Gradoni and Associates, Private Investigator, Investigators, Detective, Houston, Texas  
 

 

 



 
     
     
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Carey LeVeck became a full time employee of Gradoni & Associates on November 1, 2000, after a 19-year career in law enforcement.

LeVeck’s last 14 years were spent with the State of Texas Office of the Inspector General.

Carey is a Certified Welfare Fraud Investigator and nationally recognized as an expert in Welfare, Medicaid and Nursing Home fraud.

LeVeck served as a Regional Supervisor for the last two years over 12 field Investigators, whose responsibility was to investigate electronic benefits transfer fraud in a multi-county area.

Carey brings extensive knowledge to our criminal defense team regarding profiling, surveillance and undercover work. One of LeVeck’s “sting operations” was chronicled by the television show “20/20.”

LeVeck holds a Bachelor of Science Degree from Texas A&M University and has completed the Wicklander-Zulawski Interviewing & Interrogating Techniques Seminar. Further, she has extensive training in case management, advanced investigative techniques, resource retrieval, interviewing skills and cultural diversity.

 
   
 
 

APPOINTED CASES...
Over the years Gradoni and Associates have worked appointed cases from the various Harris County District and County Courts for a number of attorneys.

Our staff reviews the appointed case with the attorney to determine the direction of the investigation based upon the defendant’s best interest and the budget provided by the Court.

An aggressive approach to backgrounding and interviewing State’s witnesses has resulted in dismissals, acquittals, suppression of search warrants and significant sentence reductions.

We provide the same effort and diligence in appointed cases, as we do in all other cases. We work with the appointed attorney, at a reduced rate, which allows us to devote more investigative time to the case.

 
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SEARCH WARRANT ISSUES….
Search warrants and affidavits are a crucial investigative element utilized by law enforcement. In many cases the affidavit for a search and arrest warrant is overlooked.

Police Officers do make mistakes and take shortcuts in their work product. Many times the warrants lack the necessary probable cause
for the issuance of a search or arrest warrant.

In a number of affidavits reviewed it has come to light that the affidavits lack detail, facts are overlooked or just plain omitted.

The affidavits reviewed and analyzed by Kevin Templeton have identified careless mistakes by the affiant. Numerous inconsistencies and questionable informant information has resulted in case dismissal and warrants being suppressed.

If you have a search warrant issue, let us investigate the facts and details of the affidavit. You will be provided a report detailing every
problem area in the affidavit.

 
     
 
 

I am pleased to offer you our first quarterly newsletter. I feel that some informative areas have been covered in this first issue. We will strive to cover other areas related to criminal defense in upcoming issues.

I am extremely proud of our efforts and victories over the past year. I am proud of the reputation that we have obtained in the criminal defense arena and look forward to future efforts.

A client of mine once told me he used our firm “because I care”. I do care. I believe that the truth does make a difference and everyone is entitled to a thorough and diligent defense.

Our 2nd annual Court Directory has been finalized and will be available in February. If additional copies of the directory are needed please call. The first issue of the directory was very well received and documents all the Harris County Courts, United States District Courts of the Southern District of Texas, and other helpful contact information for the surrounding counties.

The directory is durable, compact and fits into a day-timer or scheduler for easy access.
J.J. Gradoni

 
     
 
 

CRIMINAL DEFENSE INVESTIGATIONS…

During the year of 2000, Gradoni and Associates are proud of our efforts in the Criminal Defense arena. We feel that the use of our
investigative services have gone a long way in proving the “Truth Makes A Difference”

Some of our successes over the past year are documented…

GRAND JURY NO BILL...
A Webb County man, represented by George Parnham, was charged with fondling his girlfriend’s niece. Gradoni & Associates Investigators obtained affidavits from four witnesses who placed the defendant in another city at the time of the alleged offense. A motive for the victim’s mother to want the defendant placed in jail was also developed.

GRAND JURY NO BILL...
A salesman, represented by Mike Ramsey and Chip Lewis, was charged with raping an 18-year old female at his residence. Witness
statements from adults who were present contradicted the victim’s version of events. Statements were obtained from individuals who
had knowledge about the victim’s history of sexual promiscuity.

POLICE OFFICER ACQUITTED...
A Houston Police Department officer, represented by Aaron Sutter and Brett Ligon, was charged with official oppression for striking a
suspect after a dangerous car and foot chase. Measurement and videotape analysis of the scene proved that the state’s only witness, a Houston Police Department sergeant, was not able to see the entire scope of the incident. The jury acquitted the officer after deliberating for only five minutes.

PATHOLOGIST ACQUITTED OF SEXUAL ABUSE OF A CHILD...
A local pathologist, represented by Mike Ramsey and George Tyson, was accused by his daughter of sexual abuse from the age of three to age 16. Witnesses were developed that disputed a number of the victim’s claims. This information combined with expert testimony and the tenacity of the trial lawyers cross examining the State’s witnesses resulted in a “Not Guilty” verdict.

INTOXICATED ASSAULT CHARGES DISMISSED...
A high school senior, represented by Alan Cohen, was charged with intoxicated assault. The complainant claimed serious bodily injury
and also filed a civil injury lawsuit against the defendant. Videotape surveillance of the complainant proved he had no serious injuries.
The felony was reduced to a DWI.

HUNG JURY FOR BABYSITTER...
A babysitter, represented by “Racehorse” Haynes, was charged with causing an injury to a child in her care that caused the child’s death. Gradoni & Associates Investigators determined that the Harris County Sheriff's Department actually believed the child’s mother, who failed a polygraph examination, was the prime suspect.

School records, analysis of telephone calls, and driven routes established
that the child was not at the babysitter’s residence for more than a few minutes, disputing the testimony of the mother.

A witness developed by Investigators provided insight about the baby’s 16 year old brother who offered a graphic description revealing
how the baby sustained the injuries. The brother was alone with the baby for 20-30 minutes that morning.

A background investigation on the State’s medical expert from California allowed Haynes to erode the witness’ credibility on the stand.

HUNG JURY FOR BOXING COACH…
A local boxing coach, represented by Stanley Schneider, was charged with sexual abuse of his girlfriend’s three children. Videotape and analytical analysis of the gym where some of the alleged incidents took place disputed the victim’s testimony.

Twenty-five character witnesses were developed that testified that the coach had been involved in the development of hundreds of youths without ever having a single complaint.

A motive was developed as to why the children’s mother would want to see her former lover sent to jail.

DELIVERY OF CRACK CASE DISMISSED...
A homeless male, represented by Robert Fickman, was charged as being a middleman in an undercover street buy of crack cocaine. Witnesses provided affidavits that the defendant was not involved in the transaction. The District Attorney agreed to drop charges when presented with the witness information.

HIGH SCHOOL STUDENT ACQUITTED OF MURDER CHARGE...
An 18-year old high school student, represented by Stanley Schneider, was charged with a robbery and shooting that occurred in the driveway of a club two blocks from his house.

The State’s only witness gave police three different versions of what she observed. The witness’ description of a blue Toyota with chrome wheels led to the defendant’s identification and arrest.

Gradoni & Associates Investigators were able to prove that the defendant’s mother had possession of the vehicle at the time of the shooting at her place of employment. The vehicle never had chrome wheels.

Additionally, a scene investigation and the development of witnesses at the scene provided Investigators with information that raised issue with the police investigation.

BARTENDER ACQUITTED OF ATTEMPTED CAPITAL MURDER...
A bartender, represented by Emily Munoz, was charged with attempted capital murder of a police officer when police officers ran
into his bar to execute a narcotics search warrant. The bartender was in a backroom at the time and felt the bar was being robbed.

Documentation was found that verified the bartender had been robbed on two previous incidents and had actually been shot on one occasion. Videotape and scene measurements proved that the bartender could not see the police officers when they entered the bar, supporting his story that he shot into the ceiling of the storeroom to scare off what he believed were robbers.

WRECKER DRIVER ACQUITTED OF INVOLUNTARY MANSLAUGHTER...
A Houston wrecker driver, represented by George Parnham, was charged with involuntary manslaughter for hitting a pedestrian standing in the middle of the roadway.

Witnesses to the accident were interviewed, who had actually seen the victim standing on the middle stripe pretending to be a bullfighter.

Videotape and scene measurements verified the poor lighting conditions at the time of the accident. All the information verified that the
wrecker driver could not have seen the victim in time to avoid striking him.

GOLFER NO BILLED BY GRAND JURY...
A golfer, represented by Robert Fickman, was charged with choking a juvenile who had gone onto the course and stolen his golf ball. The victim’s mother admitted to a Gradoni & Associates Investigator that her child had suffered no injuries as a result of the incident. Witnesses were also developed that testified that the child and his friends were trespassing all over the course.

GAMBLING CHARGE ACQUITTAL…
A Longview businessman and restaurant owner was charged with five misdemeanor counts related to his possession of four “8-liner” devices. The defense attorneys in the case were Stephen Fenoglio of Austin and Odis Hill of Longview.

The trial lasted 5 days and was prosecuted by the District Attorney and the Attorney Generals office. Kevin Templeton provided crucial
expert witness testimony about the devices and the problems with the affiant’s search warrant affidavit.

The jury deliberated for 90 minutes and returned a verdict of not guilty on each of the misdemeanor counts. As a result, other pending
cases on co-defendants were dismissed by the District Attorney’s Office.

ASSAULT CHARGE ACQUITTAL...
A male, represented by Mike DeGeurin and Heather Peterson, was charged with assault as a result of an incident that occurred at an Oriental restaurant. Information was developed that proved the co-defendant actually was guilty of the assault. Our defendant was actually an assault victim himself as verified by hospital records.

INTOXICATED HOMICIDE ACQUITTAL...
A female, represented by George Tyson, allegedly had cocaine in her system when she hit a stalled car on the shoulder of Interstate 10, killing the occupant.

Accident scene inspection, measurements and videotape proved that the victim’s vehicle was parked in a position that was very difficult to see because of the poor lighting conditions and rise in the freeway.

Gradoni & Associates Investigators were able to prove that the defendant did not have cocaine in her system at the time of the accident as a result of obtaining chemical analysis of the defendant’s hair.

750 KILOS OF COCAINE SUPPRESSED...
The defendant, represented by Robert Fickman, was one of several co-defendants charged with possession of 750 kilograms of cocaine as a result of surveillance on a business warehouse.

Kevin Templeton’s evaluation of the search warrant pointed out a number of non-specific details and unsupported statements by the affiant. The motion to suppress was granted and the charges resulting in the seizure were dismissed.

CRACK COCAINE SUPPRESSED….
The defendant, represented by Robert Fickman, was charged with possession of crack cocaine as a result of a search warrant executed at his hotel room.

Analysis of the search warrant and independent investigation by Gradoni & Associates identified a number of statements that could not be supported by proof or factual knowledge of the affiant.

GRAND JURY NO BILL...
A young man on his way to church, represented by Randy Schaffer and Cindy Henley, was involved in a traffic accident on the Beltway. The defendant struck a vehicle parked near a tollbooth, killing the driver who was changing his tire. The defendant was charged with negligent homicide because he had crossed the solid white lines in order to get to the far left EZ tag lanes.

Videotape was taken of the scene for one hour at the same evening and time that the accident occurred. The videotape captured 14 vehicles crossing the solid white line during the 60 minutes proceeding to the far left EZ tag lanes, making the defendant’s action more “normal than negligent.”

POSSESSION OF MARIJUANA CASE DISMISSED…
A young female, represented by Alan Tanner, had traveled to Houston with her boyfriend. The boyfriend had rented a car in the defendant’s name, leaving her alone in a hotel room. The Houston police, who found 65 pounds of marijuana in the trunk of the vehicle, subsequently stopped the pair.

Information was developed that led to affidavits proving that the defendant had no knowledge of her boyfriend’s criminal activities.

 
     
 
 

Do the cops perform a complete investigation following the crime to its most logical conclusion?

Do cops take shortcuts and present a biased case to the District Attorney to be prosecuted?
At Gradoni & Associates we will examine the evidence compiled by a law enforcement agency and then conduct an investigation that will be pursued to the case's most logical conclusion. Clients are provided a thorough report to support the best possible defense.

Our investigation will find witnesses overlooked by law enforcement and identify all inconsistencies in the state's case. Our experienced Investigators will leave "no stone unturned" in the defense of our client.

ADDITIONAL SERVICES INCLUDE:
Witness backgrounds– looking at both the civilian witness and the law enforcement officer to determined credibility and areas
where testimony can be impeached.

Jury Work Ups– know your jury. How do they profile?

Pre-sentence Investigations– documentation to help the client obtain probation or a reduced sentence, if convicted.

Why should the State’s PSI be the only record used by the Court. Typically the PSI is slanted against the defendant and very one-sided. There is another side!

 
     
 
 

We have compiled a notebook, to assist Defense Attorneys, with a focus on Standardized Field Sobriety Testing. We have received some very positive feedback on this data and would be happy to pass along a copy for your review and utilization.

If you would like a copy please call the offices of Gradoni and Associates.

Related to this topic a number of recent investigations for clients included scene investigations where the Field Sobriety Tests were offered to defendants suspected of driving while intoxicated. In each of the cases it had been determined that the officers asked defendants to perform the tests on terrain and conditions that did not allow for a fair test.

Our scene investigations found faulty road and pavement conditions, hazardous traffic conditions and debris, all conditions that would hinder and affect the defendants ability to successfully complete the tasks. These conditions were photographed, video taped and measured for the defense efforts.

 
     
 
 

Eight members of our staff have previous law enforcement investigative experience, totaling 117 years. Our team of diversified Investigators has experience in the investigation and prosecution of cases for virtually every Penal Code Statute.

A number of our team members have expert status in white-collar crime, gambling, search warrant analysis, child abuse, welfare fraud, railroad investigations, and fingerprints.

In the year 2000, Gradoni & Associates assisted our attorney clients in obtaining:

8 Acquittals
3 No Bills
6 Dismissals
2 Hung Juries
2 Narcotic Search Suppressions

 
     
 
 

A FINAL NOTE…
Over the past couple of years Gradoni and Associates have been asked by our clients to seek out and identify experts in related to various areas of criminal defense matters.

We have established a database of these experts. Some of the areas of expertise deal with chemical testing for narcotics, hair testing, DNA evidence, toxicology and polygraph examinations.

If you have a need for an expert or need evidence analyzed please contact us.

 
 
 
   
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