Sunday, December 7, 2008

The 13 Witness Subpoenas

On December 1, 2008, the Luzerne County District Attorneys Office filed 13 witness subpoenas for the upcoming trial... here's a list of the witnesses, along with why they're being called to testify:

1. Chris Hurd, or other designated Custodian of Records from DVInfo.net, whose current address is XXXX, is a necessary and material witness for the Commonwealth of Pennsylvania for the reason that the defendant, Harlow Cuadra, requested instructional material on January 29, 2007 on the camera HDR-FXI and all associated IP adresses for Harlow Cuadra for that date. The Commonwealth requests the custodian of records to provide IP connection log data, including member internet protocol addresses.

Additional Directives: Please come prepared to testify to postings to your website in January through March 2007 by HARLOW CUADRA. Please bring hard copies or CD's of all Harlow Cuadra communications including IP Addresses.

2. David Michaels, AKA David Mitchell, whose current address is XXXX, is a necessary and material witness for the Commonwealth of Pennsylvania for the reason that the Defendants and David Michaels, AKA David Mitchell, discussed a fake alibi for the time frame the crimes occured.

3. Michael Rozyla, or other designated Custodian of Records from VERIZON WIRELESS, whose current address is XXXX, is a necessary and material witness for the State of Pennsylvania for the reason that the Commonwealth asserts that telephone number, 570-579-4437, which is registered with Verizon Wireless, was used by “Danny Moilin”, the fictitious identity created by Harlow Cuadra in order to contact that victim. The Commonwealth further alleges this phone number registered calls to the victim at times when “Danny Moilin”, aka Harlow Cuadra, was scheduled to either call or receive calls from the victim. The Commonwealth alleges Harlow Cuadra, aka “Danny Moilin”, and Joseph Kerekes killed Bryan Kocis on January 27, 2007 at the time of an arranged meeting between “Danny Moilin” and Bryan Kocis. The Commonwealth requests all records for the phone number 570-579-4437 from January 21, 2007 to January 26, 2007. A technician from Verizon Wireless is also a necessary and material witness for the Commonwealth of Pennsylvania for the purpose of testifying to cell tower location, including the latitude and longitude for each tower location, as well as the radius of cell tower coverage for phone number 570-579-4437. The initial phone call from 570-579-4437 was placed on January 22, 2007 and was relayed from a cellular tower on Bells Road, Virginia Beach, Va.. This cellular tower is located several hundred yards form the residents of the defendants, Harlow Cuadra and Joseph Kerekes. The final call from said phone number was placed on January 25, 2007 and was relayed from a cellular tower located on Country Club Road, Dallas, Pa.. This cellular tower is located several hundred yards from the victim’s residence. The Commonwealth further requests the identification and address of cellular towers, cell site locations, related to the use of the telephones with the assigned phone numbers 757-717-0233, 757-567-0055, and 757-235-0805 for the period January 23, 2007 to January 25, 2007, specifically the following towers:

Pittston_IOS 114 41.361471-75.978111 397 Country Club Rd., Dallas, PA
Pittston_IOS 41.279275-75.821511 100 Cemetary Road, Wilkes-Barre, PA
Pittston_IOS 121 41.248158-75.836 111 East End Blvd., Wilkes-Bare, PA
Richmond 528 38.100075-77.519217
Richmond 385 37.899692-77.466219 26389 Jefferson Davis Highway
Richmond 410 37.481357-76.937944 5750 Pleasant Rd., Walker, VA

and for subscriber information, billing information, call detail records from January 23, 2007 through January 25, 2007. It is ordered that Verizon Wireless produce these records requested by the Commonwealth of Pennsylvania.

Additional Directives: Please have a technician come to testify as to cell tower location, and radius of cell tower coverage. Custodian of Records will also need to testify to the phone records for phone number 570-579-4437 issued to a tracphone on 1/22/07. You are directed to bring documents concerning the routing numbers attached hereto.

4. Christopher DeWolfe, or other designated Custodian of Records from MySpace.com, whose current address is XXXX, is a necessary and material witness for the State of Pennsylvania for the reason that the Commonwealth asserts that the Commonwealth intends to elicit testimony regarding the Defendants’ use of their MySpace accounts prior to and after the homicide, namely from June 1, 2006 through May 31, 2007, including but not limited to use of said accounts to contact Grant Roy and/or Sean Lockhart.

5. Matthew Wade Brannon, whose current address is XXXX, is a necessary and material witness for the State of Pennsylvania for the reason that the Commonwealth asserts that Mathew Wade Brannon is an acquaintance of both Defendants through the Defendants’ escort business. Additionally, Defendant, Joseph Kerekes, has listed Matthew Wade Brannan as a potential alibi witness. Mr. Brannon would testify that he was not either personally with or in contact with Joseph Kerekes at the time of the homicide.

Additional Directives: You are directed to bring all e-mails, documents, text messages, to and from Harlow Cuadra and/or Joseph Kerekes for January 1, 2007 to May 25, 2007. All phone records for January 1, 2007 to May 25, 2007.

6. Custodian of Records from OAS Phone, whose current address is XXXX, is a necessary and material witness for the State of Pennsylvania for the reason that the Commonwealth asserts that telephone number, 570-579-4437, was registered to a pre-paid mobile telephone that was shipped and distributed by OAS Phone in the Box. This pre-paid mobile telephone was used by “Danny Moilin”, the fictitious identity created by Harlow Cuadra in order to contact that victim. This phone number, registered to the pre-paid mobile phone, registered calls to the victim at times when “Danny Moilin”, aka Harlow Cuadra, was scheduled to either call or receive calls from the victim. The Commonwealth requests all purchase and/or sale records of this phone, including when the phone was activated, where it was activated from, all bills of lading and shipment records from the initial distribution center to the point of sale, any registration records, and any account information for the OAS Phone in the Box.

Additional Directives: You are directed to bring all records on the phone 570-579-4437 from June 30, 2005 to February 10, 2007 including but not limited to all shipment records, distribution records, and records concerning the phones registration.

7. Michelle Mar, or other designated Custodian of Records from USA People Search, whose current address is XXXX, is a necessary and material witness for the State of Pennsylvania for the reason that the Commonwealth asserts that the alleged murderer Harlow Cuadra did a background search on the victim, Bryan Kocis, on January 20, 2007. The Commonwealth requests the custodian of records bring all data and computer information on this request (including any and all IP addresses, i.e. IP log data including member internet protocol addresses) and any information on IP address 70.174.54.38.

Additional Directives: Please come prepared to testify to purchase of a background check on Bryan Charles Kocis on 1/20/07 by Harlow Cuadra from IP Address 70.174.54.38 using Discover Card 6011xxxxxxxx9954. The account number for the purchase was 901207-0083-0741-0942.

8. Donna Plasmere, or other designated Custodian of Records from America Online, whose current address is XXXX, is a necessary and material witness for the State of Pennsylvania for the reason that the Commonwealth asserts that the alleged murderers Joseph Kereltes and Harlow Cuadra contacted the victim, Bryan Kocis, on the victim’s business email accounts, COBRAVIDEO@AOL.COM, KINGCOBRA@AOL.COM, and BKOCIS@AOL.COM, from January 22-25, 2007. The Commonwealth requests the custodian of records attend with these records as well as IF connection log data (including member internet protocol addresses), all email content on unopened, read, sent, and deleted mail, detailed billing records (including all subscriber information, including all screen names associated with AOL accounts COBRAVIDEO@AOL.COM, KINGCOBRA@AOL.COM, and BKOCIS@AOL.COM, and all records from January 1, 2007 to January 27, 2007.

9. Angela Evans, or other designated Custodian of Records from ALLTEL, whose current address is XXXX, is a necessary and material witness for the State of Pennsylvania for the reason that the Commonwealth asserts that the Commonwealth alleges that the Defendant, Joseph Kerekes, used his cell phone(s) from January 22-25, 2007, the time frame for the homicide, and one of the phone calls bounced off the Country Club Road tower, located in Dallas, PA. The Commonwealth requests the custodian of records to testify to records of cell phones registered to Joseph Kerekes: 757-717-0233 and 757-567-0055.

Additional Directives: Please have Custodian of Records prepared to testify to records of cell phone registered to Joseph Kerekes: 757-717-0233 and 757-567-0055. You are directed to bring all: (1) Phone records of these two phones from 10/01/06 to 5/25/07; (2) Cell tower information for the phone calls made from 1/20/07 to 2/10/07.

10. That Elena Arosemena, or other designated Custodian of Records from Cox Communications, Inc., whose current address is XXXX, is a necessary and material witness for the State of Pennsylvania for the reason that the Commonwealth asserts that Cox Communications provided Harlow Cuadra with IP addresses from January 1, 2007 — March 1, 2007. The Commonwealth requests a custodian testify as to the attached records. The Commonwealth also requests IP address information for January 20, 2007.

Additional Directives: Have Custodian of Records prepared to testify to IP Addresses registered to Harlow R. Cuadra of 1028 Stratem Ct., Virginia Beach, VA from 1/20/07 through March of 2007.

11. Annie Cappeller, Director of Legal Affairs, or other designated Custodian of Records from IAC Search and Media, whose current address is XXXX, is a necessary and material witness for the State of Pennsylvania for the reason that the Commonwealth asserts that Harlow Cuadra used an internet email account provided by IAC Search and Media, HarlowCuadra@excite.com, using the same IP address as “Danny Moilin”, the fictitious identity created by Harlow Cuadra to arrange meetings with the victim. These emails, sent from an IAC Search and Media Internet account, were sent in close proximity to the time of the victim’s murder. “Danny Moilin”, aka Harlow Cuadra, used the email account, dmbottom@yahoo.com, to contact the victim and arrange a meeting on January 24, 2007.

Additional Directives: You are directed to bring all records on this e-mail address account from January 1, 2006 to May 26, 2007.

12. Jeffrey Stanford, or other designated Custodian of Records from YAHOO, INC., whose current address is XXXX, is a necessary and material witness for the State of Pennsylvania for the reason that the Commonwealth asserts that Jeffrey Stanford or other designated Custodian of Records from Yahoo, Inc. would testify to the activity content and authenticity of emails for the following email accounts: dmbottompa@yahoo.com, party757@yahoo.com, and stareyes23510@yahoo.com. Email account dmbottompa@yahoo.com was used solely for the purpose of contacting the victim. Email account party757@yahoo.com was utilized by the Defendants before and after the homicide from the same IP addresses as the dmbottompa@yahoo.com email account. Email account stareyes23510@yahoo.com was also utilized by the Defendants before and after the homicide from the same IP addresses as the dmbottompa@yahoo.com email account. The Commonwealth requests the custodian of records to provide all IP connection log data (including member internet protocol addresses), all email content on unopened, read, sent, and deleted mail, and detailed billing records (including subscriber information).

Additional Directives: Bring all records from 6/1/06 - 5/23/07 on the above accounts as well as subscriber information and any information concerning who opened the above mentioned e-mail accounts.

13. Heather Ramos, or other designated Custodian of Records from Sprint Nextel, whose current address is XXXX, is a necessary and material witness for the State of Pennsylvania for the reason that the Commonwealth asserts that Sprint Nextel issued a wireless aircard to Harlow Cuadra which he used to contact the victim with using the email address DMBOTTOMPA@YAHOO.COM and it was also used to create a fake alibi defense with Joseph Kerekes in a spurious email sent to Matt Brannon.

Additional Directives: Custodian of Records shall testify to records maintained for a wireless air card registered to Harlow Raymond Cuadra, account #0598498712, ESN 5B4B9E78.