Friday, May 3, 2013

Transcript: Juan Martinez Closing Arguments in the Jodi Arias Trial (videos)

(This is a work in progress, thank you Chris Murphy for your excellent help in transcribing. Note! The first video in the player below is jury instructions, those have not been transcribed. Prosecutor Juan Martinez begins his closing arguments in the second video.)


Click here for defense closing arguments
Juan Martinez delivers closing arguments on May 2, 2013, in the Jodi Arias trial







Juan Martinez: This individual, um, the defendant Jodi Ann Arias, killed Travis Alexander. And even after stabbing him over and over again, and even after slashing his throat from ear to ear and then even after taking a gun and shooting him in the face, she will not let him rest in peace.

But now, instead of a gun, instead of a knife she uses lies. And she uses these lies in court when she testified to stage the scene for you. Just like she staged the scene for the police, after she killed Mr. Alexander. And this woman, who would stage the scene, has even attempted to stage the scene through the use of the media. She has courted the media, she has gone on national television. You've seen the programs and you've seen some of the  -- her words to the media. She has also attempted, or gone out in search of the limelight. She has signed a manifesto, just in case she becomes famous. And to top it all off, she has indicated that she is innocent. That no jury will convict her. That none of you, will convict her, after she has staged the scene for you.

Well, she is an individual, as you have seen, who has craved the limelight. So, it seems that it is only fitting, that this individual that has craved the limelight, it is really only fitting that she now bask in a different kind of light: the light of truth.

And in the light of truth, you can see who she really is.

She's an individual, who is manipulative. This is an individual who wants to play the victim, even though there is no abuse as you heard from those that know her. She's an individual that, according to her own statements in an email on Valentine's Day of 2007 to Mr. Alexander said that she was destructive. She's the individual that talked about what she did to doors, what she did to windows. And she's an individual that does not appear to be very nice to her mother. Because she lashes out at her and strikes her physically. Additionally, when the light of truth is shining on her, she is somebody who -- it's just an individual that manipulates people. That for example, when she's speaking to Mr. Alexander during that fateful May 10, 2008, conversation, that she talks about her sister and says how dumb and stupid her sister is.

This is an individual who is manipulative. This is an individual who will stop at nothing and will continue to be manipulative and will lie at every turn and at every occasion that she has.

One of the examples is the issue of the gas cans. She indicated to you from the witness stand and looked at each and every one of you, after having taken the oath and said, "Yeah, I bought the gas can alright, and I bought it from the Salinas Wal-Mart. I did buy it from the Salinas Wal-Mart, but you know, [after being questioned by the prosecutor] I took it back, and I received cash."

Yet, you heard from Amanda Webb, the individual -- woman -- who works for Wal-Mart checked each and every single register, even those that were not geared to give refunds, checked each and every single register. And each one of those registers indicated no -- there had been no such refund.

Then of course you have the confirmatory action in Salt Lake City, after first indicating that, 'No, I've never been in Salt Lake City, I never put gas in Salt Lake City,' but you saw the receipts that she had. And not only had she put gas into her car in Salt Lake City, she had two other transactions. One for 5.09 gallons of gas and then one for slightly under 10 gallons of gas. She looked at each and every one of you, this person, and attempted to manipulate you.

Well, this individual, that attempted to manipulate you, believes, based on what we've heard, that even though she may have engaged in actions, she may have done certain things, none of it -- absolutely none of it -- is her fault.

Why could it possibly be her fault?

If you look back in her history, which is the important part of it involving her relationships with men, what do you see?

Well, even when she was young, she had this personality of manipulating the facts. Back when she was with Bobby Juarez, what did she tell you? 'Well, this was an individual that was unfaithful to me.'

'How could he be so unfaithful to me after I've done so many good things for him?' 'I tried to buy him clothing, I bought him food. I even lived in a trailer that was so bad it was infested.'

'Never mind that the reason that I moved there was because I was skipping school -- no, that wasn't my fault at all!'

'No, no no, I was doing this for Bobby and how does he repay me even though it wasn't my fault?'

Well, you know what -- he goes and he talks -- he sent letters to another woman over the Internet.

And, it isn't her fault that she found out about it, of course not. How could it be her fault that she found out about it, if the library doesn't have enough security attached to that particular computer? To have some sort of device attached to it so that somebody can't come along and hit that backspace button, so that whatever was using it before...maybe one or two or three or four people before that somebody could just come along and hit that backspace button.

And it's eerily reminiscent of what she told you happened in February of 2007, when after she and Mr. Alexander began dating that she went on to his computer and began to hit that same backspace button. It's not her fault that computers have not been improved since the 90s or the two thousand. So that you can't stop hitting that backspace button. It's not her fault that that happened. Of course not.

That's what she told you from the witness stand.

And so, according to her, she hits the backspace button and there is this conversation between Bobby Juarez and somebody else. But that's not her fault. But if you remember how aggressively she reacted to that. Nobody was going to do anything to hurt or nobody was going to be putting her or slighting her, or putting her in a position of feeling inferior if you will. She immediately went to Bobby Juarez and did something about it.

There is a pattern because the same thing happened with regards to Matthew McCartney -- the person that she jumped to after she and Bobby Juarez started to have problems. And I do say jump to because when she was dating Bobby Juarez, he moved away to Oregon. And when he moved to Oregon, he started living with a guy by the name of Matthew McCartney. When things soured with Bobby Juarez, she immediately went with Matthew McCartney. And in terms of that relationship, the reason that that broke up, it's not her fault.

Just like it wasn't her fault in regards to Bobby Juarez. It wasn't her fault at all that she had these issues with Matthew McCartney. No, she can't help it if she is a good worker. She can't help it if she's working as a waitress and people come by when she's working as a waitress and try to tell her things about her boyfriend Matthew McCartney. She can't help that?

That's what she wants you to believe. And again, isn't that reminiscent of what happened involving Mr. Alexander? It seems that this is reciprocal and it seems that the story repeats itself. It repeats itself, because she's lying. And it repeats itself because she's trying to manipulate you. Through all of the days that she spent talking to you from the witness stand after she had taken an oath.

Well, she gets to the point where she moves to Palm Desert in California, to be with an individual by the name of Darryl Brewer. And of course when she's there with Darryl Brewer, it's not her fault again, that the relationship is souring. No, not at all. It's not her fault because well, Mr. Brewer doesn't want to marry her.

What's a girl to do? It's not her fault. She's got to look for another guy. And it appears that he doesn't want to have any kids and she does. So again, it's not her fault. How could it possibly be her fault that somebody has free will? It's absolutely not her fault. That's what she tried to tell you. But resourceful as ever, resourceful as ever. She's always been this person who is manipulative, she starts looking around for somebody else. And decides that perhaps, those boys from the Mormon faith are a pretty good catch, because those boys, they have a lot of family values. And these boys think work, they seem to be very successful, they just seem to have everything that she desires in a husband, so that she can breathe.

And so, what she decides to do is to look for one of those boys. And to Travis Alexander's misfortune, he was that boy.

He was that boy, back in September in 2006, when he was at that PPL convention, yearly convention. Yes, he is the individual that went up to her, and they began to talk. And such is the way that things began between the two of them. She wanting to find a boy just like him, because she had an ulterior motive. She wanted somebody that was Mormon, she wanted somebody that could give her a child, so this seemed like the perfect catch for her.

And, although she tells you that, 'Well, he kinda was the person that pushed her into this relationship, and that he was the individual that somehow was in her'..that in the lexicon of the English language there's a word it's called, 'No,' that you can use when you don't want to do something, and yet, you can then take the witness stand; however, and say, 'Well, I do know that word, but I just chose not to use it.'

But, it's not her fault that, again, it's not her fault,  it's Mr. Alexander's fault for being interested in her, don't you see.

Can't you all see, based on those days and days that she was on that witness stand that it isn't her fault?

She was thinking though, or at least that's what she told you, this person, who told you also about the gas cans, over and over again, she kept saying, with regard to each and every single repetitious sexual act, with regard to each and every one of them -- those-- 'No. I was thinking no.'

Really? That's exactly what you were thinking? Did you ever communicate that to him? No.

This, from a woman who is manipulative. This from a woman who pretends to be the victim, even though there is no abuse.

And so, throughout this early part of the relationship, which some might call the honeymoon portion, during this part, it appears that they do what two people that are young and involved in a relationship do -- they engaged in relations. But there's this finger-pointing aspect to this relationship. As portrayed by the defendant.

Can't point the finger enough at Mr. Alexander. Can't point the finger enough at the fact that you know -- he's a bad Mormon, because he's having sex with her.

If he's such a bad Mormon, why stay with him? You're the one that chose him, if he's such a bad guy, why are you hanging out with him?

And to compound things, well, she's also Mormon too.

Why does she keep pointing the finger at him, when she is just as Mormon as he is? She converted in November of 2006. And according to Deanna Reid, there are many classes that tell you about the law of chastity, and they tell you about the law involving sexual intercourse. But wait...it's not her fault. How could you possibly think it was her fault, when those three or two Mormon missionaries came over and didn't tell her about it.

Again, it's not her fault. Although there are all these classes where they talk about it. No, let's point the finger at Travis Alexander because according to her, he's the bad guy, he's the one who told her that it was okay, and so she's going to go along with what he says, even though, those in the Mormon church are telling her otherwise. It is almost unconscionable for her to point the finger at Mr. Alexander when she's in the same situation as he is. She has the same knowledge that he does, but again, she wants you to feel sympathy, because again, it's not her fault. But you know, how could it possibly be her fault when she was thinking no.

Well, luckily for Mr. Alexander, I guess, in the beginning, this relationship was from a distance. And I say luckily, because at least when she was in Palm Desert and he was in Mesa, Arizona, during that time, at least during that time, she couldn't reach out and stab him. She couldn't reach out and shoot him in the face.

She couldn't stalk him. Couldn't come over unannounced, she wasn't living ten minutes away. At least fortunately, during that time Mr. Alexander had some extra time to live. And during that time, they were not mutually exclusive. So yes, it is appropriate, when they are not mutually exclusive for an individual to send text messages to other women if they are male or even if they are not. There's nothing wrong with that.

But if you see that long finger pointing from the witness stand to him, "How could he possibly, when we were together, how could he possibly, before we became exclusive, be talking to other women. How could he be on the Internet, how could he be sending text messages.'

But it's okay, don't you see, when she goes to his memorial service (talking about Travis Alexander's memorial service) after she killed him, it's okay for her to talk to somebody on the airplane, to get a telephone number. It's not her fault, that this guy was trying to pick her up. Of course it's not her fault. And what's a girl to do after all?

The guy that she was involved with up and died after she stabbed him, slit his throat and shot him. What is she to do?

Can't you see that it really isn't her fault?

At least that's what she wants you to believe.

And during this period, Mr. Alexander did see her, and during this period, Mr. Alexander did engage in sexual contact with her. There's nothing, absolutely nothing important about that as it applies to the killing. Other than trying to manipulate you, trying to shock you in saying, 'Oh my gosh look at this guy, he wants to kiss her and he wants to do other sexual things that other people do in their private lives.'

He doesn't want to talk about it for God's sake, and he doesn't want other people to know what it is that they are doing. Why would he want anybody to know what he is doing sexually with women. Is that something that is courteous in this society to do? It's just the opposite. But she has now turned the world sideways for you to look at that in an attempt to manipulate you.

Well, they continue on with this relationship, and she lives out in Palm Desert. At some point, in February of 2007, after this issue involving the February 14, mailing that she indicates she receives, uh, after that they make, the relationship if you will, exclusive.

What's interesting about the email from February 14, 2007, and you saw that, is not only does it talk about her violent tendencies, it does talk at length about that, but it also talks about other things, and you have it there for your review, this February 14, 2007, email. And one of the things that it doesn't talk about is the package that she supposedly received in the mail that day. Take a look at the time...it's around 4:30, 5:00 in the afternoon. I guess they have mail that's really slow there in Palm Desert.

Never mentioned the unholy underwear, these underwear, these spider man underwear, that so shocked her. Doesn't mention these chocolates, 'Thank you for sending those to me.' Doesn't thank him at all. The reason she doesn't thank him, and the reason that she doesn't mention it, 'cause there was no such delivery.

But of course, that's something that can't be verified, except that there's this inconsistency. And it starts showing that this individual will make things up, but she forgot, she forgot about that February 14, 2007, email.

And you know, short of the old saying with the truth you ain't got to remember nothing, at least you have to give her credit for having an incredible memory. Well, an incredible memory as to the fantasy world that she wants to create for you. Just like that delivery of the underwear. Can't show them to us, well, I hope she threw them away, but she took pictures of some other things, and this email was sent out at a time where she would have already received the mail. But after that, she and Mr. Alexander continue on. And they, she comes over later on in the month of February. And when she comes over in February, one of the things that happens, is that she's extremely happy, or at least that's what she tells you. That she's happy, because one of the things that she now knows is that -- well, she and Mr. Alexander are together.

If she is so happy, if she is somebody that really wants to be accepted, then why prey tell, does she need to go into his computer and hit that backspace button. That's such an oh..such an irritation to her, that these computers should have this   back space button. It's not her fault that she can't keep her hands off of his computer, it's really his fault because he's alive, he's a breathing human being who has social contact with other people: men and women.

And how dare he, when they are not exclusive, how dare he attempt to spend New Year's Eve with someone. He should really be alone in his house, or in some hut somewhere, alone. How dare he do that, but it's not her fault that she found out. At least that's what she wants you to believe.

Well, they continue this dating, and they continue both involved in this Pre-Paid Legal. But the story doesn’t get any better. What we’re able to glean or find out from the history of that is that it doesn’t get any better. And, ah, one of the things that starts to happen according to her is that she starts feeling something. Of course her feelings are so important. And rather than talk to Mister Alexander about it, rather than say “Oh I have these issues, I’m a little concerned.” What does she do? Well they’re on vacation. And when they're on vacation and it depends on the story that she tells, the one to Brian Burns or the story that she told to you from the witness stand. Take your pick. Because there are many to pick from. But it depends on the story that you believe.
During that time she goes on and she gets a hold of his text messages and goes through all of them ostensibly while he’s either asleep or taking a shower. Take your pick. And while he’s doing that, she goes through it and finds some text messages. But it’s not her fault. She’s not wrong in invading his privacy at all. How could she possibly be wrong about invading his privacy when she had feelings? And those feelings confirm the fact that he was a social human being.

That’s what in part that she liked about him, that he was very charismatic, that he was very nice, and that people liked him. That’s part of the reason why she liked him but, oh no, not when it comes to other people.

And she talked about him having sexual rendezvous with these other people. But that’s quick, if you will, on the sly and very slow on the facts, very low on the facts. You don’t have any individual that they could even point to a name.

Kirk Nurmi: Objection, Your Honor. Burden-shifting.

Judge Sherry Stephens: Overruled.

There was no name that was even pointed out that [he] even had any sexual contact with at that time. But she felt it, so according to her, that justified it. This person with this borderline personality disorder.

And so as a result of that, she says “That’s it. We’re gonna break up. And we’re done with this. Except that I’m so hurt, I’m so absolutely hurt.” she said.

You can almost feel it oozing through those fake tears that were supposedly coming from her from the witness stand. You could almost feel this. And what you could feel of course was “Yeah, yeah, yeah I’m really hurt except, let’s go on vacation. Let’s go ahead and go on vacation anyway. Even though I know all about this. I’m so hurt that I would rather go on vacation with you and enjoy it. And let’s continue going on vacation.

Yeah, that’s her way of manipulating him, that’s a way of not letting go of something that she wants. She wants to curb his free-will and when he doesn’t want to do that, well, she’s got something else coming for him. She is not going to let him get away that easily.

And so she starts engaging in this conduct. So what else does she do? She does what every person who has caught their boyfriend, according to her, being unfaithful. What does she do? She moves close to him. Moves from California to Arizona, specifically to Mesa, very close to him after they have broken up in the end of June 2007. That’s what she does.

Well, now this is when the stalking begins. Well, maybe it was a little bit before that when she’s going into his telephone. Or maybe it was before that on the first day that they decided to make this official when she started to go into his computer.

It is clear from the relationship that there was a Stalking behavior from the very beginning.

And so, she moves here to Mesa. If they are not dating, if they have broken up, why is she here? It’s not her fault, don’t you know? It’s not her fault because he’s so persuasive. He talked her into coming out here. That’s why she came out to Mesa. And it’s again it’s this thing that she can’t say “No”.

Just like whether or not they’re going to engage in this sexual conduct. Can’t say “No”. And in this particular case, according to her, and Mister Alexander’s not here to maybe dispute this, according to her she moved here because he was the one that told her to do that. Even though, according to her, at this point she had broken up with him.

And what does she do when she comes out here? Well, rather than dating, rather than becoming involved in some sort of social scene in the Mormon Church or finding friends and that sort of thing. Nope. She does something else. She begins to be more attentive - that’s the word - she begins to be more attentive to Mister Alexander. Perhaps if she’s more attentive to Mister Alexander, perhaps then he’ll want to come back and have her be the only one.

And the way that she’s attentive is the way that everyone does it normally. I mean, she goes over to his house unannounced at night, sometime around in August of 2007, and this is what everybody does. And she goes over there and starts peeping in a window, to see what it is that he is doing. And she goes over there and by the light of the television, if you remember there was this go around by the light.

Well, it may have been the light of a television but now it’s the light of truth that we are looking at things and what she was doing is she was invading his privacy by coming over and peeping in the window.

And that is Stalking behavior, irrespective of what Alyce LaViolette has to say.

This individual, Alyce LaViolette, who had problems with the truth when she spoke to you about how many times she had testified on behalf of men. This individual who, quite frankly, misrepresented that to you when she was testifying.

But according to Alyce LaViolette that was no big deal. Because that’s what a person does. She [Arias] came over, started to look inside and low and behold, it’s not her fault that she has vision. So she starts looking in there and low and behold there he is.

Yes, there he is, he’s kissing another woman. Like that is the end of the world.

So what? So what that he’s kissing another woman? He’s not seeing her, he’s entitled to do it. And he’s entitled to do it, he’s in his house. He has no lights on. It’s a romantic evening. Whether she likes it or not, he’s moved on.

And yes, she says, it’s his fault. He shouldn’t have been courting me. He shouldn’t have been continuing to have sex with me. She could’ve said “No”. She could’ve left. She could’ve moved back to California. She could’ve never come out here in the first place.

She’s the person who starts stalking him.

And so, she says “Oh I was so upset.” And she starts talking about the brassiere, whether it was unhooked or not and we went around and around about that. So what?

Well don’t you know? He’s a Mormon boy - they’re not allowed to do that.

What does she care? Is she the Mormon Conscience? Is that what this, what we have going on here? No, she’s not anything like that. But she wants to make it seem like it’s his fault.

She presented in a way to manipulate your perception, because she’s trying to take away from him what lies the only thing he has left. And that’s his reputation.

He’s not here to talk about it, and so it’s an easy shot for her.

But at this particular point, she’s the person that starts to stalk him.

And after she starts stalking him or after this event of stalking, she doesn’t leave it alone. No, she comes over the next day because she’s in the right. They’ve broken up and it’s okay if you’re broken up to come over and peep at your ex-boyfriend’s house and then in peeping finding something, and then wanting to get an explanation.

What possible explanation could he ever have owed her at that point?

Oh, and, you know she didn’t write about that’s the first incident of domestic violence, didn’t write about that incidence of domestic violence. Don’t you know? Because, well she’s a nice person.

And you know there’s this Secret that she’s watched, this movie involving The Secret that talks about the Law of Attraction. And this Law of Attraction says that you lie. That’s exactly what they want you to believe.

Now they’re starting to justify the lies. It’s okay to lie in a journal, which in a sense is saying lie to yourself because the Law of Attraction says it's okay to lie. Absolutely okay to lie. You don’t put down exactly what’s going on and so you don’t write about this.

Actually what’s going here is that she’s making it up and there’s no corroboration of any incident whatsoever.

And so this “relationship”, if you will, if you want to call it that, continues. And there are more, um, exploitive, sexual kinds of things that are presented. And that she, you are regaled with the most intimate details that you can possibly think of.

And every time it was “Well, I was uncomfortable, but I didn’t want to tell him no. It was just uncomfortable.”

Wait a minute. But she also sent him text messages. And those text messages indicated that she was not uncomfortable. She’s the one, and I don’t need to repeat it, you remember those text messages – where she’s the one that requesting the sexual acts.

She’s the one that's saying to him “If you’re good, this is what’s going to happen, and then I’m going to want something else.”

So she’s the individual that, if you look at the corroborative, the independent evidence that we have, she’s the individual that is in this as much as he is. There is no indication that he was ever forcing her to do anything, anything at all.

But you know, she’s attempting to manipulate you – by saying “Well, yeah, I went along but I really didn’t want to.”

And with regard to these acts of physical violence, “Well, they weren’t so bad and I didn’t write about them.” And with regard to any particular physical act of violence, there’s no one that knows about it.

There’s no one that’s seen any bruises. There are no police calls to 911. And she has a reason for that. The reason that she didn’t call 911 involving Mister Alexander is because she had a similar experience with Bobby Juarez. And when she had that similar experience with Bobby Juarez, well she called 911 and you know what, those 911 people in California, can’t trust them because they talked to Bobby Juarez and as a result of talking to Bobby Juarez, well they didn’t come out and so I was so soured by that circumstance that I just never decided to call 911.

She’s trying to provide a justification as to why there are no 911 calls. The reason why there are no 911 calls is because it never happened.

Everything in this case points to the fact that it did not happen. There are no medical reports, there are no friends, there is no one that can come in and say anything about that. There are no medical records, there’s absolutely nothing to the contrary.

What is it you have? Well, on the day in March of 2008 when she told Mister Alexander, according to her, that she was leaving, um, he turned around and he hit her. And according to Alyce LaViolette he slapped her but the Defendant went round and round and said no it was the back of the head, the side of the head, it depended apparently on a whim as to where he hit her.

But, if you take a look at the entry for that particular day in March of 2008, “You know I told him, he was so upset. And, he didn’t want me to leave because, you know, we were both so in love with each other” – what she writes. And then she says “Oh he kissed me, so tenderly three times. They were such wonderful tender kisses.”

Is that what she means when she is talking to you about domestic violence? Kissing – see that’s the problem – you didn’t get it the first time. Kissing is domestic violence. Tender kissing is domestic violence.

But then you bring an apologist like Alyce LaViolette and you say No, no, no, no, no, that’s not what it means. You need to go behind this diary here. Those words don’t mean what they say. You need, for example, a little cheat sheet that tells you that under the Law of Attraction, that’s not what it means. Under the Law of Attraction it means just the opposite. It means that he did hit her. Can’t you read that? Is it.. “What is wrong with you…?” almost is the way it’s being put to you “…that you can’t see that? That you can’t buy, or can’t be manipulated.

And the other thing that we have is that she claims that on January 22nd of 2008 there was also this act of domestic violence. And that is not what the act was at this point because there’s no corroboration involving that act of domestic violence either. All we have is a journal entry of January 24th of 2008. And in that journal entry of January 24th of 2008 she writes “You know, as far as January 21st, 22nd, and 23rd, nothing noteworthy happened.” Not only do we have the diary relating to that, it says “nothing happened”.

But again, you are being asked to take a leap. You are being asked, such, as in the gas can example, to think that everybody else is wrong, and she’s right.

And in that example, the one involving the 24th and the supposed incident of domestic violence on the 22nd, you are being asked to say “Nope. Something noteworthy did happen on the 22nd of January. And the thing that was noteworthy on January 22nd of 2008 was that he beat me. And this is the time that I had my hand up. And this is the time he came after me.”

But it doesn’t say that. Not only is there no corroborative evidence that could be presented, it’s to the contrary. She herself said that it didn’t happen. But she wants you to go back and say “Well, don’t look at what I wrote. Look at this clue, this Law of Attraction. Take a look at that, combine that with my words, combine it with what Alyce LaViolette says” - we’ll add that in there – “and once you do that you will be able to see and you will be able to know that hey, you know what? He did, he did abuse me.

And right before she leaves in April of 2008 she says that another incident happened. And she doesn’t tell anybody about it? And she still stays at his home, and off she goes.

And what’s interesting about these acts of domestic violence is that she was very specific as to form. But again, you know, the truth – it’s very hard to keep it straight. With the truth, you ain’t got to remember nothing – but if you’re not telling the truth, if you’re trying or attempting to manipulate, you do have a lot to remember.

She forgot that there’s a psychologist by the name of Cheryl Karp that has previously been involved in this case and had conducted an evaluation of the Defendant.

And during that evaluation with the Defendant, she gave many - not four - many – ten, fifteen, twenty incidents of physical violence. Because at that point, physical violence was being used as the predicate, if you will, the seminal act for Post Traumatic Stress Disorder. That’s what she was looking at at that time. And so of course. Let’s have a lot of acts of domestic violence.

Kirk Nurmi: Objection, Your Honor. The facts not in evidence.

Judge Sherry Stephens: Overruled. The jury is directed to recall the evidence presented during the trial. You may continue.

And so you now have this, lots of acts of domestic violence that she doesn’t tell you from the witness stand. Compared to before that she does tell you.

Which one is true? The only evidence that you have indicates that none of it is true, because she can’t keep it straight.

And she’s attempting to manipulate the evidence to fit the goal that she has at that particular time.

With regard to Cheryl Karp at that time, according to, ah, Janeen DeMarte, one of the things that was going on is that Cheryl Karp found that Post Traumatic Stress Disorder of the Defendant involved these acts of domestic violence, these many, many acts of domestic violence. Not just four.

And so now when they want to talk about things in a different vain, or a little bit differently, it’s not just all these acts, it’s only four.

And that’s the problem with the presentation and her attempt to manipulate you. It’s actually not even an attempt to manipulate you. They’re lies. That’s what they are.

And she forgot, perhaps, about speaking to other people and the statements that she made with regard to that.

Well, she does move away. And when she does move away, it’s almost as if we’re talking about light, almost like a ray of sunshine for Mister Alexander.

One can only imagine that his Stalker is now far away. Because she had done other things while she was here. One of the things that we know is that she would come over unannounced. One of the other things that she would do is she would get into his accounts and there also this incident involving Christmas and being underneath the Christmas tree.

There’s all these incidents. Perhaps Mister Alexander can let his guard down at this particular point because he really doesn’t have to deal with her on a daily basis.

And yes, there is some contact between them on May 10th of 2008. And this is the infamous phone call that involved sex. And actually that telephone call is very important because you can actually hear how she deals with him, even though he doesn’t know, based on everything that’s in the recording, that he’s being recorded.

She says “No, it was being recorded pursuant to his request, don’t you know?”
Really? Why was it being recorded at his request? He can’t listen to it. So what possible benefit is this call going to be for him?

If he’s recording it, he’s not going to get it. There’s absolutely no benefit to him on May 10th of 2008 to have that telephone call recorded. Yes, he said some things on there. But this is supposed to be, from his perspective, a private conversation never to be released to anybody, between him and this woman, that even though she’s moved to Yreka, even though they’ve broken up, even though she’s come over and watched him with another woman. Even though all of this has happened, she stalked him. Even though all of this had happened, well he’s going to continue talking to her on the telephone.

And he says, and he tells you the reason why. And the reason why is that he enjoys having sexual contact with her. And he gives you the reasons why, and he gives you some specific features that he didn’t do before, but that he does now.

He talks about how she introduced him to certain things. How that was such a good thing. How it opened his horizons to that particular aspect. And so he’s giving her credit for opening his eyes sexually.

And there’s nothing wrong with that. And there’s nothing wrong with the conversation. What is wrong, or what appears to be wrong is that one of them is recording it without the knowledge of the other.

Kurt Nurmi: Objection. Facts not in evidence.

Judge Sherry Stephens: Sustained.

You’ve listened to that recording, you can draw your own conclusions as to whether or not you believe he knew or believed that this was something that was being recorded.
She says “Oh no, I kept hitting the save button. I was the one that did it. And she kept it. And she kept it all the way from May 10th of 2008.

But things were not going so well at that point. And in fact by May 19th of 2008, just nine days after that, Mister Alexander is on the computer, this instant messaging service, with somebody named Reagan Housley.

And he’s talking to her and he says “I’m extremely afraid of Miss Arias, because of her stalking behavior."

How prophetic of him? Back on May 19th, and this is nine days after this telephone call. But he’s extremely afraid of her because of this stalking behavior.

Little does he know that he has less than a month to live.

And so he is aware of it. He’s in the best position to know what is going on between the two of them because he’s the one that’s going through it. And so when he makes that comment, that comment is indicative of what is going on.

You can have people like Alyce LaViolette say “It’s not true.” And the reason, and we have to give her credit, is that the reason Alyce LaViolette knows that is that she can read minds through the past. She can travel back to May 19th 2008 and know what Mister Alexander was thinking, don’t you know?

She’s the apologist for the Defendant. She’s the one that can really set you straight. It’s not the Defendant that manipulating you, no, no, no. If you take a look at that statement, Mister Alexander was making it all up. Wasn’t true. He was just saying it. Because you know and another part of the instant messaging, they were saying “ah ha.. hi Jodi read this”.. or words to, whatever it is they were saying. And so the Defendant doesn’t want you to pay any attention to that. But that certainly goes, and it’s the beginning of pre-meditation. Her pre-meditation to kill him.

Back on May 19th of 2008. He indicates that "I’m extremely afraid the Defendant because of her stalking behavior." And who would know better than him?

Especially since he’s the one that’s had to deal with her coming over, peeping in his window. He’s the one that’s had to deal with her showing up unannounced.

He’s the one that’s had problems, or damage to his car according to Lisa Andrews. And he’s the one that has her underneath the Christmas tree. And has had a ring stolen by her. So he would know that.

And so then, what ends up happening is that some time passes. And May 26th shows up. One of the important things about May 26th is that, that is the day they break up. And much is made by the Defense that well during much of these conversations he’s mean to her. Well why wouldn’t he be mean to her? Yes there are names that people are being called, that’s correct, there are not any nice names. But he is extremely afraid of her stalking behavior on May 26th when those names are called.

And there is anger that is being exchanged back and forth and he sort of capsulizes it by saying, or using a term that’s not quite so sexual, but really capsulizes what’s going on here and how the Defendant attempts to manipulate the truth, when he says “I am nothing more than a dildo with a heartbeat to you.” That’s what he tells her, because that’s how he feels. That’s how she makes him feel.

And yes, he uses all of those other words but he is also very derogatory about himself. He knows what’s going on. Every time, according to that statement, whenever she wants him, the way that she manipulates him is through sex. He does make that comment. And that comment was made on the 26th of May in that Instant Message.

But you don’t ignore what else is going on, on the 26th of May of 2008. On that prophetic day he also tells her something else in Exhibit 450 – She’s apologizing to him. Again she’s manipulating him. She does something, she apologizes, and everything is supposed to be okay.

But by this time, he has had enough. And he says “I don’t want your apology. I want you to understand what I think of you.” That’s what he’s telling her. He’s telling her that he wants her to understand what it is that he thinks of her. He says “I want you to understand how evil I think you are.” At that point when he’s writing that he is extremely afraid of her because of her stalking behavior. And he does think she’s evil.

And, how prophetic, looking at these next words, how prophetic, how absolutely prophetic – no one can dispute that those are the truest words that are spoken in this case, and they’re spoken by Mister Alexander, even though he is not here, through his writings.

“You, Jodi Arias, are the worst thing that ever happened to me.” Any doubt that that’s the truth? Do we need to look at the pictures of his gashed throat? Do we need to look at the sort of frog- like state that she left him in, all crumpled up in that shower? Or do we need to look at his face where she put that bullet in his right temple - to know that what he says there is true. “You are the worst thing that ever happened to me.” He’s telling her “Enough is enough.” And yes, he’s angry. Absolutely angry after everything that she has done to him.

And you’ve seen the manipulation as she has tried to manipulate you with what she has told you. And the prime example is these gas cans. No one can argue that she lied to you.

Well he’s had enough. And yes, he says “You are the worst thing that ever happened to me.”

And then he says, in this Exhibit 450, “You are a Sociopath.” No, he does not have a Psychology degree. But that certainly expresses a feeling about what she says, what she does, and how she deals with him, how she always is manipulating him. It teases this anger out of him and tries to mix in the sex and he says “You only cry for yourself.”

Well, you saw her crying on the witness stand. Can anybody debate the reason she was crying is because she cries for herself? After all, she never intended to be caught. She said that so herself after she lied to the Police. “Oh no, I was saying that because I did not want to be caught.” And so, you only cry for yourself.

And then he [Travis] says “You never cared out me”, supposedly that could be ‘for’, “and you have betrayed me worse than any example I could conjure.” She has betrayed him. For whatever reason he believes that she has done something that is, that is absolutely horrific. And he’s telling her “I’ve had it. I’m done with you.” And again, this is May 26th. He’s done with her. “You are sick and you have scammed me.”

Again, she has scammed him. Are you going to allow her to scam you? - is really the question from this text message. Are you going to buy the lies? Are you going to believe what she tells you?

And so, we get to May 28th. Just two days afterwards. Just two short days afterwards begins the plan, if you will. Just kill him. And planning takes preparation. And there’s no doubt that this woman is a very intelligent woman. And she tries to cover up her bases. And yes, she could go out and buy a gun, but you know, if you buy a gun, one of the things that she indicated in California was that there was a waiting period, and they take your name. According to her that’s something that she knows. Well, let’s get a stolen gun. She lives with her grandparents in Yreka and she knows that they have, she knows that her grandfather has guns and she knows where he keeps them.

So on May 28th of 2008 she starts the planning.

She starts the actual steps, or begins the actual steps to this journey that will take her to Mesa, Arizona to kill Travis Alexander.

There is no other explanation than that. She’s the one that stole that .25 caliber gun, this very small gun that according to her, looks like a toy. This small gun.

And on May 28th, at a time when she’s living there, there’s a burglary that is reported at her Grandparent’s house. And low and behold, it’s so amazing - and again this is the manipulative aspect of this case and the Defendant – it is so interesting that this burglary of the house – it’s kind of weird, it’s kind of strange, it’s kind of special – because these burglars were meticulous. They wanted to leave the impression that this was a burglary throughout the house. So they went through four rooms, and from each of the rooms only one item was taken.

And where the guns were? You saw. There was some money there. But these burglars didn’t want money, they just wanted the gun. And they didn’t want any kind of gun, they wanted a special gun, a small gun, because there were rifles there.

If a burglar comes in, he’s not going to be very discriminating: “Ah, you know, yeah, I’m just going to take this little gun. I don’t want to take the money, it may be too heavy. These other guns are too big, I’m not going to be able to carry them down the street.”

That’s not the way a burglary happens.

“And oh after I’ve taken one item from here, I’m going to go ahead and go to another room, and after looking in this other room I’m only going to take one item from there, and then I’ll take a total of four items.”

If you’re going to do that, if you are a burglar, then why? Why even waste the time of committing a burglary? The only thing that makes sense with regard to the burglary, is that the burglar - the person who went in there - is right there.

It’s Jodi Ann Arias. That’s the burglar. And she needs a gun. And she needs a gun to kill Travis Alexander. And she gets it. And guess what? It can’t be traced. There’s this burglary report after that. No one can say it’s her. Well, at least not initially no one can say it’s her.

But on May 28th, she began to take these steps after he [Travis] has told her in that May 26th 2008 text message that he had enough of her.

And so what does she do as part of that? Well, she then says “If I go there to Arizona, you know money is tight, there’s an issue with money, one of the things I’m probably going to have to use is my credit card. If I go to Arizona, if I fill up with gas. So I’ve got to make sure that people don’t know, if I’m going to carry this out, that I’m going to be in Arizona. Because I can’t be linked to Arizona in any way, shape or form. And certainly using a credit card is going to link me to Arizona. And so, well, why don’t I call Darryl Brewer.”

You could tell from the time that he testified that he still had feelings for her. In fact, when he was asked about this issue about the gas can he actually paused if you remember, and he gulped, and he said “Oh yeah, she did call me. She called me at the end of May.” May 28th is the end of May when this gun is stolen by the Defendant from her grandparent’s home. “Yeah she did call me then and she told me she was going to Mesa, she was going to Arizona.”

And Alyce LaViolette has the same thing in her notes, that according to Darryl Brewer, the Defendant called him at the end of May and she was going to Mesa, Arizona and needed gas cans. And Alyce LaViolette, even in her notes indicated “I thought that this was an unplanned visit.” Even in her notes, there are issues. But the Defendant’s attempting to manipulate the truth. But there are issues with regard to this because she’s telling Darryl Brewer that she’s going there. Even her own expert says “Hmmm, there’s a little bit of an issue here, there’s a problem for me, because I thought you said that you were not going to Mesa, that you were going to Utah.” Or is Utah just nothing, anything else but more than a ruse?

You can say you’re going to Utah, You can have a sexual dalliance, not an extreme one, but a sexual dalliance with Ryan Burns, you can adjust him, and nobody will be the wiser. Because nobody will ever know that you were in Arizona, because guess what? You never filled up anyway. You never put gas in the car.

Well, okay, that’s what she does. She calls Darryl Brewer in the end of May, first part of June and she gets these two containers. Two five-gallon cans for gasoline and they were empty. Wasn’t like they were full. And he [Brewer] lives in the Monterey area and she leaves on June 2nd. Well, when she leaves, she doesn’t take her car. She decides to rent a car.

And she has told you “Well, I rented the car out of Redding, California. And the reason why I rented the car out of Redding, California” – which is approximately 90 miles south of Yreka – “is because Priceline did not offer this same deal in Yreka. Priceline only offered it in Redding. And that’s why I went ahead and did it that way. It wasn’t that I didn’t want people in Yreka to know what kind of car I was renting because heaven forbid if they knew I was renting this car they could, it could come back to me. And of course I don’t want to be identified in killing Mister Alexander so I’ve already made provisions for the gas cans, now I’ve got to make provisions for the car.”

And so she says that’s the reason why she goes to Redding, California. Except that the documents show something else. Exhibit 523 is the statement from Washington Mutual from June one of 2008 to June thirty of 2008. And this is the statement that she, the Defendant, authenticated on the witness stand.

And in fact, what we have here is the Budget Rent-A-Car. See it? June 9th, Budget Rent-A-Car up in Redding, California. That’s what we’re talking about.

But if you also remember, after she killed Mister Alexander, she came to the, uh, Memorial. And she flew down there. And if you take a look at down here, there it is – see that? She paid $246.99 and that was to Priceline.com and it says Air.

[Quoting Arias] “Hmmm. This Priceline, they have to get their act together here. Yeah, yeah, at one point, when it comes down to the flight, yeah, yeah, I pay them. But when it comes to the car, even though I go through Priceline I got to pay for the car. And how is Priceline ever going to get paid if they don’t take their money up front for the rental car. That’s how it works. They get their money upfront.”

Kirk Nurmi: Objection, arguing facts not in evidence.

Judge Sherry Stephens: Overruled.

They get their money upfront, and that’s how it’s listed in these documents so that we know who’s getting the money. Otherwise, if it were left to Budget, then you’re imposing upon Budget, if Priceline is involved, another accounting step, for them to pay Priceline. And it may be a situation where Priceline never pays them.

So by this document right here, when the Defendant tells you that “Hmm, the reason I went to Redding was because of the Priceline connection.”

She lied to you.

Unless of course, Washington Mutual made this up. Maybe Washington Mutual also subscribes to the Law of Attraction. And they didn’t want to put anything negative here. Maybe. It could happen that way, right? That’s what they want you to believe. Don’t believe what’s written down. Believe what I say.
That’s the same situation here, as it is with those diaries. They want you to believe not what the diary said, but what she tells you. They don’t want you to believe what that document says, they want you to believe what she says.

So now we know that she goes to Redding after she’s made provisions for the gas cans. She goes to Redding so that people will not recognize her because she is going to kill Travis Alexander. There is no other explanation for making up all these stories that we’re talking about here. There is no other explanation. Contacts Darryl Brewer, now has the gas cans, now has the car rented. And still, this car, it’s in Redding, where people are not going to know her. And in fact it’s at an airport. By definition, an airport is where people come in, and they leave, they’re traveling. Those are not the kind of people that you’re going to run across at the supermarket. And so it’s a way for her to hide.

So she shows up there, and Mister Columbus asked to her “I got this nice little red ditty over here for you. Nice little red car that you can drive on your way to Arizona, or not Arizona, just drive around. [Columbus] “By the way, where are you going to drive?” [Arias] “Oh, you know, just around town. That’s, that’s all I’m going to do.”

Why did she lie to him? Why did she make that up to him? Because she didn’t want to tell him that she was going to Mesa, Arizona like she already told Darryl Brewer. Because then again, that would connect her. But why not take the red car? “Well, you know” according to her “red cars call the attention of the police.” And she certainly doesn’t want that. She doesn’t want the police to find out about her because she’s on a mission. She’s on a mission to kill somebody.

Why would you take a gun if you are going to go on this trip other than to kill this guy? And she says “Oh, you know, I didn’t know I was going to go there, even though I told Darryl Brewer, I didn’t know I was going to go there.”

Keep in mind that this is a rental car. And one of the things that she says as she’s pointing the finger at Mister Alexander and how viciously sexual he is - do you remember when she claimed that she was down in that office, do you remember she said “We were down in that office, and I had brought over some CD’s from the trips that we had taken with some photographs.” Do you remember that? And she said “I had scratched them”. For whatever reason she said she had scratched those CD’s. And he got mad.

And he threw that CD because you know, that guy, he gets mad at everything. And so then I have to have intercourse with him to calm him down.

That’s what she said.

If she’s not going to visit him, if she’s not going, thinking, or if she hasn’t already made up her mind to leave Yreka and visit Mister Alexander in Mesa, Arizona – Why? Why take these CD’s of the trip with her? Why take these CD’s? Who is she going to show these CD’s to other than him?

And she’s in a rental car. So that requires a volitional movement on her part to take something from inside the house or her car, whatever which one she does, but it requires a volitional movement to get those CD’s into her car and drive down to Redding, California and then put them in the rental car. There is no other explanation for those CD’s to be in Mesa, Arizona other than that she knew, she absolutely knew and had already planned it. She knew she was going to kill. Why else take the CD’s?

You think that Joe Columbo [Columbus] wanted to look at them? You think that her family in Redding cared? The ones that she claims took her to the airport. Nobody cares about that. It’s a good way to disarm, if you will, or it’s a good excuse to show up unannounced somewhere. “Look, you know the only reason I’m dropping by, just like I did back in August of 2007, the only reason I dropped by was to show you this. It’s not my fault that you haven’t seen these. It’s not my fault that I haven’t been able to get them to you. Not my fault at all. Not at all. But you know I’m making it up to you now.”

She left Yreka, California with those CD’s. But she forgot about it, as she attempted to manipulate the story from the witness stand. She forgot about it. It’s those little details that she forgets.

And so she brings those CD’s and doesn’t want the red car and the reason she doesn’t want the red car is because, well, police will see her. Doesn’t want to be stopped by police. And that’s actually foretelling at what happens later, because she stopped in West Jordan, Utah – by the police for a different reason, but she is stopped by the police and she’s right. According to her mind, a red car is more significant or stopped more prominently or frequently by police.

She doesn’t want to be stopped. Because what if she’s stopped in a place that show’s she going to Mesa? She wants to hide the fact that she’s going to Mesa, Arizona. And the only reason to hide that fact, is because she’s going to kill him.

It isn’t like the Bishop is going to be upset if she shows up in Mesa, Arizona. It’s not like her family’s going to be upset if she shows up in Mesa, Arizona there. She’s an adult. It’s not like her friends, whoever they may be, because we don’t know who they are, they’re not going to be upset if she shows up in Mesa, Arizona. The only reason to keep this whole thing a secret, which is what she tried to do, is because she was going to kill him. And she’s making preparations, and she’s very good at making these preparations. You do have to tip her hat, your hat to her.

First of all, the burglary. She does a burglary, there are no suspects. One of the only things taken at this point is this .25 Caliber. It’s lost. It’s out there, this .25 Caliber handgun. And then she rents this car, then takes the white car. And the white car does have some floor mats in it. She takes this white car and says “I’m only going to drive around here.” Again, she lies. Makes that up. It’s like a field of lies that has sprouted around her as she sat on that witness stand. It’s every time she spat something out, another lie, another weed would grow around her.

And so she gets in that car, heads out and sleeps the night at Matthew McCartney’s house. And the next morning of June 3rd of 2008 she then shows up over in the Monterey area, shows up there in the morning and sees Darryl Brewer. And yes, she now has two gas cans. And the only reason to get these gas cans is to put gas in them. There’s no other reason why anybody would get a gas can to go on this trip.

Well, the ostensible reason to get these gas cans is perhaps gas is cheaper in Utah. Or maybe gas is cheaper in Nevada, than it is in California. And that’s one of the reasons that’s given. But if gas is cheaper in Nevada or Utah, and she does fill them up in Utah, why then – why would she fill them up in Pasadena? Why would she fill up these three gas cans in Pasadena? The only reason she would fill these gas cans up in Pasadena is because she was going to take the drive to Mesa.

And sure enough, there is no evidence that she ever was in this area through, this, gas, by purchasing gasoline. Everybody that travels in, they stop somewhere and use a credit card, it’s easy to trace. But not if you don’t stop anywhere.

And so she picks up these two gas cans and begins to drive. And after she begins this ride, why not take a little detour. And this little detour is after some thought. Because this is a meticulous approach to premeditation. This is a meticulous approach to killing.

Again, why stop in Salinas, California at a Walmart to buy another five-gallon can. Because she’s been thinking, and she thinks “You know, ten-gallons, let’s say that maybe thirty miles per gallon is only 300 miles, I need another five maybe, that gives me another 150 miles, that’s 450 miles. That gets me through Arizona, and into Nevada.”

So she stops at the Walmart. And she stops at the Walmart and she does buy a gas can. She admits it. So when you look at this receipt, 237.00A, and you look at it, the bottom item there for $12.96 is the gas can. I guess that’s the price of premeditation these days – twelve dollars and ninety six cents. And she admitted it, yeah. Sure did. On cross-examination “I bought that gas can, but”, and she was very specific, “I took it back to this same store, 2458, on that same day.

Kirk Nurmi: Objection. Facts not in evidence.

Judge Sherry Stephens: Overruled.

You remember what she said on cross-examination when she was asked “Where did you take that gas can back?” And on cross-examination, specifically, she said “I took it back to the same store that I bought it from.”

Kirk Nurmi: Objection. Mischaracterizes the testimony.

Judge Sherry Stephens: Overruled. The jury is directed to recall the evidence.

And do you remember at that time that the question that was followed up was “Well would it surprise you that that store in Salinas doesn’t have any record of that?”

And her answer was “Yes, it would surprise me because I got money back. I got a refund. That’s the way the exchange went.”

And your notes should reflect that. So she didn’t take it back there, did she? But she told you that. Why did she say that? Why did she tell you that? Because that’s just crushing, if you will, in terms of whether or not this was premeditated.

And it is premeditated. She was coming to Mesa with a gun and a knife. This knife appeared from somewhere, so she had to have brought it up. Knives are not in a bathroom.

So she stops there, after thinking about it, and now has another gas can which gives her a further range of at least 30 miles per gallon. We’re talking about an extra 450 miles.

Well, one of the other things that she does as part of this premeditation, or part of what’s going on is that, well you know if you want to do something like this, it’s a good idea that when you show up that people not recognize you at the place where you’re going to commit this murder. And so if you have blonde hair, and you saw the photograph of her with the blonde locks and the black dog and how they told you that, that’s the same color.

Do you remember that line of questioning that went on with, ah, Lonnie Dworkin, their expert on computers? The question was asked “Well do you think that this hair here with the dog looks the same as the one where she’s laying back?” Do you remember that line? Like he was some sort of expert on hair color.

You don’t need anybody to tell you what the hair color was when she was there with the dog. You can see for yourself. You don’t need the Prosecutor or anybody to tell you. But you do know one thing. You were also shown photographs that were also taken on June 3rd of 2008 about this same time. And you saw the hair color, didn’t you? Are you going to believe Mister Dworkin and the Defendant, or are you going to believe your eyes?

Maybe the Law of Attraction tells you that you should believe Mister Dworkin. Because again, you can’t believe the text messages, you can’t believe what’s written down on the receipt and you can’t believe what’s in her journal because of this Law of Attraction. Now you can’t even believe your own eyes. Because if you do believe your own eyes, you know she’s premeditating the murder. She’s thinking about killing him, that’s all that’s required.

The State doesn’t even need to prove a whole plan such as this. All the State needs to prove is that the Defendant thought about it, the killing, before she actually carried it out. And this is an extensive amount of planning. Days. Six days in advance. Six to seven days in advance of her killing him. A week or so.

And so, she stops there, makes more preparations, and now she can freely drive through Mesa with these, with enough gas so that she doesn’t have to stop anywhere. More thinking that goes on.

And she tells you “Well, I hadn’t planned on going there to Arizona. Hadn’t even thought about it but Mister Alexander, that guy, always guilting me. This is, you know, God like a bad disease, this guy always guilting me. You know, it’s not my fault.” That’s what she’s telling you. “It ain’t my fault. I told him I was going to go to Utah, he was a little bit suspicious about why I was going to Utah but, why don’t you stop here in Arizona, you can stop here in Arizona.”

That’s what she told you that he said, or that he implied, that he wanted. She kept saying “No, you’re going to come up here and see me after your trip in Cancun. It’s okay.”

Well, the problem is that it’s her word. Do we really know, based on all of these lies, that that’s what he told her? Or was there just a call to try to find out what he was doing? Does he have a visitor there? Does he have somebody there? What are these roommates doing? Are they going to be there, when I arrive? What’s the situation there? Are you going to take her word for that?

Is there any indication anywhere that Mister Alexander even knew that she was coming down there? You have her word. You know, in cases that are minor to you, not even important cases, are you going to take her word? And remember this individual has no problem with telling lies.

You’ve seen throughout this whole trial – Well, she says that she does have this conversation with him, and in fact the phone records do [verify] there is this conversation. But the content of the conversation is still in doubt.

And I only have to point out as far as the May 10th 2008 conversation, in terms of showing that she has no problem lying on the telephone where she says “Well, yeah I was faking it.” And you know what she said she was faking. Even though you heard her squealing like a cat – “No, no, no, no that’s just me faking it. And you know why? Because I need two hands” That’s why she was faking it.

Okay, well, if you can lie on May 10th of 2008 on the telephone to Mister Alexander, what makes us think that you can’t like about what you and he talked about on June 3rd of 2008? And remember she’s got this history, all along, not only of lying outside of the courtroom, but she has sat in the witness stand – a place where you have taken an oath, a place that is sacrosanct in finding the truth – has sat on that witness stand, looked at each and every one of you in the eye and lied to you; specifically the gas cans, specifically about Priceline. And, another extent, the finger. If you remember she said “Oh, you know, he was starting to kick me, he broke my finger. I didn’t get any medical care, but he broke my finger.” Or, the alternative might be “I was working at Casa Ramos before I went, and when I was at Casa Ramos, uh, or Margaritaville, one of the two – you take your pick because that’s what she told Mister Brewer “and either I went up against one of the edges, the metal edges, and it cut me, or, alternatively it was a Margarita glass.”

No, and then she takes the witness stand and says “Well, in terms of the damage to the finger I actually damaged the finger when I was at Mister Alexander’s home on June 4th of 2008, but the glass was that, that’s how it happened.”

What story are you going to believe with this individual? And that’s the issue here with when she tells you something, what are you going to believe?

And so, she leaves that area and off she goes. Drives to Pasadena. Um, we know that the telephone calls with Mister Alexander are after that, but she drives to Pasadena.

And then, something that is so bizarre happens to her. It seems that there is this coincidental hoard of skateboarders in Pasadena. That’s, that’s the way the kids are in Pasadena. They go in hoards, these skateboarders. And this hoard of skateboarders, well, they carry screwdrivers. That’s one of the things. If you’re going to be in this hoard of skateboarders you have to have a screwdriver. That’s what you got to do. Or else you’re not allowed in this particular club out in Pasadena.

And you can get a Strawberry Frappuccino or whatever it is that you get at Starbucks when you go there. Be careful. Because when you go in to get this Strawberry Frappuccino, things are going to happen to your license plate if you run across this hoard of skateboarders with this screwdriver.

And so when she was questioned about that on cross-examination, one of the things that she said was “Well, yeah, I was pulling out after stopping there, and I was pulling out and I saw something flat on the ground.” And when challenged on that, if you see something flat on the ground, what makes you think that you can go and pick it up? What in God’s name would ever motivate you to go and pick this up, especially if you were afraid of this hoard of skateboarders in Pasadena? Because she did say that she was concerned for her safety. Why even get out of the car if you don’t even know what it is, and you don’t even know if it’s related to the car? And she said “I didn’t know it was related to the car. I didn’t know what it was.” And she’s having problems with the truth there because remember, she’s got to remember, she remembers that she’s got this license plate in the back that she’s got to deal with, this issue involving the license plate in the back and whether or not they’re connected.

And she said “Oh I don’t even know what the license plate was, I didn’t even look in the back.” When challenged further she said “Oh wait a minute, no, no, it wasn’t flat. It was actually standing up. And it was standing up and I was able to reflect and realize that it was yeah, it was this, not square – she corrected the Prosecutor – but rectangular. Remember that? It was a rectangular object that she recognized as a license plate.

And if you don’t have any suspicion whatsoever that it has anything to do with your car, why then? Why would you get out of the car and go look, when you’re scared, to get a license plate? Why on God’s green earth would you do that?

When you’re lying. That’s when you would do that. That’s exactly when you would do that.

And she says “Oh, you know, I went and got it and I really couldn’t tell the numbers and I didn’t compare it to the back.” So now you’re a thief. Somebody else’s license plate is sitting out there and you don’t know it’s yours. Potentially if it’s not yours it’s somebody else’s. And they may potentially come back for it. So what are you doing? You’re stealing it. You’re depriving them of the opportunity to have the front license plate which is obviously required in the State of California because this car had two of them. So that’s what you’re doing then. Because she didn’t check to see if it corresponded with the one in the back.

And the reason that she’s having problems with that is because as you know, in West Jordan, Utah, the one in the back is upside down. Like somebody took it off, and like somebody put it in the backseat of the car when they arrived at Travis Alexander’s house. So that the car wouldn’t be able to be identified to them. Just like that. That’s it. You know? But she can’t admit that and that’s why she’s having problems with this license plate that’s out there in this parking lot.

And she ends that conversation with the Prosecutor during cross-examination by saying “Oh well, you know I didn’t see numbers or whatever because you know what? I can’t see. I needed glasses back there. So I really couldn’t see. So I just grabbed it, and it had bugs on it and so I thought it was mine.”

So without any regard to whether or not she knew it was hers she throws it in the backseat of the car. Who does that? No one does that. Making it up. And she’s making it up because she got stopped in West Jordan, Utah and has to explain how it is that the front license plate got into the car – because this hoard of skateboarders from Pasadena, they can’t get into her car. So she has to be the one to do it. And the only way that she could say that she’s the one to do it is to make up a story. And she made up the story about these skateboarders, this wild hoard type of thing where you have to have a screwdriver, they’re the ones that did it.

And you know she’s making that up. She’s lying to you about it. And the reason she’s lying to you about it is because in West Jordan, Utah that license plate was found in her car.

Juan Martinez to Judge Stephens: Okay, we could stop.


** RECESS **



The Defendant had made her way to Pasadena along with her will to kill Mister Alexander in the evening of June 3rd of 2008. And she stopped at the Starbucks and after stopping at the Starbucks, or as part of this stop, she decided to fill up. And we know that she had the three gallons of gas, or the three gas cans at this point based on the receipts that are before you. And the reason that she had those gas cans filled is so that now she was prepared to make it all the way to Arizona without having to stop for gasoline. And she, on her direct testimony and also part of cross-examination, she indicated that well, the car for whatever reason had a bad engine, uh, for lack of a better term. It kept using gas so much, trying to manipulate you into thinking that she stopped at a number of places and used all the gas in the gas cans. But there are no records or any other corroborative evidence that indicates that she stopped anywhere here in the State of Arizona for gasoline.

So her plan, if you will, was working well at that point. She wanted to kill him, but there was way for anybody to say that she was even in the State of Arizona. Because the Defense would have been, well “I would have had to stop for gas.” And there was no indication anywhere and there is no indication anywhere that she stopped for gas in the State of Arizona.

Another thing that she did as she came into the State of Arizona is she turned off her telephone. And this telephone that she, the cell phone that she had was turned off so it could not be traced by law enforcement. So now not only do you have her in a vessel, an automobile that will not be traced to the State of Arizona, you also have her with a telephone that is turned off. She gave several reasons to different people as to why the telephone was turned off. One of them that she gave to Ryan Burns was that somehow it had lost its charge and that she had lost the charger and somehow she had been able to buy it at some store. That was her story and that then she was able to charge the telephone so that she then was able to call him near the Hoover, Hoover Dam.

Another story that she gave was that she stopped on the side of the road and she was cleaning up from killing Mister Alexander, she was able to go underneath the seat and find the charger. Either way, the net effect of that was that as she came into Arizona there was no electronic trail of her being here and there was no physical trail of her, uh, coming through. And this was done for the purpose. She knew she was coming to kill him. There is no other reason why you would turn off your telephone as you’re coming through here – especially this woman who clearly loved to use her telephone – but for this particular trip, for this time when she’s approaching Mesa, the telephone is off. And it doesn’t come off until sometime later near Hoover Dam, again, indicating she was never in the Mesa area. And without the electronic trail it would have been difficult for the police to find that out.

So now you have her in a position where she can come to Arizona, and no one’s going to know. She’s in a car that’s white, not red, so the police are not going to stop her, and she shows up with a gun and a knife.

And she shows up to see Mister Alexander. And if you remember that one of the things that she told the police officer, she always, whenever was not to her benefit, will say “Well no, I was lying then.” As if somehow that’s a fallback position. As if somehow that’s something to be rewarded. That “Oh, I lied. So because I have admitted that I lied, you should put that in the good column.” Forgetting that she lied to start with, and she lied to cover up the killing. And so she indicated that to this officer in a telephone call, and by this officer I mean Detective Esteban Flores, that she knew the code to his garage. Zero, One, Eight, Seven. And so she knew the code to the garage and she indicated that that’s how she came in. She didn’t knock on the front door, she didn’t go out through the back and peep through the sliding glass door just like she’s done before. She actually walked in.

There’s no indication that Mister Alexander came to the door. And this was sometime after four o’clock in the morning. And as she came in, one of the things that’s telling about what happened, is that she said “I came in, and I stood by the door. And I watched him. And I watched him for thirty – forty-five seconds.

Who does that? Who comes in and stands there. Someone with some sort of stalking behavior in their past? Someone who’s arriving there unannounced? Someone who is there to surprise Mister Alexander.

Mister Alexander happens to be awake. He’s got the dog, Napoleon with him. And the dog barks, and there’s this “Hello, how are you?” kind of thing. And at that point she says that either she does bring her stuff in or she doesn’t bring her stuff in. She may have brought her camera at that point. And we also know that she brought in her purse. And her purse is big enough for this “toy” .25, “toy-looking” .25 caliber handgun. It’s also big enough for a knife.

She comes in and according to her they go to sleep. There’s no sexual activity between them at that point. If Mister Alexander was this sexual fiend that she has attempted to portray, why didn’t he just force himself upon her there? And she said “Well, at that point I told him that I was tired and that I did not want to have sex.” So whenever that she said “No”, Mister Alexander abided by that. The only time that she ever indicated that no, no she didn’t want to have sex with him, he abided by that. And they went to sleep until the next day.

The next day, they do engage in some sexual contact. And there’s such a, uh, stigma that the Defendant has attempted to attach to this particular encounter. In fact she goes so far as to speak with Richard Samuels, Doctor Richard Samuels, and tell him about this. And tells him these photographs were actually taken when she was straddling Mister Alexander. Additionally she talks about how Mister Alexander has on his computer all these photographs of some women’s breasts. She just has to add all this to make Mister Alexander be something that he is not. Or have this encounter be something that it isn’t.

He did not go to Yreka to seek her out. She drove here, to the State of Arizona, to Mesa, to see him. Yes, he did have a camera, and yes, it was used, and thank God he had the camera because that’s the reason why we’re standing here – because of the images captured on that camera.

And so they engage in this sexual contact. And again there’s this religious sort of overtone that somehow she’s holier than thou, that it was all at his request. It was all about him. It was nothing about her. And that he’s somehow violative of the concepts or the precepts of the Mormon Faith. Why is that important? It’s important because she wants to manipulate him. She wants you to believe that “Wow, he’s such a bad guy. He’s holding himself out to be a virgin, and somehow that’s really, really bad.” That when people date, or when people talk about their sexual lives they somehow don’t want everybody to know everything that’s going on.

If you remember that Deanna Reid indicated that yes, they had transgressed. They had engaged in sexual contact but went to see the Bishop, they got whatever penance or whatever punishment or whatever happened but they never engaged in that contact again.

Somehow the Defendant wants to make it seem that Mister Alexander kept constantly going. He was this individual who had lost his priesthood or had not. Had or had not. And somehow that this encounter was a microcosm of their whole relationship. Well if it is a microcosm of their whole relationship then we have the willing partner sitting right here. Someone who enjoyed it just as much as he did. One hand or two hands, she enjoyed it as much as he did.

And so, later on in the afternoon, toward, getting later, sometime after five – the Defendant says, and it depends on what you listen, or what version that you listen to that at that point Mister Alexander wanted to show off his body, according to her. And he wanted her to take photographs of him. You’ve heard the tape of her conversation with Detective Flores that was taken and how she loved the way he shaved because it was old fashioned. And then she starts talking about how, yes, she is able to get him to get into the shower and take photographs of that.

And it really is more of her idea than his. And the only reason that the State can say that it is really more of her idea than his is if you harken back, think back to what Darryl Brewer told you, one of the things that he was asked on direct ex - or cross-examination was, when he was on the witness stand “Weren’t there ever any photographs that were taken of you by the Defendant?” And he said “Yes, only on one occasion was there photographs taken of me. I didn’t want them taken – I was in the shower when she started to snap the photographs. [She] wanted me to do it. When as part of the same case you have her saying that no he did not want her do it. But then, she starts taking photographs and according to her, very sexy.

But at that point the ill-will was already there. She is armed with both a knife and a gun at that point. And she begins to take these photographs. And as she takes these photographs, even though she says they are of a Calvin Klein kind of quality – water coming down as if it was sort of a specific, a very quiet bucolic kind of scene. That’s not what’s going on.

She talked earlier about a knife, justifying how a knife would’ve been upstairs by saying that there was this 20 foot rope. And that somehow she was tied up with that 20 foot rope to that bed. And it depends on whose she’s talking to as to whether or not she was tied on her ankles as well as her wrists.

But you’ve taken a look at that slay bed. Where is she going to be tied up on that bed? Making it up, trying to justify her trying to have a knife there for some other purpose. But if you take a look at that bed, and you’ve seen it, you know that she’s making it up. Just making it up.

If she’s not making it up, then why has she told some of the experts that she was tied by her ankles, or on the foot of the bed? Why does she tell somebody else that it was both her ankles and wrists? Why does she need to keep changing positions? Because she has a lot to remember. And with the truth, you ain’t got nothing to remember. But she has a lot to remember, a lot for her to keep straight given that’s she’s making all of this up.

And so, given the facts as we know them, and the fact that there was no rope, because it would have required her to clean up in the bedroom because that’s where the rope was. And if she was all bloody because we do know that the floor was all bloody, it was also very wet. It was either wet with water which is white, or it was wet with blood which is red, Mister Alexander’s blood. It would have had required her to go into the rest of the bedroom and leave some trail of that. And there’s nothing there. So it means there was no rope there. And there was no knife there for her to get. It means that she had both the knife and, or at least the knife at the time of the attack. And what happens then is that she’s standing there.

And then, we have this photograph, Exhibit 160.This is the last photograph of Mister Alexander.

There, not only is he defenseless, he does not have a gun, he does not have a knife. He doesn’t have any weapon whatsoever. Not only does he not have that, he doesn’t have any clothing on. And as he sits there, he doesn’t have any dignity either. She’s taken that away from him.

And if anybody is defenseless in this case, it isn’t the Defendant. It’s Travis Alexander as he sits like that in that shower with his killer standing there dressed in pants, ah, presumably a top on, because there’s no indication that she didn’t have a top on, with this camera. And she starts snapping this.

Part of the story of hers that you would have to be in the [inaudible] of this photograph. There’s nothing accidental about this. Somebody held the photograph, or the camera, firmly. The Defendant held it firmly as she pressed the button and took this photograph – the last live photograph of Mister Alexander.

And while she had him in that position, where he is in the inferior position of her, he’s down, she’s standing up - she can approach him, and she can approach him as he’s sitting there. And he’s dead. No doubt about that.

This is not a case of whether or not there was an attack here or whether or not it wasn’t her. It’s her. And it’s him. And it’s the man that she has just had sex with and it’s this individual that she has planned to kill all the way from May 28th of 2008, days. Even though the premeditation statute only requires a certain period of time. It doesn’t require days, it doesn’t require planning, it requires thinking.

And so, she’s been thinking about it for a long time because she came very prepared. And before she even went in there one of the other preparations that she took was to take the license plate off the car.

Now she’s inside. Now she’s got him like that. Can anybody think of how anything else could be so much colder or without feeling for the person than to make…

Kirk Nurmi: Objection, Your Honor. [Inaudible]

Judge Sherry Stephens: Approach.


 ** SIDEBAR **

It is cold, it is thinking, it is premeditated, to go up to this individual, someone that she has planned to kill for days, someone with whom she has been intimate with, and then attack him.

She has indicated to you that it was a shot to the head. But the evidence, the forensic evidence speaks otherwise. And for you to believe her, and for you to believe that the shot was first – you will need to set aside everything that she’s told you, for example the gas cans – everything else that she has told you, including the fact that she had lied to the police, including the fact that she lied to the experts, including the fact that she lied here. And then you have to say ‘Even though she’s lied all of these times, even though she’s looked us in the face and lied to us – we’re now going to believe her with regard to just this one particular aspect.

That is not something that is available to you, I submit. And I submit that because of everything that she has said.

And so, she gets her knife. And she took that knife and stabbed him [Inaudible]. The reason that we know that she did that is because Mister Alexander has defensive wounds. And he has defensive wounds to his left and his right hand. As she is stabbing him, he is alive, and he is cognizant of it, and he begins to grab at the knife. But unfortunately for Mister Alexander one of the knife wounds is to the heart.

Doesn’t mean he’s going to die immediately, it means he’s just going to die. And part of the dying process includes, because of the cuts to the heart, blood coming from his mouth and blood coming out from the wounds. But he’s not going to die immediately. He’s going to take some time, minutes, to bleed out. But he is going to die. So in a sense she has already killed him. He’s dead.
Well, you know that he gets up at some point. You know that he doesn’t remain seated there. Because throughout the bathroom where there’s the mat, where there’s the scale, all around the bathroom, everywhere… there’s blood. And if there’s blood everywhere that means there is movement there.

And it isn’t the kind of movement that is the flopping of the fish kind of movement, it is movement, purposeful movement on the part of Mister Alexander to save his life. And as this time is going by, again, premeditation does not take days, premeditation does not take a plan, premeditation just takes time. And it could be a shorter amount of time.

The stab wound for example, after the first stab wounds could be that. And as he is in this position of dying, he then ambulates. And we know she didn’t carry him over to the, um sink. We know that he goes there by himself. And one of the things that you see there is this. [Exhibit] 98: That’s the sink. And that’s the sink with his blood on it after he has been stabbed.

The reason that you know that he has already been stabbed, at this point, is because of the patterns you have on this particular photograph. Right here on the left. And remember the injuries to the hand. He had more stab wounds to the left hand than he did to the right hand. And one of the patterns that was described here was this smudge, or this transfer so that if he, and remember he had more injuries to his hand. That’s not something she can tell you he doesn’t, but you’ve looked at the photographs. You don’t need to believe that, you can believe the photographs and he does have an injury, a slight injury to his right hand.
But if he’s standing here, this would be where his left hand is. And you can see that there’s this smudge, or the transfer, as he moves that way, as he’s falling, moving away, indicating movement.

He’s still alive. But he’s bleeding, that red stuff there, it’s blood. And you also have the drops here. And those are placed there by gravity.

If this individual has blood in his mouth, and if you remember that the Medical Examiner testified that if you do have an injury to the heart, that’s one of the things that happens. And as he, it required Mister Alexander to be standing there with his left arm like this [demonstrating], and as he’s doing that – you do know that this is what’s happening to him - she is stabbing him in the back. This is Exhibit 192. That’s a concentric area. Exhibit 193 also shows us that. And he’s also being stabbed, as you saw, in the back of the head as he stands at that sink. Because he is standing at that sink, and he is bleeding, and the amount of blood that’s at that sink is indicative of time. You just don’t go over for a second and get those [blood] patterns.

He stood there, which means that the Defendant was there with the knife, stabbing him.

The other pattern that you see there is this, on the mirror. If you remember the Blood Spatter Person indicated that “Well, yes, that could happen from, for example, a gunshot wound, but it could also happen if someone has blood in their mouth and they get hit in the back of the head.” And that’s called blood splatter, high velocity splatter. And what that means then, is that Mister Alexander was having some force applied to his head at the time that he was standing there.

That’s how you can know that, Exhibit 193, occurred when he was standing there during the strikes to the head. Because the splatter that is on the mirror indicates movement. Hitting him. And then he goes and flies into the mirror.

But he’s not dead. He’s still standing there.

This woman, came to visit him came prepared though. So he begins to go in a different direction. And we know that he begins to go down the hallway, and he’s still standing. The reason that we know that he’s still standing is if you take a look at Exhibit 133. That’s blood transfer. That’s either an item of blood [came by] or the blood was already there. Well the item of blood in this case was Mister Alexander’s. And as he’s going by you can see him still sort of standing.

And then in this Rainbow, somewhat ironic – there is no good luck for him at the end of that Rainbow. 

But you can see that it starts high and it arcs down to the area where there’s a larger amount of blood. He’s stumbling at that point. But he’s stumbling with somebody after him. He’s trying to get away. He’s trying to get away from her over there.

And she may cry now. But the jury instructions have told you that sympathy is not to be considered in this particular case.

No doubt that she did it. No doubt that he’s trying to get away from her. And you can tell that by the arc that he’s there. You can see that even clearer, here, with regard to Exhibit 132. That’s the same view showing the arc. Just for contrast to show you that was part of what was going on. If you take a look at the other side, the other wall, you can see that these are more at the bottom, indicative of a substance with blood either rubbing it there or the blood already being there and an item going through there - as opposed to this arc that we see here.

She chases him down. That’s what she did. He’s still alive. How many stab wounds has she already given him at that point? The ones to the back – do we really need to count the number of stab wounds [inaudible]. Is there a requisite number to get through the portal of death? No. Not really. There’s enough here to get him there. He’s already got the ones to the chest, which is going to kill him. He’s already got the ones to the back of the head, they’re not failed, and he’s got the ones to his back. But, they are accelerating his departure from earth, because the more he bleeds the quicker he dies. You don’t die immediately.

You would have dispersed all over [Tape skips]... thinking this person’s not going to live. “He may get away from me in the shower, he may get away from me all the way to the sink, and he may stumble away down that hallway, but you know? I caught him.” And now, rather than stabbing him anywhere else, right here.

So it’s a very well-orchestrated killing. And it takes time. By time, if somebody takes time, people think.

So she’s now stabbed him, he’s going to die. And now he’s tried to get away, went to the sink. From what’s almost something to consider, another thing to consider while he’s at the sink is that in front of the sink is a mirror. And as he’s standing there a mirror is reflective of what’s going on behind him. And he has eyes. His eyes are still open at that point – he can see. He can see the Defendant.

But she’s not done with him yet. And again the point here is that if this was a heat of passion, if this was a situation where somebody was just upset, it would be random all over the place but this was a strike to kill – right at the neck. And then, after she does that, one of the things that we know is that a shooting didn’t take place there. The shooting took place near the sink, where he had previously been standing.

And so, one of the things that they wanted you to believe was that this person is shot and hit through the head, he couldn’t have been shot there at the sink, according to them, he’s already bleeding and still continued on. But the knife wounds do have to be first. Of course that would violate the Laws of Nature because he’s bleeding so profusely there that the Doctor by necessity would have had to found lots of blood in the track of the bullet and he didn’t.

So if he was standing at the sink, and he was shot at the sink, after being stabbed, there would be lots of blood there. And the Doctor did not find any there. So he clearly was shot after that, when the situation was such that his heart wasn’t beating, a situation when the heart wasn’t pumping enough blood to get it there.

Bottom line he was dead at the time that he was shot, in order to forensically get the result of no blood in the track of the bullet.

So, he falls there. And then we have more directed behavior. We have this, Exhibit 162. That’s Mister Alexander, that’s blood, that’s his foot, and that’s her foot. And given the fact that we know that the bathroom is this way, that’s her standing there.

And what’s important about that is that we look at this Exhibit here is that it looks like there’s been a wildebeest migration near his head. Look at that. And what’s important about that, is that even though there is this stomping of the feet, it just means she was over him, hovering him. How many times must she, was she stamping around, stomping around to get that pattern. But what’s even more important about that is that there’s nothing in the bedroom. Which means this was directed behavior at him. She was cognizant of what was going on because if she would have been in this state that she wants you to think that she was in then it would have been all over the bedroom – if she would have been in this hysterical state that she describes for you. That she went out, into the bedroom, except it’s in pristine shape.

What she does then is she begins to drag him. And again, we look at that which is Exhibit 163, which is a bit later, you can see that she’s dragging him down the hallway. What that shows is a tempt or an attempt to clean up. And as she is going by the sink again, you know that she does something else. What she does is this – Exhibit 207 – shoots him in the head. And there’s no blood in that blood track which means the heart isn’t pumping. And when the heart isn’t pumping, he is dead. There’s no other medical phenomenon or any other medical indications that um, would, ah, give any other indication. And if that’s the case, then he’s already dead.

And then you have the casing from the .25 caliber handgun that she took during this staged burglary. And we have the casing, right there – falling on top of the blood, as she’s dragging him back. Because by necessity, the body has to be there.

And what, if you remember there’s a closet that’s up here, the sink is to the left, and this is, and the sink is to the left and this falls to the right. One of the things that we talked about is that the shot is right here. If she is dragging him in this fashion, that way, and she’s pulling along here that would mean it would be this portion of the head that was exposed. If you’re pulling someone down the hallway that’s the result that you get, the casing is expelled, and it lands on the blood that is already there.

So that’s when she delivers this shot to him. Somebody that’s already dead. So she’s killed him three times over. Is that enough premeditation?

Even though she’s through all of this planning already, this was a very directed attack.

And then she goes about the business of cleaning up. And one of the most interesting things about the clean-up that she did is that, yes, she knows about cameras. She knows what to do with cameras according to her. And one of the things she knows what to do with them is delete photographs. And she’s able to look at all of the photographs that are on this camera.

Let’s assume for example that they’ve already deleted the one’s involving the sex. This one right here [inaudible], Exhibit 162 for example, had to be deleted after he was dead. There is no time travel here, because that’s really what they want you to believe.

After this happened, she located the camera. And he’s not carrying the camera as he’s trying to survive. He couldn’t care less about that camera as he’s standing over the sink. So what does he do? He just tries to get away. So the camera getting there means that she is the person that was holding on to the camera and carried it to that location.

Then, after she shoots him, she goes back and places him in the shower. Some point either after shooting him at the um, at the sink or after placing him in the shower – at some point, she’s still thinking. Because remember how much she has planned before? “I got to get rid of this evidence. I gotta delete this.” What does she do? She deletes only certain images. It’s not like all of the images are deleted. This shows somebody who was thinking. “Oh, I don’t want to delete the one of his dog, uh, or this other one. I’ll delete just the only ones that hurt me.” And that is directed behavior by somebody who claims to have Dissociative Amnesia.

Dissociative Amnesia – you heard what the definition of that was. Or is it a fog? Even a San Franciscan fog, if such a thing existed, wouldn’t be so cloudy to account for this kind of behavior. There is no fog that someone can tell you about that hasn’t lifted – or allow for this. And so, she cleans that up. She has that, and she cleans that up.

The other thing that we know is that she takes the camera at some point from that area there. And again what’s important about that - yes it’s important where it was found, yes it’s important that it was found in a washer – but what’s actually more important, to show that she was thinking, is that there are no steps leading from the bedroom down to the area where the, um, camera was found that are bloody in nature, or red. Which means she was cleaning herself up. Because if you’re going to be walking around there, you by necessity are going to get it in your socks because that’s what she’s wearing. She would’ve had to get it on her socks.

And if she’s into this horrific, hysterical state, she would have ran down or thrown it down there. But what she did is she cleaned herself up first. The police did not, and you looked at all the stairs, did not find anything that showed that there was any activity other than up in the bedroom. Which means she cleaned up.

She took her socks off, and then maybe took her shoes off, or maybe put different socks on – but definitely the item that she was wearing was taken off before that camera was taken downstairs and put in the washing machine. And it was put in the washing machine, and put through a cycle.

Oh there’s this big indication or this indication that she could’ve taken it with her. So? What does that mean? It just means that it’s an alternative. But she has done so much already.

Other things that she has done, according to her, is there was this glass underneath the sink area. And that’s the glass that’s found on top of Mister Alexander after she cleaned him up. After she cleaned him up in the shower.

We don’t know if the glass was an afterthought or if it used to actually clean him but actually shows that she went to the sink, approached his body, and dropped it on top of him. But she cleaned him up. Wanted to wash away anything or any contact or anything that would show her being there.

Again, we’re told about what DNA is and how it’s left behind. But if somebody washes it away, it’s just not going to be there. And that’s another step that she took in staging this scene. She washed away all of her DNA from him. Could’ve turned on - we don’t know if she turned on the shower. We don’t know if she used the glass. But we do know that she cleaned up. And it isn’t because she loved Mister Alexander that she cleaned him up, or it isn’t that she wanted him to look good, even though he, with all due respect, he looked a little bit crunched up there. It wasn’t that. The net effect of what she did is to destroy any of her DNA. She washed it off. That’s what people do when they want things that, such as items off their hands – they wash up. And that’s what she did.

And then we don’t know what was in the middle of the bathroom that was causing her concern. But we know that she focused in on the bathroom area as well as near the closet. Again, we don’t know exactly what was there. Perhaps that’s where she dropped the knife and she needed to clean the knife there – because we know that the knife was cleaned. We know that the knife was not left behind. So again, there is this directed behavior with regard to the knife.

Had the knife been dripping blood, and remember she had just stuck it into his neck – had that been happening, and had she been in this hysterical sort of mood that she wants you to believe, it’s fair to say then that knife would not have been bloody [inaudible]… bullet… and she would have dropped blood along the way.

No, she carried it out. She wants you to believe that she may have carried it down to the dishwasher. If she did carry it down to the dishwasher – which the State disputes – but we can use that for demonstrative purposes to show that knife, if it was carried downstairs either had to be cleaned up upstairs or wrapped in something like a towel, which shows again directed behavior, so that no blood got on any of the stairs. Didn’t get it anywhere else.

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