The State's case against Doyle is based on the sale of eight contracts after October 10, 1996. Homans in her letter to Van Dyke and various Court filings states:

1. Doyle ignored the warning of Steve Diamond during a phone call.
2. Doyle ignored the warnings of both of his lawyers Dyer and DeTroy.
3. Doyle misled Dancoes and lied to him regarding the State's inquiry.

The facts and evidenced discovered since the first guilty plea:

1. The tape of the second phone call to Diamond was found in June 2000 and it disputes and challenges the credibility of Diamond's testimony/statement as the tape gives no indication of any warning.
2. In a search of Doyle's file for anything that would exonerate him on May 23, 2001 at Van Dyke's office a letter from DeTroy to the State and two memos from Dyer to Doyle were found. Not only were Dyer and DeTroy silent on any warning they show in documents dated two and three months after they claim to have warned Doyle in October 1996 that they were actively promoting Doyle to continue the sale by word and deed. Dyer refers to the State investigation as a "bogus misuse of administrative authority". Dyer's memos would indicate that his testimony from his deposition on January 26, 2001 is perjury.
3. Dancoes' charges that he was misled by Doyle have no bearing in reality as the State has all the letters and contacts by DeTroy to both the Bureau of Insurance and Securities Dept. that show and ongoing knowledge and plan to thwart the State's investigation.