Windsor files Criminal Charges against Fulton County Georgia Politician Steve Broadbent

On August 26, 2011, I presented criminal charges to the Fulton County Sheriff’s Department against Steve Broadbent.  I have also presented the charges to the Fulton County District Attorney’s Office.  Broadbent is charged for his part in tampering with the Grand Jury.

I have accused Steven W. Broadbent of Jury Tampering in violation of  O.C.G.A. 16-10-93, Obstruction of Justice, Honest Services Fraud, Making False Statements in violation of O.C.G.A. 16-10-20, Embracery in violation of O.C.G.A. 16-10-91, Conspiracy in violation of O.C.G.A. 16-4-8, Tampering with Evidence in violation of O.C.G.A. 16-10-94, and violation of the Georgia RICO Act – O.C.G.A. § 16-14-1, et. seq.  Here is my sworn affidavit…

 

CRIMINAL CHARGES AGAINST STEVE BROADBENT, WAVERLY SETTLES, REBECCA KEEL, AND NAOMI FUDGE

FOR JURY TAMPERING, EMBRACERY, OBSTRUCTION OF JUSTICE, CONSPIRACY, AND RICO

I, William M. Windsor, the undersigned, hereby declare under penalty of perjury:

1. Grand Jury Foreman Steve Broadbent, Fulton County Assistant District Attorneys Rebecca Keel and Waverly Settles, and Fulton County District Attorney receptionist Naomi Fudge have conspired to obstruct justice, damage me, and deny me due process rights under the Constitution of Georgia and the United States by intentionally and knowingly committing the crimes of obstruction of justice, jury tampering, embracery, conspiracy, and more.  I am not an attorney, but from what I have studied, it is my belief that the charges detailed herein are proper.
   
2. Their actions are violations of Obstruction of Justice — 18 U.S.C. § 1503 and Jury Tampering — O.C.G.A. 16-10-93 and O.C.G.A. 16-10-94; and other statutes; and as such, said violations also constitute predicate act crimes and prove violation of the RICO statute of the State of Georgia. O.C.G.A. 16-14-1, et. seq.
   
3. I am involved in several civil actions that are about the most fundamental legal issues that exist: justice; honesty; fair play; equal protection; due process; Constitutional protections; the right to a fair trial before an impartial judge; the requirement that witnesses, attorneys, and judges tell the truth; the requirement that witnesses, attorneys, and judges do not violate the laws of the state and the country, abuse litigants, and commit fraud upon the courts.
4. These actions are about dishonest people cloaked in positions of authority, a judicial system that tramples the Constitutional rights of Georgia citizens, and the failure of the various individuals and authorities established to protect citizens to do anything about this.
5. The serious issues presented herein came to my attention through my experience in the United States District Court for the Northern District of Georgia and the United States Court of Appeals for the Eleventh Circuit.
6. The employees of the Fulton County District Attorney’s Office and Mr. Steve Broadbent support these illegal activities through denying citizens the ability to succeed in getting charges filed or presenting their evidence to a grand jury. Upon information and belief, policies or customs of the Fulton County District Attorney’s Office may be the moving force behind some of the violations.
7. My undeniable proof of rampant corruption by federal judicial employees operating in Fulton County Georgia has been ignored so that justice will be obstructed and the criminals will be shielded.
8. My attempts to present my evidence to the Fulton County Grand Jury have been met with a variety of actions and inactions designed to damage me and deny my legal rights. Actions were taken by each of Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge.
9. I believe my first complaint to the Fulton County District Attorney’s Office about this was in January 2008. I called and was advised that I needed to call the U.S. Attorney. I called the U.S. Attorney, and I was told I needed to contact the FBI. I called the FBI, and I was told that they only pursue things that involve over $1,000,000. [Notes of my calls in January 2008.]
10. In 2009 and 2010, I presented criminal complaints to Mr. Howard and many others. Neither Mr. Howard nor anyone on his staff even extended the courtesy of a response. I wrote every member of Congress, the President, the FBI, every Presidential hopeful, every federal appellate court judge in America, and more. [Letters – 2009, Letters – 2010, Letters – 2011.]  In 2011, I have repeatedly written to the Fulton County Grand Jury. I suspect that most of these letters were intercepted by the Fulton County District Attorney’s Office.
11. On February 10, 2011, I presented a criminal complaint to Mr. Paul Howard. Once again, Mr. Paul Howard’s office did not even extend the courtesy of a response.
12. On February 10, 2011, I wrote a letter to the Fulton County Grand Jury to ask for an investigation of the criminal acts of federal judges in Atlanta.  The Grand Jury did not respond.
13. On March 28, 2011, I again wrote a letter to the Fulton County Grand Jury to ask to speak to the Grand Jury about an investigation of the criminal acts of federal judges in Atlanta.  The Grand Jury did not respond.
14. On March 29, 2011, I sent a letter to Mrs. Rebecca Keel stating I needed to meet with the Grand Jury.  Mrs. Rebecca Keel did not respond.
15. On March 30, 2011, I sent another letter to Mrs. Rebecca Keel stating I needed to meet with the Grand Jury.  Mrs. Rebecca Keel did not extend the courtesy of a response.
16. On March 31, 2011, I sent a letter to many elected Fulton County officials.  No one extended the courtesy of a response.
17. On May 6, 2011, I sent a letter by courier to the receptionist of the Fulton County District Attorney’s Office to warn her not to interfere with letters that I had delivered to each grand juror.
18. On May 6, 2011, I sent a letter by courier to District Attorney Mr. Paul Howard to advise him not to interfere with letters that I had delivered to each grand juror because the letters included charges against the Office of the District Attorney.
19. On May 6, 2011, I sent a fax to District Attorney Mr. Paul Howard when the courier was denied the legal right to present the letters from me to each grand juror.
20. On May 6, 2011, an hour or so after I sent a fax to Mr. Howard, an assistant district attorney called to say the Deputy Sheriff would accept the letters and deliver them to the Grand Jurors.
21. On May 6, 2011, my letters to the Fulton County Grand Jury asking to speak to the Grand Jury about an investigation of the criminal acts of federal judges in Atlanta were accepted by Deputy Betts.  The letters, addressed to each grand juror by number, were delivered by a courier, and Deputy Betts called me to confirm he was going to give them to each grand juror.
22. I heard nothing from the Grand Jury.
23. On May 14, 2011, I sent a fax to District Attorney Mr. Paul Howard to advise him of a reported assassination plot. I was seeking protection and asked what the District Attorney could do. There was no response.
24. On June 7, 2011, I received a letter from Herbert J. Bridgewater, Jr., Foreman of the Grand Jury, stating that the Fulton County Grand Jury did not have the power to consider my criminal charges.
25. On June 10, 2011, I sent a letter to Mr. Bridgewater and the Grand Jury Members to advise them that Mr. Bridgewater’s letter was not factual.
26. On July 22, 2011, I went to the office of the Fulton County District Attorney to deliver letters to the Grand Jurors and to speak to the Grand Jury about criminal charges against Mr. Paul Howard and others in Fulton County.
27. I arrived with sealed confidential envelopes with evidence for the Grand Jury, and Ms. Naomi Fudge said the Grand Jury didn’t want to speak with him.  I asked how she could possibly know that, and she did not respond.
28. I have various charges against the Fulton County Sheriff’s Department, but those are the subject of a separate criminal complaint.
29. After a group of deputies left after threatening me with arrest, Ms. Cynthia Nwokocha, Chief Investigator for the Fulton County District Attorney, told me that she would give the envelopes to the grand jurors.
30. It appeared that the Grand Jury was ushered out a private entrance to keep them from passing by me when they adjourned for lunch and for the day because they definitely did not pass through the public lobby to the elevators.
31. On July 22, 2011, I returned home and researched jury tampering. I discovered that what Deputy English and the others had done to me was jury tampering. I sent a   fax to Ms. Nwokocha, District Attorney Mr. Paul Howard, Sheriff Ted Jackson, and Major Christopher Leighty of the Atlanta Police Department detailing the violations and asking that criminal charges be pursued. There was no response.
32. On July 22, 2011, I called the Atlanta Police Department to file a criminal complaint. My name and number were taken, but no one ever returned the call.
33. On July 23, 2011, I sent a fax to Ms. Nwokocha, Mrs. Rebecca Keel, and District Attorney Mr. Paul Howard demanding to speak to the Grand Jury on Tuesday, July 26, 2011. There was no response.
34. On July 24 and 25, 2011, I left voice mails for Mrs. Keel to call. There was no response.
35. I called Fulton County Sheriff Jackson and was referred to Lieutenant Colonel Graham. I left a voice mail. There was no response.
36. Mid-afternoon on July 25, 2011, I sent a fax to Ms. Nwokocha, Mrs. Rebecca Keel, District Attorney Mr. Paul Howard, Sheriff Ted Jackson, Lieutenant Colonel Graham, and Major Leighty demanding that I be allowed to speak to the Grand Jury on Tuesday and asking that criminal charges be filed. There was no response.
37. Deputy Sheriff Roye informed me that the Fulton County Grand Jury was to vote on August 9, 2011 on whether or not to consider my evidence.
38. I spent the day on Tuesday, August 9, 2011 sitting in the lobby of the District Attorney’s Office holding a HELP sign.  Once again, hundreds of people passed by with not a soul offering to help.
39. When I saw Deputy Sheriff Roye not long after I arrived, I gave her a Letter to the Grand Jury Foreman.  She said she would give it to him, and she did.  I didn’t see her again for several hours.
40. Deputy Roye later handed me a  letter from Mr. Broadbent, the Grand Jury Foreman, asking me to submit my evidence. The last sentence of the letter is completely false.  O.C.G.A. 15–12-74 says: “Grand jurors have a duty to examine or make presentments of such offenses as may or shall come to their knowledge or observation after they have been sworn. Additionally, they have the right and power and it is their duty as jurors to make presentments of any violations of the laws which they may know to have been committed at any previous time which are not barred by the statute of limitations.”
41. At this point, the Grand Jurors had knowledge of offenses because I had brought them to their attention.  It was then their duty to investigate and make Presentments.  From at least August 9 to the present, my charges have been before the Fulton County Grand Jury.
42. I went back down to the Fulton County District Attorney’s Office for a meeting with Mrs. Rebecca Keel at 3:00 pm on August 9. She is one of the top lieutenants to Fulton County District Attorney Paul Howard, Jr.   We talked for about 45 minutes.   She knew very little about my story or my efforts other than the fact that she passed by me in the lobby many times over the past month.  So, I gave her a short synopsis.
43. I asked Mrs. Rebecca Keel to ask the Grand Jury to let me speak with them.  She said she would.
44. As requested, I hand-delivered my evidence to the Fulton County Grand Jury at 10:00 am on August 12, 2011.
45. I was immediately notified by Mrs. Rebecca Keel that I had been scheduled to testify before the Fulton County Grand Jury on Friday, August 19, 2011.
46. I worked night and day preparing the information for August 19, 2011.  One of the many people who called with advice suggested that I present each Grand Juror with a binder so they would have everything in front of them.  So, I prepared 26 binders — 23 Grand Jurors and three alternates.  I didn’t finish them until 9:30 the morning of August 19, just in the nick of time to hop in the car and get to the Fulton County District Attorney’s Office by 10 am.
47. Each binder had 23 tabs, and in the back of the binder was a CD-ROM with all the relevant evidence.  The Microsoft Word files for each tabbed section were on the CD as well, and all evidence was hyperlinked.  So, if they want to see a document, all it took was a click.  I made it as simple as humanly possible.
48. I arrived at 10 am and carried my big box of binders in.  I was greeted by Sabrina, a sweet lady from Fulton County who is a victim of judicial corruption.  She had brought her affidavit to me.
49. I went to sign in at the reception desk, and I was told to come on in, and Naomi Fudge buzzed me in past the locked door.  I put my name on a list as directed and sat down as directed.
50. Scott Hintz arrived a little later.  Scott is a big-time victim of judicial corruption.
51. A lot of people passed by me INSIDE theFulton County District Attorney’s Office…people who have seen me OUTSIDE with my sign for the past two months.  A few of them had kind words.
52. At about 11:30, an Assistant District Attorney waved to me to come in.  He did not introduce himself.  He told me I would not be allowed to distribute my binders.   I learned that he was Waverly Settles, the ADA who usually presents the indictment charges to the grand juries.
53. I was asked to sit at small table facing the jurors, who were seated in four tiers of seats.  The Foreman, Steve Broadbent, and three others were seated at a table similar to mine across the room.
54. Mr. Waverly Settles began by saying I didn’t have the right to be there, but the DA and Mrs. Rebecca Keel were “doing me a favor to allow me to speak for five minutes.”  He said that I didn’t have the right to speak to the Grand Jury.  He told the Grand Jurors that the correct procedure is to get elected officials to sign a petition that goes to the Chief Judge and then a decision is made whether to impanel a special grand jury.
55. When he came up for air, I said, “Respectfully, what you have just said is incorrect.  In Tab 3 of these binders, the statutes are provided, and it is clear that the Grand Jurors have a duty to investigate any crimes that come to your attention…and that has now happened.”  I explained that there is a procedure for a petition, but none of the Fulton County elected officials have extended the courtesy of a response.  Mr. Settles then had the binders passed out as he knew it would be wrong to hide them since I said they contained proof.
56. At that point, the Foreman spoke.  Mr. Steve Broadbent said that he could find no evidence in the information that I provided to him, and he said I have no credibility.  He said that I have claimed to have been the President of Goldman Sachs and CEO of Bain Capital.  He said he checked, and neither of those statements was true.   He was extremely rude.  He asked me to take 30 seconds and explain what I had evidence of.
57. I had to start by saying to him that I have never in my life claimed to have been the President of Goldman Sachs or the CEO of Bain Capital.  I told him that my bio said I was President of a Goldman Sachs Company and CEO of a Bain Capital company.  (Both Goldman and Bain own hundreds of companies.)
    
58. The page from my letters to the Fulton County Grand Jury of July 19 and August 5 actually state very clearly: “From 1992 to 1996, I was President of Advanstar Expositions, a company owned at the time by Goldman Sachs.  Advanstar was one of the largest producers of trade shows and conferences in the world.  From 1996 to 2001, I was CEO of 1st Communications, a company owned by Bain Capital, Triumph Capital Group, and me.”  [August 5, 2011 Letter — July 19, 2011 Letter.]
59. That could not be any clearer!  This was also provided on Page 1 of Tab 2 of the binder.  Steve Broadbent just grunted.  It was clear to me that his role was to attempt to discredit me and turn the Grand Jurors against me.  He was negative and disruptive throughout.
60. I spoke for less than 30 seconds of my planned presentation when jurors started raising their hands or just speaking.  I stopped and responded to questions and comments and was never able to give my carefully-prepared and timed presentation.
61. One male Grand Juror with a beard and suspenders said if I could prove to him that Judge Orinda D. Evans did what I said, he believes they must pursue it and 60 Minutes should do a story.  He said he thought thousands would show up at the courthouse to protest. He mentioned several pages in my binder and asked that I return with a slam bam thank you ma’am, just-the-facts narrative of no more than 20 pages with the evidence to prove things.  Several other jurors asked for that as well, and I told them I would be happy to.  I explained that all I had been asked to do today was to come and present a short overview and bring evidence, which I had done.
62. The woman seated closest to me was the most negative.  She said she refused to believe that judges are not honest, or words to that effect.  She said that I file frivolous lawsuits.  When she managed to come up for air, I asked who told her that I file frivolous lawsuits because it is absolutely false.  She looked toward Steve Broadbent and stuttered without giving a response.  Steve Broadbent jumped in and said something to try to change the subject, and Mr. Waverly Settles then asked me something about the lawsuits that I had filed, and I told him that his statement was not true.  He backed right down. Improper information was communicated to the Grand Jury by members of the Fulton County District Attorney’s. The Fulton County District Attorney’s Office was named in my sealed charges presented to the Fulton County Grand Jury, and Mr. Paul Howard was warned to not interfere in any manner as that would constitute another crime. It was clear to me that interference took place.
63. At this point, it was painfully clear to me that the jury had been tampered with.  They had been told disparaging things about me that clearly are not true.  I shouldn’t have been surprised, but I was.
64. A man seated next to Steve Broadbent then jumped in and said words to the effect that I have provided information to them that he knows is false.   He claimed I said Maid of the Mist had a 40-year federal government contract.  He said he has worked with the federal government, and he knows they do not do 40-year contracts.
65. I never said any such thing. Page 3 of Tab 4 of the binder that he was alluding to says quite clearly: “…fraud in obtaining no-bid 40-year government contracts….”
66. I politely explained to him that I said GOVERNMENT contracts and that they are with the State of New York and the Province of Ontario, and I held up the two contracts.  On the CD-ROM provided in a dozen of the binders, a file includes copies of both contracts.  New York State is 40 years, issued in clear violation of New York law.  I also have dozens of newspaper articles about these, and all of this as well as an affidavit from the newspaper reporter who exposed a lot of this was on the CD-ROM in the binders.  These contracts have been front page news in Canada. The Province of Ontario voided the contract, tendered it for competitive bids for the first time in 160 years, and fired the people involved.  The New York contract should be voided in the next two months; it is in default now.
67. The man just grunted when I explained.
68. When I could get in a few words, I let them know that this is not just about me.  I identified the affidavits provided from people who wish they could testify, and I informed them that there were at least two people in the lobby hoping to speak to them.  Mr. Steve Broadbent said only I could speak.
69. One sweet lady juror said I should just forget about what happened to me.  I told her I appreciated her advice, but I am committed to this for the rest of my life.  I emphasized several times that this is not just about me.
70. This sweet lady also suggested that I get an attorney to handle this.  I told her that I spoke with 24 attorneys, and no one would handle it.  Mr. Steve Broadbent said “well that tells us something right there.”  I wasn’t turned down because of content; every attorney told me right up front that they could not risk their careers going against judges.  Mr. Steve Broadbent is a politician, very much part of the legal establishment.  I was not surprised to find that he was out to damage me.  I was surprised that he committed crimes in doing so.
71. Mr. Waverly Settles called my time to a close a little after noon.  I told them I would be back with the 20-pages and evidence. I told Mr. Waverly Settles that I would be back Tuesday morning.
72. The second I left the Fulton County Grand Jury Room on the 19th, I spoke with Scott Hintz in the lobby of the DA’s Office, and I told him that I had been invited to return on Tuesday, August 23.
73. When I spoke with Scott in the lobby afterwards, he said two sheriff’s deputies were speaking with Ms. Naomi Fudge calling me a lunatic.
74. Scott said that he heard someone say that the Fulton County Grand Jury was meeting down on the second floor.  The Grand Jury Room is on the third floor.
75. Once all the other witnesses testifying before the Grand Jury had finished and gone and I was alone in the waiting room, I overheard a woman who works for the DA’s Office commenting to the receptionist that she was surprised to see the Grand Jury had ended already.  I shrugged it off knowing I was still on the list.  I figured she was confused, but she was at the other end of the room from me, and she was peering into the Grand Jury Room when she said this.  Now putting that together with the comment about the Second Floor, here’s what I think happened: I think they took all of the Grand Jurors down to the Second Floor to tell them I am a nutcase and various and sundry lies.  I believe they then came back upstairs and called me in.  I believe that explains why the questions were negative from the get-go.
76. As soon as I returned home on Friday the 19th, I sent a fax to Assistant District Attorney Rebecca Keel to confirm my scheduled appointment with the Fulton County Grand Jury for Tuesday August 23, 2011 and to cover some procedural issues for the presentation, such as format and use of a laptop to project images.  I also called and left a voice mail asking Mrs. Rebecca Keel to call.  She did not return my call…ever.  The letter said: “It wasn’t a warm reception, but I have been invited back on Tuesday with 20 pages of specific proof.  Can you tell me what time I can speak on Tuesday?”
77. On August 19, I also sent a fax to Grand Jury Foreman Steve Broadbent and Assistant District Attorney Waverly Settles.  The last paragraph of this letter says: “When I return on Tuesday with my 20-page or less document and proof, I would like to actually be able to speak. I was not allowed to give my carefully-planned presentation today.  But thanks so much for the invitation to return.”
78. On August 21, 2011, the news report came out that the Atlanta Office of the FBI had created a special task force to investigate judicial corruption.  I sent a fax to Mrs. Rebecca Keel with a copy of the article and several comments about the jury tampering that I observed during my time with the Fulton County Grand Jury.
79. On Monday August 22, 2011, I sent a fax to Mrs. Rebecca Keel advising her that I had been working around the clock and that I would be there on Tuesday at 9 am.  I made several specific requests about my testimony.
80. So, Mrs. Rebecca Keel received three faxes and a voice mail from me from Friday through Monday — all in regard to my Tuesday testimony before the Fulton County Grand Jury.  And Mr. Steve Broadbent and Mr. Waverly Settles received one fax.  My presentation to the Fulton County Grand Jury for August 23 was confirmed again and again and again.
81. When I returned on August 23, 2011 to testify after being invited back after my meeting with the Grand Jurors on Friday, I was denied my audience with the Fulton County Grand Jury.
82. I arrived at the Fulton County District Attorney’s Office at 9:10 am.  Seven local victims of judicial, prosecutorial, and attorney corruption showed up.  Sabrina Felton, Ed Dort, Scott Hintz, Mark S., Barbara Rose, Lisa, and I got acquainted, shared stories, and made a pact that we will all work together and get others to work with us to root out the corruption and seek justice.  We were joined by a reporter from CBS Atlanta.  He asked a lot of questions and listened to each of us.  We sat and talked for two hours, and nobody said boo to us.
83. At 11 am, Ed followed me to Naomi Fudge’s window to be a witness.  I asked to see Mrs. Rebecca Keel, and Naomi Fudge rudely told me to sit down.  Ed asked whether I am always treated that way, and I told him no, it’s usually worse.
84. At 11:30 or so, Deputy Sheriff Roye came by for a chat.  She said she would check on my appearance with the Grand Jury, but she was never seen again.
85. At noon, I saw several Grand Jurors leaving; I assumed for lunch.  They never returned.
86. At about 12:45, Assistant District Attorney Mr. Waverly Settles waved me in from the outer door to the Fulton County District Attorney’s Office.  I grabbed my dolly holding two jam-packed paper cases containing my evidence — 164 exhibits to go with the 20-page Complaint that I was told to prepare.  Mr. Settles would not allow my evidence to be brought in to the DA’s Office.  I grabbed my iPhone and note pad, and I asked if my friends could come, and he said no.  I went in alone.  He took me into the Grand Jury Room where Foreman Mr. Steve Broadbent was seated at a small conference table.  The room was otherwise empty.
87. I was told by Mr. Waverly Settles and Mr. Steve Broadbent that I didn’t have an invitation to speak to the Fulton County Grand Jury on Tuesday.  I said that I most definitely did.
88. They actually sat there and told me they did not know where I got the idea that I had been invited to come back to present.  I recounted the exact discussion that was held in front of the entire Fulton County Grand Jury.  They had all of my letters in front of them with yellow highlighter over select sentences.  I reminded Mr. Waverly Settles that as I left the Grand Jury Room on the 19th, my last words to him as I exited were: “I’ll be back with the 20-pages and my evidence on Tuesday.”
89. Mr. Waverly Settles threatened me with a lawsuit for defamation.  He said a letter that I faxed to Mrs. Rebecca Keel saying I suspected that Mr. Waverly Settles and Mr. Steve Broadbent slandered me to the Grand Jurors constituted defamation. Mr. Waverly Settles said that if he sees his name in print again, he will sue me.
90. I asked Mr. Steve Broadbent for an apology for the lies that he told the Fulton County Grand Jury about me.  He refused to do so.  He said he didn’t lie.  I told him he most certainly did.  He claimed he had letters from me that say I was the President of Goldman Sachs and the CEO of Bain Capital.  I told him to produce the letters then.  I told him no such letters exist.  I told him he is a liar.
91. As I got up to leave, Mr. Waverly Settles told me to be careful what I say about the meeting because there was a reason there were two of them in the room and only me.  Upon information and belief, they planned to lie about what happened and it would be two against one.
92. Their actions are jury tampering, obstruction of justice, violation of their oaths of office, and more.  I sent a fax to Mrs. Rebecca Keel and District Attorney Paul Howard advising them that I wished to file criminal charges for jury tampering.
93. On Thursday, August 25, 2011, I mailed certified mail return receipt letters to each member of the Fulton County Grand Jury. They were personally addressed Grand Juror #1 to #23 and Alternate 1, 2, and 3. Interfering with the U.S. Mail is a federal crime.  So, if the Fulton County District Attorney’s Office interfered with the mail, additional criminal charges need to be filed — 36 counts.
94. On Friday, August 26, 2011, I spent three hours at the Fulton County District Attorney’s Office.  My two cases of evidence were parked on a dolly right next to the door.  I changed my sign to read: “EVIDENCE OF GRAND JURY TAMPERING — Act or be an Accessory.”
95. At 9:45 am, receptionist Ms. Naomi Fudge refused to accept my evidence and deliver it to the Fulton County Grand Jury.  Deputy Sheriff L. Bailey was my witness to this. 
96. At about 10:20, Senior Chief Assistant District Attorney Gabe Banks walked into the lobby with a half dozen high-powered people from the police and FBI.  They had just been in a meeting with the Fulton County District Attorney.  I hopped up and said: “I need to report jury tampering with this Grand Jury.  Will one of you help me?  No one moved or said a word.  The silence was deafening.  Finally, Mr. Banks said, “I will get someone to speak with you.”  He went inside, and when he came back out, he said, someone will be with you in just a few minutes.  Two hours and ten minutes later, no one ever came.
97. At 10:50, Deputy Sheriff Betts came by, refused to take my evidence to the Grand Jury, and made various threats to me.
98. At 11:05, the usually-friendly Deputy Sheriff Roye walked by.  She refused to deliver my evidence to the Fulton County Grand Jury.  Officer Bailey of the Atlanta Police Department was my witness to that.  Deputy Roye said I needed to talk to Mr. Waverly Settles, and I told her that’s impossible because I am bringing charges against him.  She just walked away.
99. At 11:14, Deputy Sheriff Betts came by again and sneered that “no one is coming out to see you.” I was on the telephone with Scott Hintz, and he heard the conversation.
100. At 11:18 am, I told Ms. Naomi Fudge that I needed to see Fulton County District Attorney Paul Howard, Jr.  She told me he wasn’t in.
101. At 11:45 am, a Grand Juror who knows one of the people who was there to testify with me last Friday passed by and said hi.  I asked if she would take my envelope of evidence, and she said she didn’t know if she could.  I never saw her again.
102. At 11:52 am, a group of people came to the elevator.  They told me they had just finished a meeting with District Attorney Paul Howard.  I said “that’s not possible; the receptionist told me he wasn’t in.”  I went over to Ms. Naomi Fudge and again demanded a meeting with District Attorney Howard, and she even more rudely told me to sit down.
103. At 12:15, Assistant District Attorney Rebecca Keel walked to the elevator.  She ignored my evidence.  I told her I was going to file criminal charges against her, and she said “do what you gotta do.”
104. At 12:20 pm, Fulton County Grand Jury Foreman Mr. Steve Broadbent and another man left.
105. At 12:30 pm, the Grand Juror who was supportive at the August 19 session came to the elevator.  I asked if he would accept my envelope of evidence for the Grand Jury.  I told him the envelope contained the evidence that he specifically requested last week.  He took the envelope and was opening it as he got on the elevator. He had proof of the crime that he requested, and he had my charges of jury tampering by Mr. Steve Broadbent, Mr. Waverly Settles, or whoever lied to the Grand Jury and then blocked my scheduled August 23, 2011 meeting.
106. I packed up my stuff and headed for the Fulton County Criminal Warrants Desk to make application for arrest warrants for six people.  In Fulton County, anyone can go there, fill out a brief complaint form, pay $10, and the person you are complaining about has to appear in Fulton County Magistrate Court where the Magistrate decides if an arrest warrant should be issued.  I was in line behind people getting them for an abusive husband, a rowdy neighbor, a restraining order on an ex-husband, and the like.  All submitted their form, paid their $10, and got their court date.
107. It took me about an hour to fill out my six complaints.  I proudly took them to the window with my $60 in hand, and the minute the clerk saw who I was charging, she left to speak to a supervisor.  She returned to tell me that she was unable to process them because her supervisor said to hold them until they could get clearance from some unknown power.
108. I asked to speak to her supervisor, and Ms. Asby came out and spoke with me in a jam-packed reception area.  I told her that if a woman can file a request for a warrant over a noisy neighbor, then I can certainly file warrant applications against people committing serious felonies to protect a criminal racketeering enterprise.  She didn’t budge.  She said I could see the State Court Administrator, Cicely Barber.  So, I rolled my dolly of evidence to Ms. Barber’s office.
109. I spoke to Ms. Barber for about 10 minutes.  She said “these people were acting in their official duty when they did this.”  I said, “yes, they were, but that is irrelevant.  They committed crimes, and there is no immunity — never has been — for any government official who commits crimes.”  She said she would discuss it with her boss, but she said she didn’t believe they would let me file them.  I told her that I don’t believe they have any option.
110. I sent an email to Ms. Barber and her boss, Mark N. Harper, Chief Clerk of the Superior Court of Fulton County.
111. On August 27, 2011, I sent a fax to the Fulton County District Attorney stating that I want to press criminal charges against Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge.

TAMPERING WITH EVIDENCE

1. Tampering with Evidence, in violation of O.C.G.A. 16-10-94, is when a person obstructs the prosecution or defense of any person by knowingly destroying, altering, concealing, or disguising physical evidence or making, devising, preparing, or planting false evidence. The state must prove beyond a reasonable doubt that (1) the defendant believed that an official proceeding was pending or about to be instituted, (2) the defendant (tampered with / fabricated) physical evidence, or altered / destroyed / concealed / removed) any (record / document / item) with the purpose of impairing its verity or availability in such proceeding.  O.C.G.A. 16-10-94 is a RICO predicate act.
2. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge knew that an official proceeding was pending or about to be instituted.  Mr. Steve Broadbent acknowledges this in his August 9, 2011 letter.
3. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge concealed my evidence with the purpose of impairing its availability in such proceeding. Mr. Steve Broadbent lied to the Grand Jury about the evidence that I provided to him on CD-ROM. Mr. Steve Broadbent and Mr. Waverly Settles refused to allow me to present my evidence or to even accept it.  Ms. Rebecca Keel and Ms. Naomi Fudge refused to accept my evidence on several occasions.
4. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge violated O.C.G.A. § 16-10-94.

OBSTRUCTION OF JUSTICE

1. Obstruction of Justice is deemed to be any conduct that interferes with the due administration of justice in any manner. The elements are (1) that there was a pending judicial proceeding, (2) that the defendant knew this proceeding was pending, and (3) that the defendant then corruptly endeavored to influence, obstruct, or impede the due administration of justice. Obstruction of justice is a RICO predicate act.
2. There was a pending proceeding with my charges presented to the Fulton County Grand Jury.
3. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge knew that there was a pending judicial proceeding.  Mr. Steven W. Broadbent acknowledges this in his August 9, 2011 letter.
4. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge corruptly obstructed justice and impeded the due administration of justice.
5. Mr. Steve Broadbent obstructed justice by providing false information to me, by making false and defamatory statements to the Grand Jurors, and by blocking my evidence from being presented to the Fulton County Grand Jury.
6. Mrs. Rebecca Keel obstructed justice by providing false information to me, by ignoring my criminal charges, and by blocking my evidence from being presented to the Fulton County Grand Jury.  Upon information and belief, Mrs. Rebecca Keel also gave false information to the Fulton County Grand Jury.
7. Mr. Waverly Settles obstructed justice by providing false information to me, by ignoring my criminal charges, and by blocking my evidence from being presented to the Fulton County Grand Jury.  Upon information and belief, Mr. Waverly Settles also gave false information to the Fulton County Grand Jury.
8. Ms. Naomi Fudge obstructed justice by providing false information to me and by blocking my evidence from being presented to the Fulton County Grand Jury.  Upon information and belief, Ms. Naomi Fudge also gave false information to theFulton County Grand Jury.
9. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge committed obstruction of justice

 

OBSTRUCTION OF JUSTICE AND INFLUENCING WITNESSES

1. Obstruction of Justice and Influencing Witnesses is when any person knowingly engages in misleading conduct toward another person with intent to influence, delay, or prevent the testimony of any person….”
2. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, Ms. Naomi Fudge, and unknown others are guilty of obstruction of justice and violation of O.C.G.A. § 16-10-93: “(b)(1) It shall be unlawful for any person knowingly to use intimidation, physical force, or threats; to persuade another person by means of corruption or to attempt to do so; or to engage in misleading conduct toward another person with intent to: (A) Influence, delay, or prevent the testimony of any person in an official proceeding;(C) Hinder, delay, or prevent the communication to a law enforcement officer, prosecuting attorney, or judge of this state of information relating to the commission or possible commission of a criminal offense or a violation of conditions of probation, parole, or release pending judicial proceedings.”
3. O.C.G.A. § 16-10-93 is a RICO predicate act.
4. There was a pending proceeding with my charges presented to the Fulton County Grand Jury, and I was the witness.
5. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge knew that there was a pending judicial proceeding and that I was the witness.  Mr. Steve Broadbent acknowledges this in his August 9, 2011 letter.
6. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge corruptly obstructed justice and impeded the due administration of justice with me by influencing, delaying, and preventing my testimony.
7. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge committed obstruction of justice with a witness. 

 

MAKING FALSE STATEMENTS

1. Making False Statements is when a person knowingly and willfully falsifies, conceals, or covers up by any trick, scheme, or device a material fact; makes a false, fictitious, or fraudulent statement or representation; or makes or uses any false writing or document, knowing the same to contain any false, fictitious, or fraudulent statement or entry, in any matter within the jurisdiction of any department or agency of state government or of the government of any county, city, or other political subdivision of this state. (O.C.G.A. § 16-10-20.)  O.C.G.A. § 16-10-20 is a RICO predicate act.
2. Mr. Steve Broadbent made statements to the Fulton County Grand Jury in my presence that willfully falsified material facts.
3. Upon information and belief, Mr. Waverly Settles and Mrs. Rebecca Keel made statements to the Fulton County Grand Jury that willfully falsified material facts.
4. Upon information and belief, Mrs. Rebecca Keel and Mr. Waverly Settles committed the crime of Making False Statements.
5. Upon information and belief, Mr. Steve Broadbent, Mrs. Rebecca Keel, and Mr. Waverly Settles each made false statements.
6. Mr. Steve Broadbent committed the crime of Making False Statements.
7. Upon information and belief, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge committed the crime of Making False Statements.
   

EMBRACERY

1. A person commits the offense of embracery when he, with intent to influence a person summoned or serving as a juror, communicates with him otherwise than is authorized by law in an attempt to influence his action as a juror. (O.C.G.A. § 16-10-91.)
2. Mr. Steve Broadbent communicated with the Grand Jurors in my presence in a manner otherwise than is authorized by law in an attempt to influence their actions as jurors. 
3. Upon information and belief, Mr. Waverly Settles and Mrs. Rebecca Keel communicated with the Grand Jurors in my presence in a manner otherwise than is authorized by law in an attempt to influence their actions as jurors.
4. Upon information and belief, communicated with the Grand Jurors in my presence in a manner otherwise than is authorized by law in an attempt to influence their actions as jurors.
5. Mr. Steve Broadbent committed the crime of Embracery.
6. Upon information and belief, Mrs. Rebecca Keel and Mr. Waverly Settles committed the crime of Embracery.

 

CONSPIRACY

1. Conspiracy is when two or more persons conspire to commit any criminal offense. Conspiracy to obstruct justice is when two or more people conspire to commit any crime and any one or more of such persons does any overt act to effect the object of the conspiracy. Conspiracy (1) an agreement of two more individuals; (2) to commit a crime; and (3) an overt act by one of conspirators in furtherance of the scheme. (O.C.G.A. § 16-4-8.)
2. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge conspired to obstruct justice and impede the due administration of justice with me by influencing, delaying, and preventing my testimony and blocking my evidence from reaching the Fulton County Grand Jury.
3. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge each committed overt acts in furtherance of the scheme. 
4. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Wagverly Settles, and Ms. Naomi Fudge committed conspiracy.

 

RICO

1. RICO is a pattern of committing criminal acts. RICO requires proof of at least two of several of the just identified crimes. RICO requires showing an ongoing pattern of racketeering activity, which is to commit, to attempt to commit, or to solicit, coerce, or intimidate another person to commit any crime. The acts of racketeering activity committed by the Defendants have the same or similar methods of commission in that they involve the various aspects of committing fraud in legal matters, including obstruction of justice. The “pattern of racketeering activity” consisted of many incidents of racketeering activity that have the same or similar intents, results, accomplices, victims, and methods of commission and are interrelated by distinguishing characteristics. (O.C.G.A. 16-14-1, et. seq.)
   
2. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge have conducted an enterprise through which they have committed racketeering activity.  The Georgia Act defines an “enterprise” as “any person . . . corporation . . . or other legal entity . . . or group of individuals associated in fact although not a legal entity. The Defendants were thus an “enterprise.”
3. The “pattern of racketeering activity” required to be shown by the Georgia statute is defined as engaging in “at least two incidents of racketeering activity that have the same or similar intents, results, accomplices, victims, or methods of commission or otherwise are interrelated by distinguishing characteristics and are not isolated incidents O.C.G.A. § 16-14-3 (2).
4. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge have committed multiple counts of obstruction of justice, obstruction of justice with a witness, and obstruction of justice with evidence. The predicate acts are detailed above. These are predicate acts under the Georgia RICO Act.
5. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge have engaged in an ongoing pattern of racketeering activity as defined by O.C.G.A. § 16-14-3(8).  Each one has committed crimes.
6. “Racketeering activity” is defined to mean the commission of a crime in any of thirty-one specified categories of offenses (known as predicate offenses). O.C.G.A. § 16-14-3 (3), and Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge have commitets several of the specified categories of offenses.
7. Evidence of two predicate acts is required, and Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge have committed many in providing false and defamatory information to the Fulton County Grand Jury and committing obstruction of justice by interfering with evidence for the Fulton County Grand Jury.
   
8. The acts of racketeering activity have all had the similar objective of obstruction of justice.
9. The racketeering acts were a part of a systematic and ongoing pattern that was concealed by a scheme of subterfuge and intimidation.
10. Through a pattern of racketeering activity, Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge acquired money.
11. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge are associated with an enterprise, and did through a pattern of racketeering activity, conduct and participate in the enterprise.
12. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge’s acts of racketeering activity involve a distinct threat of long-term racketeering activity.
13. This activity has continued for some time, is ongoing at the present time and will continue into the future unless halted by judicial intervention.
14. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge’s actions appear to be part of its regular way of conducting business by the Fulton County District Attorney’s Office.
15. Mr. Steve Broadbent, Mrs. Rebecca Keel, Mr. Waverly Settles, and Ms. Naomi Fudge have violated the Georgia RICO Act.

FURTHER SAITH AFFIANT NOT.

In accordance with 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct based upon my personal knowledge.

Executed this 28th day of August 2011,

William M. Windsor

Steve Broadbent’s Resume

University of Virginia
B.S., Nuclear Engineering
1971 – 1976

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email: stevebroadbent@fulcrumpartnersllc.com

William M. Windsor

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