The Lepley Letter – “others engaged in similar conduct of his client” – Exhibit D

EDITOR’S NOTE: Juvenile male victim #1 – is black, juvenile male suspect #1 – is white.

PICKING UP WHERE EXHIBIT C LEFT OFF.

The affiant also observed a copy of a letter that was provided by the Williamsport School District. On 5/31/2018, a letter from Attorney Lepley was sent to Principal Pardoe and Athletic Director Shawn McCann. It said: “Re: Misconduct Myrtle Beach”.

It also said: “I have been contacted by (redacted), parents of (redacted). The rest of the large paragraph was redacted. The last paragraph read: :It is my understanding you wish to have a meeting with (redacted) and his parents. Please note I will be present at that meeting and therefore would kindly appreciate notice of same.” The letter was signed by George Lepley.

On 9/3/2020, the affiant served a search warrant on the office for the Williamsport Area School District.

The affiant obtained a copy of the above letter without any redactions.

After reviewing this letter,

the affiant learned that Attorney George Lepley acknowledged he represented the juvenile male suspect #1.

 

Also, Attorney Lepley wrote on 5/31/2018:

“A substantial number of players engaged in the exact same conduct…” as his client.

The school district knew this on 5/31/2018,

and still chose not to notify the Myrtle Beach Police.

 

Lepley described potential criminal charges, and describes his client’s actions as:

“Inappropriate.”

 

Lepley also identified his client in the video.

Lepley threatened the school district if his client was prosecuted;

he threatened criminal prosecution of

the others engaged in similar conduct of his client;

and he threatened civil action with deposing “any and all witnesses”.

 

Lepley concluded:

“Our ultimate goal is to make sure

that one person is not singled out for conduct committed

by a substantial number of team members.”

 

The affiant also observed that, on 6/1/2018 at 0453 hours, an email from Pardoe was sent to Bowers. It read, “Also, a meeting has been arranged with the (redacted) family for June 5, 2018 at 2 PM and their attorney.”

The email continued: “Fred (EDITORS’ NOTE: “Fred” is Fred Holland, WASD Solicitor) will be attending. I plan to contact family today to inform them that their son is (redacted) until the investigation is complete. I am also going to follow up with the student, (redacted) (student who took video) today and parent to inform them that he will be in the same status.”

The email continued: “I had a conversation with the mother of (long redaction). I know that Fred has spoken George regarding the matter. In addition, Agent Weber contacted me yesterday to let me know that he as well has spoken to George Lepley about the incident.

It is my understanding that both these conversations went well.”

 

The affiant has probable cause to believe that a

criminal offense that was sexual in nature may have occurred

in Myrtle Beach, SC

involving juvenile suspects and victims.

 

The affiant also has probable cause to believe  that this incident came to the attention

of then Chief County Detective William Weber of the Lycoming County District Attorney’s Office

and the Principal of the Williamsport Area High School, Brandon Pardoe.

 

The affiant is investigating the alleged conspiracy between Weber and Pardoe to violate

PA Title 18, Section 51501:  Obstructing Administration of law or Other Governmental Functions.

This is evident by Weber not completing any reports on the “investigation” until being requested to by the Myrtle Beach Police, and by Weber not notifying the proper law enforcement authority with jurisdiction, as well as Weber lying to and Assistant District Attorney about his knowledge of any investigation.

There is also evidence that Weber had ties to the Williamsport High School baseball team.

Pardoe’s participation is evident by statements made by Pardoe to the juvenile male videographer’s mother. There is also evidence that a relative of Pardoe’s may have participated in the alleged assault.

There is also evidence that Weber, Pardoe, and Attorney George Lepley, who represented juvenile male suspect #1, communicated with each other and participated in this investigation early on.

There is also evidence that Pardoe communicated with

School District Superintendent, Dr. Timothy Bowers.

 

There is also evidence that Pardoe and Weber communicated with each other. There is also evidence that the Williamsport Area High School and School District conducted an investigation in to the above matter and never notified the Myrtle Beach Police, the law enforcement entity with jurisdiction.

The evidence indicates that Weber and Pardoe conducted at least one interview together an notes were taken. Weber, in his letter to Detective Porter of the Myrtle Beach Police, also indicated that the school district did interviews during their own investigation.

It is also alleged in the evidence that,

“Kids were aware in Myrtle Beach…

Brandon told kids to get rid of images…

Coach Miller aware of it…”

This suggests school district employees

knew of the incident shortly after it happened in 3/2018,

and they were not first notified towards the end of May 2018

by CYS via Weber.

The other violation being investigated is

PA Title 18, Section 6312(d): Sexual Abuse of Children.

There is probable cause to believe that a video was made of one juvenile male putting his penis into the face of another juvenile male, or a simulation of same; and there is probable cause to believe that this video was shared.

The affiant wishes to retrieve said video from the aforementioned School District’s files, as well as any other videos which pertain to this investigation, if they were possessed by the Williamsport Area School District as part of their “investigation”.

This concludes the Affidavit of Probable Cause seeking a search warrant for the “Files/Records Pertaining to the 2018 WAHS Baseball team Myrtle Beach Trip” (including cell phone records) of WAHS head principal Dr. Brandon Pardoe filed on September 24, 2020 by (NAME REDACTED BY AUTHOR) and signed by Lycoming County President Judge Nancy Butts.

This is a developing story on TalkWilliamsport.com.