Sunday, February 1, 2009

DA's Witnesses for Harlow Cuadra's Trial... Explained.

In a post I did yesterday called "The Witness Round-Up... Again", blogger Geoff Harvard asked "Who are all these material witnesses. I've lost track."... I can't blame you Geoff, with so many subpoenas being filed, and so many delays in the trial, I'd have to say there's been times that I've lost track too.

Since there's probably not going to be much to report between now and the start of the trial, I figured it would be a good idea to do a 'who's who' of witnesses and why they're being asked to testify, but with there being so many, it's going to take me a few days. (Update: I've decided to continue to add the additions to this same post, as it'll be easier to follow. I'll let you know when I'm finished.):

(in no particular order)

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 Defendant 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. & 11. Elena Arosemena and Michael Long: 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.

12. 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.

13. 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.

14. Heather Blewett: 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.

15. Nep Maliki: The Commonwealth alleges that Defendant Cuadra sent Nep Maliki a letter instructing him to tell authorities that he went to Cuadra’s residence at 1028 Stratem Court, Virginia Beach, Virginia for an escort call on the evening of January 24,2007.

16. Howard "Mitch" Halford: Cuadra asked former escort client Howard Halford to corroborate the Maliki story in a May 2007 interview with police. Halford agreed, but then backed off, saying he had only seen Cuadra once in a two-week span in mid-to-late January 2007.

17. Justin Hensley: A former employee of Harlow and Joe's, Justin Hensley’s testimony at the Preliminary Hearing was offered to show that one of the central objectives of the conspiracy was to secure the services and talent of Sean Lockhart aka Brent Corrigan. Which the Defendants later tried to recruit in April 2007 when they traveled to San Diego, California.

18. Kimberly Hensley: Justin Hensley's mother, outside of that, I currently haven't a clue what testimony the Commonwealth expects her to give, but I'll try to find out, and update her entry if and when I do.

19. Lance Treadway: Owner of the "Big House Gym", Treadway stated that both Cuadra and Kerekes always worked out together, to which both possess a "swipe card" which allows entry to the facility. Swipe card read outs were requested for both January and February. The most dated reading available was 01/23/07, as there is a thrity day rentention period only. Both Cuadra and Kerekes were absent, which was unusual to Treadway, on 01/23/24,25/07, however were present every day the remainder of the month, along with every day from 02/01 through 02/09/07. There were no accesses following 02/09/07. It should be noted that the date of search warrant at the residence of both Cuadra and Kerekes was 02/10/07.

20. Harry Strait: A resident of Virginia Beach, Mr. Strait told a local news station that he chatted with Caudra in a gay chat room. Caudra invited him to his house in Birdneck Woods where he met both Kerekes and Caudra. He says they offered him a job working in gay porn, but he turned them down.

21. Matthew Bedois (Custodian of Records Enterprise Rental Car): While working with the Virginia Beach Police Department, investigators with the Pennsylvania State Police learned that on the morning of 01/25/07, Officer Brent Riddick, Virginia Beach Police, obtained the registration number for a silver/grey Nissan Xterra sport utility vehicle with dark trim and three brake lights. Said registration came back to "Enterprise Leasing Company", Virginia Beach Blvd., Virginia Beach, Va.. Further investigation revealed that said vehicle was rented by accused Cuadra on 01/23/07 at approx 0940hrs. The vehicle was rented in the name of Harlow R. Cuadra, to which Cuadra's driver's license was afforded subsequent to the rental agreement. Cuadra's Virginia driver number was also recorded upon the rental agreement, as was Cuadra's signature. Rental vehicle was paid for by Discover Card issued to Harlow R. Cuadra, Norfolk Male Escorts, Inc.

22. & 23. Philip Romano and Tony Parrow: of Marriott Spring Hill Suites, Norfolk, Virginia, are necessary and material witnesses for the State of Pennsylvania for the reason that the Commonweatlh asserts the murderers fled to the Marriott and hid from Law Enforcement shortly after the homicide. The Commonwealth further alleges that the murderers stayed at this Marriott until they absconed to Miami Beach, Florida.

24., 25. & 26. Debra Crain, Ryan Dunbar, and Irving Walker are employees of Superior Pawn, where accused Cuadra along with guilty Kerekes entered and purchased a "Sigarms" model # FX1SG, lock blade folding knife with 30% serrated edge. Cuadra additionally purchased a Smith and Wesson .38 caliber revolver and ammunition, utilizing a Visa credit card issued to Harlow Cuadra. Both Cuadra and Kerekes were observed on surveillance video at said location purchasing said items.

27. Renee Martin: Prosecutors recorded numerous telephone conversations Cuadra and Kerekes conducted with Martin, while they were incarcerated at the Virginia Beach Correctional Facility, and while in Pennsylvania. Martin established and participated in three-way telephone conversations with Cuadra and Kerekes and heard “incriminating statements” they made during those calls, prosecutors said.

28. Robert Wagner: During the preliminary hearing Robert Wagner described several of the items the victim used for his business including laptop computers, computer towers, and 2257 forms. Mr. Wagner also described two camcorders owned by the victim which he positively identified in a photo marked as exhibit 45. Wagner also described Bryan Kocis’ Rolex watch that he wore all the time, as well as, a flat screen TV that the victim had just purchased at Christmastime. Robert Wagner testified that he had seen all of these items in the victim’s residence as recently as Sunday January 21, 2007. Robert Wagner also testified that Bryan Kocis was “an intensively private person” and he did not have an open-door policy to visitors; advanced notice was required.

Finally, Robert Wagner testified that Bryan Kocis planned on meeting a new model on Wednesday January 24, 2007 between 7 and 8 p.m. Kocis informed Wagner of this via email and attached photos of the new model. The photos were attached to a file named “Danny” and Wagner testified that he recognized the photos when shown to him again. He recognized the person in the photos emailed to him by the victim as Harlow Cuadra and made an in-court identification of the Defendant.

29. Grant Roy: Roy testified at an evidence suppression hearing on July 24, 2008 that he wore a microphone under his shirt as he and business partner Sean Lockhart dined with Cuadra and Kerekes at a restaurant in the La Jolla section of San Diego on April 27, and held an automobile key remote that contained a microphone as they spoke at a nude beach the next day.

The Prosecution states that Grant Roy’s testimony of his conversation with the Defendants on April 28, 2007 goes straight to their culpability of all the crimes charged. The Defendants’ admissions to Grant Roy place them at the scene of murder at the time of death, however, they also admit to having taken the aforementioned missing items from the victim’s home and later destroying them essentially in order to destroy evidence of their involvement in the murder, Mr. Roy’s testimony demonstrates multiple conspiracies committed by the Defendant: arson, robbery, abuse of corpse, homicide.

30. Deputy Coroner William Lisman: During the preliminary hearing, Mr. Lisman testified that he received a telephone call from the 911 Communication Center on the evening in question to respond to Midland Drive in Dallas, PA. He further testified that he was asked to examine a human body that was badly burned and which was later identified as the deceased Bryan Kocis. Mr. Lisman further described a frothy, bubbly area of fluid common to fire victims due to super heating of the fluid in the body, however, in Mr. Kocis’ case, the frothy, bubbly fluid was occurring around his neck. Mr. Lisman also testified, that upon a closer view of the deceased, he viewed what he believed to be stab wounds on the victim’s chest and a laceration to the victim’s neck.

Mr. Lisman further testified that the body was badly burned and it was not readily identifiable. He stated that at the autopsy on January 25, 2007, the body was identified through the use of dental records obtained by Kocis’ family members.

31. Dr. John Consalvo: Dr. Consalvo testified at the preliminary hearing that he attended the autopsy of the victim which was performed by Dr. Mary Pascucci. He stated that “the cause of death was a near decapitating wound to the neck, And the manner of death was homicide.” Dr. Consalvo also described the condition of the victim’s body. He described second degree burns on the victim’s back, as well as, third degree burning on his legs; his hands and arm were burned and his fingertips were completely burned. Fragments of cloth were burned to the skin. He further indicated that the victim’s genitals were charred and that there was a stab wound to the left side of the groin area. Eighty percent (80%) of Mr. Kocis’ body sustained 3 degree burns.

Dr. Consalvo also testified that the victim’s windpipe was completely severed as was his esophagus. Furthermore, the victim’s carotid artery, one of the main arteries from the heart to the brain, was severed. This was determined to be the probable cause of death. There was also testimony as to several stab wounds to the victim’s sternum. It was also determined that at the time the fire started the victim was not alive. Twenty-nine (29) post-mortem stab wounds were also present.

32. Amy Zamerowski: Ms. Zamerowski testified during the preliminary hearing that on the evening of January 24, 2007, she was going to pick up her friend Amy Withers at 64 Midland Drive, Dallas, right next door to the Kocis residence. She recalls that she turned onto Midland Drive at precisely 8:26 p.m. When she pulled into the Withers’ driveway, there was a light colored SUV backing out of the Kocis driveway, Ms. Zamerowski was shown exhibits 13 through 25 which were photos taken by the Pennsylvania State Police of a silver Nissan XTerra. She testified that she was previously shown these photos and informed the State Police that the Nissan XTerra could have been the vehicle she had seen backing out of the Kocis driveway on the evening in question. Finally, Ms. Zamerowski testified that after seeing the vehicle leaving the Kocis driveway, she entered the Withers residence, Approximately ten (10) minutes later, someone knocked at the door warning them to get out of the house because there was a fire next door at the Kocis residence.

33. James Gilbert: Mr. Gilbert testified during the preliminary hearing that he resides on Midland Drive in Dallas and was a neighbor of Bryan Kocis. He stated that he walked his dog on Midland Drive, including past the Kocis home, between approximately 7:35 to 7:50 p.m. on January 24, 2007. He further stated that at that time, he noticed a silver SUV in Kocis’ driveway up towards the garage. He found this somewhat peculiar because vehicles didn’t usually park in the driveway of the Kocis home; they typically parked in a spot in front of the house. Gilbert was then shown Exhibit No. 12 which was a photo of a silver Nissan XTerra. The witness positively identified Exhibit No. 12 as the make and type of vehicle that he had seen on the evening of Wednesday, January 24, 2007 in the Kocis driveway. Gilbert recalled seeing flames coming from the Kocis residence at approximately 8:15-8:30 p.m. that evening.

34. Custodian of Records from Discover Financial Services: You are directed to bring all records on Harlow Cuadra's Discover Card from 6-1-2005 to 5-25-2007.

[PC notes: A background check on Bryan Kocis, and a rental vehicle (SUV) were paid for by a Discover Card issued to Harlow Cuadra, Norfolk Male Escorts, Inc.]

35. Joseph Ryan: It's my understanding that Mr. Ryan told Harlow Cuadra that he would help with the attorney/expert witness fees, but in the end he backed-out... Joseph Ryan was also a former client, and it's alleged he had conversations with Cuadra that may have implicated Harlow in the crime.

36. Alex Puente: Mr. Puente is/was the Webmaster for CobraVideo.com. It should be noted that the deceased, Bryan Kocis, utilized the e-mail account Kingcobra@cobravideo.com. Puente was asked to provide e-mail messages from Bryan Kocis’ Cobra Video account during the last four days of his life. Puente indicated that on January 24, 2007, at 2:23 p.m., an e-mail message was sent by the victim to Sean Lockhart, which stated in part that the victim was expecting a male model to arrive at his residence this date. On Monday, January 22, 2007, at 10:18 a.m., a male model application, containing the bio of Danny Moilin, King of Prussia, Pennsylvania, was forwarded to Kocis’ e-mail account. Moilin utilized the e-mail address of DMBOTTOMPA@YAHOO.COM. The bio included several photographs of the male model applicant.

37. Dallas Twp. Fire Chief Harry Vivian: Chief Vivian testified during the preliminary hearing that a fire alarm came into the department for the Kocis home at 8:35 p.m. on January 24, 2007. It took the fire department approximately 20 minutes to one half hour to suppress the fire and there was heavy fire damage to the front porch and the front of the house, namely the living room. It was in the living room that the body of Bryan Kocis was found. Furthermore, Chief Vivian testified that when he went into the house with the State Police Fire Marshall, they found two smoke detectors which were removed from their mounts, the first floor smoke detector was placed on a table near the wall and the upstairs smoke detector was lying on the bathroom floor off the main hallway. The responding firefighters were endangered. This evidence was offered on the Arson for danger of death or bodily injury to other persons.

38. Trooper Ron Jarocha, Pennsylvania State Police Deputy Fire Marshall: Trooper Jarocha testified during the preliminary hearing that, based on his knowledge, training and experience, it was his opinion that the fire was an arson, he believed that “an open flame was used to ignite combustible materials which were placed behind the love seat.” He opined that in the area of the love seat, “you could see a burn pattern on the floor, and the charring on the back of the [seat]. If the fire started elsewhere in the room, this would be a protected area, and no reason for the fire to have burned underneath that area.” He also noted that while removing items from the area of the love seat, the State Police “found remnants of cushioning... the foam which is inside the seats. [ also found remnants of like a throw pillow. A small pillow that had like tassels on it. That was actually attached to the back of the house somewhere [the loveseat]. We also found signs of paper products, like cardboard paper. There were numerous, numerous combustible items being in the [area].” He further testified in regards to the origin of fire that he “found no causes for this fire to occur between the couch — directly behind the love seat. There was nothing there to accidentally cause this fire.” He also testified to finding the smoke detectors removed and placed in other locations. According to the prosecution, Trooper Jarocha’s testimony confirms without any doubt that the fire was intentionally set.

39. Michael Kocis: Michael Kocis was the victim’s father and the executor of the victim’s estate. During the preliminary hearing, he testified that his son was a quiet, private person who kept to himself. It was the normal practice for the family to call ahead before visiting the victim; they did not come to the victim’s house unannounced. He also testified that there were several items of personal property that were missing from Bryan Kocis’ home from the incident of January 24, 2007, namely two high-end expensive camcorders, computer towers, a Rolex watch which the younger Kocis never took off, as well as, business records such as 2257 forms. These items were reported missing to Thomas Baker, Nationwide Insurance Claims Representative who testified that the replacement value of the fire destroyed home was $208,254.00 and the total personal property loss due to the fire, as well as, items reported missing was $216,000.00.

40. Andrew Shunk: A former employee of Harlow and Joe's, Andrew Shunk is beleived by most to be confidential informant #2, and whose testmony at trial will likely be offered to show that one of the central objectives of the conspiracy was to secure the services and talent of Sean Lockhart aka Brent Corrigan. Which the Defendants later tried to recruit in April 2007 when they traveled to San Diego, California.

[PC notes: Andrew Shunk was present for the July 2008 pretrial hearing, but did not testify due to an attorney conflict issue that arose between Harlow and Joe's attorneys.]

41. Trooper Brian Murphy: During the preliminary hearing, Trooper Murhpy from the Pennsylvania State Police Computer Crimes Unit testified at length to his part in the investigation. He obtained computer information about the victim using his website and email addresses, as well as, the webmaster for the victim’s website to trace emails sent to the victim, This was due in large part to the information received that a prospective model scheduled to meet the victim on the night of his murder had emailed photos of himself to the victim. There were also “two model applications sent in by an individual identifying himself as Danny Moilin with an associated email address of dmbottompa@yahoo.com.”

Trooper Murphy described that an IP address gives a specific geographical site. “It gives us a specific internet connection location. There’s over four billion possible IP addresses, and no two IP addresses can be connected to the internet at the same time.” He determined that the model application that was completed and submitted on the victim’s website came from an IP address registered to Harlow Cuadra at 1028 Stratem Court, Virginia Beach Virginia Trooper Murphy also testified to a chain of email correspondence between the victim and the dmbottompa@yahoo.com email account. Each of the emails originating from the dmbottompa email account were associated with IP addresses registered to Harlow Cuadra at the 1028 Stratem Court, Virginia Beach, VA address and/or a Sprint Nextel Wireless air card registered to Cuadra. Attached to several of these emails were pictures of Harlow Cuadra, who was operating under the ruse that he was a ‘Danny Moilin’ who was interested in becoming a model for the victim. The last email confirmed a meeting time between the victim and Cuadra aka Danny Moilin of between 7-8 p.m. on January 24, 2007.

Trooper Murphy also noted that “Danny Moilin” was going to call the victim at 7:30 p.m. on Monday January 22, 2007. At 7:26 p.m. on said date, “Danny Moilin” called the victim Bryan Kocis. That call bounced off of the Belles Road cell tower, three-tenths (3/10) of a mile from the Cuadra/Kerekes residence at 1028 Stratem Court, Virginia Beach, Virginia. Trooper Murphy then noted that in a January 22, 2007 11p.m. email, the victim confirmed the earlier conversation.

Also, Trooper Murphy testified that he determined that on January 20, 2007, that USA People Search was contacted and a background investigation on the victim, Bryan Kocis was ordered from an IP address associated with Harlow Cuadra at 1028 Stratem Court. The purchase was made on a credit card registered to Harlow Cuadra. This was four days prior to the homicide.

42. Cpl. Leo Hannon, Pennsylvania State Police: The prosecution asserts that Cpl. Leo Hannon’s testimony during the preliminary hearing regarding various phases of the investigation, clearly tie Harlow Cuadra to the homicide and related crimes. The Defendant had information that only parties involved in the homicide could know, cameras identical to those missing from the Kocis home were found at the Defendants’ home, there is video and a receipt for the Defendants’ purchase of a consistent murder weapon, documentation evidencing the rental of a vehicle matching the description of an SUV seen at the crime scene, and various telecommunications, both through email and telephone.

43. Sean Lockhart: Since Lockhart has not testified at any hearings, I can only surmise that his testimony will be similar to that of Grant Roy's, and will demonstrate multiple conspiracies committed by the Defendant: arson, robbery, abuse of corpse, and homicide.

44. Attorney Sean Macias, Bryan Kocis' former attorney: Attorney Macias is a necessary and material witness for the State of Pennsylvania for the reason that the Commonwealth asserts he was on the phone with the victim when the alleged assailant arrived and the victim acknowledged the arrival of the expected model.

45. Special Agent Andrew Pappas, DEA San Diego Field Division: One of several law enforcement officers involved in both the Black's Beach and Crab Catcher Restaurant recordings.

46. Detective Lieutenant Daniel Yursha: On May 15, 2007 Luzerne County Detective Lieutenant Daniel Yursha and Dallas Township Police Sergeant Douglas Higgins met with Defendant Cuadra in an interview room at the Virginia Beach Police Department. After Yursha read Cuadra Miranda warnings, Yursha also read the ten page Criminal Complaint and twenty-one page Affidavit of Probable Cause. Yursha and Higgins then left the interview room.

Yursha re-entered the interview room approximately seven minutes later and again asked Cuadra if he wanted anything to eat or drink. Cuadra refused the offer but blurted out the following statements:

Cuadra stated he bought the knife and the 38 caliber pistol from a pawn shop on the same date. (The knife was seized from the glove compartment of the BMW; the revolver was seized from the search of 1028 Stratem Court). Cuadra also stated they “never went to a gay bar that night” (referring to a witness’ statement that she believes she saw them at a gay bar located near the Fox Ridge Inn in Wilkes-Barre, Pennsylvania). Cuadra also stated that “Joe didn’t do it”. According to the prosecution, these statements by Cuadra were not in response to any questioning by Yursha or Higgins.

Yursha was also involved in both the Black's Beach and Crab Catcher Restaurant recordings.

47. David Jacobsen: According to the prosecution, the informants, Andrew Shunk, Justin Hensley and David Jacobsen provided Detective Childress with information concerning the use of Harlow's BMW, as well as, money laundering and prostitution. The prosecution also asserts that Mr. Jacobsen has information that goes towards establishing motive for the homicide.

48. John Adelizzi, FC Kerbeck Premium Brand Division.

[PC notes: During the Black's Beach conversation, Harlow and Joe mention the following:

HARLOW CUADRA: He told me, ah, the Austin Martin was in fucking Delaware or something...

JOSEPH KEREKES: It was a lease he said to Harlow.

HARLOW CUADRA: The V-8 Vantage, was in the shop.


FC Kerbeck Premium Brand Division is located in Palmyra, NJ, which is where Bryan's car was being serviced at the time of his murder. I'm going to assume they will use Mr. Adelizzi's testimony to prove that Harlow had in fact spoke/met with Kocis, as this information wouldn't have been known otherwise.]

The following people have also received subpoenas, but as of this time, I'm unsure as to who they are, and/or why they're being asked to testify. If and when I'm able to find out, I'll update accordingly:

49. Brendan Sheovic (VB Corr. Facility - Material Witness)
50. CPT Cassandra Lee (VB Corr. Facility - Material witness)
51. Jospeh J. Zalusky (Material Witness)
52. Thomas Lampman (Material Witness)
53. Adam Greiber (Material Witness)
54. Christina Gist (Custodian of Records Doubletree Hotel)
55. Attorney Samuel Hall (Material Witness)
56. John Zirkle (Hilton Norfolk Airport)
57. Linda Huffman (UCN, Inc.)
58. Keena Willis (Domains by Proxy)
59. Shanta Clayton (AT&T Custodian)