OFFICE OF THE FEDERAL PUBLIC DEFENDER

NORTHERN DISTRICT OF NEW YORK

Albany Office
39 NORTH PEARL ST.
5 FLOOR
ALBANY, NY 12207
(518) 436-1850
(518) 436-1780 FAX

Syracuse Office
4 CLINTON SQUARE
3 FLOOR
SYRACUSE, NY 13202
(315) 701-0080
(315) 701-0081 FAX
Lisa Peebles
federal Public Defender

RESPOND TO SYRACUSE
OFFICE

September 2, 2015

VIA FAX

376-1656

Hon. Daniel King

Acting Oswego County Court Judge

Lewis County Courthouse
7660 State Street
Lowville, NY 13367

RE:

PEOPLE V. GARY THIBODEAU

INDICTMENT NUMBER 94-161

Dear Judge King:

I am writing to respectfully request permission to call Melissa Searles, a cousin of Heidi
Allen, as a witness to testify about a bracelet she gave Allen prior to her abduction which
eventually wound up in her mailbox 10 years after Allen was kidnapped. Although Ms. Searles
met with defense counsel on several occasions and provided these details to defense counsel, she
is a reluctant witness and would require a subpoena to testify. Enclosed is a detailed affidavit
executed by defense counsel setting forth the anticipated testimony of Searles.
Please let me know if you have any questions.
Respectfully submitted,
OFFICE OF THE FEDERAL PUBLIC DEFENDER

By:

Lisa Peebles, Esq.

Federal Public Defender

LAP: vib
cc:

Gregory Oakes, Oswego County District Attorney

Oswego County Court Clerks Office
Gary Thibodeau

SEP
COURT CL

2 2015
JFCLJ

COUNTY COURT OF THE STATE OF NEW YORK

COUNTY OF OSWEGO: CRIMINAL TERM

PEOPLE OF THE STATE OF NEW YORK,

Respondent,

AFFIDAVIT

-againstINDICTMENT #94-161
GARY THIBODEAU,
Defendant-Petitioner.

STATE OF NEW YORK)

COUNTY OF ONONDAGA)

SS.:

I, Lisa Peebles, being duly sworn, depose and state:

1. On or about July, 24, 2015, Melissa Searles, Heidi Allens cousin, contacted me after reading
a defense motion dated, July 17, 2015, that was filed with the court. This defense motion
included handwritten notes of Michael Bohrer that referenced Heidi Allen hiding a bracelet in
the seat of the vehicle she was abducted in)
2. Michael Bohrers reference to this bracelet was significant because Melissa Searles had given
a gold bracelet to Heidi Allen that was engraved with Allens name and love missy2 on the
backside of the bracelet.
3. Melissa Searles recalled in April, 1994, Bohrer was hanging out at the bar where her sister,
Shaughnessy Searles had bartended shortly after Allen was abducted. On one occasion
Bohrer approached Searles and her sister to ask about the case.3 Shaughnessy Searles was
killed in a motorcycle accident after Allens abduction not long after her encounter with
Bohrer.
4. Melissa Searles recalled that Michael Bohrer was present when she had conversations with
her sister and when she was discussing the bracelet she had given to Allen. These
conversations included Melissa Searles questioning whether Allen was wearing the bracelet
she had given her on the day she was abducted.
5. When Melissa Searles contacted me, she informed me that she discovered a white envelope
containing this bracelet in her mailbox some 10 years after Allen was abducted. Melissa
See attached Exhibit 53 Bohrers handwritten notes. (Tr. 485)
2

Searles nickname is Missy.

Bohrer testified at the post-conviction hearing that Allens cousin and a friend approached him in a public
parking lot and came forward to him to feed him information because they were directed to him. (625, 628)
Bohrer testified this encounter occurred at Spinners or Becks the Wednesday following Allens abduction. (628)

Searles never notified law enforcement of this incident and she has never tatked to anyone
else about this matter.
6. On March 21, 2013, Michael Bohrer was interviewed by Oswego County Sheriff Investigators
Pietroski and Johnson and he suggested that Gary and Sharon Thibodeau had mailed jewelry
to Allen or Sharons parents to get a reaction out of them.4
7. On July 28, 2015, I met with Melissa Searles and personally saw the bracelet and
photographed the bracelet, a copy of which is attached to this affidavit.

Lisa A. Peebles
Sworn to me this

Q1

day of September 2015.

Notary

lic

VALARIE L. BRUNI
in the State of New York
Public
Notary
Qualified in Onon. Co. No. 4858E313
My Commission Expires 5I19IJ_

Gary Thibodeau has been incarcerated since June. 1995 and Sharon Thibodeau died in 1997.

4_

Michael Bohrer
01:40:08

Direct

485

A.

I guess the Lortie family?

Q.

Very good, Mr. Bohrer.

01:40:13

01: 40:18

01: 40:21

01:40:29

01:40:31

Q.

Okay, do you know what her maiden name is?

01:40:33

A.

I have to assume now it was Hall?

01:40:36

Q.

Well, I dont want you to assume anything.

01:40:38

all do you know?

A.

She related to the Halls at

Is she married to any of the Halls?

I dont remember.

I thought Lottie is her married

name

You

either know or your dont.

01:40:39

10

01:40:43

11

01:40:45

12

01:40:53

13

01: 40:54

14

A.

01:41:02

15

visions.

01: 41: 09

16

Im

01:41:10

17

Q.

01:41:11

1$

A.

01:41:12

19

Q.

01:41:14

20

marked as Defendants Exhibit 53.

01:41:25

21

document?

01: 41: 26

22

A.

Its my handwriting.

01:41:32

23

Q.

It is your handwriting isnt it?

01:41:34

24

A.

Yeah.

01:41:41

25

A.
now.

--

I didnt until now or I didnt remember until

Im sure I heard of it.

Q.

And you

--

you consulted with her for what

patti cular reason?

She was interested in the Heidi Allen case.
She had an idea, you know.

She had

She had a story and

--

Mr. Bohrer, Im going to

--

--

listening to stories.

Im going to approach and hand you whats been

Do you recognize that

These are just notes to try to sort things

out
Jennifer Adydan
Official Court Reporter

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