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<P>&lt;head&gt;&lt;title&gt;Abuse of Usenet: Arrested!&lt;/title&gt;&lt;/head&gt;</P>



<P><center><h1>Abuse of Usenet: The Woodside Literary Agency Arrested!</h1><center></P>



<P>&lt;p&gt;</P>



<P>&lt;hr&gt;</P>



<P>&lt;p&gt;</P>



<P>GAS:SJB:js</P>



<P>F .#2000R00027</P>



<P>Leonard. Cmp</P>



<BR WP="BR1"><BR WP="BR2">

<P>UNITED STATES DISTRICT COURT</P>



<P>EASTERN DISTRICT OF NEW YORK</P>



<BR WP="BR1"><BR WP="BR2">

<P>- - - - - - - - - - - - - - - - X</P>



<Pre> 00-0021M



UNITED STATES OF AMERICA



SEALED AFFIDAVIT IN



- against- SUPPORT OF ARREST



<u>WARRANTS</u>



JAMES LEONARD T. IS, U.S.C., SS371,



also known as "John Lawrence," 1621(1), and 3551



URSULA SPRACHMAN, <u>et seq.</u></pre>



<BR WP="BR1"><BR WP="BR2">

<P> Defendants,</P>



<BR WP="BR1"><BR WP="BR2">

<P>- - - - - - - - - - - - - - - - X</P>



<BR WP="BR1"><BR WP="BR2">

<P> JOHN McDERMOTT, being duly sworn, deposes and says that he is a Postal Inspector with</P>



<P>the United States Postal Inspection Service, duly appointed according to law and acting as such.</P>



<BR WP="BR1"><BR WP="BR2">

<P> COUNT ONE</P>



<BR WP="BR1"><BR WP="BR2">

<P> 1. Upon information and belief, in or about and between January 1996 and the</P>



<P>present, both dates being approximate and inclusive, within the Eastern District of New York, the</P>



<P>defendants JAMES LEONARD, aka "John Lawrence," and URSULA SPRACHMAN</P>



<P>unlawfully, wilfully, and knowingly did combine, conspire, confederate, and agree together and</P>



<P>with each other to commit an offense against the United States, to wit, to violate Section 1341 of</P>



<P>Title 18, United States Code.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 2. It was an object of the conspiracy that the defendants, JAMES LEONARD, aka</P>



<P>"John Lawrence," and URSULA SPRACHMAN and others known and unknown, would and did </P>



<P>unlawfully, wilfully, and knowingly devise and intend to devise a scheme and artifice to defraud</P>



<P>and for obtaining money by means of false and fraudulent pretenses, representations and</P>



<P>promises, and for the purpose of executing such scheme and artifice and attempting so to do,</P>



<P>would and did knowingly cause items, to wit, check&amp; made payable to the Woodside</P>



<P>International Literary Agency, "John Lawrence" and "James Leonard," to be delivered by the</P>



<P>United States Posta1 Service, according to the direction thereon, in violation of Title 18, United</P>



<P>States Code, Section 1341.</P>



<BR WP="BR1"><BR WP="BR2">

<P> OVERT ACTS</P>



<BR WP="BR1"><BR WP="BR2">

<P>3. In furtherance of said conspiracy and to effect the objects thereof, the following overt acts</P>



<P>were committed in the Eastern District of New York and elsewhere:</P>



<BR WP="BR1"><BR WP="BR2">

<P> a. In or about March 1996 the defendant JAMES LEONARD, also known as "John</P>



<P>Lawrence," received a manuscript at 33-29 th Street, Woodside, New York.</P>



<BR WP="BR1"><BR WP="BR2">

<P> b. In or about March 1996, the defendant JAMES LEONARD, also known as "John</P>



<P>Lawrence," deposited a check in the amount of $75 made payable to "James Leonard," into an</P>



<P>account maintained at Citibank in the vicinity of Queens, New York. c. On or about</P>



<P>March 3, 1997, the defendant URSULA SPRACHMAN deposited a check in the amount of $150</P>



<P>made payable to Lawrence," into an account at First Union Savings Bank, in Florida, which had</P>



<P>been opened in the names of "Ursula Sprachman" and "James Leonard."</P>



<P> (Title 18, United States Code, Sections 371 and 3551 et seq.)</P>



<BR WP="BR1"><BR WP="BR2">

<P> COUNT TWO</P>



<BR WP="BR1"><BR WP="BR2">

<P> 1. Upon information and belief, in or about and between January 1999 and March</P>



<P>1999, both dates being approximate and inclusive, within the Eastern District of New York, the</P>



<P>defendants JAMES LEONARD, aka John Lawrence," and URSULA SPRACHMAN,</P>



<P>unlawfully, wilfully, and knowingly did combine, conspire, confederate, and agree together and</P>



<P>with each other to commit an offense against the United States, to wit, to violate Section 1621(1)</P>



<P>of Title 18, United States Code.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 2. It was an object of the conspiracy that the defendant, URSULA SPRACHMAN</P>



<P>having taken an oath, before a competent tribunal in a case in which the law of the United States</P>



<P>authorized an oath to be administered that she would testify truly, would and did unlawfully,</P>



<P>willfully, knowingly and contrary to such oath, state material matters which she did not believe to</P>



<P>be true, to wit the defendant URSULA SPRACHMAN while testifying under oath in a deposition</P>



<P>before a United States Magistrate Judge a civil matter pending in the United States District Court</P>



<P>for the Eastern District of New York, would and did identify "John Lawrence" as a friend who</P>



<P>owned and operated the Woodside Literary Agency, and identified the defendant, JAMES</P>



<P>LEONARD, also known as "John Lawrence," as her companion and someone who worked for</P>



<P>the Woodside Literary Agency as an independent contractor, when in fact, as she then and there</P>



<P>well knew and believed, there was no such individual by the name of "John Lawrence," and that</P>



<P>"John Lawrence" was an alias created</P>



<P>and used by the defendant JAMES LEONARD, also known as "John Lawrence," in violation of</P>



<P>Title 18, United States Code, Section 1621(1)</P>



<BR WP="BR1"><BR WP="BR2">

<P> OVERT ACTS</P>



<P> </P>



<P> 3. In furtherance of said conspiracy and to effect the objects thereof, the following</P>



<P> overt acts were committed in the Eastern District of Nev York:</P>



<P> a. On or about January 22, 1999 in the vicinity of </P>



<P>225 Cadman Plaza East, Brooklyn, New York, the defendant URSULA SPRACHMAN</P>



<P>answered questions during a deposition before a United States Magistrate Judge.</P>



<BR WP="BR1"><BR WP="BR2">

<P> b. In or about March 1999, in the vicinity of Naples, Florida, the defendant JAMES</P>



<P>LEONARD, also known as "John Lawrence," applied for a Florida Driver's License in the name</P>



<P>of James C. Leonard. </P>



<P>(Title 18, United States Code, Sections 371 and 3551 et seq.) </P>



<BR WP="BR1"><BR WP="BR2">

<P> COUNT THREE</P>



<P> </P>



<P> 1. Upon information and belief, on or about January 22, 1999, within the Eastern</P>



<P>District of New York, the defendant URSULA SPRACHMAN having taken an oath, bef ore a</P>



<P>competent tribunal in a case in which the law of the United States authorized an oath to be</P>



<P>administered, that she would testify truly, did knowingly, willfully and contrary to such oath state</P>



<P>material matters which she did not believe to be true, to wit: the defendant URSULA</P>



<P>SPRACHMAN, while testifying under oath in a deposition before a United States Magistrate</P>



<P>Judge a civil matter pending in the United States District Court for the Eastern District of New</P>



<P>York, identified "John Lawrence" as a friend who owned and operated the Woodside Literary</P>



<P>Agency, and identified the defendant, JAMES LEONARD, also known as "John Lawrence," as</P>



<P>her companion and someone who worked for the Woodside Literary Agency as an independent</P>



<P>contractor, when in fact, as she then and there well knew and believed, there was no such</P>



<P>individual by the name of "John Lawrence," and that "John Lawrence" was an alias created and</P>



<P>used by the defendant JAMES LEONARD, also known as "John Lawrence."</P>



<P>(Title 18, United States Code, Sections 1621(1) and 3551 et seq.) The source of your deponent's</P>



<P>information and the grounds for his belief are as follows:</P>



<BR WP="BR1"><BR WP="BR2">

<P> Introduction</P>



<BR WP="BR1"><BR WP="BR2">

<P> 1. I am an Inspector with the United States Postal Inspection Service ("USPS"), and</P>



<P> have been so employed for approximately 16 years. I have been assigned to the </P>



<P>investigation of numerous cases involving mail fraud and false statements and I have received</P>



<P>special training in conducting such investigations.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 2. I respectfully submit this affidavit for arrest warrants in connection with the</P>



<P>investigation of the above-named defendants JAMES LEONARD, also known as "John</P>



<P>Lawrence," and URSULA SPRACHMAN. This affidavit is based, in part, on my personal</P>



<P>participation in this investigation, which has included, among other things, interviews, and an</P>



<P>examination and analysis of documents, including bank records, and a copy of a certified</P>



<P>transcript of deposition testimony. In addition, this affidavit is based on reports made to me by</P>



<P>others. Since this affidavit is being submitted for a limited purpose, I have not included details of</P>



<P>every aspect of this investigation. Where actions, conversations or statements of others are</P>



<P>related herein, they are related in substance and in part, unless otherwise indicated.</P>



<BR WP="BR1"><BR WP="BR2">

<P> THE WOODSIDE INTERNATIONAL LITERARY AGENCY</P>



<P> </P>



<P> 3. I have reviewed advertisements posted on the Internet by the Woodside Literary</P>



<P>Agency and the Woodside International Literary Agency, hereinafter collectively referred to as</P>



<P>the "WLA." The WLA has advertised itself as a "New York based international literary agency . .</P>



<P>. seeking new and previously published authors" and requesting such persons to submit writing</P>



<P>samples to the WLA. I have also reviewed correspondence from the WLA to consumers. On</P>



<P>certain of the WLA's letterhead, the following addresses and phone numbers have appeared: (i)</P>



<P>33-29 58th Street, Woodside, New York, (hereinafter referred to as "WLA's Woodside</P>



<P>Premises"), telephone:718-651-8145 (hereinafter referred to as "WLA' s Woodside Telephone");</P>



<P>(ii) 1190 North Collier Boulevard, Marco Island, Florida, (hereinafter referred to as "WLA's</P>



<P>Florida Premises"), telephone: (941) 642-9660 (hereinafter referred to as "WLA's Florida</P>



<P>Telephone") and (iii) 34 Beaver Pond Road, Adirondack, New York, (hereinafter referred to as</P>



<P>"WLA's Adirondack Premises"), telephone: (518) 494-4196 (hereinafter referred to as &aelig;WLA's</P>



<P>Adirondack </P>



<P>Telephone").</P>



<BR WP="BR1"><BR WP="BR2">

<P> 4. The defendant URSULA SPRACHMAN is the owner of WLA's Woodside Premises,</P>



<P>according to publicly filed documents, as well as her own testimony in the deposition described</P>



<P>in paragraph 21. below. WLA's Woodside Telephone is listed to "John Lawrence." The records</P>



<P>of the New York State Department of Motor Vehicles indicate that an individual identified as</P>



<P>"James Leonard" and an individual identified as "John Lawrence" hold an identification card and</P>



<P>a driver's license, respectively, bearing the address of WLA's Woodside Premises.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 5. The defendant URSULA SPRACHMAN is the owner of WLA'S Florida Premises,</P>



<P>according to publicly tiled documents, as well as her own testimony in the deposition described</P>



<P>in paragraph 21 below. WLA's Florida Telephone is listed to both "John Lawrence" and "Ursula</P>



<P>Sprachman." The records of the </P>



<P>State of Florida Department of Highway Safety and Motor Vehicles indicate that an individual</P>



<P>identified as "James C. Leonard" holds a Florida driver's license and an identification card</P>



<P>bearing the address of WLA's Florida Premises.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 6. The defendant URSULA SPRACHMAN is the owner of WLA's Adirondack</P>



<P>Premises, according to her own testimony in the deposition described in paragraph 21 below.</P>



<P>WLA"s Adirondack telephone is listed to "John Lawrence."</P>



<BR WP="BR1"><BR WP="BR2">

<P> 7. A confidential source ("CS-1") providing information to the USPS advised the</P>



<P>USPS of the following, in substance and in part;</P>



<BR WP="BR1"><BR WP="BR2">

<P> a. In or about January of 1996, CS-l was contacted by an individual who identified</P>



<P>himself as "James Leonard" of the "Woodside Literary Agency" located at WLA's Woodside</P>



<P>Premises, and told CS-1, in substance and in part, that in exchange for a "reading fee" of $75, the</P>



<P>WLA would review portions of CS-1's manuscript and evaluate it for publication potential.</P>



<BR WP="BR1"><BR WP="BR2">

<P> b. On or about March 7, 1996, CS-1 sent CS-1's manuscript to the WLA by United</P>



<P>States mail at WLA's Woodside Premises to the attention of "James Leonard," along with a</P>



<P>check for $75 made payable to &aelig;James Leonard."</P>



<BR WP="BR1"><BR WP="BR2">

<P> c. Subsequently, CS-1 received a letter dated March 25, 1996 from "James</P>



<P>Leonard," which letter identified "James Leonard" as the owner of the WLA, and provided, in</P>



<P>substance and in part, that CS-1 was accepted by the WLA as a client and that CS-1 should send</P>



<P>$250 to the WLA at WLA's Woodside Premises as a "contract fee," to "secure one year of (the</P>



<P>WLA's) time and effort . . . ." The letter also provided that "(a)ccording to the agent in charge of</P>



<P>your manuscript, your book stands a strong chance of selling quickly."</P>



<BR WP="BR1"><BR WP="BR2">

<P> d. CS-1 decided not to send the $250 contract fee to the WLA and instead asked for</P>



<P>the manuscript to be returned. CS-1's manuscript was returned by the WIA in the same sealed</P>



<P>envelope in which CS-1 had sent it, appearing never to have been opened or read.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 8. A confidential source ("CS-2") providing information to the USPS advised the</P>



<P>USPS of the following, in</P>



<P>substance and in part:</P>



<BR WP="BR1"><BR WP="BR2">

<P> a. In or about February 1996, CS-2 received an electronic mail message from an</P>



<P>individual identifying himself as "James Leonard," of the WLA soliciting a synopsis of CS-2's</P>



<P>manuscript. After sending such a synopsis to the WLA at WLA's Woodside Premises, CS-2</P>



<P>received a letter from "James Leonard" of the WIA which provided, in substance and in part, that</P>



<P>in exchange for a $75 reading fee, an agent would review and evaluate CS-2's entire manuscript.</P>



<P>The letter also provided:</P>



<P>"Please be advised that only 5% of the authors who Contact us are asked to submit their entire</P>



<P>manuscript."</P>



<BR WP="BR1"><BR WP="BR2">

<P> b. In response to the above-described letter, CS-2 sent an international money order</P>



<P>in the amount of $75 to WLA's Woodside Premises, along with CS-2's complete manuscript. </P>



<P>Shortly thereafter, CS-2 received a letter dated April 4, 1996 from "James Leonard," which letter</P>



<P>identified "James Leonard" as a Manager of the WLA, and provided, in substance and in part,</P>



<P>that CS-2 was accepted by the WLA as a client and that CS-2 should send $250 to the WLA at</P>



<P>WLA's Woodside Premises, as a contract fee. The letter also provided that "(a)ccording to the</P>



<P>agent in charge of your manuscript, your book stands a strong chance of selling quickly." CS-2</P>



<P>decided not to send the requested contract fee to the WLA.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 9. A confidential source ("CS&ugrave;3") providing information to the USPS advised the</P>



<P>USPS of the following, in substance and in part:</P>



<BR WP="BR1"><BR WP="BR2">

<P> a. In response to a solicitation posted on the Internet by "John Lawrence," of the</P>



<P>WLA, CS-3 sent a small portion of CS-3's manuscript to the WLA at WLA's Woodside</P>



<P>Premises. CS-3 then received a letter from the WLA stating, in substance and in part, that the</P>



<P>WLA was interested in reading CS-3's entire manuscript and would do so in exchange for a</P>



<P>check in the amount of $150. The letter also stated: "Please be advised that only a small</P>



<P>percentage of the authors contacting us are asked to submit their entire manuscript."</P>



<BR WP="BR1"><BR WP="BR2">

<P> b. In response to the above-described letter, CS-3 sent CS-3s complete manuscript</P>



<P>along with a check for $150 to the WLA at WLA's Florida Premises.</P>



<BR WP="BR1"><BR WP="BR2">

<P> c. Thereafter, CS-3 received a letter from the WLA dated July 3, 1997, which</P>



<P>provided, in substance and in part, that CS-3 was accepted by the WLA as a client and that CS-3</P>



<P>should send a $200 contract fee to the WLA. CS-3 sent a check payable to the "Woodside</P>



<P>International Literary Agency," in the amount of $200 to WLA's Florida Premises.</P>



<P>Approximately one year 3ater, CS&ugrave;3 sent a check payable to the "Woodside International</P>



<P>Literary Agency" in the amount of $250 to WLA's Woodside Premises as a contract renewal fee.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 10. I have been informed by several other people who received correspondence from</P>



<P>the WLA similar to that described above, that in reliance on the WLA's representations, they sent</P>



<P>the WLA material they wished to have published, along with fees ranging from $75 to $250.</P>



<P>Most of the fees were paid in the form of checks made payable to "James Leonard", "John</P>



<P>Lawrence" and/or the "Woodside International Literary Agency" and most were mailed to WIA's</P>



<P>Woodside Premises. My review of such checks revealed that prior to in or about March 1996, the</P>



<P>checks were made payable to "James Leonard." Thereafter, the checks were made payable to</P>



<P>"John Lawrence" or the "Woodside International Literary Agency."</P>



<BR WP="BR1"><BR WP="BR2">

<P> 11. On or about March 4, 1996, an account in the name of "John Lawrence"</P>



<P>(hereinafter the "Lawrence Account") was opened at the Independence Savings Bank located in</P>



<P>Jackson Heights, New York. On or about April 11, 1997, an account in the name of the</P>



<P>"Woodside International Literary Agency" (hereinafter the "WLA Account") was opened at the</P>



<P>Independence savings Bank located in Woodside, New York. Many of the checks referenced in</P>



<P>paragraph 10 above were deposited into the Lawrence Account and/or the WLA Account. It</P>



<P>appears that the funds in the WLA Account and the funds in the Lawrence Account were used to</P>



<P>pay the personal debts of the defendants JAMES LEONARD, also known as "John Lawrence,"</P>



<P>and URSULA SPRACHMAN, and were not used to pay any business expenses of WLA..</P>



<P>Specifically, my review of the records of the Lawrence Account and the WLA Account failed to</P>



<P>reveal any checks payable to any of the individuals identified in WLA's correspondence as</P>



<P>employees. Such bank record: contain many checks drawn against the WLA account and the</P>



<P>Lawrence account made payable to various credit card companies, in payment of credit card</P>



<P>accounts in the name of the defendants JAMES LEONARD, also known as "John Lawrence,"</P>



<P>and or URSULA SPRACHMAN.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 12. Some of the checks referenced in paragraph 10 above were endorsed over to the</P>



<P>defendant URSULA SPRACHMAN, and deposited into a joint account under the names of</P>



<P>"Ursula Sprachman" and "James Leonard." For example, the $75.00 check sent to the WLA by</P>



<P>CS-1 (referenced in paragraph 7(b) above) was made payable to the order of "James Leonard"</P>



<P>and deposited by the defendant JAMES LEONARD, also known as "John Lawrence," into a joint</P>



<P>account at Citibank, located in Queens, New York. Said joint account had been opened in the</P>



<P>names of "Ursula Sprachman" and "James Leonard," and listed WLA's Woodside Premises as the</P>



<P>account holders' mailing address. In addition, a check in the amount of $150 made payable to</P>



<P>"John Lawrence," and mailed to WLA's Florida Premises as a reading fee to WLA, was endorsed</P>



<P>over to the defendant URSULA SPRACHMAN, and deposited on or about March 3, 1997, into a</P>



<P>joint account at First Union Savings Bank in Florida. Said joint account had been opened in the</P>



<P>names of "Ursula Sprachman" and "James Leonard," and listed WLA'; Florida Premises as the</P>



<P>account holder's mailing address.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 13. None of the individuals with whom I have spoken in connection with this</P>



<P>investigation1 or whose complaints I have reviewed ever had their submissions published as a</P>



<P>result of the WLA's efforts. In fact, I have been unable to locate anyone </P>



<P>whose submissions were published as a result of the WLA's efforts. Moreover, many of the</P>



<P>individuals with whom I have spoken stated, in substance and in part, that after paying the WLA,</P>



<P>he or she did not receive any promotional information, marketing evaluations, critiques of their</P>



<P>work, or information regarding potential publishers.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 14. Despite WLA's representations regarding its selectiveness as described in</P>



<P>paragraphs 8(a) and 9(a) above, my review of numerous submissions selected by WLA reveals</P>



<P>that regardless of the quality of such submissions, every author was told by the WLA that the</P>



<P>small portion or summary of his or her manuscript was good enough to warrant the WLA's</P>



<P>evaluation of the entire manuscript in exchange for a reading fee. For example, even the</P>



<P>individual who submitted a piece entitled "Even Hitler Got the Blues," a copy of which is</P>



<P>attached hereto as Exhibit A. was advised by WLA that it was good enough to warrant the WLA</P>



<P>evaluation of the entire manuscript in exchange for a reading fee of $150. The individual who</P>



<P>submitted Exhibit A received a letter from WLA representing the following; "The agent I</P>



<P>assigned your submission is very interested in reading the entire manuscript. Along with your</P>



<P>manuscript, kindly include a check for $150.00 made out to Mr. John Lawrence . . . Please be</P>



<P>advised that less than 5% of the authors contacting our agency are invited to submit their entire</P>



<P>manuscript."</P>



<BR WP="BR1"><BR WP="BR2">

<P> 15. I have reviewed an affidavit filed by a reporter in connection with the Hitchcock</P>



<P>Lawsuit, referenced in paragraph 20 below. In such affidavit, the reporter disclosed that in</P>



<P>January 1997, he telephoned WLA's Woodside Telephone. Pursuant to the reporter's standard</P>



<P>procedures, the reporter recorded this</P>



<P>telephone call. The reporter's call was answered by a woman who professed to be unable to</P>



<P>provide any information concerning the WLA. I have listened to this tape recording. I have also</P>



<P>spoken by telephone several times to a woman who identify herself as "Ursula Sprachman." In</P>



<P>my opinion, the woman on the reporter's tape recording is the same woman with whom I spoke,</P>



<P>who identified herself as "Ursula Sprachman."</P>



<BR WP="BR1"><BR WP="BR2">

<P> 16. I have reviewed an affidavit filed by Forensic Document Examiner John Paul</P>



<P>Osborn in connection with the Hitchcock Lawsuit, referenced in paragraph 20 below. In such</P>



<P>affidavit, Mr. Osborn stated that he compared the known handwriting of the defendant URSULA</P>



<P>SPRACHMAN with the questioned handwriting of "Rita Maldonado." The defendant URSULA</P>



<P>SPRACHMAN testified that "Rita Maldonado" is an employee of the WLA and the secretary to</P>



<P>"John Lawrence." Mr. Osborn concluded that the defendant URSULA SPRACHMAN was</P>



<P>probably the author of the documents signed in the name of "Rita Maldonado." I have also noted</P>



<P>the similarities between the handwriting of the defendant URSULA SPRACHMAN and the</P>



<P>handwriting of "Rita Maldonado." In addition, it should be noted that the defendant URSULA</P>



<P>SPRACHMAN has refused to provide handwriting exemplars to the USPS based upon a letter</P>



<P>from a doctor claiming that the defendant URSULA SPRACHMAN should not be put in any</P>



<P>stressful situations.</P>



<BR WP="BR1"><BR WP="BR2">

<P> THE IDENTITIES OF LEONARD AND LAWRENCE</P>



<BR WP="BR1"><BR WP="BR2">

<P> 17. I have reviewed the records of the New York State Department of Motor Vehicles</P>



<P>pertaining to the New York State identification card issued to an individual identified as "James</P>



<P>C. Leonard" on or about January 9, 1998 (hereinafter referred to as the "NY Leonard ID Card")</P>



<P>and the New York State driver's license issued to an individual identified as "John Lawrence" on</P>



<P>or about April 12, 1994 (hereinafter referred to as the "NY Lawrence License." I have also</P>



<P>reviewed the records of the State of Florida Department of Highway Safety and Motor Vehicles</P>



<P>pertaining to (i) an identification card issued to an individual identified as "James C. Leonard" on</P>



<P>or about March 7, 1997 (hereinafter referred to as the "Florida Leonard ID Card"); (ii) a duplicate</P>



<P>of said identification card issued on or about February 3, 1998 (hereinafter referred to as the</P>



<P>"Duplicate Florida Leonard ID Card"); and (iii) a driver's license issued to an individual</P>



<P>identified as "James C. Leonard" on or about March 9, 1999 (hereinafter referred to as the</P>



<P>"Florida Leonard License"). The photographs of the holders of the identification cards and</P>



<P>licenses referenced above (the NY Leonard ID Card, the NY Lawrence License, the Florida</P>



<P>Leonard ID Card, the Duplicate Florida Leonard ID Card, and the Florida Leonard License)</P>



<P>appear to be photographs of the same individual.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 18. The applications for the NY Leonard ID Card and the NY Lawrence License each</P>



<P>set forth the following address of the applicant: 33-29 58th Street, Woodside, New York, which</P>



<P>is WLA's Woodside Premises. No change of address has been reported by the holder of the NY</P>



<P>Lawrence License or the NY Leonard ID Card.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 19. The date of birth set forth on the applications of the NY Leonard Card ID and the</P>



<P>Florida Leonard License is May 11, 1947. The date of birth set forth on the application for the</P>



<P>NY Lawrence License is May 10, 1946. All three applications indicate that the applicant is 5'11." </P>



<P>The applications for the NY Leonard ID Card and the NY Lawrence License both indicate that</P>



<P>the applicant has hazel eyes, and appear to be in the same handwriting. The middle name printed</P>



<P>on each such application is "Charles," however this printed middle name is crossed out on the</P>



<P>application for the NY Leonard ID Card.</P>



<BR WP="BR1"><BR WP="BR2">

<P> THE HITCHCOCK LAWSUIT</P>



<BR WP="BR1"><BR WP="BR2">

<P> 20. In or about January 1997, a civil action was commenced in the United States</P>



<P>District Court for the Eastern District of New York entitled Jayne Hitchock v. Woodside Literary</P>



<P>Agency et al., civil docket number 97-0166, hereinafter referred to as the "Hitchcock Lawsuit."</P>



<P>The second amended complaint was filed on or about August 27, 1998, against the Woodside</P>



<P>Literary Agency, James Leonard, John Lawrence and Ursula Sprachman, and is still pending in</P>



<P>the United States District Court for the Eastern District of New York. In the Second Amended</P>



<P>Complaint, the plaintiff, Jayne Hitchcock alleged, among other things, that the WLA is an</P>



<P>enterprise owned and operated by James Leonard, John Lawrence and Ursula Sprachman.</P>



<P>Hitchcock also alleged that after reporting the activities of the WLA to the Office of the Attorney</P>



<P>General of the State of New York, the WLA, John Lawrence, JamesC.Leonard and Ursula</P>



<P>Sprachman engaged in actions againstHitchcock constituting defamation and intentional</P>



<P>infliction of emotional distress.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 21. On or about January 22, 1999, in the United States District Court for the Eastern</P>



<P>District of New York, located in Brooklyn, New York, the Honorable Joan M. Azrak, United</P>



<P>States Magistrate Judge for the Eastern District of New York, presided over a deposition (the</P>



<P>"Deposition") of the defendant URSULA SPRACHMAN in connection with the Hitchcock</P>



<P>Lawsuit.</P>



<BR WP="BR1"><BR WP="BR2">

<P> 22. During the Deposition, the defendant URSULA SPRACHMAN made many</P>



<P>statements to the effect that John Lawrence and James Leonard were two different individuals.</P>



<P>Specifically, the defendant URSULA SPRACHMAN represented, in substance and in part, that</P>



<P>the individual identified as "John Lawrence" was a friend of hers who rented various premises</P>



<P>from her, and who owned and operated the WLA, and that the defendant JAMES LEONARD,</P>



<P>was her "companion," and someone who worked for the WLA as an independent contractor. Set</P>



<P>forth below are certain questions asked during the Deposition and the answers given by the</P>



<P>defendant URSULA SPRACHMAN</P>



<BR WP="BR1"><BR WP="BR2">

<P>Q. When did Mr. Lawrence begin to use part of the property [located at WLA's Woodside</P>



<P> Premises]?</P>



<P>A. He rented the place in January of 1996.</P>



<P>Q. What did [Mr. Lawrence] say about what kind of business he would be opening at the</P>



<P> Woodside Premises]?</P>



<P>A. That he is going on the Internet and opening up a literary agency, and that the work would</P>



<P> be conducted</P>



<P> exclusively on his computer.</P>



<P>Q. You said you have known Mr. Lawrence for twenty-five years?</P>



<P>A. No, that is my companion, James Leonard.</P>



<P>Q. How long have you known Mr. Lawrence?</P>



<P>A. Longtime [sic].</P>



<P>Q. How long?</P>



<P>A. Over ten years.</P>



<P>Q. How did that come to be that Lawrence's answer (to the complaint in the Hitchcock</P>



<P> Lawsuit] is the same [as your answer to the complaint in the Hitchcock Lawsuit]?</P>



<P>A. Because we wrote it . . . James [Leonard] and I wrote the answer and send [sic] it to John</P>



<P> [Lawrence]. </P>



<P>Q. You are saying, I'm just Ursula Sprachman and my companion is James Leonard, and we</P>



<P> were just &ugrave; &ugrave; I owned that house and I rent the defendant premises to Lawrence and I had</P>



<P> nothing to do with (the WLA)</P>



<P>A: Yes.</P>



<P>Q. Why would. you then go to the lengths of preparing legal papers for Lawrence when you </P>



<P>A: Because of James, James [Leonard] worked for the [WLA]</P>



<P>. . . Two years ago, James very briefly worked for the</P>



<P> [WLA].</P>



<P>Q: What did he do?</P>



<P>A: He read a couple of manuscripts, edited them and then decided he didn't like it. He was an</P>



<P> independent contractor and by the end of 1996 he gave up.</P>



<BR WP="BR1"><BR WP="BR2">

<P>Q: What does [Mr. Lawrence] look like? Is he tall7 short? Is he dark, is he light?</P>



<P>A: About six feet, dark hair, round eyes; that's just about it</P>



<P>Q: What does Mr. Leonard look like?</P>



<P>A: Mr. Leonard is blondish gray. He has a beard. </P>



<P>Q: How tall?</P>



<P>A: Maybe five-foot-eight.</P>



<P>Q: I need you to convince me that Mr. Lawrence and Mr. Leonard aren't the same person.</P>



<P>A: How do you want me to do that?</P>



<P>Q: I have a suspicion that Mr. Leonard and Mr. Lawrence</P>



<P> are the same person; that there is no Mr. Lawrence. So</P>



<P> I want you to convince me that is not so.</P>



<P>A: That is trying the impossible.</P>



<P>Q: You find an old snapshot of Mr. Lawrence from your days when you socialized, you find</P>



<P> a snapshot of Mr. Leonard and a xerox copy of his Florida driver's license and send me all</P>



<P> three.</P>



<P>A: Be happy to.</P>



<BR WP="BR1"><BR WP="BR2">

<BR WP="BR1"><BR WP="BR2">

<P> 23. The records of the Florida Department of Highway safety and Motor Vehicles</P>



<P>indicate that approximately 6 weeks after the above&ugrave;described deposition, in the vicinity of</P>



<P>Naples, Florida, the defendant JAMES LEONARD, also known as "John Lawrence," applied for</P>



<P>the Florida Leonard License referenced in paragraphs 5, 2.7 and 19 above. Consistent with the</P>



<P>description given by the defendant URSULA SPRACHMAN during the Deposition, the</P>



<P>defendant JAMES LEONARD, also known as "John Lawrence," had a beard in the photograph</P>



<P>submitted in connection with the application for the Florida Leonard License, unlike the</P>



<P>photographs for the New York Lawrence License, and the Florida Leonard ID Card.</P>



<BR WP="BR1"><BR WP="BR2">

<P> WHEREFORE, it is respectfully requested that arrest warrants issue for the</P>



<P>apprehension of the defendants JAMES LEONARD, also known as "John Lawrence," and</P>



<P>URSULA SPRACHMAN, so that they may be dealt with according to law.</P>



<BR WP="BR1"><BR WP="BR2">

<BR WP="BR1"><BR WP="BR2">

<P> JOHN MCDERMOTT</P>



<P> U.S. Postal Inspector </P>



<P> U.S. Postal Inspection Service</P>



<BR WP="BR1"><BR WP="BR2">

<P>Sworn to before me this</P>



<P>6th day of January, 2000</P>



<BR WP="BR1"><BR WP="BR2">

<P>UNITED STATES MAGISTRATE JUDGE</P>



<P>EASTERN DISTRICT NEW YORK</P>



<P>&lt;/pre&gt;&lt;/b&gt;</P>



<P>&lt;p&gt;</P>



<P>&lt;hr&gt;</P>



<P>&lt;p&gt;</P>



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