IN THE CIRCUIT COURT OF MOBILE COUNTY, ALABAMA
SARALAND CITY BOARD OF
EDUCATION and AARON MILNER in his
official capacity as Superintendent of
Saraland City Schools
Plaintiffs,
vs. Case No.: 02-CV-2022-901899
JOHN QUINNELLY, SR., ERIC
WINBERG, and WINBERG, LLC
Defendant.
AFFIDAVIT OF ERIC WINBERG
1. My name is Bric Winberg and I am the owner and operator of Winberg
Investigations, LLC. I am over the age of 19 years, am fully competent to testify to, and have
personal knowledge of the matters set forth herein.
2. On or about August 8, 2022, I was contacted by John Quinnelly, Sr. and engaged
to conduct surveillance on the Lj Family with particular emphasis on the residence at SII
K QE , Daphne, Alabama 36526 (“Daphne residence”).
3. John Quinnelly, St. informed me he had reason to believe the Lg] Family was
still residing at the Daphne residence despite representations they had made a bona fide move to
Saraland, Alabama school district in April 2022.
4, T-condueted video, photo, and in-person surveillance of the residence between
August 8, 2022 and October 18, 2022. During that time, I regularly observed [I] URI at the
residence during daylight hours. | occasionally observed Mr. Lf with his young children during
these daylight observations.5. On October 20, 2022, I prepared a summary of my investigation efforts (“Report”)
based on the information I had been provided and provided my Report to John Quinnelly, Sr. per
the terms of our agreement. While I was aware Mr. Quinnelly may share my Report with the
AHSAA, I had no expectation my Report would be shared with and I never authorized Mr.
Quinnelly to release my Report to any third party or media outlet outside of the AHSAA.
6. Prior to preparing my Report and submitting it to Mr. Quimnelly, I was not aware
Mr. Lf operated a business out of the Daphne residence. Accordingly, I concluded that Mr.
LU may still be liv
7. Recently, I became aware Mr. Lig operates a dog kennel and breeding business
1g at the Daphne residence based on Mr. LgMJ’s regular presence there.
at the Daphne residence. Based on my understanding of Mr. LlMI's business operation, I cannot
conclude that Mr. LJ lived or resided at the Daphne residence during the time of my company’s
investigation,
8. Moreover, based on my understanding of Mr. LPs business operation, my
investigation efforts cannot conclude Mr. Lig was ever at the Daphne residence during the
surveillance period for anything other than legitimate business purposes.
9, As the owner and operator of Winberg Investigations, LLC, based on the
information I and my company now have, I cannot confirm nor deny that the Lagggy Family, and
specifically IIE have violated any AHSAA guidelines or regul
Further the Affiant sayeth not.
ERIC WINBERG.STATE OF ALABAMA
COUNTY OF BALDWIN
I, the undersigned Notary Public, in and for said County and state, hereby certify that ERIC
WINBERG, whose name is signed to the foregoing instrument, and who is known to me,
acknowledged before me on this date that, being informed of the contents of the instrument, he
executed the same voluntarily on the date that same bears date.
Given under my hand and Official Seal on this 31" day of October, 2022.
¢ Vp Utes
Notary Public
My Commission Expires: 4¥/¢/ 292
CLARA LL, HAYES
Notary Public:
Alabama State at Large