c. The Notebook contained several handwritten pages that express hostility towards the health insurance industry and wealthy executives in particular. For example, the Notebook contained the following statements in entries that appear to correspond to particular dates:
i. In an entry marked as “8/15” [August 15, 2024], the Notebook described how “the details are finally coming together” and “I’m glad – in a way – that I’ve procrastinated, bc [because] it allowed me to learn more about [acronym for Company-1].” The Notebook entry also stated that “the target is insurance” because “it checks every box.”
ii. In an entry marked as “10/22” [October 22, 2024], the Notebook stated: “1.5 months. This investor conference is a true windfall . . . and – most importantly – the message becomes self evident.” Later on in the entry, the Notebook describes an intent to “wack” the CEO of one of the insurance companies at its investor conference. As described above, October 22, 2024 was approximately 6 weeks before the date of the murder of the Victim, which occurred on the date of Company-1’s investor conference.
d. The Feds Letter recovered from MANGIONE stated: “I wasn’t working with anyone. This was fairly trivial: Some elementary social engineering, basic CAD, a lot of patience.” Based on my own research, I believe that “CAD” refers to “computer-aided design.” The Feds Letter also stated: “P.S. you can check serial numbers to verify this is all self-funded. My own ATM withdrawals.”
9. Based on all of the above, my review of photographs of the Shooter, and my review of arrest photographs of LUIGI NICHOLAS MANGIONE, the defendant, I respectfully submit that MANGIONE is the Shooter who shot and killed the Victim on December 4, 2024. Additionally, the Notebook entries, the Feds Letter, the Shooter’s apparent surveillance of the Midtown Hotel on November 24, 2024 and December 4, 2024, and the Shooter’s use of countersurveillance techniques and escape from New York City all suggest that the Shooter undertook extensive efforts to identify the Victim, place the Victim under surveillance, and track the Victim’s whereabouts in the time period leading up to the murder. Below are surveillance stills of the Shooter and an arrest photograph of MANGIONE:
(On left: arrest photograph of MANGIONE. On right: the Shooter at the Hostel.)
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