Exhibit (A)-ListEvidence Vault: Erika vs Marco Marco Docs

Three Pieces of Evidence That Raise Serious Red Flags

1. Sworn Affidavit from Private Investigator Jonathan Ballard

A licensed investigator confirmed that a bank account bearing Erika Girardi’s name was opened by Wilkes & Associates’ CFO at the request of Jim Wilkes—funded with an estimated $400,000 from Wilkes’ personal or firm accounts. The CFO admitted to routinely moving money without questioning it, suggesting a lack of financial oversight and a direct link between firm funds and Erika.

2. PPP Loan Data – The Wilkes Firm, P.A. (First Round)

Wilkes & Associates received $2.39 million in federal PPP loans, claiming to support 142 employees. However, sworn testimony from insiders estimated only 100 employees at the time—indicating a potential overstatement of payroll, which could amount to federal loan fraud if funds were misused or redirected.

3. PPP Loan Data – The Wilkes Firm, P.A. (Second Round)

In 2021, the firm received a second PPP loan, this time for $2 million, also fully forgiven. Taken together with the first loan, this means the firm secured nearly $4.4 million in taxpayer-backed funds. With documented inconsistencies in reported staff size and simultaneous evidence of money transfers involving Erika Girardi, this second loan further strengthens the case for a pattern of federal relief abuse and financial misconduct.

Jonathan Ballard Affidavit

Download

Jonathan David Ballard, a licensed Florida private investigator and former New York law enforcement officer, submitted a sworn affidavit detailing his investigative findings related to Wilkes & Associates and Erika Girardi (aka Erika Jayne).

Employee Count:
Ballard contacted Dara Cooley, who estimated that Wilkes & Associates had around 100 employees in May 2020 (25 attorneys and 75 support staff), noting some may have been remote due to COVID-19.
Bank Account Linked to Erika Girardi:
Ballard also interviewed Timothy Kulig, former CFO at Wilkes & Associates. Kulig stated he opened a Wells Fargo account—at the request of Jim Wilkes—that bore Erika Girardi’s name. He estimated roughly $400,000 in deposits into the account, believed to be personal or distributed firm funds from Wilkes.
Kulig noted:
- He never met Erika in person but spoke to her on the phone.
- He routinely moved funds for Wilkes without questioning their purpose.
- His name may have also been on the account for logistical reasons.
Reconfirmed Employee Estimates:
Kulig also estimated the firm’s size at approximately 100 employees in May 2020, though he acknowledged he was not 100% certain.

⚖️ Why This Affidavit Is Important to the Case

This affidavit is crucial because it supports key elements in allegations of financial misconduct:

Verifies firm size: The employee count is relevant to evaluating the legitimacy of Paycheck Protection Program (PPP) loans or payroll-related claims.
Links Erika Girardi to Wilkes firm finances: The existence of a bank account with Erika’s name on it, opened by the firm’s CFO using Wilkes’ funds, raises questions about whether funds meant for business use were diverted for personal benefit or under improper influence.
Corroborates patterns of behavior: Kulig’s statements suggest a lack of internal financial oversight, reinforcing claims that Wilkes may have enabled improper financial activity—potentially at Erika’s request or for her benefit.
Supports broader legal narrative: If the case involves claims of misappropriation, fraud, or elder exploitation, this document helps connect financial actions directly to key players.

ProPublica PPP Report — The Wilkes Firm, P.A.

Download

🧾 Summary: ProPublica PPP Report — The Wilkes Firm, P.A.

Loan Amount Approved: $2,392,079
Loan Forgiven: $2,405,846 (includes interest)
Approval Date: April 7, 2020 (First Round)
Reported Jobs: 142
Use of Funds (as declared): Payroll, utilities, mortgage interest, healthcare, rent
Business Type: Professional Association
Industry: Legal Services
Lender: American Momentum Bank
Location: Tampa, FL
Loan Status: Fully forgiven

This data was collected by the SBA and reported by ProPublica as part of its public accountability initiative on federal COVID-19 relief disbursements.

⚖️ Why This Is Important to the Case

Discrepancy in Employee Count:
- The Wilkes Firm reported 142 employees to the SBA in its PPP loan application.
- Yet sworn statements from both Dara Cooley and Timothy Kulig (via the Ballard affidavit) estimated only 100 employees at the firm around that time.
- This potential overstatement of payroll headcount could indicate misrepresentation or fraud in obtaining federal relief funds.
Financial Trail Supporting Broader Allegations:
- If any PPP funds were misused or funneled to Erika Girardi, as the Ballard affidavit suggests with the $400,000 account opened in her name, it may point to fraudulent allocation of government funds.
- This could expose both Jim Wilkes and potentially Erika Girardi to civil or criminal liability, especially if the funds were diverted for personal benefit or unrelated expenses.
Reinforces Pattern of Financial Impropriety:
- Together with affidavits and internal testimony, this loan data builds a case that The Wilkes Firm may have operated with improper financial oversight, bolstering broader claims of misconduct, money laundering, or conspiracy.
Public Record and Reputational Risk:
- This data is publicly available and verifiable, adding weight and transparency to any legal or journalistic reporting. It provides irrefutable documentation of the firm’s public financial representations.

Second PPP Loan – The Wilkes Firm, P.A.

Download

Summary: Second PPP Loan – The Wilkes Firm, P.A.

Loan Amount: [Not listed in your text, but accessible via the link: $2,000,000]
Amount Forgiven: Full forgiveness (including interest)
Approval Date: January 2021 (Second Round of PPP loans)
Lender: American Momentum Bank
Business Type: Professional Association
Location: Tampa, FL
Industry: Offices of Lawyers
Jobs Reported: Not specified in this record
Loan Status: Forgiven

This loan was issued during the second round of COVID relief, meant to support businesses still facing hardship. Full forgiveness indicates the SBA accepted The Wilkes Firm’s certification that the funds were used according to guidelines (primarily payroll and job retention).

⚖️ Why This Loan Is Important to the Case

Multiple Forgiven Loans Raise Red Flags
This second PPP loan—on top of the $2.39 million first-round loan also fully forgiven—brings the total forgiven amount for The Wilkes Firm to nearly $4.4 million. Taken together, these records suggest substantial federal relief was obtained, allegedly for job retention, even as sworn affidavits indicate discrepancies in employee counts.
Contradictory Employee Numbers
The firm reported 142 jobs on the first loan, but both Dara Cooley and Timothy Kulig (per the Ballard affidavit) estimated 100 employees at most during that time. This second loan likely relied on similar (if not the same) job numbers—amplifying the potential misrepresentation.
Potential Diversion of Funds
We now know that CFO Timothy Kulig opened a $400,000 account in Erika Girardi’s name at Jim Wilkes’ request. If these PPP loans are what funded that account—or were commingled with those funds—it could constitute loan fraud and misuse of federal funds.
Broader Pattern of Misuse
When viewed alongside the Girardi Keese PPP loan, this creates a clear pattern of law firms connected to Erika Jayne receiving and potentially misusing large federal loans, while clients, creditors, and the government were left in the dark.

📌 Contextual Note for Reporting (Exhibit A List Style)

This second PPP loan wasn’t just a lifeline—it might have been another financial smoke screen. With mounting evidence that Wilkes & Associates was funneling funds in questionable directions, this second round of federal aid adds weight to allegations of systemic abuse within the firm—and possibly points to a conspiracy to shield Erika Girardi’s finances during growing public scrutiny.

Erika Affidavit

Download

What It Is:

A 17-page sworn declaration from Erika Girardi filed in federal court (Central District of California) as part of her defense against a lawsuit brought by Christopher Psaila (co-founder of Marco Marco). The document is filed in support of an anti-SLAPP motion—an attempt to strike the complaint as an attack on protected speech.

🔍 Why It’s Useful:

Perjury Flag (Paragraph 104): Erika declares under oath that she and her assistant Laia reviewed seven flagged transactions and “have no invoices, no emails, and no texts” that could support them.
→ This is contradicted by 281 text messages and documents already produced, showing discussions, approvals, and authorization trails.
Constructed Narrative: Erika paints herself as financially isolated and unaware, portraying the charges as fraud only uncovered after AMEX alerts and Secret Service involvement. This narrative bolsters her claim that the complaint should be dismissed—but evidence suggests she was aware and involved.
Federal Filing Under Penalty of Perjury: This declaration was submitted in a federal proceeding under penalty of perjury. If proven false, it opens up Erika to significant legal exposure—not just civilly, but potentially criminally.
Pattern of Shifting Blame: Erika repeatedly points fingers at others (Chris Psaila, a bookkeeper, American Express, her ex-husband) while distancing herself from her own financial oversight and authorizations—despite having initiated many of the orders through her assistant and creative team.

Motion to reconsider its decision to strike their motion to dismiss

Download

📄 Document Summary:

This motion, filed by James Wilkes on behalf of Erika Girardi (aka Erika Jayne), Laia Ribatallada, and Michael Minden, asks the Miami-Dade County court to reconsider its decision to strike their motion to dismiss the Florida case filed by designer Marco Morante. The original motion to dismiss challenged Florida’s personal jurisdiction over the defendants, who reside in California.

🔍 Why This Is Useful:

Jurisdictional Abuse Claim: The motion accuses Bruce Bealke and Marco Morante of using the Florida court improperly to get around a stay of discovery in the federal California case involving the same parties and facts. It frames the Florida action as a strategic end-run around the paused federal litigation.
Bad Faith Allegations: Wilkes documents a series of communications showing Bealke pushing for procedural waivers in exchange for not going to the press and for halting discovery—framing this as coercion and potential misuse of legal process.
Procedural Missteps: It asserts that the hearing to strike the motion was improperly noticed and blames missed appearances on calendar mismanagement—not client neglect—undermining the basis for the court’s sanction.
Context for Press: This filing positions Erika’s legal team as being targeted through procedural gamesmanship and forum manipulation, potentially giving the Daily Mail a narrative of legal abuse, PR pressure, and retaliation.

James Wilkes Redacted PDF

Download

📄 What It Is:

An official letter from The Florida Bar, dated April 11, 2025, confirming the disciplinary and licensure status of James Lewis Wilkes, II, a Florida attorney.

🔍 Key Takeaways:

Ineligibility to Practice: Wilkes was ineligible to practice law in Florida for three days—from March 17 to March 19, 2025—due to a Continuing Legal Education (CLER) delinquency.
Currently in Good Standing: As of the date of the letter, Wilkes is listed as a member in good standing and is eligible to practice.
No Disciplinary Sanctions: There are no court-ordered disciplinary sanctions on Wilkes’s record.
Two Past Complaints (No Discipline):
- File 2023-10,511(13E): Closed October 24, 2023
- File 2024-10,620(13E): Closed April 7, 2025
  Both were closed by staff without discipline.

📌 How This Is Useful:

This document confirms Wilkes’s brief period of ineligibility, which could be relevant in:

Challenging his legal authority during that 3-day window (e.g., if he signed or submitted court filings).
Verifying his current status for credibility in legal or public records.
Contextualizing other misconduct claims—even if these closed files didn’t lead to formal action, they establish a pattern of complaints.

Exhibit 1A to Psaila Declaration

Download

📄 What It Is:

A collection of Erika Girardi’s American Express statements from 2015–2016, filed as evidence in federal court (Exhibit 1A, Case No. 2:23-cv-07120).

Why It’s Useful:

These statements itemize charges to Marco Marco over a two-year period, totaling nearly $1 million.
It contradicts Erika’s sworn statement (paragraph 104 of her affidavit), where she claims to have had no supporting documents for these charges.
The volume and detail of charges directly challenge the credibility of her claim that she had no knowledge or records of these expenses.

Shopify Chargeback Dispute (Emails)

Download

What It Is:

A detailed email thread between Chris Psaila and Shopify’s risk analyst in 2017 regarding a chargeback filed by Erika Girardi related to Marco Marco charges.

Why It’s Useful:

Chris provides contemporaneous documentation that Erika’s assistant, Michael Minden, approved the charges via text.
He shares info about design sketches, time logs, labor invoices, and photos of the garment, asserting the work was fully authorized.
This contradicts Erika’s claim that she didn’t recognize the charges or approve the work.
Psaila also mentions a Secret Service raid initiated due to Erika’s complaint, further highlighting the high-profile legal stakes involved at the time.

Messages – Marco + Laiah (Laia Ribatallada)

Download

What It Is:
A series of iMessages between Laia (Erika’s assistant) and the Marco Marco team, exported from Laia’s phone.

Why It’s Useful:

The messages confirm frequent coordination, including fittings, pickups, and performance timelines, proving Erika’s team was actively involved in costume orders.
The tone and context show an established, recurring business relationship—not a disconnected, rogue vendor situation as Erika’s affidavit suggests.
Supports Psaila’s position that Laia and Mikey ordered costumes with Erika’s knowledge, directly contradicting her sworn denial of involvement or authorization.

4/9/25

1. Exclusive Interview – Erika Jayne & The Sun

The Sun Interview Article
An exclusive piece featuring Erika Jayne discussing stress from ongoing lawsuits and supporting Teddi Mellencamp through cancer treatment. This provides recent public comments from Erika about her legal and emotional state. Source for interview is Jim Wilkes

2. Funding Erika’s Divorce – Financial Ties to Jim Wilkes

Summary Paragraph This section outlines the suspicious financial relationship between Erika Girardi and Jim Wilkes, including $400K wired into a joint Tampa account used to fund her legal fees. Raises questions about the source of the money (from Wilkes’s law firm, not Wilkes personally).

Erika Girardi’s Financial Ties to Jim Wilkes – Court Document C.

(Summary) In October 2020, Erika Girardi opened a Wells Fargo account in Tampa, Florida, with Jim Wilkes—a longtime associate of Tom Girardi—and Wilkes & McHugh’s financial controller, Timothy Kulig. Over the next several months, Wilkes & McHugh wired a total of $400,000 into this account:

$150,000 on October 14, 2020

$100,000 on December 30, 2020

$150,000 on April 2, 2021

Erika used this account to pay attorneys and other expenses. Importantly, the funds came from Wilkes’s law firm, not from Wilkes personally. The true source and purpose of the funds remain unclear, and no declaration has been submitted by Wilkes verifying the origin of the money.

When public speculation arose on social media regarding who was funding Erika’s legal fees, Wilkes aggressively tried to shut it down, threatening Plaintiff’s attorney Ronald Richards and insisting Richards was “in the dark.”

Despite formal discovery efforts, Erika refused to explain her relationship with Wilkes or whether he was holding or owed her money. Her attorneys gave noncommittal responses, stating that “in such event” she does respond, her answer will be “No.”

Wilkes Law Firm Website (Archived)
Archived attorney profile page for Wilkes & McHugh showing Jim Wilkes’s law firm and its team. Useful for establishing his professional status and affiliations.

3. PPP Loans Related to Wilkes’s Firm

Records show that Jim Wilkes overstated the number of employees at his firm when applying for COVID-19 relief funds. This discrepancy raises serious questions about the legitimacy of the PPP loans he received and whether the funds were used appropriately—especially in light of his unexplained financial support of Erika Jayne.

Wilkes Firm PPP Loan Listing (PPPreport.org)
Public database record showing PPP loan(s) issued to Wilkes’s law firm, confirming the firm received COVID relief funds.
Daily Mail Article – Erika Jayne & Wilkes Dating
Tabloid coverage linking Erika Jayne romantically to Jim Wilkes, noting his recent arrest.

4. Sexual Assault Allegations Involving Wilkes

In addition to financial irregularities, Jim Wilkes has also faced serious allegations of sexual harassment. In a case filed by a former employee, the plaintiff alleged inappropriate conduct and a hostile work environment within Wilkes’s firm. The case was ultimately settled out of court, and the terms of the settlement remain undisclosed. While the matter has been resolved legally, it adds to the growing list of concerns surrounding Wilkes’s professional and personal conduct.

Sexual Assault Case (Download)
Court filing or legal document from a sexual assault case filed against Wilkes (or his firm).
Wilkes vs. Collins – Screenshot of Allegations
A screengrab referencing a different set of allegations or litigation involving sexual misconduct or inappropriate behavior.
Tampa Bay Times – Wilkes Arrested
News article detailing Wilkes’s 2023 arrest for firing a gun during a domestic dispute—relevant for establishing a pattern of erratic or dangerous behavior.

Tampa Lawyer Arrested During Domestic Dispute
Title: Tampa lawyer arrested after firing shots in home during argument, records show
Source: Tampa Bay Times
Summary: Article reporting on Jim Wilkes’s arrest following an altercation in which he allegedly fired a weapon inside his home. Highlights Wilkes’s history and the circumstances of the incident.

Full 7 Count Transaction: DOWNLOAD

“FUCK CHRIS MEMO” DOWNLOAD

Exhibit 3: DOWNLOAD

Featured Image of Erika Jayne Girardi Credit: This file is licensed under the Creative Commons Attribution-Share Alike 4.0 International https://creativecommons.org/licenses/by-sa/4.0/deed.en
Featured Image of Jim Wikes Credit: This work is free and may be used by anyone for any purpose. If you wish to use this content, you do not need to request permission as long as you follow any licensing requirements mentioned on this page.
The Wikimedia Foundation has received an e-mail confirming that the copyright holder has approved publication under the terms mentioned on this page. This correspondence has been reviewed by a Volunteer Response Team (VRT) member and stored in our permission archive. The correspondence is available to trusted volunteers as ticket #2011020710011594.
If you have questions about the archived correspondence, please use the VRT noticeboard. Ticket link: https://ticket.wikimedia.org/otrs/index.pl?Action=AgentTicketZoom&TicketNumber=2011020710011594
Find other files from the same ticket: SDC query (SPARQL)

Discover more from Exhibit (A)-List

Subscribe to get the latest posts sent to your email.

Evidence Vault: Erika vs Marco Marco Docs