Juan Marinez- closing part 3

  1. The shot took place near the sink. The knife wounds had to be first. No blood in the wound track. The heart wasn’t beating.
  2. More direct indicators (pic of end of hall with lots of footprints in blood). Looks like a wildebeast migration. How many times was she stomping around that? But there’s nothing in the bedroom. She’s cognizant. It would have been all over the bedroom. She begins to drag him. An attempt to clean up. A head shot, no blood, heart not pumping, he is dead. The casing from the 25 caliber gun from the staged burglary falls on top of blood. Dragging him, pulling him along, head exposed, casing expelled onto blood already there. So she’s killed him three times over. Is that enough pre-meditation? A very directed attack.
  3. The clean up. An interesting thing- the camera-she deletes photos, looks at photos. Assume the sex photos were already deleted. 162 inadvertent photos deleted after death (*I think I got that wrong…seems extreme!). During the attack he couldn’t care less about the camera. She carried it to that location.
  4. After she shoots him he’s put back in the shower. She’s still thinking: ‘I’ve got to get rid of the evidence.’ She deleted only certain pictures. She deleted only certain pics- not the ones of the dog, only the ones that hurt her . That’s directed behavior. Not dis-associative amnesia. Even San Francisco fog wouldn’t be so cloudy to account for this kind of behavior. Takes the camera from that area (and important- found in washer). There are NO STEPS  (in blood) leading from the bedroom to the washer. So she cleaned herself up. Items worn were taken off. Could have taken with her. The glass under the sink…she cleaned him up. Washed away any contact to show her being there. DNA all washed away. We don’t know if she turned on the shower. It isn’t because she loved him or wanted him to look good. He’s all crumpled up there. Destroyed the DNA.
  5. She’s focused (on cleaning) the bedroom area near the closet. Maybe she dropped the knife there. Her knife had been dripping blood. She carried it out. If she carried it to the dishwasher it had to have been cleaned up upstairs or wrapped in something so there would be no blood on the stairs. She cleaned it, maybe put in her purse. Thinking the whole thing through- staging the scene. The gun is taken, footwear was not found. Even towels- one was missing from the set- were in the washer and the cycle run. She used Clorox. The hands were clean when the Clorox was grabbed. She had already cleaned up so she wouldn’t get caught. It requires a space of time. And killing someone three times over requires time, regardless of what happened first. The heart, the throat, the gunshot- all fatal. A staged scene.
  6. Equally demonstrative of how she was thinking- license plate upside down (and stopped in Utah), packed up bloody clothes, she moved or took the camera, purse, gun. She was careful there was nothing anywhere but the bathroom.
  7. She got in the car and left Napoleon behind. She comes up with gas. If in a fog how do you remember you have gas cans? Not something she does on a regular basis. She calls Ryan and lies about where she’s been. He could potentially say she was with him. She’s still staging the scene. If she didn’t kill him why call and leave him a message? She’s thinking. The message- there’s no fog, she’s not mumbling on the recording. She tried several messages. Why? Why not call police? Why continue on her journey and try to make it seem normal? Because she had it planned. Ryan = alibi, and she has some romantic interest. Gosh, you can almost hear the violins, their first kiss, and a more passionate kiss.  ‘He’s full of crap’ –anyone who doesn’t agree with her. They were involved in a sexual fashion- he has nothing to gain from lying.
  8. Leslie- she talks an=bout her and Travis’s kids in the future. Staging the scene. Well she didn’t know he was dead.
  9. Injury to her hand was from the knife slipping.

10. Dan Freeman- calls when the body is found. She’s crying and calls the Bishop to see if he’s alive. Creating a wall, no one can say she has anything to do with this. Lies to everybody. Staging the scene. A staged defense by lies.

11. In court with you that would bring out the truth? She lies to you – the gas cans- absolutely without a shadow of a doubt she’s a liar. Walmart and Salt Lake gas receipts also go to pre-med. No direct evidence- circumstantial. Evidence she appeared to direct- seeing, hearing. (He goes into the story about circumstantial evidence being like seeing footprints in the sand and knowing someone’s been there). There are many footprints here: ‘The worst thing’, stolen gun, gas cans. Lying, license, phone off, photos, the rest of the evidence. She pre-meditated the murder. The car in Redding paid directly to Budget. The finger injury- she showed it to you. When asked: ‘Well you really didn’t get any injuries’ she said ‘Well I also got the injury to my finger, then turns and says: ‘No, no no, Casa Ramos/Margaritaville/house. Looked you in the face and lied to you.

12. The Law of Attraction, all the experts. ‘No jury will convict her.’ Elizabeth Barrett Browning: ‘How do I love thee? Let me count the lies.’

13. Alyce with her Master’s and large CV- is also a liar. Said she testified on behalf of a male 1-2 times. When pressed she had no name. then ‘Well I didn’t testify.’ Keynote speaker? Snow White? She wasn’t. Tried to justify her lies to you so they wouldn’t look so bad. ‘White lies are ok’ – if it’s to her benefit. She wasn’t truthful to you- looked at you and lied. She’s an advocate lying on behalf of Jodi Arias…44 hours with her, sending books, visiting her. It’s contaminated; foul –she lied to you.

14. Dr. Samuels scoring and rescoring- why rescore? There’s no reason to rescore 3 times unless you want to change the scores. The PDS test- there is no doubt she lied on #14.  Tiger, Bear, Gopher- it doesn’t matter the bottom line is it’s a lie. If you went to the Dr. and lied about your pain is the treatment any good? She suffered trauma…which trauma? The trauma of lying about the killing of Travis or the trauma of non-existent DV? Keep in mind the PTSD was based on many DV events, yet only 4 examples to you were never linked to PTSD. And Dr. Samuels said he probably should have re-administered.

15. A litany of lies. It’s important how it fits in. Told the police exaggerations, and then minimized. Dr. Geffner says exaggeration really isn’t a lie- IT IS, because it’s not telling the truth.

16. July 15th she’s arrested – over one month (since the killing). She had time to think about it. She had a story ready. She had such a strong will; she would not budge. Det: ‘You were there.’ JA: ‘NO, I wasn’t there.’ The palm print in blood- well of course it’s there. She’s adaptable and nimble when in a situation. She’s quick thinking- designed to manipulate. Says whatever fits the story. She denied everything and wanted to see photos to conform her story to what the police knew. She asks to see the photos. Previously when showing them she was crying- for your sympathy- as she sits there with a red nose, face down apparently crying. July 16 (next day) she changes it and makes herself the hero- pushing the woman down, the gun to her head. ‘I wish I could’ve stayed there; fought.’ Manipulating the story. Now, years later she ‘s truthful? Non-stop lies- to you, the health care professionals, police and media. On TV she’s such a calm person. She’s a chameleon and will adjust to the situation. Friends- she lies to them- Leslie re: ‘When we have kids…’ What could you possibly gain from that? She goes further (than needs to)with her lies.

17. Freeman calls her then she goes to the Bishop. She adds the extras to really sell it. All of those days testifying to you. Her defense based on lies. For self defense she added ornate lies about physical violence. Goes into great detail about it, banging his head against the wall and she’s the calm one. A very good liar. A sophisticated liar. The acts of DV. Look at the journals- no acts of DV. Any reason other than the Law of Attraction and Alyce? Any reason to doubt what’s written there? Friends never saw it, no police, no medical. Monumental lies made up as fits her defense.

18. Then created a lie- a hot button topic. How horrific is it to be accused falsely of being a pedophile? (Alyce…). On the computers there’s no images anywhere. How absolutely hateful that allegation is. But she went a little too far. The journal- no event. No texts. What human doesn’t go to the police? Phone calls back and forth that don’t match. The new approach to pedophilia- let’s jump in the sack. If true the journal wouldn’t have said ‘Nothing noteworthy happened. Nothing in computer, anywhere in the house. The only thing he has left: his reputation. A hateful allegation with nothing to support it. What goes through you’re head when you hear that the first time? (He’s a horrible person). The pinnacle.

19. (*At this point Martinez compares the evidence with the juror instructions).

20. Credibility of witness: directly relates to pedophile and DV. What testimony to accept/reject. This person here’s the epitome of a liar.  How can you know when she’s telling the truth about anything? 18 days on the stand wasted. See her in the light of day. She’ll look each and every one of you in the eye and lie to you. Would you go to a Dr. who lies to you?

21. She was there. She knows. Her memory is incredible. Unless it hurts her…then the fog rolls in.

22. Manner while testifying. She attempts to cry. Gets angry. Snaps out and tries to make the person asking the questions to blame. ‘You’re scrambling my brain.’ Not my fault I keep lying. It’s your fault. I can snap at you and smirk at you from the witness stand.

23. Motive to lie. This defendant has some motive. Alyce- for her reputation? With Ryan – why lie? He lives in Utah and only met her once. Amanda- why make things up? The only person with a motive is Jodi Arias. She wrote before the trial, wrote they didn’t happen, didn’t tell anyone.  Pedophile- nothing supports what she said.

24. In order for her to prevail it actually comes down to whether or not you believe her. All of the other evidence contradicts her. You’d have to turn your back on all the other evidence. 

25. Burden of proof. You must be ‘firmly convinced.’ Absolute certainty not required. You don’t need to overcome every doubt.  A procedure you indicated you would follow.

26. Inquiry. Once found guilty that’s the end of the inquiry. You don’t need to got any further.

27. There is only one charge in this case. Pre-me / felony murder. If you vote and it is split (like 9 for pre-med and 3 for felony) it is still 1st degree murder.

28. Cause of death is proven. Knew she would cause death- slit throat, stabbed heart and shot. Killed 3 ways. Intended to kill/knew she would kill- 3 different ways.

29. After knowing she would kill him she reflected on the decision. Regardless of the length of time it’s 1st degree. Stabbed in the shower than after minutes chasing him down and slashing his throat. Shot in head also indicates she wanted him to die. This was a long period of time for Mr. Alexander to go through. From the shower, stumbling, trying to get away.

30. If she didn’t bring the gun then you have a burglary. She didn’t have his permission. If somebody dies when taking a gun it’s 1st degree.

31. Heat of passion- look at the photos. Not the instant affect of passion. (Pic) Look like he’s ready to fight? And who’s telling you? A liar. The gun is with her.

32. On June 10th she called this police officer (indicates Flores) and said Travis never had a gun…just fists. No doubt that she said it. At that time she didn’t know how important that was going to be. She did bring it- burglary at Grandpa’s. Heat of passion? She called the police and lied. I’m now going to decide to believe her? That the father gave it to him? And told Alyce it happened in the closet. There’s no bullets or cleaning supplies. Nothing to indicate he had a gun.

33. The shelves. She stepped on the second shelf. They move down with pressure. You saw the photos. There’s no activity there. Everything, her statement says there’s no heat of passion- she brought the gun. Told the police he didn’t have a gun.

34. Her first story she was ‘afraid.’ Second story- she didn’t want to get into trouble. Her first call to police she wanted to know what police knew. She didn’t know her story yet. And you’d have to disregard the 25 caliber gun from Grampa’s.

35. The circuitous route through the closet. She could have ran out. He was naked and wouldn’t have chased her outside.

36. What are you going to do with an unloaded gun? Throw it at him? It’s an absolute lie.

37. The lesser included we won’t discuss.

38. Felony murder. Attempt/burglary. To remain unlawfully. We don’t know if she was invited in. And being stabbed to death- if I was being stabbed to death I would no longer want you in my house. The consent to come in isn’t there. Furthering this is she took his gun. Even if it wasn’t her fault she caused the death and took his gun. So murder 1st degree under both.

39. These instructions are mandatory.

40. Keep in mind she attempted to manipulate you. (pic) This is what she wants you to think (*I’m guessing a ‘happy’ pic). But the reality is this (pic of stabs to the back).

41. Symbolic of the whole case is the gas cans. She wants you to disregard it. She wants you to carry the cans for her. Don’t leave this courtroom filled with the stench of gasoline on your hands. She’s asking you to help her carry them out and take them with her. The state asks you to do your duty. Return a verdict of guilty. Thank You.

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