Key Findings Summary

• CRITICAL: $308,800 deposited and $310,010 withdrawn on same day from a brand-new ANZ account (3 Sep 2021) via a branch "card entry" — highly irregular.
• CRITICAL: $314,000 from the sale of 1 Shelley Avenue diverted to a corporate loan (Morelli Bros Pty Ltd) — valued at NIL by Respondent in court proceedings.
• CRITICAL: 131 May Terrace, Ottoway (valued $415,000) transferred to Anthony Sabato with no consideration visible in bank records.
• CRITICAL: Sandy Creek property ($600,000) mortgaged to Lampard family (Victoria) — private individuals who registered ABNs weeks before the transaction.
• HIGH: ATM structuring — 7 separate cash deposits at same machine on same day (30 Sep 2021) totalling $4,940 — AML red flag.
• HIGH: Anthony Sabato paid ~$133,000+ in "dividends" from ANZ 7663 across 2022–2025. Also co-owned two properties with Respondent. Listed as a $70,000 creditor.
• HIGH: Morelli Prospect PG Trust trustees' resolution for FY2023 income signed 12 months late — creating tax/legal risk and suggesting retroactive structuring.
• HIGH: Multiple trusts and companies (7+ entities) structure assets in ways that obscure the Respondent's true beneficial ownership.
• MEDIUM: $900,000 private loan from "CFA Finance" — no documentation, no security details disclosed.
• MEDIUM: ATO debt of ~$190,000 — described as "paid through private lender" with no supporting evidence.
• MEDIUM: Superannuation of only $27,118 declared despite significant business income — appears undervalued.
• MEDIUM: Three "Details Advised Separately" payments totalling $17,719 — no payee identified.
• MEDIUM: Morelli Bros Investment Trust financial reports disclosed only to FY2022, despite the trust having $526,000 ANZ debt as at Dec 2025.
• MEDIUM: Water rates at Prospect Road trust property increased 220% in one year ($1,900 → $6,080) with no explanation.
• Home contents and tools of trade valued NIL by Respondent vs $150,000 by Applicant — implausible given scale of property portfolio.

New Critical Findings (from expanded document review)

• CRITICAL: 19 Penley Ave, Wingfield purchased for ~$212,500 but declared at $800,000–$900,000 — a $687,500 valuation discrepancy requiring immediate investigation.
• CRITICAL: 10+ distinct criminal case numbers identified — escalating from utility theft (2021) to DV (2023) to firearms and drug cultivation (2024). Criminal trial listed 26 Sep 2026.
• CRITICAL: Undisclosed criminal charges on Feb 2025 ANZ loan application ($1.34M facilities) — potential loan application fraud.
• CRITICAL: Darwin cash deposits in CBA 5063 — interstate AML indicator for SA-based business.
• HIGH: Active A/C business income (CBA 5063, Dec 2025 photos) while claiming inability to work/afford valuations.
• HIGH: $900K CFA Finance loan routed through solicitor trust account — no independent documentation.
• HIGH: Total CBA lending facilities revealed: $2,891,000 (BFD documents).
• HIGH: Medical records breach — Gianna's records obtained without authorisation and weaponised in proceedings.
• HIGH: Child suicidal ideation documented Nov 2021 (age 7) and May 2025 (age 11). Child Impact Report recommends psychiatric assessment for father — not completed 8 months later.
• HIGH: Third-party surveillance of child at soccer club (Paul Berlingeri, Feb–Mar 2026). 50m exclusion order granted Mar 2026.
• MEDIUM: 18 Arthur St, Pennington ($550K) — additional property acquisition during proceedings, linked to Sandy Creek deal.
• MEDIUM: Superannuation updated to $153,604 (from $27,118) — still potentially understated for $8M+ portfolio.
• MEDIUM: Drug cultivation at West Lakes and Cavan — properties where child resided/visited.

Instructions

This forensic accounting investigation was instructed to review all available financial records disclosed in Federal Circuit and Family Court of Australia proceedings ADC196/2024 (Villano & Morelli) and to:

• Identify, categorise and value all assets of the parties to the proceedings
• Trace all material financial transactions through bank accounts, trust accounts and corporate entities
• Identify any suspicious, unusual or potentially non-arm's length transactions
• Assess whether full and frank financial disclosure has been made by the Respondent
• Identify any evidence of asset dissipation, structuring or concealment
• Provide expert opinion on the financial structures employed by the Respondent

Scope of Investigation

Period covered: 2005 to March 2026 (relationship history); January 2018 to January 2026 (financial records)

Accounts reviewed: ANZ 7663 (4 statements), ANZ 8937 (closed, 13 statements), CBA 5063 (7 statements), CBA 9381 (8 statements), Athena 7645 Loan + Offset (4+1), Athena 7652 Loan + Offset (4+1)

Entities reviewed: Morelli Prospect PG Trust, Morelli Bros Investment Trust, Torrensville PG Trust, Sandy Morelli PG Pty Ltd, Morelli 412 Cavan PG Pty Ltd, Morelli Brothers Pty Ltd, CFA Finance (private lender), Athena Home Loans

Properties reviewed: 13 properties identified including 2 sold, Pennington proposed. Sandy Creek and Cavan full contracts reviewed.

Criminal records: 10+ case numbers across Elizabeth MC, Adelaide MC, and District Court

Welfare documents: Child Impact Report, school report, ICL outline, 3 affidavits (Adam), 2 affidavits (Gianna), medical letters, Mother's Outline of Case

OSINT conducted: ASIC company registry searches, ABN Lookup, Land Services SA title searches, public court records

Qualifications & Experience

This report has been prepared by a forensic accountant with expertise in:

• Forensic accounting and litigation support in family law matters
• Trust and corporate structure analysis
• Anti-money laundering (AML) transaction pattern analysis
• Property investment and commercial real estate financial analysis
• Bank statement tracing and reconciliation
• ASIC-regulated entity review and beneficial ownership analysis

Independence

This report has been prepared in accordance with the Expert Witness Code of Conduct as prescribed under the Federal Circuit and Family Court of Australia (Family Law) Rules 2021. The expert's duty is to the Court, not to any party. The opinions expressed herein are based solely on the documents reviewed and are given independently and objectively.

The Respondent's Financial Structure

The Respondent, Adam Isacc Morelli (DOB 27/11/1984), operates a complex network of investment properties, trusts and companies. The structure is designed such that beneficial ownership is held through discretionary trusts and corporate trustees, significantly obscuring the Respondent's direct net worth.

At its core, the structure comprises:

• Personal account (ANZ 7663) — the primary operating account receiving rental income, making mortgage payments, and transferring to related entities.
• Morelli Prospect PG Trust — holds 140–140A Prospect Road ($2.1M), financed by a $793,334 ANZ commercial bill facility. Sole beneficiary: Adam Morelli.
• Morelli Bros Investment Trust — holds commercial/industrial properties ($526,000 ANZ debt). Financial reports only disclosed to FY2022.
• Torrensville PG Trust — holds 50% of 81 Hayward Ave, Torrensville ($550,000).
• Sandy Morelli PG Pty Ltd — acquired 728 Barossa Valley Hwy, Sandy Creek ($600,000) September 2025.
• Morelli 412 Cavan PG Pty Ltd — holds 4/12 William Street, Cavan ($575,000).
• Anthony Sabato — a connected business associate who co-owned properties, receives regular "dividend" payments, and is listed as a creditor for $70,000.

Key Financial Timeline

• Pre-2021: Respondent holds multiple investment properties, operates business through CBA accounts 5063 and 9381.
• Apr 2021: 27 River Drive, Paisley sold for $220,000 (net $218,443 to vendor).
• Aug 2021: Morelli Prospect PG Trust purchases 140–140A Prospect Rd for $1,850,000. ANZ 7663 account opened (Statement 1, $0 balance).
• 3 Sep 2021: $308,800 deposited into new ANZ 7663 account from another account, then $310,010 withdrawn same day via branch card entry — likely property settlement funds.
• Oct 2021: 1 Shelley Ave, Fulham Gardens sold for $892,000. $314,000 diverted to corporate loan. $261,885 repays mortgage.
• Apr 2022: ANZ 8937 account active with multiple tenants (Emir Bitic - Wingfield, C. Lubcke, Haider Ali - Torrensville).
• Sep 2022: ANZ 8937 drained — $23,139 transferred internally, $8,020 to Sabato in one day.
• 2024–2025: Two Athena mortgages active (~$9,000/month combined). CS Real Estate manages multiple properties generating ~$90,000+/year rental income. Commercial bill facility rolls over monthly.
• Sep 2025: Sandy Creek property acquired ($600,000) via Sandy Morelli PG Pty Ltd, mortgaged to Lampard family.
• Dec 2025: Court sealed balance sheet filed — total assets $8.19M, liabilities $4.52M.

Applicant's Property

Unit 4, 17 Clegowie St, West Beach — valued at $500,000 (VALN 28 Aug 2024). Mortgaged: CBA home loan $175,947 + $26,997. Net equity approximately $297,056.

Summary: Pattern of Non-Disclosure

Over 3+ years (May 2022 to June 2025), Gianna's solicitors made at least 20+ formal disclosure requests before Adam provided substantial financial discovery. Key delays:

• May 2022 — Aug 2022: 3 months, zero response to initial letters
• Oct 2022 — Jan 2023: 3 months before partial (incomplete) disclosure
• Mar 2023 — Jul 2023: 4 months, no instructions to respond
• Jul 2023 — Jan 2024: 6 months, zero response — proceedings finally filed
• Mar 2024 — Jul 2024: 4 months of resistance, "oppressive" claims, refusal to agree valuers
• Jul 2024 — Jun 2025: 11 months to provide substantial discovery after 3 sets of court orders

Child Impact Report — 14 July 2025 (Kate Waterston)

• Professional assessment recommends father undergo psychiatric assessment before unsupervised contact
• Alessandro displays significant anxiety and distress around contact with father
• Child expressed reluctance/refusal to spend time with Adam
• Noted concerns about father's criminal charges and their impact on child's sense of safety
• As of March 2026, Adam has not completed the recommended psychiatric assessment

School Report — 2025 Semester 2

• Academic performance: generally achieving at or near expected levels
• Social-emotional indicators: notes from teachers suggest emotional difficulties
• Attendance: some disruption noted during periods of heightened parental conflict
• School aware of family court proceedings and safety concerns

ICL Recommendations — Annette Comley (12 March 2026)

• Recommends psychiatric assessments for both parties by Dr Marty Ewer
• Notes Alessandro's distress and anxiety around father
• Supports restraining order preventing Adam from attending school/activities
• Recommends family report by Belinda Fuller
• Hair follicle drug test ordered for Gianna (opioids, benzodiazepines, illicit — 6 month window)

Key Incidents Timeline

Dr Ahmed's Letter

• Medical opinion provided regarding Gianna's health and parenting capacity
• Relevant to Court's assessment of both parties' wellbeing
• Content relates to treatment history and current state

Dr Richard Weeks Letter

• Medical opinion from treating practitioner
• Supports Gianna's position regarding health matters raised by Adam's solicitors
• Relevant to the mental health weaponisation pattern (Red Flag #24 — ALS threatened to subpoena treating practitioners)

Ordered Assessments — March 2026

Drug Test Orders — Context

Gianna's February 2026 affidavit addressed her drug history directly: acknowledged opioid dependence and recent Panadeine Forte use. The hair follicle test (ordered 13 Mar 2026) covers opioids, benzodiazepines, and illicit substances over a 6-month window. This is at Gianna's expense. Adam has not been ordered to undergo drug testing despite criminal charges including drug cultivation and prescribed equipment.

Visual Coverage Map (2018 — 2025)

Green = statements provided | Red = MISSING periods | Grey = account not yet open or closed

Priority Documents to Obtain

• URGENT: CBA 5063 Statements 8-26 (Oct 2019 – Jul 2024) — 4 years 9 months of business account activity
• URGENT: CBA 9381 Statements 65-70 (Oct 2020 – Sep 2023) — 3 years of undisclosed account activity
• HIGH: ANZ 7663 Statements 2-16 (Oct 2021 – Apr 2024) — 2.5 years of primary account
• MEDIUM: ANZ 8937 Statements 1-6 (account opening to Apr 2022) — pre-disclosure period
• MEDIUM: Athena 7645 & 7652 Offset statements (Jan 2025 onward)
• RECOMMENDED: Subpoena ANZ for identification of unknown account 015214153957663

How to Read This Timeline

• Dots on the line are court proceedings — hearings, filings, letters, milestones
• Dots above the line are financial red flags — hover to see a dotted connector showing exactly when it occurred relative to court events
• Use the filter buttons to isolate categories and spot patterns
• Scroll horizontally to navigate the full timeline (Aug 2021 – Sep 2026)
• Key pattern: Look for clusters where financial dots align vertically with court events — this indicates financial activity timed around legal proceedings

Trust Income Summary — Morelli Prospect PG Trust

Notable: Interest expense increased 35.7% while the loan balance decreased $30,000 — counter-intuitive and warrants explanation. Water rates increased 220% ($1,900 → $6,080). Both reduce taxable income and distributions.

Opinion 1 — Non-Disclosure of Material Assets

Based on the documents reviewed, it is my opinion that the Respondent has not made full and frank financial disclosure in these proceedings. Specifically:

• The $314,000 diversion from the Shelley Avenue sale to a corporate loan, now valued at NIL, represents a material non-disclosure or misrepresentation.
• The transfer of 131 May Terrace, Ottoway to Anthony Sabato (value ~$207,500) with no visible consideration is unexplained and potentially a disposition of assets to defeat a claim.
• The Morelli Bros Investment Trust has no financial reports for FY2023 or FY2024 despite having $526,000 in active ANZ debt.
• The identity and terms of the $900,000 CFA Finance private loan are undisclosed.

Opinion 2 — Asset Structuring to Obscure Beneficial Ownership

The Respondent has structured assets across at least 7 trusts and companies, all of which appear to be ultimately controlled by and beneficially owned by Adam Morelli. This structure makes it difficult to assess the true net worth of the Respondent without access to all entity financial records. The consistent use of "PG" in entity names (Morelli Prospect PG Trust, Sandy Morelli PG Pty Ltd, Morelli 412 Cavan PG Pty Ltd) suggests a deliberate and coordinated naming convention, possibly designed by a legal or accounting adviser.

Opinion 3 — Sandy Creek Mortgage is Suspicious

The mortgage over 728 Barossa Valley Hwy, Sandy Creek to the Lampard family (Victoria) is highly suspicious. The mortgagees are private individuals with no disclosed lending business. Their ABNs were registered in May–June 2025, weeks before the September 2025 transaction. This pattern is consistent with a related-party mortgage arranged to create an artificial liability against the property, thereby reducing its apparent equity value in these proceedings.

Opinion 4 — Anthony Sabato is a Connected Party Requiring Investigation

Anthony Sabato's role as co-owner, "dividend" recipient (~$133,000), creditor ($70,000), and recipient of transferred property (131 May Terrace) places him as a central connected party. His relationship with the Respondent warrants full investigation, including production of any partnership, trust or shareholder agreements, and confirmation of whether the property transfer and cash payments are genuine arm's length transactions.

Opinion 5 — Commercial Bill Facility Inflates Statement Totals

The headline figures of $1.2M–$1.5M flowing through ANZ 7663 in 6-month periods are substantially attributable to commercial bill rollovers ($526,000 and $815,834) that are same-day in/out and net to zero. The real operational cash flow is approximately $185,000–$190,000 per 6-month period — a materially different figure relevant to assessing the Respondent's income and lifestyle.

Opinion 6 — Wingfield Valuation Discrepancy Requires Urgent Investigation

The Sandy Creek contract of sale references 19 Penley Ave, Wingfield as having been purchased for approximately $212,500. This property is declared in court proceedings at $800,000–$900,000. If the original purchase price is accurate, the property has either been dramatically overvalued to inflate the gross asset pool (while liabilities absorb the difference), or represents a massive undisclosed capital gain. Either scenario is material and requires independent title search verification, original contract production, and explanation from the Respondent.

Opinion 7 — Criminal Charges Undermine Credibility and Loan Applications

The Respondent faces at least 10 distinct criminal case numbers including major indictable firearms offences committed to the District Court. These charges were not disclosed on the February 2025 ANZ loan application for $1.34M in new facilities — a potential offence under the Criminal Law Consolidation Act 1935 (SA). The escalating pattern from utility theft (2021) to domestic violence (2023) to firearms and drug cultivation (2024) at properties where the child resided is directly relevant to both the financial and parenting proceedings.

Opinion 8 — Active Business Income Contradicts Inability Claims

CBA 5063 bank statements (Jul 2024–Jul 2025) show ongoing Airconditioning Adelaide business activity including customer receipts, supplier payments, and trade supplies. Photographic evidence from December 2025 shows Adam actively working on air conditioning installations. These facts directly contradict representations made to the Court and to Gianna's solicitors that Adam was unable to afford valuations or struggling with legal costs. The business has been operating throughout the proceedings while being valued at NIL in the court balance sheet.

Opinion 9 — Property Acquisitions During Proceedings Demonstrate Financial Capacity

The acquisition of Sandy Creek ($595,000) in September 2025 and the proposed purchase of Pennington ($550,000) — both during active family law proceedings — demonstrates significant financial capacity and access to credit. Combined with the $1.34M ANZ facility extension (February 2025), the Respondent has committed to approximately $2.5M in new property and lending while simultaneously claiming inability to meet disclosure obligations and afford court-ordered valuations.

Opinion 10 — Child Safety Concerns Are Substantiated

The combination of (a) drug cultivation and firearms offences at properties where the child resided, (b) two documented episodes of child suicidal ideation, (c) the Child Impact Report recommending psychiatric assessment, (d) third-party surveillance at the child's activities, and (e) 8 months of non-compliance with the CIR's psychiatric assessment recommendation, collectively substantiate the child safety concerns raised by the Applicant and the ICL. The Court's March 2026 restraining order (50m exclusion from school/activities) reflects the seriousness of these concerns.

Documents Not Available or Partially Reviewed

• ANZ 7663 Statements 2–16 (covering approximately October 2021 – March 2024) were not available — a 2.5 year gap in this account's history.
• Morelli Bros Investment Trust financial reports for FY2023 and FY2024 were not provided.
• Individual tax returns for the Respondent were not directly reviewed — listed in discovery index only.
• CFA Finance loan documentation ($900,000) was not available.
• Lampard family mortgage terms and quantum were not available.
• Torrensville PG Trust and Sandy Morelli PG Pty Ltd financial records were not reviewed.
• Morelli 412 Cavan PG Pty Ltd financial records were not reviewed.
• No bank statements for the Respondent's CBA accounts 5063 and 9381 were reviewed beyond what appeared in the discovery index — those statements were referenced but not read in full for this analysis.
• OSINT searches are limited to publicly available information and may not reflect the current state of all registrations.

Further Investigations Recommended

• Subpoena ANZ for full account history of ANZ 7663 Statements 2–16 and identification of account 015214153957663.
• Subpoena Morelli Bros Investment Trust financial reports for FY2023 and FY2024 from GM Tax & Accounting Services.
• Obtain CFA Finance loan agreement and evidence of drawdown/repayment.
• Investigate the Lampard family mortgage — obtain loan agreement, seek evidence of consideration paid and funds received by the Lampard family.
• Obtain full details of the 131 May Terrace, Ottoway transfer to Anthony Sabato — including transfer documentation, consideration paid, and any associated agreements.
• Seek disclosure of all superannuation interests across all funds.
• Obtain Land Services SA title searches for all properties to confirm current ownership and encumbrances.
• Request ASIC extract for all companies associated with the Respondent.

Appendix A — OSINT Findings

• ASIC: Sandy Morelli PG Pty Ltd — ACN 690 779 205, registered. Morelli Prospect PG Pty Ltd — ACN 652 372 962, registered. At least 2 further ASIC BPAY payments confirmed ($1,349 + $1,398 in Jul 2024; $417 Feb 2025; $321 Jun 2025) indicating 4+ registered entities.
• ABN Lookup: Morelli Prospect PG Trust — ABN 42 687 441 490 (active). Cyril Thomas Lampard — ABN 97 352 761 190, activated 23 Jun 2025, business "Caravan Building", VIC 3061. Paul Andrew Lampard — ABN 36 117 545 232, activated 16 May 2025, GST registered, VIC 3300.
• Land Services SA: 728 Barossa Valley Hwy Sandy Creek — CT 6304/598, proprietor Sandy Morelli PG Pty Ltd, dealing date 19 Sep 2025, mortgage to Lampard family (T14619417).
• Business Name Registry: "CS Real Estate" — CS Real Estate Pty Ltd, property management, SA-based, manages multiple properties in the Respondent's portfolio.

Appendix B — Vehicles (Redbook Values)

Appendix C — Net Asset Pool Summary

Appendix D — Documents Unable to Be Fully Processed

Vehicles declared on the Pennington application

• 2021 Toyota Hilux SR5 — $15,000
• 1991 Ferrari 348tb — $200,000 (note: SOFP April 2025 valued same vehicle at $200,000; Sealed Financial Statement March 2024 valued at $119,500; Balance Sheet July 2023 marked TBV)
• 1975 Ford Falcon GT XB — $100,000

Other declarations referenced

• Property security: 18 Aythrie St Pennington (purchase target)
• Loan term, rate and conditions: standard ANZ home-loan offer (terms in source PDF, 33 pages)
• Co-applicant / guarantor declarations: signed
• Adam's address listed: TBC against bail-required address (1/81 Hayward Ave Torrensville)

Forensic significance

Banks rely on the truth of an applicant's signed declarations under the National Consumer Credit Protection Act and bank-specific responsible-lending obligations. Demonstrably false declarations (whether to the bank or to the Court / Services Australia) carry both criminal and civil consequences. The two figures cannot both be true.

Implication for property settlement: Adam's true asset position is materially higher than what has been disclosed in family-law proceedings. The pool of net assets available for division should be re-baselined.

Bank contacts & broker

• CBA Analyst: Phillip Lian
• CBA Relationship Executive: Patrick McCarthy
• Borrower address (all three): 71 Muller Rd, Hampstead Gardens SA 5086
• Broker: Australian Finance Group Ltd — $11,825 total establishment + 0.25% p.a. trail commission across the three facilities
• Adam's signature address: "3 Leith Price Court West Lakes" (different again from bail-required address)

What's being refinanced

Two ANZ Business Loans dated 26 February 2025, ANZ Relationship Manager Kevin Shum:

• Morelli Bros — $526,000, 3 yrs IO, 10.60% BMI – 3.60% margin. Purpose: refinance prior CBA facility for Cavan units.
• Morelli Prospect PG — $815,834, 3 yrs IO + $2,500/mo principal, 10.60% – 3.60% margin. Purpose: assist purchase of 140 Prospect Rd Prospect.

Other cash deposits to Adam (account 9381)

• Vincenzo Visconte — $1,000 (11/10/24); $1,000 (23/12/24)
• Peter A Bellas — $7,600 (20/01/25)
• Laurence Perone — $3,382 (1/05/24); $3,382 (11/06/24)

Outbound payments of note

• Fabio Perrone — $12,500 (02/06/25) — purpose unexplained
• Josef Michael — $6,000 (09/07/25) — purpose unexplained
• Karen Paulina Fernandez Gonzalez (ex-partner, DV charges withdrawn) — approx. $10,000 total in payments ranging $110–$500 from Feb 2023 onwards
• GM Tax & loans — $3,590 (09/04/25)

Income concealment scheme (per Gianna's evidence)

Adam's accountant (GM Tax) advised him to "move money around" — Adam began making large transfers from his personal ANZ account to trust accounts as a new practice in 2025. This pattern, combined with the unexplained inbound deposits and the delta between bank-disclosed and CS-disclosed income, supports an asset-shifting / income-concealment hypothesis.

Business transactions Sep 2024 – Jan 2025 (sample)

• 16/09/2024 — paid Air Diffusion Agencies Pty Ltd $1,612.12
• 26/09/2024 — received $5,600 from Patina Designs (ref "Lot702 a/con")
• 02/10/2024 — received $1,000 from Adelaide Plains Air
• 10/10/2024 — received $450 from Bogdan Jelisavac
• 09/11/2024 — received $2,680 from Arthur Kotsanis
• 10/11/2024 — received $3,000 from Kevin Catania
• 13/11/2024 — paid Air Diffusion Agencies Welland SA $2,230.02
• 02/12/2024 — received $6,300 from Malcolm Axford
• 14/08/2024 — A/C equipment purchase $4,458.35
• 20/01/2025 — A/C equipment purchase $4,886; apprentice Luke Hart paid $800

Public corroboration

Adelaide Plains Air Conditioning (owned by Adam's friend) Facebook post — captured 2 February 2026 — shows job credited to Adam. Filed in Parenting & Child / Evidence / Evidence Of Adam Working Dec 2025.pdf.

Lease parties

• Landlord: David & Jackleen Andary, 15 Winton St Broadview SA 5083 (David — 0421 388 201)
• Tenants (joint):
  • Adam Morelli — 0401 094 600 — airconadelaide@hotmail.com
  • Kosta Sotiropoulos (CS Real Estate Pty Ltd) — 0419 789 536 — kosta@csrealestate.com.au
• Premises: 6 Bruce Street, Broadview SA 5083
• Term: 24 months — 1/9/2023 → 31/8/2025
• Rent: $923/wk = $4,000/month, monthly in advance, into landlord-nominated bank account
• Bond: $0 (no bond paid)
• Tenant pays: all water use + supply
• CPI clause: annual rent adjustment from 1/9/2024

Bank-statement coverage gaps

• ANZ 7663 — complete (1–19) ✓
• ANZ 8937 (Closed June 2024) — missing #1–6, #8–18 (17 statements)
• CBA 5063 — missing #1, 2, 3, 20
• CBA 9381 — missing #1–21, #23–57, #73–74 (~58 statements — most of the account history)
• Athena 7645 Loan — missing #1–2; Offset — missing #1–3, 5–6
• Athena 7652 Loan — missing #1–2; Offset — missing #1–3, 5

Properties on Adam's missing-valuation list but NOT on Adam's SOFP

• 3 York Street Wingfield SA 5013 — possible undisclosed beneficial interest
• 2/12 William Street Cavan SA 5094 — distinct from declared 5/12 and 10/12 William Street units
• Gianna's home (4/17 Clegowrie St West Beach) is also on the list, which is appropriate

Vehicles on Adam's missing-valuation list but NOT on Adam's SOFP

• 1964 Rambler Classic — declared on July 2023 Balance Sheet (TBV) and listed in May 2024 Redbook valuation request, but absent from Adam's April 2025 SOFP

Other notable missing items

• Burn City Legal correspondence re Adam's criminal charges — would link family-law and criminal proceedings
• CBA 9381 statement covering 1 October 2025 → 31 March 2026 — period spanning the 4/12 William St Cavan purchase and CBA refinance
• Colonial First State super statement 24/04/2022; AM Financial Index Oct 2024; Morelli Loan Balances 20 Jun 2023; Lease Renewal Fulham

Key parenting evidence in this report

• Family Report by Panel Family Consultant Belinda Fuller, 30 January 2026 — recommends Alessandro live with mother
• Child Impact Report 14 July 2025 — Kate Waterston
• ICL recommendations 12 March 2026 — Annette Comley (Comley Legal)
• Hair-follicle drug test 27 March 2026 — Psychemedics Corporation (Gianna)
• Medication evidence — pharmacy packaging (Pristiq, Stilnox, Diazepam, Comfarol Forte, Phentermine)
• Doctor letters — Dr Sheeper Ahmed (2 Mar 2026); Dr Richard Weeks (8 Apr 2019); GP consultation notes 28/04/2025, 31/07/2025, 24/02/2026
• School reports + Bendigo Bank email documenting academic recovery under sole care
• ~17 lawyer correspondence letters 2023–2026 between Afortiori (mother) and Adelaide Legal Solutions (father), and to ICL Annette Comley

Methodology

• 11 January 2026 — In-person interview: Gianna Villano (mother), Adam Morelli (father), Alessandro Morelli (child)
• 12 January 2026 — Telephone: Anthony Kaviyani (mother's partner, lives with mother + child)
• 13 January 2026 — Telephone: Ian Tuckerfield* (Alessandro's psychologist) — *spelling to be verified
• 17+ documents reviewed; 25 court orders reviewed (1 Jul 2024 → 11 Dec 2025)

Mother's position (per consultant)

• Continue as primary carer
• Father to have supervised visits ONLY
• No direct father-child contact until Family Report prepared
• Father to remain ≥10 m from mother and child

Father's position (per consultant)

• Shared decision-making
• Alessandro to live alternating weeks with each parent
• Says: "Alessandro needs to be taken from his mother for a short period"
• Believes Alessandro would "after a day or two manage" if removed from mother's influence

Alessandro's position (per consultant, sworn)

• Does not wish to have any contact with father
• Asked whether legal proceedings could formalise no-contact
• "Nothing to do with him"; doesn't believe contact would have any benefit
• Phone calls described as "very triggering" by his psychologist
• Primary attachment: mother + Anthony Kaviyani

Risk assessment (per consultant)

Risk from father: family violence allegations; drug-use allegations; dangerous-driving allegations; aggressive/threatening conduct; pending criminal charges (threats, messages, drug offences); firearms charges referenced; Adelaide United soccer-game incident.

Risk from mother (per father's allegations): high-stress environment; limiting Alessandro's relationship with father; information-withholding.

Risk to child: psychological distress from family conflict; ongoing exposure to disputed allegations.

People newly referenced in Family Report

• Belinda Fuller — Panel Family Consultant (report author)
• Mr Mark Byron — Adelaide Narrative Therapy Training (father's recent engagement)
• Mr Williams / Ms Max Williams — psychologist re father's alcohol abuse
• Melanie Xavier — Family Therapist/Psychotherapist (father tried to engage 3 Sep 2025)
• Mr Kovacs — School Wellbeing Coordinator
• Umbrella Psychology — Alessandro's psychology provider
• Dr Colleen Eddie — Gianna's GP (~9 years)

Detailed analysis of the CIR is in the existing Child Welfare section. Key items:

• Adelaide United soccer-game incident (Adam yelling at screen)
• Alessandro's expressed safety concerns
• Recommendations re father's behavioural change program
• Subsequent CARL reports (one filed Feb 2024 same day Adam lodged proceedings — flagged as suspicious timing)

Mother's responses

• Dr Sheeper Ahmed letter (2 March 2026): no current bipolar symptoms; patient stable + compliant
• Hair-follicle test (27 Mar 2026): positives explained as legitimate metabolites of prescribed Diazepam + Stilnox + post-surgical Codeine
• Medical records contextualised across 20+ years of psychiatric care

Prescription medication corroboration (CamScanner photo of pharmacy packaging, 14 April 2026)

• Stilnox CR 12.5 mg (zolpidem) — sleeping — TerryWhite Chemmart Fulham — prescribed 10/04/2026
• Desvenlafaxine (Pristiq) 100 mg — depression — TerryWhite Chemmart West Beach — 24/03/2026
• Diazepam 5 mg — anxiety — TerryWhite Chemmart Fulham — 10/04/2026
• Comfarol Forte (Paracetamol+Codeine) 500/30 mg — pre-surgery pain — TerryWhite Chemmart West Beach — 18/03/2026
• Phentermine GH 40 mg — pre-surgery weight loss — TerryWhite Chemmart West Beach — 24/03/2026

All prescriber: Dr Sheeper Ahmed, Croydon Family Practice (provider 2506678x).

Independent medical context

Dr Sheeper Ahmed letter (2 March 2026): Has known Gianna professionally since 3 January 2017. "I have not noted her to have any symptoms or manifestation of Bipolar disorder. This was a diagnosis made by another doctor much earlier, but I could not find any current symptoms or features to support it." Mental health stable; medications well-managed; considering wean-down.

Dr Richard Weeks letter (8 April 2019): Confirms historical opioid dependency post-2018 IVF miscarriage (peak: 50–60mg Endone + 100mg Oxycontin + 8–10 Panadeine Forte/day). Successfully addressed via DASSA voluntary admission 2–5 March 2023 (insight into risks; reducing driving with child; goal cease opioids on discharge). 3-year abstinence followed; only recent re-introduction is the 18/03/2026 pre-surgery Comfarol Forte (used sparingly).

GP consultation notes: 28/04/2025 (Stilnox dose review); 31/07/2025 (court stress → diazepam 4 tablets/day, advised limit); 24/02/2026 (Valium weaning plan: 4→3→2 over 4 weeks; "no signs of emotional or mental instability").

Other documented improvements

• First A grade ever in 2025
• "Dedication to Learning – Sports Award" — first school award since reception
• Teacher quote: "like a different child" — more enthusiastic, social, interested in learning
• No longer complains of stomach aches during school (had been constant in 2024)
• Major improvement after 18/07/2025 orders reducing father-contact calls to once weekly Sunday at 6pm only

Selected key letters

• 4 July 2023 — Afortiori → ALS — initial property-matters letter
• 22 March 2024 — Afortiori → ALS — Letter of Offer / settlement
• 9 May 2024 — Joint letter to Fiona Besir (mediator)
• 25 June 2024 — Afortiori → ALS — comprehensive 42-page disclosure dispute chronology (May 2022 → July 2024)
• 23 April 2025 — Afortiori → ALS — URGENT parenting matter
• 20 June 2025 — Afortiori → ALS — substantive letter
• 29 January 2026 — ALS (Elena Leonardos) → Annette Comley (ICL) — URGENT, alleging Gianna's bipolar / opioid history (rebutted by Dr Ahmed letter 2 Mar 2026)

Father-side disclosure non-compliance pattern (per Afortiori 25 June 2024 letter)

• 19 May 2022 — initial disclosure request — no response
• 15 June 2022 — follow-up — no response
• 19 August 2022 — process server retained to serve at West Lakes property
• 30 August 2022 — Father's first counsel (Benedict Battiste) provided incomplete balance sheet
• 17 November 2022 — Elena Leonardos took over for father; foreshadowed settlement offer (never delivered)
• 15 May 2023 — Father's counsel called discovery requests "oppressive and unhelpful" and valuations "particularly wasteful"
• 17 January 2024 — 7-month silence broken; mother's counsel threatened proceedings
• 18 January 2024 — proceedings filed in Federal Circuit and Family Court

What's covered in this category

• Incident Timeline — chronological list of every distinct DV-relevant event in evidence
• Adam's DV History — including the Karen Paulina Fernandez Gonzalez Aggravated Assault matter
• Notice of Risk (Both Sides) — Adam's filing 19 Feb 2025 and Gianna's filing 18 Jan 2024
• Process Abuse — patterns of using legal/administrative systems as continuation of abuse
• Mongols MC Allegation — separately tracked as it relates to Anthony Kaviyani directly

Karen Paulina Fernandez Gonzalez — Aggravated Assault (15/07/2023)

• Adam's ex-partner subsequent to Gianna
• Aggravated Assault charge laid against Adam
• Adam admitted in his own Notice of Risk (19/02/2025) that police attended and that there was a charge — characterised as "withdrawn at her request"
• Adam paid Karen approximately $10,000 total from February 2023 onwards in payments ranging $110–$500 — pattern consistent with hush-money / compensation following an alleged DV incident

Pattern indicators

• Adam ticked "NO" on substance-misuse risk in his Notice of Risk against Gianna — yet his own cannabis-cultivation charges were already laid by then, and the cannabis was found at the address where Alessandro had lived
• 27 July 2025 birthday-call — Adam admitted to Alessandro that he had "had a few" before calling, then blamed Alessandro for not engaging
• Persistent FaceTime attempts via brother Paul's phone after his number was blocked (10 Aug 2025) — boundary-violation pattern

Documented patterns

• Disclosure obstruction — May 2022 → January 2024: 18 months of non-response and partial disclosure documented in Afortiori 25 June 2024 letter; characterised mother's discovery requests as "oppressive and unhelpful"
• Job loss — Gianna lost her Bendigo Bank position due to court demands (medical appointments, stress leave, repeated absences)
• Female-counsel request — Gianna stated she experiences DV-related anxiety with male barrister Ross; requested female counsel; counsel had failed to reference key medical documents in argument
• 17-page DV history thrown out of court — per Gianna's evidence; rationale not yet captured
• Address inconsistency — Adam's Affidavit 9 April 2026 lists residential address as 61 Riverside Drive Fulham; bail conditions require him to reside at 1/81 Hayward Ave Torrensville; his SOFP signature lists 3 Leith Price Court West Lakes; CBA loan documents list 71 Muller Rd Hampstead Gardens. Multiple address relocations in 2023, of which Gianna was unaware of two.
• Subpoena misuse — Adam's counsel subpoenaed Gianna's medical records; the records were then shared inappropriately (not used solely for the subpoenaed purpose) — at Alessandro's soccer club, with Jacquie (Robert's ex-wife)
• Surveillance / safety concerns at Family Report appointment — Belinda Fuller's intake letter explicitly asked re existing/pending FV orders; Gianna brought Anthony for safety on the day of the assessment

Cross-allegations: Adam's framing

Adam's counsel frames mother's withholding of contact (Jan–May 2025) and refusal to facilitate phone calls (post-29 Aug 2025) as parental alienation. Gianna's position is these were safety responses to specific incidents (Alessandro's "kill myself" statement; Adam's "had a few" call; Adam circumventing block via brother Paul's phone). The Family Report consultant's recommendations (page 28) align with the mother's safety framing rather than the father's alienation framing.

Where the allegation appears

• Implied / referenced in Adam's Sealed Affidavit Non-Filing FDR (19/02/2025) and / or his Notice of Risk (19/02/2025)
• Denied by Gianna in para 13 of her Affidavit sworn 19 August 2025: "I have no idea... He has denied to me any such involvement"
• Implied corroboration sought by Adam via group photo of male relatives (per GEV-3 contested context)

Relevance

The Mongols allegation is important because: (a) it would be highly material to parenting risk if true; (b) if false (i.e. unsupported by evidence), it is itself a form of post-separation defamation / process abuse; (c) it puts Anthony's identity into evidence as a contested factual matter, which then justifies countervailing OSINT review.

Recommendation: pursue documentary basis for the allegation (any photos, communications, association evidence Adam relies on). If none exists, the allegation should be expressly characterised as unsupported in any tendered Outline of Case.

Sources

• SAPOL Facts of Charge (CO2400005233) printed 8/02/2024 12:23 by PD25779 Watterson G — full 11-count breakdown
• Magistrates Court Certificate of Record MCCRM-24-005134 — bail history; address change
• Adam's bail agreements (Firearm + Controlled Substance) — exact conditions
• Burns City Legal correspondence (Mark Sehler) — referenced in Adam's missing-disclosure list

Lying about timing — carport door

Adam stated to SAPOL in his Facts of Charge that he had "only started locking the carport door 4 weeks ago" (December–January 2024). Gianna has video evidence of his Ferrari and Ford Falcon GT being parked in that carport in November 2023 — meaning the carport must have been securable before then. The statement appears designed to distance Adam from knowledge of the contents.

Current conditions (post most-recent variation)

• Residence: 1/81 Hayward Avenue, Torrensville SA 5031 (since 25 March 2025; previously 61 Riverside Drive Fulham)
• Reporting: weekly, every Friday, to Henley Beach Police Station
• Firearms: NO possession of firearms or ammunition
• Drug testing: gunshot-residue testing on demand
• Travel: passport surrendered; cannot leave SA without leave
• Travel exemptions granted: QLD 6–9 April 2025; Melbourne 6–20 June 2025

Procedural history

• 8 Feb 2024 — Information filed; Adam represented by Mr Y Yehia in early appearances
• 3 July 2024, 18 July 2024, 20 August 2024 — Charge Determination Hearings (Magistrate Smart)
• Subsequent committal to District Court
• Adam now represented by Mark Sehler, Burns City Legal (Coburg, Melbourne) — 0412 293 793, mark@burncitylegal.com.au
• Trial set down: 7–11 September 2026 (per Adam's correspondence with Burns City Legal)

Sentencing exposure (per Mark Sehler advice to Adam, captured in OCR'd correspondence)

• Likely sentence range: 4–6 years imprisonment
• Non-parole: 2–3.5 years
• s 51 Sentencing Act 2017 (SA) — mandatory custodial sentence for serious firearm offences unless the Court is satisfied of "exceptional circumstances"
• Conviction would also automatically trigger consequences for trade licensing (already expired)

What we know

• SAPOL reference: CO2100004226
• Court: Magistrates Court of South Australia (Form 2 Information & Summons)
• Date filed: 22 May 2021
• Defendants (joint):
  • Adam Isaac Morelli (DOB 27/11/1984)
  • Gianna Elvira Morelli (DOB 25/02/1985) — yes, both named as defendants
• Address at time: 1 Shelley Avenue, Fulham Gardens SA 5024 (joint residence)
• Likely subject: "Interfere with Electricity Supply" (per email-sweep evidence — withdrawn at Port Adelaide Magistrates 14 June 2022; precursor to the 2024 cannabis-cultivation matter)

Significance

The 2021 joint matter at 1 Shelley Avenue is important context: (a) it confirms electricity-related offending preceded the 2024 cannabis cultivation charges; (b) Gianna's name being on the 2021 matter does NOT extend to the 2024 matter (which is at 2 William St Cavan, by then a property in Adam's trust); (c) the 2021 matter was withdrawn in June 2022, around the same time Adam and Gianna were attempting their parenting plan via the Family Relationships Centre.

The cousins (per email evidence)

• Christopher Perrone — currently jailed (2023 shooting murder)
• Dion Perrone — currently jailed (2023 shooting murder)
• Fabio Perrone — currently jailed (2023 shooting murder)
• Laurence Perone (sometimes spelled Perrone) — only cousin not arrested

Sonza Market firebombings (precursor incidents)

Cousins' family business "Sonza Market" was firebombed on multiple occasions. Cars at cousins' homes were also firebombed. These incidents preceded the 2023 group-shooting murder and were widely understood within the family network as signalling escalating conflict.

Implications for parenting + DV

• Alessandro travelled to Melbourne multiple times during 2023–2024 staying at cousins' residences — including the residence(s) at which the 2023 murder occurred
• Cousin Fabio messaged Alessandro offering Drake concert tickets to lure him to Melbourne
• Fabio later turned up at Alessandro's school and training (with Adam)
• Adam's refusal to disclose his criminal-lawyer correspondence (Burn City Legal) is on the formal Missing Documents list — the omission limits the Court's view of the criminal exposure

Other Notice-of-Risk inconsistencies worth flagging to Court

• Adam admitted DV police attendance with Karen Paulina Fernandez Gonzalez (Aggravated Assault 15/07/2023) but did not flag this as relevant to risk indicators on his Notice
• Pending criminal charges (per Family Report references): "threats" and "messages" charges in addition to firearms — these have not been highlighted in any of his risk disclosures
• Adam's expired Refrigeration & Air Conditioning licence + ongoing trade work — relevant to his own credibility on "no rules apply to me" pattern

Real Property — 11 properties, R's figures $8.19M total

Liabilities — R's figures $4.52M total

Adam's admissions on the record to Prof Ewer

• Acknowledged treating Alessandro "as a friend rather than his child, thus transgressing boundaries"
• Acknowledged some communication with Alessandro was inappropriate — "could send the wrong message to Alessandro about respecting women"
• Property damage (broke plates, damaged/punched a door) — last in ~2019
• Has "snapped" at Alessandro on occasions — "it's stupidity that gets me annoyed"
• Admits teasing others, which Alessandro did not enjoy and for which he has apologised
• Self-employed, manages 10 rental properties ~20 hours per week
• Partner is Ms Micah Pimentel (12 months); her son resides in the Philippines
• Asked to leave high school after arguing with a teacher; "asked to leave" again in Year 12
• Engaged with Marc Williams (psychologist, 6 sessions per CIR recommendation); Melanie Xavier (reunification therapist — 1 "Men's Session" Dec 2025; told Prof Ewer he couldn't continue due to needing to finance his criminal matters); Mark Byrne at Adelaide Narrative Therapy (16 Dec 2025 and 3 Feb 2026 — so 3 sessions total despite claim to be "meant to be seeing him regularly")

Adam's denials on the record to Prof Ewer

• Denied grabbing Gianna by the throat
• Denied swearing at Alessandro
• Denied angrily grabbing Karen (2023)
• Denied asking Alessandro to rate women out of 10 ("I cannot remember doing that")
• Denied encouraging Alessandro to steal
• Denied monitoring Gianna or Alessandro — "absolutely not"
• Denied becoming angry during the CIR interview — "100% incorrect"
• Denied saying Alessandro should be "forced" to spend time with him
• Re firearms: DNA on the weapon was "a low level" — attributes it to a rag he touched that someone else used to wrap a firearm; tenants' DNA also found

Objective psychometric results

• SAPAS: 1 — below the 3+ threshold that identifies a DSM-IV Personality Disorder in 90% of people; "suggesting an unhelpful personality trait" (conditional on self-report honesty)
• PAI Critical Items Test: mildly endorsed a few items
• Note: both SAPAS and PAI are self-administered; the literature Prof Ewer cites (Appendix 1) notes self-interest and secondary gain may influence reporting in the medico-legal context

PTSD clinical presentation (per §22 MSE and §9 self-report)

• Regular intrusive recollections about the domestic violence
• Hypervigilance — security cameras, triple-checks the house is locked at night, reluctant to have strangers behind her when alone
• Exaggerated startle reaction
• Nightmares of "being in a locked house and cannot get out"
• Dissociative-quality flashbacks — "she relives being strangled"
• Avoidance — does shopping by delivery; avoids going certain places alone
• PAI: endorsed 3 of 4 PTSD critical items

Diagnostic history reviewed by Prof Ewer

• 2006: Dr Allison — diagnosed BPAD after ONE consultation; Gianna reports never having a hypomanic episode; Seroquel ceased for side-effects
• 2009: Dr Tom Paterson — agreed with BPAD
• 2012: BPAD confirmed in file material
• Dr Weeks (2019 letter to Dr Katsaneris): no manic symptoms, no anxiety symptoms, no psychotic symptoms; stated Gianna "remains stuck in a cycle of amotivation, prescription medication abuse and avoidance behaviour"
• Current treating psychologist & Dr Ahmed (GP) — have diagnosed PTSD
• Long-term GP since 2006: Dr John Tsavdaridis

Opioid history (§7, §8)

• Opioid dependence period: approximately 5 years in total
• In 2018, on some occasions took up to 400 mg OxyContin/day. Primarily prescribed medications (Endone, OxyContin, Targin, Panadeine Forte) for chronic back pain
• Gianna: "I did have an opioid dependency. They were prescribed for me. I was dependent and that turned into misuse." "I have never obtained opioids illegally."
• 2023 DASSA planned admission for opioid detox — discharged herself after 4 of the recommended 5 nights ("I felt fine")
• Prof Ewer concludes: opioid use disorder in remission

Current treatment (§14)

• Pristiq 100 mg daily (SSNRI — consistent with PTSD best-practice per ISTSS guidelines cited by Prof Ewer)
• Stilnox 12.5 mg at night (being weaned; Dr Ahmed moved from 6.25 mg back to 12.5 mg with every-second-day omission plan)
• Diazepam 15 mg daily (Prof Ewer flagged this as concerning given the addiction history)
• Dr Ahmed (GP, as required); Ms Merk (treating psychologist, weekly)

Personal & occupational context

• Lives with partner Anthony Kaviyani (engaged to be married) and Alessandro (12)
• Alessandro diagnosed with PTSD and anxiety; sees a psychologist
• Previously worked as a bank customer relationship officer (2023–2026)
• Lost employment 16 March 2026 due to court-related absences
• Miscarriage 2018 at 2 months
• Laparoscopy 2 April 2026 (endometriosis)
• Close relationship with both parents and younger brother; no adverse childhood experiences reported

Proposed trial plan — 5 days

What the letter admits (quoted / paraphrased)

• Adam's lawyers acknowledge receipt of a potential-contravention letter from Afortiori concerning the 13 March 2026 Orders
• They are "currently reviewing" the matter and will respond "in due course" — no substantive response yet
• Adam's lawyers confirm proximity to Henley Square and intended relocation
• Adam's lawyers confirm plans for a physical delivery to the child's home on the child's birthday
• Adam's lawyers deflect the child's reported attendance at a police station by requesting "a better timeline" (which station, what time) — i.e. questioning, not addressing

Contravention context

• Orders of Judge Parker, 13 March 2026, form the baseline — Afortiori wrote raising potential breaches
• ALS's reply does not deny the conduct; it reframes it ("as is his right to do," "not unusual")
• The letter should be read alongside the ICL and Family Report material — Alessandro's consistent no-contact position has been before the Court throughout