'23 NOU 13 PM5:45

LEON CO. CLERK/COlU

TO: FIRST APPEARANCE MAGISTRATE

DEFENDANT: Donna Sue Adelson

CHARGES: pt Degree Murder, Conspiracy to Commit is• Degree Murder, Solicitation to

Commit 1st Degree Murder

SUMMARY OF OFFENSE AND PROBABLE CAUSE AFFIDAVIT

This affidavit sets forth probable cause to believe that Sigfredo Garcia (Garcia) and Luis
Rivera (Rivera) murdered Florida State University (FSU) Law School Professor Daniel Markel
and the murder was arranged through Katherine Magbanua, Charles Adelson and Donna Adelson
in violation of Florida Statutes: Murder per Chapter 782.

On Friday, July 18, 2014, at 11:02 a.m., a report of a shooting was received at 2116
\
Trescott Dr., the home of Florida State University Law School Professor Daniel Markel
(Markel), in Tallahassee, Florida. Upon arrival, Tallahassee Police officers found Markel
slumped over in the driver seat of his vehicle from an apparent gunshot to the head. Markel was
transported from the scene to a local hospital where he later died from the injuries sustained
during the shooting. The investigation of the crime scene found no indication that this incident
was part of any other criminal intent, such as burglary or robbery. A neighbor heard a loud bang
and looked out his window, where he saw a small silver or light-colored vehicle, resembling a
Prius, backing out of the victim's driveway. He walked over to check on Markel, discovered him
in distress, and called 911.

Investigators located the victim's ex-wife, Wendi Adelson at a local restaurant and
transported her to the Tallahassee Police Department for an interview. During the interview of
Wendi Adelson, she made statements suggesting the murder of Markel could have been arranged
by someone on her behalf, without her knowledge. Wendi indicated her parents were very angry
at Markel and further suggested that someone could have arranged the murder thinking it would
help her. She specifically mentioned that her brother, Charles aka Charlie Adelson, joked about
hiring a hit man to kill Markel in the past. She said her brother makes a lot of jokes in bad taste
and had previously commented that he looked into hiring a hit man, but it was cheaper to buy her
a television as a divorce gift. Wendi indicated that she did not think her brother would actually
commit this crime. It should be noted that Wendi's mother Donna Adelson set a television repair
appointment on July 11, 2014 for Wendi's television to be repaired on the morning of the
homicide July 18, 2014. Records obtained from Best Buy show a service was completed on her
television the morning July 18, 2014, the same date of the homicide.

Wendi stated that, after the divorce, she wanted to relocate to South Florida with her
children. She felt her former in-laws would suspect her ofmurdering their son since she was
denied the ability to move by the court.

Wendi filed for divorce on September 10, 2012. The divorce was later finalized by a
Marital Settlement Agreement (MSA) on July 31, 2013. Investigators reviewed voluminous
documents including emails, text messages, and court documents. The review determined Wendi
 Adelson and her brother, Charles, as well as their parents, Harvey, and Donna Adelson, were
determined to have Wendi and the two Markel children relocated to South Florida, where the
Adelson's reside after her divorce from Markel. Markel objected to bis ex-wife moving his
children to South Florida; and on June 20, 2013, Leo11 County Circuit Judge Hobbs formally
denied with prejudice Wendi's Motion for Relocation with·the children.

After the Court's denial Wendi's parents, especially her mother, Donna Adelson,
repeatedly tried to convince Wendi to coerce Markel into allowing the relocation to South
Florida. Donna suggested the family offer Markel $1,000,000.00 to allow the relocation, with
Donna Adelson and her husband Harvey Adelson contributing 1/3, Wendi Adelson contributing
1/3, and Charles Adelson contributing 1/3. Donna also suggested that Wendi threaten to convert
Market's children to Catholicism knowing Markel was very observant in his Jewish faith and
that the religious practices of the children were of the utmost importance to Markel.

Wendi Adelson' s prior boyfriend Jeff Lacasse stated Wendi disclosed to him that Charles
had seriously looked into hiring a hit man in the summer of2013 and he was told it would cost
either $15,000 or $50,000. Lacasse also reported that when he was visiting Charles Adelson with
Wendi Adelson in the spring of 2013, Charlie Adelson bragged about being connected to a
Cuban criminal element.

It was learned that around the time of the murder, Katherine Magbanua was involved in a
personal relationship with Charles Adelson. Magbanua's cellular telephone number was 786-
564-1312. Call records show Magbanua as one of Charles's top contacts and text
communication confirmed the relationship was more than a friendship.

It was later confirmed by Katherine Magbanua, Charles Adelson enlisted Magbanua who
then enlisted the father of her two children, Sigfredo Garcia, to carry out this murder. Garcia
enlisted Rivera's assistance and Magbanua, Garcia and Rivera were compensated for their
actions. Magbanua was the only link between Markel and the shooters, Garcia and Rivera
Magbanua's only ties to Daniel Markel are Charles Adelson and a couple instances where she
met Wendi Adelson. The only way Magbanua, Garcia, and Rivera knew of Daniel Markel and
his relationship with the Adelson family was through Charles Adelson.

While in the interview room, Wendi wanted to call her parents to notify them of the
incident. While contemplating aloud as to what she would say, she told the victim advocate
sitting next to her that her parents were very angry with Markel and described it as "a very
, fucked up situation." Wendi then called and talked to her mother, Donna. After notifying Donna
of the shooting, Wendi asked her to notify Charles of the shooting so Wendi would not have to
do so. After Wendi's conversation with her mother, Donna Adelson called Charles's cellphone at
7:11 p.m. which went to voicemail. Charles then called Donna's cellphone at 7:13 p.m. with a
call duration of 5 minutes, 47 seconds. At 7:29 p.m. Charles called Donna again with a duration
of 6 minutes, 31 seconds. At 7:36 p.m. Charles called Katherine Magbanua's cellphone with a
duration of 2 minutes and 49 seconds.

Wendi's parents, Harvey and Donna Adelson, made contact with the lead TPD
investigator at Market's memorial service on Sunday morning, July 20, 2014, in Tallahassee.
They agreed to contact the TPD investigator to arrange an interview before returning to South
Florida. The following day, the TPD investigator contacted Wendi on her cellular telephone.
Once the investigator identified himself, Wendi claimed to have a bad connection and the call
was tenninated. Less than five minutes later, Wendi's attorney called the investigator and
informed him that Wendi left town with her children and parents in route to South Florida. The
attorney could not provide a date for Wendi's return to Tallahassee, and requested he be
contacted for any further inquiries.

Harvey and Donna Adelson left Tallahassee with Wendi and the grandchildren the day
after the memorial service'without speaking with the investigator as promised. Since leaving, no
one in the Adelson family contacted TPD or inquired about th~ status of the investigation.
Charles Adelson did not attend the memorial service for his ex-brother-in-law. In July of 2015,
Wendi had her children's surname changed from Markel to Adelson.

On July 18, 2014, Markel left his home that morning and drove his two children to
daycare on the west side of Tallahassee. Markel drove to Premier Health and Fitness Center.
Markel arrived at Premier, where surveillance video shows a silver or light green Toyota Prius
enter the parking lot after Markel parked his car. After Markel went into the health club, the
video captured the Prius in the parking lot where the driver moved the vehicle to different
parking positions while Markel was in the building. No individuals ever exited the Prius.

Additional surveillance video discovered for the day of the homicide showed the same
Prius before and after the homicide, including following Markel into Market's neighborhood
immediately prior to the shooting. After analyzing the surveillance videos, the suspect vehicle
was determined to be a 2006-2009 Toyota Prius with 'Silver Pine Mica' paint color. The Prius
had tinted windows, a Sunpass transponder on the top-center of the windshield, a missing tow-
hook cover on the front bumper and a black passenger side mirror casing. It was determined the
Prius followed the victim throughout the morning and back toward his residence where the
shooting occurred. This suspect vehicle fit the description given by Market's neighbor after he
heard a gunshot and looked out the window and saw the Prius backing out of the victim's
driveway.

Florida Department of Transportation (FOOT) records for Sunpass on Alligator Alley, 1-

75 west of Ft. Lauderdale, on July 16, and 18, 2014 had one account listing a Prius as a customer
vehicle. The Sunpass transponder activity was consistent with cell site data for Rivera and
Garcia's handsets travels. The transponder of interest in this case is number 11525706-01-10,
per FOOT records. The Sunpass account using the above transponder is a rental car company in
North Miami, Florida. Law enforcement obtained the rental contract for a 2008 Toyota Prius on
July 15, 2014, three days.before the homicide. The customer is listed as "Luis Rivera" with a
contact number of 305-570-8153. A second telephone number was also written on the rental
contract, 786-372-5986, Garcia's phone, with the word "Brother" written beside the number.
The rental contract indicates the Prius was checked out at 6:15 p.m. on July 15, 2014, and rented
to Rivera through July 21, 2014, three days after the homicide.

The Prius rented by Luis Rivera on July 15, 2014, contained a OPS device installed by /
the owner to assist with theft or non-return. The GPS company records have the vehicle location
on July 15, 2014, at 10:25 p.m. EDST, at the parking lot of7501 E. Treasure Drive, North. Bay
Village, Florida. This was the location ofMagbanua's residence at that time. On July 18, 2014,
at 12:26 a.m. EDST, the vehicle was located at North Monroe Street and East 6th Avenue,
Tallahassee, Florida. On July 19, 2014, at 1:26 a.m. EDST, the vehicle was located behind 1505
N.E. 135 Street, North Miami, Florida. This address is the residence of Jessica Rodriguez, who
was a girlfriend of (and has a child with) Rivera.

Cellular location data for Magbanua, Garcia, and Rivera is consistent with them being in
the area ofMagbanua's residence during and around the time the vehicle OPS showed its
location to be in the parking lot ofMagbanua's condominium. Both Garcia and Rivera met with
Magbanua the night before departing for Tallahassee to commit the murder.

Analysis of Rivera's checking account revealed an ATM transaction took place in

Broward County on July 18, 2014, at 6:46 p.m. as they were returning to Miami from
Tallahassee, Florida. Security video from the drive-through ATM lane shows Rivera driving a
Toyota Prius up to the ATM at 6:45 p.m. As the Toyota Prius exits the ATM area at 6:47 p.m., a
Florida license plate can be seen on the rear of the car. The tag characters match those of the car
rental contract.

Cellular records show numerous contacts between Katherine Magbanua and both Charles
Adelson and Sigfredo Garcia. On one occasion, telephone records show contact between
Garcia's handset and a cellular telephone registered to Harvey Adelson, Charles and Wendi
Adelson's father on July 1, 2014. At approximately 11 :47 a.m., Magbanua's telephone began
attempting to contact Garcia's telephone. Over the next 5½ hours, Magbanua attempted to
contact Garcia approximately 48 times. At 5:05 p.m., Magbanua made contact with Garcia, and
they had a conversation lasting 6 minutes and 22 seconds. Approximately 9 minutes later, at
5:20 p.m., Garcia's cellular telephone attempted to contact Harvey's cellular telephone. The
cellular records indicate this call went to voicemail.

Telephone number 786-3 72-5986 was being used by Garcia prior to the murder and had
been in contact with Magbanua's telephone number, 786-564-1312, approximately 2,700 times
between May 1, 2014 and July 19, 2014, when Garcia's cellular phone ceased activity, the day
after the homicide. Telephone number 305-570-8153 belonged to Luis Rivera during the time
leading up to Markel's murder.

The following contacts took place the morning of July 18, 2014:

• 12:00-12:23 a.m. -RIVERA's and GARCIA's handsets communicated with cell sites in
the area of Roadway Inn on N. Monroe St.
• 12:01 a.m. - MAGBANUA contacts GARCIA (over 1 minute)
• 12:07 a.m. -CHARLES ADELSON contacts MAGBANUA (over 7 minutes)
• 12:34 a.m. -MAGBANUA contacts CHARLES ADELSON (less than 1 minute)
• 1:02 a.m. - CHARLES ADELSON contacts DONNA ADELSON
• 1:03 a.m. - CHARLES ADELSON contacts MAGBANUA (20 minutes)
• 8:09 a.m. - DONNA ADELSON contacts WENDI ADELSON (35 seconds)
• 8:50 a.m. - DANIEL MARKEL drops his children off at Creative Preschool, 2746 W.
Tharp St., Tallahassee, Fl.
• 9:02 a.m. - DANIEL MARKEL contacts WENDI ADELSON (1 minute)
• 9:12 a.m. - CHARLES ADELSON contacts WENDI ADELSON (less than 1 minute)
• 9:19 a.m. - WENDI ADELSON contacts CHARLES ADELSON (over 18 minutes)
• 9:38 a.m. - CHARLES ADELSON contacts DONNA ADELSON (30 seconds)
• 9:58 a.m. - CHARLES ADELSON contacts MAGBANUA (over 6 minutes)
• 10:07 a.m. - MAGBANUA contacts CHARLES ADELSON (over 1 minute)
• 10:08 a.m._ - MAGBANUA contacts CHARLES ADELSON (9 seconds)
• 10:09 a.m. - CHARLES ADELSON contacts MAGBANUA (6 minutes)
• 10:52-10:55 a.m. - Neighbor hears gunshot and sees small light colored vehicle puliing
out of Markel's driveway
• 11 :00 a.m. - Subject on phone with MARKEL attempts to call MARKEL back, call goes
to voicemail
• 11:01 a.m. -Subject texts MARKEL asking ifhe is okay
• 11 :02 a.m. - MARKEL'S neighbor calls 911
• 11 :06 a.m. - DONNA ADELSON contacts CHARLES ADELSON (either attempted call
or text)
• 11 :22 a.m. - CHARLES ADELSON contacts DONNA ADELSON (7 minutes)
• 11 :30 a.m. - CHARLES ADELSON contacts MAGBANUA (30 seconds)
• 11:31 a.m. - CHARLES ADELSON contacts MAGBANUA (5 minutes)

On the morning of July 18, 2014, Garcia's telephone ceased activity just before 10:00
a.m. while in the area of Premier Gym, with the last text message occurring at 9:58 a.m. The
next event on Garcia's telephone was text messages and/or notifications being received at 12:29
p.m. Immediately afterward at 12:30 p.m., Garcia placed a call to Magbanua, which was the first
contact initiated by Garcia after the homicide. This call occurred when Garcia's phone was in
the area of Lake City, Florida, on or near 1-75 approximately one and a half hours after the
shooting was reported.

Approximately two hours after Garcia and Rivera arrived back in Miami, Magbanua
departed her residence and went to Rivera's residence while attempting to contact Garcia
telephonically. While Magbanua, Garcia, and Rivera were together, Magbanua had telephonic
contact with Charles Adelson. Magbanua traveled north to Charles Adelson's residence where
she would remain until the following morning. Magbanua stated while at Charles Adelson's
residence Charles Adelson was armed and acting frantic. Charles told her his mother and father
had just left his residence and left money that his mom had washed. At Adelson' s trial,
Magbanua testified that the money she received was damp and moldy, consistent with being
physically washed, and was stapled into $1,000 stacks. Magbanua took a Xanax that was
provided by Adelson and fell asleep. The next morning, 7/19/2014, at 9:44 a.m., Magbanua left
the residence and was told by Adelson that the money was in the trunk of her car. Magbanua
attempted to contact Garcia.

Communication records in Charles Adelson's iCloud show Donna Adelson telling

Charles Adelson she was "outside your house" at approximately 8:59 pm on July 18, 2014.
Cellular records for Donna Adelson and Harvey Adelson show an arrival time of 1:25 am in
Orlando, FL leaving an approximate hour and a half time block consistent with her being at
Charles's residence. Donna and Harvey Adelson traveled to Orlando for the evening then on to
Tallahassee the following morning.

Prior to the homicide, Magbanua was employed at a Miami area dental office.
Investigation revealed that after the homicide occurred in July 2014, Magbanua started receiving
paychecks from the Adelson Institute for Aesthetics and Implant Dentistry, which were
handwritten and signed by Donna Adelson. These paychecks started in September 2014, and
were consistently in the amount of$407.58 which she received every 2 weeks. The memo
section of each check indicated it was for a period of ten days usually preceding the date of the
check. The checks continued at least through April 2016. On at least two different occasions,
Magbanua received paychecks in advance of the time period indicated on the check and
frequently received sequential checks.

Magbanua received a significant amount of cash after Markel's murder. In the month
following the murder, Magbanua deposited over $13,000 cash. In the six weeks following the
homicide, she deposited more cash than she did in the entire year leading up to the homicide.
These numerous deposits were conducted mostly through ATMs in increments of$300 to $2000.
From the homicide through November 2015, the total amount of cash that investigators identified
deposited into Magbanua's accounts is over $56,000. This amount is over and above the
paychecks she had received.

The investigation revealed that Magbanua did not work the Adelson Institute. Magbanua
was also in possession of and operating a 2001 Lexus LS430 sedan automobile which was
registered to Harvey Adelson and previously used by Charles Adelson. On January 23, 2016, the
title for this car was transferred to Magbanua and a new license plate was obtained in ·
Magbanua's name. Motor vehicle records indicate the vehicle was sold to Magbanua for the
. of$1,700. In addition, Magbanua received cash and numerous gifts from Charles Adelson
price \

smce Market's murder.

A review of their financial records indicated that Charles Adelson and Donna Adelson
had the financial means to finance this murder and provide on-going compensation to Magbanua.

On April 19, 2016 an undercover agent made contact with Donna Adelson in reference to
Markel's murder. The undercover agent provided a press release ofMarkel's murder, asked for
$5,000 and provided a phone number at which he could be contacted. As a result of this contact,
conversations were intercepted.

Call #1380 - Donna Adelson call to Charles Adelson asking him to meet her about some
paperwork that was hand delivered to her outside her condominium, The Icon, on South Beach,
was intercepted. During this conversation, when Charles inquired whether it involved him or
others, Donna responded in a whisper, "Well, probably both ofus." When Charles asked her to
repeat herself she stated, "Probably the two of us" and ''you probably have a general idea what
I'm talking about." When Charles inquired further, Donna said this was not something she
wants to discuss over the phone.
 Call #1382 -Donna and Charles discussed meeting and whether or not Charles needed to
bring cash. Charles inquired whether or not a threat was involved and whether the police should
be contacted. Donna responded that this time, she did not believe that was a good idea.

Call #1386- Charles Adelson called and immediately told his mother Donna Adelson,
don't talk about things in the apartment or anyplace. He then asked if the person was black,
white or Hispanic to which Donna said he was white. Charles said it sounds like something that
needs the police. Donna said she may have to but wants to talk to him first. When Charles asks
what the letter asked for Donna said, "This TV is probably about five." Charles asked if they
asked for $5,000 to which Donna responded affirmatively. Donna also said they mentioned an
ex-girlfriend.

Call #1392- Charles Adelson called Katherine Magbanua after trying to reach her by
phone unsuccessfully about an hour before. Charles explained the situation to Magbanua as he
understood it from his mother. Something regarding her son, something regarding his ex-
girlfriend, and the person asking for some money. Charles tells Magbanua that he is going to see
his mom the next day to discuss the matter. There is some discussion of whether Magbanua is the
girlfriend referenced by the Agent. Charles said he thought his mother said the Agent mentioned
Magbanua's name, but he is not sure and will follow up with her if the situation does involve her.
Magbanua agrees to meet Charles in person the next day, April 20, 2016, around 4:00 pm.

Charles never contacted any other females to discuss the contact between his mother and
the undercover agent.

The morning of April 20, 2016 Charles told his mother he would meet her at her home at
12:35 p.m. After Charles arrived at the Icon where his mother and father reside, he and Donna
walked outside to a remote table behind the building and sat close together while conversing.
None of their conversation was successfully captured.

After meeting with Donna in person he called Magbanua and traveled to her in Sunny
Isle at the real estate office where she worked. When Charles arrived at the strip mall where
Magbanua worked they talked briefly outside, then went into a restaurant, Dolce Vita near the
real estate office. Their conversation was captured while they sat in the restaurant. The
following statements Charles made directly to Magbanua were previously only audible with use
of proprietary software. Through the use of an expert, the audio conversation between Magbanua
and Charles was clarified. The following are portions of that conversation:

1. - If they had any evidence we would have already gone to the airport. The problem is,
even if they bugged this, even if they bugged your home phone[...] but even if they had bugged
your phone, okay, [KM?] but even if they bugged your phone, okay, you're still not talking about
any of this.

2. - So my point is, how do you get people to talk? You throw in a smoke grenade. And then
you get all the cockroaches to run out. Ahhh ahh, there's smoke in the house, there's smoke in
the house, and everyone's running and everyone's talking and you throw a smoke grenade what
do you think?
3. - They may have approached my mom because my dad may be someone who is carrying
a gun. You never know ifsomeone1 s-youknow, you don't want it to tum into afuckin'
shootout, ya know? And I can tell ya, a lot of times I carry on me. I mean, someone comes up to
me - KM -you carrying on you right now? I mean I'm gonna start carrying one on my back.
Like, ya know, a holster that fits in your shirt. If someone comes up to me, they better be ready
to shoot cuz I'm gonna shoot 'em. Someone comes up to me asking for money right now? Yeah,
and when the - guess what? When the fuckin police show up and there's a doctor-there's an
oral surgeon standing there with a dead gang member in the fucking driveway, they're not gonna
come down too hard on me and I'm not gonna talk anyway. I don't know much - I don't trust
them.

4. - Katie this is - this is not like ... some chick showing off tattoos to your man, this is
happening and it's serious because these people are going to come back. They didn't go through
the trouble of seeking my mom out to hand her that and then go away. So, I got two options.
They're not going away .... may wish they'd go away and never come back but they aint going
away - the trouble they went through -

5. - No, it's very simple. Like, if you're gonna charge me, charge me.

6. - What I'm saying is, is that this person is not going away. They came very equipped with
details -where did the details come from? I don't know. The details

7. -Two-they said the guy's name was 2-0h? I don't even know who the fuck it is. Is there
just 2-Oh ... - (KM supplies name)• Tuto's incarcerated now. And I know that you've been
helpin' out Katie and helping your family and helping out Katie and her family. Now Tuto's
family needs your help. My mom was like, I don't know what you're talking about. And he goes
well maybe this will refresh your memory. And he handed it to her - KM talking - And she
said ... respect...spoke like polite. She goes - polite and well-spoken. I said, did he have like -did
he act thug, or did he have talk with like a thick Spanish accent or anything? She said no. I said,
was he white or Hispanic? She said he was white, but he could've been Hispanic - but that- KM
talking -yeah, could've mistakes. I mean, everybody in Miami is Hispanic so it's like you can't -
you can't tell.

8. - So ... Katie they'll be back... These people know about- whoever it is knows
information.

9. - Let me ask a question, when everybody was there the next day, did any of you take any
money? It's not like you're driving around in a Bentley, cruisin' around in a mega-yacht, ya
know? Someone-he must. .. at some point. Because otherwise he'd have no idea that I had
anything to do with ...

10. - It could. It could. I wish it was a cop playing games. Why didn't they know it was me?
If it was a cop playing games, or an investigator playing games and they didn't mention me, they
did mention your son's girlfriend Katie-not mention me at all ... and my family. And I think if
they thought I had something to do with it, they would find me, and they'd talk to me. You know
what I'm saying? Like, go talk to the person who's involved, not fucking people who aren't
involved.

11. -And I'm not involved. But if they knew - if they knew - but if they knew our-your -
your relationship's with me not my family. Like, I dated you not my mom. They knew my dad's
name. This person obviously doesn't even know that we dated. That's - that's the direct
connection is who was her boyfriend? The 71-year-old guy, Dr. Adelson, or the 37-year Dr.
Adelson? Yeah, 37, let's go talk to him. Dr. Adelson ... That's who they'd talk to. Not waste your
time with mom. They needed to talk to someone who knew what the fuck went down. And so,
wouldn't it make sense that your connection to my family is me?
r
12. - Your connection to my family is not my mom. Like y~ you work for the office now
cuz the checks are from there, and that's just cuz you come in and work on the weekends; which
I trust that you're doing, cuz rm never there when I see you. You tell me you do it and the place
looks clean, so you get your checks. You clean up, whatever, but that's neither here nor there.
This person knows information, and even if they are cops ... that information... said your name.
And they also know that- they're claiming that somebody who had something to do with it is
incarcerated. I don't know anybody in jail.

13. -KM-him

14. - This is what I want you to do. I want you to call up this person and say that, I got a call
from some friends of mine who say that you reached out to them and that you mentioned my
name. And remember ... protect your name recently. So, what you're gonna say is, I got a call
from some friends of mine who said that you had reached out and that you had mentioned my
name. These people want to go to the police because they had nothing to do with what you're
talking about, okay. And frankly, I don't know what you're talking about, but the name sounds
familiar of who's incarcerated so I'm going to give you something as charity to help the less
fortunate, but do not contact these people again or they are going to the police. And let 'em know
you had to do everything in the world to prevent these people from going to the police because
they don't know anything, and I don't know anything. And that you-the name sounds a little
familiar and that I'm gonna help you out with some charity and don't ever contact me, my
friends or my family again or we will go to the police.

15. - I mean Katie I'll go to the moon and back for you. That- that's without-without even
saying I don't need to say that. KM But that's what- you know - it's like - You know what I'm
saying?- KM-... help me out, help me out- Like, you know it, I don't even have to-I don't
have to sit here and tell you what I would do I could show you what I could do. You know what
I'm saying? Like, I - you know how I am, like I - I look for things to do. You don't ask me for
shit. I'm the one that's like, "Hey, Noah's birthday's coming up, I got you." You know, I'm the
one who's like-anything I can-you know-you don't ask, you're just- I'm the one who's like,
"Hey, I'll sell you the Lexus for a very good price, I know you're having car problems." You
know what I'm saying? Like, I'm the one who - I don't have to - I don't have to tell you I show
you. There's a difference.

16. - I know. My head was .•• when I was leaving the house I literally had the bag out and I
had it with my car keys. I know well, if you want you guys can swing by my house later. So,
what are we doing? KM talking I want you to take it back, write the number down, and I'm
going to give you cash. And I want you to talk to ... 7-12, what? 65-70...

After the in-person meeting with Magbanua, Charles called Donna back to report about
his meeting and said he is handling everything. Donna then called Charles back, sounding very
concerned.

On April 21, 2016 calls were intercepted between Magbanua and Charles and they
attempt to disguise their conversation using real estate references such as security, property
posted incorrectly, and wrong tenants for rental property. Charles and his dad, Harvey, met for
dinner later that evening.

· Magbanua and Garcia were intercepted having numerous arguments over the phone. The
morning of April 21, 2016 it appeared Magbanua was trying to convince Garcia to figure out
who the phone number belonged to and place the call himself. In a heated exchange, Garcia said
"I'm not making that fucking phone call." He later said, "I am going to take care of this fucking
problem." (call 825)

On Monday, April 25, 2016, a letter was sent to Harvey and Donna Adelson. This letter
was sent via USPS by investigators for the purpose of follow up from the undercover's initial
conversation. Calls intercepted indicate Donna shared the information with Charles who in tum
forwarded it to Magbanua. Magbanua again asked Garcia to either determine who the phone
number belonged to or call the phone number. Magbanua reported to Charles the phone was
either out of service or not a good number. It appeared Garcia lied to Magbanua about making
the call or had not called the correct phone number. The Agent's phone was not called and was
working properly after conducting tests to verify.

Later the same date, Charles called Magbanua and asked if she was on her way. It
appeared Charles and Magbanua have been communicating through a different source to
schedule a meeting. Later review ofiCloud messages from Charles' records indicate he and
Magbanua would often communicate via "Whats App" a phone application that allows for secure
communication not retrieved in a cellular record. Charles directed her to Harvey and Donna's
building to meet with them. Charles told Magbanua that he was talking to his parents about
everything. Charles continued to try and convince her to meet at Donna and Harvey's building,
but eventually agreed to meet with her at another location. Magbanua called Charles back who
advised they are meeting at a marina near "Monty's."

On April, 26, 2016, Charles called Donna and they discussed the conversation that
occurred the night prior. Donna said she felt better after their conversation. Donna asked
Charles to let her know once things are taken care of. (call 1948)

He further stated that "if you don't know who the person is it's a much bigger problem.
Charles said "if you know who it is, it's very, very easy." Charles told Donna to stop getting
worked up about things. Charles assured Donna there was nothing she needed to worry about
and that it was being looked into.

On May 4, 2016, at approximately 2:09 AM, a text message was sent to Donna's cell
phone from the undercover Agent. Later in the day, Charles asked Donna if she was okay and
Donna advised she would talk to Charles about it on Sunday. Charles wanted to talk to Donna
before Sunday and they agreed to Charles coming by around 11 :30 AM the following day (May
5, 2016). While driving to meet with Donna, Charles called Magbanua advising there was a new
problem and he may need to meet with her later that day.

On May 5, 2016, Charles arrives at the Icon and they agree to meet at the pool area to
discuss the text message. This time Harvey is present with Charles and Donna as they huddled at
a corner area for privacy. There was no oral intercept captured due to the location they had the
conversation.

After the meeting, Charles left the Icon and called Magbanua (KM call #2016) asking her
how someone would get his mother's number. Magbanua told Charles it's possible to locate the
phone number online. Charles used specific phrases sent via the text message.

Charles called Donna and they discussed paying the $5,000. Charles advised the sooner
they pay the money the better. They discussed being nice, but firm when the money is paid so
the person knows that it is only a one-time payment.

On Friday, May 6, 2016, at 5:03 PM, Donna successfully contacted the Agent by calling
his phone number, 305-712-6570. The total duration of the call was 8 minutes and 48 seconds.
The call was recorded by the FBI. In summary, Donna made the excuse her grandchildren had
possession of her phone, so she did not know he called. Donna went over the previous contacts
between herself and the Agent. She said she took him seriously and she was stressed out. She
claimed she asked friends what she should do. She denied knowing anything referenced by the
Agent concerning help provided to her by the Agent's friend, (Rivera). She then brought up the
reward offered and suggested he seek that out instead. The Agent reminded her all he asked for
was $5,000. Donna claimed she had nothing to do with the death of her ex-son-in-law and that
she was left out of the loop. The Agent reminded her, the problem was not going away, and she
did know Magpanua and what was done for her. Donna continued to deny knowledge and ended
the conversation by saying she would call the Agent back.

Call #3290- 5/7/16@ 5:07 PM

Charles told Magbanua about a new CD he wanted her to listen to, indicating he had a recording
of the call between Donna and the Agent. Charles used the reference "pot belly pigs" (Police) to
which Magbanua responded, "That's not good."

On May 25, 20146 Sigfredo Garcia was arrested for his involvement in this case.

On May 26, 2016, electronic surveillance suggested that Charles Adelson and Katherine
Magbanua were in close proximity to each other and may have met in the over-night, early
morning hours.

On June 28, 2016, Luis Rivera was arrested for his involvement in this case.

On September 30, 2016 a proffer was conducted with Luis Rivera in the presence of his
attorney. This proffer was not recorded. Rivera was sworn prior to any testimony.

Rivera stated he has known Sigfredo Garcia since childhood. Garcia told Rivera about a
high dollar robbery he wanted to do with Rivera in Tallahassee, Fl. The first time Rivera and
Garcia traveled to Tallahassee was in June 2014. Once they departed for Tallahassee in June
2014, was when Rivera learned Garcia wanted him to commit a murder not a robbery. Garcia
promised Rivera $30,000 to commit the murder. While enroute to Tallahassee Garcia provided
Rivera with more details explaining a woman with two kids wanted her ex-husband murdered so
she could have full custody of the children in Miami. Garcia told Rivera the offer was presented
to him by Katherine Magbanua and the total payment for the murder would be $100,000. Rivera
suggested robbing the woman of the $100,000 instead of committing the murder.

The two traveled with a long barrel .38 Taurus revolver and a short barrel black .38 S&W
revolver. The two around the victim's residence and followed the victim's vehicle. Rivera
recalled Garcia having a colored printed photo of the victim with words printed on it. Rivera
could not recall what was printed. They would eventually park the car at Winthrop Park and wait
for the victim to leave. Rivera would later show investigators where they parked and the routes,
they took to the victim's residence.

Rivera indicated Garcia told him Magbanua approached Garcia with the offer of
$100,000 to be divided amongst the three. $40,000 was for Garcia, $35,000 was for Rivera and
the remainder was for Magbanua. Garcia later offered $2,000 more to Rivera. After losing the
victim and failing to complete the murder in June, the two decided to return to Miami.

Approximately a month later the two returned to Tallahassee to commit the murder.
Rivera rented the Prius in his name. They arrived in Tallahassee in the early morning July 17,
2014. The same morning, July 17, 2014, they drove to the victim's neighborhood. While driving
around, Garcia involuntarily discharged the revolver through the floorboard of the Prius. Rivera
noticed the car started losing power and they learned Garcia shot a hole through the gas line.
They were able to repair the vehicle and continue traveling. A search warrant was issued in
October 2016 for the Prius. The fuel line underneath the passenger side of the vehicle was
spliced together and the corresponding hole was located in the floorboard consistent with the
information provided by Rivera.

The following morning July 18, 2014, Rivera and Garcia traveled back to back to the area
of the Victim's residence where they observed the victim leaving the neighborhood. They
followed the victim around town as he dropped his kids off and went to Premier gym. As they
returned to the victim's residence the victim turned off Thomasville Rd. prior to Betton Rd.
Rivera and Garcia traveled further down to Betton and entered the neighborhood from the south.
As they approached the victim's residence the victim was pulling in the driveway in front of
them. They pulled in behind the victim and as he parked in the garage Garcia exited the Prius
and approached the driver side door of the victim's car. Garcia shot the victim twice in the head
then returned to the Prius and the two left Tallahassee. They travelled north on Thomasville Rd.
to I-10 to I-75 confirming the information previously discovered through electronic data.

While driving back to south Florida Garcia called Magbanua approximately an hour into
the drive. Garcia told Magbanua, "It's done." Rivera explained he could hear Magbanua's voice
as Garcia held the phone up to his ear. During the drive Garcia asked Rivera to pull over near a
bridge and waterway so Garcia could dispose of the firearm. Numerous attempts to locate this
bridge and water way were unsuccessful. Upon returning to south Florida Rivera and Garcia
withdrew cash from the ATM in Pembrooke Pines where they were observed on ATM security
camera. They then drove to Rivera's residence.

The following morning Rivera received a call from Magbanua. She told him if he wanted
the money he needed to tell her where to meet because she could not get ahold of Garcia. Rivera
knew Garcia was at Stefanie Carmona's residence so he called a friend, Anthony Ortiz to go pick
him up. While waiting to return home Rivera received a call from his child's mother Jessica
Rodriguez whom he lived with. Jessica told Rivera the Garcia and Magbanua were at their
residence with a package for him. Rivera returned home he observed Magbanua's white SUV in
the driveway. As he entered the residence, he received a package from Magbanua and Garcia.
Rivera did not want Jessica to know what was in the package. Rivera then left the residence with
Garcia. Rivera described the package as stack of cash ($100 bills) stapled together.

In July of 2018, contact was made with June Umchinda. Umcbinda was a girlfriend of
Charles Adelson at the time of the undercover operation in which an FBI agent approached
Donna Adelson. Of relevance in her interview was her recollection of Charles Adelson having
stapled money in a safe in his residence. June stated she followed the case in the news and when
she heard about stapled money, she found it odd because she remembers Charles keeping his that
way. June also testified that Charles Adelson was acting angry, agitated, and nervous around the
time of the undercover operation and Magbanua arrest. Adelson advised June that he gave
Magbanua a car and financed a portion of her breast augmentation. June Umchinda also
observed Donna Adelson to be stressed out during this time frame and Donna Adelson made a
statement to June Umchinda that she felt Dan Markel was haunting her from the grave.

In July 2021, contact was made with Ryan Fitzpatrick. During the interview with
Fitzpatrick it was learned the two had a falling out in recent years over financial disagreements.
He said Charles's entire demeanor changed when Magbaunua was arrested. Adelson started
putting up security cameras and was constantly paranoid of arrest. During a conversation with
Fitzpatrick Charles Adelson said, "you can get away with murder if you keep your mouth shut."
Fitzpatrick also stated he knows Charles staples bis money together because he has received
money from him in that manner. Fitzpatrick said Charles staples his money in $1,000.00 ·
increments.

In October 2019, Garcia was tried and convicted. He was sentenced to life in prison. In
April 2022, after the clarified audio recording from Dolce Vita revealed Charles Adelson making
additional incriminating statements, he was arrested for first degree murder, solicitation to
commit first degree murder, and conspiracy to commit first degree murder. In May 2022,
Katherine Magbanua was tried and convicted. She was sentenced to life in prison.

In October 2022 and November 2022, the proffers previously mentioned were conducted
with Katherine Magbanua.

In October 2023, trial for Charles Adelson commenced. On November 6, 2023 Charles
Adelson was found guilty on all charges. He is set to be sentenced in December 2023. In
Adelson's trial, Magbanua testified that Adelson told her that his mother, Donna Sue Adelson,
had just departed his residence at the time Magbanua arrived on the night of the homicide.
Magbanua said the money she received appeared to have been washed.

Jail calls from after Charles Adelson's guilty verdict include multiple calls in which
Donna Sue Adelson- is telling Charles Adelson that she is getting tltlngs in order, creating trusts,
and making sure her grandchildren are taken care of. Donna discusses plans for a suicide, but
also discusses plans to flee to a non-extradition country. Donna Sue Adelson has considerable
financial resources to accomplish this.

On November 7, 2023, Donna and Harvey Adelson booked flights to Vietnam with a stop
in Dubai. The flight, EK0214 departs Miami, Fl. on November 13, 2023 at 8:10 p.m. to Dubai.
Flight EK0392 departs Dubai on November 15, 2023 at 9:35a.m. and lands in Saigon at 7:35
p.m.

SIONATUREC:---- 2 ~w
THE PRECEDING I S ~ ~ !3..Jl9F MY PRESENT KNOWLEDGE OR BELIEF.

AGENCY: Office of the State Attorney

NOTARIZATION: SWORN AND SUBSCRIBED BEFORE ME THIS~ DAY OF

---'¥~~~-' 2023.

TATEATTO

TYPE OF IDENTIFICATION:
PERSONALLY KNOWN: -~--,----,,----------
 ORDER

THIS CAUSE coming before me as a First Appearance Magistrate, and having reviewed
the preceding Affidavit, this Court finds:
--- -- -

X Probable cause is sufficient

_ _ Probable cause is not sufficient and unless corrected within seventy-two hours the
defendant shall be released on his own recognizance.

JUDGE
 Warrant#· 2o'2-~cR-32Z..\.Q ~ \
In the County Court Agency Case# TPD 2014-19848
Officer I.D.# - SAO
-- 2 -----
Leon County, Florida Charge First Degree Murder

STATE OF FLORIDA Degree of Charge Capital Felony

vs. Statute No. 782.04(1)(a)l
Donne Sue Adelson DOB 02/05/1950 Sex F
Defendant.
-5'06"
---
WARRANT Race W Hgt
Wgt 140 Hair Blonde
2127 Brickell Avenue Apt 1602,
Miami, FL 33129 Eyes Brown SSN
Address.

IN THE NAME AND BY THE AUTHORITY OF THE

STATE OF FLORIDA:

TO ALL AND SINGULAR THE SHERIFFS OF THE STATE OF FLORIDA:

WHEREAS, a complaint has this day been filed before me by Inv. Jason Newlin, who, being first
duly sworn says that one the 18th day of July, A.D. 2014, in Leon County, Florida, the aforesaid
defendant

did commit the unlawful killing of a human being, Daniel E. Markel, by shooting him with a
firearm, and the killing was perpetrated from a premeditated design to effect his death,

contrary to the statute, rule regulation or other provision of the iaw in such case made and provided, and
against the peace and dignity of the State of Florida.

THESE ARE, THEREFORE, to command you to arrest instanter the aforesaid defendant and
bring him or her before me to be dealt with according to law.

Given under my hand and seal this 13 day of November, 2023.

4 _-_____
___._ J -------~-----·~--------------(SEAL)
Coun~ County

WARRANT
 Received this Warrant on t h e _ day of _ __
IN THE COUNTY COURT
2023 and served same on the _ _ day of _ _ _,
COUNTY, FLORIDA
2023, by delivering a true copy of same to the within
named defendant,
THE STATE OF FLORIDA,
PLAINTIFF

vs.

Donna Sue Adelson Sheriff County, Florida

Defendant
2127 Brickell Ave. Apt 1602, Miami, FL 33129
Address
By:
Deputy Sheriff.

WARRANT

First Degree Murder

THE AMOUNT OF BAIL IN TIDS CASE IS

HEREBY SET IN THE SUM OF

 Warrant# 2oZ'&E 3 '2.~lo ¢:.. \
In the County Court Agency Case# TPD 2014-19848
Officer I.D.# SAO 2
---'--------
Leon County, Florida Charge First Degree Murder

STATE OF FLORIDA Degree of Charge Capital Felony

vs. Statute No. 782.04(1)(a)1
Donne Sue Adelson DOB 02/05/1950 Sex F
----
Defendant. COMPLAINT Race W
----- Hgt 5'06"
Wgt 140 Hair Blonde
2127 Brickell Avenue Apt 1602, Miami, FL 33129 Eyes Brown SSN
Address.

IN THE NAME AND BY THE AUTHORITY OF THE STATE

OF FLORIDA:

Before me, the undersigned authority, personally appear by Inv. Jason Newlin, who, first being
duly sworn says that one the 18th day of July, A.D. 2014, in Leon County, Florida, the aforesaid
defendant

did commit the unlawful killing of a human being, Daniel E. Markel, by shooting him with a firearm, and
the killing was perpetrated from a premeditated design to effect his death,
: contrary to Sec., 782.04(1)(a)1 F.S.
contrary to the statute, rule regulation or other provision of law in such case made and provided, and
against the peace a · ity of thl~......._ of Florida.

State Attorney's Office, Leon County Courthouse, 301 S. Monroe St., Suite 475, Tallahassee, FL 32301
Address

Sworn to and subscribed before me this 13 day of November, 2023.

 Warrant# Zo2~ cF ~'2.."2.J..o ~~
In the County Court Agency Case# TPD 2014-19848
Officer I.D.# 2
Leon County, Florida -SAO--
Solicitation to- - - 1-st -
Commit
Charge Degree Murder

STATE OF FLORIDA Degree of Charge 1st Degree Felon~

vs. Statute No. 777.04{2}
Donne Sue Adelson DOB 02/05/1950 Sex F
Defendant. WARRANT Race w Hgt 5'06
11

Wgt 140 Hair Blonde

2127 Brickell Avenue Apt 1602,
Miami, FL 33129 Eyes Brown SSN
Address.

IN THE NAME AND BY THE AUTHORITY OF THE

STATE OF FLORIDA:

TO ALL AND SINGULAR THE SHERIFFS OF THE STATE OF FLORIDA:

WHEREAS, a complaint has this day been filed before me by Inv. Jason Newlin, who, being first
duly sworn says that one the 18th day of July, A.D. 2014, in Leon County, Florida, the aforesaid defendant

did solicit another person, Charles Adelson, and others to commit first degree murder and in the course
of such solicitation did engage in specific conduct which resulted in the death of Daniel Markel,

contrary to the statute, rule regulation or other provision of the law in such case made and provided, and
against the peace and dignity of the State of Florida.

THESE ARE, THEREFORE, to command you to arrest instanter the aforesaid defendant and
bring him or her before me to be dealt with according to law.

Given under my hand and seal this 13 day of November, 2023.

-~-..-.;:~,.:+--"'--

County~
-xi. . .--~~.
4 ..._._._ _____ County
(SEAL)

WARRANT
 Received this Warrant on t h e _ day of _ _ _,
IN THE COUNTY COURT
2023 and served same on t h e _ day of _ _ _,
COUNTY, FLORIDA
2023, by delivering a true copy of same to the within
named defendant,
THE STATE OF FLORIDA,
PLAINTIFF

vs.

Donna Sue Adelson Sheriff County, Florida

Defendant
2127 Brickell Ave. Apt 1602, Miami, FL 33129
Address
By:
Deputy Sheriff.

WARRANT

Solicitation to Commit 1 st Degree Murder

THE AMOUNT OF BAIL IN TIDS CASE IS

HEREBY SET IN THE SUM OF

$ _..........
ri....a...;A...:....fZ_ __

"'o co~~ tN i& (!,J:, -&;rJspi'r~.l,x-s

 Warrant# ~'2..S~022c.o ~"Z..
In the County Court Agency Case#
Officer I.D.# SAO 2
__,;;__.;;_ ___
TPD 2014-19848
___,,---
Soli citation to Commit 1st
Leon County, Florida Charge Degree Murder

STATE OF FLORIDA Degree of Charge 1st Degree Felony

vs. Statute No. _7_7_7._04.....(2_._)_ _ _ __
Donne Sue Adelson DOB 02/05/1950 Sex F
----
Defendant. COMPLAINT Race W
----- Hgt 5'06"
Wgt 140 Hair Blonde
2127 Brickell Avenue Apt 1602, Miami, FL 33129 Eyes Brown SSN
Address. 1-,44Sl
IN THE NAME AND BY THE AUTHORITY OF THE STATE
OF FLORIDA:

Before me, the undersigned authority, personally appear by Inv. Jason Newlin, who, first being
duly sworn says that one the 18th day of July, A.D. 2014, in Leon County, Florida, the aforesaid
defendant

did solicit another person, Charles Adelson, and others to commit first degree murder and in the course
of such solicitation did engage in specific conduct which resulted in the death of Daniel Markel,

: contrary to Sec., 777.04(2) and 782.04(1)(a)l, F.S.

contrary to the statute, rule regulation or other provision of law in such case made and provided, and
against the peace and dignity of the State of Florida.

State Attorney's Office, Leon County Courthouse, 301 S. Monroe St., Suite 475, Tallahassee, FL 32301
Address

Sworn to and subscribed before me this 13 day of November, 2023.

 Warrant# 2.DZ.'3CF-::S'2.Zu, A-3>
In the County Court Agency Case# TPD 2014-19848
Officer I.D.#
Leon County, Florida -SAO
-- 2
-----
Conspiracy to Commit I st
Charge Degree Murder

STATE OF FLORIDA Degree of Charge 1st Degree Felony

vs. Statute No. _7_7_7._04_...(3_._)_ _ _ __
Donne Sue Adelson DOB 02/05/1950 Sex F
Defendant.
-510611
---
WARRANT Race W Hgt
Wgt 140 Hair Blonde
2127 Brickell Avenue Apt 1602,
Miami, FL 33129 Eyes Brown SSN
Address.

IN THE NAME AND BY THE AUTHORITY OF THE

STATE OF FLORIDA:

TO ALL AND SINGULAR THE SHERIFFS OF THE STATE OF FLORIDA:

WHEREAS, a complaint has this day been filed before me by Inv. Jason Newlin, who, being first
duly sworn says that one the 18th day of July, A.D. 2014, in Leon County, Florida, the aforesaid
defendant

did conspire with another person, Charles Adelson, and others to commit first degree murder and in the
course of such conspiracy did engage in specific conduct which resulted in the death of Daniel Markel,

contrary to the statute, rule regulation or other provision of the law in such case made and provided, and
against the peace and dignity of the State of Florida.

THESE ARE, THEREFORE, to command you to arrest instanter the aforesaid defendant and
bring him or her before me to be dealt with according to law.

Given under my hand and seal this 13 day of November, 2023.

_._
/4_A-~_xf_-f_______
Count~dge
ude County
(SEAL)

WARRANT
 Received this Warrant on the_ day of _ _,_,
IN THE COUNTY COURT
2023 and served same on the _ _ day of _ __
COUNTY, FLORIDA
2023, by delivering a true copy of same to the within
named defendant,
THE STATE OF FLORIDA,
PLAINTIFF

vs.

Donna Sue Adelson Sheriff County, Florida

Defendant
2127 Brickell Ave. Apt 1602, Miami, FL 33129
Address
By:
Deputy Sheriff.

WARRANT

Conspiracy to Commit 1st Degree Murder

THE AMOUNT OF BAIL IN TIDS CASE IS

HEREBY SET IN THE SUM OF

s____F_A-_f<._ _ __
NO e.orJ+~ WI~ o+ht!r e.D-C'.oNsr,·r~r-S
 warrant# 2c-Z..'3 c.f'. !;)22'4> .A.3
In the County Court Agency Case# TPD 2014-19848
Officer I.D.#
-SAO-- 2
-----
Conspiracy to Commit 1st
Leon County, Florida Charge Degree Murder

STATE OF FLORIDA Degree of Charge pt Degree Felony

vs. Statute No. _7__7_7_.0~4(,.;..3.....
) _ _ _ __
Donne Sue Adelson DOB 02/05/1950 Sex F
----
Defendant. COMPLAINT Race W Hgt 5'06"
\- ----
Wgt 140 Hair Blonde
2127 Brickell Avenue Apt 1602, Miami, FL 33129
-----
Eyes Brown SSN
Address.

IN THE NAME AND BY THE AUTHORITY OF THE STATE

OF FLORIDA:

Before me, the undersigned authority, personally appear by Inv. Jason Newlin, who, first being
duly sworn says that one the 18th day of July, A.D. 2023, in Leon County, Florida, the aforesaid
defendant

did conspire with another person, Charles Adelson, and others to commit first degree murder and in the
course of such conspiracy did engage in specific conduct which resulted in the death of Daniel Markel,

: contrary to Sec., 777.04(3) and 782.04(1)(a)l F.S.

contrary to the statute, rule regulation or other provision of law in such case made and provided, and
against the peaee-1dlllnNgnity of the State of Florida.

State Attorney's Office, Leon County Courthouse, 301 S. Monroe St., Suite 475, Tallahassee, FL 32301
Address

Sworn to and subscribed before me this 13 day of November, 2023.