Patterson

FACTS

I. Facts Adduced at Defendant’s Criminal Trial

In the days before April 28, 2011, Leonard Vivian (Leonard) showed his friend Michelle Toner (Toner) a backpack full of cash and silver coins. Toner did not know how Leonard had come by the cash. On April 28, 2011, Leonard asked his mother, Mary, to take him to rent a storage unit. Leonard did not have his identification, so Mary rented a unit for him at Derrel’s Mini Storage. Mary drove Leonard to the specific unit they had rented. Leonard exited the car and took a backpack with him to the storage unit. Leonard also put a safe into the storage unit. Mary could tell Leonard was “stressed over something,” but she “didn’t want to know what was going on” and stayed in the car. Later that same day, Mary drove Leonard to a Quality Inn. Mary rented a room for Leonard since he did not have identification. She came out to tell Leonard the price of a room and saw him speaking with a male and a female in a red car. Leonard paid for the room with cash. Leonard went to the room Mary had rented. At some point, he came out of the room and spoke to his friend, Toner, who was there with her then-boyfriend, Dustin

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