MARY EVA COLALILLO CAMDEN COUNTY PROSECUTOR CAMDEN COUNTY OFFICE OF THE PROSECUTOR 25 NORTH FIFTH STREET CAMDEN, NJ 08102

STATE OF NEW JERSEY Plaintiff

v.

BRUCE ARlSTEO Defendant.

SUPERIOR COURT OF NEW JERSEY LAW DIVISION - CAMDEN COUNTY

(Criminal)

Indictment No. 2454-08-13

CRIMINAL ACTION

AFFIDAVIT IN SUPPORT OF MOTION TO REMOVE DEFENDANT FROM PRETRIAL SERVICES PROGRAM AND INCREASE DEFENDANT'S BAIL

Tracy A. Cogan, being duly sworn according to law, deposes and says:

1. I am an Assistant Camden County Prosecutor.

2. I am the Assistant Prosecutor assigned to prosecute the above captioned Indictment pending against State v. Bruce Aristeo.

3. The defendant is indicted for a violation ofN.J.S. 2C:I2-lOc, Stalking, third degree. Trial in this matter is currently scheduled for January 11, 2016.

4. The Honorable Lee A. Solomon signed the initial bail order with special conditions on May 17, 2013. A copy of this Order is attached hereto and made part hereof as Exhibit A.

5. This Court most recently modified defendant's bail on May 29,2015, allowing defendant to reside in Philadelphia as a modification of his Pretrial Supervision Agreement. However, the special conditions of defendant's bail remained in effect, including the condition that the Defendant is prohibited from making or causing to be made any communication, directly or indirectly, or through third parties regarding Jody Raines, her family, her friends, her business, or her pets in

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any manner which may be construed by this Court as likely to cause annoyance or alarm, and that defendant is prohibited from utilizing any internet and/or social media postings, directly or indirectly, or through third parties regarding, referring to, or simulating, characterizing or alluding to Jody Raines, her family, her friends, her business or her pets in any form, including, but not limited to Y ouTube, Facebook, LinkedIn and Twitter. A copy of this Order with the special conditions is attached hereto and made part hereof as Exhibit B.

6. On or about November 9,2015, Detective Auletto of the Camden County Prosecutor's Office located a website Defiantly.net. On the website Matthew Valor indicated he received documents from Bruce Aristeo. As per the website these documents were uploaded and are currently available for viewing by the public. The documents include the Indefinite TRO entered in this matter, along with some videos that are the subject of the pending Indictment, along with other discovery and correspondence. On Defiantly.net there is alink to another website, Scribd. Available on Scribd are various pieces of discovery in this matter.

7. Detective Auletto also located defendant's Twitter account; twitter.comlBruceAristeo@BruceAristeo. Available on defendant's Twitter account is a link to the above website, Defiantly.net, providing direct access to the discovery, videos, and references to the victim in this matter, as well as her business, etc.

8. Attached hereto and made part hereof is Exhibit C, a disc, which includes screen shots of Defiantly.net, videos posted on Defiantly.net; and screen shots of defendant's Twitter account.

9. The State avers that these postings on Defiantly.net and Twitter are in violation of this Court's special bail conditions prohibiting defendant from making or causing to be made any communication, directly or indirectly, or through third parties regarding J ody Raines, her family, her friends, her business, or her pets in any manner which may be construed by this Court as likely to cause annoyance or alarm and prolubiting defendant from utilizing any internet and/or social media postings, directly or indirectly, or through third parties regarding, referring to, or simulating, characterizing or alluding to Jody Raines, her family, her friends, her business or her pets.

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Based upon the foregoing, the State is asking the Court to remove defendant from Pretrial Services Supervision and increase bail to the original amount of $75,000 cash or bond with the special conditions of said bail to remain in effect. The State is further requesting the added condition that the defendant be denied access to the internet or any social media via any means.

Sworn and subscribed to before me on this t...l-'" day 0~er20l5.

&.. ./ Attorney-at-~ew Jersey 1<~",\ R"er.. {).,lD#"O:l."l132

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~~~ Assistant Prosecutor Attorney ID #025661994