D.C. criminal defense attorney

“You do not know how to read a Google Map?”

Jamison KoehlerTrial Advocacy

Q:        So you followed him back to his house?

A:         I didn’t follow him.  I was on my way to my mother’s house.  She lives in that area.  

Q:        You told police that your mother lives on B Street, right?

THE COURT:    Is that Northeast, Southeast – 

DEFENSE COUNSEL:    — You told police that your mother lives on B Street, Southeast.  Right?

A:         I don’t remember what I told the police.  

Q:        You don’t remember speaking with police?

A:         I remember speaking with them.  But I don’t remember what I said.  That was a long time ago, and I was upset.  You — 

Q:        — Let me put it this way.  When you came across my client standing in his yard, you were on your way from where the accident was on Benning Road to where your mother lives on B Street?

A:         Yes.  But I was not following him.

Q:        But my client’s house is on Bass Place, Southeast.

A:         I don’t know where he lives.  But he – 

Q:        — You drove by my client’s house and he just happened to be standing there in his yard?

A:         Uh huh.

Q:        You need to answer yes or no.

A:         Yes.  But I wasn’t following him.  He — 

Q:        — He is standing there in his yard?  And you drive by, on your way to your mother’s house on B Street, and you just happen to see him.

A:         He – 

Q:        — And my client’s house on Bass Place – 

THE COURT:    Counsel, counsel.  You need to let the witness finish her answer.

DEFENSE COUNSEL:    I am sorry, Your Honor.  And my client’s house is on Bass Place, Southeast and that is between Benning Road and where your mother lives on B Street?

A:         I don’t know where he lives.

Q:        You don’t know where he lives?  

A:         No.  That is what I keep telling you.

Q:        May I approach?

THE COURT:    You don’t need to ask.

DEFENSE COUNSEL:    Showing to counsel.  [Pause.] Ms. Smith, I am showing you a piece of paper marked as defense exhibit #1.  Please take a moment to look at it. 

A:         I, I –

Q:        —  Do you recognize what I have given you?

A:         I don’t know what it is.

Q:        It is a Google Map.  Can you tell what it is a map of?


A:         I, I can’t tell what this.

Q:        Do you not know where your mother lives?

THE PROSECUTOR:     Objection.

THE WITNESS:             I can’t tell what this is.

THE PROSECUTOR:     Hold on, hold on.  

THE COURT:    Counsel.  We are not going to get into that.  We are not going to put her mother’s address into the public record.

DEFENSE COUNSEL:    I am not asking for the specific address. Just the general area.


DEFENSE COUNSEL:    We can put it under seal.

THE COURT:    Next question.

DEFENSE COUNSEL:  Ms. Smith.  Do you not know how to read a Google Map?

THE COURT:    Counsel.  That’s enough.  The witness has not identified the map, the piece of paper.  Move on.  

DEFENSE COUNSEL:    I’d like to make a proffer.

THE COURT:    I said to move on.  

DEFENSE COUNSEL:    Ms. Smith.  So you are on your way from Benning Road, Southeast, to your mother’s house on B Street, right?

A:         Uh huh.

Q:        And you just happen to drive by my client’s house?

A:         Yes.

Q:        Coincidentally?

A:         Yes.  I did not follow him.  I told police – 

Q:        — And my client is standing out in his yard with his wife and their newborn baby?

A:         I didn’t see any woman.  It was just him.  He was getting something out of the back of his car.

Q:        So you pulled your car over?

A:         Uh huh.

Q:        You need to answer yes or no.

A:         Yes.

Q:        You got out of your car?

A:         I never got out of the car.  I stayed in my car because I was afraid of him.  He had just called me an old B – 

Q:        So you were speaking to him through the window?

A:         Yes.

Q:        And you were angry?

A:         I wasn’t angry.  I was upset.

Q:        Was that the driver side window or the passenger side?

A:         I don’t remember.  I think it was the driver’s side.

Q:        What direction were you facing on Bass Place?

A:         I have no idea where I was.  I told you — 

Q:        — And you told him you now know where he lives?

A:         No.

Q:        You didn’t tell him that?  We have the body worn camera.  Would you like to see that?  You didn’t tell him you now know where he lives?

A:         Well, I didn’t say it like that.  I said that I knew his address.

Q:        You told him you knew his address?

A:         Yes.

Q:        And by that you were just being friendly?

A:         I told him I knew his address.