Showing posts with label Alibi Witness. Show all posts
Showing posts with label Alibi Witness. Show all posts
Sunday, February 1, 2009
DA's Witnesses for Harlow Cuadra's Trial... Explained.
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Saturday, January 31, 2009
The Witness Round-Up... Again.
Over the past week or so, the DA's office has filed subpoenas for a total of 26 witnesses to attend Harlow Cuadra's upcoming February trial:
The Commonwealth of Pennsylvania is scheduled to commence criminal prosecution of Harlow Cuadra at trial commencing on February 17, 2009 in the Luzerne County Court of Common Pleas, 200 N. River Street, Wilkes-Barre, Pennsylvania 18711. [Witness Name] is a material witnesses for the Commonwealth and the attendance at the aforesaid trial is necessary from February 17, 2009 through March 20, 2009. The Commonwealth of Pennsylvania requests that in the event that the witness is uncooperative, that the witness be taken into immediate custody and delivered to an officer of the Commonwealth of Pennsylvania to ensure his/her inclusive attendance at the Pennsylvania trial proceedings as per Pennsylvania Rule of Criminal Procedure 522 and all relevant comments thereto and pursuant to 42 Pa.C.S.A. section 5964 relating to witnesses from another state summoned to testify in this Commonwealth. The Commonwealth certifies the compulory attendance of this witness is not for the purpose of serving said witness with process from another civil or criminal proceeding. The Commonwealth hereby waives its right to serve said witness with process, civil or criminal, by virtue of the witness' attendance/presence in Pennsylvania in this matter.
(in no particular order)
Christopher Dewolfe (Custodian of Records MYSPACE)
Chris Hurd (Custodian of Records DVINFO.net)
Matthew Brannon (Material Witness)
Michael Rozyla (Custodian of Records Verizon Wireless)
Annie Cappeller (Custodian of Records IAC Search & Media)
Heather Blewett (Custodian of Records Sprint/Nextel)
Angela Evans (Custodian of Records All Tell)
David Mitchell aka David Michaels (Material Witness)
Michelle Mar (Custodian of Records USA People Search)
Jeffrey Stanford (Custodian of Records YAHOO!)
Justin Hensley (Material Witness)
Brendan Sheovic (VB Corr. Facility - Material Witness)
CPT Cassandra Lee (VB Corr. Facility - Material witness)
Matthew Bedois (Custodian of Records Enterprise Rental Car)
Lance Treadway (Material Witness)
Andrew Shunk (Material Witness)
Debra Crain (Superior Pawn Shop)
Ryan Dunbar (Superior Pawn Shop)
Irving Walker (Superior Pawn Shop)
Joseph J. Zalusky (Material Witness)
Nep Malaki (Material Witness)
Thomas Lampman (Material Witness)
Adam Greiber (Material Witness)
Christina Gist (Custodian of Records Doubletree Hotel)
Kimberly Hensley (Material Witness)
Harry Strait (Material Witness)
The Commonwealth of Pennsylvania is scheduled to commence criminal prosecution of Harlow Cuadra at trial commencing on February 17, 2009 in the Luzerne County Court of Common Pleas, 200 N. River Street, Wilkes-Barre, Pennsylvania 18711. [Witness Name] is a material witnesses for the Commonwealth and the attendance at the aforesaid trial is necessary from February 17, 2009 through March 20, 2009. The Commonwealth of Pennsylvania requests that in the event that the witness is uncooperative, that the witness be taken into immediate custody and delivered to an officer of the Commonwealth of Pennsylvania to ensure his/her inclusive attendance at the Pennsylvania trial proceedings as per Pennsylvania Rule of Criminal Procedure 522 and all relevant comments thereto and pursuant to 42 Pa.C.S.A. section 5964 relating to witnesses from another state summoned to testify in this Commonwealth. The Commonwealth certifies the compulory attendance of this witness is not for the purpose of serving said witness with process from another civil or criminal proceeding. The Commonwealth hereby waives its right to serve said witness with process, civil or criminal, by virtue of the witness' attendance/presence in Pennsylvania in this matter.
(in no particular order)
Christopher Dewolfe (Custodian of Records MYSPACE)
Chris Hurd (Custodian of Records DVINFO.net)
Matthew Brannon (Material Witness)
Michael Rozyla (Custodian of Records Verizon Wireless)
Annie Cappeller (Custodian of Records IAC Search & Media)
Heather Blewett (Custodian of Records Sprint/Nextel)
Angela Evans (Custodian of Records All Tell)
David Mitchell aka David Michaels (Material Witness)
Michelle Mar (Custodian of Records USA People Search)
Jeffrey Stanford (Custodian of Records YAHOO!)
Justin Hensley (Material Witness)
Brendan Sheovic (VB Corr. Facility - Material Witness)
CPT Cassandra Lee (VB Corr. Facility - Material witness)
Matthew Bedois (Custodian of Records Enterprise Rental Car)
Lance Treadway (Material Witness)
Andrew Shunk (Material Witness)
Debra Crain (Superior Pawn Shop)
Ryan Dunbar (Superior Pawn Shop)
Irving Walker (Superior Pawn Shop)
Joseph J. Zalusky (Material Witness)
Nep Malaki (Material Witness)
Thomas Lampman (Material Witness)
Adam Greiber (Material Witness)
Christina Gist (Custodian of Records Doubletree Hotel)
Kimberly Hensley (Material Witness)
Harry Strait (Material Witness)
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.
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.
Friday, August 8, 2008
DA's Motion to Limit Caudra's Alibi Defense
COMMONWEALTH'S MOTION TO LIMIT DEFENDANT CUADRA'S ALIBI DEFENSE AT TRIAL UNDER PENNSYLVANIA RULE OF CRIMINAL PROCEDURE 567
AND NOW COMES, the Commonwealth of Pennsylvani by and through its Attorneys, Jacqueline Carroll, District Attorney of Luzerne County; Michael Melnick, Assistant District Attorney, Shannon Crake, Assistant District Attorney, and Allyson L. Kacmarski, Assistant District Attorney and in support thereof avers as follows:
1. On May 15, 2007, the Defendant was arrested and charged with multiple offenses arising from a criminal homicide which occurred on January 24, 2007, at 60 Midland Drive, Dallas Twp, Luzerne County, Pennsylvania.
2. A preliminary hearing was held on August 20 and 23, 2007, before Honorable James Tupper.
Defendant was formally arraigned on October 4, 2007, and entered a plea of Not Guilty to all of the following charges: Criminal Homicide; Criminal Conspiracy to Commit Homicide; Arson-Danger of Death or Bodily Injury; Arson-Inhabited Building or Structure; Robbery-Inflict Serious Bodily Injury; Theft by Unlawful Taking-Movable Property; Tamper With/Fabricate Physical Evidence; Abuse of Corpse; Criminal Conspiracy to Commit Robbery; Criminal Conspiracy to Commit Tampering With or Fabricating Physical Evidence; and Criminal Conspiracy to Commit Arson, and Criminal Use of a Communication Facility.
4. Defendant’s criminal case was consolidated with Co-Defendant’s, Joseph Manuel Kerekes, criminal case, 3094 CR 2007.
5. Joseph Kerekes was also formally arraigned on October 4, 2007, and entered a plea of Not Guilty to the charges of: Criminal Homicide; Criminal Conspiracy to Commit Homicide; Arson-Danger of Death or Bodily Injury; Arson-Inhabited Building or Structure; Robbery-Inflict Serious Bodily Injury; Theft by Unlawful Taking-Movable Property; Tamper With/Fabricate Physical Evidence; Abuse of Corpse; Criminal Conspiracy to Commit Robbery; Criminal Conspiracy to Commit Tampering With or Fabricating Physical Evidence; and Criminal Conspiracy to Commit Arson.
6. At the time of the formal arraignment, Defendant could no longer afford private counsel and the Court thereafter appointed the Luzeme County Public Defender’s Office to represent the Defendant.
7. On January 3, 2008, the Luzerne County Public Defender’s Office withdrew from the case and the Court appointed Conflict Counsel, Stephen Menn, Michael Senape, and Paul Galante, to represent the Defendant.
8. On January 28, 2008 Attorney Demetrius Fannick entered his appearance on behalf of Harlow Cuadra.
9. On March 19, 2008, the Court ordered that Attorney Fannick is disqualified to represent the Defendant and that the Defendant will be represented by Conflict Counsel, Stephen Menn, Michael Senape, and Paul Galante.
10. Defense Counsel was granted an extension to file all omnibus pre-trial motions by May 9, 2008.
11. On May 9, 2008, Attorney Galante requested and was granted an additional one week one week extension to file all omnibus pre-trial motions.
12. On May 16 2008, Defendant filed his omnibus pre-trial motions, which did not include a Notice of Alibi Defense.
13. On July 9, 2008, Attorney Galante withdrew as Counsel and the Defendant is currently represented by Conflict Counsel Stephen Menn and Michael Senape.
14. On July 30, 2008, Defendant filed a Notice of Possible Alibi Defense.
15. Defendant states in his Notice of Alibi Defense that his possible alibi defense will be that at the time of the alleged offense, the Defendant was at the Fox Ridge Hotel, Room 211, Plains Township, PA.
16. Commonwealth notes that the Defendant’s co-Defendant, Joseph Kerekes, also filed a Notice of Alibi Defense on January 30, 2008, stating that Joseph Kerekes’ possible alibi defense will be that at the time of the alleged offense, the Defendant was at the Fox Ridge Hotel, Room 211, Plains Township, PA.
17. Most noteworthy is the Defendant states he may call other yet unknown and unidentified witnesses to suppott his alibi defense.
18. Commonwealth notes that the Defendant’s Alibi Defense is consistent and compatible with that of his co-Defendant’s alibi defense.
19. The Commonwealth also notes that the Co-Defendants are intimate partners in a relationship and the fact that they are staying together at the same hotel is entirely consistent with their relationship.
20. The, Commonwealth avers that Pennsylvania Rule of Criminal Procedure
567. Notice’ of Alibi Defensec states:
“(A) A defendant who intends ‘to offer the defense of alibi at trial shall file with the clerk of courts not later than the time for filing the omnibus pretrial motion provided in Rule 579 a notice specifying an intention to offer an alibi defense, and shall serve a copy of the notice and a certificate of service on the attorney for the Commonwealth.”
21. The Commonwealth avers that Pennsylvania Rule of Criminal Procedure
579, Time for Omnibus Pretrial Motionand Service states:
“(A) Except as otherwise provided in these rules, the omnibus pretrial motion for relief shall be filed añd served within 3O days after arraignment, unless opportunity therefore ‘did not exist, or the defendant or defense attorney, or the’ attorney for the Commonwealth was not aware of the grounds for the motion, or unless that time for filing has been extended by the court for cause shown.”
22. According to Rule 567, Notice of Alibi Defense, Defendant’s Notice of Possible Alibi Defense Motion was not filed and served within 30 days of the Defendant’s date of arraignment, October 4, 2007.
23. As previously stated, Defense Counsel’s deadline for filing all omnibus pre-trial motions was May 16, 2008.
24. Commonwealth submits that the Defendant’s Notice of Alibi Defense is an omnibus pre-trial motion and was required to be filed by May 16, 2008, in order to be considered timely.
25. ‘The Commonwealth avers that Pennsylvania Rule of Criminal Procedure 567. Notice of Alibi Defense Subsection B. Failure to File Notice states:
“(B)(1) If Defendant fails to file and serve the notice of alibias required by this rule, the court may exclude entirely any evidence offered by the defendant for the purpose of providing the defense, except testimony by the defendant, may grant a continuance to enable the Commonwealth to investigate such evidence, or may make such other order as the interests of justice require.”
26. Based on the Defendant’s untimely filing of his Notice of Alibi Defense, the Commonwealth asks this Court to exclude entirely any other evidence offered by the Defendant for the purpose of providing an alibi defense at trial, except for the Defendant’s own testimony.
27. The Commonwealth avers that Pennsylvania Rule of Criminal Procedure 567. Notice of Alibi Defense. Subsection (A)(2). Notice by Defendant states:
“(A) (2) The notice shallcontain specific information as to the place or places where the defendant claims to have been at the time of the alleged offense and the names and addresses of the witnesses whom the defendant intends to call in support of the claim.”
28. Defendant’s Notice of Possible Alibi Defense states specific information as to the place where the Defendant claims to have been at the time of the alleged offense, however, the Notice fails to specificaily state the names and addresses of the witnesses whom the defendant intends to call at trial in support of his alibi defense.
29. The Commonwealth notes that Defendant has reserved the Right to supplement his Notice of Alibi Defense as to the witnesses that the Defendant would possibly call in support of his claim, however, given the approaching start date of trial, the Commonwealth would not have sufficient time to investigate the filing of the Notice
30. The Commonwealth submits that due to the lack of specificity of the Defendant’s Notice of Alibi Defense, in regards tothe possible witnesses, the Court should exclude entirely any evidence offered by the Defendant for the purpose of providing an alibi defense at trial, except for the Defendant’s own testimony.
WHEREFORE, the Commonwealth requests this Honorable Court to grant the Commonwealth’s Motion Limiting Defendant’s Alibi Defense at trial to the testimony of the Defendant, Harlow Cuadra, and no other witnesses, based on the Defendant’s failure to meet the requirements of Rule 567 specifically regarding the Defendant’s filing of his eleventh-hour Alibi Notice, as well as the lack of specificity as to possible witnesses that the Defendant may call at trial to support this evolving defense.
1. On May 15, 2007, the Defendant was arrested and charged with multiple offenses arising from a criminal homicide which occurred on January 24, 2007, at 60 Midland Drive, Dallas Twp, Luzerne County, Pennsylvania.
2. A preliminary hearing was held on August 20 and 23, 2007, before Honorable James Tupper.
Defendant was formally arraigned on October 4, 2007, and entered a plea of Not Guilty to all of the following charges: Criminal Homicide; Criminal Conspiracy to Commit Homicide; Arson-Danger of Death or Bodily Injury; Arson-Inhabited Building or Structure; Robbery-Inflict Serious Bodily Injury; Theft by Unlawful Taking-Movable Property; Tamper With/Fabricate Physical Evidence; Abuse of Corpse; Criminal Conspiracy to Commit Robbery; Criminal Conspiracy to Commit Tampering With or Fabricating Physical Evidence; and Criminal Conspiracy to Commit Arson, and Criminal Use of a Communication Facility.
4. Defendant’s criminal case was consolidated with Co-Defendant’s, Joseph Manuel Kerekes, criminal case, 3094 CR 2007.
5. Joseph Kerekes was also formally arraigned on October 4, 2007, and entered a plea of Not Guilty to the charges of: Criminal Homicide; Criminal Conspiracy to Commit Homicide; Arson-Danger of Death or Bodily Injury; Arson-Inhabited Building or Structure; Robbery-Inflict Serious Bodily Injury; Theft by Unlawful Taking-Movable Property; Tamper With/Fabricate Physical Evidence; Abuse of Corpse; Criminal Conspiracy to Commit Robbery; Criminal Conspiracy to Commit Tampering With or Fabricating Physical Evidence; and Criminal Conspiracy to Commit Arson.
6. At the time of the formal arraignment, Defendant could no longer afford private counsel and the Court thereafter appointed the Luzeme County Public Defender’s Office to represent the Defendant.
7. On January 3, 2008, the Luzerne County Public Defender’s Office withdrew from the case and the Court appointed Conflict Counsel, Stephen Menn, Michael Senape, and Paul Galante, to represent the Defendant.
8. On January 28, 2008 Attorney Demetrius Fannick entered his appearance on behalf of Harlow Cuadra.
9. On March 19, 2008, the Court ordered that Attorney Fannick is disqualified to represent the Defendant and that the Defendant will be represented by Conflict Counsel, Stephen Menn, Michael Senape, and Paul Galante.
10. Defense Counsel was granted an extension to file all omnibus pre-trial motions by May 9, 2008.
11. On May 9, 2008, Attorney Galante requested and was granted an additional one week one week extension to file all omnibus pre-trial motions.
12. On May 16 2008, Defendant filed his omnibus pre-trial motions, which did not include a Notice of Alibi Defense.
13. On July 9, 2008, Attorney Galante withdrew as Counsel and the Defendant is currently represented by Conflict Counsel Stephen Menn and Michael Senape.
14. On July 30, 2008, Defendant filed a Notice of Possible Alibi Defense.
15. Defendant states in his Notice of Alibi Defense that his possible alibi defense will be that at the time of the alleged offense, the Defendant was at the Fox Ridge Hotel, Room 211, Plains Township, PA.
16. Commonwealth notes that the Defendant’s co-Defendant, Joseph Kerekes, also filed a Notice of Alibi Defense on January 30, 2008, stating that Joseph Kerekes’ possible alibi defense will be that at the time of the alleged offense, the Defendant was at the Fox Ridge Hotel, Room 211, Plains Township, PA.
17. Most noteworthy is the Defendant states he may call other yet unknown and unidentified witnesses to suppott his alibi defense.
18. Commonwealth notes that the Defendant’s Alibi Defense is consistent and compatible with that of his co-Defendant’s alibi defense.
19. The Commonwealth also notes that the Co-Defendants are intimate partners in a relationship and the fact that they are staying together at the same hotel is entirely consistent with their relationship.
20. The, Commonwealth avers that Pennsylvania Rule of Criminal Procedure
567. Notice’ of Alibi Defensec states:
“(A) A defendant who intends ‘to offer the defense of alibi at trial shall file with the clerk of courts not later than the time for filing the omnibus pretrial motion provided in Rule 579 a notice specifying an intention to offer an alibi defense, and shall serve a copy of the notice and a certificate of service on the attorney for the Commonwealth.”
21. The Commonwealth avers that Pennsylvania Rule of Criminal Procedure
579, Time for Omnibus Pretrial Motionand Service states:
“(A) Except as otherwise provided in these rules, the omnibus pretrial motion for relief shall be filed añd served within 3O days after arraignment, unless opportunity therefore ‘did not exist, or the defendant or defense attorney, or the’ attorney for the Commonwealth was not aware of the grounds for the motion, or unless that time for filing has been extended by the court for cause shown.”
22. According to Rule 567, Notice of Alibi Defense, Defendant’s Notice of Possible Alibi Defense Motion was not filed and served within 30 days of the Defendant’s date of arraignment, October 4, 2007.
23. As previously stated, Defense Counsel’s deadline for filing all omnibus pre-trial motions was May 16, 2008.
24. Commonwealth submits that the Defendant’s Notice of Alibi Defense is an omnibus pre-trial motion and was required to be filed by May 16, 2008, in order to be considered timely.
25. ‘The Commonwealth avers that Pennsylvania Rule of Criminal Procedure 567. Notice of Alibi Defense Subsection B. Failure to File Notice states:
“(B)(1) If Defendant fails to file and serve the notice of alibias required by this rule, the court may exclude entirely any evidence offered by the defendant for the purpose of providing the defense, except testimony by the defendant, may grant a continuance to enable the Commonwealth to investigate such evidence, or may make such other order as the interests of justice require.”
26. Based on the Defendant’s untimely filing of his Notice of Alibi Defense, the Commonwealth asks this Court to exclude entirely any other evidence offered by the Defendant for the purpose of providing an alibi defense at trial, except for the Defendant’s own testimony.
27. The Commonwealth avers that Pennsylvania Rule of Criminal Procedure 567. Notice of Alibi Defense. Subsection (A)(2). Notice by Defendant states:
“(A) (2) The notice shallcontain specific information as to the place or places where the defendant claims to have been at the time of the alleged offense and the names and addresses of the witnesses whom the defendant intends to call in support of the claim.”
28. Defendant’s Notice of Possible Alibi Defense states specific information as to the place where the Defendant claims to have been at the time of the alleged offense, however, the Notice fails to specificaily state the names and addresses of the witnesses whom the defendant intends to call at trial in support of his alibi defense.
29. The Commonwealth notes that Defendant has reserved the Right to supplement his Notice of Alibi Defense as to the witnesses that the Defendant would possibly call in support of his claim, however, given the approaching start date of trial, the Commonwealth would not have sufficient time to investigate the filing of the Notice
30. The Commonwealth submits that due to the lack of specificity of the Defendant’s Notice of Alibi Defense, in regards tothe possible witnesses, the Court should exclude entirely any evidence offered by the Defendant for the purpose of providing an alibi defense at trial, except for the Defendant’s own testimony.
WHEREFORE, the Commonwealth requests this Honorable Court to grant the Commonwealth’s Motion Limiting Defendant’s Alibi Defense at trial to the testimony of the Defendant, Harlow Cuadra, and no other witnesses, based on the Defendant’s failure to meet the requirements of Rule 567 specifically regarding the Defendant’s filing of his eleventh-hour Alibi Notice, as well as the lack of specificity as to possible witnesses that the Defendant may call at trial to support this evolving defense.
Similar Alibis Don’t Require Separate Trials, Prosecutors Say
According to an article in the Citizens' Voice... The similarity of the alibis being considered by accused killers Harlow Cuadra and Joseph Kerekes cannot be used as grounds for a defense motion to have them tried separately, prosecutors argued in a brief filed Thursday.
Attorneys for Cuadra and Kerekes have said the defendants could both claim they were in Room 211 at the Fox Ridge Motel in Plains Township motel the night Bryan Kocis was killed in January 2007 in Dallas Township, 12 miles away.
Cuadra, 27, and Kerekes, 34, both of Virginia Beach, Va., are accused of killing Kocis and later setting fire to his Midland Drive, Dallas Township, home. They face the death penalty and are scheduled to stand trial together, beginning Sept. 2.
Michael Senape, an attorney for Cuadra, disclosed the possible alibi last month in a closed-door meeting with Judge Peter Paul Olszewski Jr., prosecutors and the other defense attorneys on the case. Kerekes’ attorneys made a similar alibi claim in a notice filed in January.
Both defense teams suggested in a brief filed Wednesday that the similar alibis, combined with a deteriorating relationship between Cuadra and Kerekes, will lead to competing, antagonistic defenses at trial.
“The jury will have no choice but to disbelieve the testimony offered on behalf of one of the defendants in order to believe the testimony offered on behalf of the other defendant,” the defense attorneys said.
Cuadra and Kerekes had previously agreed to an alibi defense they referred to as “Plan B,” according to telephone conversations recorded while they were imprisoned at the Virginia Beach Correctional Facility.
Under “Plan B,” Kerekes claimed he stayed at the Fox Ridge Inn sending e-mail messages and viewing Web sites while Cuadra went to visit Kocis. Kerekes said Cuadra arrived at Kocis’ home after it had already been broken into and set on fire. Cuadra drove back to the motel, they packed quickly and fled to Virginia Beach, Kerekes said.
“In this case, Cuadra’s and Kerekes’ alibi defenses are consistent,” prosecutors said. “Neither defendant is pointing the finger at the other. Neither defendant is saying the other committed any crime whatsoever.”
Attorneys for Cuadra and Kerekes have said the defendants could both claim they were in Room 211 at the Fox Ridge Motel in Plains Township motel the night Bryan Kocis was killed in January 2007 in Dallas Township, 12 miles away.
Cuadra, 27, and Kerekes, 34, both of Virginia Beach, Va., are accused of killing Kocis and later setting fire to his Midland Drive, Dallas Township, home. They face the death penalty and are scheduled to stand trial together, beginning Sept. 2.
Michael Senape, an attorney for Cuadra, disclosed the possible alibi last month in a closed-door meeting with Judge Peter Paul Olszewski Jr., prosecutors and the other defense attorneys on the case. Kerekes’ attorneys made a similar alibi claim in a notice filed in January.
Both defense teams suggested in a brief filed Wednesday that the similar alibis, combined with a deteriorating relationship between Cuadra and Kerekes, will lead to competing, antagonistic defenses at trial.
“The jury will have no choice but to disbelieve the testimony offered on behalf of one of the defendants in order to believe the testimony offered on behalf of the other defendant,” the defense attorneys said.
Cuadra and Kerekes had previously agreed to an alibi defense they referred to as “Plan B,” according to telephone conversations recorded while they were imprisoned at the Virginia Beach Correctional Facility.
Under “Plan B,” Kerekes claimed he stayed at the Fox Ridge Inn sending e-mail messages and viewing Web sites while Cuadra went to visit Kocis. Kerekes said Cuadra arrived at Kocis’ home after it had already been broken into and set on fire. Cuadra drove back to the motel, they packed quickly and fled to Virginia Beach, Kerekes said.
“In this case, Cuadra’s and Kerekes’ alibi defenses are consistent,” prosecutors said. “Neither defendant is pointing the finger at the other. Neither defendant is saying the other committed any crime whatsoever.”
Thursday, August 7, 2008
Prosecutors ask PPO to Not Allow Possible Alibi for Cuadra
Today's Citizens' Voice is reporting that prosecutors filed a motion Wednesday asking Luzerne County Judge Peter Paul Olszewski Jr. to preclude attorneys for accused killer Harlow Cuadra from presenting evidence and witnesses to corroborate his possible alibi.
In a notice of possible alibi filed last month, Cuadra’s attorneys, Stephen Menn and Michael Senape, said Cuadra, 27, of Virginia Beach, Va., could claim he was in Room 211 of the Fox Ridge Motel in Plains Township at the time Bryan Kocis was killed in Dallas Township in January 2007.
Under state law, Cuadra’s attorneys were required to file the alibi notice on May 16, at the same time they submitted a series of omnibus pre-trial motions, including requests to suppress evidence, move the location of the trial and separate Cuadra’s trial from that of his co-defendant, Joseph Kerekes, prosecutors said.
“Based on the defendant’s untimely filing of his notice of alibi defense, the Commonwealth asks this court to exclude entirely any other evidence offered by the defendant for the purpose of providing an alibi defense at trial, except for the defendant’s own testimony,” prosecutors said, citing the section of the Pennsylvania Rules of Criminal Procedure that allows judges latitude to limit alibi defenses.
Cuadra and Kerekes, 34, also of Virginia Beach, Va., are accused of killing Kocis, a rival producer of gay pornographic films, and later setting fire to his Midland Drive, Dallas Township, home.
They face the death penalty and are scheduled to stand trial together beginning Sept. 2. Olszewski said he could rule on pre-trial motions within a week.
Kerekes’ attorneys, Shelley Centini and John Pike, filed a similar alibi notice in January and listed potential witnesses from Internet companies to support a theory that he stayed at the motel, sending e-mail messages and viewing Web sites, while Cuadra visited Kocis.
Neither notice indicated Cuadra and Kerekes were together at the motel.
Cuadra’s one-page notice listed no witnesses who could potentially corroborate his alibi story, but the attorneys said they reserved the right to list witnesses on future supplemental filings.
“Given the approaching start date of trial, the Commonwealth would not have sufficient time to investigate the defendant’s witnesses, given the late filing of the notice,” the prosecutors argued.
Late Wednesday, prosecutors filed a list of 93 prospective witnesses they could call to rebut Cuadra’s alibi defense, including investigators, neighbors who said they saw a vehicle rented by Cuadra leaving Kocis’ driveway just before the fire was called into 911, and two men who had settled a lawsuit with Kocis a week before his death.
In a prison telephone conversation with acquaintance Renee Martin, Kerekes said the men, Grant Roy, a former suspect in the killing, and his business partner and lover, Sean Lockhart, had spoken to Cuadra by telephone as he was killing Kocis.
“They were on the phone from San Diego with (Cuadra), like while this was, while that was happening,” Kerekes told Martin.
“While the murder was happening?” Martin said.
“Yes,” Kerekes said. “(Investigators) know that Grant and Brent weren’t there.”
“They were on the phone with him while the murdering was happening?”
“Yes, that’s all knowledge, everyone knows,” Kerekes said.
In a notice of possible alibi filed last month, Cuadra’s attorneys, Stephen Menn and Michael Senape, said Cuadra, 27, of Virginia Beach, Va., could claim he was in Room 211 of the Fox Ridge Motel in Plains Township at the time Bryan Kocis was killed in Dallas Township in January 2007.
Under state law, Cuadra’s attorneys were required to file the alibi notice on May 16, at the same time they submitted a series of omnibus pre-trial motions, including requests to suppress evidence, move the location of the trial and separate Cuadra’s trial from that of his co-defendant, Joseph Kerekes, prosecutors said.
“Based on the defendant’s untimely filing of his notice of alibi defense, the Commonwealth asks this court to exclude entirely any other evidence offered by the defendant for the purpose of providing an alibi defense at trial, except for the defendant’s own testimony,” prosecutors said, citing the section of the Pennsylvania Rules of Criminal Procedure that allows judges latitude to limit alibi defenses.
Cuadra and Kerekes, 34, also of Virginia Beach, Va., are accused of killing Kocis, a rival producer of gay pornographic films, and later setting fire to his Midland Drive, Dallas Township, home.
They face the death penalty and are scheduled to stand trial together beginning Sept. 2. Olszewski said he could rule on pre-trial motions within a week.
Kerekes’ attorneys, Shelley Centini and John Pike, filed a similar alibi notice in January and listed potential witnesses from Internet companies to support a theory that he stayed at the motel, sending e-mail messages and viewing Web sites, while Cuadra visited Kocis.
Neither notice indicated Cuadra and Kerekes were together at the motel.
Cuadra’s one-page notice listed no witnesses who could potentially corroborate his alibi story, but the attorneys said they reserved the right to list witnesses on future supplemental filings.
“Given the approaching start date of trial, the Commonwealth would not have sufficient time to investigate the defendant’s witnesses, given the late filing of the notice,” the prosecutors argued.
Late Wednesday, prosecutors filed a list of 93 prospective witnesses they could call to rebut Cuadra’s alibi defense, including investigators, neighbors who said they saw a vehicle rented by Cuadra leaving Kocis’ driveway just before the fire was called into 911, and two men who had settled a lawsuit with Kocis a week before his death.
In a prison telephone conversation with acquaintance Renee Martin, Kerekes said the men, Grant Roy, a former suspect in the killing, and his business partner and lover, Sean Lockhart, had spoken to Cuadra by telephone as he was killing Kocis.
“They were on the phone from San Diego with (Cuadra), like while this was, while that was happening,” Kerekes told Martin.
“While the murder was happening?” Martin said.
“Yes,” Kerekes said. “(Investigators) know that Grant and Brent weren’t there.”
“They were on the phone with him while the murdering was happening?”
“Yes, that’s all knowledge, everyone knows,” Kerekes said.
Monday, August 4, 2008
Accused Killers’ Words, Actions Tie them to Kocis Murder
The Citizens' Voice is reporting in a rather lengthy story that since they were arrested in May 2007, accused killers Joseph Kerekes and Harlow Cuadra have attempted to place themselves in a number of locations at the time of Bryan Kocis’ murder in Dallas Township on Jan. 24, 2007 — from the Fox Ridge Motel in Plains Township, about 12 miles away, to their home in Virginia Beach, about 385 miles due south.
Cuadra, 26, and Kerekes, 34, both of Virginia Beach, Va., are accused of slashing the neck of Kocis, a rival producer of gay pornographic films, and stabbing his torso nearly 30 times and later setting fire to his Midland Drive home.
They face the death penalty and are scheduled to stand trial together beginning Sept. 2.
In actions and conversations, they tried independently and jointly to create fail-safe alibis and failed at every turn, foiled by prosecution evidence, technology and logic.
Last week, attorneys for Cuadra filed a notice of potential alibi stating he might claim he was at the Fox Ridge Inn at the time Kocis was killed — a claim similar to an alibi being considered by Kerekes.
Luzerne County Judge Peter Paul Olszewski Jr. said he would likely rule by Aug. 12 on a number of pre-trial motions, including requests by both defense teams to suppress potentially incriminating evidence and to have separate trials for Cuadra and Kerekes.
Ultimately, barring a plea agreement, a case dismissal or the defendants’ demise, a jury will decide whether Cuadra and Kerekes are guilty or innocent. For now, the question remains, what of their mutual and mutually exclusive defenses is fact and what is fiction.
These are their stories, with details on how they surfaced and how the evidence stacks up against them.
Harlow Cuadra
At the motel, no witnesses
Alibi: In a notice of possible alibi filed last week, Cuadra’s attorneys, Stephen Menn and Michael Senape, said Cuadra could claim he was in Room 211 of the Fox Ridge Motel in Plains Township at the time of Kocis’ killing.
The one-page notice listed no witnesses who could potentially corroborate Cuadra’s alibi story, but the attorneys did reserve the right to list witnesses on future supplemental filings.
Kerekes’ attorneys filed a similar notice in January and listed potential witnesses from Internet companies to support a theory that he stayed at the motel, sending e-mail messages and viewing Web sites, while Cuadra visited Kocis.
Neither notice indicated Cuadra and Kerekes were together at the motel.
Evidence: Cuadra and Kerekes shared vivid details about Kocis’ killing in conversations recorded by investigators in San Diego in April 2007.
Cuadra and Kerekes met with Grant Roy, a former suspect turned informant, and Sean Lockhart, Roy’s lover and business partner.
Lockhart had acted in gay pornographic films produced by Kocis’ company, Cobra Video. He and Roy had been engaged in a lawsuit over the use of his stage name, Brent Corrigan.
A settlement reached on Jan. 18, 2007, less than a week before the killing, allowed Lockhart to star in movies not involving Cobra Video, in exchange for a payment of 20 percent of the proceeds to Cobra.
Roy asked Cuadra and Kerekes if Kocis felt any pain as he was being killed. After a few moments of silence, Cuadra leaned toward Lockhart and said quietly, “Don’t worry, he went quick.”
Cuadra offered more details the next day, as he walked with Kerekes, Roy and Lockhart along a nude beach in the La Jolla section of San Diego. Roy captured the conversation with a recording device hidden in a car key remote.
“Actually seeing that (expletive) going down, actually it’s sick, but it made me feel better inside,” Cuadra said, referring to Kocis.
“It almost felt like I got revenge and I know that sounds (expletive) up.”
Cuadra first contacted Kocis via e-mail two days before the killing, posing as an inexperienced actor from the Philadelphia area named Danny Moilin.
Cuadra created an e-mail address for the Moilin character and activated a pre-paid cell phone used only to contact Kocis. Cuadra sent photographs to Kocis and requested that they meet to discuss a possible role in a future film project.
Cuadra said during the meeting Kocis had been critical of Lockhart, referring to him as “a little bitch” and “the product.”
Kerekes said Cuadra and Kocis each had a glass of wine during the meeting and stated he believed that Cuadra “slipped him something,” in his drink.
“Don’t feel too bad for him,” Cuadra told Lockhart.
“It’s what kind of made the whole decision kind of easy, almost a little too easy,” Cuadra said. “I should have thought where all those fingers would have pointed, I remember looking at the press. I’m just glad this (expletive) is over.”
During the San Diego conversations, Cuadra and Kerekes described Kocis’ home — the design of his front door and the high-end home entertainment system he owned.
Cell phone data obtained by prosecutors also indicated Cuadra and Kerekes were in Kocis’ neighborhood at the time of the killing and witnesses reported seeing a silver Nissan Xterra rented by Cuadra at the Kocis home between 6:30 and 8:26 p.m.
The meeting between Cuadra and Kocis was scheduled for between 7 and 8 p.m. and Cuadra said he was expecting to arrive around 7:15 p.m.
The Dallas Fire Department was dispatched to the fire at Kocis’ home at 8:34 p.m.
Investigators found more links between Cuadra, Kerekes and the killing in a February search of the Virginia Beach, Va., home where the alleged killers lived, including two Sony digital video cameras that had been taken from Kocis’ home.
An escort call in Virginia
Alibi: Cuadra sent a handwritten note to acquaintance Nep Maliki last year, setting the story line for an alibi in which he claimed to be working as a male escort in Virginia at the time Kocis was killed.
Cuadra told Maliki, who works at a fast food restaurant in the Virginia Beach area, that they had met at Cuadra’s home on the morning of Jan. 24, 2007, the day Kocis was killed.
They were there for about an hour before they showered together and Maliki left, Cuadra said.
“I guess the thing we need to get clear is the time you came over,” Cuadra said in the note. “Did you work early that day after you saw me? At what time did you go into work that day? Please check with your work.”
The note, which Cuadra told Maliki was “for his eyes only,” was included as an exhibit in the prosecutors’ answer to an omnibus pretrial motion filed by Cuadra’s attorneys in March.
Cuadra asked former escort client Howard Hallford to corroborate the Maliki story in a May 2007 interview with police. Hallford agreed, but then backed off, saying he had only seen Cuadra once in a two-week span in mid- to late January 2007.
Evidence: The evidence, witnesses, cell phone data and e-mail records used to disprove the motel alibi placed Cuadra in Dallas Township around the time Kocis was killed.
The uncertainty and unwillingness of Maliki and Hallford to cooperate damaged any corroboration Cuadra may have received. Even if Cuadra and Maliki did meet the morning of Jan. 24 — a possibility muted by Cuadra and Kerekes’ arrival at the Fox Ridge Inn the night before — Cuadra still could have had time to make the seven-and-a-half hour drive from Virginia Beach to Kocis’ home.
Joseph Kerekes
Out of state, out of mind
Alibi: In a telephone conversation recorded by investigators while he was imprisoned at the Virginia Beach Correctional Facility, Kerekes explained to Renee Martin, an acquaintance and former neighbor who has been described by prosecutors as their business associate, that he planned to fight his arrest and eventual extradition to Luzerne County by claiming he was not in Pennsylvania when Kocis was murdered.
Evidence: Kerekes checked into the Fox Ridge Inn in Plains Township with Cuadra on Jan. 23, 2007, and showed a photo identification to the owner, Thakor Patel. Kerekes also indicated to Patel that the vehicle he and Cuadra had arrived in was gray with a Virginia registration. Cuadra rented a silver Nissan Xterra the previous morning from an Enterprise Rent-a-Car office in Virginia Beach, prosecutors said.
On the check-in slip, Kerekes noted that he was from Virginia and originally started to provide an address of “1028 Str,” before crossing it out and giving a different Virginia address, but with a Florida zip code, prosecutors said. Kerekes and Cuadra lived at 1028 Stratem Court in Virginia Beach.
‘Plan B’: a hypothetical alibi
Alibi: After they became disconnected, Kerekes called Martin back and said he was ready to confess the real story of what happened the night Kocis was killed. Martin sug-gested Kerekes tell the story in a hypothetical form — an alibi referred to by the defendants and prosecutors as “Plan B.”
“OK, once upon a time there was a gay escort couple that, ya know, once upon a time that thought maybe working with this movie producer would be good, whereas he, you know, he had access to other young stars that would enhance one of the two’s career, so they set up an appointment to meet,” Kerekes told Martin.
Kerekes said one of the men went to meet the producer while the other stayed in a hotel room. The hypothetical story matches up to Cuadra visiting Kocis and Kerekes staying at the Fox Ridge Inn, prosecutors said.
“When he approached the home, obviously there had been an intrusion, and the door was open,” Kerekes said. “Hypothetically and supposedly then, he found what was there, and he, supposedly and hypothetically, ran and came back to the older one, which was in the hotel and they were scared.”
Evidence: The phone data obtained by prosecutors indicated Cuadra and Kerekes were in Kocis’ neighborhood at the time of the killing. Their own admissions in the San Diego conversations, as well as the other evidence used to disprove Cuadra’s motel alibi, show an intimate knowledge of the Kocis’ home and the events surrounding his death.
Staying in, sending e-mails
Alibi: Kerekes previously suggested he had been making an escort call, sending e-mails and visiting Web sites at the Fox Ridge Inn when the killing occurred.
Kerekes sent an e-mail to the alleged client, Matthew Brannon of Fayetteville, N.C., at-tempting to bolster his Fox Ridge Motel claim, four minutes after the fire at Kocis’ house was called in to 911 and 10 to 13 minutes after a neighbor witnessed the Nissan Xterra backing out of Kocis’ driveway, prosecutors said.
Evidence: Brannon, a computer expert, said he was not in Pennsylvania on Jan. 24, 2007, and adamantly denied to investigators being with Kerekes that night.
He said the e-mail from Kerekes could have been sent from anywhere using a mobile air card. State police confirmed continuous Internet connectivity is available throughout the area where Kocis’ house was located.
Cuadra, 26, and Kerekes, 34, both of Virginia Beach, Va., are accused of slashing the neck of Kocis, a rival producer of gay pornographic films, and stabbing his torso nearly 30 times and later setting fire to his Midland Drive home.
They face the death penalty and are scheduled to stand trial together beginning Sept. 2.
In actions and conversations, they tried independently and jointly to create fail-safe alibis and failed at every turn, foiled by prosecution evidence, technology and logic.
Last week, attorneys for Cuadra filed a notice of potential alibi stating he might claim he was at the Fox Ridge Inn at the time Kocis was killed — a claim similar to an alibi being considered by Kerekes.
Luzerne County Judge Peter Paul Olszewski Jr. said he would likely rule by Aug. 12 on a number of pre-trial motions, including requests by both defense teams to suppress potentially incriminating evidence and to have separate trials for Cuadra and Kerekes.
Ultimately, barring a plea agreement, a case dismissal or the defendants’ demise, a jury will decide whether Cuadra and Kerekes are guilty or innocent. For now, the question remains, what of their mutual and mutually exclusive defenses is fact and what is fiction.
These are their stories, with details on how they surfaced and how the evidence stacks up against them.
Harlow Cuadra
At the motel, no witnesses
Alibi: In a notice of possible alibi filed last week, Cuadra’s attorneys, Stephen Menn and Michael Senape, said Cuadra could claim he was in Room 211 of the Fox Ridge Motel in Plains Township at the time of Kocis’ killing.
The one-page notice listed no witnesses who could potentially corroborate Cuadra’s alibi story, but the attorneys did reserve the right to list witnesses on future supplemental filings.
Kerekes’ attorneys filed a similar notice in January and listed potential witnesses from Internet companies to support a theory that he stayed at the motel, sending e-mail messages and viewing Web sites, while Cuadra visited Kocis.
Neither notice indicated Cuadra and Kerekes were together at the motel.
Evidence: Cuadra and Kerekes shared vivid details about Kocis’ killing in conversations recorded by investigators in San Diego in April 2007.
Cuadra and Kerekes met with Grant Roy, a former suspect turned informant, and Sean Lockhart, Roy’s lover and business partner.
Lockhart had acted in gay pornographic films produced by Kocis’ company, Cobra Video. He and Roy had been engaged in a lawsuit over the use of his stage name, Brent Corrigan.
A settlement reached on Jan. 18, 2007, less than a week before the killing, allowed Lockhart to star in movies not involving Cobra Video, in exchange for a payment of 20 percent of the proceeds to Cobra.
Roy asked Cuadra and Kerekes if Kocis felt any pain as he was being killed. After a few moments of silence, Cuadra leaned toward Lockhart and said quietly, “Don’t worry, he went quick.”
Cuadra offered more details the next day, as he walked with Kerekes, Roy and Lockhart along a nude beach in the La Jolla section of San Diego. Roy captured the conversation with a recording device hidden in a car key remote.
“Actually seeing that (expletive) going down, actually it’s sick, but it made me feel better inside,” Cuadra said, referring to Kocis.
“It almost felt like I got revenge and I know that sounds (expletive) up.”
Cuadra first contacted Kocis via e-mail two days before the killing, posing as an inexperienced actor from the Philadelphia area named Danny Moilin.
Cuadra created an e-mail address for the Moilin character and activated a pre-paid cell phone used only to contact Kocis. Cuadra sent photographs to Kocis and requested that they meet to discuss a possible role in a future film project.
Cuadra said during the meeting Kocis had been critical of Lockhart, referring to him as “a little bitch” and “the product.”
Kerekes said Cuadra and Kocis each had a glass of wine during the meeting and stated he believed that Cuadra “slipped him something,” in his drink.
“Don’t feel too bad for him,” Cuadra told Lockhart.
“It’s what kind of made the whole decision kind of easy, almost a little too easy,” Cuadra said. “I should have thought where all those fingers would have pointed, I remember looking at the press. I’m just glad this (expletive) is over.”
During the San Diego conversations, Cuadra and Kerekes described Kocis’ home — the design of his front door and the high-end home entertainment system he owned.
Cell phone data obtained by prosecutors also indicated Cuadra and Kerekes were in Kocis’ neighborhood at the time of the killing and witnesses reported seeing a silver Nissan Xterra rented by Cuadra at the Kocis home between 6:30 and 8:26 p.m.
The meeting between Cuadra and Kocis was scheduled for between 7 and 8 p.m. and Cuadra said he was expecting to arrive around 7:15 p.m.
The Dallas Fire Department was dispatched to the fire at Kocis’ home at 8:34 p.m.
Investigators found more links between Cuadra, Kerekes and the killing in a February search of the Virginia Beach, Va., home where the alleged killers lived, including two Sony digital video cameras that had been taken from Kocis’ home.
An escort call in Virginia
Alibi: Cuadra sent a handwritten note to acquaintance Nep Maliki last year, setting the story line for an alibi in which he claimed to be working as a male escort in Virginia at the time Kocis was killed.
Cuadra told Maliki, who works at a fast food restaurant in the Virginia Beach area, that they had met at Cuadra’s home on the morning of Jan. 24, 2007, the day Kocis was killed.
They were there for about an hour before they showered together and Maliki left, Cuadra said.
“I guess the thing we need to get clear is the time you came over,” Cuadra said in the note. “Did you work early that day after you saw me? At what time did you go into work that day? Please check with your work.”
The note, which Cuadra told Maliki was “for his eyes only,” was included as an exhibit in the prosecutors’ answer to an omnibus pretrial motion filed by Cuadra’s attorneys in March.
Cuadra asked former escort client Howard Hallford to corroborate the Maliki story in a May 2007 interview with police. Hallford agreed, but then backed off, saying he had only seen Cuadra once in a two-week span in mid- to late January 2007.
Evidence: The evidence, witnesses, cell phone data and e-mail records used to disprove the motel alibi placed Cuadra in Dallas Township around the time Kocis was killed.
The uncertainty and unwillingness of Maliki and Hallford to cooperate damaged any corroboration Cuadra may have received. Even if Cuadra and Maliki did meet the morning of Jan. 24 — a possibility muted by Cuadra and Kerekes’ arrival at the Fox Ridge Inn the night before — Cuadra still could have had time to make the seven-and-a-half hour drive from Virginia Beach to Kocis’ home.
Joseph Kerekes
Out of state, out of mind
Alibi: In a telephone conversation recorded by investigators while he was imprisoned at the Virginia Beach Correctional Facility, Kerekes explained to Renee Martin, an acquaintance and former neighbor who has been described by prosecutors as their business associate, that he planned to fight his arrest and eventual extradition to Luzerne County by claiming he was not in Pennsylvania when Kocis was murdered.
Evidence: Kerekes checked into the Fox Ridge Inn in Plains Township with Cuadra on Jan. 23, 2007, and showed a photo identification to the owner, Thakor Patel. Kerekes also indicated to Patel that the vehicle he and Cuadra had arrived in was gray with a Virginia registration. Cuadra rented a silver Nissan Xterra the previous morning from an Enterprise Rent-a-Car office in Virginia Beach, prosecutors said.
On the check-in slip, Kerekes noted that he was from Virginia and originally started to provide an address of “1028 Str,” before crossing it out and giving a different Virginia address, but with a Florida zip code, prosecutors said. Kerekes and Cuadra lived at 1028 Stratem Court in Virginia Beach.
‘Plan B’: a hypothetical alibi
Alibi: After they became disconnected, Kerekes called Martin back and said he was ready to confess the real story of what happened the night Kocis was killed. Martin sug-gested Kerekes tell the story in a hypothetical form — an alibi referred to by the defendants and prosecutors as “Plan B.”
“OK, once upon a time there was a gay escort couple that, ya know, once upon a time that thought maybe working with this movie producer would be good, whereas he, you know, he had access to other young stars that would enhance one of the two’s career, so they set up an appointment to meet,” Kerekes told Martin.
Kerekes said one of the men went to meet the producer while the other stayed in a hotel room. The hypothetical story matches up to Cuadra visiting Kocis and Kerekes staying at the Fox Ridge Inn, prosecutors said.
“When he approached the home, obviously there had been an intrusion, and the door was open,” Kerekes said. “Hypothetically and supposedly then, he found what was there, and he, supposedly and hypothetically, ran and came back to the older one, which was in the hotel and they were scared.”
Evidence: The phone data obtained by prosecutors indicated Cuadra and Kerekes were in Kocis’ neighborhood at the time of the killing. Their own admissions in the San Diego conversations, as well as the other evidence used to disprove Cuadra’s motel alibi, show an intimate knowledge of the Kocis’ home and the events surrounding his death.
Staying in, sending e-mails
Alibi: Kerekes previously suggested he had been making an escort call, sending e-mails and visiting Web sites at the Fox Ridge Inn when the killing occurred.
Kerekes sent an e-mail to the alleged client, Matthew Brannon of Fayetteville, N.C., at-tempting to bolster his Fox Ridge Motel claim, four minutes after the fire at Kocis’ house was called in to 911 and 10 to 13 minutes after a neighbor witnessed the Nissan Xterra backing out of Kocis’ driveway, prosecutors said.
Evidence: Brannon, a computer expert, said he was not in Pennsylvania on Jan. 24, 2007, and adamantly denied to investigators being with Kerekes that night.
He said the e-mail from Kerekes could have been sent from anywhere using a mobile air card. State police confirmed continuous Internet connectivity is available throughout the area where Kocis’ house was located.
Thursday, July 31, 2008
Cuadra, Kerekes Mull Similar Alibis
The Citizens' Voice reports that Attorneys for Harlow Cuadra said Wednesday the accused killer might claim he was at a Plains Township motel the night Bryan Kocis was killed in Dallas Township in January 2007 — the same potential alibi defense being considered by co-defendant Joseph Kerekes.
In Cuadra’s notice of alibi defense, filed Wednesday after the conclusion of a multi-part hearing on evidence suppression, and Kerekes’ alibi notice, filed in January, both defendants claim they were in Room 211 at the Fox Ridge Motel, about 12 miles from Kocis’ Midland Drive home.
Neither notice said if Cuadra or Kerekes would claim they were in the room together at the time of the killing, though Kerekes has indicated to Renee Martin, an acquaintance and former neighbor who has been described by prosecutors as their business associate, that he stayed at the motel while Cuadra went to visit Kocis.
The conflicting alibi accounts could bolster a defense argument, made at a previous suppression hearing, that Cuadra and Kerekes should be tried separately. A growing rift between the former lovers and business partners could jeopardize their defense if they are tried together, as prosecutors have advocated, the attorneys said.
Kerekes, 34, and Harlow Cuadra, 26, both of Virginia Beach, Va., are accused of slashing the neck of Kocis, a rival producer of gay pornographic films, to the point of near decapitation, stabbing his torso nearly 30 times and later setting fire to his home. They face the death penalty and are scheduled to stand trial together, beginning Sept. 2.
Kerekes discussed several possible alibis with Martin, including a disproved theory that he was not in Pennsylvania at the time. Kerekes mentioned the Fox Ridge Motel in a hypothetical situation he described for her during one telephone conversation while an inmate at the Virginia Beach Correctional Facility.
“Can I tell you exactly what happened or should I, should I keep my mouth shut?” Kerekes said.
Martin suggested Kerekes tell the story in a hypothetical form.
“OK, once upon a time there was a gay escort couple that, ya know, once upon a time that thought maybe working with this movie producer would be good, where as he, you know, he had access to other young stars that would enhance one of the two’s career, so they set up an appointment to meet.”
Kerekes said one of the men went to meet the producer while the other stayed at a hotel that had been rented. The hypothetical story matches up to Cuadra visiting Kocis and Kerekes staying at the Fox Ridge Inn, prosecutors said.
“When he approached the home, obviously there had been an intrusion, and the door was open, hypothetically and supposedly then, he found what was there, and he, supposedly and hypothetically, ran and came back to the older one, which was in the hotel and they were scared.”
Cuadra ordered an online background check of Kocis days before the murder, sent e-mail messages and photographs to Kocis, placed telephone calls to him on a cell phone purchased and used only to call Kocis, and rented a vehicle that was seen by witnesses in Kocis’ driveway around the time of the killing, prosecutors said.
In another telephone conversation, Martin alluded to the possibility Grant Roy, a former suspect in the killing who testified at an evidence suppression hearing Thursday, and his business partner and former lover, Sean Lockhart, had been at Kocis’ home.
Lockhart had acted in gay pornographic films produced by Kocis’ company, Cobra Video.
He and Roy had settled a lawsuit with Kocis on Jan. 18, 2007, allowing Lockhart to star in movies not involving Cobra Video, in exchange for a payment of 20 percent of the proceeds to Cobra.
Kerekes said Roy and Lockhart were not directly involved, but had spoken to Cuadra by telephone.
“They were on the phone from San Diego with (Cuadra), like while this was, while that was happening,” Kerekes told Martin.
“While the murder was happening?” Martin said.
“Yes,” Kerekes said. “(Investigators) know that Grant and Brent weren’t there.”
“They were on the phone with him while the murdering was happening?”
“Yes, that’s all knowledge, everyone knows,” Kerekes said.
In Cuadra’s notice of alibi defense, filed Wednesday after the conclusion of a multi-part hearing on evidence suppression, and Kerekes’ alibi notice, filed in January, both defendants claim they were in Room 211 at the Fox Ridge Motel, about 12 miles from Kocis’ Midland Drive home.
Neither notice said if Cuadra or Kerekes would claim they were in the room together at the time of the killing, though Kerekes has indicated to Renee Martin, an acquaintance and former neighbor who has been described by prosecutors as their business associate, that he stayed at the motel while Cuadra went to visit Kocis.
The conflicting alibi accounts could bolster a defense argument, made at a previous suppression hearing, that Cuadra and Kerekes should be tried separately. A growing rift between the former lovers and business partners could jeopardize their defense if they are tried together, as prosecutors have advocated, the attorneys said.
Kerekes, 34, and Harlow Cuadra, 26, both of Virginia Beach, Va., are accused of slashing the neck of Kocis, a rival producer of gay pornographic films, to the point of near decapitation, stabbing his torso nearly 30 times and later setting fire to his home. They face the death penalty and are scheduled to stand trial together, beginning Sept. 2.
Kerekes discussed several possible alibis with Martin, including a disproved theory that he was not in Pennsylvania at the time. Kerekes mentioned the Fox Ridge Motel in a hypothetical situation he described for her during one telephone conversation while an inmate at the Virginia Beach Correctional Facility.
“Can I tell you exactly what happened or should I, should I keep my mouth shut?” Kerekes said.
Martin suggested Kerekes tell the story in a hypothetical form.
“OK, once upon a time there was a gay escort couple that, ya know, once upon a time that thought maybe working with this movie producer would be good, where as he, you know, he had access to other young stars that would enhance one of the two’s career, so they set up an appointment to meet.”
Kerekes said one of the men went to meet the producer while the other stayed at a hotel that had been rented. The hypothetical story matches up to Cuadra visiting Kocis and Kerekes staying at the Fox Ridge Inn, prosecutors said.
“When he approached the home, obviously there had been an intrusion, and the door was open, hypothetically and supposedly then, he found what was there, and he, supposedly and hypothetically, ran and came back to the older one, which was in the hotel and they were scared.”
Cuadra ordered an online background check of Kocis days before the murder, sent e-mail messages and photographs to Kocis, placed telephone calls to him on a cell phone purchased and used only to call Kocis, and rented a vehicle that was seen by witnesses in Kocis’ driveway around the time of the killing, prosecutors said.
In another telephone conversation, Martin alluded to the possibility Grant Roy, a former suspect in the killing who testified at an evidence suppression hearing Thursday, and his business partner and former lover, Sean Lockhart, had been at Kocis’ home.
Lockhart had acted in gay pornographic films produced by Kocis’ company, Cobra Video.
He and Roy had settled a lawsuit with Kocis on Jan. 18, 2007, allowing Lockhart to star in movies not involving Cobra Video, in exchange for a payment of 20 percent of the proceeds to Cobra.
Kerekes said Roy and Lockhart were not directly involved, but had spoken to Cuadra by telephone.
“They were on the phone from San Diego with (Cuadra), like while this was, while that was happening,” Kerekes told Martin.
“While the murder was happening?” Martin said.
“Yes,” Kerekes said. “(Investigators) know that Grant and Brent weren’t there.”
“They were on the phone with him while the murdering was happening?”
“Yes, that’s all knowledge, everyone knows,” Kerekes said.
Sunday, July 20, 2008
So What's the Next Plan?
Harlow Cuadra and Joseph Kerekes have already thrown away their "plan a" defense, in which both would deny being in Pennsylvania the day/night of the murder... that's where the run for alibi witnesses came from... and failed... not just once, but two... three... and four times.
Apparently once they realized that "plan a" wasn't going to work, Harlow and Joe decided that it was time for "plan b"... in which they would admit to being in Pennsylvania, but that it was only Harlow who went to Bryan Kocis' house... smelled smoke... saw a body... heard a noise upstairs, and left... all while Joe was conveniently sitting at the Fox Ridge Inn sending emails. (Reference: 1, 2 & 3 ... just to name a few).
With all of the revelations that have come out recently, one has to wonder how Harlow & Joe think "plan b" is going to work either. I can only imagine what "plan c" will entail... assuming that they try to change their story once again... though nothing would surprise me at this point.
Personally... I think "plan c" is going to be nothing more than finger-pointing towards each other... "he did it".
Apparently once they realized that "plan a" wasn't going to work, Harlow and Joe decided that it was time for "plan b"... in which they would admit to being in Pennsylvania, but that it was only Harlow who went to Bryan Kocis' house... smelled smoke... saw a body... heard a noise upstairs, and left... all while Joe was conveniently sitting at the Fox Ridge Inn sending emails. (Reference: 1, 2 & 3 ... just to name a few).
With all of the revelations that have come out recently, one has to wonder how Harlow & Joe think "plan b" is going to work either. I can only imagine what "plan c" will entail... assuming that they try to change their story once again... though nothing would surprise me at this point.
Personally... I think "plan c" is going to be nothing more than finger-pointing towards each other... "he did it".
Monday, July 14, 2008
Alibi Witness #4
In their fourth attempt in trying to find an alibi, Harlow Cuadra and Joseph Kerekes reached out to David Michaels, for yet another fake alibi. The following are the e-mails concerning this fake alibi:
Received: from [70.10.18.170] by web51408.mail.yahoo.com via HTTP; Mon, 04 Dec 2006 14:01:29 PST
Date: Mon, 4 Dec 2006 14:01:28 -0800 (PST)
From: NME correspondence
subject: Re: membership fees
TO: David Michaels
In-Reply-To:
wonderful sorry about misunderstanding
David Michaels
wrote: Joe
I put a check in the mail today for the internet service. AS I told you on Friday I did have it to give to Harlow. I am sorry for the mix up and I look forward to using your site. I will 'be back in town soon and hope to see you and Harlow.
David
PS I put a little something extra for you two for the holidays. Merry Christmas
---
Received: from [70.174.54.38] by web51407.mail.yahoo.com via HTTP; Thu, 25 Jan 2007 12:28:11 PST
Date: thu, 25 Jan 2007 12:28:10 -0800 (PST)
From: NME correspondence
subject: Hello
TO: drmdogone@yahoo.com
sorry dave no one is available till saturday would you like Harlow then?
Joe
---
Received: from [64.209.56.10] by web51410.mail.yahoo.com via HTTP; Tue 13 Feb 2007 15:33:52 PST
Date: Tue, 13 Feb 2007 15:33:52 -0800 (PST)
From: NME correspondence
subject: Re: Let me know
To: David Michaels
In-Reply-To:
david can u please call my lawyer and let him know you saw harlow the morning after his number 757-676-6999
Joe
David Michaelswrote:
Joe and Harlow
I will be in Athens Ga for the remainder of the week.
If you two need to get away, come on down. I have a very nice suite and nothing to do :) In the meantime whatever I can do, I will. Take care of yourself.
David
--- NME
correspondence wrote:
> thanks david we may call on your gracious offer
>
> Harlow and Joe
>
> David
Michaels wrote:
> Joe and Harlow
>
> I just saw the info on the internet about Harlow. I th1nk Harlow
---
Received: from [64.209.56.10] by web51402.mail.yahoo.com via HTTP; Wed, 14 Feb 2007 02:07:55 PST
Date: Wed, 14 Feb 2007 02:07:55 -0800 (PST)
From: NME correspondence
subject: actually
TO: drmdogone@yahoo.com
it would help verify harlows VERY much if you would please call my lawyer barry taylor and state you were with harlow the following morning
thanks
Joe
Barry taylor...757-430-1200 office or 757 the cell i gave
---
Received: from [65.8.143.237] by web51401.mail.yahoo.com via HTTP; Thu, 15 Feb 2007 16:34:15 PST
Date: Thu, 15 Feb 2007 16:34:14 -0800 (PST)
From: NME correspondence
subject: hello its joe andharlow
To: drmdogone@yahoo.com
if you still want to help we could really use you please give us a
number we can call you at Harlow needs to talk with you
Harlow & joe
---
Received: from [207.244.168.2J by web51412.mail.yahoo.com via HTTP; Sat, 17 Feb 2007 06:35:55 PST
Date: Sat, 17 Feb 2007 06:35:55 -0800 (PST)
From: NME correspondence
subject: please call harlow at
To: drmdogone@yahoo.com
804-244-0820
---
Received: from [69.84.124.207] by web51405.mail.yahoo.com via HTTP; Thu, 22 Feb 2007 09:40:05 PST
Date: Thu, 22 Feb 2007 09:40:01 -0800 (PST)
From: NME correspondence
subject: Re: call on Friday
To: David Michaels
In-Reply-To:
there is obviously no urgency in your desire to belp dont bother
David Michaelswrote:
Joe and Harlow
I will finally be in a location where I can talk at length on Friday evening. Are you guys on the west coast or east coast now? Let me know so that I can call at the appropriate time.
Dave
---
Received: from [66.162.150.4J by web38612.mail.mud.yahoo.com via HTTP; Mon, 05 Mar 2007 08:23:35 PST
Date: Mon, 5 Mar 2007 08:23:35 -0800 (PST)
From: David Michaels
subject: Friday
To: Joe Kerekes
Joe and Harlow
I assume the last few weeks have been hard for you two. I am sending this last email offer to help if you still need me. I checked in to the DoubleTree on Wednesday January 24th and did not check out until Friday the 26th. I am offering an alibi for Harlow during any of that time period if he needs it.
I was on vacation with my famlly during the first part of February and I could not easily contact you. The one phone call that I tried to make I was almost caught. I hope you two understand.
I do not believe any of the crap on the internet. Harlow had nothing to gain from any of this. If you do not need my help I wish you both well.
I still feel you are both the best
Dave
Received: from [70.10.18.170] by web51408.mail.yahoo.com via HTTP; Mon, 04 Dec 2006 14:01:29 PST
Date: Mon, 4 Dec 2006 14:01:28 -0800 (PST)
From: NME correspondence
subject: Re: membership fees
TO: David Michaels
In-Reply-To:
wonderful sorry about misunderstanding
David Michaels
I put a check in the mail today for the internet service. AS I told you on Friday I did have it to give to Harlow. I am sorry for the mix up and I look forward to using your site. I will 'be back in town soon and hope to see you and Harlow.
David
PS I put a little something extra for you two for the holidays. Merry Christmas
---
Received: from [70.174.54.38] by web51407.mail.yahoo.com via HTTP; Thu, 25 Jan 2007 12:28:11 PST
Date: thu, 25 Jan 2007 12:28:10 -0800 (PST)
From: NME correspondence
subject: Hello
TO: drmdogone@yahoo.com
sorry dave no one is available till saturday would you like Harlow then?
Joe
---
Received: from [64.209.56.10] by web51410.mail.yahoo.com via HTTP; Tue 13 Feb 2007 15:33:52 PST
Date: Tue, 13 Feb 2007 15:33:52 -0800 (PST)
From: NME correspondence
subject: Re: Let me know
To: David Michaels
In-Reply-To:
david can u please call my lawyer and let him know you saw harlow the morning after his number 757-676-6999
Joe
David Michaels
Joe and Harlow
I will be in Athens Ga for the remainder of the week.
If you two need to get away, come on down. I have a very nice suite and nothing to do :) In the meantime whatever I can do, I will. Take care of yourself.
David
--- NME
correspondence wrote:
> thanks david we may call on your gracious offer
>
> Harlow and Joe
>
> David
Michaels wrote:
> Joe and Harlow
>
> I just saw the info on the internet about Harlow. I th1nk Harlow
---
Received: from [64.209.56.10] by web51402.mail.yahoo.com via HTTP; Wed, 14 Feb 2007 02:07:55 PST
Date: Wed, 14 Feb 2007 02:07:55 -0800 (PST)
From: NME correspondence
subject: actually
TO: drmdogone@yahoo.com
it would help verify harlows VERY much if you would please call my lawyer barry taylor and state you were with harlow the following morning
thanks
Joe
Barry taylor...757-430-1200 office or 757 the cell i gave
---
Received: from [65.8.143.237] by web51401.mail.yahoo.com via HTTP; Thu, 15 Feb 2007 16:34:15 PST
Date: Thu, 15 Feb 2007 16:34:14 -0800 (PST)
From: NME correspondence
subject: hello its joe andharlow
To: drmdogone@yahoo.com
if you still want to help we could really use you please give us a
number we can call you at Harlow needs to talk with you
Harlow & joe
---
Received: from [207.244.168.2J by web51412.mail.yahoo.com via HTTP; Sat, 17 Feb 2007 06:35:55 PST
Date: Sat, 17 Feb 2007 06:35:55 -0800 (PST)
From: NME correspondence
subject: please call harlow at
To: drmdogone@yahoo.com
804-244-0820
---
Received: from [69.84.124.207] by web51405.mail.yahoo.com via HTTP; Thu, 22 Feb 2007 09:40:05 PST
Date: Thu, 22 Feb 2007 09:40:01 -0800 (PST)
From: NME correspondence
subject: Re: call on Friday
To: David Michaels
In-Reply-To:
there is obviously no urgency in your desire to belp dont bother
David Michaels
Joe and Harlow
I will finally be in a location where I can talk at length on Friday evening. Are you guys on the west coast or east coast now? Let me know so that I can call at the appropriate time.
Dave
---
Received: from [66.162.150.4J by web38612.mail.mud.yahoo.com via HTTP; Mon, 05 Mar 2007 08:23:35 PST
Date: Mon, 5 Mar 2007 08:23:35 -0800 (PST)
From: David Michaels
subject: Friday
To: Joe Kerekes
Joe and Harlow
I assume the last few weeks have been hard for you two. I am sending this last email offer to help if you still need me. I checked in to the DoubleTree on Wednesday January 24th and did not check out until Friday the 26th. I am offering an alibi for Harlow during any of that time period if he needs it.
I was on vacation with my famlly during the first part of February and I could not easily contact you. The one phone call that I tried to make I was almost caught. I hope you two understand.
I do not believe any of the crap on the internet. Harlow had nothing to gain from any of this. If you do not need my help I wish you both well.
I still feel you are both the best
Dave
Sunday, July 13, 2008
Joe's Alibi Witness Interview(s)
Synopsis: On 1-30-2008 Attorney's for Joseph Kerekes filed a notice in which indicated that Matthew Brannon may be an alibi witness for Kerekes. On 02-01-2008 Brannon indicates that he has no knowledge of the reason he may be considered an Alibi Witness for Kerekes.
Details: On 02-01-2008 this officer contacted Brannon reference this investigation, Brannon adviced this officer that he was not in the company of Joseph Kerekes or Harlow Cuadra on January 24, 2007. He did not recall any personal contacts with them on said date. Brannon indicated that he was previously interviewed by the Pa. State Police regarding Kerekes and Cuadra and reported information that he had within his knowledge information regarding January 24, 2007 was previously reported on HAR page 271.
Brannon also stated that Cuadra owed him approximately $4,000 which prepaid for a booking. Brannon also stated that he believes that he was being deceived by Cuadra and the person representing to be Mark or Trent.
Brannon sent this officer two emails regarding the aforementioned paragraph. Brannon also forwarded this officer emails which he had saved from Cuadra and/or Kerekes.
Details: On 02-01-2008 this officer contacted Brannon reference this investigation, Brannon adviced this officer that he was not in the company of Joseph Kerekes or Harlow Cuadra on January 24, 2007. He did not recall any personal contacts with them on said date. Brannon indicated that he was previously interviewed by the Pa. State Police regarding Kerekes and Cuadra and reported information that he had within his knowledge information regarding January 24, 2007 was previously reported on HAR page 271.
Brannon also stated that Cuadra owed him approximately $4,000 which prepaid for a booking. Brannon also stated that he believes that he was being deceived by Cuadra and the person representing to be Mark or Trent.
Brannon sent this officer two emails regarding the aforementioned paragraph. Brannon also forwarded this officer emails which he had saved from Cuadra and/or Kerekes.
Joe's Alibi Witness Interview (2)
SYNOPSIS: BRANNON had email communication with CUADRA during January 2007, including January 24th, 2007 near the time of the homicide. He confirmed the email accounts of harlowrcuadra@excite.com, stareyes23510@yahoo.com, and party757@yahoo.com were accounts used in these communications. There were three emails sent on January 24th, 2007 two originated from IP address 70.10.229.19 and the other being 68.242.32.189.
DETAILS: After reviewing the emails of Harlow CUADRA related to the harlowrcuadra@excite.com account, one of the emails was sent to wade_70@hotmail.com on January 24th, 2007 at 17:03:20 EST with associated IP address of 70.10.229.19.
On 03/06/2007 at approx. 12:05 hrs. I sent an email to wade_70@hotmail.com requesting that he contact me via telephone. He returned this telephone call and spoke to Tpr. Michael GOWNLEY who is involved in this investigation and asked BRANNON some preliminary information. Refer to Tpr. GOWNLEY's report of his interview with BRANNON.
At approx. 1330 hrs. I called BRANNON via telephone at XXX-XXX-XXX. He related the wade 70@hotmail.com was his email address and confirmed email communications with Harlow CUADRA and the business owner of Norfolk Male Escorts named Mark. He stated that he met with CUADRA at the residence of 1028 Stratem Ct, Virginia Beach, Va on January 19th, 2007 and January 20th, 2007. He said he saw the news reports relating to the homicide and saw CUADRA's picture on the television, and figured a police officer would be in contact with him. He indicated that he paid for sexual encounters with Harlow CUADRA. His appointments in January 2007 were pre-booked for a price of $2400 which he paid in November or December of 2006.
BRANNON related that he has some of the emails saved when he communicated with Harlow CUADRA. The email addresses that he can recall are harlowrcuadra@excite.com, stareyes23510@yahoo.com, and party757@yahoo.com. He emailed and faxed some email communications with CUADRA. An email was sent on January 24th, 2007 at 17:36:36 PST or 20:36:36 EST, on the date of the homicide. This email was from party757@yahoo.com to wade70@hotmail.com. It should noted that this email is related to the email archive found during the forensic examination of item #51 on property number P17225G. This email was sent from IP address 70.10.229.19 which is registered to Harlow CUADRA's Sprint wireless air card. This archive also shows a later email on January 24th, 2007 at 20:03:59 PST or 23:03:59 EST, this email originated from IP address 68.242.32.189.
BRANNON stated that he also talked via internet and telephone with a person who identified himself as Mark. BRANNON had never seen Mark at the residence only Harlow and "Trent". He suspected that Mark may not exist but did not press the issue with Harlow. He suspected this because Harlow said that Mark owned everything, the business, house, and the cars. Then on 01/19/2007 Harlow picked him up at the Hilton and they were pulled over by the Virginia Beach PD for window tint and were given a citation. BRANNON observed several other citations in the vehicle and CUADRA said that Mark has a lawyer that will take care of them. BRANNON observed that the vehicle was registered in CUADRA's name. He said that Mark put the car in his name due to legal issues. BRANNON thinks the time of the traffic stop was at approx. 14:30 hrs on 01/19/2007.
While at the residence BRANNON recalled some of the conversations with CUADRA.
CUADRA talked about returning from a Las Vegas trip where he attended a convention. He had lost his plane tickets and boarding passes from Southwest Airlines and Mark had to buy new ones.
CUADRA talked about making a movie with a gay porn star named Brent Corrigan. It sounded like it would be happening soon but CUADRA did not say specifically.
CUADRA talked about Corrigan making a movie with Falcon Studio's called The Velvet Mafia, but they could not use his name and Corrigan was mad about that.
CUADRA said he was a Navy Corpsman, had been hurt and was getting out in a few months.
CUADRA also talked about Mark having him put a gym together to work out.
BRANNON received an email on January 24th, 2007, from CUADRA's party757@yahoo.com account. This seemed odd because Harlow was asking for money to attend a webmaster school for his website boybatter, he thought he might be getting scammed. CUADRA was asking to charge $1,000 to his credit card, which he allowed. BRANNON also was traveling to the Newport News Area in March 2007 to teach a military class and prepaid $5,500 on February 8th, or 9th 2007 for several appointments with CUADRA.
BRANNON related that he would be available for interview in person if needed.
DETAILS: After reviewing the emails of Harlow CUADRA related to the harlowrcuadra@excite.com account, one of the emails was sent to wade_70@hotmail.com on January 24th, 2007 at 17:03:20 EST with associated IP address of 70.10.229.19.
On 03/06/2007 at approx. 12:05 hrs. I sent an email to wade_70@hotmail.com requesting that he contact me via telephone. He returned this telephone call and spoke to Tpr. Michael GOWNLEY who is involved in this investigation and asked BRANNON some preliminary information. Refer to Tpr. GOWNLEY's report of his interview with BRANNON.
At approx. 1330 hrs. I called BRANNON via telephone at XXX-XXX-XXX. He related the wade 70@hotmail.com was his email address and confirmed email communications with Harlow CUADRA and the business owner of Norfolk Male Escorts named Mark. He stated that he met with CUADRA at the residence of 1028 Stratem Ct, Virginia Beach, Va on January 19th, 2007 and January 20th, 2007. He said he saw the news reports relating to the homicide and saw CUADRA's picture on the television, and figured a police officer would be in contact with him. He indicated that he paid for sexual encounters with Harlow CUADRA. His appointments in January 2007 were pre-booked for a price of $2400 which he paid in November or December of 2006.
BRANNON related that he has some of the emails saved when he communicated with Harlow CUADRA. The email addresses that he can recall are harlowrcuadra@excite.com, stareyes23510@yahoo.com, and party757@yahoo.com. He emailed and faxed some email communications with CUADRA. An email was sent on January 24th, 2007 at 17:36:36 PST or 20:36:36 EST, on the date of the homicide. This email was from party757@yahoo.com to wade70@hotmail.com. It should noted that this email is related to the email archive found during the forensic examination of item #51 on property number P17225G. This email was sent from IP address 70.10.229.19 which is registered to Harlow CUADRA's Sprint wireless air card. This archive also shows a later email on January 24th, 2007 at 20:03:59 PST or 23:03:59 EST, this email originated from IP address 68.242.32.189.
BRANNON stated that he also talked via internet and telephone with a person who identified himself as Mark. BRANNON had never seen Mark at the residence only Harlow and "Trent". He suspected that Mark may not exist but did not press the issue with Harlow. He suspected this because Harlow said that Mark owned everything, the business, house, and the cars. Then on 01/19/2007 Harlow picked him up at the Hilton and they were pulled over by the Virginia Beach PD for window tint and were given a citation. BRANNON observed several other citations in the vehicle and CUADRA said that Mark has a lawyer that will take care of them. BRANNON observed that the vehicle was registered in CUADRA's name. He said that Mark put the car in his name due to legal issues. BRANNON thinks the time of the traffic stop was at approx. 14:30 hrs on 01/19/2007.
While at the residence BRANNON recalled some of the conversations with CUADRA.
CUADRA talked about returning from a Las Vegas trip where he attended a convention. He had lost his plane tickets and boarding passes from Southwest Airlines and Mark had to buy new ones.
CUADRA talked about making a movie with a gay porn star named Brent Corrigan. It sounded like it would be happening soon but CUADRA did not say specifically.
CUADRA talked about Corrigan making a movie with Falcon Studio's called The Velvet Mafia, but they could not use his name and Corrigan was mad about that.
CUADRA said he was a Navy Corpsman, had been hurt and was getting out in a few months.
CUADRA also talked about Mark having him put a gym together to work out.
BRANNON received an email on January 24th, 2007, from CUADRA's party757@yahoo.com account. This seemed odd because Harlow was asking for money to attend a webmaster school for his website boybatter, he thought he might be getting scammed. CUADRA was asking to charge $1,000 to his credit card, which he allowed. BRANNON also was traveling to the Newport News Area in March 2007 to teach a military class and prepaid $5,500 on February 8th, or 9th 2007 for several appointments with CUADRA.
BRANNON related that he would be available for interview in person if needed.
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