In this presentation, I will be making a presentation to the court seeking an arrest warrant against one Damien Jones following the murder of Paul “Shorty” Alcorn. I have sufficient evidence to enable me to present a prima facie case against the said accused person. That evidence ranges from police reports regarding the homicide, police reports regarding the robbery with violence; we have forensic reports and also the analysis of the forensic reports. In the analysis of the forensic reports, we will be looking at the various pieces of evidence including documentary evidence. We also have the various property records of the robbery, the property records of medical report and the property records of the crime scene. All these properties will be presented to the court a way that is sequential, orderly and adequate to ensure that justice prevails.
We have various witness statements including the statement of the suspect. We made use of the suspect whom we arrested as a result of the robbery with violence to get the other witnesses of the homicide. We will be presenting the witnesses in an orderly manner depending on the statements they made when we interviewed them. As we do so, we will be calling the various witnesses to testify orally in court. Finally, we will then ask the court to have the suspect defend himself in court. We have reason to believe that the evidence that we have is sufficient to sustain a trial against the suspect and therefore we urge the court to issue an arrest warrant against the suspect to be produced in court to take his plea. I have a team of detectives who will be assisting me in the presentation of this case. All our evidence is in order, having obtained an indictment from the
Summary of homicide
This case involves the homicide shooting of one Paul “Shorty” Alcorn who was born in 07/03/60. He was suspiciously murdered on the murdered on the night of Friday, November 3 1989. The main suspects as per the Police file, Damien Jones, Ronald Ingram and Albert Pope. These, according to the police, were the strongest suspects that the police had produced. According to the police, however, the accused persons relied on the alibi of one Dolores Jenkins.
The police could not, therefore, sustain a strong case against the accused persons. The testimony provided by Officer Shearer was collaborated and supplemented by the evidence provided by other three officers who attended the scene of crime immediately after the murder. According to officer shearer, on the fateful day, he was dispatched to a call of shots which were being fired at the corner of Broadway and North Ave. when he arrive at the scene of the crime at approximately 0015HRS, Officer Last and EMS also arrived. According to him, the deceased was a white man of approximately 30 or 40 years. He had bullet wounds, one on the chest and another to the abdomen. He identified him as Paul Alcorn. He then called a dispatch to request back up and to ask for detectives who would then respond to the crime.
He has written testimony to the effect that the shooting occurred outside the Blue Boy Lounge 101. There was one Eric Kriz who happened to be a bartender and who happens to have been drinking with the deceased before the shooting occurred. Kriz, according to the officer, is always cooperative with the police and gave them all the information that they required including the information that the deceased had been drinking at the bar with many other people. Kriz had had enough and therefore had to push the deceased out of the bar. He was afterwards heard fighting with another customer outside the bar. After some minutes, more police officers joined the previous officers and interviews were conducted with the people who had been at the bar ad who were now watching the scene.
Most of them, however, did not have the requisite information save for one Betty Fischer who agreed to be interviewed by Officer Fischer. Detective Brady also supplemented the evidence of the first officer, adding that he had too been dispatched to the scene of the crime following the shooting. He supported the testimony of Officer Shearer. The police conducted various follow-ups for a number of days including a canvass on Monday, November 6, 1989. We have a full report of the canvass and we will be making use of it in our case. We will be making use of the oral testimony of the police regarding this crime because they had the opportunity of witnessing the scene of crime and also interviewed various witnesses who had arrived at the scene to witness the aftermath of the shooting.
Summary of the armed Robbery Case number 200-0609
Officer Leach was dispatched at the scene of the robbery on Friday night to respond to a shooting at the Quickie Convenience Store at 100 Avenue. He found an injured man lying unconsciously on the ground. The officer then called an ambulance to assist in rushing him to hospital. He took digital photographs to aid in evidence because he had an advantage of being at the crime scene. Det. McCarthy supplemented this report by asserting that they were together with Officer Leach at the scene and that he rushed to the hospital to interview the injured man. The injured man told him that a white male 40-60 years old had entered the store. The injured man, a Mr. Carter, told the police officer that the robber had taken some fruits on the store when he later shot at him. The man could not remember anything that happened later, though.
The police conducted a search and compiled a report about the robbery. The report was signed by Judge Howard of the Virtual Circuit Court. The report shows the arrest of one Ronald Ingram who was arrested at the scene of the robbery. The search was conducted by the reporting detective Det. Blanche. The officers say that more investigations are in progress to get additional information. We will be making use of this report in the litigation of our case.
Forensic reports
We sent various objects to the government laboratory as a way of gathering sufficient information to assist us in our investigations. Latent fingerprints from exhibit CS-5 did not match those of our prime suspect Damien Jones. Various cartridges and projectiles collected from the scene of the crime were also taken to the lab. The projectiles were found to have been fired from the same weapon. The cartridges were also found to have been fired from the same weapon. There was however no firearm to be matched with these exhibits and even after they were entered into the IBIS database no matches could be found. We intend to have them remain the database for future retrieval in case we find other matches.
When casings of the projectiles and the firearm were entered into the NIBIN database, they were found to have been fired from the same weapon and a match was identified. Although there was not enough friction to assist in identifying fingerprints, there was sufficient evidence to show that the finger prints were those of the Quickie Convenience Store Robbery victim, one Mr. Carter.
When we analyzed telephone numbers, Exhibit ME-2A, we found that the telephone contained seven numbers. After a research was done, it was found that the phone belonged to one Darryl Hornsby, a member of the Charles Street Crew. It should be remembered that the Charles Street Crew were enemies to the Mulberry Street Crew. After being arrested with possession and possession with intent of controlled dangerous substances, he was killed in prison riot in 2001.
We also took Exhibit ME-6A, a baggie which contained ten packets of green plant material. After analysis, the material was found to be marijuana, which falls under controlled substances. We also took various projectiles, including the bullets which had hit the deceased in the chest and the abdomen, the cartridge casings form the scene the Gluck handgun ammunition, and other projectiles which had been taken from the body of the deceased. There was sufficient matching and the analysis confirmed that the various projectiles had been fired from the guns that we had produced. We will be making use if these projectiles, cartridges, ammunition and casings as evidence before the court in an attempt to secure the conviction of the suspect. All other objects are in the safe custody of the police and after analysis they remained with the police to be used in this case.
We took cigarette butts and blood vial recovered from the scene of the crime for forensic analysis. Saliva was identified on both exhibits and when DNA was extracted and applied using Polymerase Reaction, it was found that the DNA did not originate from the deceased. The DNA was submitted to the state police so that it is included in the CODIS. It identified one Albert Pope as suspect match. He was one of our suspects in the previous case. We took latent fingerprints for forensics also. These were the ones that had been recovered from the beer bottles. The Automatic Fingerprint Identification System provided one Ronald Ingram as a prime suspect and another Albert Pope. The analysis of the fruit wrappers from the Mulberry Street matched the fingerprints of the prime suspect in the robbery, Ronald Ingram and others matched those of the victim in the robbery, Shaun Carter. We still have some more fingerprints which have not yet been identified and therefore we have ongoing investigations. Once we are through, we will present the same to this court because we intend to rely on it in our case.
The Glock fire arm did not have sufficient fingerprints to assist us in deriving enough fingerprints for comparison. It would appear, as far as we can tell, that the firearm had been previously wiped before being put in store. It was therefore was not of much help to us.
Property records of the robbery
We have an inventory comprising a list of all the property that we used in the investigation and which we intent to rely on in our case, these property have been duly labeled and stamped as required by the laws of evidence. We, therefore, have everything in safe custody.
Witness interviews
We embarked on a mission to in review all the witnesses that we had in our list of witnesses. The most important witnesses were the suspects that we had in our previous case of the homicide. The testimony that they gave us was not under duress. Even before we interviewed the witnesses, we informed them of their Miranda rights. They had the right to be represented by a legal counsel; they had the right to keep quiet and also the right to say everything that they wanted to say for the interest of justice. All the testimony that we have is documented safely and we will make use of the same in our case.
We had Dolores Jenkins, Ronald Ingram, the prime suspect in the robbery case, Albert Pope, and the prime suspect that we have in the homicide case, Damien Jones. We could have made use of Marcus Reed but unfortunately he is deceased. If he was alive, he would have assisted us a lot because he has been linked the crime by most witnesses. The suspect that we have was incriminated by most of the witnesses that we had. We choose to single out the testimony of Dolores Jenkins, on which we are going to rely for the better part of this case. We started by letting him know that we were reopening the litigation of the homicide case concerning the murder of the deceased. This was occasioned by capture of important information following the recent robbery incident. Jenkins did not think that Ingram could have short the deceased because they had been together before the incident. When the police followed the incident, Jenkins told us that he was together with Ingram and that there was no way in which he could have shot the deceased, Jenkins went ahead to give us the whole account of how Damien, our prime suspect, had lost his temper on that fateful night. That he was drunk and was not himself. He was quarreling with people around and that they heard shots outside. Ingram and the rest of the witnesses and they all implicated Damien with the murder. We have reason to believe that he was the person who shot the deceased. We have compiled all the information regarding this and we have a prima facie case to believe that he should take full responsibility.
Determination of facts
We have viewed all the evidence that we have, we have considered the right of the family of the victim and therefore we have come to a conclusion that the deceased was brutally shot by Damien Jones. This has arisen from the fact that the evidence we have from the other witnesses is consistent and corroborative that he in fact committed the homicide.
Conclusion
With all the evidence that we have and the fact that we have the prime suspect in this homicide, we believe that we will establish a prima facie case for the court to grant us the arrest warrant of the prime suspect Damien Jones. He is supposed to be apprehended in court to answer to charges of murder of the deceased. We will therefore submit to the court that for the sake of justice, it issues the arrest warrant for the arrest of the accused. That is our position.
We trust in the court that it is the custodian of the law and with this kind of overwhelming evidence it is highly likely that it will grant the arrest warrant. The granting of the warrant will not be a win for us. We know that it is in the interest of justice considering that an innocent person lost their life in 1989. It is for the sake of this justice that we commit ourselves towards achieving this end. We also know that the case is not won yet. We still have to present our oral evidence before the court and that if the warrant is granted; the accused person still has his Miranda rights. He will have the opportunity to be put on defense to defend himself before the court and also question the evidence that we have.
Finally, we appreciate the assistance that we got from various quarters in gathering this evidence. Right from the witnesses that we interviewed concerning the homicide case and also the robbery case, the people whom the police officers met at the scene of the crime, the people who were even willing to give their account of the murder without being asked to do so and all those who allowed us to collect specimen to take to the lab. All these people made our job easier. Without them we could not have gone this far. And now when we head the homestretch of this case, we even need more support from them. We have to ensure that the ends of justice are met.
References
Cole, G., & Gertz, M. (2012). The Criminal Justice System: Politics and Policies. New York: Wadsworth.
Herring, J. (2012). Criminal Law: Text, Cases, and Materials. London: Oxford University Press.
Pollock, J. (2012). Criminal Law. New York: Newnes.
Scheb, J. (2010). Criminal Law and Procedure. New York: Cengage Learning.
Siegel, L. (2009). Introduction to Criminal Justice. New York: Cengage Learning.
