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Final Closing Arguments

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Willmott

  1. “People are far better than their very worst deed.” Each of you has to make your own decision. Does her life have value? You were asked if when you gave her 1st degree murder if you could still give her life. The state doesn’t require an execution for 1st degree.
  2. The burden is not beyond a reasonable doubt but beyond the preponderance of the evidence. We have to prove the mitigators are more true than not true.
  3. Each juror can choose a different mitigator. You don’t have to agree to find a reason to find value in her life, to find a reason to punish her with life in prison. Stand by your decision. You don’t have to explain it to anyone else.
  4. The state’s case is all about lies and manipulation. That somehow lying equals the death penalty. That’s not even a crime. Not even an aggravating factor.
  5. Mitigators are reasons to believe there’s something of value. Not excuses for what she did. You already convicted her for that. Are the mitigators substantial to call for life in prison? Mitigators are separate from the crime. They don’t have to be connected. Life in prison is appropriate.
  6. As an example- anyone under 30 I don’t believe should get the death penalty. If sufficient for you then that’s your vote.
  7. There was good and bad before (Travis). The trajectory of her life changed.
  8. Good things of value:

–       She was 27 when she killed Travis with no prior criminal record. We’re not talking about lying. She’s not like a criminal who commits a crime, 1, 2, 3 times. She has none. A reason to show mercy- life in prison instead of executed.

–       A good friend. People care about her. Darryl – 4 years he loved and trusted her with his son. Her friends were shocked – they didn’t expect this to happen, like Leslie Uty who said she was ‘sweet.’ Ryan Burns said that people enjoyed her, she got along well. What does it matter considering what she did to Travis? The state wants to paint her as a one-dimensional character. So it’s easier for you to execute. She’s not. She has made so many people happy in her life. The Freemans took trips with her and Travis. Enjoyed spending time with her. Had dinner and treated her like family, like a sister.

–       Her family has been here day in and day out. They are here for her now. She asked you to consider them.

–       Her value- she tried to improve her life; make the best of it. Gus said she was the utmost professional and worked hard. Darryl and her had a house together. If given the chance she will continue to improve. She’s already donated her hair 3 times. She doesn’t have to do that. She has goals. Teaching Spanish, reading and writing. She’s an amazing poet and artist and excellent writer. She wants to use these talents and dedicate them to domestic violence. This is for behind bars- not to get out.

        9.  She didn’t know she was capable of such violence. We need   to ask why? She could have been a famous artist, a saleswoman an attorney sitting next to me. What changed the trajectory of her life?

      10.  When she was a little girl her and Carl felt the love from her Mom. She treated her scrapes and read to her. They grew apart. Angela was born and things changed. They were no longer getting along. She couldn’t do anything right. She was grounded for inexplicable reasons. Everything changed for Jodi. She watched how her Dad treated her Mom- yelled, ridiculed. She learned that language. And loyalty- you stay no matter what.

      11. Her Psych. Testing-she had low self-esteem, almost no ego. Depression from when a teen. When she met Travis in 2006 she was vulnerable. She wanted a family; kids. Darryl didn’t. She thought he (Travis) was perfect. She was impressed by the executive banquet. Later when he wanted oral she gave it to him – didn’t want to lose him. He sends missionaries. She converts. She put him on a pedestal, she trusted him and loved him. She also saw the other side of him. Whether you believe the domestic violence – we know he was verbally abusive. Hateful one day and loving the next. ‘Corrupted carcass’, ‘worst thing that ever happened to me’ then ‘you’re beautiful inside and out.’ If he was sitting next to me the prosecutor would be using the same hateful words against him.

      12. Jodi lied- told herself a lie about her relationship with Travis. No person wants to be treated like that and called those names. It’s not an excuse to kill Travis. It is absolutely not and you have already convicted her. But abuse is a mitigating factor. Look at her solid relationship with Darryl- and they’re still friends. What changed the trajectory? Verbal abuse is not an excuse for what she did. She handled it the only way she knew how- she lied to herself, the detective, friends, the media, Travis’ family. It doesn’t diminish the abuse. She was once a happy, bubbly little girl, nose in a book. She will be haunted for what she did to Travis’ family, to Travis and to her family. 

13.  What’s so tragic is if either had sought help none of us may never have been here. The trajectory.

14.  Dr. Demarte said she had Bi-Polar Disorder. From a child her feelings weren’t validated. Cut bond with parents, was immature. Prone to violent outbursts- is that what happened? She can’t choose to have a personality disorder. Dr. Samuels also said she had one. Her BPD is not an excuse for what she did to Travis. But a reason substantial for life in prison. Another reason to be merciful.

15.  There’s so much mitigators in this case you can find to be merciful, to get life in prison and not execution. She has just one aggravating factor.

16. Strong mitigator is no criminal history. Jodi took Travis away but two wrongs don’t make a right. Her life still has value and you have a choice. (She quotes someone) ”…all life is worth saving and mercy is (best) attribute.” Her life is worth saving and despite her worst day she still has value. Sentence her to eternal life in prison.

 

Martinez:

  1. “To his family Travis will be forever young.” You’ve seen many photos of him from a child to older. But to his family he’ll be 30 for the rest of his life.
  2. They have tried to remember his life (pic of him smiling) with a twinkle in his eye. But they also told you they couldn’t forget what happened on June 4th, that he suffered immense physical pain, emotional distress and it was especially cruel. It hurt- was painful. And you shouldn’t forget what you saw in (pic of slit throat). An especially cruel crime. Take that back with you.
  3. The mitigators- you are not investigators. Find the facts. Don’t go out on a limb. You could say: ‘Well he’s dead so he’ll never suffer cancer- she saved him from that’- that’s an extreme example. You are not an advocate.
  4. The rest of her life in prison- on your questionairre it explained what it was – she’s eligible for release in 25 calendar years. Consider that.
  5. The 8 factors you looked at- an artist- she showed you pictures- Frank Sinatra, Elvis…so she has a skill, she’s entitled to get an easier path? All it is is a skill. Don’t give her preferential treatment. Not a mitigator.
  6. 27 years old. The age of majority is 18- people got to war at 18. She’s 9 years past that. A great relationship with Darryl. She enjoyed life. Had loving parents when growing up. Was employed, intelligent, had love affairs; a vast array of life experiences. Not a mitigator. If 16 0r 55 you could make the same argument. She had lived a full life. She’s 32 now but Travis is 30. Still. And the person responsible stood before you in court and asked you to look at that- only 27.
  7. Her pics of yesterdays, growing up. He has no more pics. What she will miss- nephew, Christmas with her photo, how’s that a mitigator when you look at the violence on Travis?
  8. No priors, never done this before. When people kill in this fashion they are arrested so they won’t do it again. Without laws there would be anarchy. She sat in the witness chair, took an oath, looked you in the eyes and lied to you. The gas cans- that’s perjury. Just because she’s not convicted doesn’t mean she hasn’t engaged in crime. Lied to the police- that’s a crime. They want you to just look past that. There is a criminal history. Not a mitigator.
  9. A good friend- friendship means you know the person better than most. Leslie said she never thought she would do something like this- but her friendship with Leslie was based on a lie. ‘When we have kids they will play together’? A friendship? When lying?
  10. Ryan – I guess it’s a friendship when you adjust someone, but he’s ‘full of crap.’ She lied to him. A good friend? Not a mitigator.
  11. Most of all this has come from her mouth. When the truth fails she’ll come up with a lie. A mitigator is proved by the preponderance of the evidence. The friend who couldn’t be here, judging from her credibility <Sidebar> The Womack issue raised by the defense- consider her credibility to assess id there is a good friend out there.
  12. Lacks support from family and then talks out the other side of her mouth. Well they’ve been here throughout the trial. The August peeping incident she called her father and he supported her. She spoke of her brother in glowing terms. It hasn’t been proven.
  13. Abuse and neglect as child and adult. When she was a child she liked to play the victim. Manipulative. There’s no records of any abuse. The 911 call with Bobby- no corroboration. There’s no abuse.
  14. Making the best of life/improving- she’s just going through life. Don’t most want to improve their life? She’s doing the bare minimum.
  15. None of these are mitigators. Jury instructions tell you what to do. If all find no mitigators it’s mandatory. A lack of connection may impact quality or strength so an artist? What does that have to do the crime? 27? How does that affect the crime? The horrific nature of the killing? No priors, though we know she has committed crimes- it doesn’t have anything to do with the crime. Same with friends and family. They don’t have a connection to the killing = no weight.
  16. Engage in analysis like the 1st (and 2nd) phase. Look at the facts and the law, then apply. The mitigators (if there are any) must be sufficiently substantial for leniency. Nothing presented here is a mitigating circumstance, but if 1 or 2 are possible mtitigators is it sufficient when you look at what this individual did? Travis will be forever 30. (Pic) That’s as old as he is going to get. No mitigators- even if you find some they’re not substantial for leniency. You have a duty. Do the right thing, the difficult thing. The only thing you can do is to return a verdict of death. Thank you.

Willmott

  1. A single question- Do you kill her? She has done something very bad and you have convicted her of that. The question is now do you kill her?
  2. Does she have value? Something you believe is worth saving her life? Living her life in prison? After 25 years parole- you are not supposed to consider that. The last time someone was paroled was eons <Objection, sustained>
  3. The lack of criminal history does matter. The entitlement because she’s an artist is false. Quite the opposite – she’s fighting for her life. Is it worth keeping her around to provide some type of value in this world? Criminal history- she doesn’t have any. We know she’s lied and manipulated- not a capital offense. You don’t sentence to death because she lied.
  4. The friendships were not based on lies. Several years with Darryl. Shows something happened; changed the trajectory, what she could have been.
  5. Family support- they’re here. Not when she needed them. Bi-Polar disorder- a lack of bonding. That little girl needed someone. A reason to be merciful and give life in prison.
  6. She plays the victim- one statement form someone who knew her from 1st– 5th grade.
  7. Doing the bare minimum- no value- what all of us do. She has something to give to this world.
  8. It’s an awful thing that she did and Travis’ family is suffering. But with your conviction- now they get some peace. It speaks to what she did- it is what it is. Before you is: do you kill her for the one horrible thing she did? Or can you see there’s a reason for her to live? She has value, and love from her family. She won’t be living with them or us but in prison. Can she contribute to this world? I’m asking you to find mercy. These mitigating factors are a reason. I’m asking you to give her life in prison.
  9. The judge gives final instructions. The jury goes into deliberations.

Juan Martinez’s Closing Argument- Parts 1-2-3 Together

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  1. This is a not a transcript I have paraphrased. It is much better to watch as the dripping sarcasm and tone of Mr. Martinez’s voice are important.
    1. Main themes: JA is a manipulator, a liar and nothing is her fault.
    2. This individual killed Travis and even after stabbing him over and over and slashing his throat and even after shooting him she will not let him rest in peace. Now she uses lies.
    3. She looked at the jurors and lied directly to them (re: gas cans).
    4. Relationships- She manipulates the facts. She moved in with Bobby (who cheated) and I was so good (sarcasm) and lived in a trailer (never mind I was skipping school). She hits the backspace button to read his private e-mails (not her fault there isn’t better security on the computers in the library) just as she did with Travis. She immediately went to Bobby and confronted him.
    5. She staged the scene for the police.
    6. She uses the media, craves the limelight. She autographed her manifesto for when famous. Said: ‘No jury will convict me.’ Now let’s bask in the light of the truth. See who she really is. A manipulator. She wants to play the victim even though there’s no abuse. Her own e-mail said she was destructive.
    7. After Bobby she got with Matt. It’s not her fault she’s a good worker, a waitress and someone comes in and tells her things (what she wants you to believe just like with the Travis’ story, it repeats because she’s lying. She’s trying to manipulate you.
    8. Derryl- not her fault he doesn’t want to marry or have more kids. How can it be her fault that people have free will? She looks for someone else. Those Mormon boys are a good catch- family values, successful and to Travis’s misfortune he was that boy. Wanted a Mormon, a child- perfect catch.
    9. He (Travis) was so sexually interested in her (not her fault the word ‘No’ is not in her lexicon). She was thinking ‘No’- at least that’s what she told you. Never communicated to him. Manipulates and pretends to be the victim. She can’t point the finger enough that Travis was a bad Mormon. Why not leave if he is so bad? You are Mormon too.

    10. She converted and had classes/met with missionaries. Not her fault they didn’t tell her (Law of Chastity). Travis is the bad guy- he said it was ok. In conceivable- she’s in the same situation. She wants your sympathy.

    11. This relationship was long distance. She couldn’t reach out and shot him in the face. She stalked him and showed up unannounced.

    12. They weren’t mutually exclusive so it’s ok to send texts to other women. But it’s ok after his Memorial to talk to a guy on the airplane and get a phone number. After all, the guy she was with up and died after she stabbed, slit throat and shot him.

    13. Travis did see her and have sex. They are trying to shock you. He does what others do behind closed doors and he doesn’t want people to know.

    14. On Feb. 14 she talks about her violent tendencies. One of the things she doesn’t talk about is receiving the package. It’s 4:30 – 5 pm (if mail is slow in Palm Desert) and there’s no mention of Spiderman underwear, no ‘Thank you’ for the chocolates, no such delivery. It can’t be verified- but she will make things up. She forgot about the e-mail. With the truth you don’t have to remember nothing.’ She can’t show the undies…she threw them away.

    15. When she came over in Feb. she was ‘happy.’ Why did she have to go through his computer and hit ‘back-space?’ It’s not her fault, it’s his fault he has contact with men and women and how dare he attempt to spend New Year’s Eve with someone- he should be in a hut somewhere.

    16. They are on vacation. She goes through his phone. One of the things she liked about him was he was social. There’s no names of anyone having sexual contact with him at that time. So that justified it, this person with borderline- so that’s it. We’re gonna break up (and she’s oozing through those fake tears on the stand) – yeah, I’m really hurt but let’s go on vacation anyway. She wants to curb his free will. But she’s not letting him go that easy. She moves close to him after the break-up. The stalking begins. Well, before she did the phone and the computer the first day they were officially boyfriend – girlfriend. There was stalking behavior from the beginning.

    17. She’s in Mesa. Why is she here? He’s so persuasive he talked her into it. She just can’t say ‘No.’ According to her he asked her. When here rather than dating and being social she begins to be more attentive, perhaps then she’ll be the only one.

    18. August 2007 she goes to his house unannounced. Peeps in the windows. By the light of the TV (now the light of truth) she sees them kissing. That is the end of the world. So what? He’s entitled to do it. The lights are off and he’s moved on. She could’ve left or never come in the first place. She’s so upset- sees the bra unhooked…so what is she? The Mormon conscious? She wants to manipulate your perception. Ruin his reputation. She comes back the next day (they are broken up) it’s ok to peep but she wants an explanation. What explanation did he ever owe her at that point?

    19. The first domestic violence (DV) event she didn’t write because she’s a nice person. Or the Law of Attraction. You lie. It’s ok to lie to your journal- you’re lying to yourself. She’s making it up. There’s no corroboration of any incident.

    20. Exploitive sex. She regaled us with these intimate details but she’s ‘uncomfortable?’ In the texts she’s the one requesting the sexual acts. ‘If you’re good…’ They were both in it. He never forced her to do anything. It’s an attempt to manipulate you.

    21. The physical violence ‘wasn’t so bad’ so she didn’t write. No one knows, sees, no police calls – had a similar situation with Bobby and after calling 911 they didn’t come out. Justification. No 911 calls. Because it never happened. Everything in this case points to it did not happen. No medical records.

    22. March 2008 she’s leaving and he hits her. In journal he ‘didn’t want me to leave’ and ‘gave me 3 tender kisses.’ Kissing is domestic violence. Then an apologist like Alyce LaViolette says: ’those words don’t mean what they say.’ Law of Attraction- it means just the opposite.

    23. Jan. 22- DV – no corroboration. Says in journal ‘nothing noteworthy has happened.’ You are being asked to make a leap.

    24. April 2008 another DV incident. She doesn’t tell anyone. She was very specific as to 4 of them. If telling the truth you don’t need to remember nothing. ’She told Dr. Karp there were 10, 15, 20 incidents of DV at that point for PTSD. What’s true? None of it is true. She’s manipulating the evidence. Karp said she had PTSD based on these DV acts. Not actually an attempt to manipulate- they are lies!

    25. She moves and it’s like a ray of sunshine for Travis. When she was here she came over unannounced, broke into accounts and hid behind his Christmas tree.

    26. May 10th– the sex tape. It’s very important to hear how she deals with him. He doesn’t know he’s being recorded. He can’t listen to it so what’s the benefit? Yes, he said some things, it was a private conversation between he and her even though they were broken up and she had stalked. He enjoys the sexual contact. She introduced him to certain things and opened his eyes sexually. What’s wrong is one is recording it. You can listen, draw your own conclusions. She kept it.

    27. May 19 2008 Travis i-m’s Regan that he’s ‘extremely afraid of Jodi because of her stalking behavior. He has less than a month to live. He knows what’s going on between them. Alyce said it wasn’t true. She can read minds from the past and know what Travis is thinking. No- Jodi is manipulating. It says: ‘Jodi-read this.’

    28. It was pre-meditated-who would know better than him? The peeping, tires, ring stolen, Christmas tree.

    29. May 26. Well, he’s mean to her. That’s correct- he’s extremely afraid when those names are called. ‘I’m nothing more than a dildo with a heartbeat’ that’s how she made him feel. He feels derogatory to himself. She manipulates with sex. May 26 he tells her. She apologizes to him and all is supposed to be forgiven. He’s had enough. “I don’t want your apology, I want you to understand what I think of you. He’s afraid and he does think she’s evil. And look at the next words- how prophetic: ‘You are the worst thing that has ever happened to me.’ Any doubt that’s the truth? Do we need to look at pictures of his slashed throat? His frog-like crumpled up state in the shower- bullet in the temple? Yes he’s angry over everything she’s done to him. Like she‘s manipulated you with the gas cans- she lied. Then he says ‘you are a sociopath’ that expresses his feelings. ‘You only cry for yourself- you saw her cry on the witness stand. She never expected to get caught!  ‘You have never cared about me…you have betrayed me.’ He believes she has done something horrific. He’s done with her. ‘You’re sick and you have scammed me.’ Are you going to allow her to scam you- buy the lies?

    30. May 28 (2 short days after) there’s a plan. No doubt she’s intelligent. She could buy a gun but in California there’s a waiting period. She indicated it. Knows her grandfather has guns. Begins the actual steps to Mesa to kill Travis. There’s no other explanation- she stole it, a very small gun ‘looks like a toy.’ The burglary was strange- they went through four rooms talking one thing from each room. Didn’t take money, left the large guns – rifle. Burglars don’t do that. The burglar is Jodi Arias sitting right there (points) and she needs a gun that can’t be traced. She began to take these steps after the text where he had had enough of her.

    31. Money is tight, she needs to use credit cards. People can’t link her to Arizona. She calls Derryl. He still has feelings for her. He gulped before talking about the call where she says she’s going to Mesa. Alyce has the same in her notes. She needed gas cans. Alyce thought it was supposed to be an unplanned visit.

    32. Utah- Ryan…no one will know she was in Arizona. Gets 2 gas cans from Derryl. Rents a car from 90 miles away. Says Priceline didn’t offer same deal in Yreka. Her bank statement says she used Budget. She used Priceline for the flight to Travis’ Memorial. She lied to you. People won’t recognize her in Redding. Won’t be recognized at an airport. Gets a nice little red car. Says she’s just driving ‘around town.’ Red gets the attention of police and we certainly don’t want that. She’s on a mission to kill somebody. Why would you take a gun if not to kill this guy?

    33. They have sex down in the office. She scratched the CD- he throws it. He gets mad at everything! Why take these CD’s? To show who- other than him? She planned it- it’s a good way/excuse to show up…’the only reason I dropped by…’ She left Yreka with the CD’s but forgot when attempting to manipulate from the stand. She had to take those CD’s from her house then put in her car then in rental.

    34. The red car- police will see her. She was stopped by police in West Jordan. Wants to hide she’s going to Mesa because she’s going to kill him. Nobody would be upset if she showed up in Mesa…not the Bishop, not her family. Only reason is to kill. She makes preparations…you gotta tip your hat to her. The white car- gonna drive around…a field of lies sprouted around her on the witness stand.

    35. Spends a night at Matts, then Derryls. Got gas cans. Gas cheaper in Utah, Arizona- that was one of her reasons…so why fill them in Pasadena? For taking the drive to Mesa with no evidence she was here.

    36. Takes a detour- with some afterthought. A meticulous approach to killing. Buys a gas can in Walmart. Admits it. $12.96…I guess that’s the price of pre-meditation today. She is very specific: “I took it back to the same store that day.” JM: “Would it surprise you there’s no record of a return?” JA: “Yes it would, I got money back.” Why did she you tell you that? It’s pre-meditated…going to Mesa with a gun and knife. Knives are not in the bathroom.

    37. She doesn’t want to be recognized. (He puts up pic of her with dog, her hair has blond streaks). You don’t need anybody to tell you her hair color believe your eyes. She’s pre-meditating the murder. The state doesn’t even need to prove a whole plan like this, just that she thought about it. Now she can freely drive through Mesa.

    38. ‘Mr. Alexander guilted me into coming.’ Not her fault. She told him she was going to Utah. Problem is her word. Do we really know what he told her on that call? Or did she call to see who’s there and what he’s doing? Did he even know she was coming? Are you gonna take her word- she has no problem telling lies. ‘Yeah I was fakin’ it’…Squealing like a cat…’because I need 2 hands.’

    39. She lies outside the courtroom and on the witness stand.  She looked each one of you in the eyes and lied to you. Gas cans, Priceline, the finger- he kicked me (but no medical).  Cut at Casa Ramos or Margaritaville on a metal edge or a glass, or June 4th at Travis’ on a glass. What story are you gonna believe?

    40. Something bizarre and coincidental – a hoard of skateboarders that carry screwdrivers (or you’re not allowed in the club). Get a Strawberry Frappe and things will happen to your plate. ‘I was pulling put and saw something flat on the ground. What would motivate you to go pick it up if you’re concerned with safety and you don’t know what it is? She didn’t even look at the back plate. Then it was a rectangle. No suspicion it’s for your car- why get outside of car and go back? When you’re lying – that’s when you do that. She didn’t compare the numbers, she takes it so now you’re a thief. In Utah one is upside down. So she can’t be identified. Can’t see because I need glasses, picks it up with bugs on it…thought it was mine. Who does that? No one does that! Because she got stopped and has to explain, so she made up a story.

    41. Fills cans in Pasadena to get enough gas to get through Arizona. She said she stopped for gas. There is no evidence of it. She turned off the phone so she can’t be traced. Lost the charger…bought one at a store (that’s what she told Ryan) when cleaning up (from killing Travis) she found the charger under the seat. There is no electronic or physical  trail of her being here. She knows she was coming to kill him. No need to stop the phone, she loves the phone. Has a white car, gun and a knife.

    42. She shows up to see him. She admitted she lied like that’s good. She knows the code 0187. She didn’t knock on the front door or peep in the back window. There’s no indication he came to the door.  It’s 4 am. Remember she said ‘I came in and stood by the door and watched him for 30-45 seconds.’ Who does that? Some stalker- unannounced- to surprise. The dog barks. ‘Hello.’ Brings purse in- big enough for gun and knife. They go to sleep. No sex? The sex fiend? ‘I was tired.’ She said no and he abided. They slept. The next day they have sex. Dr. Samuels says the photos were taken when she was straddling him. She tells him Travis had pictures of all these breasts on his computer.

    43. He didn’t go to Yreka, she drove there. The camera- Thank God for the camera! Religious overtones. It’s all about him nothing about her. About the Mormon faith- she wants to manipulate you. He’s holding himself out as a virgin. With Deanna they transgressed and went to the Bishop and never did it again. The willing partner is right here…1 hand or 2 hands…she enjoyed it. (Shows pic of her naked on bed) Her face- can you tell by her grimacing face if that’s a bad face? The psych’s said that. It’s all about Travis. She never wanted to do it- it was all him. She was enjoying it so stop pointing a finger at him! Being a Mormon isn’t being a human? The finger points at both. That’s not what this case is about. Travis adopted what she provided (KY) what she introduced.

    44. Shower pics- she says Travis wanted to show off his body.  She told Detective Flores that he really didn’t want to, he was reluctant. She told him she loved the way he shaved- old fashioned. She got him into the shower- it was more her idea than his. Think back to Derryl- he was asked if she ever took photos of him and he said only once, ‘I didn’t want them, I was in the shower.’ She takes photos…sexy…ill will there. Armed with both the knife and gun at that point. It’s ‘Calvin Klein’ the water dripping…it’s bucolic. That’s not what’s going on.

    45. The rope. 20’ long tied to the bed. Depends on who whether tied at wrists or ankles and wrists. She’s making it up to justify the knife there. Why ankles? Then wrists and ankles? She changes positions- she has a lot to remember. There’s NO ROPE! She would’ve had to move to clean up the bedroom, wet with water and blood and go into bedroom and leave a trail. Nothing’s there.

    46. The last photo of Travis (seated in shower) while still living. Quite a legacy. Defenseless- no gun, no knife. No dignity either. If anybody’s defenseless it isn’t Jodi Arias. His killer standing there dressed with a camera. Part of this story of hers is this is an accidental photo but look at the acuity/sharpness. She held camera firmly and pushed the button. She has him in that position, she can approach him. It’s her with the man she just had sex with and planned to kill May 28. Although pre-meditation requires thinking, not a plan, not days. It’s cold, without feeling pre-meditation, intimate with and attacks. Shot to head? Forensics say otherwise.

    47. She lied to the police, the experts and here. Now we believe her with this one aspect? The cuts (knife) were in front, defensive wounds. He was alive. A knife wound to the heart, he’s not dying immediately, blood’s coming from his mouth. In a sense she’s already killed him. We know he gets up because throughout the bathroom everywhere there’s blood- that equals movement. Not ‘flopping if the fish’ but purposeful movement to save his life. As this time goes by there’s pre-meditation. After the first stab wounds he ambulates (she didn’t carry him to the sink) he goes there by himself. (Photo of the blood on the sink). The sink with his blood after he’s been stabbed. There’s patterns on this photo, injuries to the hands, more on the left…the smudge. Slight injury to right hand. He’s still alive but he’s still bleeding. There’s drops by gravity. Blood in his mouth. He’s stabbed in the back while there (pics) and the back of the head as he stands at the sink. Took time…he stood there. The defendant was there with the knife stabbing him. The mirror has blood spatter. Force was applied to his head (pic) when he was standing there- spatter on the mirror. He’s not dead. Still standing there. She came to visit him. (Pic) Blood transfer…the item with blood was Mr. Alexander. It’s a rainbow. Ironic, no good luck at the end of that rainbow.

    48. He’s stumbling with somebody after him. He’s trying to get away from her. (Juan sees JA crying) Oh, she may cry now on instructions sympathy is not to be considered. Blood on the other wall, more at the bottom. She chases him down, that’s what she did. He’s still alive. How many stab wounds? Do we need to count? One to the chest will kill him. The back of the head, his back, accelerating his departure from earth. The end of his rainbow. That’s what she does (pic) slits his throat from ear to ear. He got there by his own movements as he tried to get away from her. He collapses. She goes for the throat. And you want to believe she doesn’t remember now? Why is she so directed if it’s just heat of passion? You wouldn’t have a directed hit to kill it would be all over the place. Indication of thinking. I caught him and now (pic). This was a well-orchestrated killing and it took time. People think…now stabbed, he tried to get away, at the sink, the mirror is reflective of what’s behind him. He’s seeing her stabbing him. She’s not done with him yet.

    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.

Juan Martinez Closing Argument-Part 2

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  1.  (31) Money is tight, she needs to use credit cards. People can’t link her to Arizona. She calls Derryl. He still has feelings for her. He gulped before talking about the call where she says she’s going to Mesa. Alyce has the same in her notes. She needed gas cans. Alyce thought it was supposed to be an unplanned visit.
  2. Utah- Ryan…no one will know she was in Arizona. Gets 2 gas cans from Derryl. Rents a car from 90 miles away. Says Priceline didn’t offer same deal in Yreka. Her bank statement says she used Budget. She used Priceline for the flight to Travis’ Memorial. She lied to you. People won’t recognize her in Redding. Won’t be recognized at an airport. Gets a nice little red car. Says she’s just driving ‘around town.’ Red gets the attention of police and we certainly don’t want that. She’s on a mission to kill somebody. Why would you take a gun if not to kill this guy?
  3. They have sex down in the office. She scratched the CD- he throws it. He gets mad at everything! Why take these CD’s? To show who- other than him? She planned it- it’s a good way/excuse to show up…’the only reason I dropped by…’ She left Yreka with the CD’s but forgot when attempting to manipulate from the stand. She had to take those CD’s from her house then put in her car then in rental.
  4. The red car- police will see her. She was stopped by police in West Jordan. Wants to hide she’s going to Mesa because she’s going to kill him. Nobody would be upset if she showed up in Mesa…not the Bishop, not her family. Only reason is to kill. She makes preparations…you gotta tip your hat to her. The white car- gonna drive around…a field of lies sprouted around her on the witness stand.
  5. Spends a night at Matts, then Derryls. Got gas cans. Gas cheaper in Utah, Arizona- that was one of her reasons…so why fill them in Pasadena? For taking the drive to Mesa with no evidence she was here.
  6. Takes a detour- with some afterthought. A meticulous approach to killing. Buys a gas can in Walmart. Admits it. $12.96…I guess that’s the price of pre-meditation today. She is very specific: “I took it back to the same store that day.” JM: “Would it surprise you there’s no record of a return?” JA: “Yes it would, I got money back.” Why did she you tell you that? It’s pre-meditated…going to Mesa with a gun and knife. Knives are not in the bathroom.
  7. She doesn’t want to be recognized. (He puts up pic of her with dog, her hair has blond streaks). You don’t need anybody to tell you her hair color believe your eyes. She’s pre-meditating the murder. The state doesn’t even need to prove a whole plan like this, just that she thought about it. Now she can freely drive through Mesa.
  8. ‘Mr. Alexander guilted me into coming.’ Not her fault. She told him she was going to Utah. Problem is her word. Do we really know what he told her on that call? Or did she call to see who’s there and what he’s doing? Did he even know she was coming? Are you gonna take her word- she has no problem telling lies. ‘Yeah I was fakin’ it’…Squealing like a cat…’because I need 2 hands.’
  9. She lies outside the courtroom and on the witness stand.  She looked each one of you in the eyes and lied to you. Gas cans, Priceline, the finger- he kicked me (but no medical).  Cut at Casa Ramos or Margaritaville on a metal edge or a glass, or June 4th at Travis’ on a glass. What story are you gonna believe?

10. Something bizarre and coincidental – a hoard of skateboarders that carry screwdrivers (or you’re not allowed in the club). Get a Strawberry Frappe and things will happen to your plate. ‘I was pulling put and saw something flat on the ground. What would motivate you to go pick it up if you’re concerned with safety and you don’t know what it is? She didn’t even look at the back plate. Then it was a rectangle. No suspicion it’s for your car- why get outside of car and go back? When you’re lying – that’s when you do that. She didn’t compare the numbers, she takes it so now you’re a thief. In Utah one is upside down. So she can’t be identified. Can’t see because I need glasses, picks it up with bugs on it…thought it was mine. Who does that? No one does that! Because she got stopped and has to explain, so she made up a story.

11. Fills cans in Pasadena to get enough gas to get through Arizona. She said she stopped for gas. There is no evidence of it. She turned off the phone so she can’t be traced. Lost the charger…bought one at a store (that’s what she told Ryan) when cleaning up (from killing Travis) she found the charger under the seat. There is no electronic or physical  trail of her being here. She knows she was coming to kill him. No need to stop the phone, she loves the phone. Has a white car, gun and a knife.

12. She shows up to see him. She admitted she lied like that’s good. She knows the code 0187. She didn’t knock on the front door or peep in the back window. There’s no indication he came to the door.  It’s 4 am. Remember she said ‘I came in and stood by the door and watched him for 30-45 seconds.’ Who does that? Some stalker- unannounced- to surprise. The dog barks. ‘Hello.’ Brings purse in- big enough for gun and knife. They go to sleep. No sex? The sex fiend? ‘I was tired.’ She said no and he abided. They slept. The next day they have sex. Dr. Samuels says the photos were taken when she was straddling him. She tells him Travis had pictures of all these breasts on his computer.

13. He didn’t go to Yreka, she drove there. The camera- Thank God for the camera! Religious overtones. It’s all about him nothing about her. About the Mormon faith- she wants to manipulate you. He’s holding himself out as a virgin. With Deanna they transgressed and went to the Bishop and never did it again. The willing partner is right here…1 hand or 2 hands…she enjoyed it. (Shows pic of her naked on bed) Her face- can you tell by her grimacing face if that’s a bad face? The psych’s said that. It’s all about Travis. She never wanted to do it- it was all him. She was enjoying it so stop pointing a finger at him! Being a Mormon isn’t being a human? The finger points at both. That’s not what this case is about. Travis adopted what she provided (KY) what she introduced.

14. Shower pics- she says Travis wanted to show off his body.  She told Detective Flores that he really didn’t want to, he was reluctant. She told him she loved the way he shaved- old fashioned. She got him into the shower- it was more her idea than his. Think back to Derryl- he was asked if she ever took photos of him and he said only once, ‘I didn’t want them, I was in the shower.’ She takes photos…sexy…ill will there. Armed with both the knife and gun at that point. It’s ‘Calvin Klein’ the water dripping…it’s bucolic. That’s not what’s going on.

15. The rope. 20’ long tied to the bed. Depends on who whether tied at wrists or ankles and wrists. She’s making it up to justify the knife there. Why ankles? Then wrists and ankles? She changes positions- she has a lot to remember. There’s NO ROPE! She would’ve had to move to clean up the bedroom, wet with water and blood and go into bedroom and leave a trail. Nothing’s there.

16. The last photo of Travis (seated in shower) while still living. Quite a legacy. Defenseless- no gun, no knife. No dignity either. If anybody’s defenseless it isn’t Jodi Arias. His killer standing there dressed with a camera. Part of this story of hers is this is an accidental photo but look at the acuity/sharpness. She held camera firmly and pushed the button. She has him in that position, she can approach him. It’s her with the man she just had sex with and planned to kill May 28. Although pre-meditation requires thinking, not a plan, not days. It’s cold, without feeling pre-meditation, intimate with and attacks. Shot to head? Forensics say otherwise.

17. She lied to the police, the experts and here. Now we believe her with this one aspect? The cuts (knife) were in front, defensive wounds. He was alive. A knife wound to the heart, he’s not dying immediately, blood’s coming from his mouth. In a sense she’s already killed him. We know he gets up because throughout the bathroom everywhere there’s blood- that equals movement. Not ‘flopping if the fish’ but purposeful movement to save his life. As this time goes by there’s pre-meditation. After the first stab wounds he ambulates (she didn’t carry him to the sink) he goes there by himself. (Photo of the blood on the sink). The sink with his blood after he’s been stabbed. There’s patterns on this photo, injuries to the hands, more on the left…the smudge. Slight injury to right hand. He’s still alive but he’s still bleeding. There’s drops by gravity. Blood in his mouth. He’s stabbed in the back while there (pics) and the back of the head as he stands at the sink. Took time…he stood there. The defendant was there with the knife stabbing him. The mirror has blood spatter. Force was applied to his head (pic) when he was standing there- spatter on the mirror. He’s not dead. Still standing there. She came to visit him. (Pic) Blood transfer…the item with blood was Mr. Alexander. It’s a rainbow. Ironic, no good luck at the end of that rainbow.

18. He’s stumbling with somebody after him. He’s trying to get away from her. (Juan sees JA crying) Oh, she may cry now on instructions sympathy is not to be considered. Blood on the other wall, more at the bottom. She chases him down, that’s what she did. He’s still alive. How many stab wounds? Do we need to count? One to the chest will kill him. The back of the head, his back, accelerating his departure from earth. The end of his rainbow. That’s what she does (pic) slits his throat from ear to ear. He got there by his own movements as he tried to get away from her. He collapses. She goes for the throat. And you want to believe she doesn’t remember now? Why is she so directed if it’s just heat of passion? You wouldn’t have a directed hit to kill it would h=be all over the place. Indication of thinking. I caught him and now (pic0. This was a well orchestrated killing and it took time. People think…now stabbed, he tried to get away, at the sink, the mirror is reflective of what’s behind him. He’s seeing her stabbing him. She’s not done with him yet.