A photo taken by the Illinois State Police in 2002, was made public by the government.
L. Thomas Lakin
Her 20th birthday present was a 12-inch square, two-inch deep plateful of cocaine.
So says the U.S. government in a motion to introduce evidence at an upcoming trial against former Madison County powerhouse attorney Thomas Lakin.
The government filed a motion Jan. 9, asking U.S. District Judge Phil Gilbert to allow it to introduce evidence pursuant to Rules 404(b) and 413 of the Federal Rules of Evidence, or alternatively, as intricately-related evidence involving 20 "Jane Does."
In a 36-page filing, the government claims that witnesses identified as Jane Does 7, 8 and 9 will testify that in late November 2001, "Lakin gave a plateful of powder cocaine, measuring approximately 12" x 12" x 2" to Jane Doe 7 as a birthday present for her 20th birthday."
Other evidence the government plans to introduce includes the testimony of a witness who saw Lakin and his guests use cocaine approximately 100 times between 1992 and 2005.
Lakin has been charged in an 18-count indictment that alleges he had engaged in sex with underage John Doe both before and after taking him to Malibu in May 2005. It alleges that John Doe declined Lakin's requests for oral sex in California but once they returned to East Alton the relationship continued.
The indictment also states that Lakin gave several females cocaine so they would engage in sexual activity with John Doe so Lakin could watch and masturbate after the minor declined further sexual activity with Lakin himself.
The indictment also seeks forfeiture of Lakin's property at 31610 Broad Beach Road in Malibu, Calif.
According to the motion filed Jan. 9, Jane Doe 5 would testify she witnessed cocaine being used by Lakin and others at his East Alton home approximately 100 times, most of which were between 1992 and 1994, when she was involved in a relationship with Lakin.
She would also testify that Lakin was aware others used cocaine at his residence and would also testify that on 20 or 30 occasions, she brought cocaine to Lakin's residence and shared it with him, the motion states.
Jane Doe 6 would testify that Lakin provided her cocaine at least 10 times when she was 15- or 16-years-old and would also testify that on numerous occasions while using cocaine and distributing cocaine to Jane Doe 6 and Jane Doe 20, Lakin asked them to engage in sex with each other in his presence and on one occasion, made threats of an economic nature to them if they did not have sex with each other, the motion states.
Jane Doe 6 would also testify that Lakin provided her with Xanax and Vicodin on numerous occasions in 2001 to "come down off of cocaine highs."
"Although these drugs were not charged in the Second Superseding Indictment, such distributions constitute evidence of intent and knowledge as to the drug counts because they were distributed and used in connection with the distribution of cocaine to help bring the user down from highs resulting from Lakin's cocaine," the motion states.
Jane Doe 9 would testify that Lakin told her that he could teach her how to perform oral sex, and later instructed her while she performed oral sex on him, the motion states.
"This is consistent with John Doe 8's anticipated testimony: Lakin said that he liked 15- 16 year-old girls because he could mold them and teach them," the motion states.
The other Jane Does would have similar testimony about Lakin providing them cocaine in exchange for sexual acts, the motion states.
John Doe 5, Lakin's former son-in-law, is also scheduled to testify if Gilbert allows the motion.
He is expected to testify that he saw cocaine and drug paraphernalia on several occasions at Lakin's residence during the approximately 10 years he was married to Lakin's daughter.
John Doe 5 would also testify that he and his wife were aware of Lakin's drug use and were reluctant to let their children spend time alone with Lakin at his home because of the drug use.
The government also wants to present evidence of a separate investigation of Lakin that occurred in 2002 at Lakin's home when he was out of town.
According to the motion, a female attendee of a party claimed that she had been sexually assaulted after having been given an unknown substance.
The incident resulted in an investigation by the Illinois State Police (ISP), the motion states. However, the investigation terminated when the complainant decided that she did not want press charges.
But as part of the ISP investigation, photographs were taken of Lakin's bedroom and bathroom and one of the photographs shows a leopard print robe.