From the Palfrey trial transcripts: April 7th, 2008 excerpt

Ed.--This excerpt comes from the opening day of the trial of Deborah Jeane Palfrey. The witness for the government being questioned is Mark Hines, beginning at the bottom of page 12 and ending on the bottom of page 20. Palfrey always contended to me and others on the defense team that she thought the investigation into her began around May/June of 2004 in the Baltimore IRS office, apparently brought to their attention by USPS investigators.

I'm unaware of the entire extent of discovery materials she was given by the prosecution, but basically rang true at the time, and in a way it still does. Except for one thing. The real inquiry into the "DC Madam" began in August, 2001. Until reading the trial transcript, I was completely unaware of this fact, partly because press coverage of the trial was almost non-existent, and what little there was lacked any substance or detail.

Eventually, either I, the government, or someone else will post it online in toto, and the public can finally judge for themselves how fair her trial proceedings were, and all of the roads the government didn't go down.

For example: why couldn't they have gotten her for underreporting her income? A source informs me that this would have been the easiest of charges to prosecute.

Why didn't they do it? I have my suspicions, and it includes Palfrey and the government both lying about how much money she earned, and that she hid a lot of it. My guess is that they're either still investigating to find it, or they've already located most of it. She made a lot more money than anyone's reporting. The text has been broken-up for easier reading. Page breaks are noted. It appears that the investigation into Palfrey actually did originate in Washington D.C. and not in Baltimore, but in Linthicum, Maryland as Palfrey and author Bill Keisling once contended...

... "DIRECT EXAMINATION

22 BY MS. BUTLER [Ed.--Nice typo, Butler is a "Mr."]:

23 Q Good afternoon.

24 A Good afternoon.

25 Q State your full name and spell your last name, please. [Page Break]

13

1 A My name is Mark Hines. Last name is spelled H-i-n-e-s.

2 Q Mr. Hines, where do you work?

3 A I'm employed as a Assistant Special Agent in Charge with
4 the Postal Service Office of Inspector General.

5 Q And just briefly, what does the Inspector General's
6 office do?

7 A The Postal Service AIG is the internal law enforcement
8 arm of the postal service, and we investigate fraud, waste,
9 and abuse within the postal system and also employment conduct
10 issues.

11 Q And how long have you been with that office?

12 A I started work with them in 2005.

13 Q Okay. Where were you before that?

14 A Prior to that I was employed as a U.S. Postal Inspector
15 in New Orleans, Louisiana.

16 Q Okay. And how long were you there?

17 A I was there from 2003 to 2005.

18 Q Okay. And before that, where were you?

19 A I was employed as a postal inspector in the Washington
20 Division, the Washington Metro area.

21 Q And how long were you there?

22 A I was employed as a postal inspector in Washington
23 between 1994 and 2003.

24 Q Okay. And just briefly, describe what the Postal
25 Inspection Service does. [Page Break]

14

1 A Postal Inspection Service is the external law enforcement
2 branch of the postal service. They investigate violations of
3 postal law and external attacks on the postal system.
4 Examples of that would be robbery of a post-office,
5 a burglary of a post-office, dangerous mailings or illicit
6 mailings going through the postal system and mail fraud.

7 Q Okay. In about 2000, what was your assignment within the
8 Postal Inspection Service at that time?

9 A In 2000, I was assigned to the Prohibited Mailings Team.
10 That was a team that investigated illicit items and contraband
11 being mailed through the postal system.

12 Q Okay. And was there a specific place or location where
13 you were -- primarily would do that?

14 A Yes, sir. I was assigned -- my last duty station was the
15 incoming mail facility at BWI Airport.

16 Q Baltimore/Washington International Airport?

17 A Yes, sir.

18 Q Okay. And what was your -- what was your assignment at
19 that time? What was your job description?

20 A It had two functions. One function was to profile
21 express mail system for illicit mailings containing
22 contraband; that would be narcotics and also illicit funds.

23 Q Okay. And you said two functions.

24 A Yes, sir.

25 Q What's the second function? [Page Break]

15

1 A The other function was to investigate violations
2 involving postal money orders.

3 Q Okay. Now, let's sort of make sure everyone's operating
4 from the same place in terms of knowledge. Express mail, what
5 is that, just briefly?

6 A Express mail is the service provided by the U.S. Postal
7 Service, an overnight delivery service. You can go to the
8 counter at a post-office, pay a larger fee than you would
9 normally, to mail a first-class envelope, and then that item
10 has a control number assigned to it and it's delivered in a --
11 in an expedited fashion, overnight typically.
12 The other aspect of express mail is that you can
13 track its process through the postal system by the use of that
14 assigned control number.

15 Q And you mentioned money orders. What -- just, again,
16 just briefly, what is a money order?

17 A Postal service money order is a financial instrument
18 that's available to postal customers. You can go into a
19 post-office and with currency purchase a negotiable instrument
20 similar to a check or a money order you might get at a
21 7-Eleven or another outlet.
22 In turn, that document, you can convey to somebody
23 else and it can be cashed at a post-office or it can be
24 deposited like a check at a bank.

25 Q And a money order, does it show who purchased the money [Page Break]

16

1 order on the face of the document?

2 A There is a portion on the face of the document for the
3 person remitting it to write the purchaser of the money order
4 and the sender of the money order, although it's not always
5 completed.

6 Q Okay. And in your assignment at BWI, what were you
7 looking for in terms of express mail labeling and in terms of
8 money orders?

9 A During the course of my assignment, we would look for
10 patterns of suspicious mailing activity; we would look at that
11 through the paperwork which would be the express mail labels
12 from these postal mailings. We would also look at live mail
13 that would go out to the postal service facility, the
14 processed incoming express mail for the D.C. Metro area and
15 also outbound express mail coming from the D.C. Metro area,
16 again, for suspicious mailings.

17 Q What were you looking for? What, in particular, were you
18 looking for? What were you trying to find?

19 A In particular, what we were looking for was in the
20 mornings, we were looking for inbound mailings that typically
21 contained drugs, illegal controlled substances, and then in
22 the evening, at the outbound mail, outbound express mail, we
23 were looking for illicit funds, currency, and also postal
24 money orders and other negotiable instruments.

25 Q And did there come a time when you focused on a business [Page Break]

17

1 called Pamela Martin & Associates?

2 A We did, yes, sir.

3 Q And how did that come about?

4 A In August of 2001 [Ed--My emphasis.], I had been profiling for outbound
5 express mailings and came across an express mail piece going
6 to Venetia, California, which had also come to my attention
7 during our review of Postal Service Express Mail labels.

8 Q Okay. And based on that, what did you do?

9 A With that particular piece, I tried to investigate what I
10 could about the sender, the recipient, and the goal was to
11 obtain a federal search warrant to open the mail piece and
12 determine whether contraband, in other words, illicit funds
13 were within that mail piece.

14 Q Did you have sufficient information at that time to
15 obtain a warrant for that piece of information?

16 A I had sufficient information to seek one.

17 Q Okay. Did you actually obtain one, though, at that time?

18 A I did not.

19 Q Okay. So what did you do with that package then?

20 A The package was returned to the mail stream for delivery.

21 Q And did you follow up on that at all?

22 A I did. That mail piece and the information that I found
23 out, which I attempted to get a search warrant on the basis
24 of, developed further through a longer term investigation and
25 became the first mail piece of a series of suspicious [Page Break]

18

1 mailings.

2 Q Okay. And did you look at patterns or other -- you say
3 other mailings. What did you do to look at other mailings
4 that were going to that post-office box? What did you do?

5 A There were a couple of initial investigative steps. We
6 reviewed the mailing history for express mailings going to
7 this particular address in Venetia, which was P.O. Box 1211 in
8 Venetia, 94510 is the ZIP code, Venetia, California.
9 Over an extended period of time, we developed about
10 247 mailings emanating from the Washington Metro area going to
11 this P.O. box.
12 We also did a mail cover tracking to --

13 Q Describe -- before you go too far, what is a mail cover?

14 A Mail cover is an investigative tool available to law
15 enforcement where law enforcement is authorized to review
16 incoming mail, the face of incoming mail going to a given
17 delivery address based on a criminal investigation. So, for a
18 period of 30 days or 60 days, we can review who is sending
19 mail to a given subject of an investigation.

20 Q And as part of that, what information did you develop
21 through that mail cover?

22 A What it developed was that the box holder of P.O. Box
23 1211 in Venetia was a Deborah Jeane Palfrey and that this
24 individual was associated with an out-call escort service
25 named Pamela Martin & Associates. [Page Break]

19

1 Mail directed to that P.O. box came in the name of
2 Deborah Jeane Palfrey, Pamela Martin, Pamela Martin &
3 Associates and combinations thereof. The mail cover that we
4 did illustrated a quantity of express mailings similar to the
5 ones that we had already tracked through our historical
6 documents, and those documents and the mail cover results
7 indicated that about 25 female senders were mailing express
8 mails and the grand total was 247 of them to this P.O. box in
9 Venetia.

10 Q And for what period of time are you talking about?

11 A The records that I reviewed were between the year 2000
12 and 2002.

13 Q Okay. And did you take steps in the local area to
14 determine if you could identify the women who were sending
15 those documents to Venetia, California?

16 A Yes, I did.

17 Q What steps did you take?

18 A We used address checks checking through the postal system
19 to see who receives mail at a given address; in this case, the
20 return address on the mailings. We have also used Department
21 of Motor Vehicle checks and Auto Track, which is a
22 commercially available address check system to try to identify
23 the mailers such as they appeared on the return address
24 portion of these express mails.

25 Q Okay. Were you able to identify any individuals who were [Page Break]

20

1 actually sending documents to Venetia, California?

2 A Yeah, approximately 25 of them.

3 Q Okay. And did you identify specifically by name any
4 individuals? Without giving their names, were you able to --
5 not just get the names of the persons but to identify -- to
6 figure out who they were, where they lived, that type of
7 thing?

8 A Yes, we were able to figure out many aspects of their
9 background.

10 Q Okay. And did you take steps at the post-offices
11 themselves to see if you could track those individuals'
12 actions relative to sending those express mail packages?

13 A Yeah. During the course of the investigation, I dealt
14 with many different postal employees, from window clerks who
15 sold the express mail service, to delivery employees who
16 delivered the express mailing in California and other
17 locations, and those individuals did provide me with
18 information.

19 Q And did you also take steps on the California end of
20 things to see if you could identify further who Deborah
21 Palfrey was and that type of thing?

22 A Yes, I did. The steps on the California end were to
23 determine whether or not, first of all, Ms. Palfrey held this
24 P.O. box, and in review of our postal records is each P.O. box
25 is a P.O. box application, a Form 1093." ...

Intelwire.com publishes U.S. Postal Service files of DC Madam's early-1990s bust

WWW--Freelance reporter J.M. Berger's site--Intelwire.com--is a treasure trove of declassified and primary documentation of the war on terror and American involvement in global politics. On July 8th, he posted around 40 pages from the early-1990s federal investigation into Deborah Jeane Palfrey and her first escort service, which also included the use by the late madam of money orders, credit cards, and a generally criminal misuse of the postal system.

The documents are included with commentary from Mr. Berger, who has written and researched for the National Geographic Channel, NPR, and numerous other media outlets. His work looks pretty sound and unbiased, and the site is a good place to start for researchers looking into far-ranging topics as 9/11, the Oklahoma City bombing, FBI misconduct, our intelligence community and their links with known international terrorists, government informants running amok and committing profoundly violent crimes--and that's just for starters.

My own question is: why post it on a site dedicated to "the War on Terror, domestic and international extremism, and Middle Eastern politics"?

http://intelwire.egoplex.com/2008_07_08_blogarchive.html#2187829177917801058

Michael Mukasey - Will You Help Me?, by Deborah Jeane Palfrey

Michael Mukasey – will you help me?

The dubbed D.C. Madam Deborah J. Palfrey seeks fairness in a sea of injustice.

55 years imprisonment and my entire life’s savings – this is what they want to take from me, in my real life ‘David and Goliath’ struggle with the United States Department of Justice.

For the past year, I have discovered myself immersed in the world of the Justice Department; a world, replete with on-the-record faulty memories, omissions of fact and out-and-out lies; one where political motive and groupthink usurp integrity and the rule of law and where as hard as one might try, justice is nowhere to be found. This is the setting I have been placed in to do battle with a bureaucratic behemoth.

As I fight for my very life ostensibly on a daily basis, I have experienced a legal and financial pounding– a premeditative orchestration created to best the most resolute among us, by the Department of Justice or the Department of Injustice, as it more widely regarded these days.

On October 4^th of last year, a dozen plus federal agents descended upon my sedate, restored Victorian home in Northern California armed with a search warrant and arrested - of all things - my property (my turn came later in March). The process known as civil asset forfeiture allows the government to seize a person’s property and assets, without due process often leaving them destitute, when there is suspicion – not actual proof, but merely a suggestion of wrong doing.

In my case, the Federales claimed I had proffered the unthinkable – pleasures of the flesh - for financial gain, to the male denizens and visitors in our nation’s capitol. Accordingly, I found myself – besides instantaneously broke - charged with over-the-top and obscene federal crimes. My job description was elevated exponentially from retired escort service operator to the powerful, to money launderer and conspirator over night and later to racketeer.

What particularly made and continues to make my case so unusual, actually bizarre is no one ever has been charged similarly to me, in the metropolitan Washington, D.C. area. Over time, I have come to understand my case is truly one of a kind. Considering there are more adult service businesses than McDonald’s restaurants in operation in the overall vicinity, a virtual array of rich targets for the Feds to pursue – I and I alone appear to be the only subject of their interest. Furthermore, none of the estimated 10,000 or so clients, who patronized my agency or the almost 150 subcontracted women, who worked for me over the years have been charged.

The question begs. Why me and why only me? In part, the answer may lie in the fact I operated a high-end, erotic outcall service continuously (a bit of an anomaly) for a thirteen year period, from 1993 through 2006, in a part of the world laden with politically influential men; many with high level security clearances. Although, my firm routinely was patronized by the typical, garden-variety doctor, lawyer and perchance even, Indian chief; it nonetheless saw more than its share of the high and the mighty.

As flattering as it might be – albeit in a rather perverse way – for me to think I was ever the real object of the DOJ’s attention, it would be sheer folly to believe such. The clientele base, specifically the more notable customers were the true persons of interest and the reason I believe I was surveilled personally and professionally, for at least a five year period, before I decided to close shop and retire to Europe, in August of 2006. Ironically, it was this very decision to shut down the business and disrupt the status quo, in conjunction with my desire to move out of the country, which I feel ignited the raid on my home, in early October.

The combination of selective prosecution, a politically sensitive clientele and an extended surveillance period points to a matter, which has less to do with the goings-on of an alleged prostitution ring than it does with spying activities involving a constitutionally protected, American citizen. As I often have stated, my case has something to do with something, but it sure as heck has very little, if anything to do with a small-time escort business. My case - had it been more customary in nature - would have been under the sole purview of the state courts and never entered the federal realm.

But then the culture at the Justice Department, under former Attorney General Alberto Gonzales has been revealed – particularly of late with the suspect attorney firings - as one more concerned with the inclinations of the White House, i.e. the GOP than with those of truthfulness and fair dealing toward a society at large; a society, which most assuredly includes me and my idiosyncratic case. The founding fathers desire for a wide divide to exist between the Executive Branch of government and the Judiciary appears to have been profanely abused by former AG Gonzales and his cohorts outside Justice.

I rather suspect that as time marches on, with it will come a multitude of eye-opening disclosures, which will call into question further the practices of the DOJ, the past several years. I believe my case is part and parcel of any such coming revelations. That is of course, if the newly appointed Attorney General – be it Bush nominee, Judge Michael Mukasey or another – chooses to do right by us, the American people; to ally with us and not the current administration. For me in my politically charged case, such a decision by the future Attorney General holds particular weight; quite possibly, whether or not I will spend the remainder of my natural life behind bars or as a free person.

Nonetheless as I begin my second year combating the beast, I do so with significant hope. After a full twelve months of being stonewalled at every twist and turn along the way, including access to discovery materials, by the assigned Assistant U.S. Attorneys - my counsel, Mr. Montgomery B. Sibley, a small band of interested third parties and I have pieced together sufficient reason to believe my case - simply put - is rotten to the core. Since the Government for all intents and purposes has run out of tactical maneuvers to prohibit me from uncovering the truth any longer, I anticipate exposure of considerable wrongdoing by the DOJ, in short order. Additionally, the fact Alberto Gonzales, perhaps one of the most dishonest and politically aligned attorney generals in U.S. history, the very one who has reigned over my specific case this last year has resigned – leaves open the hope that his predecessor may correct the direction of a wayward and seemingly corrupt Justice Department and in its wake my increasingly frightening tale of woe.

However, time will tell. In the interim, I only can remain determined and trust in the final analysis, I indeed will find justice in this dark and terrifying sea of injustice I have been thrust.

[Ed., 08.28.2008--Why she felt a shill and an apparatchiki like Mukasey would help her is beyond my ken.]

Some Reflections on Judge Kessler's Ruling, Ending Prosecution's Injunction in "DC Madam" Case

Washinton D.C.--The ruling is an interesting read, albeit rife with legalisms that would make anyone outside of the legal profession's head spin. But it's fairly to-the-point: the temporary injunction barring Deborah Jeane Palfrey from distributing copies of her phone records to investigative journalists, bloggers, citizen journalists, and those like myself who do a mix of news analysis, opinion, & investigative journalism, has begun.

Ms. Palfrey is going to tell her story, and nobody is going to stop it; whatever the truth is, some of it is going to begin leaking-out in the intervening months. As Palfrey has stated in a recent newsletter:

Deciphering the voluminous amount of data – some of which is well over a decade old – will not be an easy task. Frankly, this likely is understating matters. It will take a small army of people skilled in computer and phone technology, investigation as well as factual knowledge regarding the significance OR non-significance of identified persons. No one individual or entity will be able to connect all of the dots. The overall endeavor easily could take many months, if not years to research and report conscientiously. [Ed., 09.01.2008--From a Palfrey Defense newsletter.]

Indeed, this is going to be a very arduous task, but a worthy one. The public trust has been violated again-and-again under this administration, and it's time to get to the bottom of things. If Congress intervened to accelerate the process--even better. In 46 lbs. of phone records, it's statistically inevitable that there are at least a dozen more prominent individuals still holding public office in them. We already know this from early-results, and ABC's producers told Palfrey of other names--names they would not make public. A very Special thanks go to Maria Cuvillion (phonetic) and Joe Clark, the postal inspectors who walked-past the phone records several times in their search of Ms. Palfrey's home. You missed the most important evidence in the case--the evidence that could exonerate Ms. Palfrey, and maybe cage some of you abusers of our federal bureaucracy.

Why they sent you, and not the FBI is hard to understand, Joe and Maria, but it worked-out OK for everyone. At the Justice Department, they have even bigger-problems besides the U.S. Attorney firings scandal--Assistant U.S. Attorneys William R. Cowden, Catherine K. Connelly, Daniel Butler, and their interim appointed boss Jeffrey A. Taylor are in for quite a ride. Judge Kessler was paying attention during the hearings:

At oral argument, the Government was asked whether the List contained the telephone numbers of unindicted co-conspirators. After a significant silence, Government counsel agreed that the answer to the Court's question was "yes." One cannot help wondering why the Government has exhibited such a strong interest in protecting a list containing the telephone numbers of unindicted co-conspirators, i.e., the women who the Government alleges provided the illegal sexual services and the men who the Government alleges sought and obtained such illegal sexual services. (US vs Palfrey, July 5th, 2007 'Memorandum Order,' pg. 7)

In short, there's no good legal reason to let the temporary injunctions on release of the phone records stand. "Unindicted co-conspirators" don't get to hide behind legalisms trotted-out by the federal prosecution, and the five "confidential informants" (really "co-operating witnesses," which fits the Government's contentions more accurately) are going to be unmasked for the purposes of the defense.

This doesn't bode well for the Government's case at all. That observation of a prolonged silence in the above quotation is Judge Kessler noting her doubts in the Government's contention over the injunctions. This was just one of a number of reasons and observations given by Federal District Judge Kessler, but the observation is perhaps her way of hinting she's not buying all of the prosecution's story.

This saga of the injunctions began in mid-March, with a lot of peculiar legal maneuvering by the prosecution. The phone records themselves have been defined and redefined a number of times, which is also peculiar and resembles obstructionism. To be sure, that's the case regarding the 46 lbs. of Pamela Martin & Associates phone records that range from 1993-2006.

If there are "unindicted co-conspirators" within the records, they should be revealed, correct? We have to know if Ms. Palfrey's accusers are impeachable, otherwise there's no real discovery or due process. To only indict Ms. Palfrey and nobody else would appear strange to just about any sitting judge. You can only be so credulous for so long.

The floodgates have been opened, but it's going to take a good deal of careful research on-the-part of investigative journalists and researchers. What's most important, however, is the beginning of carefully released primary documents that are essential in understanding such a twisted example of our Justice system run amok. Now--hopefully--it's time to understand how far it has gone outside-the-bounds of the rule of law (if it has, but there is smoke). Never mind Scooter Libby, this could be it. Patience is a virtue.

"HOOKERGATE," CONFIDENTIAL INFORMANTS, AND "THE KIDS"

VALLEJO, CALIFORNIA/WASHINGTON D.C.--In an earlier article, this writer mentioned two names in the headline--Joe Clark and Maria Couvillon (phonetic). According to Ms. Deborah Jeane Palfrey and her civil attorney Blair Sibley, these are the two postal investigators who called Palfrey's realtor at 2pm for access to her home.

At this time, they had no warrant, and secured one later that day in Sacramento from a lowly magistrate. Clark and Couvillon obtained their warrant, but with what information? Read on. Did they accuse Ms. Palfrey of links to Al-Qaida? Apparently not, since she's not at Guantanamo Bay prison. Ms. Palfrey has informed me that Couvillon, Clark, and IRS agent Troy Burrus--not the UK pop star--are all in their late-twenties. How is this important? Further investigation could tell us, and about a whole lot more.
USPS couldn't confirm on the two from postal investigations, but Palfrey asserts that all were in this age-range (she calls them, "the kids"). Why would this matter? It could have something to do with the current "war on terror," and hiring and appointment-practices under the Bush administration. How did Monica Goodling get her job? She was appointed, she is 33, and she attended Pat Robertson University for her law degree (take that, Harvard!). Can the same be said for Clark and Burrus? According to Palfrey's civil attorney (Sibley), Couvillon has no substantial educational background that would qualify her as a postal investigator. Importantly: why was Couvillon present with IRS agent Troy Burrus on a visit to Palfrey's mother in Florida about a week ago? More on this aspect later. If any readers have information pertaining to the educational background of government agents covering this case, it would be greatly appreciated.

Mr. Clark left his home phone number with Ms. Palfrey's realtor--want it? Mainstream media and many so-called "liberal" blogs don't appear interested in this story anymore. They should know that there were "screaming matches" at ABC over whether to run the full-story or not. Brian Ross wanted to do full-disclosure, but his Executive producers quashed the segment. Many things ended-up "on the cutting-room floor," asserts Palfrey. Considering the run-up to the show, this is not hard to believe.

A call to the USPS's PIO (Public Information Office) has so far yielded no new answers, and many of the unanswered questions cannot simply be due to investigative procedures. There could be some stonewalling. I'm still waiting, but was told that the release of how long both agents were with the USPS as investigators was likely. J-7 readers will be the first to know. Author William Keisling has informed me that Sunday's Sopranos finale had a line referencing a prostitution and bribery scandal. Jeane was excited to watch the show that night, and it must have been a stunner, she's a big fan of the show (hey, who isn't?). One can grant that it's entirely legitimate to withhold certain facts in an investigation (there are legitimate concerns not to expose procedure), but shouldn't Ms. Palfrey and her civil attorney know who authorized the trip of Ms. Couvillon and Mr. Clark? Was it the grand jury? Shouldn't we all know by now?

If the investigation into her lasted over two years, why is it still ongoing after nine months after its disclosure? It gives the appearance that this--as Ms. Palfrey so aptly put it--is a "loser" case run by incompetents, and that there is a lot of scrambling going on in various bureaus. Why isn't she being given due process? Was there ever really an investigation at all? These are worthy questions, and the prosecution and investigators won't answer them. We could have a case of gross incompetence here, and that's just-for-starters. But it's even worse: there was use of informants. "[There were] five girls that they questioned in December of 2005, and questioned them--believe me, very leading questions. This is the information that they used for the search warrant...The girls who were interviewed in December of 2005 were girls who worked for me in 2000, 2001, 2002, and 2003. That's why the information was at least 3-1/2-to-5-years-old....[from] these five "confidential informants," states Palfrey.

She goes on to detail what she's been shown of these "affidavits," most statements totaling "a couple of paragraphs, tops." This sounds all-too-familiar. The affidavits sound consistent with the strategy of the press: don't name any names of clients, especially if they're prominent.

For other primary documents:
www.deborahjeanepalfrey.com/html.legal