Ray Coyle

 

Witness for the People:  Guilt Phase

July 12, 19 & 20, 2004

 

Direct Examination by Rick Distaso

DISTASO: Detective, what is, you work for the Modesto Police Department?

COYLE: That's correct.

DISTASO: All right. And what's your current assignment?

COYLE: I'm a detective in crimes against persons.

DISTASO: And how long have you been a peace, a police officer in California?

COYLE: Almost 25 years.

DISTASO: And were you involved in the search warrant at 523 Covena in the City of Modesto on the 26th and 27th of December of 2000 and 2?

COYLE: Yes, I was.

DISTASO: What were your primary duties there?

COYLE: To assist in the search of the residence.

DISTASO: And specifically were you assigned any particular locations?

COYLE: Initially, yes.

DISTASO: And where was that?

COYLE: The master bedroom, or north, excuse me, southwest bedroom of the residence.

DISTASO: Okay. Now, when you're assigned one particular room of a house in a search warrant, is that the room, you then search that room, correct?

COYLE: That's correct.

DISTASO: Okay. After you're finished searching that room, are you free to go assist other detectives or other officers in searching other locations?

COYLE: Yes.

DISTASO: All right. And did you do that in this particular case?

COYLE: Yes, I did.

DISTASO: Okay. The, let's just start with the master bedroom first. When did you first go into that particular room?

COYLE: After the initial video and photos were taken and we were cleared to begin searching is when I entered the residence to search that bedroom.

DISTASO: So the jury just saw a videotape of, of the house and the back, and the yard. Is that what you're talking? About the videotape is done, correct?

COYLE: Yes.

DISTASO: And then the people can come in and search?

COYLE: Yes.

DISTASO: And on the 26th, were you looking for any specific thing? Or were you limited in your directions?

COYLE: We were given a briefing prior to the search detailing the specific items that were being sought under the search warrant. We also initially were asked to look for trace evidence prior to doing a hand searching.

DISTASO: Okay. And did you go through the room that you were asked to search, the master bedroom, and look for any trace evidence?

COYLE: Yes, I did.

DISTASO: And by that, we're, were you primarily looking for blood or blood splatter, something of that nature?

COYLE: Hair, fibers, yes. But mostly blood.

DISTASO: Okay. And did you find anything that caught your attention on the 26th?

COYLE: Yes, I did.

DISTASO: And what was that?

COYLE: There were a couple of small spots on the comforter that was on the bed in that room, and I called that to Detective Skultety's attention.

DISTASO: And Detective Skultety we've heard was the crime scene manager, but it's really like the search team manager?

COYLE: Refer to him as probably the case agent.

DISTASO: Okay. And for a particular search warrant, when the officers are searching something in the house, and they find something, do you call whoever the, whatever we want to call him, crime scene manager, case agent, whatever, do you call him over to show that person where it is?

COYLE: Yes.

DISTASO: And then is that person responsible for collecting and booking that item into evidence?

COYLE: Yes.

DISTASO: The, in the, what, on the 26th specifically, what exactly did you do in the master bedroom?

COYLE: Initially I, I searched using a flashlight. Before entering the room I swept my flashlight across the floor, looking for anything I could see with that. And then I entered the room and again checked surfaces with my flashlight and inspected things for any kind of blood spatters or blood drops. And after completing that sort of forensic search, then began a little preliminary hand search.

DISTASO: And "preliminary hand search," what does that mean?

COYLE: Well, we were sort of limited on time, or not necessarily limited, but a decision had been made that we were going to hold, freeze the residence, hold it during the night and resume the searching in the morning. So we were, we had a limited amount of time on the 26th. So while others were completing their initial forensic searches, I had a little extra time and I began searching the room.

DISTASO: Okay. And what did you do?

COYLE: I, I started in one corner and went clockwise throughout the room, searching as I went. The corner that I began in was the corner near the dresser and near the window.

DISTASO: Okay. Let me stop you. If you look back on People's 38 behind you, do you recognize that as a schematic of the, of the master bedroom?

COYLE: Yes.

DISTASO: Or of the entire house, really. But do you see the master bedroom there?

COYLE: Yes.

DISTASO: And can you just draw, I mean can you take that red pen that's next to you and just draw on there where the dresser would be and then where you're talking about? Just write the word "dresser" on there, if you want.

COYLE: (complies.)

DISTASO: And there's a big square there. Can you write "bed" there so we know that's what that is?

COYLE: (complies.)

DISTASO: Okay. So you started searching, you said, in that upper right corner; is that right?

COYLE: Yes. Right in this corner, between the window and the dresser.

DISTASO: Now, when you were searching, were there specific items you were told to look for that were named in the search warrant?

COYLE: Yes.

DISTASO: And what items were they?

COYLE: Some clothing items and some jewelry items, specifically that I recall.

DISTASO: Okay. And what clothing items specifically were you looking for?

COYLE: There was a white long-sleeved blouse or shirt, a pair of black maternity pants. There was a watch that was described that had some stones around the outside of it, and a diamond ring.

DISTASO: And did, was there a hamper in that corner, in that corner that you looked through?

COYLE: Yes.

DISTASO: Clothes hamper? And when you were looking through the room, were your instructions to document every piece of women's clothing that was contained in the room?

COYLE: No.

DISTASO: So you were looking for these specific items?

COYLE: That's correct.

DISTASO: For the jury's understanding,

GERAGOS: Objection. Leading. All of these questions have been leading.

JUDGE: Yes. It's a little late now.

GERAGOS: Well, at a certain point,

JUDGE: I can't sustain nunc pro tunc.

GERAGOS: I'm not asking you to, asking you to give him an advisory opinion.

JUDGE: Don't ask any leading questions.

DISTASO: I'll try, Judge.

JUDGE: All right.

DISTASO: When you are serving, when you are serving a search warrant, are, there's specific items that you're looking for?

COYLE: Yes.

DISTASO: And does that apply only to this particular house? Or is that in other cases where you've served search warrants as well?

COYLE: In every search warrant there's particular item or items listed in the search warrant that are called for in the search, and those are the things that you're looking for.

DISTASO: So did you go through the entire master bedroom here and document all of the women's clothing that was contained inside there?

COYLE: That would be a list ad infinitum. No, I did not.

DISTASO: And did you look through that particular hamper, though, on the night of the 26th?

COYLE: Yes, I did.

DISTASO: And how did you do that?

COYLE: I removed the clothing items from it, trying to, one by one, and placed them on the bed. And then after searching the entire hamper contents, then replaced all the items back in the hamper.

DISTASO: So you took them back off the bed and put them back in the hamper?

COYLE: That's correct.

JUDGE: Okay. This might be a good time to take the recess.

<Noon recess>

DISTASO: Detective, when we left off, detective, when we left off, you were just kind of talking about the initial search on the night of the 26th.

COYLE: Yes.

DISTASO: You said you searched that hamper in the bedroom?

COYLE: Yes.

DISTASO: Let me show you a picture of People's 7. Was the hamper searched again the next day?

COYLE: Yes.

DISTASO: So it was gone through a couple of times.

COYLE: The initial night I don't know that I completely searched everything. I looked at a couple of the items briefly, because we just had a few minutes. It wasn't until the next day that I completely emptied the hamper and searched every item in there, then put things back in.

DISTASO: So when you went through the hamper, did you take the items out exactly as they were, then put them back in exactly the same order?

COYLE: Well, not exactly. Because I just sort of made a pile on the bed as I was doing it. And things were kind of tied together, and stuff. It wasn't like they came apart one item at a time.

DISTASO: But the items from the hamper, you took them out of the hamper and put them back into the hamper?

COYLE: Yes.

DISTASO: For example, you didn't take a pair of pants out of the hamper and put in a drawer, or something like that?

COYLE: No.

DISTASO: Let me show you People's 7. This is a picture, this is the one, I think, Mr. Geragos showed earlier one of the witnesses. But this is a picture from the search warrant on either the 26th or the 27th. Items that are in that hamper were present somewhere in the hamper on the 26th or the 27th?

COYLE: Yes.

DISTASO: Maybe not in this exact order.

GERAGOS: Objection. Leading.

JUDGE: Sustained.

DISTASO: When you went through it, is this the exact, do you know as you sit here today, that's the exact items that were there?

COYLE: No.

DISTASO: There is an, in this picture, People's 7, the hamper that's right by the dresser, that's the dresser?

COYLE: Yes.

DISTASO: And it's on the right-hand side?

COYLE: Yes.

DISTASO: The, where you wrote dresser up there on People's 38, that's the same dresser?

COYLE: Yes, it is.

DISTASO: Was there a paper bag on the 26th or the 27th with some clothes in it anywhere around that hamper area?

COYLE: Not that I have found. There was no paper bag in that room that I know of.

DISTASO: On the 27th, did you go back during the daytime and do a more thorough search of the bedroom?

COYLE: Yes.

GERAGOS: Objection. Leading.

JUDGE: Overruled.

DISTASO: And on that date, did you look for some items of jewelry?

COYLE: Yes, I did.

DISTASO: Were those items of jewelry named in the search warrant?

COYLE: Yes.

DISTASO: Let me show you People's 20. I'm sorry, People's 8. This. What are we looking at here?

COYLE: That's the tray, the wooden tray out of the jewelry box that was on the dresser. There is a couple of solitaire pendants that I laid out, because I didn't have a really good description. But it was asking for a solitaire pendant necklace. Search warrant asked for a watch, ladies watch, had some stones around the outside of it. I found that in that jewelry box as well. Then next to that is a blue and white stoned ring. I believe they were sapphires and diamonds. But I'm not a jeweler.

DISTASO: These are some of the jewelry items that you remember pulling out of the jewelry box that was on top of the dresser?

COYLE: Yes.

DISTASO: Do you recognize what that item is right there?

COYLE: Yes. It's the corner of a Social Security card.

DISTASO: Do you know whose that is?

COYLE: Yes.

DISTASO: Whose Social Security card is that?

COYLE: It had the name Laci Peterson on it.

DISTASO: So a Social Security card with Laci Peterson's name on it was present in the house on the 26th of December, 2002?

COYLE: Yes.

DISTASO: Or the 27th, I guess?

COYLE: Yes. Both.

DISTASO: Let me show you, this is a, 111-F. Is that the jewelry box that you have been talking about?

COYLE: Yes. With the tray removed. There was a top tray. And that's showing the bottom portion of it.

DISTASO: Is that, that shows the Social Security card with Laci Peterson's name on it?

COYLE: Yes.

DISTASO: And couple of passports?

COYLE: Yes.

DISTASO: Is that the location that they were in when you searched those items on the 26th and the 27th?

COYLE: Yes, when I found them.

DISTASO: This is 111-G. It's just a, the items all laid out. Do you see the jewelry items back behind the placard number 14?

COYLE: Yes.

DISTASO: And then also the passports and the Social Security card?

COYLE: Yes.

DISTASO: After you searched the bedroom area, before we leave there, let me show you 111-I. You said you saw the comforter in the bedroom as well?

COYLE: Yes, I did.

DISTASO: Let me show you People's 111-I. Is that a picture of the comforter that you saw?

COYLE: Yes, it is.

DISTASO: Okay. And you said you saw some very small, looked like bloodstains, to you, on it?

COYLE: Couple small stains. They could be blood, yes.

DISTASO: But you didn't conduct, you personally didn't conduct any testing of those items?

COYLE: No, I did not.

DISTASO: After you searched the bedroom area, did you also assist in searching the outside of the house?

COYLE: Yes, I did.

DISTASO: And did you see a canvas-colored boat cover in a small shed?

COYLE: Yes, I did.

DISTASO: Where was?

COYLE: It was on the southeast corner of the house, actually behind the fence, again, for the backyard.

DISTASO: Let me show you People's 111-A. That's the shed where you saw the boat cover?

COYLE: Yeah, that's the corner of it.

DISTASO: And that's this item right here?

COYLE: Yes.

DISTASO: And is this a picture of the inside of the boat cover, sorry, inside of the shed?

COYLE: Yes, it is.

DISTASO: And was the, where was the boat cover located inside the shed?

COYLE: Was basically laying on top of some of the items that were on the floor of the shed and underneath the yard blower that's depicted there in that photograph.

DISTASO: Okay. Did you let me show you 111-C. Is that the boat cover you are talking about?

COYLE: Yes, it is.

DISTASO: And did you notice anything about the particular boat cover, anything about what it smelled like?

COYLE: Yes.

DISTASO: What was that?

COYLE: It had a strong odor of gasoline coming off of it, and obvious stain that was wet at the time I first found it.

DISTASO: Why is the boat cover hanging up on the fence there?

COYLE: We didn't want to package it up and transport it in a closed vehicle with it smelling the way it did, heavy gasoline odor. And so we hung it out on the fence to air try and to dissipate some of the odor.

DISTASO: Did you also find a blue tarp somewhere?

COYLE: Yes.

DISTASO: And where was that?

COYLE: That was in a small shed that was across the patio, near the barbecue, from the house.

DISTASO: Let me show you People's 111-D. And do you see the blue tarp in that picture?

COYLE: Yes.

DISTASO: And is that it right here inside the shed?

COYLE: Yes.

DISTASO: What's it sitting on top of?

COYLE: I believe it was like a yard sprayer, weed sprayer.

DISTASO: And do you know what was inside there?

COYLE: I lifted the cap and smelled it. I don't know exactly what it was. Smelled like some sort of fertilizer to me. Maybe been like fish emulsion, some kind of fertilizer.

DISTASO: Was that tarp was removed at some point from the shed?

COYLE: Yes.

DISTASO: Here is 111-E. And looks like the tarp and the fertilizer sprayer, whatever that was, have been removed from the shed.

COYLE: That's correct.

DISTASO: Can you, on People's 38 there, there is a red pen right by you. Can you take that pen and just write "Blue Tarp" and, slash, "Fertilizer Sprayer", and put the date, 12-26 or 12-27, whichever one you want. Do you have the boat cover with you?

COYLE: Yes, I do.

DISTASO: Didn't realize you brought that down. Let me get that marked.

JUDGE: People's next in order.

GERAGOS: 112.

JUDGE: 112. Package and Contents

GERAGOS: Bag with the,

DISTASO: Bag and boat cover inside.

JUDGE: Bag and contents. Okay. Boat cover.

DISTASO: Detective, could you just pull that out of there, and just fold it? You don't need to unroll. Just hold it up so the jury can see it. And that's the boat cover you found in that small shed on the side of the house?

COYLE: Yes. On the southeast corner of the house, yes.

DISTASO: You can put it back in the bag. Did you also, were you also tasked as part of this investigation, kind of leave the search warrant stuff now. Were you also tasked as part of this investigation to follow up on some of the 290 registrants and parolees that were in the area?

COYLE: Yes.

DISTASO: And how many people did you end up coming in contact with or, reviewing their files, or looking at?

COYLE: There was a list that I was given of about 309 parolees and sex registrants. And out of that, to date, 285 have been contacted and completed.

DISTASO: And when you would contact these, did you contact some of these folks yourself?

COYLE: Many of them myself, yes.

DISTASO: You didn't contact every single one yourself?

COYLE: No.

GERAGOS: There would be an objection and motion to strike as to what had been completed. If he didn't do it himself there is no foundation.

JUDGE: Yeah, there is no foundation for that.

GERAGOS: Plus I was precluded from getting into this with,

JUDGE: He's opening the subject for you now.

GERAGOS: I understand. But the problem is, I was precluded from getting into this with the other officer.

JUDGE: Because it was beyond the scope of direct examination. But now he's opening up for you to pursue it.

DISTASO: He's going to cross examine him.

JUDGE: 285 may be stricken. He doesn't know of this of his own knowledge.

DISTASO: Did you review reports from officers who had talked to some of these other people?

COYLE: Yes. I was in charge of looking at each report as they were completed to determine if as much investigation that could be done had been done on that particular person.

JUDGE: Did you tally up the number that were interviewed?

COYLE: Yes.

JUDGE: Then, all right. Then the answer 285 then may remain.

DISTASO: When you would contact these people, were you, what was your purpose in doing that?

COYLE: To attempt to determine their whereabouts and some verification of that on December 24th, 2002.

DISTASO: And were you able to do that with every single one of these people?

COYLE: No.

DISTASO: Were you able to do it with a large number of them?

COYLE: I would say the biggest majority of, majority of that figure we were able to contact someone who could verify where they were, yes.

DISTASO: And if somebody would come in to you, for example, and, why don't you just take us through what happened. Would you call these people in, or they would come in; is that right? Some of the folks,

GERAGOS: Objection. It's compound.

JUDGE: Question. Sustained. How did, how was this investigation conducted with the sex offenders? How was it done?

COYLE: Several different ways. As I was going to start to explain, some of the folks were registrants. They have dates that they have to be in and register by. If we hadn't contacted them prior to that, on the date that they came in to register, we would interview them then. Many of the folks were contacted because we had their home addresses either through parole or through their 290 records. We put out information through our warrants system that when an officer ran a particular person that we needed to talk to, that name would pop up. They would then be held until the detective or an investigator could interview them. So there were several different methods that we did.

DISTASO: Okay. You had contacted them. Once you get contact with these people, what would you do?

COYLE: We would try and determine their whereabouts, and through some other source verify that their story was true and correct.

DISTASO: What kind of other sources did you look at?

COYLE: In some cases it was employers. A lot of family members. Friends. You know, someone they could say, well, I was with this person, whatever that was, and then we would contact that person to find out if they knew where they were.

DISTASO: If somebody came in and said they were with their mother, for example, would you try to verify their story right then? Or would you wait? Or how would that work?

COYLE: If at all possible, at least the ones that I did, and some of the ones that I witnessed being done, we tried to contact their alibi person while they were still with us, yes.

DISTASO: They would be sitting there and say I was at my mom's house, you say, well, let me call up your mom and see?

COYLE: That's correct.

DISTASO: And of the ones that you were not able to contact, how many have you not been able to really deal with at all?

COYLE: I think there is about 15 or 20 that we have not been able to locate at all.

JUDGE: Is that 290 registrants and parolees?

COYLE: That's correct.

DISTASO: Of the, of those 20 people, are these just people that are just gone,

GERAGOS: Objection. Calls for speculation.

JUDGE: Well, I think it's leading.

DISTASO: Okay. Let me ask you a different way. Of these 20 people, were you able to find out any information at all about some of them?

COYLE: Yes.

DISTASO: What kind of information could you find out?

COYLE: Several of them we determined were deceased, had gone someplace else, out of state, moved out of state, and had died prior to us being able to contact them. Several of them, through the Department of Justice Sex Registrants Website, had indications from other agencies that this person had left the jurisdiction of the State of California. So obviously they moved someplace, but we didn't have any indication as to where. Several of them we determined are actually in prison serving time, and have not been able to contact those folks.

DISTASO: In your investigation of these people, these 290 registrants, the sex registrants, the parolees, of this list of people that you were given to work on, was there any evidence that arose in any of these people that you looked at that led you to believe that any of them had any involvement in the disappearance of Laci Peterson?

COYLE: No.

GERAGOS: Objection. Calls for speculation.

JUDGE: Overruled.

DISTASO: Nothing further, your Honor.

 

Cross Examination by Mark Geragos

GERAGOS: I'm going to do a very limited area.

GERAGOS: Officer, this eight page list which is purple with white that was in your binder, is this the compilation of the sum total of the 290 registrant list?

COYLE: And parolees, yes.

GERAGOS: Okay. There are various columns on this list. One says the name, correct?

COYLE: I believe so. I'm not looking at it right now. But yes.

GERAGOS: Next one says parole. And then there is either a yes or a no, writing or blank, right?

COYLE: Yes.

GERAGOS: Okay. Then it says 290 registrants, for whether or not they are a sex offender that has to register; is that correct?

COYLE: That's correct.

GERAGOS: Then It says next column is contact. What does that mean?

COYLE: Whether or not detective or investigator has spoken to them.

GERAGOS: Okay. Next column has "elim" which is short for eliminated, right?

COYLE: That's correct.

GERAGOS: Okay. Now, in this eight-page document, I'm going to show you page one. It's in alphabetical order, correct?

COYLE: That's correct.

GERAGOS: Where it shows eliminated, you have got, looks would like, what looks like 41 names on this page, right?

COYLE: Yes.

GERAGOS: How many of those would you say eliminated are "no"?

COYLE: Out of that 41 on the first page, looks like, by that, the majority of them.

GERAGOS: Okay. How about page two. How many have not been eliminated, out of the, these go up to 83?

COYLE: How many have not been eliminated, or how many does it say have not been eliminated?

GERAGOS: How many does it say have not been eliminated?

COYLE: Majority of them.

GERAGOS: Page three, which looks like it goes from 84 to 125. Safe to say maybe two thirds haven't been eliminated?

COYLE: According to that, yes.

GERAGOS: Page four, which is 126 through 167, looks to me like out of that page we have got two people have been eliminated out of that crew, isn't it?

COYLE: Two that it says have been eliminated, yes.

GERAGOS: Well, when you do not eliminate, is that some kind of a secret?

DISTASO: Objection. Argumentative.

JUDGE: Overruled.

COYLE: This list.

JUDGE: He was, let the officer finish his answer. What was your answer?

COYLE: This list was given to me. I did not put it together. I did not make the columns. The only thing that I was interested in once it was handed over to me were the alphabetical names, and then the reports corresponding to them. Everything that is in purple there is a report that has been completed for all those persons. Eliminated, not eliminated on that list was done prior to me ever taking control of this.

GERAGOS: Yeah. And you did exactly, by my count, 23 out of these 300, some odd you contacted; is that correct?

COYLE: That's not correct.

GERAGOS: How many did you contact?

COYLE: Two binders full.

GERAGOS: I have got,

COYLE: Somewhere in the area of about 285.

GERAGOS: You personally?

COYLE: No, not me personally.

GERAGOS: You personally contacted how many people?

COYLE: I don't know. Probably 40.

GERAGOS: Okay. Now, on this page, how many have been eliminated?

COYLE: Several.

GERAGOS: On this page how many have been eliminated?

COYLE: How many does it say again have been eliminated? A few.

GERAGOS: 210 to 251, I have got about another 41. What would you, just about six have been eliminated?

COYLE: About that. Again, that's what it says.

GERAGOS: You are in charge of, didn't Mr. Distaso ask you if you were in charge?

COYLE: I don't know if I was in charge of it. I was tasked with making sure that folks were contacted, yes.

GERAGOS: You weren't in charge. That isn't, he didn't ask you if you were in charge of the 290 sex registrants in contacting them?

COYLE: I don't know whether or not he asked in charge or not.

GERAGOS: Okay. Same issue here. It's just a fraction of the people have been eliminated in this list from 235 down to 293?

COYLE: Yes, it says.

GERAGOS: On the last page assume things what are, got one out of 25. One out of two were eliminated?

COYLE: Yes.

GERAGOS: I'd like to reserve the remainder of cross examination of this witness until Thursday, your Honor.

JUDGE: All right, detective, we'll order you back Thursday morning at 9:00 o'clock.

DISTASO: I'd like to redirect.

JUDGE: He hasn't finished his cross.

GERAGOS: I have not finished.

JUDGE: You redirect him after he finishes his cross examination. Otherwise we're going to do it twice. Finishes his cross, you can ask him back for your redirect. Mark it. Let's make a copy and give these back to the officer.

DISTASO: That's fine, Judge.

JUDGE: We'll mark this list of the parolees and sex offenders as defendant's, people's next in order. It's really from the people. Number 113. And we'll,

GERAGOS: Make that defense next in order.

JUDGE: Well it's a People's exhibit. So it's from the people. I'm going make it 113. That's the list of parolees.

GERAGOS: And 290 registrants.

JUDGE: And 290 registrant. And then we'll give this, give this list back to the officer. And we'll substitute a copy for People's Number 113. And then make sure you bring that back.

COYLE: Yes.

JUDGE: He's going to make a copy right now. We'll have Detective Coyle stick around. We'll give it back

15 to him. Give it to you, then give it to Detective Coyle?

DISTASO: That's fine, judge. We can, you can just hand it back to us. We'll give it to him.

JUDGE: All right. He'll give it to you.

 

July 19, 2004

GERAGOS: Detective Coyle, when we left off last week, we were talking about some of these 290 reports and the investigation in connection with them?

COYLE: Yes.

GERAGOS: You had a, you provided me with a list, an eight page list that had a number of names on them; is that correct?

COYLE: That's correct.

GERAGOS: Okay. Do you have the list in front of you?

COYLE: I do.

GERAGOS: Do you see the, I want to avoid using their names, and I'll just refer you to the number, if that's okay.

COYLE: That's fine.

GERAGOS: Second page.

COYLE: Number, number 42.

GERAGOS: Number 42. You have a Bates numbered report in connection with that?

COYLE: Yes, I do.

GERAGOS: Okay. Is this person somebody who was contacted? And cleared?

COYLE: Contacted and completed. The investigation was completed.

GERAGOS: Okay. Now, so that I understand, last week when you and I talked, if I understood it correctly, the eight page list that you gave me contains 300 and some-odd numbers, right?

COYLE: That's correct.

GERAGOS: Out of those 300 and some-odd names, 280 I think were the number you estimated were the people who have been contacted?

COYLE: I believe I said 285. It was close.

GERAGOS: Out of those 285, when we were doing this with the exhibit last week, I don't have it right in front of me, I'll get it at the break, but when we were doing this last week, there was a column that said eliminated?

COYLE: That's correct.

GERAGOS: Did you, and if I understood your testimony correct, this list was given to you at some point having been pre-done, if you will, or collated by somebody prior to you dealing with this whole area, right?

COYLE: That's correct.

GERAGOS: Okay. So when you get the list, somebody has previously alphabetized on some kind of an Excel sheet all of these names of the registered sex offenders in Modesto, is that right?

COYLE: No. It was a select group of registered sex offenders, and some parolees as well. So they're not, not everybody on the list was a registered sex offender. And this is definitely not all the registered sex offenders in Modesto. This is just a particular group that was selected.

JUDGE: If I ask one question?

GERAGOS: Sure.

JUDGE: Because I,

GERAGOS: Sure.

JUDGE: When you testified last time, when you were shown that list you said they've been cleared to date.

COYLE: Completed.

GERAGOS: Completed.

JUDGE: To date. But when you say "to date," what date are you referring to? Is it today?

COYLE: Yeah. Up until today. Now. Up until that date then.

JUDGE: So when you said up to date, they were cleared up at the time you testified two weeks ago?

COYLE: What I meant by that is I have about 24 files that I'm still working on, because those people have never been contacted or located.

JUDGE: Okay. I just thought, just troubling me when he said "to date." I don't know what he meant.

GERAGOS: I understand.

COYLE: In other words, I'm still continuing to go, still continuing to work on those.

JUDGE: Still working on those.

GERAGOS: So I understand the sequence, you, you receive this list that somebody has culled out a, what you call a select group of sex offenders and parolees, is that correct?

COYLE: That's correct.

GERAGOS: Somebody's made an assessment that out of, is it fair to say out of the thousands of sex offenders, of over a thousand sex offenders in Modesto, these are the, these are the most likely, candidates most likely not to succeed?

COYLE: I don't know how many we have. I just know this is not a complete list. I don't know if it's in the thousands or not.

GERAGOS: Okay. Then you don't know what the screening process was to eliminate the others before this list was compiled, do you?

COYLE: Essentially, essentially I do know, based on conversations I've overheard. I wasn't in on the original process, no.

GERAGOS: Okay. So you get this list, and then there's the specific column, which is to the right, that says eliminated; is that correct?

COYLE: That's correct.

GERAGOS: Okay. Now, that to your mind is different than contacted; is that correct?

COYLE: I didn't have anything to do with either, either of those columns as far as contacted or eliminated. I didn't set this up, and I'm not sure what was in their mind. My mindset at the point in time that I got this was what I felt I needed to do with it. It had nothing to do with contacted or eliminated.

GERAGOS: Okay. Now, the, I've counted, I went through your file and I counted approximately 23 either parolees or 290 registrants that you personally talked to; is that an accurate number?

COYLE: I would think that the number, off the top of my head, is a little bit closer to 50 that I personally interviewed.

GERAGOS: Okay. I've got, basically, the reports, and I guess it looks like you've done something since we were last here. You now have Bates number stamps that correspond; is that correct?

COYLE: That's correct.

GERAGOS: Okay. Now, did you do something to, when you contacted them, to either, last week you had said 280 had been contacted; is that correct?

COYLE: No, I said completed.

GERAGOS: Completed means, what does completed mean to you?

COYLE: As far as I'm concerned, that term means that something was done in regards to that person, and it was taken as far as it could go. In some of those cases it was merely checking with vital statistics to find out that that person was deceased. Obviously that's as far as we could go. In some of the cases we interviewed the person himself and an alibi person or two. In some cases we interviewed a staff person for several of the guys that were in a particular program and were in a lock-down facility during that time period. So there's, there's a lot of variation in what we did to complete that.

GERAGOS: Okay. Now, when you get to complete, that does not mean eliminated; isn't that correct?

COYLE: That's correct.

GERAGOS: Okay. So when you say 280 were completed, that does not mean that, by any means, that 280 were eliminated as potential suspects in this case?

COYLE: Essentially I'm the only person I know that I can eliminate.

GERAGOS: You're the only person who makes a determination as to whether or not you can eliminate someone?

COYLE: No, I'm saying that if, if I'm going to say somebody's eliminated, as far as I'm concerned I'm the only guy that didn't do it, that I know of.

GERAGOS: Okay. Well, do you know for a fact, for instance, when somebody has indicated to you where their alibi is, there's a number of these people, and I'll direct you specifically to number 42, did you take a look at this particular investigation?

COYLE: Yes, I did.

GERAGOS: Okay. When you took a look at this, did you conduct this investigation?

COYLE: No, I did not.

GERAGOS: Somebody else did?

COYLE: Yes.

GERAGOS: Was this in one of the ones that you totaled as the 280 for completed?

COYLE: Yes.

GERAGOS: Okay. And this person was listed as what, a parolee or as a sex offender?

COYLE: I'd have to refer back to the report. Is that all right?

GERAGOS: That's fine.

JUDGE: Sure.

GERAGOS: If it helps you, I've got it on 30, Bates number stamp 3579.

COYLE: I do it alphabetically here.

GERAGOS: It actually starts,

JUDGE: Mr. Geragos, if you're going to project it, I think it would be a good idea to cover the names. If you're going to,

GERAGOS: I wasn't planning on projecting it. I was going to avoid that.

JUDGE: Okay.

COYLE: I don't believe he was a parolee, no.

GERAGOS: So, registered sex offender?

COYLE: Sex offender, yes.

GERAGOS: Okay. And then this person was contacted; is that correct?

COYLE: Yes.

GERAGOS: And he claimed that he was out of state; is that correct?

COYLE: Let me check just a second here. You're talking about number 42?

GERAGOS: Yeah. Let me just show you, since we're trying to avoid putting names up, if I could just show you what I'm looking at. Is this the same?

COYLE: Okay. Let me, I'll turn to that page.

GERAGOS: Sure enough. Take a minute to read it to yourself, refresh your recollection.

COYLE: Yes, he claimed he was out of state.

GERAGOS: Okay. And then somebody received a questionnaire, a questionnaire later on that was filled out. The questionnaire was the page you were just reviewing, right?

COYLE: Right.

GERAGOS: Okay. And so they were reviewing the information that this particular gentleman gave them, right?

COYLE: Yes.

GERAGOS: Okay. And the, this particular gentleman, we'll just call him Edward and won't say a last name, Edward stated that he had spent last Christmas Eve with his sister Carol; is that correct?

COYLE: Yes.

GERAGOS: And he said he hadn't seen or talked to his sister in a year, correct?

COYLE: That's correct.

GERAGOS: Okay. The investigator then went out and spoke to another gentleman; is that correct? At the address that was apparently listed for the sister?

COYLE: Yes.

GERAGOS: Okay. And at that address that was apparently listed for the sister, what did the gentleman who was there say?

COYLE: He did not know them and did not have any information on how to contact her.

GERAGOS: In fact, he said that he had lived at that residence for three years, correct?

COYLE: Yes.

GERAGOS: So this registered sex offender is saying I was with my sister, she lives over at this address on blank avenue, and that's where I was a year ago, right?

COYLE: Well, no. According to the report that we just went through, the portion just before that, he claimed that he was with his sister in Patterson. Our officer, or our Detective Blake finds an address through DMV records that he then goes to.

GERAGOS: When he went there,

COYLE: So it's a different, different locations.

GERAGOS: Yeah. But when they went there, they were unable to find any sister as having resided there within the last three years, correct?

COYLE: That's correct.

GERAGOS: Okay. And next they, somebody called the Stanislaus County Sheriff, right?

COYLE: Yes.

GERAGOS: And they said they didn't even have any entries for the sister's name, correct?

COYLE: Right.

GERAGOS: Okay. And this person also on their questionnaire, can you tell me on question number eight of the questionnaire, what was the vehicle that this person has access to?

COYLE: At that time a Chevy van 1985, white.

GERAGOS: Okay. Did that, is that significant in any way to you in terms of this investigation?

COYLE: No.

GERAGOS: Okay. So a van, or white van, mid 80s, with a sex offender who's giving us an address that can't be verified, is this a completed investigation? Does this go into the completed column?

COYLE: Well, there's additional reports.

GERAGOS: Okay. Now, on the additional, is this a completed investigation?

COYLE: Yes.

GERAGOS: The, give you another one that I believe is listed on your list as number 18. Do you have that in front of you?

COYLE: Yes.

GERAGOS: Okay. Now, is this a completed or cleared person?

COYLE: This is a completed one, yes.

GERAGOS: Okay. Now, completed does not mean eliminated, correct?

COYLE: Right. I'm not using that term at all.

GERAGOS: Okay. This person basically said that they were at the Mission, first of all, they're a registered sex offender, correct?

COYLE: That's correct.

GERAGOS: Told the officers that he had slept at the Mission. You knew that to be the Gospel Mission?

COYLE: Yes.

GERAGOS: On the 23rd? Is that correct?

COYLE: Yes.

GERAGOS: He left in the morning of the 24th?

COYLE: Yes.

GERAGOS: Went to the library, he said, at 8:30?

COYLE: That's correct.

GERAGOS: Okay. Then he had gone to the park; is that correct?

COYLE: Yes.

GERAGOS: And then he went to the grocery store?

COYLE: Yes.

GERAGOS: Okay. The, he says he doesn't own a vehicle; is that correct?

COYLE: That's what he says, yes.

GERAGOS: Okay. And is that basically the, he was then looked at, didn't see any signs of a struggle on him; is that correct?

COYLE: That's correct.

GERAGOS: Now, that would have been on what date that somebody looked at him to see if he had signs of a struggle?

COYLE: August 18th, 2003.

GERAGOS: So it would have been about nine months after the incident itself?

COYLE: Yes.

GERAGOS: Okay. And did that then complete the investigation?

COYLE: Yes.

GERAGOS: Did anybody, as far as you know, go to the library to confirm whether he had been to the library?

COYLE: Not as far as I know, no.

GERAGOS: Did anybody go to the place called the Tower Park to see if he had actually been there?

COYLE: Not as far as I know.

GERAGOS: Did anybody go to run a DMV on him to see if he had access to a vehicle?

COYLE: I don't know whether anybody did or not.

GERAGOS: You certainly didn't.

COYLE: I did not.

GERAGOS: And there's no report that's contained in there that shows that?

COYLE: I don't have a report to that effect, no.

JUDGE: Mr. Geragos, would this be a good time to take the afternoon recess?

GERAGOS: Sure.

JUDGE: Ladies and gentlemen of the jury, we'll take the recess until, give you until 3:00 o'clock. Remember the admonition I've heretofore given you. We'll pick up where Mr. Geragos left off.

<recess>

GERAGOS: That one that we just did was the, that was the extent of the investigation as far as you know?

COYLE: Yes.

GERAGOS: Okay. The, that one that looks like, we've got one that looks like on your list, No. 141. And if your, at any point if you want, I know you've got some of the Bates numbers, but I've also got supplemental.

COYLE: Go ahead. I'm with you.

GERAGOS: Is this person, I'll just call him Robert, is this kind of a two-fer, both currently off of parole, at least mid '03 and a registered sex offender, correct?

COYLE: Yes.

GERAGOS: And his last known address was what?

COYLE: I believe the Gospel Mission.

GERAGOS: That's right over by Covena, correct?

COYLE: It's a few blocks away, but, yeah, it's in the general area.

GERAGOS: And then it looks like there was an Officer Locke who did this investigation?

COYLE: That's correct.

GERAGOS: Okay. The first notification was, it looks like sometime in mid January the Modesto parole office tried to or came up with some a list of names of people who were parolees or former parolees?

COYLE: That's correct.

GERAGOS: Okay. He was one of them that's currently discharged from parole and whereabouts were unknown?

COYLE: That's correct.

GERAGOS: And then does, and that was January of '03 was when the person, the whereabouts were unknown, correct?

COYLE: Yes.

GERAGOS: Then the, there was some investigation that was done in an address for a similar name that came back to a place in Citrus Heights?

COYLE: Yes.

GERAGOS: They were unable, however, they went to Citrus Heights, checked the address and were told he didn't live there, correct?

COYLE: Yes.

GERAGOS: And then somebody contacted this guy's ex-employer who advised that he was no longer working for him and they had no current info on him, correct?

COYLE: Yes.

GERAGOS: Does that, does that basically constitute the extent of the investigation as to Robert?

COYLE: Yes.

GERAGOS: Okay. And basically nobody's ever found this person?

COYLE: No, that's correct.

GERAGOS: The next one I'm going to refer you to is 139. And that last one that we did that I called Robert that was a, that was completed in terms of the investigation; is that correct?

COYLE: Yes.

GERAGOS: That's one of the 285 names?

COYLE: Right.

GERAGOS: This person, looks like this person was contacted; is that right?

COYLE: Yes.

GERAGOS: Was originally contacted, where, at the jail?

COYLE: At the jail, yes.

GERAGOS: And that was when, in July of '03?

COYLE: That's correct.

GERAGOS: And this person is a registered sex offender?

COYLE: Yes.

GERAGOS: And where did he list as his address?

COYLE: I believe the mission as well.

GERAGOS: On Yosemite in Modesto?

COYLE: Yes.

GERAGOS: And he was questioned, while he was in the jail that was at Stanislaus County Jail?

COYLE: Yes.

GERAGOS: He was questioned about where he was on the 24th between 8:30 and 5:00?

COYLE: Yes.

GERAGOS: And he said he couldn't remember?

COYLE: That's correct.

GERAGOS: And he had no one to verify his whereabouts?

COYLE: That's correct.

GERAGOS: And he says he remembered, he admitted to being near the foot bridge south of Scenic and Coffee Road?

COYLE: Yes.

GERAGOS: All right. In July he had no visible injuries or scars on his hands or face, correct?

COYLE: According to the report, yes, that's correct.

GERAGOS: Okay. It says he didn't have access to any vehicles?

COYLE: Yes.

GERAGOS: It said he couldn't remember where he was on either the 24th or the 25th?

COYLE: Yes.

GERAGOS: Now somebody told him that they had a day pass or that he had a day pass issued for that day, according to the staff.

COYLE: Yes.

GERAGOS: And he said he didn't remember checking out that day, had no family members to go to and visit, and didn't have any alibi, so to speak; is that correct?

COYLE: That's correct.

GERAGOS: Did that constitute the completed investigation for this gentleman who's No. 139 on your list?

COYLE: Yes.

GERAGOS: All right. And that goes into the count of 285?

COYLE: Yes.

GERAGOS: He had, it looks like No. 68.

COYLE: I'm with you. Go ahead.

GERAGOS: Do you have it in front of you?

COYLE: Yes.

GERAGOS: This person was contacted when?

COYLE: I believe it was on 12/31/02.

GERAGOS: Okay. Now, if I'm correct, it looks like he was contacted by an officer, is it Fainter?

COYLE: Yes.

GERAGOS: Okay. And is this the sum total of the notes that we've got on him?

COYLE: Yes.

GERAGOS: Okay. So he contacted this particular gentleman whose number I gave you, and this guy said he was home alone on Christmas Eve and on Christmas day, his family is from Oakland, he has no friends around and he works at, and he gave a specific thing?

COYLE: Yes.

GERAGOS: Did that complete the investigation of this person?

COYLE: Yes.

GERAGOS: And he goes into the 280?

COYLE: Yes.

GERAGOS: Okay. Do you know how, was he contacted by phone?

COYLE: I believe at that point everybody was being contacted in person.

GERAGOS: And so, as far as you know, nothing was done in order to confirm whether this person was at home on Christmas Eve or Christmas day, all you know is that he was contacted, correct?

COYLE: Yes.

GERAGOS: And he just said I was home alone and then that went into the completed file?

COYLE: That's correct.

GERAGOS: I've got another one here which it looks like 248. No.

COYLE: Oh, sorry. Okay.

GERAGOS: Okay. Now, this person was contacted on May 6 of last year?

COYLE: That's correct.

GERAGOS: And gave his daughter's information as his contact person?

COYLE: Yes.

GERAGOS: Is that to be as an alibi, so to speak?

COYLE: Well, it appears that he said he was going to be going there, gave her name, so it looks like we contacted her. She said he was going to come, but did not.

GERAGOS: And did he say he was home alone on the 24th all day?

COYLE: Yes.

GERAGOS: And that nobody else can verify his statement?

COYLE: Well, when we did contact her she said that she did call him at home on the 24th.

GERAGOS: So she received some calls from him?

COYLE: Yes.

GERAGOS: But she didn't say that she called him?

COYLE: Correct. She talked to him on the phone.

GERAGOS: She talked to him on the phone. He called her. She doesn't recall the exact time, right?

COYLE: Right.

GERAGOS: Do you know if any phone records were obtained to verify that these calls were made?

COYLE: No.

GERAGOS: And this person is a registered sex offender?

COYLE: That's correct.

GERAGOS: In the Modesto area?

COYLE: Yes.

GERAGOS: And was, at least by somebody's judgment, thought to be a high risk-type person?

COYLE: I couldn't say that they thought he was high risk, no.

GERAGOS: He was culled out, so to speak, out of the larger universe of sex offenders that live in Modesto?

COYLE: That's correct.

GERAGOS: Now, I've got another one here that's, it looks like 66. Now, and by the way, the one that I just referred to, I'll call him Larry, Larry is a completed one; is that correct?

COYLE: Yeah.

GERAGOS: Because he was contacted?

COYLE: That's correct.

GERAGOS: And that goes into the 285?

COYLE: That's correct.

GERAGOS: Now, this one I just gave you, 66, is this one not complete?

COYLE: This is not complete, yes.

GERAGOS: Okay. This is a person who has an extensive criminal history?

COYLE: I don't know if I can say extensive. He does have some sex crime history, yes.

GERAGOS: He's been arrested for rape and oral copulation of a child under 14?

COYLE: Yes. Excuse me, sorry, they were all adults, I think.

GERAGOS: Are you looking at 38513.

COYLE: 38513?

GERAGOS: Bates numbered stamp, I'm sorry.

COYLE: Okay.

GERAGOS: Right at the, let me show you mine.

COYLE: Okay.

GERAGOS: Right there, second line, do you want to read that to yourself to see if that refreshes your recollection?

COYLE: Yes.

GERAGOS: Was he apparently arrested for rape and oral copulation of a child under 14 in '83?

COYLE: Yes.

GERAGOS: Then in '85 another arrest for the same crime along, except this crime a sexual battery?

COYLE: Yes, that's correct.

GERAGOS: Okay. The one contact in Modesto was July of '03 was arrested drunk in public?

COYLE: That's correct.

GERAGOS: Okay. It looks like you never were able to find him; is that correct?

COYLE: No, there's additional reports on him under 38496 and 38497.

GERAGOS: Okay. The 38496 says there's a list and it looks like a supplemental report and somebody's classified him as a high risk sex offender. And here they put down that his victims were all adults; is that correct?

COYLE: That's correct. I was reading from this page originally before you referred me to the other one.

GERAGOS: Okay. This person specifically was later contacted this year?

COYLE: Yes, he was.

GERAGOS: Okay. He was drinking when he was contacted?

COYLE: Yes, appeared he had been drinking, but he was non-intoxicated, according to the officer that interviewed him.

GERAGOS: Okay. Now, did you at any point, this was not completed and why was that?

COYLE: I did not sign off as this one as a completed because they attempted to contact the father to verify his alibi and apparently was unable to reach him and there were no later indications that they were able to talk to him.

GERAGOS: Okay. So he gave his father as an alibi for the 24th; is that correct?

COYLE: That's correct.

GERAGOS: And nobody's been able to contact the father to see whether that was correct?

COYLE: As far as I know, yes.

GERAGOS: Okay. Somebody spoke to his sister and she indicated that she's not sure where he was on the 24th, he might have been in Modesto; is that correct?

COYLE: That's correct.

GERAGOS: He didn't live in Modesto, did he?

COYLE: No.

GERAGOS: It appears that she, I guess the sister, she being the sister, indicated that she thought that on the 24th of December her brother may have been in Modesto, right?

COYLE: She, I think she said she didn't know where.

GERAGOS: Okay. Did you show her anywhere where he has access to vehicles?

COYLE: No.

GERAGOS: Okay. Did anybody run a DMV as far as you know showing if he's got any vehicles?

COYLE: Not as far as I know.

GERAGOS: Do you know if anybody ran his father's DMV to see if he had any vehicles?

COYLE: I don't have that information either.

GERAGOS: Okay. I will show you, and is that the extent of the investigation at this point as far as you know?

COYLE: To this date, yes.

GERAGOS: Okay. Now, there's a, I'm going to point you to another one, numerical list. I'll just show it to you to see if you can find it for me because I'm having trouble with the first name. It's Bates No. 32582.

DISTASO: What's the number on the list?

GERAGOS: I can't tell because it doesn't, That's the witness, who's the subject here?

COYLE: 1, 2, 3, 4.

GERAGOS: I'll take them in order then. We'll start with the first one who is, it looks like 238.

COYLE: 238. Is that right, 238?

GERAGOS: 238, that's the first one in this report?

COYLE: Yes.

GERAGOS: Okay. And it looks like in this, and correct me if I'm wrong, Officer Beffa, did some investigation, right?

COYLE: Yes.

GERAGOS: And he talked to somebody who was in charge of the halfway houses?

COYLE: Yes.

GERAGOS: And where is this, where are these halfway houses located?

COYLE: On Angle Lane in Modesto, which is out in the Yosemite Boulevard area.

GERAGOS: How far away is that from Covena?

COYLE: Oh, eight, ten blocks maybe, maybe a little further.

GERAGOS: So this is separate and apart, this Angle Lane halfway house is separate and apart from the Gospel Mission area?

COYLE: That's correct.

GERAGOS: Okay. So we the Gospel Mission, which is five or six blocks away from the Covena house?

COYLE: I think it's a little more than that.

GERAGOS: Less than a mile?

COYLE: Yeah.

GERAGOS: Okay. And we've got a halfway house that also has parolees and sex offenders living at it and that's approximately how far away?

COYLE: It's probably a couple blocks further than the mission, but, again, this is sort of the same general area.

GERAGOS: Okay. When you contacted or Officer Beffa contacted the person who runs the halfway house, he was told that there were one, two, three, four registered sex offenders that were there at the appropriate time period?

COYLE: Actually, the report that you're referring to under 32940 is really an additional supplement because all four of those subjects had previously been contacted, but the Randall Hughes, the witness, had not been indexed so the officer was sent back out to re-contact him and get his information and verify.

GERAGOS: Were all four of these people, was that completed at that point?

COYLE: Yes.

GERAGOS: Now the underlying investigations as to those four individuals, were you able to establish in any of those four where the people were on the 24th?

COYLE: Just referring to the one subject that you started with in that one, the first one there, according to him, and when he was originally interviewed, he said he was at the Bethesda Ministries all day the entire day.

GERAGOS: Okay. Was Mr. Hughes the guy, the witness that was contacted, was he able to verify that?

COYLE: Yes.

GERAGOS: How about the second person that was there, which I think is, it looks like number 70?

COYLE: Yes, he also was interviewed and said that he was there all day long.

GERAGOS: Okay. And the next, the other two, same thing?

COYLE: I can't see that, the third one there.

GERAGOS: And the third one?

COYLE: Was, I can't see that he was contacted, however, he went to the halfway house and ended up speaking to Mr. Hughes again, the witness who verified he was also there.

GERAGOS: That's No. 1, isn't it?

COYLE: That's correct, No. 1.

GERAGOS: He hasn't been contacted, correct?

COYLE: Reading this report, it does not appear he was personally, no.

GERAGOS: Okay. And then the last one looks like, let's see if I can remember the number.

COYLE: 155.

GERAGOS: Right. Contacted or not?

COYLE: Yes, he was and he says that he was there all day.

GERAGOS: Okay. Did you receive any records from the, this halfway house showing like a sign-in sheet or anything like that?

COYLE: No.

GERAGOS: Did you receive any parole notifications or anything of that nature that would have verified that the people were there on the 24th and the 25th?

COYLE: There was nothing to do with parole, no.

GERAGOS: Okay. Did you have anything at that halfway house, other than Mr. Hughes saying that they were living there at the time?

COYLE: No.

GERAGOS: Okay. And Mr. Hughes is a person who's in charge of the location, if I understand correctly?

COYLE: He's staff there, yes.

GERAGOS: Staff. Okay. Then I'm going to point you to a No. 35.

COYLE: I'm with you. Go ahead.

GERAGOS: Okay. Did this, were you able to contact this person?

COYLE: Yes.

GERAGOS: Okay. And when you contacted this person, were they able to give you some information as to where they said they were on the 24th?

COYLE: Where he said he believed he was, yes.

GERAGOS: And where did he say he believed he was?

COYLE: Visiting his brother out of town.

GERAGOS: Did you contact his brother?

COYLE: Yes.

GERAGOS: Did his brother tell you he was unable to give you an answer?

COYLE: He said he couldn't recall whether it was the 24th or the 25th that his brother was there.

GERAGOS: And he said he needed to think about it before giving you a definite answer?

COYLE: Yes.

GERAGOS: He said his brother later called you back?

COYLE: I contacted him later personally, yes.

GERAGOS: And he said he could not recall for sure whether it was Christmas Eve, Christmas day or Christmas day and the day after?

COYLE: That's correct.

GERAGOS: And did that complete the investigation as to him?

COYLE: Yes.

GERAGOS: Okay. And let me show you, ask you to refer you to No. 9.

COYLE: Go ahead.

GERAGOS: This person is a registered sex offender?

COYLE: Yes.

GERAGOS: Okay. When you first tried to find him, somebody tried to, it wasn't you personally, back on December 29th?

COYLE: Yes.

GERAGOS: Okay. He listed an address on Kerr, K-e-r-r?

COYLE: That's correct.

GERAGOS: Two officers went over to try and contact him at that Kerr Avenue address?

COYLE: Yes.

GERAGOS: Now, when a registrant lists an address, it's extremely important, it's a violation of law if they are listing an address where they are not staying, correct?

COYLE: That's correct.

GERAGOS: Okay. That in and of itself can be a strike offense, correct?

COYLE: I wouldn't have any information about strikes, I just know it is a criminal offense, but I don't know what.

GERAGOS: Okay. When the officers went over to this address on Kerr Avenue, what happened?

COYLE: Apparently there was no one there that answered the door. They talked to somebody else who said that their relative was in charge of the property and they didn't know the person we were looking for.

GERAGOS: Okay. You went a little bit farther and said no one under the name of this particular sex offender lived at that location, correct? I'm looking at the first paragraph.

COYLE: Right, he didn't know anybody by that name staying at the residence, yes.

GERAGOS: Okay. Then at some point somebody went back to this Kerr Avenue address?

COYLE: That's correct.

GERAGOS: And they interviewed two people who lived there, two residents?

COYLE: Yes.

GERAGOS: Both the residents said they lived at that residence for how long?

COYLE: Two years.

GERAGOS: And they didn't know this sex offender and no one under his name stayed with them?

COYLE: That's correct.

GERAGOS: They had a back house, but there was no one under this sex offender's name who lived there?

COYLE: That's correct.

GERAGOS: And whoever the officer was, I think Musto, went to the back house and contacted the resident and she also denied knowing who the person was and she lived there for over a year?

COYLE: That's correct.

GERAGOS: Then at some point somebody conducted a driver's license check?

COYLE: Yes.

GERAGOS: They found a name that matched that had another address?

COYLE: Yes.

GERAGOS: Okay. Went to the address, attempted to contact him, no answer?

COYLE: That's correct.

GERAGOS: Left a note?

COYLE: Yes.

GERAGOS: Do you remember what date that was? It's either May 5th

COYLE: I believe it's May 5th, yes.

GERAGOS: Okay. Then this gentleman was contacted on May the 7th?

COYLE: Yes. He actually leaves a message on the 6th or he telephoned on the 6th and they arranged for a meeting on the 7th.

GERAGOS: He said he was at home on the 24th between 8:30 and 5:00?

COYLE: Yes.

GERAGOS: And he said he might have visited some friends in the surrounding area, that he would not have done so until after 5:00 o'clock?

COYLE: That's correct.

GERAGOS: He says he has a car, a four-door Accord?

COYLE: Yes.

GERAGOS: And did that complete the investigation of this gentleman?

COYLE: Yes.

GERAGOS: That went into one of the 285 that was noted by you to be complete?

COYLE: Yes.

GERAGOS: I've got another one that's listed on your list as I think 101?

COYLE: 101. Go ahead.

GERAGOS: Okay. Now, the, specifically this person was contacted by Officer Musto?

COYLE: Actually, it was two officers together, Officer Kelly and Officer Musto, I believe.

GERAGOS: Was this person contacted over the phone?

COYLE: In person on one occasion. I'm looking to make sure that he wasn't.

GERAGOS: I'm at 3120. Is that what?

COYLE: Yes, on that occasion that was by phone.

GERAGOS: Now this person by phone said he had never seen Laci Peterson before and never had contact with her?

COYLE: That's correct.

GERAGOS: Then he says, "I observed no visible signs of cuts or scratches on this gentleman's arms or hands"?

COYLE: Yeah, I believe he does a supplement later saying that was entered in error there.

GERAGOS: Because it would have been very hard to observe that, he didn't have a video, phone or anything?

COYLE: Absolutely. It would have been hard.

GERAGOS: So at some point later on somebody goes back and takes a look and sees that on this report he's got telephone contact and he's writing in the report "I observed no visible signs of cuts or scratches"?

COYLE: That's correct.

GERAGOS: Okay. Was this person completed?

COYLE: Yes.

GERAGOS: And this person had access to a car? I'm once again referring you to the neighbor who gave Officer Kelly and Musto the original information that same as?

COYLE: Yes, it appears he has a car that's connected to him somehow, yes.

GERAGOS: And this was a completed investigation?

COYLE: Yes.

GERAGOS: And goes into that list of 285?

COYLE: Yes.

GERAGOS: Now, I'm going to return for just one moment to the gentleman you started off with. There was

COYLE: Which number was that?

GERAGOS: It was No. 42.

COYLE: Go ahead.

GERAGOS: Okay. Now, this person had a history of mental illness; is that correct?

COYLE: I don't know if I could say "history," we did contact him at our mental health facility at one point.

GERAGOS: He was not apparently in an institution on the 24th and 25th?

COYLE: I don't believe he was, no.

GERAGOS: Okay. He was interviewed by one of the sergeants, correct?

COYLE: No, I don't think so.

GERAGOS: It looks like Sergeant Conner, Corder, I'm sorry. Is it Corder?

COYLE: Well, that's, that is, yeah, that's who spoke to our detective but

GERAGOS: Okay. So Sergeant Corder, if I understand what happened with this particular person, Sergeant Corder arrested this gentleman for some vandalism and traffic violations?

COYLE: Yes.

GERAGOS: And while he interviewed this guy, this guy claimed he committed a murder in Modesto around Christmas time?

COYLE: Yes.

GERAGOS: Said he murdered a female named Alisa Peterson at Scenic Park?

COYLE: Yes.

GERAGOS: He said the only witness was the dog?

COYLE: Yes.

GERAGOS: Said he was driving his sister's white Chevy van during that time period?

COYLE: Yes.

GERAGOS: Said he murdered her by breaking her neck?

COYLE: Yes.

GERAGOS: And then he called friends over to pick up the body and drive it over to the Bay Area?

COYLE: Yes.

GERAGOS: Now it looks like on the next page that there was an Officer Wolfe who interviewed this gentleman later on; is that correct?

COYLE: That's correct.

GERAGOS: And that would have been about a year later in sometime December 2002?

COYLE: Yes.

GERAGOS: 2003, I'm sorry.

COYLE: 2003.

GERAGOS: And he was eliminated, is that correct, as a suspect because of his history of mental illness?

COYLE: No, I wouldn't say he was eliminated. I can't say eliminated at all. He was completed because of the witnesses who were also interviewed by our detective.

GERAGOS: Can I show you a report by Detective Brocchini?

COYLE: Yes.

GERAGOS: Okay.

COYLE: I've got that.

GERAGOS: You've got that there. Did Detective Brocchini write Kegel was eliminated as a suspect because of his history of mental illness?

COYLE: That's what's written here, yes.

GERAGOS: Okay. You certainly weren't going to eliminate him because he's got a history of mental illness?

COYLE: I didn't want to eliminate anybody, but, I mean, I didn't want to eliminate him at all, no.

GERAGOS: Okay. But that report was prepared, the one that you and I are reading from is from Brocchini; is that correct?

COYLE: That's correct.

GERAGOS: Is it a fair statement, I'm not going to go through every single one of these. I mean, you've got Bates number stamped here. Is the selection of the number of these items that I've gone through, has that been somewhat typical of what you would find if we went through the 280 of these?

COYLE: No. I wouldn't say so.

GERAGOS: Has there been an out of whack from the others?

COYLE: Just from memory, I would say the vast majority of the 285 there was some person who said, whether his employer, a relative or whatever that said I was with him on that day. Do I know whether they were lying or not? No, I don't. But the vast majority who said I was with him and they were here.

GERAGOS: Okay. And when you say the "vast majority," either a friend or a mother or wife or somebody would say

COYLE: Employer in several cases.

GERAGOS: Say I was with him. The rest were, fall into the categories of the ones we done today or this afternoon?

COYLE: No, I wouldn't even say the rest. Then there were a large group that were incarcerated in county jails in California state prison system and state prisons outside of California at the time. Then there was a group who were deceased.

GERAGOS: Well, how many would you say, you had a category or somebody had a category as "eliminated"; correct?

COYLE: Not me.

GERAGOS: You did not?

JUDGE: Not eliminated, completed.

GERAGOS: But somebody had started that category prior to you?

COYLE: Right. Somebody did.

GERAGOS: You, however, did not eliminate anybody unless they were incarcerated or dead; is that correct?

COYLE: Well, I didn't even consider them eliminated. I mean I guess they would be if they were dead at the time, sure. But I wasn't going by that, I was going by completed investigations.

GERAGOS: Now, the, I think you were also asked on direct whether you had been in the house on Covena on the 26th and the 27th?

COYLE: Yes.

GERAGOS: And what was your function on the 26th and the 27th?

COYLE: I was assisting in the search. I was one of the search team members.

GERAGOS: Now, what, specifically what area did you, were you responsible for?

JUDGE: Detective Coyle, there's a pointer there.

COYLE: Initially the master bedroom, and then eventually assisting in some of the outside areas, and a little bit in the dining room and kitchen area as well.

GERAGOS: Now in the master bedroom did you see a hamper in there?

COYLE: Yes.

GERAGOS: Now, I've got one photo, it's not really great, it's not color, but does that look like the hamper that you saw in there?

COYLE: Yes, the bottom end of it, yeah.

GERAGOS: Okay. Now, is it a fair statement that when you went in there you did not see what appears to be People's 10 in the hamper?

COYLE: No, that's not a fair statement.

GERAGOS: I'm going to show you some notes. Tell me if you know what these are.

COYLE: Well, I see what it says.

GERAGOS: Can I ask you, did you say that you've been shown, did you tell somebody that you've been shown the photograph of the hamper from 12/26, 12/27 search?

COYLE: Yes.

GERAGOS: Did you tell them you did not recall seeing the shirt that I'm pointing to, this shirt, People's 10, is that what you referred to?

COYLE: When I said at that point in time

JUDGE: It's not a shirt, I think it's a maternity blouse.

GERAGOS: I'm just using "shirt" because that's what on the notes. But I assume what you're referring to was the blouse, People's 10?

COYLE: That's correct.

GERAGOS: In the notes it indicates that you did not recall seeing the shirt, did you tell them that?

COYLE: When I was, that conversation was in regard to, did you see this particular shirt? I said, gee, I don't recall that. I don't remember that. I was then shown a photograph and I said, well, yes, now I recall it. But at the point in time prior to being shown the picture, I didn't remember that specific item.

GERAGOS: Did you, now you apparently, if I understand correctly, we've had some testimony from some of the other officers, the officers would be If I can mark this as next in order.

JUDGE: Okay.

GERAGOS: I'll find the color and substitute the color.

JUDGE: OOOO.

GERAGOS: Were you assigned or somebody else to search the master bedroom?

COYLE: Not, not necessarily. I believe I began searching it myself. There were other officers that came along as they finished their specific areas.

GERAGOS: Now, I'll give you another exhibit, which is People's 7. Is that how the hamper looked when you went in there to do the search?

COYLE: Well, I actually had partially searched it originally on the evening of the 26th, then completely searched it on the 27th. I don't recall when that photo was specifically taken, whether it was after the partial search, before any search was done, the photographs upon leaving the residence or somewhere in between.

GERAGOS: These, is it a fair statement that you had gone in, had taken a look at the stuff or searched on the 26th; is that correct?

COYLE: That's correct.

GERAGOS: Came back the next day on the 27th, searched again?

COYLE: That's correct.

GERAGOS: Okay. Would that explain, for instance, why People's 7 looks like that and then the items that I'm marking, which I'm taking from a video camera look like they do?

COYLE: That's correct.

GERAGOS: And also a fair statement that it appears it looks like it's light in that room?

COYLE: Right. This was daylight.

GERAGOS: Okay. That would have been a video taken the next day on the 27th?

COYLE: Correct. And this may have been the exit video.

GERAGOS: The exit video. So that would have been after somebody had searched that hamper area at least once or twice; is that correct?

COYLE: Correct.

GERAGOS: And does that, do those two pictures that I showed you accurately represent what the condition of the hamper was when you left the house?

COYLE: Well, I can't say for sure that that was the exit video. I'm just assuming that but

GERAGOS: Because it's day time and it appears different in terms of the clothes that are in the hamper?

COYLE: That's correct.

GERAGOS: Now, I'm specifically going to set these up here for one second. You don't need to look at them quite yet, but let me just finish here. So this is the hamper presumably when you come into the house; is that correct?

COYLE: Again, I don't know when that photograph was taken. I don't know if this was prior to any searching or whether that was after I had initially searched it. I also don't know whether somebody came along behind me and searched again.

GERAGOS: Now, when you have the next photo. We've got, this is the one that we were referring to that looks like it's light in the room?

COYLE: Yes.

GERAGOS: And also appear that there's some blue items there. And I'll show you one of the other pictures because it loses something in the projection. Does that look blue to you?

COYLE: Powder blue, although, it's hard to tell with the light. It may be white and it's just reflecting. I'm not sure, but light colored.

GERAGOS: I'm showing you People's 17, did you notice these pajamas in this hamper?

COYLE: Actually, it almost looks more like a shirt than pajamas as far as the color, but it's hard to tell because of the video still.

GERAGOS: Did you, when you did the search, did you itemize what was in the hamper?

COYLE: No.

GERAGOS: Did you, is there anyplace in your report where you note what was in the hamper?

COYLE: No.

GERAGOS: Now the, you did seize a comforter; is that correct?

COYLE: I didn't seize anything. I did point out a comforter, yes.

GERAGOS: Is this the comforter? <4Q>

COYLE: Yes.

GERAGOS: And is this comforter as well?

COYLE: Yes.

GERAGOS: Okay. Both these pictures accurately represent the comforter on the day you did the search?

COYLE: Yes.

GERAGOS: And there's, it looks like a little square, not at square, but a right angle ruler there; is that correct?

COYLE: That's correct.

GERAGOS: Mark these next in order.

JUDGE: Quadruple Q1 and 2.

GERAGOS:

GERAGOS: Now, the comforter was taken because it appeared that there was a small stain on it; is that correct?

COYLE: Yeah, two small spots. I just pointed them out to Detective Skultety.

GERAGOS: Can you tell me on here, can you see the two small spots?

COYLE: Definitely not, no.

GERAGOS: That's quadruple Q1. This is quadruple Q2. Can you see the two small spots in that picture?

COYLE: I can't from here, no.

GERAGOS: I'm going to show you the item not projected. Can you see it there?

COYLE: I can see one of them.

GERAGOS: How big would you say the spot was?

COYLE: I mean, it was just fractions of an inch.

GERAGOS: 16th, 32nd, fleck?

COYLE: Maybe an eighth, eighth of an inch.

GERAGOS: And is that why you put, is that item that's right there at the vortex, if you will?

COYLE: Yes.

GERAGOS: May I publish this to the jury because it's hard to see?

JUDGE: If you want to move it into evidence.

DISTASO: No objection.

JUDGE: Okay. You can publish it to the jury. So QQQQ1 is admitted into evidence, same number, same letter.

GERAGOS:

GERAGOS: Now, did you, you hand searched the entire room; is that correct?

COYLE: Yes.

GERAGOS: Okay. And when you say hand searched, what do you mean by that?

COYLE: It means I opened stuff, went through things, handled things. Rather than a visual search, I handled things.

GERAGOS: Okay. And that was done on the 26th when you came in?

COYLE: I little bit, yes.

GERAGOS: Okay. Did you do more of that on the 27th?

COYLE: Yes.

GERAGOS: And when did you that on the 27th were you also looking for forensic evidence of some kind?

COYLE: Well, I mean if I had seen any, I'm sure I would have called that to someone's attention, but we actually did the forensic search on the evening of the 26th prior to doing hand searching.

GERAGOS: And did you on that day you executed the search warrant, find a binder with some life insurance documents on it?

COYLE: Yes.

GERAGOS: Do you know where you found those from?

COYLE: I believe it was on the bookshelf in the second bedroom, the room that was set up kind of as a guest room, office-type room.

GERAGOS: Does that picture look familiar?

COYLE: Yes.

GERAGOS: Is that you?

COYLE: That's me.

GERAGOS: With the placard and the bookshelf and pointing to the life insurance document?

COYLE: Actually, I'm just holding the placard next to it, but, yes.

JUDGE: Quadruple R.

GERAGOS: Does that accurately represent what was going on that day?

COYLE: Yes.

GERAGOS: And how the room looked?

COYLE: Yes.

GERAGOS: The life insurance documents, were those the principle life documents that are dated 6/25 of '01?

COYLE: At this point I can't recall. I just pointed the documents out to Detective Skultety who was collecting.

GERAGOS: That would have been from right about here?

COYLE: Yes.

GERAGOS: Do you want to mark that with red. What the judge has been asking, if you just draw a line out to the margin and then write "life insurance" or "LI"?

COYLE: (complies.)

GERAGOS: Okay. Now, did you also search the kitchen area?

COYLE: Yes.

GERAGOS: And you found a camera there, correct?

COYLE: Yes.

GERAGOS: Okay. And then while you were there you also located the tarp, the boat tarp?

COYLE: Well, once I went outside, not while I was searching the kitchen, but, yes.

GERAGOS: Okay. And where did you locate that?

COYLE: Actually, I found it originally when we were doing a walk-around on the 26th I pointed it out to Detective Brocchini, and then on the day of the 27th it was out in the backyard area.

GERAGOS: Okay. After you, did you point out anything besides the placard that I showed or that's up there with the life, that pertain to the life insurance and the comforter that you put, that the jury's looking at right now, did you point out anything else at the house?

COYLE: Yes.

GERAGOS: What else?

COYLE: Numerous items. Several pieces of jewelry, a diary out of the dresser, a pair of shoes out of the closet, passports, a Social Security card. I believe I also found a checkbook that I pointed out in the bedroom, the other bedroom. I can't recall whether that was taken into evidence or not.

GERAGOS: Okay. Did you, when you were in the bedroom, did you look for, were you looking for some black maternity pants?

COYLE: Yes.

GERAGOS: Okay. Can you tell me, did you find some black maternity pants hanging in the closet on a hanger?

JUDGE: In the master bedroom.

GERAGOS: In the master bedroom?

COYLE: I don't recall that, no.

GERAGOS: You recovered some from the nursery; is that correct?

COYLE: Someone did, yes.

GERAGOS: Okay. Now, at some point were you told that you had found some black maternity pants in the closet of the home hanging on a hanger?

COYLE: Somebody told me apparently according to that report, yes.

GERAGOS: Okay. Well, what I'm asking you is, when you went through, did you not see the black maternity pants hanging on a hanger?

COYLE: I did not find any black maternity pants, no, not in the master bedroom.

GERAGOS: Were you later told that there were some that were hanging up?

COYLE: I believe I was told there were some black maternity pants found, I don't know where they were found.

GERAGOS: Okay. And did you tell, was this Detective Grogan?

COYLE: I don't know who wrote that report. I didn't see who was the author there.

GERAGOS: Did you tell them, Detective Grogan, that there was a pillow in the bedroom where the dog slept?

COYLE: Yes.

GERAGOS: Is that correct?

COYLE: Well, I mean obviously it appeared to be that. I don't have any information that that's actually where the dog slept, but that's what it looked like.

GERAGOS: Okay. The, specifically the, you were shown a series of photographs by Detective Grogan in February; is that right?

COYLE: That's correct.

GERAGOS: Okay. And they, they told you basically, the detectives, that they were looking for a specific recollection by you of certain items; is that correct?

COYLE: A specific item, yes.

GERAGOS: Okay. And they told you that they were trying to determine if the clothes were inside the house on that date?

COYLE: That's correct.

GERAGOS: Okay. And they showed you various items; is that correct?

COYLE: Photographs, yes.

GERAGOS: Okay. And one of them was the hamper; is that right?

COYLE: That's correct.

GERAGOS: And the photos that I just went through?

COYLE: That's correct.

GERAGOS: Okay. You could not, at that point, say anything except that you remembered that you found some khaki-colored men's walking shorts; is that correct?

COYLE: That's correct.

GERAGOS: You found corduroy men's pants?

COYLE: That's correct.

GERAGOS: White or tan pajama top?

COYLE: Yes.

GERAGOS: There were two pairs of boxer shorts and a pair of women's panties in the hamper?

COYLE: Yes.

GERAGOS: Now, did you

COYLE: Those were the items that I could recall seeing.

GERAGOS: Right. And you did not, and that item that I just showed you, you didn't recall seeing the blouse, the black and tan blouse, correct?

COYLE: When they asked me if I remembered seeing a black blouse, I said I couldn't recall seeing that, but obviously once I saw the photographs, yes.

GERAGOS: Okay. Well, when they asked you, and I'm going to show you this report, did you state you did not see the blouse during the search of the house?

COYLE: I don't believe that were my words. I said I didn't remember it.

GERAGOS: Would this report by Grogan be inaccurate if it says "Coyle said he did not see the blouse during the search of the home"?

COYLE: I'm not sure I can say inaccurate, I'm just not sure that that's what I said exactly. Maybe that's what he interpreted, but I don't recall if that's what I said.

GERAGOS: Did you also tell them that you did, when you were doing the hand search, you were opening drawers?

COYLE: That's correct, yes.

GERAGOS: And as you were opening the drawers were you pulling out clothes?

COYLE: I don't think I really pulled anything out. I sort of lifted stuff up, looked underneath, you know, felt around in between, but I don't think I pulled clothes out of the drawers, no.

GERAGOS: Okay. And you told that to Detective Grogan that you did not unfold each item of clothing from the drawers; is that correct?

COYLE: That's correct.

GERAGOS: And some of the items of clothing that you were looking for could have been present, correct?

COYLE: Well, I guess I was trying to say that I didn't see anything. I was given a briefing as everyone else was for the specific items. I didn't recall seeing those, but, again, I told him I didn't unfold each item. So theoretically something could have been present there that I missed, but I didn't see the ones I was looking for.

GERAGOS: Now, was there an issue of a camouflage jacket that you were also looking for?

COYLE: It seems to me that that was part of the briefing information, however, I don't recall seeing a jacket.

GERAGOS: Okay. And on the search warrant on, were you there on 2/18 as well on February 18th?

COYLE: No, I was not.

GERAGOS: Okay. Did they ask you if the camouflage jacket was hanging inside the closet on 12/26 or 12/27?

COYLE: I can't recall if I was asked that or not.

GERAGOS: Let me show you one paragraph and see, and this is Detective Grogan's 3/13 report, the yellow highlighted portion, can you read that silently to yourself and see if that refreshes your recollection.

COYLE: (complies.)

GERAGOS: Does that refresh your recollection?

COYLE: Yes.

GERAGOS: Okay. Would you tell me if you were asked if you had seen the camouflage jacket hanging in the house on December 26th or 27th?

COYLE: Yes.

GERAGOS: And what did you tell them?

COYLE: That I did not see one.

JUDGE: Let's stop right there.

 

July 20, 2004

GERAGOS: Good morning.

COYLE: Good morning.

GERAGOS: Officer Coyle?

JUDGE: Or Detective Coyle?

GERAGOS: Detective?

COYLE: (Nods)

GERAGOS: Detective Coyle, yesterday we talked at some length about the 290 registrants. And I went back and looked at some of the others last night. Do you have your file there?

COYLE: I do.

GERAGOS: Or your list? The first one I'd point you to is, looks like number 84. And then I show a Bates stamp of 3151.

COYLE: Yes.

GERAGOS: Okay. Now, this person was on active parole; is that correct?

COYLE: Yes.

GERAGOS: Okay. And had a, it looks like had access to a, some kind of a SUV or minivan or something like that; is that right?

COYLE: Some type of vehicle, yes.

GERAGOS: Okay. And then also the last known address was this Yosemite and Kerr, K-E-R-R. Do you know where that is?

COYLE: Yes, I do.

GERAGOS: What is that location?

COYLE: Just an intersection Yosemite Avenue and Kerr Avenue. Yosemite Boulevard and Kerr Avenue, which is very close to the Gospel Mission.

GERAGOS: Okay. Now, he said that he was, when asked about where he was on December 24th, he said that he was at his mom's house and he gave an address, correct?

COYLE: That's correct.

GERAGOS: And said he was sick that day, doesn't keep track of time real well?

COYLE: That's correct.

GERAGOS: But he said his mother would verify his whereabouts; is that correct?

COYLE: That's correct.

GERAGOS: And then his mother was contacted, correct?

COYLE: Yes.

GERAGOS: And she said she couldn't verify his whereabouts?

COYLE: That's correct.

GERAGOS: And she also said that there was no indication at her home that he had ever been there that day; is that correct?

COYLE: Yes.

GERAGOS: Okay. And that was referring to the 24th of December?

COYLE: Yes.

GERAGOS: Now, this was an investigation that was done by Officer J. Locke, L-O-C-K-E, and this was done exactly a week later. This was done on the 31st of December; is that right?

COYLE: I believe so, yes.

GERAGOS: At least that's the date that's on the report itself. So, obviously, if the report was generated on December 31st, the contact was made sometime within that week is my guess; is that accurate?

COYLE: That's correct.

GERAGOS: Okay. Does that constitute a completed investigation?

COYLE: Yes.

 GERAGOS: Okay. And the next one I'm going to point you to is listed as the last one on the page, 209. And then if it helps, the Bates number that I've got is 32902.

COYLE: Okay, I'm with you.

GERAGOS: Okay. Now, this person is a 290 registrant, which means he's a convicted sex offender, correct?

COYLE: That's correct.

GERAGOS: Okay. And he said he was living in the alley. He was contacted, said he was living in the alley behind the social security office on 11th Street?

COYLE: Yes.

GERAGOS: He said on the 24th of December he was with another gentleman, that he named, in the alley, right?

COYLE: That's correct.

GERAGOS: They smoked marina, snorted some speed together?

COYLE: Yes.

GERAGOS: And then his friend left and he remained in the alley with some adult magazines; is that correct?

COYLE: That's correct.

GERAGOS: Containing pictures of nude women, and then he engaged in some self-flagellation or something; is that correct?

COYLE: That's correct.

GERAGOS: Okay. That, he said he was unable to tell you where the friend was who was in the alley with him?

COYLE: Yes.

GERAGOS: Okay. And he says he was shot in the head during a prior incident?

COYLE: Yes.

GERAGOS: Okay. And he apparently was responsive to some questions, but then would talk about a myriad of other things and made no sense?

COYLE: Yes.

GERAGOS: All right. And this was an investigation that was conducted by, is it Officer Banks?

COYLE: Yes.

GERAGOS: And this investigation was conducted September, or the interview, at least, was conducted on September 18th of last year?

COYLE: That's correct. Oh three.

GERAGOS: And this would constitute a completed investigation?

COYLE: Yes.

GERAGOS: The next one is a number 200. And if it helps, I think it's 381, looks like 66. I could be wrong.

COYLE: Probably 38136.

GERAGOS: 136. Could be.

COYLE: I'm with you. Go ahead.

GERAGOS: Okay. Now, this is a person who's also a registered sex offender, correct?

COYLE: Yes.

GERAGOS: And this person was at the Mission? Or I guess they went to the Mission; is that correct?

COYLE: Yes.

GERAGOS: Okay. And apparently the person who's the registered sex offender had not been at the Mission for two years; is that your understanding?

COYLE: Yes.

GERAGOS: So the address that was on, did, you get kind of a database for registered sex offenders at the police department, right?

COYLE: That's correct.

GERAGOS: Part of what the law is is that if a person is a convicted sex offender and they're released from prison, they have to go and register within five days at the police department, correct?

COYLE: Yes.

GERAGOS: And then that list, that database is maintained under a, in a computer log, right?

COYLE: That's correct.

 GERAGOS: Okay. This person listed his address as the Mission, right?

COYLE: I'm not for sure on that. That may have been one of the places he was staying, but I don't know if that was his registered address or not.

GERAGOS: Okay. Then the officer who went out to do this investigation went to the Mission, he hadn't been at the Mission for two years, then they went to another address that had been listed on the driver's license back in 99; is that right?

COYLE: That's correct.

GERAGOS: Okay. And they contacted somebody there, and that person said he had never heard of the sex offender, right?

COYLE: That's correct.

GERAGOS: Okay. And then you, you went so far as to contact the broker who handled the renting of the house; is that right?

COYLE: Yes.

GERAGOS: And they said they'd never even heard of this guy?

COYLE: That's correct.

GERAGOS: Even though they had handled the rental of the house back at the time that he listed his address there for the driver's license with the DMV?

COYLE: (Nods)

GERAGOS: And then there was another address that was on the criminal history, correct?

COYLE: That's correct.

GERAGOS: Now, when you talk about a criminal history, the computer will show various contacts that somebody might have with police, correct?

COYLE: Yes.

GERAGOS: And those contacts will list what they're arrested for, what they're convicted for, last known address, right?

COYLE: I'm not sure if the database that they're talking about, or you're talking about actually shows an address or not. I'm not sure which criminal history record they're referring to here. In this. They didn't, they didn't state which one it was.

GERAGOS: Okay. They went to another address that at least the officer says was connected to this particular sex ine 8 offender's criminal record, and when they got there the person said that they had also, or he had never heard of this person, right?

COYLE: That's correct.

GERAGOS: And he said he gets lots of mail for different people, but he's never seen any mail come for this guy?

COYLE: That's correct.

GERAGOS: And the officer says, the last line was: At this point I've exhausted all my resources to contact blank, this gentleman?

COYLE: That's correct.

GERAGOS: Okay. Was this a completed investigation?

COYLE: Well, actually, there's another supplement, with some additional information.

GERAGOS: Okay. And you have a Bates number on there?

COYLE: Yeah. 40516.

GERAGOS: Okay. And in the supplement that they've got there, there was several other attempts to find him?

COYLE: Yes.

GERAGOS: Okay. And at that point they did not, or they were not able to, and I guess claimed that he, or feel that he ran or was in Tennessee? Not ran, but had moved to Tennessee?

COYLE: That's correct.

GERAGOS: Okay. And they had an address in Tennessee?

COYLE: Yes.

GERAGOS: But they were not able to contact him there?

COYLE: No.

GERAGOS: Okay. So they had gone to all of these addresses, including one in Tennessee, and they still couldn't locate him at the one in Tennessee?

COYLE: That's correct.

GERAGOS: Okay. Does this constitute, and is that the end of the supplemental report?

COYLE: Yes.

GERAGOS: Does this constitute the end of the completed investigation?

COYLE: Yes.

GERAGOS: Okay. The next one is 53.

COYLE: I'm with you.

GERAGOS: Okay. Now, this is a person I believe who is a registered sex offender, correct?

COYLE: Yes.

GERAGOS: Okay. So at some point he was convicted somewhere of a registerable sex offense and he was supposed to register or had registered in Modesto, correct?

COYLE: That's correct.

GERAGOS: Okay. Now, then it looks like Officer Munoz was assigned to follow-up this case and try to locate this gentleman?

COYLE: Yes.

GERAGOS: And they checked the MPD, the Modesto Police Department, two different databases, is that correct?

COYLE: That's correct.

GERAGOS: What were those two databases?

COYLE: Those are our electronic computerized file systems where every report, every contact, every citation, every arrest, names get indexed into.

GERAGOS: Okay. And they checked that and they couldn't find anything, correct?

COYLE: Right. We had no contact with him.

GERAGOS: Then they checked, this person checked DMV and tried to get one of those SOUNDEXs from DMV?

COYLE: That's correct.

GERAGOS: SOUNDEX, if you have got a person's name and date of birth, law enforcement can make a request of DMV and they will send down a copy of the driver's license, picture, and the thumbprint, correct?

COYLE: That's correct. If the person has one, that's correct.

GERAGOS: If the person matches the information you give them. They requested, or the officer requested that information from the DMV, and there was no photo available; is that correct?

COYLE: That's correct.

GERAGOS: Then they checked for warrants on the separate, I assume a separate database?

COYLE: Yes.

GERAGOS: Would have been the CLETS, C-L-E-T-S, system probably?

COYLE: I think it was probably just our local system.

GERAGOS: When they did that, it turned out there was a warrant outstanding for this person, right?

COYLE: Yes.

GERAGOS: They found the last known booking photo?

COYLE: Yes.

GERAGOS: That's this? You have that?

COYLE: Yes.

GERAGOS: Okay. The, and then the, in checking the criminal history discovered that his last arrest was about ten years before in Hawaii?

COYLE: Yes.

GERAGOS: Hawaii was contacted, somebody in Honolulu PD?

COYLE: Yes.

GERAGOS: And it was apparent that his last known contact with them was back in 98?

COYLE: Yes.

GERAGOS: And he currently has numerous active warrants for his arrest in the Hawaii jurisdiction?

COYLE: According to them, yes.

GERAGOS: Okay. And it looks like this investigation was done sometime in, looks like this was done last year; is that right?

COYLE: Yes. December of 03.

GERAGOS: Okay. So about seven months ago?

COYLE: Yes.

GERAGOS: Did this constitute a completed investigation?

COYLE: Yes.

GERAGOS: Even though he was never located and there was numerous warrants out for him?

COYLE: That's correct, yes.

GERAGOS: Okay. The next one that I've got on here is number 158?

COYLE: Go ahead.

GERAGOS: Okay. Now, this gentleman is, let's see. What is he, a 190, a 190 registrant, another registered sex offender?

COYLE: 290.

JUDGE: 290.

GERAGOS: 290, I'm sorry.

GERAGOS: Now, he's identified as a Hawaiian, a male?

COYLE: Yes.

GERAGOS: And sometime, it looks like December, about seven months ago, he was contacted. Who was he contacted by?

COYLE: He was contacted by Detective Schmierer.

GERAGOS: Okay. And he's a registered sex offender in Stanislaus, City of Modesto?

COYLE: Yes.

GERAGOS: He said he was at his residence all day on Christmas Eve of 2002?

COYLE: Yes.

GERAGOS: He said he was by himself and didn't see anyone until he visited a friend about 5:00?

COYLE: That's correct.

GERAGOS: He said his friend lived at a place called Ralston Towers?

COYLE: Yes.

GERAGOS: And he gave the first name of the friend, right?

COYLE: Yes.

GERAGOS: He owns a pickup truck?

COYLE: Yes.

GERAGOS: He said that, this Zach (phonetic) at Ralston Towers was basically his alibi; is that correct?

COYLE: That's correct.

GERAGOS: This officer went to Ralston Towers?

COYLE: Yes.

GERAGOS: And was, met with the manager?

COYLE: Yes.

GERAGOS: And the manager told him that no one by the first name of Zach lived at Ralston Towers?

COYLE: Yes.

GERAGOS: Okay. And you were also, the person was also, the officer was also advised that Zach was not living at Ralston Towers on Christmas Eve of December 24th of 2000 and 2; is that correct?

COYLE: That's correct.

GERAGOS: The last line of the report is: I was unable to confirm blank's alibi, correct?

COYLE: That's correct.

GERAGOS: And this constituted a completed investigation?

COYLE: Yes.

GERAGOS: Okay. The next one is 167. It's the bottom of the page.

COYLE: Are you on Bates stamp 35846?

GERAGOS: That is it.

COYLE: Okay.

GERAGOS: This person is a registered sex offender?

COYLE: Yes.

GERAGOS: And this person was contacted January of this year?

COYLE: Yes.

GERAGOS: And was spoken to over the phone from his parole agent's office?

COYLE: Yes.

GERAGOS: Okay. He said he was living at the Mission in Modesto on December 24th?

COYLE: Yes.

GERAGOS: He said that during the day people living at the Mission are kicked out onto the street?

COYLE: Yes.

GERAGOS: He said that normally he hung out at the library or Jack in the Box, although he didn't know where he was that day?

COYLE: That's correct.

GERAGOS: He said he didn't have any relatives in town that he spent the day with, and no one was with him except a couple of fellow transients who also lived at the Mission who he hung around with at this time?

COYLE: Yes.

GERAGOS: He gave the name of somebody, two names that he thought were probably with him on that day?

COYLE: Could have been, yes.

GERAGOS: Okay. He said he didn't have a car, right?

COYLE: Yes.

GERAGOS: And he said that he didn't have anything to do with Laci Peterson's disappearance, correct?

COYLE: That's correct.

GERAGOS: And did that constitute a completed investigation?

COYLE: Yes.

GERAGOS: And that was all done over the phone, correct?

COYLE: That's correct.

GERAGOS: Do you, are you familiar with the Mission, that area of the Mission?

COYLE: Yes, I am.

GERAGOS: And is it your understanding that during the day people living at the Mission, registered sex offenders, are kicked out on to the street?

COYLE: Well, they didn't really live there, per se. It's a transient come and go place. They're able to go there in the evening, have dinner, they provide them a bed for the night, and then in the morning, yes, they have to leave.

GERAGOS: Do you know what time in the morning they're told to leave?

COYLE: I don't know for sure.

GERAGOS: The next one I've got here is 285.

COYLE: Are you on 35882?

GERAGOS: Right.

COYLE: Okay.

GERAGOS: Now, this person is a registered sex offender?

COYLE: Yes. And maybe also a parolee.

GERAGOS: Looks like paroled out of, well, looks like he was contacted in January of this year, right?

COYLE: Yes.

GERAGOS: Okay. I'm assuming that the second line in there is a typo in terms of the date.

COYLE: Well, actually maybe the first line is.

GERAGOS: Okay. The first line?

COYLE: Yes.

GERAGOS: Okay. Now, one of them is a typo in terms of the year; is that correct?

COYLE: That's correct.

GERAGOS: Okay. Now, the, there was contact made with this gentleman; is that right?

COYLE: Yes.

GERAGOS: And did you try to determine where he was on December 23rd?

COYLE: Yes.

GERAGOS: And it says, I guess, he called out from whatever jail facility he was in?

COYLE: I believe the detective actually called into there; but, yeah.

GERAGOS: Okay. And he said he moved from Modesto to Fresno in the year 2000?

COYLE: Yes.

GERAGOS: He said he thought that, or said he had not been back to Modesto since he moved in 2000?

COYLE: Yes.

GERAGOS: He said he thought he was in Fresno County Jail on December 24th?

COYLE: But he cannot be sure, right.

GERAGOS: Right. He said if he wasn't in jail he was living with another friend, whose name he gave?

COYLE: That's correct.

GERAGOS: Okay. The officer confirmed that the friend lives in Fresno?

COYLE: Yes.

GERAGOS: But was unable to contact the friend?

COYLE: That's correct.

GERAGOS: Then I guess the Fresno County Sheriff's Department and the police department were contacted?

COYLE: Yes.

GERAGOS: And they said that they had several contacts with him beginning in the year 2000 and 1?

COYLE: Yes.

GERAGOS: No contacts in the Stanislaus County?

COYLE: That's correct.

GERAGOS: Okay. He was paroled, looks like he was arrested October 24th of 2001 in Fresno?

COYLE: Yes.

GERAGOS: And then he was paroled back to Fresno on what date?

COYLE: December 5th, 2002.

GERAGOS: Okay. And then was arrested on June 19th of 2003?

COYLE: Yes.

GERAGOS: And returned to prison?

COYLE: Yes.

GERAGOS: Okay. So he would have been out, at least given the law enforcement's custody record, during the time of the 23rd and 24th of December? He was clearly out of custody, based upon the information this officer developed?

COYLE: That's correct.

GERAGOS: Okay. And they were never able to, at least at this time, when this report was prepared, find the friend who could confirm his alibi?

COYLE: That's correct.

GERAGOS: And this constituted a completed investigation?

COYLE: Yes.

GERAGOS: The next one I've got is 253.

COYLE: 35878?

GERAGOS: Yes. And 79.

COYLE: Okay.

GERAGOS: It looks like, for whatever reason, 35879 looks like it's the first report. The 35878 looks like it's the follow-up; is that the way you read it?

COYLE: Yes.

GERAGOS: Start with 35879.

COYLE: Okay.

GERAGOS: Looks like this person was a registered sex offender?

COYLE: Yes.

GERAGOS: This person also had a warrant out, bench warrant for a sex offense?

COYLE: Yes.

GERAGOS: And looked like that warrant had been outstanding for at least twelve years?

COYLE: Yes.

GERAGOS: And you ran what I called before, this CLETS file? Or you didn't, but C-L-E-T-S file; is that correct?

COYLE: Yes.

GERAGOS: It's a law enforcement database?

COYLE: That's correct.

GERAGOS: And it showed that the Department of Justice had entered and they had determined he was residing out of state?

COYLE: That's correct.

GERAGOS: Okay. So somebody called the Department of Justice?

COYLE: Yes.

GERAGOS: They gave this gentleman's information, and it was apparent he had not registered since 1990?

COYLE: Yes, in California.

GERAGOS: Okay. Showed he was last listed as living in Arizona?

COYLE: Yes.

GERAGOS: And they then called a sheriff's department in Arizona?

COYLE: Yes.

GERAGOS: And confirmed that he's registered there but have no further information?

COYLE: Yes.

GERAGOS: Okay. Then there was another call made to an administrative clerk there?

COYLE: Yes.

GERAGOS: And also shows that the last contact they had with this gentleman was in 1990?

COYLE: That's correct.

GERAGOS: And at that point they were unable to locate any further information on him?

COYLE: Yes.

GERAGOS: Okay. Then it looks like about three weeks later, January of this year, the, once again, he contacted a detective in Arizona; is that correct?

COYLE: Yes.

GERAGOS: And he said he would attempt to locate or determine the status of this guy?

COYLE: Yes.

GERAGOS: However, at this time he had no further information on his whereabouts?

COYLE: That's correct.

GERAGOS: Okay. And then also in the file they had a Texas driver's license number?

COYLE: Yes.

GERAGOS: And that comes back apparently to a different name in Texas; is that right?

COYLE: That's correct.

GERAGOS: But apparently he was under a alias of some kind?

COYLE: Or somebody transposed a number. There's several other things could happen there.

GERAGOS: Okay. They also used the web site to see if maybe he died, correct?

COYLE: That's correct.

GERAGOS: And there was no match?

COYLE: That's correct.

GERAGOS: And at that time there was no further information regarding this gentleman?

COYLE: Yes.

GERAGOS: And that constituted a completed investigation?

COYLE: Yes.

GERAGOS: Number 256. I only have a couple more of these. 256 is also a registered sex offender?

COYLE: Yes.

GERAGOS: Now, Officer Hinkley again was assigned to try and find this person in December, about seven or eight months ago?

COYLE: Yes.

GERAGOS: And they checked this CLETS file, law enforcement database again?

COYLE: Yes.

GERAGOS: And determined at least from that database that he was residing out of state?

COYLE: Yes.

GERAGOS: Once again, he went through the same thing. He called the Department of Justice again?

COYLE: Yes.

GERAGOS: And then gave that Arizona address, not address but said contact Arizona?

COYLE: That's correct.

GERAGOS: Which Hinkley did, Hinkley called and talked to a criminal records specialist?

COYLE: Yes.

GERAGOS: Who stated that in July this sex offender said he would, was going to move back to California?

COYLE: Yes.

GERAGOS: They don't have anything showing that he, whether he moved, right?

COYLE: That's correct.

GERAGOS: First started registering in Arizona in 98?

COYLE: Yes.

GERAGOS: And in July of 2000 and 3, at that point he was located because he had stopped registering?

COYLE: Yes.

GERAGOS: Okay. They felt that he was currently in compliance, correct?

COYLE: Yes.

GERAGOS: And then called another department in Maricopa County; is that correct?

COYLE: Yes.

GERAGOS: Made several attempts to call the number that this gentleman lists on his registration form, correct?

COYLE: That's correct.

GERAGOS: They were never able to locate him, is that correct?

COYLE: That's correct.

GERAGOS: Were never able to locate, I think the last sentence says: I was unable to locate any other information to help me determine where Artie (last name redacted) was residing or how to contact him, is that correct?

COYLE: That's correct.

GERAGOS: And this was then a completed investigation?

COYLE: Yes.

GERAGOS: Next one is 196.

COYLE: Are you on 32875?

GERAGOS: I am.

COYLE: Okay.

GERAGOS: This person is also a registered sex offender?

COYLE: Yes.

GERAGOS: This one, this person was met by Detective Brocchini in the Modesto Police Department?

COYLE: Yes.

GERAGOS: He said he had been homeless for several, several years?

COYLE: Yes.

GERAGOS: And that he was living at the Gospel Mission or down at the river in the park?

COYLE: Well, it doesn't say "park." Just saying staying down at the river. That could mean,

GERAGOS: Does that refer, does that refer to more than one location when you're talking about,

COYLE: Well, we actually have three fairly good-sized rivers within a fairly close distance to downtown Modesto, so I'm not sure which one he's talking about, or where at.

GERAGOS: Okay. He said he cannot be sure of where he was on Christmas Eve?

COYLE: Yes.

GERAGOS: He thinks he was at the river?

COYLE: Yes.

GERAGOS: And he said his only contact with family would be his brother?

COYLE: Yes.

GERAGOS: He said he possibly called his brother, except he wasn't sure?

COYLE: That's correct.

GERAGOS: He said many people live at the river and many of them use their name or use different names?

COYLE: That's correct.

GERAGOS: This,

COYLE: At least that's what he said, anyway.

GERAGOS: Right. This interview took place in September of oh three?

COYLE: Yes.

GERAGOS: Okay. And Officer Brocchini, Detective Brocchini notes that in December, in September of oh three that this person had no noticeable injuries, scars or marks or recently healed injuries on him, correct?

COYLE: That's correct.

GERAGOS: He also, Brocchini notes that he's not driven a car in many years and had no access to any vehicle; is that correct?

COYLE: That's correct.

GERAGOS: And the, looks like somebody contacted his brother

COYLE: Yes.

GERAGOS: to confirm whether or not he received a call on Christmas Eve or Christmas day?

COYLE: Yes.

GERAGOS: And turns out that the brother said he cannot recall speaking to him on Christmas Eve or Christmas day?

COYLE: That's correct.

GERAGOS: Okay. He was, Detective Brocchini was unable, writes: I was unable to positively alibi Mr. Moreno for Christmas Eve or Christmas day?

COYLE: That's correct.

GERAGOS: And this gentleman's an older white male; is that correct? 72?

COYLE: 72, yes.

GERAGOS: Okay. And therefore did this constitute a completed investigation?

COYLE: Yes.

GERAGOS: The next one is 198.

COYLE: Go ahead.

GERAGOS: This is one that you actually did; is that correct?

COYLE: Yes.

GERAGOS: This is a registered sex offender?

COYLE: Yes.

GERAGOS: And this person said that he was currently a transient, or homeless?

COYLE: Yes.

GERAGOS: And he was, he's required to register as a sex offender?

COYLE: That's correct.

GERAGOS: And he said he currently owned a yellow Dodge pickup with a full-sized cab over a camper?

COYLE: Yes.

GERAGOS: He said he lives in his truck?

COYLE: Yes.

GERAGOS: And he purchased the pickup four or five years before you interviewed him?

COYLE: Yes.

GERAGOS: And you interviewed him in September of oh three?

COYLE: That's correct.

GERAGOS: Okay. He said he had not had any serious injuries, he had several heart attacks, suffers from emphysema, cannot exert himself; is that correct?

COYLE: Yes.

GERAGOS: He said, to you he appeared frail and sickly; is that correct?

COYLE: That's correct.

GERAGOS: Did this person recall where he was on December 24th?

COYLE: No, he could not recall.

GERAGOS: Okay. And he just said that he lives in his truck and parks along the San Joaquin River?

COYLE: Yes.

GERAGOS: Okay. And said he could not think of anything to verify his whereabouts on December 24th?

COYLE: That's correct.

GERAGOS: Okay. And that constituted a completed investigation?

COYLE: Yes.

GERAGOS: Did your, you made some notes about his health, that it was obvious to you that he was not in good health; is that correct?

COYLE: That's correct.

GERAGOS: And it was also your opinion that he could not have struggled with a healthy person or been able physically to abduct someone?

COYLE: That was my opinion, yes.

GERAGOS: Okay. Because of his stature and the state of his health?

COYLE: Yes. And the fact when we were worried when he came up the stairs we were going to have to call an ambulance. He nearly didn't make it, so

GERAGOS: Okay. The, did this, did anybody have contact with him, that you're aware of, prior to this September 3rd date, in connection with this investigation?

COYLE: Not that I'm aware of.

GERAGOS: Okay. That constituted a completed investigation?

COYLE: Yes.

GERAGOS: The next one I've got I think is 199.

COYLE: Is that 32879?

GERAGOS: 32879, correct.

COYLE: Okay.

GERAGOS: Now, this person was interviewed by Officer Beffa?

COYLE: That's correct.

GERAGOS: He had recently been released from parole?

COYLE: Yes.

GERAGOS: Okay. He was a registered sex offender?

COYLE: Yes.

GERAGOS: Okay. He was originally, it looks like, contacted by Beffa to determine his whereabouts on the 24th of December?

COYLE: Yes.

GERAGOS: And when he was originally contacted on January 2nd, he said he had been with his fianc‚e, correct?

COYLE: That's correct.

GERAGOS: And that he had been at work at a Save-Mart on Paradise Road?

COYLE: That's correct.

GERAGOS: The, apparently Beffa was unable to contact the fiancée?

COYLE: Right.

GERAGOS: And but he did speak to the manager at Save-Mart?

COYLE: Yes.

GERAGOS: The manager at Save-Mart told him that this guy was not working that day, right?

COYLE: That's correct.

GERAGOS: He then asked, I guess that was back in January, right?

COYLE: Right.

GERAGOS: So then he comes back and follows up, Officer Beffa does, in August? I'm assuming that, looking at the top on the supplement there.

COYLE: Yes.

GERAGOS: August of oh three. So he then asked, again asked him what were your whereabouts. I guess the implication being: I talked to the Save-Mart person, you weren't working, where were you?

COYLE: That's correct.

GERAGOS: He told me that he had, after he, the sex offender said after he had spoken with Officer Beffa in January he had remembered that he had not worked that day but he had been with his fiancée‚e the whole day. They had been at home in the evening. They had gone to the parents' house; is that correct?

COYLE: That's correct.

GERAGOS: He was asked if he had vehicles that he drives, and he says he's got a suspended license, right?

COYLE: That's correct.

GERAGOS: He said that his fiancée drives him around?

COYLE: That's correct.

GERAGOS: Okay. At approximately, looks like about a week later, the fiancée was contacted?

COYLE: About five, six days, that's correct.

GERAGOS: Okay. And she, and this was over the phone?

COYLE: Yes.

GERAGOS: Okay. And she said that yes, she was with him the whole day?

COYLE: Yes.

GERAGOS: Okay. That constituted a completed investigation?

COYLE: Yes.

GERAGOS: The next one is 154.

COYLE: Are you at 32795?

GERAGOS: 32795.

COYLE: Okay.

GERAGOS: Okay. This is somebody who was released from Folsom sometime, looks like May of 02?

COYLE: Yes.

GERAGOS: Lived at this Bethesda House from May until February of 03?

COYLE: Yes.

GERAGOS: And he says that he was at this Bethesda Ministries House all day?

COYLE: Yes.

GERAGOS: Said that he left on Christmas day?

COYLE: Yes.

GERAGOS: Okay. He also, I guess it looks like Detective Schmierer contacted the Bethesda House?

COYLE: Yes.

GERAGOS: And they show, to confirm, to try to confirm the alibi?

COYLE: Yes.

GERAGOS: They showed the officer a pass request from 12/23; isn't that correct?

COYLE: That's what it says here, yes.

GERAGOS: Okay. Did this constitute a completed investigation?

COYLE: Yes.

GERAGOS: The next one is 186.

COYLE: 35849?

GERAGOS: Correct.

COYLE: Okay.

GERAGOS: This is a person who apparently had lived at the Mission while he was running from parole?

COYLE: Yes.

GERAGOS: And couldn't remember where he was on the 24th?

line COYLE: Yes.

GERAGOS: Couldn't remember who he was with?

COYLE: That's correct.

GERAGOS: Had no relatives, says he doesn't have a vehicle?

COYLE: That's correct.

GERAGOS: Says he's disabled and takes medication?

COYLE: Yes.

GERAGOS: Okay. Said he didn't have anything to do with the disappearance of Laci?

COYLE: Yes.

GERAGOS: And this gentleman is, what, about 35?

COYLE: About that, yes.

GERAGOS: And that constituted a completed investigation?

COYLE: Yes.

GERAGOS: When he was interviewed, he was interviewed, he was back in jail?

COYLE: Yes.

GERAGOS: He had also indicated that he was released from prison the month before she disappeared, Laci disappeared? End of the first paragraph.

COYLE: He said he believed he had just gotten out, yes.

GERAGOS: Next one is 189.

COYLE: 35850?

GERAGOS: That's correct.

COYLE: Okay.

GERAGOS: This is an investigation by Banks?

COYLE: Yes.

GERAGOS: This person is a registered sex offender?

COYLE: Yes.

GERAGOS: He was met in person; is that correct?

COYLE: Yes.

GERAGOS: He stated that on the 24th he was in Turlock?

COYLE: Yes.

GERAGOS: He stayed alone in his camper most of the day?

COYLE: Yes.

GERAGOS: He couldn't remember who he had visited that day?

COYLE: Yes.

GERAGOS: And did that constitute the extent of the investigation?

COYLE: Yes.

GERAGOS: And was that a completed investigation?

COYLE: Yes.

GERAGOS: 191.

COYLE: 32838 or 839?

GERAGOS: I've got 3128 and then 32838. 3128 is just a one-sentence deal, if you want to take a look at it.

COYLE: I may not have gotten discovery on that.

GERAGOS: Do you have this one, the 32838?

COYLE: I have 32838.

GERAGOS: Okay. The only other one I was able to locate was this. Do you have that?

COYLE: I think so.

GERAGOS: Okay. Looks like in December of last year somebody was tasked to look for this gentleman?

COYLE: Yes.

GERAGOS: This gentleman is a registered sex offender?

COYLE: Yes.

GERAGOS: And there was an address, I guess, that was on the registration card that apparently there is no such address, correct?

COYLE: That's correct.

GERAGOS: They looked through records and there's no new address or contacts for him; is that correct?

COYLE: That's correct.

GERAGOS: There were no further leads to contact him; is that right?

COYLE: That's right.

GERAGOS: And on December 19th they called the Stanislaus County jail and confirmed that he was not in custody?

COYLE: That's correct.

GERAGOS: Okay. Was that a completed investigation?

COYLE: Well, obviously not, because you've got pages I don't seem to have, so I'm not sure exactly what else was done on him right now.

GERAGOS: Okay. 195.

COYLE: 32874?

GERAGOS: Right.

COYLE: Okay.

GERAGOS: This one is something by Officer Kelley?

COYLE: Yes.

GERAGOS: And this person is a registered sex offender?

COYLE: Yes.

GERAGOS: And the officer attempted to contact him, called the General Store Post Office and spoke to a witness?

COYLE: Yes.

GERAGOS: And the witness said that the P.O. Box he listed is no longer registered to him?

COYLE: That's correct.

GERAGOS: Okay. He then contacted the San Bernardino County Sheriff's Department?

COYLE: Yes.

GERAGOS: They had them go look at an address he had also given?

COYLE: Yes.

GERAGOS: Told him that that's a bad address?

COYLE: Yes.

GERAGOS: The DMV check revealed that his license was surrendered in Nevada sometime in 93 to 97?

COYLE: That's correct.

GERAGOS: And at that time the officers exhausted all possible leads in locating this gentleman?

COYLE: That's correct.

GERAGOS: And was this a completed investigation?

COYLE: Yes.

GERAGOS: Okay. I'm done with the 290s. I'm just going to ask you a couple more areas and I'll be done with it. The, we discussed yesterday the search that you, the search,

JUDGE: Mr. Geragos, could you speak a little louder?

GERAGOS: Sure. We discussed yesterday the searches that you were involved in?

COYLE: Yes.

GERAGOS: Okay. And the 2/18 search, was that, what was your role in that search?

COYLE: On February 18th?

GERAGOS: February 18th.

COYLE: I was not involved in that.

GERAGOS: Okay. So is it a fair statement that your role in the searches was on the 26th and the 27th?

COYLE: That's correct.

GERAGOS: Master bedroom and that hamper area and for clothing?

COYLE: Yes. Several other places in the house as well, but primarily that.

GERAGOS: Primarily that. And did you, I'd asked you yesterday, I wonder if you thought about it since yesterday; did you have somebody that was partnered up with you on the day of the search in the master bedroom?

COYLE: I know there was other detectives that came and went from the room, but I don't believe I was specifically given a partner to search, no.

GERAGOS: Okay. Now, you also did some searches of the Bay as well; is that correct?

COYLE: I spent one day, yes.

GERAGOS: And that was October 3rd of 2003?

COYLE: Well, I'd have to, I'll take your word for it, but I would have to refer to the report

GERAGOS: Sure.

COYLE: to be sure.

GERAGOS: I'll just show you. Take a look, if you would, at the yellow highlighted portion.

COYLE: Yes.

GERAGOS: Okay. Now, and you did, you were in the search operations in the Bay with Detective Hendee?

COYLE: Yes.

GERAGOS: Okay. And there were four targets that you were searching for, or that you searched for?

COYLE: That's correct.

GERAGOS: Okay. And those were located by the side-scan sonar device?

COYLE: Yes.

GERAGOS: And of those four objects that were brought to the surface, they were all small sticks; is that correct?

COYLE: Except one big fishing net.

GERAGOS: Five feet long,

COYLE: Fishing net, yes.

GERAGOS: About five feet by three feet?

COYLE: Yes.

GERAGOS: Are these the, you recorded all of the items you found with a digital camera?

COYLE: Yes.

GERAGOS: Do you have a better version of these pictures than mine?

COYLE: I don't know if it's better. Let me check. No, it's about the same.

GERAGOS: Okay. The items, I'm going to, while that's warming up, can you, I'll mark this defense next in order, Judge.

JUDGE: That will be Quadruple S. SSSS.

GERAGOS: And can I ask you, that document which you're looking at, which I've got a copy of, does that accurately reflect the photos, the photos accurately reflect the items that were brought up on the search of the Bay on October 3rd?

COYLE: Well, they're poor quality, but they are the digital, or copies of digital photographs of those items, yes.

GERAGOS: As soon as this warms up, I'll put it up there and you can identify which item it is.  This is poor quality.

GERAGOS: The, can you just identify for the jury which, I know it's extremely bad quality, but these items here that,

COYLE: That was the fishing net.

GERAGOS: Okay. That was about, as you indicated, about five feet by three feet?

COYLE: Yes. The net bag is about three foot wide. The net handle itself is about five foot long.

GERAGOS: If we see it correctly, that's the handle right there?

COYLE: Yes.

GERAGOS: And then the outline right there, kind of like a tennis racket?

COYLE: That's correct.

GERAGOS: And then the netting is in here?

COYLE: Right.

GERAGOS: Okay. That was on the floor of the Bay?

COYLE: Yes.

GERAGOS: And that was, obviously there was an object there that became a target that was dived for and then retrieved and brought up and photographed?

COYLE: Yes.

GERAGOS: Okay. These items here?

COYLE: Some sticks. Just small branches, sticks.

GERAGOS: This, this is a ruler?

COYLE: That's correct.

GERAGOS: Approximately how long?

COYLE: One foot.

GERAGOS: Okay. The sticks are, what, somewhere between four inches and six inches long?

COYLE: Approximately.

GERAGOS: Okay. Fair statement that the side-scan sonar was able to pick up four inch and six inch objects?

COYLE: Well, I can't, I don't know anything about the side-scan sonar. We just went to a target location. That's what came up. I don't know if those were picked up by the scanner or not.

GERAGOS: Is this one right here a stick as well?

COYLE: Well, no. Actually, that was a piece of wood.

GERAGOS: Okay. So it's a slightly larger or bigger size than the sticks itself?

COYLE: That's correct.

GERAGOS: Okay. This item right here?

COYLE: That was another piece of branch, or stick.

GERAGOS: Also the same thing; this is a one-foot ruler?

COYLE: That's correct.

GERAGOS: Okay. So it's smaller than a foot?

COYLE: Yes.

GERAGOS: Is this another photo of that net?

COYLE: Yes.

GERAGOS: And the handle itself?

COYLE: Yes.

GERAGOS: And then what is this right here?

COYLE: That's just a piece of paper with the case number, I think. And I can't remember, maybe the date on there as well, it looks like.

GERAGOS: Now, the, these items here, this one, two, three, and four, were those specifically items that were at a location that you dived, that divers went down for?

COYLE: Yes.

GERAGOS: Thank you. I have no further questions at this time.

 

Redirect Examination by Rick Distaso

DISTASO: Detective, regarding the list of parolees and 290s, why was that list created?

COYLE: Originally within the first few hours, or first day, it was sort of like round up the usual suspects. It was a starting point of something that's, that's a decision that was made above me, and it was somebody that decided that we needed to start checking people out to see if it would lead anywhere.

DISTASO: Okay. So this list of 309 or so many names was created?

COYLE: Yes.

DISTASO: And let me make sure I've got that number right. 310 names. There's 310 names on this list, but there are actually two people that are listed twice, correct?

COYLE: That's correct. One guy has an alias and one name was misspelled once.

DISTASO: So we're probably talking around 308 people?

COYLE: Around that, yes.

DISTASO: And did this part of the investigation have anything to do with the defendant?

COYLE: No.

DISTASO: I mean did, was this looking into these folks, did this have anything to do with the investigation looking into the defendant's activities?

COYLE: Not, not that I know of, no.

DISTASO: Okay. And the, when this list was done, what was kind of the goal?

COYLE: Well, again, I mean, you know, we had really not much to go on in the beginning. And it was suggested that something of this type could have been done by a person who was a convicted felon or a sex registrant. And so, again, it was folks we were looking at, trying to see if it led us anyplace, you know, would develop some evidence.

DISTASO: Was there ever, when the list was first created, was there ever any evidence that pointed to each of these individual people? Like Well, we got something against number one, we've got something against number two, three, four, all the way down to 308?

COYLE: No.

DISTASO: These were people that were just 290 registrants, sex registrants, right?

COYLE: Actually, they drew a circle on a map within a range, I think it was a mile of the Covena residence, and every sex registrant living within that circle was attempted to be located.

DISTASO: And the list included both sex registrants and certain parolees that were living in the area, or information you had on people in that area?

COYLE: That's correct.

DISTASO: And the, down in that area, or five or six blocks away, is the Mission, correct?

COYLE: That's correct.

DISTASO: And the Mission is, like you described, a place where homeless folks can come and spend the night?

COYLE: Yes.

DISTASO: It's, it's not really their home or their house, but they can come there each night, spend the night, then they have to leave in the morning?

COYLE: That's correct.

DISTASO: So the people that are going there and staying are transients, or obviously homeless people?

COYLE: That's correct.

DISTASO: And many of these people, as we've heard, when they were contacted, stated they were getting around town by riding their bikes or,

GERAGOS: Objection. Leading.

DISTASO: walking.

JUDGE: Sustained.

DISTASO: Well, I mean how did some of the, how did these people that were living at the Mission, most of them say they were getting around?

COYLE: Most of them on foot. In some cases, yes, they had bicycles.

DISTASO: Now, you were asked about just a small number, and I'm not going to go through every single one of these either, but they, you were asked about a small number of these people. But like you said yesterday, in fact I counted up the ones you, were you were asked about, there was 32, of the 308, there were a large number of these people who had someone they could say They were with me on this particular day on the 24th?

GERAGOS: Objection. Leading.

JUDGE: Sustained.

DISTASO: Was there a large number of people who had somebody who would say Yes, this person was with me on the 24th?

COYLE: Without actually counting them up, I'm just guessing, but I think it was a majority of the folks. Now, that may have only been 51 percent; but, yeah, a majority of the folks that we contacted had someone, family member, in several cases it was their employer. We, we actually  line 2 got several of them that we got time cards from their employer showing that they were at work that day. So yeah, there was a lot of, lot of them that had alibis.

DISTASO: And some of these people were deceased, correct?

COYLE: Yes.

DISTASO: And the records reflected that?

COYLE: Yes.

DISTASO: And some of these people, even the ones that counsel were asking, was asking you about, from the records it appears they hadn't been in California for some years?

COYLE: Several of them, yes.

DISTASO: One I think was number, let me find the number here. Number 53, that individual, looks like the last contact that any law enforcement had with him was he was in Hawaii?

COYLE: That's correct.

DISTASO: And when was the last contact that the Hawaiian authorities had contact with this person?

COYLE: 1998.

DISTASO: So how did that person get on your particular list?

COYLE: I don't know if he was one that was at some point supposed to be registering in Modesto and so we have to carry them on our database, although he's out of compliance, obviously, if he has to register with us, or whether this was one of the parolees. I don't know.

DISTASO: Okay. And he was, looks like his birth date was 1943, so he would be approximately, what, 59 years old, if my math is right? At the time of this?

COYLE: Yes.

DISTASO: All right. You were asked about a couple other individuals. One was what, number 198. And counsel has already talked about the fact that when he came in to talk to you at the Modesto Police Department, you observed that he was sickly and in ill health?

COYLE: Yes.

DISTASO: And that person's age I think was 61 years old?

COYLE: Yes.

DISTASO: You were asked about another person, number 195, who was unable to be located. Do you want to pull that record up real quick?

COYLE: Okay.

DISTASO: And what was that person's date of birth?

COYLE: 1925.

DISTASO: Okay. So he would have been 77, I guess, at the time this happened?

COYLE: Yes.

DISTASO: You were asked about number 196. That was someone who was also looked at. And I believe counsel asked you about his birth date. And he was an individual who was 72 years old?

COYLE: That's correct. Born in 1930.

DISTASO: So just so we get a clear picture of these people, some of these people are, were elderly, correct?

COYLE: That's correct.

DISTASO: Some of them were obviously in ill health?

COYLE: Yes.

DISTASO: Some of them, as counsel brought up, there was a 35 year old who was living in an alley. He didn't particularly seem to be in bad health?

COYLE: That's correct.

DISTASO: And it looks like some of these folks, let me count here, one, two...I don't have everyone listed, but there were a number of people that you looked up in these records that were actually in custody on December 24th?

COYLE: Yes. Either in a county jail or a state prison facility.

DISTASO: Okay. So even though you don't like using the term, those people, assuming the custody records are correct, could not have committed this crime?

COYLE: Yes.

DISTASO: Now, what did you mean by when you, when you called these, these investigations complete, if someone is unable to be located and you said that was completed, what did you mean by that?

COYLE: I meant that we had done everything humanly possible to attempt to locate these folks to interview them.

DISTASO: Okay. And when you got somebody and you did actually sit down and interview them and they gave you, you know, whatever statement they gave you about where they were, did you try to verify it?

COYLE: Yes.

DISTASO: And if you could not verify it, what happened after that?

COYLE: Well, in some cases it just, that's where it ended, because there was nothing else we could do.

DISTASO: Was, if you had received additional information that led, you know, somewhere else with these folks, would you have continued the investigation into them?

COYLE: Yes. In fact, on several of the reports the detectives turn in, I did some additional digging and found other information.

DISTASO: The, there were, somebody that counsel, I think, asked you about yesterday. Number 42. I want to talk about him for a minute. This person was originally contacted where?

COYLE: He was originally contacted in Modesto in December of oh three at our mental health facility.

DISTASO: Okay. So he was, he was contacted by one of Modesto police officers?

COYLE: Yes.

DISTASO: And he was at the Behavioral Health Center?

COYLE: Yes.

DISTASO: And then he was interviewed, correct?

COYLE: Yes.

DISTASO: And he stated that on December 24th of oh two he had been with his sister in Patterson?

COYLE: That's correct.

DISTASO: Subsequently in February of 04, like counsel was asking you yesterday, he, he was arrested in Oregon?

COYLE: Yes.

DISTASO: And that's where he gave his story saying he committed a murder in Modesto and broke a woman's neck, right?

COYLE: Yes.

DISTASO: In, back in Christmastime, I think you said, of 02?

COYLE: Yes.

DISTASO: Let me make sure I got that right. Yeah. So he's originally interviewed at the Behavioral Health Center?

COYLE: That's correct.

DISTASO: And he says he didn't have anything to do with it?

COYLE: Yes.

DISTASO: And then he gives this story up in Oregon where he says he is involved?

COYLE: Yes.

DISTASO: Or at least in some murder, correct?

COYLE: Yes.

DISTASO: And then did the officer, it was Detective Brocchini in this case, did he follow-up with the, I don't think counsel asked you this yesterday. Did he follow-up with number 42's sister and mother to confirm where he was on the 24th?

COYLE: Yes.

DISTASO: And where did they say he was?

COYLE: His sister said she was positive that he was with her on that date.

DISTASO: And that was in Patterson?

COYLE: Yes.

DISTASO: And she said that he was living with her in Patterson during that time?

COYLE: Yes.

DISTASO: And she also stated that he has severe mental problems when he doesn't take his medication, correct?

COYLE: That's correct.

DISTASO: Now, let's look at number 18. This was an individual who counsel asked you about. And he did not, his alibi was not able to be confirmed. You can go ahead and pull that up.

COYLE: That's correct.

DISTASO: When was he interviewed?

COYLE: On August 18th, 2003.

DISTASO: And for what purpose was he at the police department?

COYLE: He was coming in for his normal registration appointment.

DISTASO: So he was conducting his normal yearly registration appointment?

COYLE: That's correct.

DISTASO: So that means he voluntarily came into the police department to register?

COYLE: Yes.

DISTASO: And then he agreed to be interviewed about this particular incident?

COYLE: Yes.

DISTASO: There was a number of people that counsel asked you about yesterday. Number, you don't need to turn to them, but number 70, number 1, number 155, and number 238. And those people stated that they were living at a halfway house; is that right?

COYLE: That's correct.

DISTASO: Angle Lane. And their alibi, they stated they were there at the halfway house on the 24th?

COYLE: That's correct.

DISTASO: And their alibi was confirmed by a staff member there at the halfway house?

COYLE: Yes.

DISTASO: There was one, number 101, Mr., well, I won't say his name, but, and I think counsel stated that he was an, only contacted by phone; do you remember that?

COYLE: No, he referred to the report where he was contacted by phone, yes.

DISTASO: Okay. I don't know, maybe counsel wasn't looking at the other report, but,

GERAGOS: Objection. Misstates the evidence. We specifically went over that, where the report was written, saying that he was contacted by the phone. There was a supplemental.

JUDGE: I think so. Yeah. Well, the jury's heard the evidence.

DISTASO: Right. Well, that's, for whatever reason, Judge, I mean

DISTASO: There is that report, Detective, where it shows that he was actually contacted in person; is that right?

COYLE: That's correct.

DISTASO: And that has a Bates stamp number on it?

COYLE: Yes.

DISTASO: And what date was he contacted in person?

COYLE: The first time?

DISTASO: Yes.

COYLE: 12/29/02.

DISTASO: Counsel asked you today about number 154, and that was another individual who was living at that Angle Lane halfway house? You can pull that report up.

COYLE: Yes.

DISTASO: And in that report that, it was the same staff member who confirmed the other individual's alibis for the 24th, also confirmed that number 154's alibi; is that right?

COYLE: That's correct.

DISTASO: And the pass request he showed him was for the day prior, on the 23rd?

COYLE: According to the report, yes.

DISTASO: All right. Let me move on from those and ask you a question about the search warrant that took place on the 26th and 27th. You were not present at the search warrant on February 18th; is that right?

COYLE: No, I was not.

DISTASO: Let me show you a photograph I'll have marked next in order.

JUDGE: This will be number 142.

DISTASO: Detective, these, let me show you some items that were recovered on that search warrant on the 18th. Do you remember seeing any of those items in the hamper when you searched it on the 26th and the 27th?

COYLE: No.

DISTASO: And regarding those actual items, since you weren't there on the 18th, you don't have any knowledge of these, correct?

COYLE: That's correct.

DISTASO: Okay.

JUDGE: What does that purport to be? Just photographs of?

DISTASO: Photograph of clothes.

JUDGE: Photograph of clothes, okay.

DISTASO: Nothing further, your Honor.

 

Recross Examination by Mark Geragos

GERAGOS: The, Mr. Distaso was asking you about number 42.

COYLE: Yes.

GERAGOS: Number 42 is this person who confessed to killing somebody in Scenic Park?

COYLE: Yes.

GERAGOS: Said a witness was, the only witness to the murder was a dog?

COYLE: Yes.

GERAGOS: He said he was driving his sister's white 1985 Chevy van?

COYLE: Yes.

DISTASO: Objection, your Honor. This is, asked and answered yesterday, and goes beyond scope of redirect.

GERAGOS: I asked,

JUDGE: I don't think so. Overruled.

GERAGOS: The reason that this person was cleared was two-fold: Because the sister said that he was with her, is that right?

COYLE: Yes.

GERAGOS: And that he had mental problems?

COYLE: Yes.

GERAGOS: Did anybody ever check whether or not the sister had a 1985 Chevy van?

COYLE: I don't have that information, no.

GERAGOS: Do you know if anybody ever did, if she had a van, any forensic testing of that van?

COYLE: I don't have that information either, no.

GERAGOS: Has anybody run a check on the sister to see if the sister had any criminal history?

COYLE: No. Not that I know of.

GERAGOS: Did anybody do any check to see if there was anything about why, you've been an officer for how long?

COYLE: Almost 25 years.

GERAGOS: Have you ever known family members to cover up for other family members?

COYLE: Oh, sure.

GERAGOS: Can you tell me do you know of anything that was done, beyond calling the sister and the interview, to confirm whether or not she was, in fact, covering up?

COYLE: Well, the mother was interviewed as well. But I don't know if you could tell from that whether the sister was covering up or not.

GERAGOS: Okay. The mother said that she saw them the next day; is that correct?

COYLE: That's correct.

GERAGOS: Okay. She didn't see them on the 24th?

COYLE: That's correct.

GERAGOS: Okay. The others that Mr. Distaso was asking you about were the various agents, but I was asking you the same thing. You were looking at people on this, as you say, the usual suspects list, because obviously in a case like this where there's very little to go on, a logical place to look are registered sex offenders, correct?

COYLE: It's one place, yes.

GERAGOS: Okay. And that's why resources were expended to try to follow-up on these, on this class of people, correct?

COYLE: Yes. Again, trying to get something, trying to find some evidence.

GERAGOS: And I think, if I understood what you told Mr. Distaso, set it up here, basically what you said is that you took, somebody took a location, point to where, and then roughly drew a circle; is that correct?

COYLE: I believe they went a one-mile radius circle, yes.

GERAGOS: Okay. And I'm,

JUDGE: Just for the record.

GERAGOS: Pointing here to People's 58.

JUDGE: All right.

GERAGOS: So they basically flipped the house, wherever the house is on this particular map, and drew a one-mile circle, and you've got 300 sex offenders within a mile of Modesto?

COYLE: No, because part of them are parolees, not sex offenders.

GERAGOS: Do you know how many, when you draw a circle a mile circle around the house, do you know how many registered sex offenders are in Modesto?

COYLE: No, I don't.

GERAGOS: Is it over 200 within that one mile radius?

COYLE: I don't know.

GERAGOS: I was looking at the list that you had given me, the, and I think it was the one that was given to you. That column that says 290?

COYLE: Yes.

GERAGOS: If you just glance at it, would you say that the overwhelming majority of those it says yes?

COYLE: Yes, definitely the majority.

GERAGOS: Okay. So I mean, as a guess, it's going to be at least two-thirds, wouldn't it?

COYLE: Oh, probably at least that, yes.

GERAGOS: Okay. So within one mile of this house we've got approximately 200 registered sex offenders? Actually it's less than a mile, because it's a, the, well, I take that back. It's a one-mile radius; is that right?

COYLE: I'm going from memory. Again, I wasn't in on that part of it. I'm just, that's what I recall it to be. So I may be wrong on that, but, but that's what I recall.

GERAGOS: Okay. And in addition to that, the, you can't mean to suggest, I'm sure, that just because you were able to contact a portion of these, that that necessarily eliminated everybody?

COYLE: That's correct.

GERAGOS: I mean there's, there's no suggestion that if you reach 51 percent of the usual suspects, that everybody else is eliminated?

COYLE: Oh, absolutely not, no.

GERAGOS: Okay. Now, did you, I had thought that you had done a search of the truck at some point. Was that

COYLE: No.

GERAGOS: mistaken?

COYLE: I was not involved in the search of the vehicles.

GERAGOS: Not at all?

COYLE: Not at all.

GERAGOS: On either the 26th, the 27th or the 18th?

COYLE: No.

GERAGOS: And then that last photo that Mr. Distaso showed you, which was marked as 142, that, we talked yesterday briefly about the clothes that were in the hamper. So that we're clear, you didn't itemize the clothes in the hamper; is that correct?

COYLE: That's correct.

GERAGOS: And we went through it, but just so that we're clear again, there was an item that I pointed to as People's number 10, which was the maternity blouse. Your memory was that you didn't remember seeing it, but obviously when you saw it, was shown a picture a couple of months later, it was obviously there, so obviously you must have, correct?

COYLE: Well, once I was shown the photo, yes, that refreshed my recollection of it. But when I was just merely asked by description of it, I couldn't recall it at that point, yes.

GERAGOS: Okay. And once again, as we went over yesterday, that hamper was searched by you at least twice, and you're not sure if others went through it as well, correct?

COYLE: That's correct.

GERAGOS: Thank you. I have no further questions.

 

2nd Redirect Examination by Rick Distaso

DISTASO: Just so we're clear on number 142, I just want to make sure that we're totally accurate on it. What it said is: I spoke to the defendant's mother, correct? Number, and that was number 42. I won't say his last name. If you look at the bottom.

COYLE: Yes, that's correct.

DISTASO: And then it says: The mother said she spent Christmas day with number 42 and the sister?

COYLE: Yes.

DISTASO: And then it says: The mother said Edward was with the sister on 12/24?

COYLE: Yes.

DISTASO: And then the mother said that Edward was on several different medications for his mental problems?

COYLE: Yes.

DISTASO: The, regarding that hamper that counsel just went through, you did remember the, some specific items that were in there, though, right off the top of your head, correct?

DISTASO: Yeah. Detective Grogan asked me what I could remember about that, and I listed several things that, that popped into my memory. Specific items that I had seen in there. But when he asked me about the blouse, I just, I couldn't recall that one.

DISTASO: Okay. What, did you write, is it in the report as to what items you specifically remembered?

COYLE: It's in Detective Grogan's report, yes.

DISTASO: Okay. Do you have that in front of you?

COYLE: Yes, I do. Go ahead.

DISTASO: And what items do you specifically remember were in the hamper?

COYLE: I told him there were some khaki men's walking shorts, pair of corduroy men's pants, a couple of pairs of boxers, and one pair of women's panties.

DISTASO: And the,

COYLE: That I recall.

DISTASO: Right. These, this People's 142, there's looks like a pair of women's underwear in there?

COYLE: Yes.

DISTASO: And do you remember seeing that particular pair of women's panties?

COYLE: That's not the pair of panties that was in the hamper, no.

DISTASO: Okay. I don't have anything further, Judge.

JUDGE: Last go-round. Any questions?

GERAGOS: Break time.

JUDGE: Detective Coyle may be excused, with the usual stipulation?

DISTASO: (Nods)

JUDGE: All right. Detective Coyle, we're going to excuse you. Thank you very much.