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IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS STATE OF MISSOURI Honorable Rex M. Burlison, Judge STATE OF MISSOURI, ) ) Plaintiff, ) ) vs. ) Cause No. 1822-CR00642 ) ERIC GREITENS, ) ) Defendant. ) TRANSCRIPT OF MOTION HEARING March 21, 2018 HON. ROBERT DIERKER MS. KIMBERLY GARDNER Circuit Attorney's Office 1114 Market Street St. Louis, MO 63101 on behalf of the State of Missouri; MR. JAMES G. MARTIN HON. JACK F. GARVEY MR. EDWARD DOWD Carey, Danis & Lowe DOWD BENNETT LLP 8235 Forsyth Blvd. #1100 7733 Forsyth Blvd. #1900 St. Louis, MO 63105 St. Louis, MO 63105 MR. SCOTT ROSENBLUM Rosenblum Schwartz & Fry 120 South Central Avenue #130 St. Louis, MO 63105 on behalf of the Defendant. JENNIFER A. DUNN, RPR, CCR #485 OFFICIAL COURT REPORTER CITY OF ST. LOUIS CIRCUIT COURT TWENTY-SECOND JUDICIAL CIRCUIT

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Page 1: IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS ...kmov.images.worldnow.com/library/40ad3d45-7fb4-42fc-beb0...EDWARD DOWD Carey, Danis & Lowe DOWD BENNETT LLP 8235 Forsyth Blvd. #1100

IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS STATE OF MISSOURI

Honorable Rex M. Burlison, Judge

STATE OF MISSOURI, ) )

Plaintiff, ) )

vs. ) Cause No. 1822-CR00642 )

ERIC GREITENS, ) )

Defendant. )

TRANSCRIPT OF MOTION HEARING March 21, 2018

HON. ROBERT DIERKER MS. KIMBERLY GARDNER Circuit Attorney's Office 1114 Market Street St. Louis, MO 63101

on behalf of the State of Missouri; MR. JAMES G. MARTIN HON. JACK F. GARVEY MR. EDWARD DOWD Carey, Danis & Lowe DOWD BENNETT LLP 8235 Forsyth Blvd. #1100 7733 Forsyth Blvd. #1900 St. Louis, MO 63105 St. Louis, MO 63105

MR. SCOTT ROSENBLUM Rosenblum Schwartz & Fry 120 South Central Avenue #130 St. Louis, MO 63105

on behalf of the Defendant.

JENNIFER A. DUNN, RPR, CCR #485 OFFICIAL COURT REPORTER

CITY OF ST. LOUIS CIRCUIT COURT TWENTY-SECOND JUDICIAL CIRCUIT

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(The following proceedings were had in open

court:)

THE COURT: Court calls Cause Number

1822-CR00642. State of Missouri versus Eric Greitens.

I became aware sometime yesterday that we had a

hearing today. I'm not sure who noticed this up.

MR. GARVEY: Judge, it was us. Just for

housekeeping, just to set out what's what and where where.

Today we would like to have a hearing on our motion to

advance the trial date. On Monday we have set for a hearing

our motion to dismiss based on the misinstructing of the

Grand Jury, our motion to disqualify the special prosecutor,

although I don't know whether that's necessary any more, we

understand that he might have removed himself from the case.

So if that's the case, there will be no hearing on that.

And then that's -- those are the motions that will

be heard on Monday.

THE COURT: Okay.

MR. GARVEY: Today it's just the motion to

advance the trial date.

THE COURT: And there was a motion regarding

waiver of jury, is that a Monday item you say?

MR. GARVEY: I think we notified the Court he

is going to waive his right it a Grand Jury, the governor

will, and we will, if the Court would like, whatever the

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Court's schedule, he would be appearing to waive the jury

trial, we're planning on doing that on just whatever day the

trial is, the bench trial, and then you can put him on the

record to waive it.

THE COURT: And there's been a filing by the

State in that regard?

MS. GARDNER: Yes, there has, your Honor.

THE COURT: Are the parties prepared to hear

that today?

MR. GARVEY: We can set that on Monday,

Judge.

MS. GARDNER: We're prepared to hear that

today, the motion to the waiver of jury trial and the motion

for shortened time. I think we're prepared to hear that

today.

MR. GARVEY: Judge, we haven't responded to

their objections to the motion to waive a jury trial.

THE COURT: I'm not sure the State has a

right to object to that.

MR. GARVEY: That's the thing, Judge.

THE COURT: I'm not sure your client has an

absolute right to waive a jury.

MR. GARVEY: That is correct, Judge.

THE COURT: As long as we know that the

Court's going to have the final say in that. I don't care

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if we hear it today or Monday, but neither side has an

absolute -- I don't think the State has a right to object,

and I don't think your client has an absolute right to

waive.

MR. GARVEY: We understand, Judge. We would

like Monday then to argue that motion.

MS. GARDNER: Your Honor, I'm asking today

because also we have issues with deposition notices being

served on potential witnesses yesterday without notice, and

we're trying to shorten time for motion to quash subpoenas

because we had original dates that were set in preparation

for trial, and I think this issue needs to be spoken to

today. We cannot wait for that.

So I think the motion for shortened trial, as well

as a motion to waive a jury trial needs to be addressed

today, not Monday.

MR. GARVEY: Judge, our client is going to --

is going to present himself in front of the Court to have a

hearing and you will inquire to him whether or not he has

been adequately informed and adequately advised that he can

waive his right to a jury trial. The State has no standing

to challenge that.

However, the Court does have a huge role in

deciding whether or not he can waive his right to a jury

trial. They have filed this response, frankly, we haven't

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even really given it any time because we didn't think they

had any standing to challenge it at all.

We're not prepared today to argue that motion. We

will be prepared on Monday to argue that motion.

THE COURT: Well, as we speak this matter is

set for trial by jury, and all subpoenas and all actions

should be directed towards the present status of this case.

I will give the defense until Monday to present whatever

evidence that the defense wants to present in light of Rule

27, which makes all criminal cases triable by a jury.

But as we proceed from now until the Monday

hearing, I would suggest all parties to assume this is a

trial by jury.

MR. GARVEY: Thank you, Judge.

THE COURT: So we'll finish hearing that on

Monday when you all are prepared. Yes, sir.

MR. DIERKER: Your Honor, the circuit

attorney alluded to the need to hear a motion to quash

subpoenas and deposition notices on the victim and another

witness, and we have filed a motion to shorten time, so we

did notice that up for Monday morning, and I wanted to be

clear that I did tell counsel we were going to be ask to be

able to present those motions on Monday.

THE COURT: The motion to quash, I assume

Mr. Simpson's here on that.

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MR. DIERKER: Right.

THE COURT: Today.

MR. SIMPSON: I am not here specifically on

that motion, Judge. I am here for when the Court takes up

the request to advance the trial setting to be heard on that

issue.

THE COURT: Well, if this motion, I assume

the one you're talking about was just handed in chambers.

MR. DIERKER: Right.

THE COURT: Okay. 9 o'clock Monday.

MR. DIERKER: That's what we're requesting.

MR. BENNETT: No problem.

THE COURT: Okay. So that leaves us to

moving up the trial date.

MR. GARVEY: Yes, Judge.

THE COURT: Okay.

MR. GARVEY: If I may, Judge. I appreciate

the Court taking the time on this issue. I know this is an

extraordinary --

THE COURT: Hang on a second. I'm sorry.

MR. GARVEY: We're aware this is an

extraordinary request to make of the Court, especially after

a scheduling order has been entered for the May 14th trial

date.

However, I think the Court will agree this is an

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extraordinary case never seen before. We have a lot of

parts moving in this case. We start off, first, with the

House is moving along with their investigation. We feel it

best a quick resolution of this case here in the city will

help the House and the State of Missouri and the citizens of

this state to get moving on and get the business of Missouri

moving on.

Second, we have what is going on down here. There

will be absolutely no prejudice to the parties if this trial

date is moved up. We will be ready on the date we are

requesting, April 2nd. The State, at most, has three

witnesses that they are going to call. It's going to be a

very brief and short trial.

In addition, the deposition of Mr. Tisaby was

taken this week. Now, some background is necessary here.

Mr. Tisaby is the chief inspector and the chief investigator

on this case. Frankly, he's the only investigator on this

case. He has been signed up by the Circuit Attorney's

Office to investigate this case. He reports only to circuit

attorney, Ms. Gardner, in this case.

When his deposition was taken, he admitted and

told us under oath a lot of things that shows that the State

is ready for this trial in that they don't have much for

this trial.

On page 64 of his deposition, and I have a full

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copy of it here for the Court so you can follow along.

Mr. Tisaby is asked:

But you have not seen any alleged picture?

"ANSWER: No, I have not. I don't think

anybody has.

"QUESTION: And you did complete a thorough

investigation and have not found anybody that has seen any

alleged picture?"

Correct. That was his answer.

He was also asked:

"QUESTION: So your testimony is you're

unaware of anybody that has made any effort to locate any

alleged photograph?

"ANSWER: Not that I know of."

He's not aware of anyone looking for this photo.

"QUESTION: Are you aware of anybody else who

is making any efforts to locate any alleged photograph?"

Personally I do not.

He was asked: How about not personally?

I mean, I am not sure what you mean by

personally, I do not.

I'm asking for any knowledge you have at all.

Have you heard that anybody is trying to locate the

photograph that allegedly was taken?

"ANSWER: I have not.

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"QUESTION: Have you heard -- have anybody

who is trying to find a transmission of the alleged

photograph?

"ANSWER: I have not.

"QUESTION: Have you talked to any witness

that has told you that any alleged picture was transmitted

as alleged in the indictment?"

His answer was: Neither K.S. or J.W. have

told me as such.

"QUESTION: Are you aware of any evidence

that there is any picture that was transmitted as alleged in

the indictment?

"ANSWER: Am I aware of any?

"QUESTION: Yes. Are you aware of any

evidence?

"ANSWER: Not that I know of.

"QUESTION: And finally, okay, and so you

never found evidence of a photograph, correct?

"ANSWER: No, sir."

Now, Judge, the reason I went through all that is

that is the case there. The Court is aware of the elements

in this case. Mr. Tisaby, the only investigator, the chief

inspector in this case, testified under oath that's what

they have in this case. Which is virtually nothing.

They have no expert ready to testify. They have

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nothing ready to go in this case, which will make this a

very short case to try, and a bench trial will make it even

shorter, cutting down the resources of this Court to be

used.

There is no prejudice to either side in moving up

this court date to April 2nd.

We respect the Governor of Missouri, and we feel

very strongly that this case needs to be ended, especially

in light of the lack of evidence that has been testified to

by Mr. Tisaby. Thank you.

THE COURT: All right. Thank you,

Mr. Garvey. Chief.

MR. DIERKER: Your Honor, you're aware of a

glitch in the filing of the memorandum in opposition, so I'm

going to re-file that with some revisions so that we avoid

unnecessary issues.

You know, the defense strategy throughout this

case has been to try to abort the case on some kind of quasi

summary judgment basis and have the Court make a ruling on

the facts of the case without a trial.

And, you know, the case is -- there is, at a

minimum, a strong circumstantial case that the defendant is

guilty, and the State is entitled and is indeed obligated to

continue to review the facts of the case to ensure that it

is proceeding with a case that is meritorious.

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And I would add that the scheduling order on which

the State has relied sets a deadline for disclosure of

experts, the engagement of experts is ongoing, and given

that the defendant had exclusive control of the best

evidence in this case for three years, the State's task is

made that much more difficult.

So I think that the efforts of the defense, and

while I understand their efforts to abort a trial by

irregular means are ingenious, they're without merit, and I

don't intend to give an opening statement in the guise of

responding to their motion to expedite the trial.

The Court expedited the trial as it was, and the

State was put to quite a bit of pressure to respond to the

May setting, and I think that the public interest and

importance of this case warrants at least some deliberation

in preparation and we agreed to a scheduling order and the

Court entered it, and now the defense thinks it's to their

advantage to throw that overboard, and I can understand why

they think that, but I don't think that would be

appropriate.

And I would also say they represent the Governor

of the State of Missouri. We represent the People of the

State of Missouri. And we think the People and the victim

are entitled to a trial that is presented carefully and

deliberately. So we see absolutely no reason to expedite

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the trial on the basis they're suggesting.

THE COURT: Thank you, Chief. Response.

MR. GARVEY: Judge, it was their

investigator, their only investigator, who has been put in

charge of this case to seek out that evidence. He is

admitting under oath and on the record that's it. That's

all they have.

And with that in mind, then we're ready, and I

believe the State is ready to proceed, and we should be able

to advance this case in light of those admissions made by

their investigator.

THE COURT: All right.

MS. GARDNER: Your Honor, can I respond to

that?

THE COURT: Sure.

MS. GARDNER: Your Honor, when we talk about

this investigation, Mr. Tisaby was hired to do specific

things on this case, as well as other issues that I cannot

discuss in open court.

So, on this case, he was tasked with finding two

individuals; the victim in this case, and other witnesses in

this case, and that is it. And Mr. Tisaby, that was his

only task, and those witnesses and victims went into the

Grand Jury and presented testimony that was enough to secure

an indictment on the invasion of privacy felony offense as

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charged.

So, you know, when the other side talks about what

evidence I have, they don't know what evidence I have. They

know right now what I've turned over, and we'll continue to

turn over discovery as needed as we get it. So I think when

you talk about the investigator, the investigator had a

specific purpose, the investigator was not in Grand Jury.

He was to find people and that was his job in this task, but

we have a victim here and the victim has -- needs their day

in court, and I think we have to look at an expedited trial

date affects the victim. There is a victim.

THE COURT: Ms. Gardner, I am not going to

make a decision of trial setting based on substantive

evidence in this case that has been presented in a motion.

So your point's well taken.

Mr. Simpson, did you have -- want to be heard on

this?

MR. SIMPSON: Briefly, your Honor, Scott

Simpson, and I represent the victim in this case. The

points I would like the Court to consider when moving up

this trial setting is that my client is a full-time student,

employed full time, as well as a single mother, and she --

if the trial is moved into April, she will be in a position

where her school will be in its last full month as they lead

into finals. Adding the trial and the deposition and all of

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those on an expedited fashion I think would impose a

hardship upon her, and she has rearranged her schedule and

her life to make sure that this May trial date works.

So we would ask the Court to consider the hardship

on the victim as it makes its decision. Thank you.

THE COURT: Thanks, Mr. Simpson.

MR. GARVEY: Judge, if I may, just two

things. Ms. Gardner said we don't know the evidence she

has. That's very disturbing because we should know.

THE COURT: Mr. Garvey, at this point, as I

say, I'm not going to make decisions on trial settings based

on the degree and weight of evidence that is known at this

point. That's just not -- that's just not going to go into

the forum.

MR. GARVEY: Judge, that is not forwarded to

you on the basis to argue the merits of the case, but only

to show their evidence in this case. It's a subterfuge to

say they need more time. We're ready, they're ready. There

is really no reason to delay this case. And under the

extraordinary circumstances of who our client is, that's

what we're asking for.

I did not mean to invade the province of the Court

and argue this case on this case, they were examples of how

they are ready.

Mr. Tisaby has testified. In the deposition, Ms.

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Gardner has never instructed me as far as what investigative

steps I am doing. I report to her and things that I need.

As far as the Grand Jury, which she says he wasn't involved

with. She and I don't talk about it and don't discuss it.

I am trying to work this case as independently as possible.

So we're getting mixed messages here. I only

bring this to the Court's attention regarding the evidence

that she says we don't know what she has because we should

know what she has under the rules of discovery, and if

there's something being withheld, that's very disturbing.

Thank you.

THE COURT: Okay. Most important in this

case and in all trials is the stability and predictability

of a trial setting. I advanced this case at the request of

the defendant and set a date over the State's objection.

The fact that there are things that happen west of

here that have occurred in the interim, it does not affect

my trial setting decision. I will not change the trial

setting that may create -- that -- based on an advantage or

disadvantage that may be perceived.

The case is set for the 14th of May. That's the

court date. That's the trial date. That's regardless of

what is going on west of here. I am going to do all I can

to keep anything outside of this courtroom that goes on away

from this case. And so I'm not influenced about anything

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other than the fact that I gave an early trial setting,

that's the trial setting you get, that's the one we'll keep.

Anything further?

MR. MARTIN: Thank you for your time.

MR. GARVEY: Thank you.

MR. SIMPSON: Thank you, your Honor.

THE COURT: Court will be in recess.

(The hearing was concluded.)

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CERTIFICATE

I, Jennifer A. Dunn, Registered Professional

Reporter and Certified Court Reporter, do hereby certify

that I am an official court reporter for the Circuit Court

of the City of St. Louis; that on March 21, 2018, I was

present and reported all the proceedings had in the case of

STATE OF MISSOURI, Plaintiff, vs. ERIC GREITENS, Defendant,

Cause No. 1822-CR00642.

I further certify that the foregoing pages

contain a true and accurate reproduction of the proceedings.

"/s/JENNIFER A. DUNN, RPR, CCR #485"

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MR. MR. MR. MR. BENNETT: BENNETT: BENNETT: BENNETT: [1] [1] [1] [1] 6/11 MR. MR. MR. MR. DIERKER: DIERKER: DIERKER: DIERKER: [5] [5] [5] [5] 5/16 5/25 6/8 6/10 10/12 MR. MR. MR. MR. GARVEY: GARVEY: GARVEY: GARVEY: [17] [17] [17] [17] 2/6 2/18 2/22 3/9 3/15 3/19 3/22 4/4 4/16 5/13 6/14 6/16 6/20 12/2 14/6 14/14 16/4 MR. MR. MR. MR. MARTIN: MARTIN: MARTIN: MARTIN: [1] [1] [1] [1] 16/3 MR. MR. MR. MR. SIMPSON: SIMPSON: SIMPSON: SIMPSON: [3] [3] [3] [3] 6/2 13/17 16/5 MS. MS. MS. MS. GARDNER: GARDNER: GARDNER: GARDNER: [5] [5] [5] [5] 3/6 3/11 4/6

12/12 12/15 THE THE THE THE COURT: COURT: COURT: COURT: [26] [26] [26] [26]

/////s/JENNIFE/s/JENNIFE/s/JENNIFE/s/JENNIFER [1] R [1] R [1] R [1] 17/16

11111100 [1] 1100 [1] 1100 [1] 1100 [1] 1/181114 [1] 1114 [1] 1114 [1] 1114 [1] 1/15120 [1] 120 [1] 120 [1] 120 [1] 1/21130 [1] 130 [1] 130 [1] 130 [1] 1/2114th [2] 14th [2] 14th [2] 14th [2] 6/23 15/211822-CR001822-CR001822-CR001822-CR00642 [3] 642 [3] 642 [3] 642 [3] 1/7 2/4 17/81900 [1] 1900 [1] 1900 [1] 1900 [1] 1/19

22222018 [2] 2018 [2] 2018 [2] 2018 [2] 1/11 17/521 [2] 21 [2] 21 [2] 21 [2] 1/11 17/527 [1] 27 [1] 27 [1] 27 [1]

5/102nd [2] 2nd [2] 2nd [2] 2nd [2] 7/11 10/6

4444485 [2] 485 [2] 485 [2] 485 [2] 1/24 17/16

666663101 [1] 63101 [1] 63101 [1] 63101 [1] 1/1663105 [3] 63105 [3] 63105 [3] 63105 [3] 1/19 1/19 1/2264 [1] 64 [1] 64 [1] 64 [1] 7/25

77777733 [1] 7733 [1] 7733 [1] 7733 [1] 1/19

88888235 [1] 8235 [1] 8235 [1] 8235 [1] 1/18

AAAAable [2] able [2] able [2] able [2] 5/23 12/9abort [2] abort [2] abort [2] abort [2] 10/18 11/8about [7] about [7] about [7] about [7] 6/8 8/19 12/16 13/2 13/6 15/4

15/25absolute [3]absolute [3]absolute [3]absolute [3] 3/22 4/2 4/3absolutelyabsolutelyabsolutelyabsolutely [2] [2] [2] [2] 7/9 11/25accurate [1]accurate [1]accurate [1]accurate [1] 17/10actions [1] actions [1] actions [1] actions [1] 5/6add [1] add [1] add [1] add [1] 11/1Adding [1] Adding [1] Adding [1] Adding [1] 13/25addition [1]addition [1]addition [1]addition [1] 7/14addressedaddressedaddressedaddressed [1] [1] [1] [1] 4/15adequatelyadequatelyadequatelyadequately [2] [2] [2] [2] 4/20 4/20admissionsadmissionsadmissionsadmissions [1] [1] [1] [1] 12/10admittedadmittedadmittedadmitted [1] [1] [1] [1] 7/21admittingadmittingadmittingadmitting [1] [1] [1] [1] 12/6advance [4]advance [4]advance [4]advance [4] 2/10 2/20 6/5 12/10advancedadvancedadvancedadvanced [1] [1] [1] [1] 15/14advantageadvantageadvantageadvantage [2] [2] [2] [2] 11/18

15/19advised [1] advised [1] advised [1] advised [1] 4/20affect [1] affect [1] affect [1] affect [1] 15/17affects [1] affects [1] affects [1] affects [1] 13/11after [1] after [1] after [1] after [1] 6/22agree [1] agree [1] agree [1] agree [1] 6/25agreed [1] agreed [1] agreed [1] agreed [1] 11/16all [15] all [15] all [15] all [15] 5/2 5/6 5/6 5/10 5/12 5/16 8/22 9/20 10/11 12/7 12/12 13/25 15/13 15/23 17/6alleged [8] alleged [8] alleged [8] alleged [8] 8/3 8/8 8/13 8/17 9/2 9/6 9/7 9/11allegedlyallegedlyallegedlyallegedly [1] [1] [1] [1] 8/24alluded [1] alluded [1] alluded [1] alluded [1] 5/18along [2] along [2] along [2] along [2]

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AAAAalong... [2] along... [2] along... [2] along... [2] 7/3 8/1also [3] also [3] also [3] also [3] 4/8 8/10 11/21althoughalthoughalthoughalthough [1] [1] [1] [1] 2/13am [9] am [9] am [9] am [9] 6/3 6/4 8/20 9/13 13/12 15/2 15/5 15/23 17/4another [1] another [1] another [1] another [1] 5/19answer [9] answer [9] answer [9] answer [9] 8/4 8/9 8/14 8/25 9/4 9/8 9/13 9/16 9/19any [16] any [16] any [16] any [16] 2/13 5/1 5/2 8/3 8/7 8/12 8/12 8/17 8/17 8/22 9/5 9/6 9/10 9/11 9/13 9/14anybody [6]anybody [6]anybody [6]anybody [6] 8/5 8/7

8/12 8/16 8/23 9/1anyone [1] anyone [1] anyone [1] anyone [1] 8/15anythinganythinganythinganything [3] [3] [3] [3] 15/24 15/25 16/3appearingappearingappearingappearing [1] [1] [1] [1] 3/1appreciateappreciateappreciateappreciate [1] [1] [1] [1] 6/17appropriateappropriateappropriateappropriate [1] [1] [1] [1] 11/20April [3] April [3] April [3] April [3] 7/11 10/6 13/23April 2ndApril 2ndApril 2ndApril 2nd [2] [2] [2] [2] 7/11 10/6are [12] are [12] are [12] are [12] 2/16 3/8 5/16 7/10 7/12 8/16 9/10 9/14 11/9 11/24 14/24 15/16argue [5] argue [5] argue [5] argue [5] 4/6 5/3 5/4 14/16 14/23as [26] as [26] as [26] as [26] ask [2] ask [2] ask [2] ask [2]

5/22 14/4asked [3] asked [3] asked [3] asked [3] 8/2 8/10 8/19asking [3] asking [3] asking [3] asking [3] 4/7 8/22 14/21assume [3] assume [3] assume [3] assume [3] 5/12 5/24 6/7attentionattentionattentionattention [1] [1] [1] [1] 15/7attorney [2]attorney [2]attorney [2]attorney [2] 5/18 7/20Attorney'sAttorney'sAttorney'sAttorney's [2] [2] [2] [2] 1/15 7/18Avenue [1] Avenue [1] Avenue [1] Avenue [1] 1/21avoid [1] avoid [1] avoid [1] avoid [1] 10/15aware [9] aware [9] aware [9] aware [9] 2/5 6/21 8/15 8/16 9/10 9/13 9/14 9/21 10/13away [1] away [1] away [1] away [1] 15/24

BBBBbackgroundbackgroundbackgroundbackground [1] [1] [1] [1] 7/15based [4] based [4] based [4] based [4] 2/11

13/13 14/11 15/19basis [3] basis [3] basis [3] basis [3] 10/19 12/1 14/16be [23] be [23] be [23] be [23] became [1] became [1] became [1] became [1] 2/5because [5]because [5]because [5]because [5] 4/8 4/11 5/1 14/9 15/8been [8] been [8] been [8] been [8] 3/5 4/20 6/23 7/18 10/9 10/18 12/4 13/14before [1] before [1] before [1] before [1] 7/1behalf [2] behalf [2] behalf [2] behalf [2] 1/16 1/22being [2] being [2] being [2] being [2] 4/8 15/10believe [1] believe [1] believe [1] believe [1] 12/9bench [2] bench [2] bench [2] bench [2] 3/3 10/2BENNETTBENNETTBENNETTBENNETT [1] [1] [1] [1] 1/18best [2] best [2] best [2] best [2] 7/4 11/4

bit [1] bit [1] bit [1] bit [1] 11/13Blvd [2] Blvd [2] Blvd [2] Blvd [2] 1/18 1/19brief [1] brief [1] brief [1] brief [1] 7/13Briefly [1] Briefly [1] Briefly [1] Briefly [1] 13/18bring [1] bring [1] bring [1] bring [1] 15/7Burlison [1]Burlison [1]Burlison [1]Burlison [1] 1/2businessbusinessbusinessbusiness [1] [1] [1] [1] 7/6

CCCCcall [1] call [1] call [1] call [1] 7/12calls [1] calls [1] calls [1] calls [1] 2/3can [8] can [8] can [8] can [8] 3/3 3/10 4/20 4/24 8/1 11/18 12/13 15/23cannot [2] cannot [2] cannot [2] cannot [2] 4/13 12/18care [1] care [1] care [1] care [1] 3/25carefully [1]carefully [1]carefully [1]carefully [1] 11/24Carey [1] Carey [1] Carey [1] Carey [1] 1/18

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CCCCcase [45] case [45] case [45] case [45] cases [1] cases [1] cases [1] cases [1] 5/10Cause [3] Cause [3] Cause [3] Cause [3] 1/7 2/3 17/8CCR [2] CCR [2] CCR [2] CCR [2] 1/24 17/16Central [1] Central [1] Central [1] Central [1] 1/21CERTIFICATCERTIFICATCERTIFICATCERTIFICATE [1] E [1] E [1] E [1] 17/1Certified [1]Certified [1]Certified [1]Certified [1] 17/3certify [2] certify [2] certify [2] certify [2] 17/3 17/9challengechallengechallengechallenge [2] [2] [2] [2] 4/22 5/2chamberschamberschamberschambers [1] [1] [1] [1] 6/8change [1] change [1] change [1] change [1] 15/18charge [1] charge [1] charge [1] charge [1] 12/5charged [1]charged [1]charged [1]charged [1] 13/1chief [5] chief [5] chief [5] chief [5] 7/16 7/16 9/22 10/12 12/2

circuit [8] circuit [8] circuit [8] circuit [8] 1/1 1/15 1/25 1/25 5/17 7/18 7/19 17/4circumstancircumstancircumstancircumstances [1] ces [1] ces [1] ces [1] 14/20circumstantcircumstantcircumstantcircumstantial [1] ial [1] ial [1] ial [1] 10/22citizens [1] citizens [1] citizens [1] citizens [1] 7/5city [4] city [4] city [4] city [4] 1/1 1/25 7/4 17/5clear [1] clear [1] clear [1] clear [1] 5/22client [5] client [5] client [5] client [5] 3/21 4/3 4/17 13/21 14/20completecompletecompletecomplete [1] [1] [1] [1] 8/6concludedconcludedconcludedconcluded [1] [1] [1] [1] 16/8consider [2]consider [2]consider [2]consider [2] 13/20 14/4contain [1] contain [1] contain [1] contain [1] 17/10continue [2]continue [2]continue [2]continue [2] 10/24 13/4

control [1] control [1] control [1] control [1] 11/4copy [1] copy [1] copy [1] copy [1] 8/1correct [3] correct [3] correct [3] correct [3] 3/23 8/9 9/18counsel [1] counsel [1] counsel [1] counsel [1] 5/22court [30] court [30] court [30] court [30] Court's [3] Court's [3] Court's [3] Court's [3] 3/1 3/25 15/7courtroomcourtroomcourtroomcourtroom [1] [1] [1] [1] 15/24CR00642CR00642CR00642CR00642 [3] [3] [3] [3] 1/7 2/4 17/8create [1] create [1] create [1] create [1] 15/19criminal [1]criminal [1]criminal [1]criminal [1] 5/10cutting [1] cutting [1] cutting [1] cutting [1] 10/3

DDDDDanis [1] Danis [1] Danis [1] Danis [1] 1/18date [12] date [12] date [12] date [12] 2/10 2/20 6/14 6/24 7/10 7/10 10/6 13/11 14/3

15/15 15/22 15/22dates [1] dates [1] dates [1] dates [1] 4/11day [2] day [2] day [2] day [2] 3/2 13/9deadline [1]deadline [1]deadline [1]deadline [1] 11/2deciding [1]deciding [1]deciding [1]deciding [1] 4/24decision [3]decision [3]decision [3]decision [3] 13/13 14/5 15/18decisionsdecisionsdecisionsdecisions [1] [1] [1] [1] 14/11defendantdefendantdefendantdefendant [6] [6] [6] [6] 1/9 1/22 10/22 11/4 15/15 17/7defense [5] defense [5] defense [5] defense [5] 5/8 5/9 10/17 11/7 11/17degree [1] degree [1] degree [1] degree [1] 14/12delay [1] delay [1] delay [1] delay [1] 14/19deliberatelydeliberatelydeliberatelydeliberately [1] [1] [1] [1] 11/25

deliberatiodeliberatiodeliberatiodeliberation [1] n [1] n [1] n [1] 11/15depositiondepositiondepositiondeposition [7] [7] [7] [7] 4/8 5/19 7/14 7/21 7/25 13/25 14/25did [5] did [5] did [5] did [5] 5/21 5/22 8/6 13/16 14/22didn't [1] didn't [1] didn't [1] didn't [1] 5/1DIERKER [1]DIERKER [1]DIERKER [1]DIERKER [1] 1/14difficult [1] difficult [1] difficult [1] difficult [1] 11/6directed [1]directed [1]directed [1]directed [1] 5/7disadvantadisadvantadisadvantadisadvantage [1] ge [1] ge [1] ge [1] 15/20disclosuredisclosuredisclosuredisclosure [1] [1] [1] [1] 11/2discoverydiscoverydiscoverydiscovery [2] [2] [2] [2] 13/5 15/9discuss [2] discuss [2] discuss [2] discuss [2] 12/19 15/4dismiss [1] dismiss [1] dismiss [1] dismiss [1] 2/11disqualifydisqualifydisqualifydisqualify [[[[1111]]]] 2/12

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DDDDdisturbingdisturbingdisturbingdisturbing [2] [2] [2] [2] 14/9 15/10do [5] do [5] do [5] do [5] 8/18 8/21 12/17 15/23 17/3does [2] does [2] does [2] does [2] 4/23 15/17doing [2] doing [2] doing [2] doing [2] 3/2 15/2don't [13] don't [13] don't [13] don't [13] 2/13 3/25 4/2 4/3 7/23 8/4 11/10 11/19 13/3 14/8 15/4 15/4 15/8DOWD [2] DOWD [2] DOWD [2] DOWD [2] 1/18 1/18down [2] down [2] down [2] down [2] 7/8 10/3DUNN [3] DUNN [3] DUNN [3] DUNN [3] 1/24 17/2 17/16

EEEEearly [1] early [1] early [1] early [1] 16/1EDWARD [1]EDWARD [1]EDWARD [1]EDWARD [1] 1/18

effort [1] effort [1] effort [1] effort [1] 8/12efforts [3] efforts [3] efforts [3] efforts [3] 8/17 11/7 11/8either [1] either [1] either [1] either [1] 10/5elementselementselementselements [1] [1] [1] [1] 9/21else [1] else [1] else [1] else [1] 8/16employedemployedemployedemployed [1] [1] [1] [1] 13/22ended [1] ended [1] ended [1] ended [1] 10/8engagemenengagemenengagemenengagement [1] t [1] t [1] t [1] 11/3enough [1] enough [1] enough [1] enough [1] 12/24ensure [1] ensure [1] ensure [1] ensure [1] 10/24entered [2] entered [2] entered [2] entered [2] 6/23 11/17entitled [2] entitled [2] entitled [2] entitled [2] 10/23 11/24ERIC [3] ERIC [3] ERIC [3] ERIC [3] 1/8 2/4 17/7especiallyespeciallyespeciallyespecially [2] [2] [2] [2] 6/22 10/8even [2] even [2] even [2] even [2] 5/1 10/2

evidenceevidenceevidenceevidence [14] [14] [14] [14] 5/9 9/10 9/15 9/18 10/9 11/5 12/5 13/3 13/3 13/14 14/8 14/12 14/17 15/7examplesexamplesexamplesexamples [1] [1] [1] [1] 14/23exclusiveexclusiveexclusiveexclusive [1] [1] [1] [1] 11/4expediteexpediteexpediteexpedite [2] [2] [2] [2] 11/11 11/25expeditedexpeditedexpeditedexpedited [3] [3] [3] [3] 11/12 13/10 14/1expert [1] expert [1] expert [1] expert [1] 9/25experts [2] experts [2] experts [2] experts [2] 11/3 11/3extraordinaextraordinaextraordinaextraordinary [4] ry [4] ry [4] ry [4] 6/19 6/22 7/1 14/20

FFFFfact [2] fact [2] fact [2] fact [2] 15/16 16/1

facts [2] facts [2] facts [2] facts [2] 10/20 10/24far [2] far [2] far [2] far [2] 15/1 15/3fashion [1] fashion [1] fashion [1] fashion [1] 14/1feel [2] feel [2] feel [2] feel [2] 7/3 10/7felony [1] felony [1] felony [1] felony [1] 12/25file [1] file [1] file [1] file [1] 10/15filed [2] filed [2] filed [2] filed [2] 4/25 5/20filing [2] filing [2] filing [2] filing [2] 3/5 10/14final [1] final [1] final [1] final [1] 3/25finally [1] finally [1] finally [1] finally [1] 9/17finals [1] finals [1] finals [1] finals [1] 13/25find [2] find [2] find [2] find [2] 9/2 13/8finding [1] finding [1] finding [1] finding [1] 12/20finish [1] finish [1] finish [1] finish [1] 5/15first [1] first [1] first [1] first [1] 7/2follow [1] follow [1] follow [1] follow [1] 8/1followingfollowingfollowingfollowing [1] [1] [1] [1] 2/1

foregoingforegoingforegoingforegoing [1] [1] [1] [1] 17/9Forsyth [2] Forsyth [2] Forsyth [2] Forsyth [2] 1/18 1/19forum [1] forum [1] forum [1] forum [1] 14/14forwardedforwardedforwardedforwarded [1] [1] [1] [1] 14/15found [2] found [2] found [2] found [2] 8/7 9/18frankly [2] frankly [2] frankly [2] frankly [2] 4/25 7/17front [1] front [1] front [1] front [1] 4/18Fry [1] Fry [1] Fry [1] Fry [1] 1/21full [4] full [4] full [4] full [4] 7/25 13/21 13/22 13/24full-timefull-timefull-timefull-time [1] [1] [1] [1] 13/21further [2] further [2] further [2] further [2] 16/3 17/9

GGGGGARDNERGARDNERGARDNERGARDNER [5] [5] [5] [5] 1/14 7/20 13/12 14/8 15/1GARVEY [3] GARVEY [3] GARVEY [3] GARVEY [3] 1/17 10/12

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GGGGGARVEY...GARVEY...GARVEY...GARVEY... [1] [1] [1] [1] 14/10gave [1] gave [1] gave [1] gave [1] 16/1get [4] get [4] get [4] get [4] 7/6 7/6 13/5 16/2getting [1] getting [1] getting [1] getting [1] 15/6give [2] give [2] give [2] give [2] 5/8 11/10given [2] given [2] given [2] given [2] 5/1 11/3glitch [1] glitch [1] glitch [1] glitch [1] 10/14go [2] go [2] go [2] go [2] 10/1 14/13goes [1] goes [1] goes [1] goes [1] 15/24going [14] going [14] going [14] going [14] 2/24 3/25 4/17 4/18 5/22 7/8 7/12 7/12 10/15 13/12 14/11 14/13 15/23 15/23governorgovernorgovernorgovernor [3] [3] [3] [3] 2/24

10/7 11/21Grand [5] Grand [5] Grand [5] Grand [5] 2/12 2/24 12/24 13/7 15/3GREITENSGREITENSGREITENSGREITENS [3] [3] [3] [3] 1/8 2/4 17/7guilty [1] guilty [1] guilty [1] guilty [1] 10/23guise [1] guise [1] guise [1] guise [1] 11/10

HHHHhad [7] had [7] had [7] had [7] 2/1 2/5 4/11 5/2 11/4 13/6 17/6handed [1] handed [1] handed [1] handed [1] 6/8Hang [1] Hang [1] Hang [1] Hang [1] 6/20happen [1] happen [1] happen [1] happen [1] 15/16hardshiphardshiphardshiphardship [2] [2] [2] [2] 14/2 14/4has [27] has [27] has [27] has [27] have [35] have [35] have [35] have [35] haven't [2] haven't [2] haven't [2] haven't [2] 3/16 4/25he [15] he [15] he [15] he [15] 2/14 2/23 3/1 4/19

4/20 4/24 7/18 7/19 7/21 8/10 8/19 12/5 12/20 13/8 15/3he's [2] he's [2] he's [2] he's [2] 7/17 8/15hear [5] hear [5] hear [5] hear [5] 3/8 3/12 3/14 4/1 5/18heard [5] heard [5] heard [5] heard [5] 2/17 6/5 8/23 9/1 13/16hearing [9] hearing [9] hearing [9] hearing [9] 1/11 2/6 2/9 2/10 2/15 4/19 5/12 5/15 16/8help [1] help [1] help [1] help [1] 7/5her [5] her [5] her [5] her [5] 13/24 14/2 14/2 14/3 15/2here [11] here [11] here [11] here [11] 5/25 6/3 6/4 7/4 7/8 7/15 8/1 13/9 15/6 15/17

15/23hereby [1] hereby [1] hereby [1] hereby [1] 17/3him [2] him [2] him [2] him [2] 3/3 4/19himself [2] himself [2] himself [2] himself [2] 2/14 4/18hired [1] hired [1] hired [1] hired [1] 12/17his [9] his [9] his [9] his [9] 2/24 4/21 4/24 7/21 7/25 8/9 9/8 12/22 13/8HON [2] HON [2] HON [2] HON [2] 1/14 1/17Honor [8] Honor [8] Honor [8] Honor [8] 3/7 4/7 5/17 10/13 12/13 12/16 13/18 16/6HonorableHonorableHonorableHonorable [1] [1] [1] [1] 1/2House [2] House [2] House [2] House [2] 7/3 7/5housekeepihousekeepihousekeepihousekeeping [1] ng [1] ng [1] ng [1] 2/8how [2] how [2] how [2] how [2] 8/19 14/23However [2]However [2]However [2]However [2] 4/23 6/25

huge [1] huge [1] huge [1] huge [1] 4/23

IIIII'm [9] I'm [9] I'm [9] I'm [9] 2/6 3/18 3/21 4/7 6/20 8/22 10/14 14/11 15/25I've [1] I've [1] I've [1] I've [1] 13/4importanceimportanceimportanceimportance [1] [1] [1] [1] 11/15importantimportantimportantimportant [1] [1] [1] [1] 15/12impose [1] impose [1] impose [1] impose [1] 14/1indeed [1] indeed [1] indeed [1] indeed [1] 10/23independenindependenindependenindependently [1] tly [1] tly [1] tly [1] 15/5indictmentindictmentindictmentindictment [3] [3] [3] [3] 9/7 9/12 12/25individualsindividualsindividualsindividuals [1] [1] [1] [1] 12/21influencedinfluencedinfluencedinfluenced [1] [1] [1] [1] 15/25informedinformedinformedinformed [1] [1] [1] [1] 4/20ingeniousingeniousingeniousingenious [1] [1] [1] [1] 11/9

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IIIIinquire [1] inquire [1] inquire [1] inquire [1] 4/19inspectorinspectorinspectorinspector [2] [2] [2] [2] 7/16 9/23instructedinstructedinstructedinstructed [1] [1] [1] [1] 15/1intend [1] intend [1] intend [1] intend [1] 11/10interest [1] interest [1] interest [1] interest [1] 11/14interim [1] interim [1] interim [1] interim [1] 15/17invade [1] invade [1] invade [1] invade [1] 14/22invasion [1]invasion [1]invasion [1]invasion [1] 12/25investigateinvestigateinvestigateinvestigate [1] [1] [1] [1] 7/19investigatioinvestigatioinvestigatioinvestigation [3] n [3] n [3] n [3] 7/3 8/7 12/17investigativinvestigativinvestigativinvestigative [1] e [1] e [1] e [1] 15/1investigatorinvestigatorinvestigatorinvestigator [9] [9] [9] [9] 7/16 7/17 9/22 12/4 12/4 12/11 13/6 13/6 13/7involved [1]involved [1]involved [1]involved [1] 15/3

irregular [1]irregular [1]irregular [1]irregular [1] 11/9is [52] is [52] is [52] is [52] issue [3] issue [3] issue [3] issue [3] 4/12 6/6 6/18issues [3] issues [3] issues [3] issues [3] 4/8 10/16 12/18it [20] it [20] it [20] it [20] it's [4] it's [4] it's [4] it's [4] 2/19 7/12 11/17 14/17item [1] item [1] item [1] item [1] 2/22its [2] its [2] its [2] its [2] 13/24 14/5

JJJJJ.W [1] J.W [1] J.W [1] J.W [1] 9/8JACK [1] JACK [1] JACK [1] JACK [1] 1/17JAMES [1] JAMES [1] JAMES [1] JAMES [1] 1/17JENNIFERJENNIFERJENNIFERJENNIFER [3] [3] [3] [3] 1/24 17/2 17/16job [1] job [1] job [1] job [1] 13/8Judge [16] Judge [16] Judge [16] Judge [16] 1/2 2/7 3/11 3/16

3/20 3/23 4/5 4/17 5/14 6/4 6/15 6/17 9/20 12/3 14/7 14/15judgmentjudgmentjudgmentjudgment [1] [1] [1] [1] 10/19JUDICIALJUDICIALJUDICIALJUDICIAL [1] [1] [1] [1] 1/25jury [16] jury [16] jury [16] jury [16] 2/12 2/22 2/24 3/1 3/13 3/17 3/22 4/15 4/21 4/24 5/6 5/10 5/13 12/24 13/7 15/3just [8] just [8] just [8] just [8] 2/7 2/8 2/19 3/2 6/8 14/7 14/13 14/13

KKKKK.S [1] K.S [1] K.S [1] K.S [1] 9/8keep [2] keep [2] keep [2] keep [2] 15/24 16/2KIMBERLYKIMBERLYKIMBERLYKIMBERLY [1] [1] [1] [1] 1/14

kind [1] kind [1] kind [1] kind [1] 10/18know [14] know [14] know [14] know [14] 2/13 3/24 6/18 8/14 9/16 10/17 10/21 13/2 13/3 13/4 14/8 14/9 15/8 15/9knowledgeknowledgeknowledgeknowledge [1] [1] [1] [1] 8/22known [1] known [1] known [1] known [1] 14/12

LLLLlack [1] lack [1] lack [1] lack [1] 10/9last [1] last [1] last [1] last [1] 13/24lead [1] lead [1] lead [1] lead [1] 13/24least [1] least [1] least [1] least [1] 11/15leaves [1] leaves [1] leaves [1] leaves [1] 6/13life [1] life [1] life [1] life [1] 14/3light [3] light [3] light [3] light [3] 5/9 10/9 12/10like [4] like [4] like [4] like [4] 2/9 2/25 4/6

13/20LLP [1] LLP [1] LLP [1] LLP [1] 1/18locate [3] locate [3] locate [3] locate [3] 8/12 8/17 8/23long [1] long [1] long [1] long [1] 3/24look [1] look [1] look [1] look [1] 13/10looking [1] looking [1] looking [1] looking [1] 8/15lot [2] lot [2] lot [2] lot [2] 7/1 7/22LOUIS [7] LOUIS [7] LOUIS [7] LOUIS [7] 1/1 1/16 1/19 1/19 1/22 1/25 17/5Lowe [1] Lowe [1] Lowe [1] Lowe [1] 1/18

MMMMmade [3] made [3] made [3] made [3] 8/12 11/6 12/10make [7] make [7] make [7] make [7] 6/22 10/1 10/2 10/19 13/13 14/3 14/11makes [2] makes [2] makes [2] makes [2] 5/10 14/5

Page 24: IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS ...kmov.images.worldnow.com/library/40ad3d45-7fb4-42fc-beb0...EDWARD DOWD Carey, Danis & Lowe DOWD BENNETT LLP 8235 Forsyth Blvd. #1100

MMMMmaking [1] making [1] making [1] making [1] 8/17March [2] March [2] March [2] March [2] 1/11 17/5Market [1] Market [1] Market [1] Market [1] 1/15MARTIN [1] MARTIN [1] MARTIN [1] MARTIN [1] 1/17matter [1] matter [1] matter [1] matter [1] 5/5may [8] may [8] may [8] may [8] 6/17 6/23 11/14 14/3 14/7 15/19 15/20 15/21May 14thMay 14thMay 14thMay 14th [1] [1] [1] [1] 6/23me [2] me [2] me [2] me [2] 9/9 15/1mean [3] mean [3] mean [3] mean [3] 8/20 8/20 14/22means [1] means [1] means [1] means [1] 11/9memorandmemorandmemorandmemorandum [1] um [1] um [1] um [1] 10/14merit [1] merit [1] merit [1] merit [1] 11/9meritoriousmeritoriousmeritoriousmeritorious [1] [1] [1] [1] 10/25

merits [1] merits [1] merits [1] merits [1] 14/16messagesmessagesmessagesmessages [1] [1] [1] [1] 15/6might [1] might [1] might [1] might [1] 2/14mind [1] mind [1] mind [1] mind [1] 12/8minimumminimumminimumminimum [1] [1] [1] [1] 10/22misinstructimisinstructimisinstructimisinstructing [1] ng [1] ng [1] ng [1] 2/11MISSOURIMISSOURIMISSOURIMISSOURI [10] [10] [10] [10] 1/1 1/5 1/16 2/4 7/5 7/6 10/7 11/22 11/23 17/7mixed [1] mixed [1] mixed [1] mixed [1] 15/6MO [4] MO [4] MO [4] MO [4] 1/16 1/19 1/19 1/22MondayMondayMondayMonday [14] [14] [14] [14] 2/10 2/17 2/22 3/10 4/1 4/6 4/16 5/4 5/8 5/11 5/16 5/21 5/23 6/10

month [1] month [1] month [1] month [1] 13/24more [3] more [3] more [3] more [3] 2/13 11/6 14/18morning [1]morning [1]morning [1]morning [1] 5/21most [2] most [2] most [2] most [2] 7/11 15/12mother [1] mother [1] mother [1] mother [1] 13/22motion [22]motion [22]motion [22]motion [22] motions [2]motions [2]motions [2]motions [2] 2/16 5/23moved [2] moved [2] moved [2] moved [2] 7/10 13/23moving [7] moving [7] moving [7] moving [7] 6/14 7/2 7/3 7/6 7/7 10/5 13/20MR [11] MR [11] MR [11] MR [11] 1/17 1/18 1/20 7/14 7/16 8/2 9/22 10/10 12/17 12/22 14/25Mr. [5] Mr. [5] Mr. [5] Mr. [5] 5/25

10/12 13/16 14/6 14/10Mr. GarveyMr. GarveyMr. GarveyMr. Garvey [2] [2] [2] [2] 10/12 14/10Mr.Mr.Mr.Mr. Simpson Simpson Simpson Simpson [2] [2] [2] [2] 13/16 14/6Mr.Mr.Mr.Mr. Simpson's Simpson's Simpson's Simpson's [1] [1] [1] [1] 5/25MS [5] MS [5] MS [5] MS [5] 1/14 7/20 13/12 14/8 14/25much [2] much [2] much [2] much [2] 7/23 11/6my [2] my [2] my [2] my [2] 13/21 15/18

NNNNnecessarynecessarynecessarynecessary [2] [2] [2] [2] 2/13 7/15need [3] need [3] need [3] need [3] 5/18 14/18 15/2needed [1] needed [1] needed [1] needed [1] 13/5

needs [4] needs [4] needs [4] needs [4] 4/12 4/15 10/8 13/9neither [2] neither [2] neither [2] neither [2] 4/1 9/8never [3] never [3] never [3] never [3] 7/1 9/18 15/1no [12] no [12] no [12] no [12] 1/7 2/15 4/21 6/12 7/9 8/4 9/19 9/25 10/5 11/25 14/19 17/8not [30] not [30] not [30] not [30] nothing [2] nothing [2] nothing [2] nothing [2] 9/24 10/1notice [2] notice [2] notice [2] notice [2] 4/9 5/21noticed [1] noticed [1] noticed [1] noticed [1] 2/6notices [2] notices [2] notices [2] notices [2] 4/8 5/19notified [1] notified [1] notified [1] notified [1] 2/23now [5] now [5] now [5] now [5] 5/11 7/15 9/20 11/17 13/4Number [1] Number [1] Number [1] Number [1] 2/3

Page 25: IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS ...kmov.images.worldnow.com/library/40ad3d45-7fb4-42fc-beb0...EDWARD DOWD Carey, Danis & Lowe DOWD BENNETT LLP 8235 Forsyth Blvd. #1100

OOOOo'clock [1] o'clock [1] o'clock [1] o'clock [1] 6/10oath [3] oath [3] oath [3] oath [3] 7/22 9/23 12/6object [2] object [2] object [2] object [2] 3/19 4/2objectionobjectionobjectionobjection [1] [1] [1] [1] 15/15objectionsobjectionsobjectionsobjections [1] [1] [1] [1] 3/17obligatedobligatedobligatedobligated [1] [1] [1] [1] 10/23occurredoccurredoccurredoccurred [1] [1] [1] [1] 15/17off [1] off [1] off [1] off [1] 7/2offense [1] offense [1] offense [1] offense [1] 12/25Office [2] Office [2] Office [2] Office [2] 1/15 7/19official [2] official [2] official [2] official [2] 1/24 17/4okay [6] okay [6] okay [6] okay [6] 2/18 6/10 6/13 6/16 9/17 15/12one [2] one [2] one [2] one [2] 6/8 16/2ongoing [1]ongoing [1]ongoing [1]ongoing [1] 11/3only [7] only [7] only [7] only [7] 7/17 7/19

9/22 12/4 12/23 14/16 15/6open [2] open [2] open [2] open [2] 2/1 12/19opening [1]opening [1]opening [1]opening [1] 11/10oppositionoppositionoppositionopposition [1] [1] [1] [1] 10/14order [3] order [3] order [3] order [3] 6/23 11/1 11/16original [1] original [1] original [1] original [1] 4/11other [4] other [4] other [4] other [4] 12/18 12/21 13/2 16/1our [5] our [5] our [5] our [5] 2/9 2/11 2/12 4/17 14/20out [2] out [2] out [2] out [2] 2/8 12/5outside [1] outside [1] outside [1] outside [1] 15/24over [3] over [3] over [3] over [3] 13/4 13/5 15/15overboardoverboardoverboardoverboard [1] [1] [1] [1] 11/18

PPPPpage [1] page [1] page [1] page [1]

7/25page 64 [1]page 64 [1]page 64 [1]page 64 [1] 7/25pages [1] pages [1] pages [1] pages [1] 17/9parties [3] parties [3] parties [3] parties [3] 3/8 5/12 7/9parts [1] parts [1] parts [1] parts [1] 7/2people [3] people [3] people [3] people [3] 11/22 11/23 13/8perceivedperceivedperceivedperceived [1] [1] [1] [1] 15/20personallypersonallypersonallypersonally [3] [3] [3] [3] 8/18 8/19 8/21photo [1] photo [1] photo [1] photo [1] 8/15photographphotographphotographphotograph [5] [5] [5] [5] 8/13 8/17 8/24 9/3 9/18picture [4] picture [4] picture [4] picture [4] 8/3 8/8 9/6 9/11Plaintiff [2] Plaintiff [2] Plaintiff [2] Plaintiff [2] 1/6 17/7planningplanningplanningplanning [1] [1] [1] [1] 3/2point [2] point [2] point [2] point [2] 14/10 14/13

point's [1] point's [1] point's [1] point's [1] 13/15points [1] points [1] points [1] points [1] 13/20position [1]position [1]position [1]position [1] 13/23possible [1]possible [1]possible [1]possible [1] 15/5potentialpotentialpotentialpotential [1] [1] [1] [1] 4/9predictabilipredictabilipredictabilipredictability [1] ty [1] ty [1] ty [1] 15/13prejudiceprejudiceprejudiceprejudice [2] [2] [2] [2] 7/9 10/5preparationpreparationpreparationpreparation [2] [2] [2] [2] 4/11 11/16preparedpreparedpreparedprepared [6] [6] [6] [6] 3/8 3/12 3/14 5/3 5/4 5/16present [6] present [6] present [6] present [6] 4/18 5/7 5/8 5/9 5/23 17/6presentedpresentedpresentedpresented [3] [3] [3] [3] 11/24 12/24 13/14pressure [1]pressure [1]pressure [1]pressure [1] 11/13privacy [1] privacy [1] privacy [1] privacy [1]

12/25problem [1]problem [1]problem [1]problem [1] 6/12proceed [2]proceed [2]proceed [2]proceed [2] 5/11 12/9proceedingproceedingproceedingproceeding [1] [1] [1] [1] 10/25proceedingproceedingproceedingproceedings [3] s [3] s [3] s [3] 2/1 17/6 17/10ProfessionaProfessionaProfessionaProfessional [1] l [1] l [1] l [1] 17/2prosecutorprosecutorprosecutorprosecutor [1] [1] [1] [1] 2/12province [1]province [1]province [1]province [1] 14/22public [1] public [1] public [1] public [1] 11/14purpose [1]purpose [1]purpose [1]purpose [1] 13/7put [3] put [3] put [3] put [3] 3/3 11/13 12/4

QQQQquash [3] quash [3] quash [3] quash [3] 4/10 5/18 5/24quasi [1] quasi [1] quasi [1] quasi [1] 10/18QUESTIONQUESTIONQUESTIONQUESTION [8] [8] [8] [8] 8/6 8/11 8/16 9/1 9/5

Page 26: IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS ...kmov.images.worldnow.com/library/40ad3d45-7fb4-42fc-beb0...EDWARD DOWD Carey, Danis & Lowe DOWD BENNETT LLP 8235 Forsyth Blvd. #1100

QQQQQUESTION..QUESTION..QUESTION..QUESTION... [3] . [3] . [3] . [3] 9/10 9/14 9/17quick [1] quick [1] quick [1] quick [1] 7/4quite [1] quite [1] quite [1] quite [1] 11/13

RRRRre [1] re [1] re [1] re [1] 10/15re-file [1] re-file [1] re-file [1] re-file [1] 10/15ready [9] ready [9] ready [9] ready [9] 7/10 7/23 9/25 10/1 12/8 12/9 14/18 14/18 14/24really [2] really [2] really [2] really [2] 5/1 14/19rearrangedrearrangedrearrangedrearranged [1] [1] [1] [1] 14/2reason [3] reason [3] reason [3] reason [3] 9/20 11/25 14/19recess [1] recess [1] recess [1] recess [1] 16/7record [2] record [2] record [2] record [2] 3/4 12/6regard [1] regard [1] regard [1] regard [1] 3/6

regardingregardingregardingregarding [2] [2] [2] [2] 2/21 15/7regardlessregardlessregardlessregardless [1] [1] [1] [1] 15/22RegisteredRegisteredRegisteredRegistered [1] [1] [1] [1] 17/2relied [1] relied [1] relied [1] relied [1] 11/2removedremovedremovedremoved [1] [1] [1] [1] 2/14report [1] report [1] report [1] report [1] 15/2reported [1]reported [1]reported [1]reported [1] 17/6reporter [4]reporter [4]reporter [4]reporter [4] 1/24 17/3 17/3 17/4reports [1] reports [1] reports [1] reports [1] 7/19representrepresentrepresentrepresent [3] [3] [3] [3] 11/21 11/22 13/19reproductioreproductioreproductioreproduction [1] n [1] n [1] n [1] 17/10request [3] request [3] request [3] request [3] 6/5 6/22 15/14requestingrequestingrequestingrequesting [2] [2] [2] [2] 6/11 7/11resolutionresolutionresolutionresolution [1] [1] [1] [1] 7/4

resourcesresourcesresourcesresources [1] [1] [1] [1] 10/3respect [1] respect [1] respect [1] respect [1] 10/7respond [2]respond [2]respond [2]respond [2] 11/13 12/13respondedrespondedrespondedresponded [1] [1] [1] [1] 3/16respondingrespondingrespondingresponding [1] [1] [1] [1] 11/11responseresponseresponseresponse [2] [2] [2] [2] 4/25 12/2review [1] review [1] review [1] review [1] 10/24revisionsrevisionsrevisionsrevisions [1] [1] [1] [1] 10/15Rex [1] Rex [1] Rex [1] Rex [1] 1/2right [12] right [12] right [12] right [12] 2/24 3/19 3/22 4/2 4/3 4/21 4/24 6/1 6/9 10/11 12/12 13/4ROBERT [1] ROBERT [1] ROBERT [1] ROBERT [1] 1/14role [1] role [1] role [1] role [1] 4/23ROSENBLUROSENBLUROSENBLUROSENBLUM [2] M [2] M [2] M [2] 1/20 1/21RPR [2] RPR [2] RPR [2] RPR [2]

1/24 17/16Rule [1] Rule [1] Rule [1] Rule [1] 5/9rules [1] rules [1] rules [1] rules [1] 15/9ruling [1] ruling [1] ruling [1] ruling [1] 10/19

SSSSsaid [1] said [1] said [1] said [1] 14/8say [5] say [5] say [5] say [5] 2/22 3/25 11/21 14/11 14/18says [2] says [2] says [2] says [2] 15/3 15/8scheduleschedulescheduleschedule [2] [2] [2] [2] 3/1 14/2schedulingschedulingschedulingscheduling [3] [3] [3] [3] 6/23 11/1 11/16school [1] school [1] school [1] school [1] 13/24SchwartzSchwartzSchwartzSchwartz [1] [1] [1] [1] 1/21SCOTT [2] SCOTT [2] SCOTT [2] SCOTT [2] 1/20 13/18second [3] second [3] second [3] second [3] 1/25 6/20

7/8secure [1] secure [1] secure [1] secure [1] 12/24see [1] see [1] see [1] see [1] 11/25seek [1] seek [1] seek [1] seek [1] 12/5seen [3] seen [3] seen [3] seen [3] 7/1 8/3 8/7served [1] served [1] served [1] served [1] 4/9set [7] set [7] set [7] set [7] 2/8 2/10 3/10 4/11 5/6 15/15 15/21sets [1] sets [1] sets [1] sets [1] 11/2setting [9] setting [9] setting [9] setting [9] 6/5 11/14 13/13 13/21 15/14 15/18 15/19 16/1 16/2settings [1] settings [1] settings [1] settings [1] 14/11she [9] she [9] she [9] she [9] 13/22 13/23 14/2 14/8 15/3 15/4 15/8 15/8

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SSSSshe... [1] she... [1] she... [1] she... [1] 15/9short [2] short [2] short [2] short [2] 7/13 10/2shorten [2] shorten [2] shorten [2] shorten [2] 4/10 5/20shortenedshortenedshortenedshortened [2] [2] [2] [2] 3/14 4/14shorter [1] shorter [1] shorter [1] shorter [1] 10/3should [4] should [4] should [4] should [4] 5/7 12/9 14/9 15/8show [1] show [1] show [1] show [1] 14/17shows [1] shows [1] shows [1] shows [1] 7/22side [3] side [3] side [3] side [3] 4/1 10/5 13/2signed [1] signed [1] signed [1] signed [1] 7/18Simpson [3]Simpson [3]Simpson [3]Simpson [3] 13/16 13/19 14/6Simpson'sSimpson'sSimpson'sSimpson's [1] [1] [1] [1] 5/25single [1] single [1] single [1] single [1] 13/22sir [2] sir [2] sir [2] sir [2] 5/16 9/19

so [19] so [19] so [19] so [19] some [4] some [4] some [4] some [4] 7/15 10/15 10/18 11/15somethingsomethingsomethingsomething [1] [1] [1] [1] 15/10sometimesometimesometimesometime [1] [1] [1] [1] 2/5sorry [1] sorry [1] sorry [1] sorry [1] 6/20South [1] South [1] South [1] South [1] 1/21speak [1] speak [1] speak [1] speak [1] 5/5special [1] special [1] special [1] special [1] 2/12specific [2] specific [2] specific [2] specific [2] 12/17 13/7specificallyspecificallyspecificallyspecifically [1] [1] [1] [1] 6/3spoken [1] spoken [1] spoken [1] spoken [1] 4/12ST [7] ST [7] ST [7] ST [7] 1/1 1/16 1/19 1/19 1/22 1/25 17/5stability [1] stability [1] stability [1] stability [1] 15/13standingstandingstandingstanding [2] [2] [2] [2] 4/21 5/2start [1] start [1] start [1] start [1]

7/2state [19] state [19] state [19] state [19] State's [2] State's [2] State's [2] State's [2] 11/5 15/15statementstatementstatementstatement [1] [1] [1] [1] 11/10status [1] status [1] status [1] status [1] 5/7steps [1] steps [1] steps [1] steps [1] 15/2strategy [1]strategy [1]strategy [1]strategy [1] 10/17Street [1] Street [1] Street [1] Street [1] 1/15strong [1] strong [1] strong [1] strong [1] 10/22strongly [1]strongly [1]strongly [1]strongly [1] 10/8student [1] student [1] student [1] student [1] 13/21subpoenassubpoenassubpoenassubpoenas [3] [3] [3] [3] 4/10 5/6 5/19substantivesubstantivesubstantivesubstantive [1] [1] [1] [1] 13/13subterfugesubterfugesubterfugesubterfuge [1] [1] [1] [1] 14/17such [1] such [1] such [1] such [1] 9/9suggest [1] suggest [1] suggest [1] suggest [1] 5/12suggestingsuggestingsuggestingsuggesting [1] [1] [1] [1] 12/1summarysummarysummarysummary [[[[1111]]]] 10/19

sure [6] sure [6] sure [6] sure [6] 2/6 3/18 3/21 8/20 12/15 14/3

TTTTtaken [4] taken [4] taken [4] taken [4] 7/15 7/21 8/24 13/15takes [1] takes [1] takes [1] takes [1] 6/4taking [1] taking [1] taking [1] taking [1] 6/18talk [3] talk [3] talk [3] talk [3] 12/16 13/6 15/4talked [1] talked [1] talked [1] talked [1] 9/5talking [1] talking [1] talking [1] talking [1] 6/8talks [1] talks [1] talks [1] talks [1] 13/2task [3] task [3] task [3] task [3] 11/5 12/23 13/8tasked [1] tasked [1] tasked [1] tasked [1] 12/20tell [1] tell [1] tell [1] tell [1] 5/22testified [3]testified [3]testified [3]testified [3] 9/23 10/9 14/25

testify [1] testify [1] testify [1] testify [1] 9/25testimonytestimonytestimonytestimony [2] [2] [2] [2] 8/11 12/24than [1] than [1] than [1] than [1] 16/1Thank [9] Thank [9] Thank [9] Thank [9] 5/14 10/10 10/11 12/2 14/5 15/11 16/4 16/5 16/6Thanks [1] Thanks [1] Thanks [1] Thanks [1] 14/6that [89] that [89] that [89] that [89] that's [18] that's [18] that's [18] that's [18] their [10] their [10] their [10] their [10] 3/17 7/3 11/8 11/11 11/17 12/3 12/4 12/11 13/9 14/17then [4] then [4] then [4] then [4] 2/16 3/3 4/6 12/8there [11] there [11] there [11] there [11] 2/15 2/21 3/7 7/8 9/11 9/21

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TTTTthere... [5] there... [5] there... [5] there... [5] 10/5 10/21 13/11 14/18 15/16there's [2] there's [2] there's [2] there's [2] 3/5 15/10they [16] they [16] they [16] they [16] 4/25 5/1 7/12 7/23 9/24 9/25 9/25 11/19 11/21 12/7 13/3 13/3 13/24 14/18 14/23 14/24they're [3] they're [3] they're [3] they're [3] 11/9 12/1 14/18thing [1] thing [1] thing [1] thing [1] 3/20things [5] things [5] things [5] things [5] 7/22 12/18 14/8 15/2 15/16think [17] think [17] think [17] think [17] 2/23 3/14

4/2 4/3 4/12 4/14 5/1 6/25 8/4 11/7 11/14 11/19 11/19 11/23 13/5 13/10 14/1thinks [1] thinks [1] thinks [1] thinks [1] 11/17this [59] this [59] this [59] this [59] thoroughthoroughthoroughthorough [1] [1] [1] [1] 8/6those [5] those [5] those [5] those [5] 2/16 5/23 12/10 12/23 14/1three [2] three [2] three [2] three [2] 7/11 11/5through [1] through [1] through [1] through [1] 9/20throughoutthroughoutthroughoutthroughout [1] [1] [1] [1] 10/17throw [1] throw [1] throw [1] throw [1] 11/18time [9] time [9] time [9] time [9] 3/14 4/10 5/1 5/20 6/18 13/21 13/22

14/18 16/4Tisaby [8] Tisaby [8] Tisaby [8] Tisaby [8] 7/14 7/16 8/2 9/22 10/10 12/17 12/22 14/25today [12] today [12] today [12] today [12] 2/6 2/9 2/19 3/9 3/13 3/15 4/1 4/7 4/13 4/16 5/3 6/2told [3] told [3] told [3] told [3] 7/22 9/6 9/9towards [1] towards [1] towards [1] towards [1] 5/7TRANSCRIPTRANSCRIPTRANSCRIPTRANSCRIPT [1] T [1] T [1] T [1] 1/11transmissiotransmissiotransmissiotransmission [1] n [1] n [1] n [1] 9/2transmittedtransmittedtransmittedtransmitted [2] [2] [2] [2] 9/6 9/11triable [1] triable [1] triable [1] triable [1] 5/10trial [41] trial [41] trial [41] trial [41] trials [1] trials [1] trials [1] trials [1] 15/13true [1] true [1] true [1] true [1] 17/10

try [2] try [2] try [2] try [2] 10/2 10/18trying [4] trying [4] trying [4] trying [4] 4/10 8/23 9/2 15/5turn [1] turn [1] turn [1] turn [1] 13/5turned [1] turned [1] turned [1] turned [1] 13/4TWENTY [1]TWENTY [1]TWENTY [1]TWENTY [1] 1/25TWENTY-SETWENTY-SETWENTY-SETWENTY-SECOND [1] COND [1] COND [1] COND [1] 1/25two [2] two [2] two [2] two [2] 12/20 14/7

UUUUunaware [1]unaware [1]unaware [1]unaware [1] 8/12under [5] under [5] under [5] under [5] 7/22 9/23 12/6 14/19 15/9understandunderstandunderstandunderstand [4] [4] [4] [4] 2/14 4/5 11/8 11/18unnecessarunnecessarunnecessarunnecessary [1] y [1] y [1] y [1] 10/16until [2] until [2] until [2] until [2] 5/8 5/11

up [8] up [8] up [8] up [8] 2/6 5/21 6/4 6/14 7/10 7/18 10/5 13/20upon [1] upon [1] upon [1] upon [1] 14/2us [3] us [3] us [3] us [3] 2/7 6/13 7/22used [1] used [1] used [1] used [1] 10/4

VVVVversus [1] versus [1] versus [1] versus [1] 2/4very [5] very [5] very [5] very [5] 7/13 10/2 10/8 14/9 15/10victim [9] victim [9] victim [9] victim [9] 5/19 11/23 12/21 13/9 13/9 13/11 13/11 13/19 14/5victims [1] victims [1] victims [1] victims [1] 12/23virtually [1]virtually [1]virtually [1]virtually [1] 9/24

WWWWwait [1] wait [1] wait [1] wait [1] 4/13

Page 29: IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS ...kmov.images.worldnow.com/library/40ad3d45-7fb4-42fc-beb0...EDWARD DOWD Carey, Danis & Lowe DOWD BENNETT LLP 8235 Forsyth Blvd. #1100

WWWWwaive [9] waive [9] waive [9] waive [9] 2/24 3/1 3/4 3/17 3/22 4/4 4/15 4/21 4/24waiver [2] waiver [2] waiver [2] waiver [2] 2/22 3/13want [1] want [1] want [1] want [1] 13/16wanted [1] wanted [1] wanted [1] wanted [1] 5/21wants [1] wants [1] wants [1] wants [1] 5/9warrants [1]warrants [1]warrants [1]warrants [1] 11/15was [24] was [24] was [24] was [24] wasn't [1] wasn't [1] wasn't [1] wasn't [1] 15/3we [46] we [46] we [46] we [46] we'll [3] we'll [3] we'll [3] we'll [3] 5/15 13/4 16/2we're [11] we're [11] we're [11] we're [11] 3/2 3/12 3/14 4/10 5/3 6/11 6/21 12/8 14/18 14/21 15/6week [1] week [1] week [1] week [1] 7/15

weight [1] weight [1] weight [1] weight [1] 14/12well [6] well [6] well [6] well [6] 4/14 5/5 6/7 12/18 13/15 13/22went [2] went [2] went [2] went [2] 9/20 12/23were [4] were [4] were [4] were [4] 2/1 4/11 5/22 14/23west [2] west [2] west [2] west [2] 15/16 15/23what [13] what [13] what [13] what [13] 2/8 6/11 7/8 8/20 9/23 13/2 13/3 13/4 14/21 15/1 15/8 15/9 15/23what's [1] what's [1] what's [1] what's [1] 2/8whateverwhateverwhateverwhatever [3] [3] [3] [3] 2/25 3/2 5/8when [7] when [7] when [7] when [7] 5/16 6/4 7/21 12/16

13/2 13/5 13/20where [3] where [3] where [3] where [3] 2/8 2/8 13/24whether [3]whether [3]whether [3]whether [3] 2/13 4/19 4/24which [5] which [5] which [5] which [5] 5/10 9/24 10/1 11/1 15/3while [1] while [1] while [1] while [1] 11/8who [5] who [5] who [5] who [5] 2/6 8/16 9/2 12/4 14/20why [1] why [1] why [1] why [1] 11/18will [17] will [17] will [17] will [17] 2/15 2/16 2/25 2/25 4/19 5/4 5/8 6/25 7/4 7/9 7/10 10/1 10/2 13/23 13/24 15/18 16/7withheld [1]withheld [1]withheld [1]withheld [1] 15/10without [3] without [3] without [3] without [3]

4/9 10/20 11/9witness [2] witness [2] witness [2] witness [2] 5/20 9/5witnesseswitnesseswitnesseswitnesses [4] [4] [4] [4] 4/9 7/12 12/21 12/23work [1] work [1] work [1] work [1] 15/5works [1] works [1] works [1] works [1] 14/3would [11] would [11] would [11] would [11] 2/9 2/25 3/1 4/5 5/12 11/1 11/19 11/21 13/20 14/1 14/4

YYYYyears [1] years [1] years [1] years [1] 11/5Yes [4] Yes [4] Yes [4] Yes [4] 3/7 5/16 6/15 9/14yesterdayyesterdayyesterdayyesterday [2] [2] [2] [2] 2/5 4/9you [33] you [33] you [33] you [33] you're [3] you're [3] you're [3] you're [3] 6/8 8/11 10/13

your [13] your [13] your [13] your [13] 3/7 3/21 4/3 4/7 5/17 8/11 10/13 12/13 12/16 13/15 13/18 16/4 16/6