Baltimore graffiti

Is it a ledger? Or is it an address book?

Jamison KoehlerTrial Advocacy


Q:     Good morning, Officer.

A:      Good morning, sir.  How you doing?

Q:     Fine, fine.  Thank you.

A:      All right.

Q:     Officer.  Your first name is Steven, right?

A:      Yes.

Q:     Do people call you Stevie?

A:      I am sorry.  You said Stevie?

Q:     Yes.  Stevie.

A:      No, they do not.

Q:     Okay.  When we were watching the body worn camera yesterday, there was a scene – or segment – in which you were using a battering ram, right?

A:      Correct.

Q:     And while you were doing that, we could hear another officer shouting at you, go Stevie, go Stevie, right?

A:      I believe they said, let’s go Steve.  I believe that’s what they said.  I believe.  I’m not 100 percent.

Q:     And when we were watching the body worn camera in court yesterday, I was watching your face and you laughed when we came to that part of the recording, right?  You laughed?

A:      I smiled.

Q:     I see.  So you watch yourself breaking into someone’s home in the early morning, they have a two-year-old child, and you found that funny?

A:      You said I was breaking into their home?  We were executing a search warrant.

Q:     You have a battering ram, and you’re breaking down their door.  It is early morning.  They are sleeping.

A:      I don’t know what they were doing.

Q:     There is a child inside.   It’s your testimony that’s not breaking into their home?

A:      I would say it’s a Court ordered – a Court-issued search warrant.  You’re making an entry into the home by force.  So, yes, we were breaking through the door, but I’m not actually breaking into someone’s house.  

Q:     I see.  And you and your colleagues view this as sort of fun, like a sporting event?  Let’s go, Stevie, right?

A:      No.  I was actually laughing because I couldn’t hit the door.  That’s why I was smiling . . .

Q:     Officer, you testified earlier about recovering a so-called ledger from the hamper in the laundry room, right?

A:      Officer Jones found it underneath the hamper in the little room right off the kitchen.

Q:     You are using the word ledger because that suggests some type of business relationship, right?  Maybe some type of illicit business?

A:      I used the word ledger because that was the best word I could think of.  Drug dealers often –

Q:     — Officer.   It was a spiral notebook with addresses and phone numbers on it, right?

A:      Right.

Q:     There were no drug quantities on there, no dollar amounts owed, nothing to indicate that this had anything to do with the sale of drugs, am I right?

A:      I mean, it could be a ledger; it could be something else.  I’m not sure what it was, but that’s why we collected –

Q:     –What do you call a collection of names and telephone numbers?  You call that an address book, right?

A:      It could be considered one.

Q:     Okay.  But in this case, in your mind, it was a ledger, right?

A:      It could have been, yes sir.  It can be.

Q:     Did anyone ever try to call any of the numbers listed on it? 

A:      Not to my knowledge.

Q:     As far as you know, no one knows whose handwriting this was?

A:      I don’t know who it belongs to, sir.

DEFENSE COUNSEL:  May I approach?

THE COURT:  You may.


Q:     I am showing you what the government identified earlier as Government Exhibit 9.  Do you remember testifying to this earlier?

A:      I do.  

Q:     I would like you to take another look at it.  Please look up when you have had the opportunity to refresh your memory.

A:      I have looked at it.  I remember it.

Q:     You would agree with me that it consists only of a list of names and telephone numbers, right? And a few addresses?

A:      Yes.

Q:     You would also agree with me that there is a heart next to two of the names listed, right?

A:      There appear to be, yes.  

Q:     Did either you or anyone else ever attempt to match the handwriting on this address book with my client’s handwriting?

A:      I am not a handwriting expert.

Q:     That was not my question.  

A:      Not to my knowledge.

Q:     Did anyone try to take fingerprints or DNA evidence off the notebook?

A:      Not that I remember.

A:      Officer, does my client look like the type of guy who would put a heart next to someone’s name?

PROSECUTOR:  Objection.

THE COURT:  Sustained.


Q:     Officer.  You have seen the handwriting.  Does this appear to be a man’s handwriting or a woman’s handwriting?

PROSECUTOR:  Objection.

THE COURT:  If he knows.  Overruled.

THE WITNESS:  I am not a handwriting expert.  As I said, I have no idea who wrote this.