FAQs

Coingate FAQs
Please note that this FAQ is not intended as an alternative to reading the book. If you haven’t read at least the Express Section and the Conclusion, it’s not likely that this information will be useful.

Was There Really Theft in Coingate?

Q- The Toledo Blade, even after agreeing that the coin funds made a profit, still says that Noe “stole” some $12 million. Is that accurate?
A- No, I don’t think that’s accurate at all. Agreeing with this conclusion would require legal and logical twists so extreme they’d qualify as origami.

Q- Explain.
A- First, there’s the false argument that Noe had committed theft because there were some missing coins. Some coins were in fact missing from inventory, because Noe did use falsified coin sales as a way to take loans. In other words, he said he sold a coin from his own business to the fund and got the cash for the sale, but in fact didn’t physically transfer the coin – usually because he didn’t own it. [NB The nature of the coin funds and how Noe took undocumented loans is explained in depth in the book.]

A- This sure sounds like theft.
Q- Yes, it sounds like it. And it’s why the whole thing is confusing to the public. What you need to understand, though, is that, as explicitly stated in the contract, no coins ever belonged to the state (in this case, “the state” means the Bureau of Workers Compensation). Instead, the contract specified that Noe had to provide the value of the coins held in the fund when the agreement ended after eleven years. What’s relevant in considering whether there was theft isn’t the physical presence of the coins, but whether Noe, as the fund manager, was legally and visibly documented as responsible for their value. Both the physical coins and the notes saying the fund owned the coins were the same thing:  representations of value. Since the evidence shows he had fully recorded his loans, that’s not theft.

Q- Explain that a little more.
A- Sure. In the contract between the and Noe, he got money to invest – primarily in coins but also in other things -- and after a certain period of time would return the state’s money with a profit. Coins were an investment instrument, but not what the state owned or was supposed to get back. The state put money in and got money back.

Q- OK, but how is it that the documents Noe left in the funds’ accounts were the same as actual coins?
A- They were the same from the point of view of the accounting -- they both represent assets of a certain value held by the funds. In accounting, a quantity of cash and an obligation to pay the same amount are treated as of equal value.

Q- You’ve said that Noe used fake coin sales to take loans. Was that legal?
A- There’s no question that in the contracts he was allowed to take loans at his own discretion and didn’t have to secure them or pay interest. But he was also required to keep accurate records and, by not describing the fake coin sales as loans in the documents he gave to the state, he was certainly violating that provision. Noe was guilty of false accounting – including the formal charge of “tampering with records” --and he admits that.

Q- If he had so much flexibility to take loans, why didn’t he describe them directly as such?
A- He used the loans for various purposes, some easily justifiable, some not. One use was that he had to repay some personal loans he’d taken to buy coins for the funds before the state money arrived. Another is that he had miscalculated what it was going to cost him to run the funds at the outset and needed more operating money for an initial period. He could have explained these two uses and not had a problem. But his accounting was poor and he didn’t think it was necessary to do all the work of documenting, so he didn’t. Also, it seems clear he used some of the loans to support personal expenses. It was definitely wrong to do that, but he had so much flexibility and such a long time to repay, Noe said he didn’t think repayment would be a problem. Again, this was obviously wrong and he has admitted that. Still, because he left the funds with assets in the form of complete documentation of the loans, it wasn’t theft. Theft would have occurred only if he had hidden his obligation to repay or if he had no reasonable ability to repay. Neither of those was the case.

Q- OK, back to the ownership of the coins. How is it that the state didn’t own the coins? Wasn’t that the whole point of the investment?
A- Not quite. The state invested in a company that invested in coins – and also other things like collectibles and stocks. The state didn’t own the coins, it owned shares in the company.

Q- You mean like a mutual fund?
A- Exactly. In a mutual fund you own shares in the fund, not the actual stocks that the fund buys and sells. Also, in a mutual fund, you don’t have the right to challenge the transactions that the funds make – what is bought and sold and when. If you don’t like what the fund managers are doing, your only option is to cash out. That’s exactly how the coin funds worked.

Q- But you say in the book that the state violated its contract by terminating its investment. Why?
A- Because the coin funds were actually more like special type of mutual fund, called a hedge fund. Hedge funds are much less flexible because the idea is to support a long term investment that are not likely to be highly liquid. Investors can’t easily get their money out before the term ends. And that’s exactly how the coin funds were structured – and for the same reason of supporting long term investment. Noe was very clear about that in the prospectus he gave the state before the investment was made.

Q- If the state didn’t own the coins but did have the promissory notes for Noe’s loans, how was it able to claim theft?
A- The state argued that, despite the explicit language in the contract to the contrary, it really did have ownership of the coins so Noe couldn’t take loans in the way he did. The state’s lawyers said the contract wasn’t valid.

Q- Why did the state take the extreme step of denying the clear contract language and therefore undermining a type of contract that is used in many other investment relationships? Why did prosecutors decide to assert what could become a radical and risky precedent?
A- The answer appears to be in the fact that, in criminal law, proving theft requires proving intent (“mens rea”). If you first consider that the IOUs Noe left were equal in value to the coins and that the IOUs were highly visible and effectively impossible to change in the accounting, and then also consider that Noe likely had the ability to repay, criminal intent is impossible to prove. Hence the only alternative for the prosecutors was to deny the contract and assert state ownership of the coins.  

Q- Isn’t it a problem when one party denies the terms of a contract?
A- It sure is, and that’s especially true here because the contract was reviewed multiple times by multiple state lawyers before it was signed. Noe had every reason to believe the contract was valid.

Q- Doesn’t the state’s decision to override an officially agreed contract set a bad precedent?
A- It certainly should. If you take the Noe case as a precedent, the state couldn’t invest in a hedge fund or lots of other similar financial agreements. The state’s approach here even denies the concept of a mortgage – if you accept the state’s logic, your bank is really the owner of your house and could revoke your mortgage if they didn’t like the color you used to paint your kitchen.

Q- How strong is the precedent? Won’t it become impossible for the state to work with private companies?
A- No. It’s not a real precedent. Like so many things in the Coingate saga, it’s a one-off interpretation – the legal origami I mentioned earlier. It’s to be applied only to Noe and then forgotten in the future. And that’s the core of what’s so deeply troubling about the Noe case.

Did Noe Really Intend to Repay?

Q- Noe says he intended to repay all the money he took as loans and advances. Of course, pretty much everyone who is charged with fraud says that. Why do you believe Noe?
A- I believe him for several reasons. One, which I’ve stated in another of these discussions, is that he appears to have had the financial ability to cover the value of the loans -- the “missing” coins – and more.

Q- OK, but didn’t he hide the loans? Wouldn’t that be in anticipation of just taking the money and keeping it?
A- That’s two questions. The answer to the first, whether he hid the loans, is yes and no. In the reports to the Bureau, he did hide his loans by saying he’d bought coins and this false reporting was a violation of his contract and conceivably a criminal offense. But it wasn’t theft, and the accounting he used actually ensured that he’d have to repay.

Q- Again, why wasn’t it theft?
A- Because the coin funds didn’t own physical coins, they owned the value those coins represented. And by saying that he held a particular coin in the name of a coin fund, Noe was specifically taking responsibility for the fund’s – and indirectly the state’s – ownership of that value.

Q- Explain that a little more.
A- Sure. Let’s say the Noe told the Bureau he bought two coins, each worth $5,000. One of those he really bought and one he didn’t but just left a note saying he did. When the fund terminated, the revenue owed to the state would be the same whether there was a physical coin or a note saying one was owned. That’s because Noe was responsible for providing the state with money equal to the value no matter whether it was in the inventory physically or just listed on paper. By the way, assets weren’t necessarily to be held to the end of the contract – most were sold for a profit after a period of time – but the principle is the same.

Q- OK, I see that. But how does it show he intended to repay?
A- Noe, by saying he had the coin when he didn’t, was taking a fully documented loan of $5,000. He wasn’t surreptitiously taking cash out of the till. He wasn’t pretending to pay bills he didn’t owe. He wasn’t doing any of the things people do to cover up fraud so it will never be known. Instead, he was very clearly and very specifically documenting his loans. If he didn’t intend to repay, he wouldn’t have used such a highly visible and nearly impossible to change accounting method.

Was Noe Able to Repay the Loans?

Q- You said that having the physical coin and having a note saying a coin was owned would be the same thing for the coin funds. But that’s true only if Noe had the ability to repay the loan that the document – the paper coin if you will -- represented. Could Noe have repaid the loans he took? Did he have the resources?
A- Even after accounting for his loans, Noe could have given the state a considerable overall profit – one probably three times greater than what was actually delivered. In most accounting disputes I’ve seen, covering everything and having a notable profit is enough to have everyone walk away and forget about the costs of legal action.

But even if the state had insisted that this wasn’t enough, and taken the path of requiring repayment of loans separate from profits, arguing that he could have made even more money, I think he could have repaid, and probably quickly. But there are so many variables here it’s impossible to answer with numeric and temporal certainty.

Q- What are the variables?
A- One is time – when he’d have had to repay – i.e. if he had the reasonable time allowed for in the contract vs. being forced into a quasi-fire sale situation as actually happened. Another is whether he’d be in charge of dissolving the funds as provided for in the contract – remember that he was owed 20% of profits. Another important variable is how much he actually owed – when you look carefully at the supposedly “missing” $12 million, you know the number is bogus. The audits described a lot of money as missing because the auditors couldn’t prove it wasn’t missing – sort of backwards from the way it should be. Some of the money described as missing was in fact still there, either in cash accounts or in other parts of the coin funds. The indictment should have said something like “as much as $12 million may have been missing” instead of giving a concrete figure. You really have to read the book to understand all this – it can’t be summarized in a few words.

Beyond that, recall that Noe did have considerable personal resources in his business and he had other assets beyond that in investments and in real estate. And, if suddenly put in a difficult position, it’s highly likely he could have borrowed money from friends. Unlike the cases of alleged or actual fraud I’ve read while researching the book, Noe was at a minimum very close to being able to immediately repay everything he’d taken as loans, and almost certainly able to repay in the short term. There’s a certain irony here, since it’s very common for charges to be dropped (or not presented at all) when there’s a chance of repayment even over the long term. The unusual, if not unique, treatment of Noe strongly implies that he was prosecuted for a reason other than collecting a debt that may have been owed to the state.

Q- Couldn’t Noe have avoided repayment by transferring profits from other areas to cover loans? Doesn’t this possibility undermine the idea that he intended to repay?

A-   It’s true this scenario is described in one of the Non-Political Noe examples, and referenced in some examples. But that shouldn’t be taken to mean that it’s a likely outcome or that Noe could reasonably have planned on using it to avoid repayment.

Recall that the coin funds were set to run for a period of time, then close. At that point, there would be a full accounting and Noe wouldn’t have been able to hide loans against coins with funds transferred from other areas. I referenced the idea of the state possibly overlooking these transfers only in the context of a rapid, almost panicky closure of the funds. Noe couldn’t have counted on this kind of ending and certainly didn’t want it. And there’s nothing more than a possibility that the accountants would have missed the transfers in this situation.

Again, the kind of accounting gimmick Noe used to hide loans from the state wasn’t a permanent solution, one that could make an ordinarily careful accountant think everything was OK. On the contrary, the loans were highly visible to anyone doing a full audit.

Also, it isn’t just Noe who said that the intention was always to repay:  Tim LaPointe, a prosecution witness, repeatedly said the same thing.

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In summary, covering coin-based loans with profits from elsewhere wouldn’t have been a viable strategy for Noe. The only way he would have been safe was to repay the loans. Something he likely could have done but wasn’t allowed to try.

Q- Do you really believe that what Noe did was OK – do you really think he shouldn’t have been punished at all?

A- No, and I did say at numerous points in the book that he falsified records (“tampering” in legalese) and that he probably evaded some small amount of taxes through his record-keeping. I also point out that, even though the contract permitted him to take loans and advances without permission, he likely would have been challenged on the amounts he withdrew if he hadn’t submitted misleading records.

Q- So isn’t that enough to justify punishment?
A- Yes, but perspective is important. First, most cases like this are handled in civil rather than criminal court. It’s really pointless for me to say what the outcome would have been in a civil case, in part because I have no legal training and in part because, from my layman’s perspective, there seems to be such a wide variation in decisions. In other words, I’ve read about similar cases where the outcome was just an agreement to repay and others in which the loser had to pay a major settlement as well as legal costs. NB – judgments in civil courts do not lead to jail sentences.

Q- But is it completely unreasonable for this to have been a criminal case?
A- No. Absent the political context I think a criminal charge would have been very unlikely. But such a charge is legally possible and not entirely unprecedented.

Q- So the outcome could be seen as OK?
A- No. I don’t agree with that. The issue is perspective and proportionality. As mentioned, the only charge I think was valid was tampering with records and possibly tax evasion (he actually wasn’t charged with that). I don’t believe any ordinary, non-political person would have faced a theft charge, much less RICO (Racketeer Influenced Corrupt Organization), in an accounting-based case like this. As an aside, it would be interesting to see how the Lucas County Prosecutor – or indeed other prosecutors in Ohio -- used the RICO law before Noe.

Q- Are you saying that white collar crime shouldn’t occasion criminal charges?
A- No. On the contrary, I believe criminal charges should be used more widely in some white collar cases. Just now there are reports of doctors prescribing an unnecessary and potentially dangerous drug to the elderly in return for payments from a pharmaceutical company. The federal government is investigating and the article I read said that charges in these cases are usually brought in civil court. I disagree. These seem like criminal offenses to me, and I believe that the parties – if proven guilty -- should serve some prison time – maybe a year or so. And doctors should lose licenses.

The comparison above illustrates clearly the problem with Noe’s case:  it isn’t the abstract issue of white collar crime, it’s the specific process and outcomes. Noe didn’t put anyone’s health at risk, he didn’t threaten anyone’s financial livelihood – the state got back more than its original investment (even after using a fire sale to liquidate assets), and didn’t even allege specific victims in his case. Instead, it seems clear to me that he was subjected to a special set of rules simply because he was politically prominent and both parties wanted to get him, albeit for different reasons. The result was a punishment that stands completely and radically apart from what’s normal. That’s more than troubling; that such a thing could happen is dangerous to our society.

Were the Charges Against Noe Honestly Created? Why Are All the Records Gone?


Q- Why are you so concerned with how the charges in the indictment handed down against Noe were developed?
A- The process and the origins of what charges to file are not clear, and all the relevant records appear to have been destroyed. Those facts should make anyone suspicious, particularly given the political overtones of the case.

Q- Who was involved?
A- There was something called a State Task Force (STF) that oversaw the initial actions against Noe, including the search warrant in May of 2005. Members of the STF included:  the Office of the Attorney General, the Office of the Auditor of State, the Office of the Inspector General, the highway patrol, the Lucas and Franklin County Prosecutors, the US Attorneys for the Northern and Southern Districts of Ohio, and staff from the Bureau of Workers Compensation.
There appears to be no documentation at all from this group. Freedom of Information requests to the AG, AOS, and IG offices yielded no documents on how the charges were developed. A similar query to the Lucas County Prosecutor’s office went unanswered.

Q- Isn’t information about criminal investigations usually secret? For example, isn’t information presented to a grand jury secret?
A- Grand jury information is certainly secret, but investigative information that leads to charges is normally exposed during a trial. Still, the issue here is a little different:  how were the charges developed? Specifically, why did the STF decide to turn an accounting-based civil case into a criminal one that included the ten-year minimum RICO (Racketeer Influenced Corrupt Organization) charge?

Q- Isn’t that kind of information normally withheld? Aren’t internal deliberations non-public?
A- Yes. Such records are normally seen as confidential and for good reason. But there are two important variations here. In June of 2005 the AOS contracted with an external firm to do a special audit of the coin funds. The charge to the firm was broad but specific:  identify all assets (including coins, collectibles, accounts receivable, real property etc.); review all transactions for discrepancies; and identify any discrepancy between the value of the funds’ assets and the initial investment made by the OBWC.

However, when the audit was released, in February of 2006, it almost entirely ignored the original charge:  there was no identification of all assets, no review of all transactions, and no information on valuation vs. initial investment. Also ignored were 5 coin fund affiliates in 5 different states. The focus was limited to only one budget category at one location:  coin inventories at Noe’s office in Maumee. And, although others involved in the coin funds appeared to have made transactions similar to those for which Noe was indicted, only he was charged with theft.

Q- That’s kind of dramatic. But maybe there aren’t any records. Maybe the change was done informally?
A- That doesn’t seem possible.  A big, well-respected accounting firm, which has lots of lawyers as well as accountants, isn’t going to radically change its contract and scope of engagement  based on a hallway conversation. The firm would have insisted on a revised contract. There have to have been records –both within the firm and in the records of the state agencies -- of when and how the change in focus was made.

Q- You said there was a second issue?
A- The second issue is the motives of the players on the STF. Almost all of them repeatedly bragged to the media about the wonderful job they were doing in defending the public purse. But, as noted elsewhere, they first refused to release the working papers of the external firm, then they appear to have destroyed all of their own internal records. If their focus was on the public good rather than on an effort to get Noe, why didn’t they retain evidence in support of that fact? If they were so proud of their work, why did they violate at least the spirit of the records retention law and destroy the records?

Why Was the Trial Held in Toledo? What About Conflicts of Interest?

Q- Should the trial have been moved somewhere outside of Lucas County?
A- It shouldn’t have been just the trial but also the investigation and determination of charges that should have been moved elsewhere -- Columbus, the state capital, was an eminently reasonable option here. Otherwise, as happens not infrequently, it should have been turned over to a special, outside prosecutor. The prosecutor and the judge were subject to powerful bias based on their own interests. The jury pool was hopelessly tainted by negative pre-trial publicity, directly and indirectly from the Blade but also from other outlets.

Q- You don’t think the prosecutor and judge acted appropriately?
A- I don’t think they consciously did anything wrong, but research in psychology shows clearly that people often fail to resist what’s called unconscious bias. They should have known about that and recused themselves.

Q- How were the prosecutor and judge biased?
A- The prosecutor is married to a judge against whom Noe and his then wife Bernadette had led repeated electoral attacks. The prosecutor can’t have been unaware of these. Also, the prosecutor’s step-daughter and her husband were both reporters for the Blade, which was relentlessly attacking Noe. Take that together and there’s a mountain of potential bias -- and that’s especially important because the prosecutor determined the charges, including the anomalous RICO charge.

Q- And the judge?
A- Noe had filed ethics charges against him, charges that the judge had to defend in an investigation by the Ohio Supreme Court. The judge said he didn’t remember or know that Noe was behind the charges, but that became beside the point when the issue became public. The judge did know Noe had filed charges against him before the trial started. And the judge did make one crucial, discretionary decision -- to prevent presentation of evidence of the funds’ overall success -- that essentially destroyed Noe’s ability to present a defense. Finally, almost immediately after the judge’s decision, the Blade endorsed him in an unusually prominent way for a fiercely contested upcoming election.

Q- And the jury?
A- There’s a lot of solid research showing that jurors are strongly affected by media coverage that’s negative to a defendant. That’s true even if they don’t believe they have been affected. Often, they’ll say they don’t read newspapers or watch TV news, but many people get media information secondhand from family, friends, and co-workers.

Q- But can’t they be fair anyway?
A- Some certainly can. But the research shows that many don’t act in an open-minded way after exposure to media bias. Even when they dismiss the media coverage or other information they’ve received, and argue they can be fair, the research shows they often act in a biased way. The jury foreman later submitted an affidavit stating that they jury felt pressured by public opinion not just to convict, but to do so quickly.

Q- Most major trials get some media coverage – wouldn’t this mean they’d all have to be moved? That would be expensive and difficult.
A- Often, media coverage doesn’t matter much because a lot of people don’t pay attention to an occasional article on criminal issues. But in Noe’s case there was almost a year and a half of constant coverage of the front page variety, not to mention continuous TV, radio, and political advertising that was also prevalent at the time of the trial. Remember that the jury wasn’t sequestered.

Q- Did the Noe jury react the same way as the research suggest?
A- It certainly appears they did. A large number of prospective jurors had to be dismissed right away because they said they’d formed an opinion – this despite having previously responded to a questionnaire that was supposed to weed such people out.

Q- “Stealth jurors” are people who have biases for or against a defendant and want to be on a jury to act on their feelings – they are people with conscious bias who conceal that in order to be selected. Do you think stealth jurors were a problem in Noe’s case?
A- There’s no way to know for sure. But, given the research on this topic, and given the supercharged political nature of this trial, it seems likely that at least one juror wanted to be on the case to enforce some personal belief.

Q- What should be done to avoid the kind of bias Noe faced?
A- First understand that such extreme cases will be rare. When you look at the specifics of the Noe case, including especially the media bias and the fact that he had been a leader in confronting the political party to which the prosecutor and judge belonged -- as well as those individuals directly -- it’s unlikely that any jurisdiction will see such a case more often than once in a generation – if that often. The solution is for the Ohio Supreme Court to step in when unusual circumstances are revealed. In fact, as discussed in another of these Q and As, they now seem to have decided to do that.

Has the Ohio Supreme Court Changed Its Mind About the Dangers of Potential Bias?

Q- What about the 2017 Ohio Supreme Court case ruling on judicial “appearance of impropriety”?
A- In 2017, the Ohio Supreme Court ordered a retrial with a new judge in a case where the original judge, Judge Crawford, was very slightly acquainted with someone involved with the accused. The Supreme Court’s Chief Justice, who delivered the ruling, emphasized that she had no reason to believe the original judge acted in biased way, but employed majestic and powerful language to stress that the Court had to protect against even “the appearance of impropriety.” Judge O’Connor wrote, in part: “…even in cases where no evidence of actual bias or prejudice is apparent, a judge’s disqualification may be appropriate to avoid an appearance of impropriety or when the public’s confidence in the integrity of the judicial system is at issue.”

The Toledo Blade, the paper that pursued Noe, strongly concurred with Judge O’Connor. If the Crawford case had an appearance of impropriety rank of “1,” the Noe case would rank as “100.” The appearance of impropriety was absolutely pervasive in Noe’s case. So, yes, the Supreme Court has changed its mind.

Was Your Research Balanced?

Q- Didn’t you get a lot of help from Noe’s friends? Why didn’t you talk to people on the other side?
A- First, I didn’t talk to anyone at any length about the substance of Coingate until I was well into the project. I really had no important conversations until I had read all of the core information:  the Blade and other media coverage, the court documents, and the transcripts. In part, this delay in talking to people was because I wanted to form my own opinion. In part it was also because I wanted to be efficient when I did interviews – ill-informed questions waste time and annoy people. Finally, as noted on the website, in my early conversations with Noe I avoided substance. I didn’t really interview him in the sense of asking focused questions about what happened and what he did until I was essentially finished with the research.

It’s true that the people I wound up talking to were in fact mostly friends of Noe:
  • His sister Beth June has helped with logistics of the prison visits and with contact information.
  • A handful of friends and family read early drafts and commented. None had special or important knowledge of the case.
  • A friend of Noe offered the help of an artist for the cover. The artist did a wonderful job (in a few hours) and I’m very grateful because, while I had the idea for a drawing, I don’t have the talent to do it.
  • No one offered me money or anything of value beyond a couple of cups of coffee. On the other hand, I’ve had non-trivial expenses, primarily for travel, that I doubt will be covered by book sales. I also was about to launch a business helping people with biographies or auto-biographies that I put on hold to do this. I can’t say with certainty that I lost money as a result of the decision to do this book instead of the business, but I’d like to think I did because I thought the business would be modestly remunerative (and fun).

I did talk to a number of people in the coin industry who were recommended by Noe. They offered useful advice about their area, and one was also a very good manuscript reader. But I think all were disappointed that there wasn’t more in the book about coins and the industry.

I had expected to need help on legal issues and had lined up assistance in that area, but wound up deciding that Coingate wasn’t really about technical aspects of the law. Still, two very experienced lawyers – one with criminal experience and one with a civil law background -- did read the final manuscript and offered valuable comments.

Three of the five people who were the most engaged in critiquing the manuscript had never heard of Noe until I asked for their help.

My original idea was to do lots of interviews, but that changed for two reasons:  1) the first two contacts I made with people who had Toledo political connections resulted in nothing because they (politely) refused to talk to me. Even with a promise of anonymity, they said they were too afraid of retaliation from the Blade; 2) After this, and some further reflection, I decided that more information on the political context in Toledo wasn’t really useful to the direction I had chosen. Even if I’d come to a different conclusion, it seemed I was very unlikely to get balanced commentary.

I didn’t contact the former Blade reporters because I thought it very unlikely they would talk to me – they are still employed in the profession and are therefore likely vulnerable if they have thoughts at variance with what the Blade published in its stories and editorials. Perhaps they’ll want to comment on the Facebook page or send articles to post on the website – if the latter, I would expect to publish in full.

I didn’t try to talk to the judge because I was advised by everyone I asked that he would almost certainly refuse.

I did send questions to the prosecutors by certified mail but they never acknowledged or replied.
I didn’t think I’d get much help from former state officials, but did try to get documents from their offices that could then have been useful material for interviews. As recounted elsewhere, this effort failed totally.

I should emphasize that the fact that I talked primarily to Noe and a few of his friends shouldn’t be seen as lack of balance – after all these people, including especially Noe, had little presence in the public record before the trial. On the other hand, the people who I didn’t talk to – the Blade, the prosecutors, the judge – all have had an enormous opportunity to express themselves to the public and have taken extensive advantage of that. And those who read the full version of the book will see that the thoughts and opinions of the prosecutors and the Blade are extensively referenced, mostly with their own words.