Busted!

Alonso, looking haggard, had turned herself in, along with her husband Leonel, at the Doral headquarters of the Miami-Dade Police Department and then disappeared into an explosion of TV lights and shouted questions from the press. This was the second go-round in four months for the Alonsos, who earlier had been arrested on a variety of corruption charges. The additional charges severely complicated the Alonsos' legal problems, but perhaps more significantly, represented a milestone for State Attorney Katherine Fernandez Rundle.

Since Rundle assumed the top prosecutor's job in 1993, following Janet Reno's appointment as U.S. Attorney General, a shocking number of prominent public officials have been charged with corruption: Miller Dawkins, Cesar Odio, James Burke, Bruce Kaplan, Humberto Hernandez, Alberto Gutman, Carmen Lunetta, Pedro Reboredo, Donald Warshaw, and Demetrio Perez, Jr. Eight of those individuals were brought to justice by federal prosecutors (Rundle did successfully charge Hernandez with vote fraud, but only after he'd been convicted in federal court on money-laundering and mortgage-fraud charges). The two men whose cases were the sole province of the State Attorney -- former county commissioners Kaplan and Reboredo -- managed to avoid trial and the threat of prison by cutting deals with Rundle's office.

Some people saw these two cases as examples of Rundle's tepid approach to public corruption. In particular the Reboredo plea agreement, reached in May 2001, rankled certain local law-enforcement officials who believed he should have been charged with a felony. In response, when Miami-Dade Police detectives last year began making a case against Miriam Alonso, they did not inform Rundle as they normally would, which prompted speculation that the cops hoped to take their information to the U.S. Attorney's Office for tougher federal prosecution. One source with knowledge of the Alonso investigation told New Times last year: "The people working on this don't want anything sent to the State Attorney's Office."

Eventually the police and the SAO settled their differences and the Alonso case stayed with Rundle. The result: more charges and more serious charges brought against an elected official than any in recent memory.

In April of this year Miriam and Leonel Alonso, along with Miriam's chief of staff Elba Morales, were arrested on multiple corruption charges ranging from grand theft and money laundering to "exploitation of official position." The Alonsos were alleged to have looted Miriam's 1998 re-election campaign treasury of at least $54,000, money they then simply used. (Miriam was also charged with ordering a county employee to spend substantial time working as her personal handyman.) Miriam faced one misdemeanor and three felony counts. Leonel was charged with eight felonies. Fourteen felony counts were brought against Morales.

The new charges filed September 4 included a slew of felonies and misdemeanors; notable among them were alleged crimes committed after the Alonsos' April arrest -- fabricating evidence and coaxing potential witnesses into lying to investigators. Overall, though, the alleged crimes seemed familiar -- looting a treasury of nearly $80,000 in donations from contributors who believed they were helping Miriam battle an effort to recall her from office.

Also familiar was the presumed motive: the personal enrichment of Leonel and Miriam Alonso. Not that the duo are in dire need of enrichment. In her most recent financial-disclosure form, filed July 1, Miriam declared her net worth at $2,720,489, wealth principally derived from at least fifteen rental properties she and her husband own in Miami and Hialeah.

Motivation aside, the stakes are now extraordinarily high for both the Alonsos and Rundle. If convicted at trial of all charges, Miriam and Leonel could spend the rest of their lives in prison. If, on the other hand, they seek a plea agreement with Rundle, the pressure will be on the State Attorney to extract at least one felony conviction and some prison time for both.

The report below is the unedited text (except where summarized in italics) of the arrest affidavit describing the most recent charges against the Alonsos. It was sworn to by Miami-Dade Police Ofcr. Antonio Rodriguez and Miami-Dade Inspector General's Office special agent John Kennedy. Far from being a dry legal document, it is, as Inspector General Mazzella put it, a kind of textbook on malfeasance.

But more than that, and thanks largely to the testimony of former chief of staff Elba Morales, it provides a rare glimpse into the psychodynamics of greed and corruption. The chilling details of the Alonsos' schemes to steal and defraud are matched by their ruthless demands to collect ill-gotten cash, even during the grieving for Morales's deceased husband. When they become aware they are under investigation, the Alonsos recklessly conspire to conceal their alleged crimes by enlisting friends and associates in a coverup. In time paranoia takes hold, allies defect, and a grand betrayal leads to the conspiracy's collapse.

-- The Editors

What started in the fall of 1999 as the most parochial of issues -- a bunch of Miami Lakes residents opposed to a Jacksonville company's plans to build a 90-foot dump nearby -- has since evolved into a momentous tale of political corruption. The company proposing to build the dump, Peerless Dade, hired heavy hitters to lobby its case to the Miami-Dade County Commission, including state Republican Party Chairman Al Cardenas. Political consultant and former Hialeah councilman Herman Echevarria, who is close to Mayor Alex Penelas, disclosed that he had a financial stake in the project. Opposing the issue were Miami Lakes activist and lawyer Michael Pizzi and community councilman Carl Dasher. When it appeared that county commissioner Miriam Alonso, whose District 12 covered the area affected, was taking the side of the developers, Pizzi announced a plan to start a recall campaign to force Alonso out of office. In response, the Alonso camp started the political action committee (PAC) "Concerned Citizens of District 12" to raise funds to fight the recall effort. Investigators say that no funds were ever raised or expended under this PAC. Instead a bank account under the name "Neighbors of District 12" was opened at Union Planters Bank on November 9, 1999. Monies donated to fight the recall effort were deposited in this account, even though Alonso knew by then the recall was a dead issue.

In fact the dump expansion was dropped, so the recall movement was moot. This fact was driven home on November 1, 1999, when Dasher's organization, "Miami Lakes Country," sent a fax to Alonso's office stating, "The war is over against the dump for now." Pizzi sent another fax to Alonso's office on November 10, 1999, stating that the recall effort had ended. Although Alonso and her supporters were aware that the recall was over, contributions kept coming into the "Neighbors of District 12" bank account between November 10 and December 6, 1999. Contributors were apparently never informed the recall effort had foundered.

In early 2001, two sources contacted authorities and alleged that the recall money had become a personal slush fund for Miriam Alonso and her husband Leonel, who was her campaign treasurer. On April 11, 2002, the Miami-Dade State Attorney's Office charged Alonso's chief of staff Elba Morales with money laundering, grand theft, and mortgage fraud. The Miami-Dade Police Department's Public Corruption Squad, along with the Miami-Dade Office of the Inspector General, threatened Morales, who had signed many of the incriminating documents and who had solicited her daughter, Christine Morales, to sign documents as well. By late July of 2002, Morales had become a cooperating witness against the Alonsos. She revealed the alleged inner workings of the conspiracy to extract money from the account for personal use while making it look as if the money was spent on legitimate anti-recall efforts. For her cooperation, authorities reportedly agreed not to prosecute her daughter, and will recommend probation for Morales.

According to Elba Morales, Miriam and Leonel Alonso wished to devise a method or scheme by which checks from the "Neighbors of District 12" bank account would be written to certain individuals, who were willing participants that would, in turn, cash the checks and return the U.S. currency back to them. This was done to hide the fact that the money was not used on legitimate expenses related to the anti-recall effort, which had ended by the first week of November 1999. Part of the scheme was to backdate checks written to certain individuals to make it appear as if the checks were written prior to the deadline for the recall petition. According to Elba Morales, this was done to make it appear that the checks were payments for work conducted in the anti-recall effort.

The investigators noted that they interviewed ten of the commissioner's aides, who had no knowledge of anyone actually campaigning, fundraising, or establishing a phone bank on behalf of the anti-recall effort. One aide said she was asked to stay after hours to make calls regarding the recall. The affidavit notes that another aide, Benito Filomia, initially told investigators he worked for several weeks canvassing and organizing the recall effort. He later recanted his testimony and admitted he only worked one day to combat the recall.

Investigators also interviewed numerous contributors. They noted that 48 of the contributors recalled that their donations were specifically to help Alonso fight the recall effort. Others said they believed their contributions were for a political purpose but were not sure exactly what. Nearly all said they did not intend their donations for the Alonsos' private use.

Elba Morales stated to your affiants that at the time the fund was created, she met with Miriam and Leonel Alonso to discuss how the donations or contributions would be solicited. She also stated that Miriam Alonso wrote out a list of individuals with amounts that she believed these individuals would be able to contribute, and directed Elba Morales to contact them and advise that the contributions would be made on behalf of Miriam Alonso's effort to fight the recall. Morales added that she was also personally instructed by Miriam Alonso to make arrangements for having the checks picked up.

One contributor, Nelson Garcia, advised your affiants that he was personally solicited by Miriam Alonso for a contribution for the "Neighbors of District 12" fund. The solicitation occurred at a luncheon at the Versailles restaurant, which is located at the 3500 block of SW 8th Street in Miami, FL. Garcia then authorized a $1000 contribution to the fund from his company, Elinel Corporation. It should be noted that the check from Elinel was dated November 18, 1999, and deposited on November 24, 1999, both of which dates were after then-Commissioner Miriam Alonso had been informed that the recall effort against her had ended.

With regards to the expenditures made from the account, your affiants' investigation has revealed the following information:

A review of subpoenaed bank records from the "Neighbors of District 12" account reflected that there was $88,100 contributed and deposited into the account. Elba Morales, who is cooperating with this investigation, has told your affiants that out of the $88,100 that was raised from contributors for the purported recall campaign, only $9805.43 was actually spent on recall-related expenditures. Elba Morales gave detailed information concerning all fraudulent expenditures. Wherever possible, your affiants have corroborated her testimony by speaking with other witnesses or examining available documents.

ONE STOP ENTERPRISES, INC. ($10,000)

One Stop Enterprises, Inc., is a business owned by Ileana Morales, who is Elba Morales's daughter and the signatory on the "Neighbors of District 12" bank account. The idea behind the business is that it was meant to be a one-stop location for concession vendors to purchase different sorts of vending machine supplies, as well as cold foods. According to Ileana Morales, who is a cooperating witness in this investigation, no business was actually ever conducted by this corporation.

Early on in the investigation, some witnesses referred to telephone banks that had been used in the anti-recall effort, and it was speculated that perhaps the phone banks were funded by the checks issued to One Stop Enterprises, Inc. However, the witnesses who initially stated this have since recanted it, and Ileana Morales has now stated, and Elba Morales verified, that there were no phone banks organized for the anti-recall effort, and there was no other active work done on the anti-recall issue for the monies paid to One Stop Enterprises.

At the time the two checks were issued to One Stop Enterprises, according to Elba Morales, she and Miriam Alonso were deciding on which individuals to ask to cash checks from the "Neighbors of District 12" account. According to Elba Morales, Ms. Alonso suggested to her that a $10,000 payment to a phone bank could be easily justified, and One Stop Enterprises could be listed as having operated the phone banks. Two checks were subsequently issued to One Stop, one for $4815, and the second for $5185. The first check was used to open an account under One Stop Enterprises at a Washington Mutual Bank branch, and the second check was deposited two days later into the same account. A check from this account was subsequently issued to Vanessa Morales, a close friend of Ileana Morales, for $8000, which she stated she cashed and turned over to Ileana Morales. Elba Morales and Ileana Morales both stated to your affiants that the $8000 was then turned over by Ileana Morales to Elba Morales, who, in turn, stated she gave it to Miriam Alonso. A second check from the One Stop account for $500 was written to "Cash" and cashed by Elba Morales, who stated that she did cash it and turned the U.S. currency over to Miriam Alonso.

Elba Morales stated that of the remaining $1500 from the funds paid to One Stop Enterprises, $1200 was allotted with Alonso's permission to Elba Morales's daughter, Christine Morales, for her use in paying her federal income taxes for 1998. The reason for this, according to Elba Morales, was that Christine Morales had cashed $8500 worth of checks during Miriam Alonso's 1998 re-election campaign and returned the cash to Elba Morales, who then gave the cash to Miriam Alonso. Christine Morales had incurred federal income tax liability due to her acceptance of those checks. Elba Morales also stated that at the time that Christine Morales was to file her 1998 Federal income tax return in early 1999, Miriam Alonso had agreed to allow Elba Morales to apply monies still owed to Alonso by Morales from checks that had been issued to One Stop Enterprises from the "Neighbors of District 12" account toward Christine Morales's federal income taxes for 1998. This reduced by $1200 the amount of monies owed to Miriam Alonso from checks that had been cashed.

Elba Morales stated that the remaining $300 from the $1500 not turned over to Miriam Alonso was paid back to Miriam Alonso when Elba Morales cashed a personal check from her First Union bank account. In fact, the $1200 supposed to have been allotted to cover Christine Morales's tax bill was actually spent by Ileana Morales and Vanessa Morales to cover personal bills of theirs.

VANESSA MORALES ($18,000)

Vanessa Morales is a close friend of Ileana Morales, and the two share an apartment in the Miami Beach area. Vanessa received a total of three checks from the "Neighbors of District 12" bank account. These were as follows: Check No. 1003, dated 11/30/99, for $3000; Check No. 1019, dated 01/14/00, for $10,000; and Check No. 1020, dated 11/30/99, for $5000.

With regards to the first check, Elba Morales stated that she gave the check to Vanessa on the day it was cashed, December 23, 1999; that Vanessa took the check and cashed it at a Union Planters Bank branch; and that Vanessa returned to Elba Morales's apartment and turned the $3000 in U.S. currency over to Elba Morales. Vanessa, who initially told your affiants that she performed work on the anti-recall effort, has recanted her prior statements and has become a cooperating witness in this investigation. Vanessa Morales has now admitted that she did no such work and has verified the testimony of Elba Morales. Elba Morales also stated that she took the cash from Vanessa and shortly afterward took it to Miriam Alonso's residence, where she turned all of that cash over to Ms. Alonso.

According to Elba Morales, the second check, which was written on January 14, 2000, for $10,000, was written by Vanessa Morales herself, at Elba Morales's direction. January 14, 2000, was the day after Elba Morales's husband, Orlando Morales, had passed away, and Miriam Alonso had requested that Elba withdraw some funds from the "Neighbors of District 12" account for her (Miriam Alonso). Elba Morales stated that she instructed Vanessa Morales to fill out the check and cash it. Vanessa verified this information, and stated that she turned the cash over to Elba Morales at her apartment. Later that day, Elba Morales stated that she was at the funeral home during her husband's viewing, when Miriam Alonso arrived to pay her respects. The viewing took place at the Rivero Funeral Home, which is located at the 8200 block of SW 40th Street in Miami, FL. According to Elba Morales, during the visit she spoke briefly to Miriam Alonso about the money and inconspicuously slipped a bank envelope containing $8000 in U.S. currency into Miriam Alonso's purse. According to Elba Morales, Miriam Alonso had agreed to lend her the two-thousand-dollar balance from the check to help pay whatever outstanding bills she had as a result of her husband's death.

Elba Morales stated that for the next several months, Miriam Alonso reminded her of the $2000 balance owed to Alonso. Later that year, in October 2000, according to Elba Morales, Miriam Alonso told her that she wished to help her daughter, Miriam Alonso-Miles, with some money for her children's school. Elba Morales told your affiants that Miriam Alonso instructed her to write a check to Alonso-Miles for the $2000 loan she still owed her. Elba Morales stated that on October 16, 2000, she wrote and delivered a check to Alonso-Miles, which Alonso-Miles cashed on the same day. Elba Morales also stated that Miriam Alonso-Miles did not work on any anti-recall effort. Miriam Alonso-Miles has also stated to your affiants that she did no such work.

The third check written to Vanessa Morales, the one for $5000 dated November 30, 1999, was used to open a joint bank account between Vanessa and Ileana Morales. Elba Morales stated to your affiants that she wrote the check to Vanessa Morales to make it appear that it was payment for work done by Vanessa on a phone bank during Miriam Alonso's anti-recall effort. Vanessa Morales verified that the check was deposited into the joint account. On March 14, 2000, Elba Morales advised Vanessa that she needed to write a check from the joint account in order to return some of the money from the check to Miriam Alonso. Elba Morales advised that she personally wrote a check for $3000 in Vanessa Morales's name and asked Ileana Morales, her daughter, to sign the check. Vanessa Morales stated that she took the check, cashed it, and later turned the $3000 in U.S. currency over to Elba Morales, who stated that she, in turn, gave the cash to Miriam Alonso. Although the $2000 that remained in the account from the check was still owed to Miriam Alonso, Vanessa Morales and Ileana Morales stated that the money was used by them to settle personal bills.

With regards to the still remaining $2000 debt to Miriam Alonso, Elba Morales stated that approximately $1100 was also supposed to be allotted to her daughter, Christine Morales, for her use in paying her 1998 federal income taxes. According to Elba Morales, as previously stated, Christine Morales had cashed $8500 worth of checks during Miriam Alonso's 1998 re-election campaign and returned the cash to Elba Morales, who says she turned it over to Miriam Alonso. Elba Morales also stated that at the time Christine Morales was to file her 1998 federal income taxes in early 1999, Miriam Alonso had agreed to allow Elba Morales to use monies still owed to Alonso by Morales from checks that had been issued to One Stop Enterprises and Vanessa Morales from the "Neighbors of District 12" account to cover Christine Morales's federal tax bill. Because of this, the amount of monies still owed to Miriam Alonso from monies received from the "Neighbors of District 12" account was reduced by an additional $1100, which, coupled with the previous reduction of $1200, amounted to a total reduction of the debt to Alonso of $2300, all of which was to be applied to Christine Morales's taxes. Elba Morales stated she herself wrote a personal check from her account to settle Christine's 1998 federal income taxes, since the funds allocated to Christine's taxes had actually been spent already by Ileana Morales and Vanessa Morales.

Elba Morales stated that she later wrote out a personal check for $500 from her First Union Bank account and cashed it. She advised that she personally handed Miriam Alonso the $500 in U.S. currency to reduce any balance owed to Alonso from checks that had been cashed. Elba Morales also stated that there was $400 from the original $5000 check to Vanessa Morales that she could not show how the currency had been returned to Miriam Alonso.

Although at the time that she cashed the checks and returned cash to Elba Morales, Vanessa Morales was not aware of the purpose of the returned currency, she was later asked to provide false testimony with regards to the events surrounding the three checks. Elba Morales stated that she was instructed by Miriam Alonso to speak to Vanessa Morales and advise her that if she were questioned by police investigators with regards to the checks, then she should state that the checks were received as a result of work performed for Miriam Alonso's anti-recall effort. She was also to state that part of the cash returned to Elba Morales was used to pay expenditures related to the anti-recall effort.

BENITO FILOMIA ($10,000)

At the time he was subpoenaed to provide testimony in this investigation, according to Benito Filomia, he met with Elba Morales, who instructed him on what his testimony should be. He was instructed by Morales to state that he had been paid a $10,000 fee for his supposed efforts in fighting the recall against former Commissioner Alonso. Elba Morales has stated that she gave these instructions to Filomia after she had received them from Miriam Alonso. According to Elba Morales, Miriam Alonso, in an effort to isolate herself from the criminal investigation, would always have her (Elba Morales) speak to Filomia with regards to providing false testimony about payments he received from the "Neighbors of District 12" fund. Part of the fictitious fee was paid directly to Filomia in a $5000 check to Filomia and the other $5000 was paid to Attorney Benedict Kuehne for having represented Filomia in litigation connected to a residency challenge against City of Sweetwater Commissioner Manuel Marono in early 1999, which was several months before the recall effort was initiated, and was in no way associated with Miriam Alonso's recall. Since then, Mr. Filomia has become a cooperating witness in this investigation and advised the actual course of events as they occurred.

Mr. Filomia stated that he had been asked by Elba Morales to cash the $5000 check that had been written to him and return the cash to Elba Morales, who has stated to your affiants that she turned the currency over to Miriam Alonso. Benito Filomia cashed the $5000 check on January 10, 2000. Elba Morales also stated that Mr. Filomia's $5000 legal fees for the legal issue regarding the 1999 Sweetwater election were settled with attorney Benedict Kuehne from funds that came from the "Neighbors of District 12" bank account. Mr. Filomia advised your affiants that then-Commissioner Miriam Alonso had initially promised to pay his (Filomia's) legal fees if he were to proceed with the civil litigation regarding the Sweetwater residency issue. Elba Morales and Benito Filomia stated that Miriam Alonso had a clear interest in the Sweetwater litigation, since Manuel Marono, a Sweetwater City Council candidate whose residency was being challenged by Filomia in the litigation, was a political ally of Sweetwater Mayor José "Pepe" Diaz. Morales and Filomia further advised that Miriam Alonso would support anyone who would oppose Mayor Diaz or his interests.

The legal fees were paid to attorney Kuehne via a $9000 check that was written to attorney Jesus Uriarte and deposited into attorney Uriarte's trust account. Attorney Uriarte, in turn, wrote a $5000 check from his trust account to attorney Kuehne. Both Elba Morales and Benito Filomia have verified that no actual work was conducted in order to combat the recall effort and that the money paid to attorney Kuehne was for the Sweetwater matter, which was totally unrelated to the recall of former Commissioner Miriam Alonso. Mr. Kuehne, in a statement to your affiants, confirmed this.

Mr. Filomia stated that at the time that he became aware of this investigation during 2001, he decided to amend his 1999 federal income taxes in order to avoid any possible sanctions by the Internal Revenue Service for not paying federal income taxes on the fictitious fee he had received. Mr. Filomia stated that before he filed the amendment to his 1999 federal income taxes, he received instructions from Elba Morales that he should amend his taxes to reflect the $10,000, to include both the $5000 check to him and the $5000 payment to Attorney Kuehne. Morales stated that she gave Filomia these instructions just as she had received them from Miriam Alonso.

Berta Filomia, the wife of Benito Filomia, advised your affiants that at one point she personally advised Leonel Alonso that she still had a pending legal bill with Attorney Richard Diaz, who had represented both her and Benito Filomia when they rendered testimony in this investigation. Leonel Alonso advised her that payment of the bill would not be a problem, and that she should speak to Elba Morales regarding the issue. Berta Filomia went on to advise that between mid-2001, when the Filomias' taxes were amended, and early 2002, when the two initially provided sworn statements at the State Attorney's Office, Elba Morales stated that she gave Benito Filomia U.S. currency to cover the expenses of legal counsel incurred by the couple during the investigation, as well as to cover the additional taxes paid by Filomia. During this period Elba Morales stated that she delivered to Benito Filomia approximately $5461 in currency from Leonel Alonso. From these monies, $2961 was used to pay income taxes when the couple's taxes were amended in 2001, and the remaining $2500 was used to pay Attorney Diaz for the couple's representation, according to Benito Filomia.

JESUS URIARTE ($9000)

Jesus Uriarte is an attorney and an acquaintance of Elba Morales and Miriam and Leonel Alonso. As previously stated above, Mr. Uriarte received a $9000 check from the "Neighbors of District 12" account, which was deposited into his law firm's trust account. Mr. Uriarte then took the check and disbursed in three checks as follows: $5000 to Attorney Benedict Kuehne; $3000 to Attorney Kendall Coffey; $1000 to himself. The reason for the issuance of the check to Attorney Benedict Kuehne was stated above, and it was not for any anti-recall-related expense.

Uriarte and Morales both verified that the $3000 check issued to Coffey was payment for legal fees not related to the recall. Coffey stated that he did provide some legal advice to Alonso regarding the recall, but "he made it very clear that this work was not billed and not part of the $3000 payment he had received."

Morales and Uriarte verified that the remaining $1000 was paid to Uriarte as a fee for legal research he did on recall-related issues.

Investigators interviewed eight individuals who admitted their roles cashing checks from the District 12 account, all for less than $5500, and then turning the money over to Morales or Alonso. Among them was Edward Lyon, who shares an apartment with Morales's daughter. Morales wrote him a check for $2250, which both say he cashed and then turned the proceeds over to Morales. When the State Attorney's Office subpoenaed Lyon, he and Morales told investigators that Morales gave him $1000 for legal fees. Morales says this money was provided by Leonel Alonso.

Others whom investigators identified as having cashed checks on behalf of the Alonsos include Berta Gonzalez, a former tenant of Morales, who cashed a check for $4205. Eugenio Coto told investigators that he cashed three checks worth $5500 for Morales. When Coto was subpoenaed, Morales gave him $2500 for legal fees and told him to testify that he worked on the anti-recall effort. Morales says the money came from Leonel Alonso while Miriam Alonso instructed her on what to tell Coto. Morales told investigators that she and her daughter, Christine Morales, picked up Coto's girlfriend, Berta Valdes, who has since died, on February 26, 2000, and drove her to a bank to cash a check for $2500, then took her to lunch. (Morales said she had previously used Valdes to cash a check for fraudulent campaign expenses during Alonso's 1998 re-election campaign.) Morales stated that she and her daughter then drove to Alonso's house and gave the cash personally to Miriam Alonso.

LA COVACHA ($11,144)

La Covacha is a restaurant/nightclub that is located at the 10700 block of NW 25th Street in Miami, FL. La Covacha is owned by Aurelio Rodriguez. According to Elba Morales, she met Mr. Rodriguez several years earlier. Elba Morales stated that at the time that monies were being dispersed from the "Neighbors of District 12" bank account, she decided to approach Mr. Rodriguez and ask him if he would cash a check from the account and return the currency to her. Mr. Rodriguez had been asked to do the same thing the previous year with a campaign check after Miriam Alonso had been re-elected to her commission seat, and he had done so.

Once again, Mr. Rodriguez agreed to cash checks and return the currency to Elba Morales. Ms. Morales stated that she provided Mr. Rodriguez with three checks from the "Neighbors of District 12" bank account, which she wrote in the name of his business, La Covacha. These checks, which totaled $11,144, were deposited into La Covacha's business account on February 3, 2000. Mr. Rodriguez stated that over a period of time, he returned the $11,144 to Elba Morales in U.S. currency. On each occasion, Ms. Morales stated that she would drive to the Alonso residence and turn the currency over to either Miriam or Leonel Alonso.

Ms. Morales further advised that since there was not an anti-recall effort, the services of La Covacha were never needed, and the business never provided any food products for any anti-recall effort. La Covacha did, however, provide meals for several events at local elderly centers during late 1999. Ms. Morales and Mr. Rodriguez have both verified that La Covacha donated the meals for these events, and Ms. Morales stated that Miriam Alonso had knowledge of the fact that the meals were donated. As evidence of this fact, your affiants have obtained from Commissioner Alonso's office a letter dated November 30, 1999, signed by Commissioner Miriam Alonso on County Commission stationery, thanking La Covacha for its generosity in providing the food.

In November 2001, a subpoena was served on One Stop Enterprises requesting records for services and payments showing business transacted between One Stop Enterprises and "Neighbors of District 12." Elba Morales stated that sometime during the summer of 2001, she and Miriam and Leonel Alonso learned of the inquiry and ongoing criminal investigation into the expenditures from the "Neighbors of District 12" bank account. Since Ms. Morales and the Alonsos knew that the vast majority of the monies from the account had not been expended on actual anti-recall related activities, the three, according to Elba Morales, then embarked in an effort to determine how to make all of the illegitimate expenditures appear as if they were legitimate. According to Elba Morales, Miriam Alonso instructed her to obtain receipts from different businesses and individuals that could then be used to account for and justify the monies disbursed from the account.

Morales said that Alonso instructed her to seek out numerous receipts that they then turned over to Morales's attorney, Steven Chaykin, who in turn gave them to investigators on March 20, 2002, as a response to the subpoena to One Stop Enterprises. Investigators were able to find discrepancies with purported transactions involving such companies as Jensen's Liquors, A Corporate Impression, The Voice Publishing, Caballero Flowers, La Covacha, and Gus Exposito, the former chairman of the Country Club of Miami Community Council and a principal in a roofing business who also owns several car washes. Exposito has prior convictions for possessing counterfeit money and mail fraud.

AGUSTIN "GUS" EXPOSITOA review of the records provided by One Stop Enterprises revealed a handwritten invoice that appeared to have been written by Gus Exposito. The invoice states that Exposito had been reimbursed $3000 by Elba Morales for distribution of flyers for the Miriam Alonso anti-recall effort in November 1999. Elba Morales stated that in February or March 2002, after the subpoena had been issued to One Stop Enterprises and Elba Morales and Leonel and Miriam Alonso were engaged in an active effort to obtain receipts to attempt to make all of the illegitimate expenditures appear as if they were legitimate, Leonel Alonso suggested that Gus Exposito could be asked to justify such an expense.

Elba Morales told your affiants that Mr. Alonso advised her that she should ask Mr. Exposito for a bogus $3000 receipt that would help justify some of the checks issued from the "Neighbors of District 12" account. Elba Morales stated that Leonel Alonso believed that this was a believable amount for work that could have actually been performed by Exposito. Mr. Exposito, when initially questioned under oath in this investigation, stated that he had in fact performed services and incurred expenses in connection with the purported anti-recall campaign that were reimbursed to him by the $3000 check. He later recanted this testimony, and has become a cooperating witness.

Mr. Exposito stated that Miriam or Leonel Alonso contacted him and asked him to stop by their residence. When Mr. Exposito arrived at the Alonso residence, he was met by Leonel Alonso and Elba Morales. The three had a brief conversation at the garage area of the residence before Elba Morales asked to speak to him in his vehicle. When he and Ms. Morales entered his truck, Ms. Morales advised Mr. Exposito that some receipts were missing. She further advised Mr. Exposito that receipts were needed to account for printing and other work done on the anti-recall effort, and she asked him for such receipts. Mr. Exposito agreed to do this and advised that he would attempt to obtain printing receipts. Approximately two days later, Elba Morales contacted Mr. Exposito and asked him to stop by Miriam Alonso's district office, where she asked him to write out the receipt for reimbursement of the $3000. Mr. Exposito stated that he wrote out the receipt and handed it over to Elba Morales. Ms. Morales provided the receipt to Attorney Steve Chaykin, who handed it over to investigators in response to the subpoena to One Stop Enterprises.

When Mr. Exposito was subpoenaed to provide testimony regarding the receipt, he advised Elba Morales that he was subpoenaed, and she requested that he meet with her at Miriam Alonso's district office. Leonel Alonso and Elba Morales both met with Mr. Exposito outside of the district office, expressing fear that the office had been "bugged" and their conversations were being monitored by police. During their conversation with Mr. Exposito, Elba Morales and Leonel Alonso both advised Mr. Exposito to tell investigators that the information he had written on the receipt was correct and was indeed a reimbursement for monies he had expended on the anti-recall effort. Mr. Exposito stated that Leonel Alonso advised him to "stick to his guns" and not change his story. On the day that Mr. Exposito provided false sworn testimony at the State Attorney's Office, he responded to Miriam Alonso's district office thereafter. He again spoke to Elba Morales and Leonel Alonso, who questioned him regarding his testimony. Mr. Alonso stated that he was pleased with what Exposito had done. Mr. Alonso called Exposito a "true friend," and embraced him. The events described above by Exposito were corroborated by Elba Morales.

Mr. Exposito stated that sometime in late July 2002, Miriam Alonso contacted him at his cellular telephone and asked him to go by the Alonso residence, because she and Leonel wished to speak to him. When Exposito arrived at Miriam and Leonel Alonso's residence, he was advised by the Alonsos that they wished to speak to him at a different location. They asked him to accompany them to a friend's residence nearby. Leonel Alonso then drove Mr. Exposito and Miriam Alonso to this residence, where they briefly met with the owner. The owner of the residence then walked up to the second floor and left Mr. Exposito alone with Miriam and Leonel Alonso in the living room area. Leonel Alonso then proceeded to advise Mr. Exposito that Elba Morales was now cooperating with the police. Leonel Alonso told Mr. Exposito that he should consider Elba Morales's lifestyle, and Miriam and Leonel Alonso stated that Ms. Morales had been stealing from them.

1. Organized Scheme to Defraud ($50,000 or more), F.S. 817.034(4)(a) 1D Felony

2. Grand Theft (between $20,000 and $100,000), F.S. 812.014(2)(b) 2D Felony

3. Tampering With or Fabricating Physical Evidence, F.S. 918.13(b) 3D Felony

4. Conspiracy to Tamper With or Fabricate Physical Evidence, F.S. 777.04(3) 1D Misdemeanor

5. Solicitation to Commit Perjury in Official Proceedings, F.S. 777.04(2) 1D Misdemeanor

6. Exploitation of Official Position, Dade County Code Section 2-11.1(g) 2D Misdemeanor (Miriam Alonso only)

Detective Antonio Rodriguez, Co-affiant

Special Agent John Kennedy, Co-affiant