Direct Examination Flashcards
Would you please state your name for the record?
Detective Nichols
what police department do you work for?
I am a homicide detective for the Midlands State Police Department
In your years of police work, what kind of training have you received?
National Highway Transportation Safety Administration (NHTSA) training
Evidence preservation and collection
Witness interrogation
Undercover officer safety and confidential informant handling
Computer and machine based data collection and analysis
Did anything unusual happen the night of July 16th at around 11PM?
Yes, I was working that night. I responded to an incident call in the Jaywood Building condos at about 11:10 in Downtown Midlands City to investigate a report of a potential homicide
What happened when you arrived?
I briefly spoke with Ofc. Sandlin and Ofc. Stanfield, who pointed out the victim and informed me that the victim was found unconscious
Who was this victim identified as?
A woman named Kerry Bell Leon
When you interviewed Kerry Bell-Leon, were there any visible injuries?
Yes. She had a bump above her right eye (pg 3, line 13; line 22) She also had bruises on her throat
What did Kerry Bell-Leon tell you had happened to her that night?
once she regained consciousness, she immediately accused Dylan Hendricks of attacking her in her condo in the jaywood building
What did you do next detective
I began my investigation at Kerry Bell Leon’s condo
Did you find any evidence in the condo?
Well there were no signs that anything was stolen. But I did find an orange extension cord on the floor in the living room
Would you recognize this extension cord if I showed you it today?
Yes
I am now showing you what has been previously marked as exhibit 4 for identification purpose, do you recognize it?
Yes, its the extension cord I found at the bell leon residence
How do you recognize it?
It is in the same condition as when I collected the cord at the bell leon residence. I impounded it into evidence and took it to the evidence locker at the police station, where it has been kept until today
What is the significance of the extension cord to the case?
I saw marks and bruises on Kerry’s neck upon my investigation. Based on my training and expertise, I suspected that some form of strangulation occurred, but could not conclude what had caused it. Upon investigating the condo itself.
Did you find any other evidence other than this extension cord?
Yes, I also found a key on the living room floor
What is the significance of this key?
Well, I had been informed that the crime involved breaking and entering. So when I found that key, I wanted to see if maybe that was the key the intruder had used
Would you recognize this key if I showed it to you today?
I believe so yes
I am now showing you what has been marked as exhibit 6 for identification, Do you recognize it?
Yes, it’s the key I found at the bell leon’s resident
Is this an accurate representation of that key?
Yes
How do you recognize it?
It appears to be in the same condition as when I discovered it at the Bell-leon residence. Like the chord, I impounded it into evidence and took it to the evidence locker at the police station, where it has been kept until today
Now detective, what did you do with that key?
I tried it on the doors and it opened the front and back condominium doors, as well as the door at bottom of the fire escape
Would you be able to locate those doors for the court today on a floor plan of the Bell Leon residence?
Yes I would
I am now showing you what has been marked as exhibit 10 for identification, Do you recognize it?
Yes, it’s the bell leon’s condo floor plan
How do you recognize it?
It has the same detailed floor plan that i investigated during the night of july 16th
Does this accurately represent the bell leon’s condo?
Yes
Now, can you locate those on the floor plan for us?
Yes, here is the front door. And here is the back door. The back door makes a straight path towards the fire escape.
Where does the fire escape lead to?
To a locked door under a lit awning, which is opened by the same key i found in Kerry’s condo
When you first arrived at the scene, did you investigate the entrances?
Yes, and none of them showed any evident forced entry. However, the door to the utility closet and the back door to the condo were wide open
Did you talk to any other witnesses after you were done in the apartment?
Yes. A street musician named Charlie Waters. He saw a person leaving the jaywood building and then throw something in the dumpster.
Did you search the dumpster?
Yes, and I found a Baker revolver loaded with a single bullet
Would you recognize this gun if I showed it to you today?
Yes I would
I am now showing you what has been marked as exhibit 5 for identification, Do you recognize it?
Yes, it’s the baker revolver i found in the dumpster
How do you recognize it?
It is silver and has a black handle. It appears to be in the same condition as when I impounded it and took it to the evidence locker at the police station, like the key and extension cord.
Does this accurately represent the revolver you found?
Yes
Did Mr. Waters provide any other information regarding this crime?
Yes, he turned over a receipt for a firing range that ended up in his music case and it included Dylan Hendrick’s name
Would you recognize this receipt today?
Yes
I am now showing you what has been previously marked as exhibit 31 for identification purposes only, do you recognize it?
Yes
What is it?
It is an authentic receipt belonging to Dylan Hendricks from De Rosa firing range
How do you know this is the authentic receipt from De Rosa’s firing range?
The manager at the range had identified the receipt to the police following the night of the crime
Can you please read the date stated on the receipt?
The date was July 15, 2017, just one day before Kerry Bell Leon’s attack
Now after talking to Waters, did that conclude your investigation at the scene of the crime?
No. I then also arrested a suspect at the scene of the crime, Dylan Hendricks, based on the accounts of 3 witnesses, including the victim.
Following the night of july 16th, were you contacted by anyone else having information regarding the night of the crime?
Yes. One other person contacted me: Jaime Morrison. He gave me a receipt detailing the ride he gave Dylan the night Kerry was attacked
Would you recognize this receipt today?
Yes
I am now showing you what has been marked as exhibit 30 for identification, what is it?
Its the receipt Jamie provided me with
Is this a complete and accurate representation of that receipt?
Yes
Now, what does the receipt reveal about Dylan’s whereabouts the night of the crime?
That Jamie picked him up at 555 S. Johnson St. at 11:27 PM and then Dropped him off at Chuggies at 11:38 PM
Do you recognize either of these locations?
Yes. Chuggies is a bar right next to the crime scene, and 555 Johnson is Hendricks’ house.
Did you use this information to investigate Dylan further?
Yes. I performed 3 test drives from Ellis (where Dylan said he parked) to his house, around the same time of night he might have been driving, and found that it took between 11 and 15 minutes to make the drive.
Based off of your investigation, what time did you determine the crime to occur?
At 11 PM
Given the test drives you did and other facts learned during your investigation, did the defendant have enough time to drive home and be picked up at 11:27PM assuming he left the area of the Jaywood building around 11PM?
Given the timeline of the night and my experience, I believe Hendricks had enough time to drive home before being picked up at 11:27 by the uber
What further investigation did you do following July 16th?
at 2 AM the following day, I went to Dylan Hendricks’ house
Why did you go to the defendant’s house?
To search for more evidence that might link him to the attempted murder at the Bell Leon condo.
Did you find anything at Hendricks’ house?
Yes, I found a single damp Souper Soups t-shirt in his washing machine. I also searched his food truck, where I found disposable gloves that appeared to be washed
What color were the gloves?
Purple
Now did you ever interview Dylan himself?
Yes, on July 18th I held our first interview and our second on July 21st. Before the first interview, he voluntarily handed in his phone which was investigated
How did Dylan describe his relationship with the Bell-Leon’s?
He told me that he had been in a relationship with Carmen since February and that he loves her. They met on a dating app called tender and to his knowledge they are still together
Did Dylan visit the Bell-Leon residence often?
Yes, he said that he had been there dozens of times. In fact, after I showed him the floorplan in Exhibit 10, he confirmed that it was an accurate model.
You previously mentioned that he turned in his cell phone in prior to your interview, did his cell phone verify their relationship?
Yes, I found a series of Tender messages between him and Carmen, which he identified during our second interview.
Would you recognize these messages if I showed you them today
Yes
I am now showing you what has been previously marked as exhibit 19 for identification purpose, do you recognize it?
Yes, its one of the many messages between Carmen and Dylan
Is it a complete and accurate representation of a tender message between Carmen and Dylan
Yes
Will you please read the message from Dylan?
Of course. On June 20th Dylan wrote, “Been thinking about what you said. Don’t know if I can do it”
What day was this message sent?
On june 20th 2017
Would you recognize other tender messages if i showed you them today?
Yes
I am now showing you what was previously marked as exhibit 26 for identification purposes only, do you recognize it?
Yes, it is another one of the tender messages between carmen and dylan
Is it a complete and accurate representation of this message?
Yes
Now what does this message read:
Dylan simply sent, “I’m finished”
When was this message dated?
JULY 16th at 11:05 PM
And what day and time did you determine the crime to occur again?
July 16th at 11 PM
Now continuing on with your interrogation of Dylan Hendricks, Did you discuss the firing range receipt you received from Waters?
Yes. When I asked him about his trip to DeRosa’s firing range, he told me that he went there at Carmen’s request.
What kind of gun did Dylan use at the firing range?
The gun used at the range was a Baker 9mm Revolver, the same kind of gun I found in the dumpster Charlie Waters pointed me to.
