supreme Court Clerk not to file the “True and Certified Copy” of the less fraudulent September 1, 2004 docket in the appellate record, which contained documentation of the subpoenas requested by Eric and Victoria Hoggatt, which attorney Victoria Hoggatt referred to extensively in her Petition to the United States Supreme Court in her Petition for a Writ of Certiorari, then most certainly Special Assistant Attorney General Mary Jo Woods entered into a conspiracy to obstruct the orderly administration of justice, and perhaps violated Section 1102 of the Sarbanes-Oxley Act, which amends the existing federal criminal obstruction of justice statute, making it a crime to corruptly alter, destroy or conceal a document with the intent to impair the object's integrity or availability for use in an official proceeding or otherwise obstruct any official proceeding.

As of January 2006, the box sent by the Mississippi Supreme Court containing the appellate record contained a facsimile cover sheet for the September 2, 2004 copy of the second fraudulent docket, whereas the January 6, 2006 “True Copy” of the Mississippi Supreme Court certified docket prepared by the Mississippi Supreme Court Betty Sephton contains no listing of such September 1, 2004 second docket ever being filed in the Mississippi Supreme Court. Interestingly, there is no file stamp indicating the second docket was ever filed in the trial court in Natchez, Mississippi, either, though the second fraudulent trial court docket document does contain an Adams County Circuit Clerk’s stamp saying that the fraudulent second trial court docket is a “True and Certified Copy”. Of what?

There is also no entry on the January 6, 2006 “True Copy” of the Mississippi Supreme Court certified docket prepared by the Mississippi Supreme Court Betty Sephton for the Notice of Appeal that has been fraudulently file stamped as to date filed by the Mississippi Supreme Court, nor is there an entry for the “Order Designating the Record”, though the box sent by the Mississippi Supreme Court in January 2006 did contain a facsimile transmission cover sheet dated September 2, 2004 from Clerk M.L. Vines showing that Judge John Hudson’s Order Designating the Record was transferred on that date, over a year after it was purportedly signed, as well as a copy of the actual Order Designating the Record with the facsimile transmission date of 9/2/04. By the 5^th of October, 2004, Special Assistant Attorney General Mary Jo Woods was referring to Judge Hudson’s Order Designating the Record, in her Response in Opposition to Appellants’ Motion to Compel Production of Documents and to Compel Amendment of the Docket, showing that she was aware of Judge Hudson’s Order Designating the Record being contained in the court file by that time.

If in fact Special Assistant Attorney General Mary Jo Woods knew that Adams County Circuit Clerk Vines’ did not send Judge Hudson’s Order Designating the Record to the Mississippi Supreme Court on or about July 23, 2003, and then she or some other person advised Mississippi Supreme Court Clerk Betty Sephton not to respond to attorney Victoria Hoggatt’s email request of a more specific itemization of the Official Supreme Court Docket’s listing of the seven “Trial Court Orders Received”, and Mary Jo Woods knew of the existence of Vines’ letter that would have made it possible for Mississippi Supreme Court Clerk Betty Sephton to comply with such request for itemization, and if Mary Jo Woods or some other person in the Mississippi Attorney General’s office so acted in order that the fact might be concealed that Judge Hudson’s Order Designating the Record was not among those generically listed items, well, it just wouldn’t be nice, as she knew that deprivation of rights of due process of law and equal protection of the laws, including the right to designate the record for appeal and the Mississippi court’s interference with the subpoena power, as well as other intentional criminal acts committed by the Adams County Court, were the essential elements of the United States Supreme Court cert petition.

The office of the Mississippi Supreme Court Clerk has a policy of returning exhibits to the party that sent them in, yet removed, concealed, and destroyed thousands of dollars worth of audio and video exhibits that were attached to the Hoggatts’ Petition for an Emergency Writ of Special Assistance and other Extraordinary Collateral

Relief, filed November 17, 2003. Such destruction made an appeal of denial of the Hoggatts’ Petition for an Emergency Writ of Special Assistance and other Extraordinary Collateral Relief to the United Supreme Court impossible.

The Hoggatts’ Petition for an Emergency Writ of Special Assistance and other Extraordinary Collateral Relief coincidentally included exhibits of audio recording of Assistant Attorney Generals Patricia Marshall and John Gadow, and asked that the Mississippi Supreme Court order an investigation under its plenary power to determine the role of the Mississippi Attorney General in denial of access to court records.

The Petition for an Emergency Writ of Special Assistance and other Extraordinary Collateral Relief contained allegations made by MDHS supervisor Raymond Holeman, on legally recorded audiotape, that Assistant Attorney General John Gadow had directed him that MDHS worker Ashley Junkin was not to attend a hearing July 10, 2003, to which the Hoggatts had requested and paid for a subpoena to be issued to MDHS worker Ashley Junkin. The Petition for an Emergency Writ of Special Assistance and other Extraordinary Collateral Relief contained, as well, recorded statements by Assistant Attorney General John Gadow denying such instruction to MDHS supervisor Raymond Holeman, and recorded statements by MDHS worker Ashley Junkin fraudulently denying knowledge of the requested subpoena that requested her appearance at the July 10, 2003 hearing, as well as admissions by Holeman and Eidt that they had each spoken to Judge Hudson prior to the hearing, and admissions by Assistant Attorney Generals Patricia Marshall and John Gadow that they had each spoken with Judge Hudson or his court docketing secretary, the same court docketing secretary, Jeanine Wickham, that made the interstate phone call fraudulently stating that Adams County Judge would direct Clerk M.L. Vines to issue the Hoggatts’ subpoenas.

(8) PERJURY, Subornation of Perjury, CONSPIRACY, Perjury and False Declarations Before A Court

What little part of the court record was ever made available to Eric and Victoria Hoggatt documents that on or about March 6, 2003 and again on April 1, 2003, that multiple proffers of evidence by the Hoggatts, for impeachment purposes, including audiotaped conversations, offered to show that CASA Guardian ad Litem Manfred Eidt (R 83-84), witnesses Isaiah Hoggatt (R 164-166), Wilton Hoggatt, Noah Hoggatt (R 112-113), and Court Appointed Attorney Philip LeTard (R 174-177), were then committing perjury, were rejected by the trial court, in order to impede and obstruct evidence being entered on the record for criminal and civil prosecution.

On or about April 1, 2003, all youth court officers, at the suggestion of the trial court judge, even stipulated that Noah Hoggatt, then 19 years old and an adult for purposes of criminal prosecution, had made prior inconsistent statements that were offered into evidence to show that he was then committing perjury, all in an effort to make sure that Noah Hoggatt’s defense of his grandfather’s, Wilton Hoggatt’s, assistance to the Aggravated Incest perpetrator would not be included on the record. Judge Hudson, Eidt, Toussaint and LeTard acted in concert to make sure that the role of Mississippi officials in the conspiracy against rights would not be included on the record.

Noah Hoggatt on cross by Victoria Hoggatt

Line 29 Q. You did not say that? (R 106)

Line 1 A. I did not say that. (R 107)

Line 15 Mrs. Hoggatt: - - Your Honor, I would like to admit into evidence, and I can play it anywhere you’d like, for any part of the hearing you’d like, to show that this in Noah’s attitude, and that – that he did say that; that he is now committing perjury, which is a serious thing that some grandfather would play upon the love and trust of children to ruin and twist their minds…. (R 107)

Line 26 Mrs. Hoggatt: The tape says what I have just said, that Noah said, “Yeah, sure, mom, just have the FBI come make a clean sweep of all of us”, when he’s talking about - - also about his, grandfather’s participation in the - - Andrew Allbritton affairs …(R 107)

Adams County Court Judge John Hudson: What is this - - what is this - - what does the - - what does the tape purport to say? (R 108)

Adams County Court Judge John Hudson: So you’re making an offer of proof. Do you have any objection to that offer of proof being - -

[Court appointed attorney for W.N.H.] Mr. LeTard: - - No, sir.

Adams County Court Judge John Hudson: - - what was actually said so we don’t have to go listen to a tape?

Mr. LeTard: No, sir.

Adams County Court Judge John Hudson: OK. Go ahead.

Mrs. Hoggatt: Now you are saying I can admit into evidence the tape?

Adams County Court Judge John Hudson: I’m saying there’s no need to because they’re accepting that - - accepting your version of what was said as what was said.

Mrs. Hoggatt: Well…

Adams County Court Judge John Hudson: Why you need a tape - -

Mrs. Hoggatt: - - Who’s accepting my version of what was said?

Adams County Court Judge John Hudson: Everybody at the table.

Mrs. Toussaint [youth court prosecutor]: Yes.

Mrs. Hoggatt: They - - you all believe that he said, “Tell the FBI to come, make a clean sweep of all of us”?

Adams County Court Judge John Hudson: For the purpose of this hearing they’re saying that –

Mr. LeTard: - - For the purpose of this hearing, if that’s what you said that’s what the tape said, we’ll acknowledge that.

Mrs. Toussaint [youth court prosecutor]: We’ll accept that.

Mrs. Hoggatt: Okey-doke.

Mr. LeTard: OK. And that’s just so that we can get as much done as we can, So we’re willing to accept - - (R 110-111)

Mrs. Hoggatt: Okay, your Honor, I would like to admit into evidence the conversation that Noah does defend the aggravated incest , and the cover up, and the sending money, because we keep saying there’s no evidence, but N., himself, gave the evidence, whether or not Noah has been affected, whether or not Noah is defending it.

Adams County Court Judge John Hudson: Is this the conversation that – is this a tape that has been given to Mr. - - uh, Mr. Eidt?

Mrs. Hoggatt: No, sir.

Adams County Court Judge John Hudson: Oh, this is another tape?

Mrs. Hoggatt: Yes, sir.

Mr. LeTard: Your Honor, I think - - I don’t think Mrs. Hoggatt has, uh, complied with the rules of impeachment. I don’t think the tapes themselves are admissible evidence. (R 153)

A more pressing matter of public safety could scarcely be imagined than the apprehension of a fugitive wanted for Aggravated Incest, after the victim had attempted suicide over five years after the crime, and the involvement of the Hoggatts’ children, including perjury, to protect the criminal conduct of Wilton Hoggatt, Eric Hoggatt’s father, who was then aiding and abetting the fugitive for profit. Mississippi Special Assistant Attorney General Mary Jo Woods knew that testimony to that fact was not “outside the record”.

Eric Hoggatt on Direct (R 149, line 4)

Mrs. Hoggatt: Did your father perjure – did your mother perjure herself at Noah’s custodial hearing?

Mr. LeTard: Objection your Honor.

Adams County Court Judge John Hudson: Sustained.

Line 18 Mr. LeTard: Objection your Honor. Assumes facts not in evidence.

Line 21 Mrs. Hoggatt: Hmm. Did your father aid and abet Andrew Allbritton?

Line 22 Mr. LeTard: Objection your Honor.

Mrs. Hoggatt: He said there’s no proof in evidence and the man - -

Mr. LeTard: -- No facts in evidence.

Adams County Court Judge John Hudson: Into - - into - - you’ve got to have some factual - -

Mrs. Hoggatt: - - He was there. He – that’s called testimony. He was there when his father told him.

Adams County Court Judge John Hudson: We’ll you didn’t ask that. You asked a conclusion, you didn’t ask a factual question.

Mrs. Hoggatt: Did your father tell you he was sending money through Daphne Woods to Andrew Allbritton?

Eric Hoggatt: Yes.

Mrs. Hoggatt: Did he tell you many times? (R page 147, line 29)

Q. …[D]id your father tell you that he sent money, tens of thousands of dollars, to Andrew Allbritton?

Mr. LeTard: Objection your Honor.

Adams County Court Judge John Hudson: Sustained. (R 148, line 2)

Q. Has he knowledge of A.J. Allbritton’s whereabouts today? Your father [Wilton Hoggatt]?

A. I’m sure he does. (R 148, lines 7-9)

Mr. LeTard: Objection your Honor.

Adams County Court Judge John Hudson: Sustained.

In the Mississippi Attorney General’s April 22, 2004 Appellee’s Response in Opposition to Appellant’s Motion to Extend Length of Principal Brief and Appellee’s Motion to Strike Portions of Brief for the Appellant, Special Assistant Attorney General Mary Jo Woods intentionally and fraudulently states regarding the above audio exhibits proffered to prove that Noah and court officials were then committing perjury, “None of these exhibits were presented as evidence at trial.”

Wilton Hoggatt, from the time of the sham hearing on Toussaint’s fraudulent petition in 2000 and at all times subsequent thereto, including at the time of filing of the Petition for Disclosure, utilized the Mississippi court proceedings to obstruct justice. Extensive sworn testimony by Manfred Eidt, who illegally transported Noah Hoggatt, substantiates the truthfulness of those allegations. Manfred Eidt’s testimony on or about April 1, 2003, also vividly illustrates the effectiveness of such combined efforts of Toussaint, Judge Hudson, FBI Agent Songer and Manfred Eidt.

Manfred Eidt, - direct by Mr. LeTard, April 1, 2003, Natchez, Mississippi

A. Yes, I spoke with Agent Nathan Songer, who is out of the Monroe FBI office. (R 76 Line 12) …He said, well, are we going to charge him with anything, he said, no, he said the Bureau is never going to charge Mr. [Wilton] Hoggatt for anything.

Audiotape evidence submitted to the trial court to prove Manfred Eidt was committing perjury on or about April 1, 2003, as to the Hoggatts’ efforts to view custody decrees in person in October of 2001 was excluded by the Mississippi court. (R 82-83).

The Mississippi trial judge making intentionally false statements on the record may not be perjury, but it’s not nice, and obstructs the orderly administration of justice. Judge Hudson, on or about April 1, 2003 stated on the record as follows:

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: I don’t know if such a thing exists” …“the Aggravated Incest charge on Mr. Allbritton”. (R 137) Since the Mississippi judge was then holding in his hand the Federal Bureau of Investigation’s Most Wanted Fugitive Poster for Andrew Allbritton contained in the Hoggatts’ Petition for Disclosure, he most assuredly did know that a warrant was outstanding for the arrest of Andrew J. Allbritton for Interstate Flight to Avoid Prosecution for Aggravated Incest. (CP 96-98).

Prosecutor Toussaint’s and the Mississippi judge’s assistance to Wilton Hoggatt and FBI Agent Songer began no later than September 2, 2000 until frustration of service of process for Agent Songer the April 1, 2003 hearing. Such illegal assistance was documented extensively o the record, and through out the appellate process.

In return, Agent Cal Seig, Agent Songer’s supervisor, repeatedly stated that Mississippi court officials would never be investigated. The reason that Seig and Assistant Chief Division Counsel Daniel J. Wehr knew that Mississippi public officials and Franklin Parish Louisiana law enforcement would never be investigated nor charged with anything, is because in return for the illegal assistance of Vivian Toussaint, Manfred Eidt, Clerk Vines, and Judge John Hudson as to frustration of service of process to Agent Songer so that he wouldn‘t be compelled to testify under oath, Agent Songer and his supervisors kindly refrained from investigating the alleged violations of federal criminal statutes of the Mississippi court system.

The carefully orchestrated assistance of Toussaint, Vines, LeTard, and Hudson to Wilton. E. Hoggatt as he was testifying on cross-examination by Victoria Hoggatt on a hearing for disclosure of records, April 1, 2003 is apparent.

Victoria HOGGATT: …[D]id you, on a conversation with the father of the little girl who your brother in law committed aggravated incest --

PHILIP LETARD: -- Objection, your honor, that’s not in evidence. There’s no proof of it, he’s not been convicted of anything and it’s an improper question.

JUDGE JOHN HUDSON: Sustained.

MRS. HOGGATT: …[D]id the animosity begin when Eric Hoggatt went down in front of Sheriff Parker when Sheriff Parker asked you not to bail out A.J.?

MR. LETARD: Objection your Honor, the - -

JUDGE JOHN HUDSON: An objection has been lodged.

MRS. HOGGATT: When do you think - -

JUDGE JOHN HUDSON: No, you don’t have to answer that question. Ask another question. (R137)

PHILIP LETARD [Court appointed attorney for child]: Why do we spend this time cross-examining Mr. [Wilton] Hoggatt and make him a villain?… There’s no proof of it, he’s not been convicted of anything and it’s an improper question. (R 131-136)

Extensive testimony under oath on or about April 1, 2003, show that all parties in the youth court knew why Eric and Victoria Hoggatt wanted access to the records.

MRS. HOGGATT: Manfred, did I warn you over a year ago that – that Judge Hudson had invited me to sue him for a civil rights violation and that to not –

MR. LETARD: Objection to the form of the question. It’s not relevant.

MRS. HOGGATT: harm yourself.

MR. LETARD: It’s not – it’s not relevant.

JUDGE JOHN HUDSON: Sustained, and I suggest that you be careful in your comments, Mrs. Hoggatt. (R 101)

The fact that the court appointed attorney distributed youth court records to hostile extended family members, including Craig Johnson in Virginia and Isaiah Hoggatt in Louisiana, clearly demonstrates that the youth court was never trying to protect the confidentiality of youth court records, nor was ever acting in the best interest of the Hoggatts’ son, but has other motives. Such disclosure and interstate distribution constituted a criminal act in the State of Mississippi, for which attorney Victoria Hoggatt filed a criminal affidavit in Adams County, Mississippi, on July 18, 2003. Perjury by attorney Philip LeTard and Isaiah Hoggatt as to how court records were distributed to Craig Johnson in Virginia also was a criminal act.

The record clearly reveals that the judge and officers of the youth court had listened to audiotapes of Wilton Hoggatt (CP 45-46), and of Wilton Hoggatt’s daughter, Tessa Hoggatt Albritton, and of Victoria Hoggatt’s brother Craig Johnson discussing the relatives’ assistance to the fugitive prior to filing any motion by the officials of the Mississippi youth court to “terminate jurisdiction” filed without notice on or about March 5, 2003. Mississippi Special Assistant Attorney General Mary Jo Woods knew that testimony to egregious criminal conduct was not “outside the record”.

Manfred Eidt [CASA] on Cross by Mrs. Hoggatt

MRS. HOGGATT: OK. When did you first hear Eric and I tell you about the extreme animosity between Wilton and Mae Hoggatt against us for, uh, for –that had existed for a year prior to that time, about A.J. Allbritton?

MANFRED EIDT: I think it may – it was probably on that, that September the 7^{th , [}2000]. It was the first date you came –the date you came to, uh youth court after the – there – there was the incident at the Day’s Inn and then I think that was, uh, the Monday, the Monday after the incident, and I think that was the 7th, September 7^th [2000]. (R 80)

MRS. HOGGATT: OK, did we talk to you prior to the hearing, the first hearing?…[T]he first time we talked to you, did we tell you about it? (R 80)

MANFRED EIDT: I’m pretty sure, yeah; the first time, that was a concern. (R 81)

JUDGE JOHN HUDSON: I don’t know if such a thing exists” …“the Aggravated Incest charge on Mr. Allbritton”. (R 137) Cf. Wanted Poster for Andrew Allbritton (CP 96-98), contained in the Petition for Disclosure that Judge Hudson was then holding.

Evidence of Perjury and Inconsistent statements by Judge John Hudson, Isaiah Hoggatt, Prosecutor Toussaint, and Court Appointed Attorney for Minor, Philip LeTard

Adams County Judge John Hudson

Adams County Judge John Hudson knows that the youth court record includes, by statutory definition, all Mississippi Department of Human Services and CASA records and intake reports, required by law to be kept in one file, in the Circuit Clerk’s office, and was further aware that the docket, that Judge Hudson illegally attempted to omit from the appellate record, listed that an “Intake Report” was filed September 15, 2000.

9/15/2000 Intake report and order filed. (See CAS Exhibit 2, tenth entry)

July 10, 2003, the following exchange took place on the court record, in Natchez, Mississippi.

MRS. HOGGATT: …In Mrs. Toussaint’s objection to my designation of the record, she states that those documents that were considered for the March 6^th hearing would be made part of the appellate record. That she recommends that. I have been denied access to them this morning. I would like copies of them before me right now so that I can use them to argue designation of record because - -

JUDGE JOHN HUDSON: - - Who has denied you access to them this morning?

MRS. HOGGATT: This lady right here [Deputy Circuit Clerk.

Melody Bradley ]

Judge John Hudson: They don’t have those records. So you’ve not requested them of the proper place.

MRS. HOGGATT: Yes, sir, I did yesterday.

JUDGE JOHN HUDSON: They don’t have the records. They have not denied you anything. That - - what you’re talking about are not court records. You’re talking about social services records, which are not housed at the Circuit Clerk’s office and are not part of the official record of this - - of this court.

JUDGE JOHN HUDSON: I understand what you’re saying. You made an erroneous statement, that they denied you, and I’m not going to let you make erroneous statements in that they denied you these records. They don’t have those records to deny them to you. They’re not part of the official court record of this court. They are social services records. What you’re talking about are social services records and they’re not housed at the Circuit Clerk’s office. They’re not part of the record of this court, the legal records of this court.

MRS. HOGGATT: Why were they provided to me as documents necessary for argument of this motion, March 6^th?

JUDGE JOHN HUDSON: They weren’t provided to you by the Circuit Clerk. They were - -

MRS. HOGGATT: - - No, they were provided by Vivian Toussaint.

JUDGE JOHN HUDSON: - - provided to you by social services folks.

MRS. HOGGATT: Mm-Hmm.

JUDGE JOHN HUDSON: They were provided to you by social services folks.

MRS. HOGGATT: Right.

JUDGE JOHN HUDSON: So I’m just correcting your error that you made on the record. You’re not going to make an allegation toward them that they can’t defend cause they don’t have those records. They didn’t have those records. They didn’t have the records to deny them to you.

MRS. HOGGATT: I’m not trying to cast aspersions - -

JUDGE JOHN HUDSON: - - OK.

MRS. HOGGATT: - - on the character of the Circuit Clerk. I would like - - what I’m saying is I would like - -

JUDGE JOHN HUDSON: - - I’m just correcting your error, Mrs. Hoggatt. You made an error, OK. Now go on with your argument.

MRS. HOGGATT: I would like copies of those records to work from right now for this hearing. They were on the motion that Vivian filed, Mrs. Toussaint. She says - -

MRS. TOUSSAINT: - - Judge, I would object to her having copies of those records.

JUDGE JOHN HUDSON: She will get no copies.

MRS. TOUSSAINT: I think the ruling was that no copies were to be released, but could review them. I would not object to the review of them.

MRS. HOGGATT: May I have them to review?

JUDGE JOHN HUDSON: You - - you’ve got time to make your argument for this motion, and I will make a ruling on this motion at the end of this argument. We’ve got thirty minutes allotted for this hearing and that’s all. So move on with your argument, please, ma’am. (R 192 line 12 through 194 line 16)

This exchange is significant because it shows that attorney Victoria Hoggatt still believed at the time of the July 10, 2003 hearing, that the***Amended*** Motion document that Toussaint had sent through the interstate mails to Texas, with a note asking that Attorney Victoria Hoggatt join in for an Agreed Order as to determination of the appellate record, and containing CASA and MDHS records, was the motion that was then being heard July 10, 2003.

It is believed that Vivian Brown-Toussaint, Clerk Vines, or Judge Hudson had by July 10, 2003 removed, concealed, and destroyed the ***Amended*** Motion document that Toussaint had sent through the interstate mails, asking Attorney Victoria Hoggatt to join in for an Agreed Order as to determination of the record, and containing CASA and MDHS records. It is believed that no pending motion was in the court file at its inspection July 10, 2003, prior to the hearing. All CASA and MDHS records had likewise been removed. Additionally, if Judge Hudson was telling the truth, and there were no longer any social services reports in Clerk Vines official court file, then Vines, Toussaint, Hudson or some person directed by them had removed, concealed, and destroyed the “Intake report” listed as filed on or about September 15, 2000 on the first docket from the official court file.

At some date believed to have been later than the July 10, 2003 hearing itself, a document other than Toussaint’s ***Amended*** Motion was ‘filed’ by Hudson, Toussaint, and/or Vines, to substitute for Toussaint’s ***Amended*** Motion , styled ‘Motion Objecting to the Designation of Record of Appellant [sic] and to Designate Record’ , with June 10, 2003 on the file stamp date, though the first fraudulent docket lists nothing filed that date. The replacement motion filed by Toussaint and Vines is listed on the first fraudulent docket as filed July 10, 2003, the date of the hearing, by entry “Motion Objecting to the Designation of Record of Appellant and to Designate Rexcords [sic]”. The file stamp on the fraudulently substituted document eventually sent to the Mississippi Supreme Court, and believed to be now in the court file, is not signed by the receiving clerk, Vines.

The second fraudulent docket, which Vines’ deputy clerk had sent Victoria Hoggatt to Texas by interstate mail on or about September 2, 2004, portrays Toussaint’s motion as filed June 10, 2003, and nothing filed the day of the hearing except the judge’s order, which is not file stamped July 10, 2003. If you think this is confusing, that’s what obstruction of justice is. An attempt to obfuscate, impede, and stop the orderly administration of justice. If I may be permitted an opinion, even the Mississippi court’s obstruction of justice was carried on in an exceedingly disorderly manner.

Since the Motion Objecting to the Designation of Record and to Designate Record now contained in the court file is file stamped June 10, 2003, and Vivian Toussaint sent a letter through the interstate mails or by interstate wire on or about June 11, 2003 stating that the motion had been “filed”, (See CAS Exhibit 10), yet the 1^st docket contains no entry for June 10th, or June 11^th, but does say that the Motion Objecting to the Designation of Record and to Designate Record was filed on July 10, 2003, it is obvious that the Motion Objecting to the Designation of Record and to Designate Record was indeed filed on June 10, 2003. Then Toussaint’s ***Amended*** Motion document was filed, and the first motion was removed from the docket, and the docket altered to conceal the fact that the first one was filed. Then the ***Amended*** Motion document was later removed, concealed and destroyed, by the Circuit Clerk, prosecutor Toussaint, or by the Circuit Clerk’s staff , and the first file stamped Motion Objecting to the Designation of Record and to Designate Record was reinserted the court file, and fraudulently listed on the docket as filed July 10, 2003, the date of the hearing, at some date after the hearing, by prosecutor Toussaint, Clerk Vines, and/or Judge Hudson.

If Clerk Vines knew that it was documented on videotape that Mrs. Alexander was saying on the afternoon of July 11, 2003 that no order designating the record had been filed, and she was filmed checking the docket on the computer, and then Vines was documented on videotape bringing Hudson’s July 10, 2003 order in for filing on July 11, 2003, it makes no sense to list that order on the second fraudulent docket as having been filed on the docket July 10, 2003.

Apparently it took a while for Toussaint, Vines, and Hudson to decide what to do with the variance about Toussaint’ s ***Amended*** Motion, and what they planned to send up on appeal, or even if they were in fact going to file the July 10, 2003 order at all. Vines’ poor unsuspecting deputy, Mrs. Alexander, brought in for the occasion, is seen in Video Exhibit 2, on or about July 11, 2003, refusing Victoria Hoggatt a copy of Judge Hudson’s July 10, 2003 newly received order.

In Video Exhibit 5, a deputy Circuit Clerk believed to be Jackie Pegues is documented refusing attorney Victoria Hoggatt a copy of the July 10, 2003 order on or about July 18, 2003. When Toussaint, Vines, and Hudson finally decided that they would transmit a copy of the “Order Designating the Record” that they all knew was fraudulently file stamped as to date, by interstate mail to Texas, on or about July 21, 2003, Clerk Vines conveniently forgot to include the page of the order that listed what part of the record that Prosecutor Toussaint, Clerk Vines, and Judge Hudson were planning on sending to the Mississippi Supreme Court on appeal.

Maybe they couldn’t agree. After all, Toussaint had represented in writing by interstate mail that she had filed an amended motion requesting that certain CASA and MDHS records be included in the appellate record, with a cover letter stating that certain named CASA and MDHS records were in the file, and would be included in the appellate record, whereas Judge Hudson had stated at least four times, for emphasis, on the record that the same documents weren’t in the court file. Maybe Clerk Vines didn’t want to send a copy of the “Order Designating the Record” through the interstate mails, with full knowledge that it was fraudulently file stamped as to date, and that it was based on a fraudulently file stamped motion that had replaced Toussaint’s ***Amended*** motion that he knew had been removed from the court file, concealed and destroyed.

Maybe Clerk Vines didn’t want to send the “Order Designating the Record” through the interstate mails with a fraudulent file stamp on it, when he knew it wasn’t listed as ever filed on the first docket. Maybe Clerk Vines knew that Toussaint and Judge Hudson were still discussing whether to ever file the “Order Designating the Record”, what to include in it, or to how to ask him not to send the “Order Designating the Record” to the Mississippi Supreme Court, like he failed to send the Notice of Appeal on that order, that was entered on the first trial court docket on or about July 18, 2003.

This denial of inspection of the MDHS and CASA records that had been removed from the court file by July 10, 2003 was in spite of Judge Hudson’s March 6, 2003 statement on the record:

“Alright. So all they [other attorneys hired to represent the Hoggatts] have

to do is come forward and they may inspect these same records, [which

included the MDHS and CASA records noted in the Criminal Affidavit]

including…..of course, included in those records are the petition that she

had filed earlier”.

Adams County Mississippi Circuit Clerk M. L. “Binky” Vines

Perjury Warren Noah Hoggatt

On or about April 1, 2003, Noah Hoggatt, age 19, an adult for criminal prosecution in the state of Mississippi, Youth Court Division of the Adams County Court, Judge John Hudson presiding.

MRS. HOGGATT: Noah, are you aware of where Andrew Allbritton is right now?

Noah Hoggatt: No, I’m not.

MRS. HOGGATT: You have no knowledge of that?

Noah Hoggatt: No, I do not.

MRS. HOGGATT: OK, and Isaiah [Hoggatt], no one’s, mentioned it to you?

Noah Hoggatt: No, they have not.

MRS. HOGGATT: OK. Fine. And, are you angry at the idea that your parents would offer testimony to the federal government about Wilton and Mae Hoggatt’s participation in harboring a fugitive? Are you angry about that?

Noah Hoggatt: Angry that you would offer testimony?

MRS. HOGGATT: Yes.

Noah Hoggatt: Not at all. You can go - -

MRS. HOGGATT: - - Not at all.

Noah Hoggatt: - - do whatever you’d like.

MRS. HOGGATT: Your Honor, I would like to admit the tape for the purpose of showing - - this is what I’m showing is that the grandfather would have them perjure themselves. If we listen to the tape and compare it with the testimony - -

MR. LETARD: - - Your Honor, there’s - -

MRS. HOGGATT: - - we’ll know whether or not he would perjure himself.

MR. LETARD: - - absolutely no evidence that Mr. Hoggatt, Wilton Hoggatt, is controlling this nineteen year old and making him do - -

Judge John Hudson: - - You need to be asking questions about that if you want to ask questions - -

MRS. HOGGATT: - - Yes, sir, that’s what’s on the tape is - -

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON:- - you’re leaping - - you’re leaping to - -

MRS. HOGGATT: - - his defense of the aggravated incest, is what’s on the tape. I said - -

MR. LETARD: I said evidence - -

Judge John Hudson: - - But you’re saying - - you’re showing this - - you’re asking this tape to be admitted, uh, for the purposes of showing that Mr. Hoggatt is controlling him - -

MRS. HOGGATT: - - No.

Judge John Hudson: - - That’s what you just said.

MRS. HOGGATT: No, No. I’m offering it to show that Noah - -

Judge John Hudson: - - I realize you’re shooting all over the page right now, but you just said that. That’s what you just said, all right, and the record here will show that. My question to you is that you - - if that’s what you’re wanting to do, then you have to - - you have to ask some - - some - - some foundational questions as to whether or not there is any control going on here.

MRS. HOGGATT: Do you believe your grandfather has done that, Noah, sent A. J. Allbritton money for years and years?

MR. LETARD: Objection. Now that’s not relevant.

MRS. HOGGATT: Well, I’m trying to lay a foundation - -

Judge John Hudson: - - Sustained.

MRS. HOGGATT: - - whether or not my son is - -

MR. LETARD: - - It’s not relevant.

MRS. HOGGATT: - - has been influenced to believe that that’s fine and dandy. That’s criminal activity.

Judge Hudson: Sustained. Sustained. (R 112-114)

Inconsistent statements made on or about April 1, 2003 indicating perjury and subornation of perjury by Philip LeTard, an adult person, who was the Court Appointed Attorney for the Minor, Judge Hudson, and witness Isaiah Hoggatt, an adult person, made concerning their transfer of protected youth court records from Natchez, Mississippi to Louisiana to Virginia.

On or about March 30, 2003, attorney Victoria Hoggatt reported to Adams County Court official Manfred Eidt by interstate telephone (Texas to Mississippi) that she had learned of the illegal transmission of the Petition for Disclosure and Release of Records with its exhibits to Craig Johnson in Virginia, the person alleged in the Petition for Disclosure and Release of Records to have committed years of egregious criminal activity against the Eric Hoggatt family, in New York, Virginia, and Mississippi. Texas legal assistant Ethan Hoggatt had hand delivered the same information about the Mississippi court’s continuing conspiracy against rights and obstruction of justice to the United States Department of Justice, namely Assistant U.S. Attorney Jim Nobles, for the Eastern District of Texas, Tyler Division, with exhibits and audio exhibits, including recordings of Wilton Hoggatt, Tessa Hoggatt Albritton, state and federal law enforcement officers FBI Agent Nathan Songer and personnel in the Franklin Parish Sheriff’s office, and Mike and Marisa Allbritton, the parents of the sexual assault victim, alleging law enforcement assistance to the fugitive, and alleging Wilton Hoggatt and Agent Nathan Songer’s continuing cooperation in obstruction of the apprehension of the fugitive, and the assistance of the Adams County Court officers to Wilton Hoggatt and others then assisting the fugitive. On or before January 31, 2003 the same information had been both faxed and mailed to the Mississippi Attorney General, without the audiotape exhibits.

Attached to the information sent to the USDOJ in Texas and to the Mississippi Attorney General were affidavits sworn to by Marisa Allbritton, of Denham Springs, Louisiana, the mother of the sexual assault victim, by Eric Hoggatt, DDS, Ethan Hoggatt, and attorney Victoria Hoggatt of Texas, and by Shari Johnson of Virginia. The sworn affidavits alleged ongoing and current obstruction of justice, witness intimidation, and denial of access to the court file by Adams County Court officials, and well as the assistance to the fugitive by law enforcement, now documented in the larger Criminal Affidavit.

Vines, Hudson, and or LeTard or some person directed by them must therefore had to have copied and distributed the legal length Petition for Disclosure and Release of Records sometime in the window period of January 29 and March 6, 2003, during which time Judge Hudson illegally ordered CASA worker Manfred Eidt to make copies of the privileged and copyrighted audio cassettes of Wilton Hoggatt speaking to Mike Allbritton, father of the incest victim, attorney Victoria Hoggatt with Wilton Hoggatt conversing about Wilton Hoggatt’s assistance to the fugitive, attorney Victoria Hoggatt with Pharmacist Tessa Hoggatt Albritton conversing about Pharmacist Tessa Hoggatt Albritton’s father, Wilton Hoggatt’s, assistance to the fugitive and the FBI’s assurance that Wilton Hoggatt wouldn’t get “in any trouble at all’, attorney Victoria Hoggatt with Craig Johnson in Virginia conversing about Wilton Hoggatt’s assistance to the fugitive and how Craig Johnson planned to be the “meanest son of a bitch that ever came down the pike’, which audiotapes were submitted as exhibits to Eric and Victoria Hoggatt’s Petition for Disclosure. Judge Hudson’s court docketing secretary Jeanine Wickham relayed from Judge Hudson that the described audiotapes would be listened to ‘by the other attorneys’, presumed to be prosecutor Toussaint and LeTard.

On or about February 10, 2003, Hudson’s court docketing secretary opined that Judge Hudson had already listened to the recordings. Manfred Eidt stated on the court record that he had listened to the recordings that he later stated Judge Hudson told him to copy, though Eidt had been specifically directed by attorney Hoggatt that they were not to be duplicated.

Whether Eidt transmitted copies to law enforcement officials that were subpoenaed by the Hoggatts to the April 1, 2003 hearing is not known, but as outlined in the Criminal Affidavit, it is known that prosecutor Toussaint, Judge Hudson, Eidt, and Adams County Circuit Clerk M.L. Vines, his deputy Melody Bradley, and Adams County Sheriff’s Deputy Jack Smith all acted in concert with the Mississippi Attorney General to obstruct the orderly administration of justice by following Judge Hudson’s direction to not issue any of the subpoenas duly requested for both April 1, 2003 and July 10, 2003 hearings by Eric and Victoria Hoggatt to Eidt, MDHS worker Junkin, Wilton Hoggatt, Warren Johnson, Franklin Parish Sheriff’s Deputy Tim Pylant, Vines, his deputies, Donna Hoggatt Rombs, approximately 35 witnesses total.

Since by July 10, 2003, Andrew J. Allbritton himself had been extradited to Louisiana, and was 30 miles away from Natchez in the Franklin Parish jail, and attorney Victoria Hoggatt thought it would be quite showy to have Andrew J. Allbritton himself testify at the scheduled July 10, 2003 in Natchez, Mississippi, she contacted Louisiana Fifth District Attorney William R. “Billy” Coenan Jr., who refused to help obtain Andrew J. Allbritton’s attendance at the July 10, 2003 hearing, stating he had no idea how to procedurally request an incarcerated person’s attendance at a court hearing. If the DA doesn’t know, who would? Louisiana Fifth District Attorney William R. “Billy” Coenan Jr. said to contact a “civil attorney”, who may have some idea.

Isaiah Hoggatt- Direct by Mrs. Hoggatt (Adverse)

MRS. HOGGATT: . . . . did Mr. [Wilton] Hoggatt tell you, and did you tell me two weeks ago, that [Wilton] Hoggatt told you that the Patts told A. J. [Allbritton] they wanted his land, and the next day they filed aggravated incest charges against him; did you tell me that?

ISAIAH HOGGATT: That I heard that?

MRS. HOGGATT: Yes, sir.

ISAIAH HOGGATT: Uh, I think - - that’s the version of the story I believe and that’s why I - - I - - uh, so yes. (R 168 line 7 through line 14)

Compare

MRS. HOGGATT: But you do believe that what your grandfather told you, that A.J. [Allbritton] never molested the little girl; is that right?

MR. LETARD: Objection, your Honor. It’s not relevant - -

ISAIAH HOGGATT: - - Grandpa never talked to me - - grandpa never - -

MR. LETARD: - - Excuse me. It’s not relevant as to what he believes - -

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON:- - Sustained.

MRS. HOGGATT: OK, your Honor, is this adequate foundation to have the audiotape of Isaiah [Hoggatt]’s reaction to the suicide of the child [SEXUAL ASSAULT VICTIM] or the attempted suicide?

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: You’ve got to - - you can ask him questions about - - about that tape and the conversation if you want to, but you haven’t laid the adequate foundation yet, no, ma’am.

MRS. HOGGATT: OK. Isaiah, did you say that, about ‘blood being thicker than water’ and how bad that was if your grandfather was ever prosecuted for his part in it?

ISAIAH HOGGATT: I did say that.

MRS. HOGGATT: Yeah. Do you realize that if he didn’t do anything, the FBI will not ever prosecute him?

ISAIAH HOGGATT: That’s what the FBI said and that’s the premise they’re operating under, that he hasn’t done anything.

MRS. HOGGATT: Oh, they are?

ISAIAH HOGGATT: That’s correct, as entered in testimony earlier.

MRS. HOGGATT: Well, Manfred told what Nathan Songer said, that there were no criminal charges pending, but [Monroe, Louisiana FBI Agent] Nathan Songer told me that he knew the Hoggatts had lied to him.

MR. LETARD: Objection to the hearsay.

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: Sustained.

MRS. HOGGATT: So - - and - - OK. On the audiotape, Isaiah, what was your reaction to finding out that your cousin, your dad’s first cousin’s daughter, had attempted to kill herself?

ISAIAH HOGGATT: Um, first of all, I’ve never met this girl; I don’t know her name; all I know is this - -

MRS. HOGGATT: - - What was your reaction, Isaiah?

ISAIAH HOGGATT: To the news that she had attempted suicide?

MRS. HOGGATT: Yes.

ISAIAH HOGGATT: Uh, it wasn’t a very nice one, but knowing that you were trying to hurt my grandfather is what amounted of it, uh, came of it. You were trying to hurt my grandfather and it involved someone that we had never met and you had only recently…

MRS. HOGGATT: Yeah. And did you say that maybe, you know, they ruin people’s lives just remembering these things? Are you aware of the medical evidence that had to do about the little girl?

ISAIAH HOGGATT: No, I . . . .

MR. LETARD: Your Honor, - -

MRS. TOUSSAINT: - - Judge, what’s the - -

MRS. HOGGATT: - -were you aware that your father - -

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: - - Sustained. Come on.

MRS. HOGGATT: Yes. See, it may not disturb anyone else and they may think it’s irrel . . . but it’s not a bit irrelevant, and if you believe it to be so - -

MR. LETARD: - - If the Judge said it’s irrelevant and - -

MRS. HOGGATT: - - It’s irrelevant, OK.

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: It’s irrelevant. (R 169 line 6 through 171 line 10)

MRS. HOGGATT: to your knowledge, does Craig Johnson have a copy of the petition [Petition for Disclosure and Release of Records] that was filed?

ISAIAH HOGGATT: He does.

MRS. HOGGATT: How did he get it?

ISAIAH HOGGATT: I spoke with Mr. LeTard about it earlier. Uh, when we were here the last time, uh, we were reading it and it was pretty funny, and so I said “Grandma and grandpa have got to see this!”; and I was informed that I was not supposed to after I had already done it. I just this morning - -

MRS. HOGGATT: - - And, but how did you get it?

ISAIAH HOGGATT: Um, we were looking over documents with Noah’s attorney.

MRS. HOGGATT: Where?

ISAIAH HOGGATT: In an of . . . .I don’t recall exactly.

MRS. HOGGATT: Here in Natchez?

ISAIAH HOGGATT: That’s the only place I’ve ever met Mr. LeTard.

MRS. HOGGATT: In his private office or in the youth court?

ISAIAH HOGGATT: Do you have an office here?

MR. LETARD: You’re talking about right here.

ISAIAH HOGGATT: Uh, right across the hall here.

MRS. HOGGATT: No, I’m saying when you were talking to Mr. LeTard and you had the youth court record in your hand - -

ISAIAH HOGGATT: - - He didn’t know I had it. I was reading it throughout the - - while you were, uh, talking the last court date.

MRS. HOGGATT: OK. So then how - - that was the last petition that Mr. Le Tard had; how did you get hold of it?

ISAIAH HOGGATT: We were - - Noah and I were reading it and just, incredulously, about all the stuff you were alleging, and some of it was almost laughable and so - - well, a lot of it was laughable.

MRS. HOGGATT: Um-hmm. So how did you get - - now you’re going to have to answer the question sooner or later, who gave - -

MR. LETARD: - -I believe he answered the question.

MRS. HOGGATT: - - it to you?

ISAIAH HOGGATT: I was reading the documents.

MRS. HOGGATT: Where did - - you were reading it, right, but that doesn’t get it to Virginia. You were reading the document and - -

ISAIAH HOGGATT: - - Oh, I mailed it.

MRS. HOGGATT: Mr. LeTard - -

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: - - Well, ask the question. You hadn’t ask the right question yet.

MRS. HOGGATT: Answer the question. Where did you get the youth court petition that I filed to - -

ISAIAH HOGGATT: - - As I said earlier, Noah and I were looking over those documents and I - - it came into my possession, sitting there [pointing to an area of the youth courtroom]. It was passed to me from left to right.

MRS. HOGGATT: Where, right there? Sitting over there?

ISAIAH HOGGATT: No. I’ve specified it was in this office across the hall.

MRS. HOGGATT: So Mr. Letard had the petition and he gave it to you to read; is that right?

ISAIAH HOGGATT: No. Mr. Letard did not give me the petition to read. Noah and I read it. We were looking over it, cause he’s his attorney, and so we were looking over this stuff.

MRS. HOGGATT: So how did it get - -

ISAIAH HOGGATT: - - That’s how it came into my possession.

MRS. HOGGATT: And so you picked it up and you copied it?

ISAIAH HOGGATT: No, I did not copy it.

MRS. HOGGATT: You stole it?

ISAIAH HOGGATT: No. I didn’t look at it as a theft cause it wasn’t a - - it carried no weight at all. It was just a dissertation of why your life has gone wrong.

MRS. HOGGATT: You don’t think it’s a - - a youth court pleading?

ISAIAH HOGGATT: I was under the impression - - I realize now that I should not have done that and I apologize to the court, but I didn’t realize it at the time, and, uh, I really - - just this - - the majority of the things in there were just baseless and made up and twisted facts, and so I thought my fellow accused relatives ought to have a chance of seeing what horrible crimes they’re accused of. (165 line 5 through Page 166, Line 15)

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: Call your next witness.

MRS. HOGGATT: Phillip Letard.

MR. LETARD: Pardon me.

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: What possible purpose could you be calling the attorney for the child?

MRS. HOGGATT: I’ve spent approximately eight thousand dollars here in Natchez trying to get access to youth court records. Isaiah just said he received from Phillip Letard - -

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: - - This is - - this is - -

MRS. HOGGATT: - - the youth court record.

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: This is about the custody. That’s what this is about.

MRS. HOGGATT: Hmm. OK, - -

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: Do you want to make your proffer as to what happened - - how that happened. You can make that for the record.

MR. LETARD: For the record, your Honor, I was interviewing Isaiah. I was interviewing N. Uh, I wanted them to look only at the petition that was filed, the allegations in the petition. At no time did they see the youth court record or any other part of the record that - - that was - - uh, this was a copy of the long petition that was not filed in the youth court record, but I had asked them to review that to see if - - if we were going to use him as a witness, or if I was going to use him as a witness, if those were the issues that were going to be heard.

Uh, I was not aware that Isaiah had taken that copy. In fact, I asked for one copy back. I thought the copy was in my possession. I, at no time, uh, gave them access to any records, uh, other than the petition; and as Noah’s attorney, I’m also entitled to look at that petition because, certainly, that was going to be an issue that was before the court on her motion and possibly the motion that I had filed. So, at no time, did I give them an - - uh, and I am - - I am sorry that the petition went out of this office. It certainly - -

MRS. HOGGATT: - - You’re saying it’s not part of the youth court record?

MR. LETARD: The pe . . . the petition that I give him, the long petition, was not filed. In fact, I know for a fact that that petition was not filed in the record because that was the petition - - the short petition was different. There was different language in the short petition that you filed in the petition that what I was having them review. So - -

MRS. HOGGATT: - - [the Petition for Disclosure filed on or about January 31, 2003 on legal length paper] was filed prior to [the Petition for Disclosure filed on 81/2 by 11 inch paper at the direction of Judge John Hudson], and Judge Hudson said it was not on legal length paper.

MR. LETARD: Yeah, I’m offering - - I’m making my offer - -

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: - - Well, regardless - -

MR. LETARD: - - Irregardless, Judge, it was not my intention to give them, uh, material. Certainly, nobody, uh, had no idea that they were taking this outside this courthouse, and I, at no time, took these records, any of the records, out of this courthouse - -

MRS. HOGGATT: - - How - -

MR. LETARD: - - and nobody gave me - - I gave no one permission and no one talked to me about taking this to Virginia. If they had, I would have told them absolutely not. That would have been inappropriate.

MRS. HOGGATT: - - So how did they get it?

MR. LETARD: I just said that they were reviewing the petition as a witness - -

MRS. HOGGATT: - - Were you there?

MR. LETARD: With my knowledge, they were reviewing the petition and the petition only.

MRS. HOGGATT: Were you there when they were doing that?

MR. LETARD: That’s - - that’s my offer of proof, Judge.

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: OK. He has set out how the petition got into Mr. Isaiah Hoggatt’s hands and Isaiah Hoggatt has testified as to what he did with the petition.

MRS. HOGGATT: No, sir. He, at one time, said he gave the petition to Isaiah. I want to know was he there and watched Isaiah walk out the door with it?

MR. LETARD: Well, no. I can add that; I certainly was not there, was not aware that Isaiah had the petition. Had I seen him with the petition, I would have stopped him and gotten the petition away from him. It was not my intention to give him records, only to review that record in anticipation of using him as a witness.

MRS. HOGGATT: So that was one of - -

MR. LETARD: - - That’s our - - that’s all the proffer of proof I have, your Honor.

MRS. HOGGATT: Um-hmm. I’m still sort of cloudy about, uh, - - so you were not in the room when he left with the petition?

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: Mrs. Hoggatt, he didn’t know he had the petition. He would not know if he was in the room or not at the time he left with the petition.

MRS. HOGGATT: He said he gave him the petition.

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: To look at, to prepare for the trial.

MRS. HOGGATT: Right, and so I’m wondering - - was Isaiah - - did he leave them with the petition?

MR. LETARD: I’m not going to be cross-examined, Judge. I - - I object to her calling me as a witness.

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: The proffer is accepted by the court; now, move on. (R Page 174 line 16 through 177 Line 29)

MRS. HOGGATT: Uh, Mr. Letard, I don’t believe, has read the record prior to. He said it would have been very relevant at that time. It was very relevant at that time and Ashley and Ginger and Manfred were all told at length that they [Wilton and Mamae Hoggatt] had great hatred for us because we were participating as federal witnesses or had offered ourselves as information prior to the dispositional hearing. It is not a dead issue. The little girl has tried to kill herself. They’re all on tape about their reaction to that and, Mr. Wilton Hoggatt, he’s going to pray for her, and he’s also on tape, saying he has recently talked to the criminal. He has also contacted - - been in contact, in the last week, with my son, Isaiah, in his home, about this criminal. It’s my husband’s first cousin’s daughter. It’s his first cousin. It’s not a dead issue. They’re calling to tell me they’re going to - - Oh, I should like to know, since I spent from January 11^th to March 7^th in Natchez and the vicinity, trying to get access, as the mother, who’s never been judged unfit, for youth court records to prepare for whatever may come up, and was denied them. My brother from Virginia called me two days ago and said he was going “to rack my ass“, and was reading from the youth court petition. How did that happen? Isaiah Hoggatt, my adult son, was sitting in the youth court reading it. Flipping it over, saying this is really interesting. I was just wondering, Mr. Letard said he did not supply it to him, I’m wondering how did they get it.

MR. LETARD: No, that’s not correct. What I said was that no records left this courthouse under anybody’s authority. That’s what I said. So, for the record, let me correct you, Mrs. Hoggatt. You asked me how your brother would get access to records outside of this courthouse, and I said that nobody, certainly not me, and nobody that I’m aware of, took any records out of this courthouse.

MRS. HOGGATT: Well, I’m just - - that’s why I’m asking the question. I’d like to know how did he get them?

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: What petition are we talking about?

MR. LETARD: She’s talking about her - - her sixty page motion, not - -

MRS. HOGGATT: - - which is part of the youth court file.

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: That sixty page motion has been e-mailed by you all over the United States.

MRS. HOGGATT: No, sir, it has not.

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: Oh, yes, it has.

MRS. HOGGATT: Oh, only to the people that the Department of Human Services said to send it to, the Attorney General’s office.

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: Well, but I mean, it’s - - we don’t have control over something that’s been published to third parties.

MRS. HOGGATT: Yes, sir, but he didn’t - - my brother didn’t get it from the Attorney General’s office.

ADAMS COUNTY MISSISSIPPI JUDGE JOHN HUDSON: I don’t know where it came from. I don’t know where your brother would have gotten it from. He didn’t get it from this building.

MRS. HOGGATT: But the people are still harboring the criminal and it’s a - - it’s a current thing and, yes, it is, it’s a serious thing. It’s not just that, that’s why the petition, even though everyone talks about how long it is, it’s been a seven-year assault. There are a lot of things they’ve done. Breaking and entering is a serious thing… (R 62 line 1 through R 63 line 26)

Judge Hudson’s possession of the legal length Petition for Disclosure and Release of Records is significant, because after Judge Hudson directed his court secretary Jeanine Wickham to call interstate to attorney Victoria Hoggatt and state that the pleadings were invalid, legal assistant Ethan Hoggatt retrieved the file stamped legal length Petition for Disclosure and Release of Records from Clerk Vines.

Though Judge Hudson asserted as a dilatory tactic that attorney Victoria Hoggatt must re-file her Petition for Disclosure and Release of Records “because Mississippi Rules of Civil Procedure no longer admitted filing on legal length paper”, he is believed to have directed his court clerk Vines, Manfred Eidt, and / or Court Appointed Philip LeTard to illegally copy the legal length Petition for Disclosure and Release of Records that was filed on or about January 29, 2003, or Judge Hudson copied it himself.

John Hudson was documented on the court record as in personal possession of a copy of the Petition for Disclosure and Release of Records himself by April 1, 2003, although anyone except the attorney for the minor is prohibited by statute from copying youth court records.

(12) Conspiracy against Constitutionally Protected Fundamental Rights, viz., First Amendment Rights of Speech and Press, and the Right to Peacefully Petition the Government for Redress of Grievances, 14^th Amendment Right to Equal Protection and Due Process of the Laws.

Freedom of Speech and Freedom of Press, 1st Amendment

On March 6, 2003, April 1, 2003, and July 10, 2003 Judge John Hudson repeatedly stated that attorney Victoria Hoggatt would be committing a criminal act should she disclose any information contained in youth court records, even though he always knew that no Mississippi youth court criminal nor civil complaint had ever been filed, and thus no Adams County youth court case had ever in fact existed, stating things like, “Those notes are confidential and cannot be published to anyone without the permission of this court, OK. And that’s the law in the state of Mississippi”, (R 47), though he defended court appointed attorney Philip LeTard’s unlawful disclosure of records of over 100 pages of youth court documents, that prompted Craig Johnson to call the Hoggatt family from Virginia to threaten attorney Victoria Hoggatt in Tyler, Texas, “I’m going to rack your ass”. (CP 174-177). Judge Hudson and all court officials knew from the Hoggatts’ January 31, 2003 Petition for Disclosure, to which Marisa Allbritton, the mother of the sexual assault victim, was an affiant, while the fugitive was yet a fugitive, that both the parents of the sexual assault victim, and Eric and Victoria Hoggatt were doing everything in their power to promote federal criminal prosecution of Judge Hudson, prosecutor Toussaint, Manfred Eidt, and extended family members.

Hudson’s order signed July 10, 2003 states, as read by Adams County Deputy Circuit Clerk on the July 11, 2003 video, “ …the record of this appeal shall not be copied except for the use of the Supreme Court in camera and the record and the information contained therein shall at all times be maintained confidential.” Evidence of criminal conduct by the Mississippi court and others requires duplication of fraudulent documents contained therein, and of publication of intentionally false and material statements of perjury on the record. Toussaint, Eidt, and Judge John Hudson feared no disclosure, as long as they held hands and denied inspection of the court file. The part the office of the Mississippi Attorney General played in denial of inspection and interference with service of process is outline more extensively in the Criminal Affidavit proper.

Just like the sex offender, Andrew J. Allbritton, Jr. threatened his eight year old granddaughter, what would happen to her if she told her parents of his nasty activity, stating, “You’re gonna pay”, Adams County Judge Hudson and Agent Kaiser’s superiors, and others threatened that disclosure of criminal activity, including their criminal activity, would result in sanctions, inferring that attorney Victoria Hoggatt could lose her license to practice law, if she told the press and prosecutors what they had been doing.

They had little to worry about. Prosecutors are loath to prosecute other prosecutors. The very thought of considering audio taping another FBI agent to document criminal activity of an FBI agent is anathema to an FBI agent or Justice Department official. Ever know of a highway patrolman with a speeding ticket?

The only time I have ever been in a car going about 100 miles an hour down the interstate, was when I interned as a youth court counselor for the Third Chancery District of Mississippi in 1973, as part of a MSU criminal corrections graduate program, prior to law school. I had ridden with a Grenada County Deputy Sheriff to transport a minor child to Columbia Training School. There are certain perks society may afford law enforcement officers. Aggravated Incest committed against an eight-year-old child should not be one of them. Unfettered and egregious Deprivation of Rights against unpopular minorities is another naughty that should not be aided and abetted by those charged with defending the United States Constitution.

Right to Peacefully Petition the Government for Redress of Grievances, 1^st Amendment

As outlined in the Criminal Affidavit, prosecutor Toussaint, Adams County Judge John Hudson, Clerk M.L. Vines, and others acted in concert with Circuit Judge Forrest Johnson to obstruct the prosecution of criminal charges contained in sworn affidavits filed in Adams County Mississippi for perjury, obstruction of justice, conspiracy, interference with service of process, assault, on or about July 18, 2003.

Daniels v. Wal-Mart Stores , 634 So. 2^nd 88, 92 (Miss. 1993) set the standard for judicial abuse of discretion as to disclosure of Mississippi juvenile records. Neither case supports the contention that this Mississippi County Court judge was within his discretion to keep records secret in the never existing “case”. Quite the reverse. In Daniels v. Wal-Mart Stores, the Court held “Justice requires a total view.” At page 94, the Daniels’ court stated, “the shield of confidentiality was not designed and cannot be permitted to fraudulently defeat civil reparation of juvenile wrong.” How much more the shield of confidentiality was not designed and cannot be permitted to fraudulently defeat civil and/or criminal reparation of deprivation of rights under color of law, nor to actually encourage delinquent behavior in children, cover aggravated incest committed by a quasi-law enforcement official, and to facilitate premeditated and concerted criminal assault with the stated aim of destruction of the family unit. The Daniels Court correctly held, “We will not allow courts to see only part of the whole picture. Although justice is blind so that all who approach it do so on equal footing, justice is not dumb unless made so by courts or judges.”

May there exist prosecutors in New York, Texas, Virginia, Mississippi, and Louisiana that “will not allow” good ole boys to protect other good ole boys who commit extortion, interstate kidnapping, or obstruction of justice, and who profit financially from aggravated incest committed by a grandfather against his own 8 year old granddaughter.

No matter how prominent. No matter what official capacity.

Freedom of Worship

Freedom of worship means that no one may be “punished for entertaining or professing religious beliefs or disbeliefs, for church attendance or non-attendance.” One significant reason that prosecutor Toussaint, Judge John Hudson, Agent Songer, and others saw the necessity of obstructing justice to keep from being examined on the record, and to obstruct justice to prevent having the requested September 2000 and mid 2001 Mississippi hearings’ court records transcribed and conveyed to the Mississippi Supreme Court or to the United States Supreme Court on appeal, is because the Mississippi Attorney General, prosecutor Toussaint, Judge John Hudson, and Eidt knew that the record of the sham hearings is filled with egregious religious prejudice and animosity, not just from extended family members, but by Judge John Hudson himself. Testimony by law enforcement officers and extended family members would have revealed that appealing to religious bigotry was the essential factor in getting law enforcement personnel and public officials to cooperate in an ongoing criminal conspiracy at every level.

The Petition for Disclosure contained examples of numerous statements denoting religious bigotry made by Judge Hudson and others, which the Mississippi Attorney General was aware of by sworn affidavits prior to January 31, 2003, and was aware of prior to directing Clerk Vines, Mississippi Department of Human Services employees, and other Mississippi officials to continue to deny access to the court file. Clerk Vines, Mississippi Department of Human Services employees, and other Mississippi officials not only ordered others to deny all information to Eric and Victoria Hoggatt, but condoned, facilitated, and even ordered violent acts, both prior to and after their other illegal actions. (See Video Criminal Affidavit Exhibits 3, 4, and 6 of Adams County Circuit Clerk Vines, his deputy Melody Bradley informing MDHS officials to “Call the police. They need to come and take it [the video camera away from her [Victoria Hoggatt]”, while she was filming Manfred Eidt as to his actions in concert with Judge Hudson as to interference of service of process to Eidt to attend the July 10, 2003 hearing, and NPD officer Carl Houston following the MDHS officials’ and Mississippi court officers’ direction to ‘take the camera away’; See also, Criminal Affidavit Audio Exhibits 11 Craig Johnson; Audio Exhibit 15 Noah Hoggatt; Audio Exhibit 23 Craig Johnson; Audio Exhibit 24 Craig Johnson; Audio Exhibit 25 of Judge Hudson, prosecutor Toussaint, and Manfred Eidt)

The Mississippi Attorney General was aware of such statements in the file, (and then by direction of the Mississippi Judge, un-filed) Petition for Disclosure as follows:

“Conversely, due to egregiously hate filled testimony on the court record of the dispositional hearing, and from statements from Relatives in conversations with intake workers that revealed extreme animosity towards Parents and their religion, youth court workers for the youth court of Adams County

knew, or should have known,….”

“Noah Hoggatt, preceding any court proceedings, spoke with Attorney [and Noah’s mom, Victoria Hoggatt] about his grandfather, Warren Johnson, coaching the boys, and said, “We’re going to use your religion against you, and you know you can’t defend yourself against that.”

“What is so bizarre, or perhaps not, is that Noah Hoggatt was holding himself out as one of Jehovah’s Christian Witnesses, participating in the meetings, carrying the microphones, and making himself useful in the congregation in New York immediately preceding the incident. That is the influence of the Relatives, to be thoroughly treacherous, and to play to your audience. Being around said relatives is like flipping a switch, from sane and kind, to absolutely boldly bad, as if destruction of the happiness of your fellowman is a delightful game.”

“To illustrate, the morning after Noah spent the night in the Day’s Inn in the room Relatives [Craig Johnson, Warren and Dorothy Johnson in Virginia] bought him, he came to see if he could borrow the iron, and wanted to know how his mother liked his hair. Attorney [Victoria Hoggatt], his mother, replied he could borrow the iron if he would iron Sascha a dress, which he did. He said, “As a lawyer, what do you think would impress this judge?” [Victoria Hoggatt] replied that ‘Almighty God, the judge of the whole earth, hates duplicitness’. Noah said, “No, I mean this human judge.” [Victoria Hoggatt] replied, “I think he would be impressed by the same thing”, meaning sincerity.

Noah said, “I’m worried about who’s going to remind you about your posture now.” And asked that she “Please tell Dad that I don’t mean anything by it, but I’m going to do whatever it takes.”

“Relatives think their activity is a game. It is sick and twisted. As Donna Rombs said, “Vicious and sadistic”. “

“The Court Record, a transcript of which is hereby requested, contains such statements as:

1) “Mainstream religions consider them a cult”

“Relatives are on audiotape volunteering such charming sentiments as “I said when you became a Jehovah’s Witness that I would have rather my sister had become a whore,” “you’re part of the second most hated cult in history” (they didn’t volunteer who came in first), and lots more. Hours more. Using the F word. Screaming as loudly as they could manage, sometimes together, at the same time. Admitting to hitting Ethan repeatedly because he had “f....d over Grandma” by not joining in a prayer at her funeral.”

“In the front seating area of the old youth court building in Natchez, Mississippi, Attorney [Victoria Hoggatt], who is mother of the minor, spoke with Judge Hudson and said, “We really were telling the truth about my family. You really ought run an NCIC on my family”, meaning extended family members, Warren Johnson, Craig Johnson, and Isaiah Hoggatt, father, brother, and son, respectively. As said conversation took place, Judge Hudson became increasingly angry and loud, and the conversation drew attention of those in the area.

“……In the presence of Manfred Eidt, Court Appointed Special Advocate; and in the presence of Ginger Johnson and Ashley Junkin of the Mississippi Depart of Human Services, Division of Youth Services of Adams County, Mississippi; and in the presence of Leslie Martin, court appointed attorney of the minor, now thought to be residing in Missouri, and in the presence of several clerical youth court personnel, and perhaps youth court Prosecutor Vivian Toussaint and Cassandra Guise of Fayette, Mississippi, Judge Hudson replied, “You need to change! You need to change!”

Judge Hudson said, “I’m a United Methodist, and if Isaiah had done half the things you said in there, he would have been thrown out Millsaps a long time ago!” (Compare Exhibit D, letters from Millsaps College, outlining the very serious and destructive infractions committed by Isaiah Hoggatt January 2000 to June 2000, which led to his being placed on Social and Disciplinary Probation for the remainder of Spring 2000 Semester and the Fall Semester, which were part of the court file and given to all intake workers prior to adjudication and disposition.) (See USDOJ/MAG 1/29/2003 with sworn affidavits of Shari Johnson, Marisa Allbritton, Eric, Ethan and Victoria Hoggatt)

Publicly accusing a practicing attorney of dishonesty, and worse, perjury, is defamation per se in Mississippi for civil liability.

If every prosecutor, every civil attorney in New York, Texas, Virginia, Mississippi, and Louisiana chose a cause of action, and prosecuted or sued Wilton Hoggatt, Warren and Dorothy Johnson, Agent Nathan Songer and his supervisors, prosecutor Vivian Brown Toussaint, Ronnie and Donna Hoggatt Rombs, Tessa Hoggatt Albritton, CASA worker Manfred Eidt, and/or Craig Johnson for intentional infliction of mental distress, and/or conspiracy against rights, and proved successful, no amount of depositions and interrogatories, press releases, civil awards, or criminal sanctions, no amount of imprisonment, could ever cause the pain, shame, disgrace, frustration, fear, sorrow, and despair intentionally inflicted by Wilton Hoggatt, acting in concert with FBI Agent Nathan Songer and his supervisors, by Donna and Ronnie Rombs, by prosecutor Vivian Brown Toussaint, CASA worker Manfred Eidt, Judge John Hudson and Andrew J. Allbritton, Jr., on Mike and Marisa Allbritton and their daughter, on Eric and Victoria and Sascha and Ethan Hoggatt, and on Shari Johnson and her children, for trying to protect themselves and their children.

Pharmacist Tessa Hoggatt Albritton told mom Marisa Allbritton when she begged for assistance while her daughter was in the Our Lady of the Lake Hospital in Baton Rouge under suicide watch after having attempted suicide six years after the assault, that the mom should just “give it to the Lord”.

Explaining her comments to the grieving mom, who was scared witless for the life of her tormented daughter who knew all the law enforcement folks and relatives were playing for the other side, Pharmacist Tessa Hoggatt Albritton told her sister in law, attorney Victoria Hoggatt, “Vengeance is the Lord’s. It is not mine, Vicky, it is not yours.”

What Tessa did not relate, as Paul Harvey says, is the rest of the story. Tessa quoted the apostle Paul at Romans 12:19, but perhaps has not reflected deeply on verses 20 and 21, where Paul writes, "Beloved, never avenge yourselves, but leave room for the wrath of God; for it is written, "Vengeance is mine, I will repay, says the Lord."

The scripture quotation in this passage comes from Deuteronomy 32:35... In translating "I will take revenge" [KJV: "vengeance is mine"] it is important to indicate that God takes revenge for what others have done, but not necessarily to himself. In other words, God is not being vengeful in the sense that he retaliates for what people do to him. Rather, he exercises judgment upon those who harm others. Therefore, one may translate "I will take revenge on the evil that has been done" or "I will take revenge on those who have done evil." In some languages the closest equivalent may be "to pay back" -- for example, "I will pay them back for how they have caused others to suffer." In other languages one may translate as "I will cause them to suffer in return." In Greek it is not the noun form of revenge that is used in Rom 12:19; rather, it is a verb form, antapodoso <Strong's Greek word # 467>, that is used, and is translatable as, "I will give back again."

Barclay Newman and Eugene Nida,Translator's Handbook on Paul's Letter to the Romans (New York: United Bible Societies, 1973, page 242)

No matter how prominent. No matter what official capacity.

The effect of concert criminal activity of state, federal, and local officials may best be illustrated by the effect that such litigation has had on the economic and emotional health of the sexual assault victim and her family, as outlined in the Criminal Affidavit. It was the intent of Warren Johnson and Dorothy Johnson and Wilton Hoggatt to intentionally inflict the most extreme mental distress upon Eric Hoggatt and Victoria Hoggatt.