---
title: Defense Investigation
description: "# Documents from Adnan’s Defense Team After his [arrest](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/arrest-and-bail), Adnan’s family hired attorneys Douglas Colbert and Chris Flohr, who tried, although unsuccessfully, to get him out of jail on bail. After a few weeks, Colbert and Flohr helped Adnan’s family…"
url: "https://donclinedinstandthekillingofhaeminlee.debisimons.com/wiki/defense-investigation/"
updated: "2024-07-11"
category: Before Trials
---

# Defense Investigation

# Documents from Adnan’s Defense Team

After his [arrest](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/arrest-and-bail), Adnan’s family hired attorneys Douglas Colbert and Chris Flohr, who tried, although unsuccessfully, to get him out of jail on bail. After a few weeks, Colbert and Flohr helped Adnan’s family to hire another lawyer to prepare for trial, and [in April 1999](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/XAEB-19990708-Gutierrez-Billing-pp66-68.pdf) Maria Cristina Gutierrez was hired. Some evidence from her files appears below.

There is some other evidence available that hasn’t yet been integrated into this page. During the February 2015 PCR hearing in Baltimore Gutierrez’s files (incorporating Flohr and Colbert’s records) became part of the official court records. Only a few dozen pages, of several hundred, are publicly available. The prosecution selected some and published them during their appeal to COSA, you can find details on a [separate page – with the reference type “A-XXXX”](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/2017-state-cosa-appendix). None of the Syed Appendices that were submitted to COSA were published and we have no explanation why.

## Defense Team

**Douglas Colbert** – Adnan’s lead bail attorney
**Chris Flohr** – Colbert’s assistant attorney

**Maria *Tina* Gutierrez** – Adnan’s lead trial attorney
**Andrew Davis, Thor Daniels** – private investigators working for Adnan. Davis worked for both Colbert/Flohr and then Gutierrez, Daniels just worked for Gutierrez
**Mike Lewis, Kaliope Parthemos, Ali Pournader, Julie Remey** – law clerks, paralegals and/or law students working for Gutierrez’s firm: Redmond, Burgin & Gutierrez
**Rita Pazniokas, Mark Martin, Phil Dantes, Bill Kanwisher** – Attorneys working at Redmond, Burgin & Gutierrez
**Michael Millemann** – attorney from another firm who briefly represented Adnan during the State’s attempt to disqualify Gutierrez

## Evidence Reviews

Gutierrez and/or her team inspected the [physical evidence](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/physical-evidence/) collected by Baltimore Police. There are several drafts of their write ups, but we don’t have a complete or final copy. These reviews are helpful because they often give a much more detailed description than the Police records, where many items were logged collectively. E.g. “Items from the Back Seat” from the Police records vs listed items, with details such as the style, size and color of clothing, what brand of perfume bottle was found inside Hae’s purse, details of what is on a particular receipt.
[Combined pages posted on Rabia’s blog](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/STMB-Defense-Evidence-Review-extracts-dates-Nov-3-8-12-1999-combined.pdf), various dates 11/3, 11/8 and 11/12/1999.
[Undisclosed pages relatinng to Hae’s car](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/UdE05-Defense-Evidence-Review-Contents-of-Hae-Car-19991111.pdf)
[Undisclosed section about the Exxon Receipt (in Hae’s car) from Jan 5, 1999](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/UdE02-19990105-Crown-Gas-receipt-extr-from-Defense-Evidence-Review.pdf)

## Evidence Collected

[Adnan’s AT&T Bill](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/STMB-Adnan-ATT-bill.pdf)
[Prayer Notes](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/EVPB-19990114-Bilal-Adnan-prayer-notes.png) that Adnan and Bilal went through on 1/13/999 in anticpation of Adnan’s 1/14/99 talk at the mosque
Combined (searchable) extracts from [Becky’s Notebook](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/T2xd15-Becky-Journal-Defense-Exhibit-15-selected-extracts-only-Adnan-Hae-Relationship.pdf)
Individual pages: [Adnan’s Character](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/STMB-Becky-Notebook-Adnan-Character.png); Adnan’s and Hae’s [Relationship](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/STMB-Becky-Notebook-Adnan-and-Haes-Relationship.png); Adnan’s Behavior [When Hae Went Missing](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/STMB-Becky-Notebook-When-Hae-Missing.png); Adnan’s Behaviour [At The End](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/SDTJ-Ep115-Becky-Notebook-End-of-Relationship.png) Of The Relationship

## Interviews with Adnan

[Handwritten notes 7/13/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/UdE01-Adnan-Defense-Clerk-Ali-notes-incl-Asia-19990713.pdf) prepared by clerk from visit to Adnan in jail, mention of Asia McClain in library
[Memo 8/25/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/UdE01-Adnan-Memo-Defense-Clerk-Kali-19990825.pdf) from Gutierrez clerk written after visiting Adnan in jail, describing filming in detention center, relationship with Jay, Adnan’s memories of January 13th
[Handwritten notes 8/25/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/UdE01-Adnan-his-handwritten-notes-for-attorney-19990825.pdf) prepared by Adnan describing his day on 1/3/99
[Memo 10/6/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/STMB-Adnan-statement-re-Hae-and-Jay-cheating-Extract-from-Clerk-Kali-Memo-19991006.pdf) from Gutierrez clerk describing Hae being upset about Jay cheating on Stephanie
[Memo 10/12/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/ACA-19991012-Defense-Clerk-Kali-Memo-Adnan-Details-Hae-and-Relationship.pdf) – lengthy interview by Gutierrez clerk of Adnan, regarding Hae’s diary and his relationship with Hae
[Memo 1/15/00](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/STMB-20000115-Visit-to-Adnan-Memo-Clerk-Kali-to-Gutierrez.pdf) from Gutierrez clerk written after visiting Adnan in jail with his thoughts after the first trial. Describes his thoughts on Officer Adcock, Nurse Watts, Debbie and the “I am going to kill” note, track, and Jay, including his relationships with Stephanie and Jenn

There are [more memos about Flohr’s visits to Adnan](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/2017-state-cosa-appendix/) in the defense files,.

## Other witness investigations

[Undated snippet](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/STMB-Tayib-snippet-from-defense-files.pdf) from defense files stating that **Jay**told **Tayib** Adnan showed him Hae’s body at a gas station and he helped Adnan bury the body
[Undated handwritten notes](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/EVPB-Defense-Clerk-Julie-notes-contact-medical-examiner.png) from defense files to contact a **medical examiner**
[Undated handwritten notes](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/1999xxxx-Gutierrez-Asia-library-Adnan-notes-MCGs-handwriting-Extr-from-20150120.pdf) from defense files about **Asia**, **Jay**, **Stephanie**
[Notes 3/10/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/UdA03-Sis-Statement-Defense-Investigator-19990310.pdf) from defense investigator Drew Davis about interview with **Sis from Southwest Video** about Jay’s work schedule
[Memo 3/10/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/UdA06-Stephanie-First-Interview-with-the-Defense-PI.pdf) from defense investigator Drew Davis describing his interview with **Stephanie** at her home
[Memo 3/11/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/UdA06-Stephanie-Second-Interview-Defense-PI.pdf) from defense investigator Drew Davis describing his interview with **Stephanie** at Hae’s memorial service
[Memo 8/4/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/UdE10-Defense-Memo-on-Anonymous-Call-and-Yaser.pdf) from clerk Kali P to Gutierrez summarizing the police’s anonymous call memo and summarizing an interview with **Adnan’s brother Tanveer** and **mother** about **Yaser Ali**.
[Memo Updated 8/4/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/ACA-19990804-Defense-Memo-summarizing-Jay-in-police-files.pdf) – titled “Information in file concerning **Jay Wilds**,” author unknown
[Memo 8/21/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/ACA-19990821-Defense-Memo-Adnan-Brother-and-or-Ali.pdf) – from clerk Ali P to Gutierrez summarizing an interview with **Adnan’s brother**, also called Ali here)
[Handwritten Statement of **Neighbor Boy** 9/3/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/UdA03-Neighbor-Boy-Statement-Defense-Investigator-19990903.pdf) given to defense investigator Drew Davis
[Memo 9/3/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/ACA-19990903-Davis-Note-Wilds-refused-to-speak.pdf) – Davis attempted to interview **Jay**
[Memo 10/16/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/EVPB-19991016-Track-team-roster.pdf) – one of Gutierrez’s clerks **lists the boys on the indoor track team**, matches names and order of list from the Woodlawn High School yearbook who medaled in track
[Memo 12/15/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/ACA-19991215-Defense-Memo-File-Contacting-Potential-Trial-Witnesses.pdf) – Describes alibi witnesses that Davis would need to contact
[Undated handwritten notes](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/EVPB-Clerk-notes-Gutierrez-Jay-3rd-interview.png) by Gutierrez clerk about **Jay**‘s third interview, but likely during or between the first and second trials
[Undated handwritten notes](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/EVPB-19990303-MCG-her-notes-re-Coach-Sye-PI-Davis-interview.pdf) in Gutierrez’ own handwriting about Davis’s interview with **track coach Michael Sye** (that was probably on 3/33/99)
[Handwritten notes ](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/EVPB-Gutierrez-notes-Korell-testimony.png)[12/14/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/EVPB-Gutierrez-notes-Korell-testimony.png) by Gutierrez about **Dr M Korell**‘s testimony (about the autopsy), notes undated but likely taken made 12/14/99 during the direct, first trial.
[Memo 1/21/00](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/EVPB-Law-student-defense-summary-Jauan-police-interview.pdf) from Gutierrez law student clerk summarizing **Ja’uan**‘s police interview
[Memo 1/14/00 from colleague to Gutierrez](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/EVPB-20000114-Defense-Memo-to-Gutierrez-Russell-WHS-subpeona.pdf) with message from **assistant track coach Russell**, noting subpoena had been misaddressed to his former employer, Woodlawn High.
[Memo 2/2/00](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/EVPB-20000202-Clerk-Julie-memo-Gutierrez.pdf) from Gutierrez clerk documenting efforts to look into **Jay**‘s sentencing for accessory after the fact and **Mr. S.**‘s indecent exposure charges

## Miscellaneous

[Single page To Do list, undated](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/ACA-Undated-Defense-Handwritten-Clerk-To-Do-page.pdf) – handwritten, not clear if it’s by Davis or one of Gutierrez’ clerks
[Notes undated](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/ACA-Undated-Gutierrez-Handwritten-Page-Debbie-Saw-Hae-Strip-2-Tapes-Who-Prepped-Jay.pdf) – handwritten, by Gutierrez, topics include Debbie, Jay
[Notes undated – handwritten, by Gutierrez](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/STMB-Gutierrez-Notes-Jenn-P-police-Statement-MCG-handwriting.pdf), on Jenn P’s 2/27/99 statement
[Billing Summary 3/31/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/ACA-19990331-Davis-Billing-Summary.pdf) from Andrew Davis, describing work for bail hearing
[Gutierrez Bill 06/29/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/ACA-19990629-Gutierrez-Bill.pdf) – for work done by Martin and Gutierrez from 4/7/99 to 6/29/99
[Bilal’s Waiver for Gutierrez 07/09/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/STMB-19990709-Bilal-Gutierrez-conflict-waiver.pdf) – allowing her to work for Adnan after having earlier represented Bilal at the Grand Jury
[Task List 9/4/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/ACA-19990904-Defense-Team-Task-List-Table.pdf) – lengthy defense task list discussed on Undisclosed
[Extracts from March 1999 report into Don’s alibi](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/STMB-199903xx-Extract-of-Defense-report-Don-C-by-PI-Andrew-Davis.pdf)by Andrew Davis.
[Memo 9/16/99](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/wp-content/uploads/2018/06/EVPB-19990916-Acosta-Martinez-memo.pdf) suggesting Gutierrez was confusing the Acosta Martinez case with Adnan’s case

See also the [Pre-Trial and Discovery](https://web.archive.org/web/20230914194503/https://www.adnansyedwiki.com/pre-trial-and-discovery) page:

The Defense Investigation Continues . . .

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