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Mega Edition: What Did we Learn From The Various Forensic Reports (10/10/26) · Beyond The Horizon

0:00
Speaker 1: Everyone and welcome back to the program. One of the
0:04
Speaker 1: girls who was murdered in Moscow, Idaho, Zanna Kernodle, had
0:10
Speaker 1: bruises and put up a fight against her killer, according
0:13
Speaker 1: to the autopsy and according to her father, who is
0:16
Speaker 1: speaking out about his daughter's death. And I can't even
0:20
Speaker 1: begin to imagine what that must be like. Can you
0:23
Speaker 1: imagine walking around in that daze? Your daughter was just
0:26
Speaker 1: brutally murdered. You can't even come to grips with that.
0:30
Speaker 1: And you're walking around and it's real life. It must
0:35
Speaker 1: be the most torturous, painful experience one can even ever
0:40
Speaker 1: think of going through. Never mind actually living through it.
0:46
Speaker 1: But the autopsy results came back and it did show
0:49
Speaker 1: that all four of these students were in fact killed
0:53
Speaker 1: with a knife. So let's dive into this article from
0:55
Speaker 1: Fox News and let's see what sort of new information
1:00
Speaker 1: we can come up with. Headline, University of Idaho victim's
1:04
Speaker 1: father says Zanna Kernodle had bruises, put up a fight
1:08
Speaker 1: against her killer. And this is an interesting part right here, too.
1:12
Speaker 1: Another little golden nugget of information we didn't have before.
1:16
Speaker 1: and that is Zanna Kernodle's father also revealed that the
1:19
Speaker 1: suspect either knew the code to her door lock or
1:22
Speaker 1: entered through a side door. So either of those obviously
1:26
Speaker 1: are a possibility. We know from earlier reports that there
1:30
Speaker 1: was no forced entry, nobody barged their way in, so
1:34
Speaker 1: it was either a door was left open or somebody
1:37
Speaker 1: that they knew. This article was authored by Audrey Conklin.
1:43
Speaker 1: University of Idaho homicide victim Zanna Kernodle's father, Jeff Kernodle,
1:48
Speaker 1: said that his daughter had bruises on her body indicative
1:51
Speaker 1: of putting up a good fight with her attacker in
1:54
Speaker 1: an interview with an Arizona news outlet. That's interesting as
1:57
Speaker 1: well because maybe she caused some damage to this attacker
2:01
Speaker 1: that will help investigators if they get a lead and
2:04
Speaker 1: latch onto this person or person's Zanaker Nodal, 20, was
2:10
Speaker 1: killed in the early morning hours of November 13th, along
2:13
Speaker 1: with her boyfriend, Ethan Chapin, and two friends, Madison Mogan
2:18
Speaker 1: and Kaylee Goncalves, in a home on King Road in Moscow, Idaho,
2:23
Speaker 1: near the university. Police have not mentioned any suspects or
2:27
Speaker 1: motives as of Thursday. Bruises torn by the knife, Jeff
2:32
Speaker 1: Kernodle told Arizona news outlet 3TV CBS 5, adding that
2:36
Speaker 1: her injury showed signs of putting up a fight against
2:39
Speaker 1: her attacker. She's a tough kid. Whatever she wanted to do,
2:43
Speaker 1: she could do it. He also told the outlet that
2:46
Speaker 1: the door to their home locks with a number code. Well,
2:49
Speaker 1: considering we heard that the house had a lot of
2:51
Speaker 1: parties and there was a lot of transient people going
2:54
Speaker 1: in and out, meaning people there all the time. Well,
2:57
Speaker 1: a lot of people could have had that code, right?
3:00
Speaker 1: You would think that being in a fraternity, in a sorority,
3:04
Speaker 1: you're giving that code out willy nilly for your friends
3:06
Speaker 1: to come over. Or if it's not that and it's
3:09
Speaker 1: the side door, then it was obviously left open. But
3:13
Speaker 1: it's interesting that this door had the combination lock because
3:18
Speaker 1: how many people have that number? Well, we don't know that.
3:21
Speaker 1: We could start to piece it together. I mean, logically speaking,
3:24
Speaker 1: if you have a party house where people are coming
3:27
Speaker 1: over all the time, my guess is a significant amount
3:30
Speaker 1: of people have the code to get into the door.
3:34
Speaker 1: Every time you go, you have to go around the
3:37
Speaker 1: house because of the number code. So they either knew
3:39
Speaker 1: that or went around and maybe found the slider door open.
3:43
Speaker 1: Kernodle told the outlet, which is very possible as well. Look, remember,
3:48
Speaker 1: People don't think that they're going to get murdered in Moscow, Idaho.
3:51
Speaker 1: There hasn't been a homicide since 2015. My guess is
3:55
Speaker 1: most people up here sleep with the door open. I
3:59
Speaker 1: know for a fact that even in New York, like
4:01
Speaker 1: I said in a previous episode, in a part of
4:04
Speaker 1: New York where my family lives, they have the doors open.
4:08
Speaker 1: It's crazy to think about for me. I'm so worried
4:11
Speaker 1: that I would have the door locked no matter what.
4:14
Speaker 1: I don't trust human beings at all. But when you're
4:17
Speaker 1: not in that mindset and, you know, you're living your
4:19
Speaker 1: life as a college student, the last thing these kids
4:22
Speaker 1: are thinking about is somebody murdering them. Moscow Police Department
4:26
Speaker 1: Chief James Fry said during a Wednesday press conference that
4:30
Speaker 1: there were no signs of forced entry at the house.
4:33
Speaker 1: When they initially responded to reports of an unconscious person
4:37
Speaker 1: at 11.58 a.m. on November 13th, police found the four victims,
4:42
Speaker 1: all University of Idaho students, and members of Greek life
4:46
Speaker 1: at the school, stabbed to death inside the home. The
4:49
Speaker 1: Lata County coroner on Thursday revealed the victim's manner of
4:52
Speaker 1: death is homicide, murder, and their cause, death is stabbing. Now...
4:58
Speaker 1: Being in the fraternities or the sororities, does that have
5:00
Speaker 1: anything to do with it? Possibly. Can't rule it out.
5:03
Speaker 1: Was there animosity with people? Did they have some sort of,
5:08
Speaker 1: you know, beef with somebody and it spilled over and
5:11
Speaker 1: somebody lost their shit? Again, we don't know. But my
5:15
Speaker 1: guess is the investigators are going hard and trying to
5:18
Speaker 1: retrace all of that and talking to just about everybody
5:22
Speaker 1: that these girls know or knew. He also said Zanna
5:26
Speaker 1: was in contact with her family before the attack. She
5:30
Speaker 1: and Ethan went to a party on the night of
5:31
Speaker 1: November 12th while Mogan and Goncalves were out at a bar.
5:36
Speaker 1: It is unclear if the victims walked home or got
5:38
Speaker 1: a ride. And again, this is still evolving. We don't
5:42
Speaker 1: have all of the information. That's why it's important to
5:45
Speaker 1: add the information as we get it to continue building
5:48
Speaker 1: this puzzle out. Because this is crazy. How are you
5:53
Speaker 1: going to have four young people murdered like this And
5:56
Speaker 1: nobody knows a thing? Police say the victims arrived home
6:02
Speaker 1: at 1.45 a.m. The murders occurred around 3 a.m. or
6:06
Speaker 1: 4 a.m., authorities said during the Wednesday press conference. So
6:10
Speaker 1: they were home for a very short period of time
6:14
Speaker 1: before this happened. So it wasn't like they were settled in,
6:17
Speaker 1: nothing like that. Probably got home and were just going
6:20
Speaker 1: to bed or just fell asleep. And this psychopath or
6:23
Speaker 1: psychopaths fell on them. I heard from her, I think,
6:27
Speaker 1: before we went out, Kernodle told 3TV CBS 5. I
6:32
Speaker 1: think midnight was the last time we heard from her
6:34
Speaker 1: and she was fine. He described Zanna as responsible and
6:38
Speaker 1: unworried about drama or material things. She and Chapin had
6:43
Speaker 1: been in a relationship for about a year, he said.
6:46
Speaker 1: So they were going steady for a year, going strong.
6:48
Speaker 1: And according to her dad, she was living her life,
6:51
Speaker 1: you know, having a great time, having that college experience,
6:55
Speaker 1: met a boyfriend, been with them for a year, relationship,
6:59
Speaker 1: all of that stuff, and all of it just taken
7:01
Speaker 1: away in an instant. And the person or persons responsible,
7:07
Speaker 1: I hope that when they're caught and after a speedy
7:10
Speaker 1: trial and they're convicted, they get the harshest sentence that
7:14
Speaker 1: Idaho has on the books. When I went up there, she...
7:18
Speaker 1: I saw her just a week before that, and she
7:21
Speaker 1: changed a lot, Kernodle told the outlet. She had a life.
7:24
Speaker 1: She got to see what it was like to have
7:26
Speaker 1: a boyfriend you live with, and she really turned around.
7:30
Speaker 1: She was really responsible, helping him out with his studies
7:32
Speaker 1: and stuff. I was really impressed. So, obviously, she was
7:36
Speaker 1: doing well. And she was, you know, starting to turn
7:39
Speaker 1: that corner in her life, where you start to become
7:42
Speaker 1: more of a, you know, an adult. You have your
7:44
Speaker 1: boyfriend you live with. You leave the nest. And as
7:47
Speaker 1: a parent, you get to sit back and watch your work, right?
7:50
Speaker 1: This is my kid. I'm proud of them. Look at
7:52
Speaker 1: how great they're doing. And now this gentleman is having
7:56
Speaker 1: that completely stolen from him. For what reason? There's not
7:59
Speaker 1: going to be a reason good enough for this to occur.
8:03
Speaker 1: I don't care what the motivation is or what the
8:05
Speaker 1: reasoning is. It's never acceptable. And the hyper-violent society that
8:12
Speaker 1: we live in, we talk about it all the time.
8:14
Speaker 1: It's just really crazy to think that people are out
8:17
Speaker 1: there who are capable of shit like this. But unfortunately,
8:20
Speaker 1: we all know that people like this exist, and they're
8:23
Speaker 1: even in places like Moscow, Idaho, obviously. Moscow police have
8:28
Speaker 1: teamed up with state and federal law enforcement officers to
8:31
Speaker 1: try and track down a suspect. Many students left campus
8:36
Speaker 1: early before Thanksgiving break after the tragedy. Authorities are imploring
8:40
Speaker 1: anyone with information to about the murders or the victims'
8:44
Speaker 1: whereabouts on the evening before the attack to contact the
8:47
Speaker 1: Moscow police at 208-883-7054. That number once again, 208-883-7054. We're
8:58
Speaker 1: going to hear a lot more stories like this about
9:02
Speaker 1: these victims from their friends and families as all of
9:06
Speaker 1: this continues to move forward. And they're all going to
9:10
Speaker 1: be heartbreaking. These are all young people who had their
9:12
Speaker 1: whole lives ahead of them. And if you look at
9:14
Speaker 1: their social media accounts, they had a very, you know,
9:18
Speaker 1: enjoyable social life, it looked like. So I'm sure there's
9:21
Speaker 1: a lot of friends out there who are going to
9:23
Speaker 1: be absolutely crushed by this. And the community as a whole, well,
9:28
Speaker 1: they're sitting around saying to themselves, where'd this person go?
9:31
Speaker 1: Where are these people at? Do we have to worry?
9:34
Speaker 1: I'm guessing in Moscow, everybody has their doors locked now.
9:38
Speaker 1: And that's unfortunate, isn't it? You have a place like
9:41
Speaker 1: this where people don't think about murder happening. And then
9:45
Speaker 1: you wake up to the news that four college students
9:48
Speaker 1: have been brutally murdered in their home right off of campus. Yeah,
9:53
Speaker 1: that would be enough to make me lock my door
9:55
Speaker 1: as well. So let's hope that this investigation, these authorities...
9:59
Speaker 1: the FBI, the local police, everybody else involved is on
10:04
Speaker 1: their shit. They're drinking 19 Red Bulls tonight and they're
10:07
Speaker 1: ready to go out and capture whoever did this. All right, folks,
10:12
Speaker 1: that's going to do it for me. If you'd like
10:14
Speaker 1: to contact me, you can do that at bobbycapucci at protonmail.com.
10:19
Speaker 1: That's B-O-B-B-Y-C-A-P-U-C-C-I at protonmail.com. If you'd like to find me
10:26
Speaker 1: on Twitter, you can do that at B-O-B-B-Y underscore C-A-P-U-C-C-I.
10:32
Speaker 1: The link that I discussed can be found in the
10:35
Speaker 1: description box. What's up everyone and welcome back to the program.
10:44
Speaker 1: The coroner from Idaho has released the autopsy results and
10:49
Speaker 1: she also gave an interview to NBC News talking about
10:54
Speaker 1: what she found and what some of those results could mean.
10:58
Speaker 1: So that's what we're going to talk about on this episode.
11:00
Speaker 1: We're going to talk about the autopsy results and what
11:04
Speaker 1: the coroner had to say about those results. This article
11:09
Speaker 1: is is published by Today.com, and the headline, Coroner offers
11:14
Speaker 1: new details about fatal slayings of four University of Idaho
11:18
Speaker 1: students after preliminary autopsies. The four students were found stabbed
11:23
Speaker 1: to death inside a home in Moscow, Idaho, on November 13th.
11:32
Speaker 1: This article was authored by Samantha Kubata. The local coroner
11:38
Speaker 1: is offering more details about the brutal slaying of four
11:41
Speaker 1: college students in Moscow, Idaho, early November 13th. The autopsies
11:47
Speaker 1: for Madison Mogan, 21, Kaylee Goncalves, 21, Zanna Kernodle, 20,
11:53
Speaker 1: and Ethan Chapin, 20, were completed November 16th, Latah County
11:58
Speaker 1: Coroner Kathy Maybutt said. In an interview with NBC News,
12:02
Speaker 1: November 17th, Mayboot said the autopsy gave a clearer picture
12:07
Speaker 1: of what time the four were killed, their extensive wounds,
12:10
Speaker 1: and what the murder weapon was. Now, we've talked about
12:13
Speaker 1: this a little bit, about the time frame and stuff
12:16
Speaker 1: like that, but it's always a good idea when we
12:19
Speaker 1: can hear directly from the coroner or the person who
12:22
Speaker 1: is responsible for the autopsy. And that's what we have here.
12:27
Speaker 1: It would have been early in the morning, sometime after
12:29
Speaker 1: 2 a.m., but still during the night, Mabbitt said, adding
12:34
Speaker 1: that there wasn't a medical way to determine who was
12:36
Speaker 1: attacked first, but investigators are trying to put timelines together
12:40
Speaker 1: with other text messages and other technology, whatever that means. So,
12:46
Speaker 1: you know, they're utilizing everything at their fingertips, whatever they can,
12:50
Speaker 1: you know, use to try and rebuild this timeline. They're
12:52
Speaker 1: certainly doing that, I would guess. And with the FBI
12:55
Speaker 1: being involved, that opens up a whole different lane for
12:58
Speaker 1: them to have, you know, better technology, more support and
13:02
Speaker 1: more logistical support as well. She said the murder weapon
13:07
Speaker 1: would have been a bigger knife to be consistent with
13:10
Speaker 1: their pretty extensive wounds. And that's what we've talked about
13:13
Speaker 1: with the Rambo knife, the K-Bar knife. That's the big
13:17
Speaker 1: knife that Rambo used to carry around in the movie.
13:20
Speaker 1: Serrated side on one edge, regular knife blade on the other.
13:24
Speaker 1: And then if you open it up, it has like,
13:26
Speaker 1: you know, the compass matches and all of that jazz
13:28
Speaker 1: inside of it. But that's that's what they're saying was
13:31
Speaker 1: used as the murder weapon. Mabbitt couldn't say how many
13:36
Speaker 1: times each victim was stabbed, but said it was safe
13:39
Speaker 1: to say each of them had multiple wounds. She declined
13:42
Speaker 1: to say where on the body they were stabbed and
13:45
Speaker 1: later clarified that the victims were stabbed in different places
13:49
Speaker 1: and a different amount of times. So not too much
13:53
Speaker 1: information there as far as, you know, where they were stabbed,
13:57
Speaker 1: like actual locations. But we get the idea, right? And
14:02
Speaker 1: when you have a knife like that and you're getting
14:03
Speaker 1: stabbed anywhere, it's a critical situation. So all of that
14:08
Speaker 1: stuff will come out, I'm sure, later on down the road.
14:11
Speaker 1: But just getting this prelim stuff from her kind of
14:14
Speaker 1: gives us an idea of what went down that night.
14:17
Speaker 1: Kind of had some speculation, but when you have DNA
14:20
Speaker 1: to go off of or a reconstructed timeline given to
14:24
Speaker 1: you by the coroner, kind of puts things in a
14:28
Speaker 1: little bit better of a perspective, if you will. Mabbitt
14:31
Speaker 1: said it was likely the four had bled out in
14:33
Speaker 1: the home. Well, when you look at the crime scene
14:36
Speaker 1: photos that they have released and you see the blood
14:38
Speaker 1: seeping out of the wall like that, I could see
14:41
Speaker 1: that for sure. And when we were first talking about this,
14:44
Speaker 1: that was one of the things that confused me. I said,
14:46
Speaker 1: you would think that there'd be a lot of blood
14:48
Speaker 1: at a crime scene like this. And obviously, as we
14:51
Speaker 1: got more information, it turns out that there was a
14:54
Speaker 1: ton of blood at this crime scene. She said DNA
15:00
Speaker 1: samples had been taken from the scene and are being processed.
15:03
Speaker 1: When pressed, she said it was possible that some of
15:06
Speaker 1: the DNA being tested from the four victims. There were
15:09
Speaker 1: nail clippings that were taken and other ones that are
15:12
Speaker 1: being sent off and some that will be processed, she said.
15:16
Speaker 1: So that's interesting. Nail clippings that were taken? Huh? Nail
15:21
Speaker 1: clippings that were left at the crime scene? All right. Well,
15:24
Speaker 1: I guess we'll have to see what comes of that.
15:26
Speaker 1: But look. With the way technology is these days, if
15:30
Speaker 1: you leave any DNA at these crime scenes, the police
15:34
Speaker 1: and the investigators, they're going to find it, and they're
15:36
Speaker 1: going to put the pieces together eventually. They are waiting
15:40
Speaker 1: for final autopsy results, which will not be available for
15:43
Speaker 1: another four to six weeks, pending toxicology. Mabbitt said in
15:47
Speaker 1: this case, the toxicology reports likely wouldn't be important to
15:52
Speaker 1: the investigation. Yeah, why would it be important? I don't
15:55
Speaker 1: care if these kids went out and partied the night before.
15:57
Speaker 1: Who cares if they were drunk or whatever? They were
16:01
Speaker 1: murdered in their beds. So let's worry about that. And
16:05
Speaker 1: I think the most important part of the autopsy is
16:09
Speaker 1: how it happened. I mean, where the wounds were, what
16:13
Speaker 1: kind of weapon was used, was any DNA left behind,
16:15
Speaker 1: that sort of stuff. She added that the autopsies were
16:19
Speaker 1: completed by Spokane Medical Examiner's Office, located in Spokane, Washington,
16:25
Speaker 1: about 90 minutes northwest of Moscow. But she responded to
16:29
Speaker 1: the scene a few hours after police were called. It's
16:33
Speaker 1: pretty traumatic when there's four dead college students who have
16:35
Speaker 1: been stabbed to death in one location, she said, adding
16:39
Speaker 1: that there was quite a bit of blood at the scene.
16:41
Speaker 1: And that's what I would have thought right away. And
16:43
Speaker 1: that's why I just can't put the pieces together here
16:46
Speaker 1: with the other roommates. You would think that you would
16:49
Speaker 1: come downstairs to go to the bathroom or walk out
16:52
Speaker 1: of your room, or if you were hiding when it
16:54
Speaker 1: was happening, you'd come out and investigate afterwards. But there
16:58
Speaker 1: is a bunch of incomplete information, if you will, when
17:02
Speaker 1: it comes to what went on in that apartment. And
17:05
Speaker 1: that's expected at this point, unfortunately. With the police not
17:09
Speaker 1: releasing anything about a publicly known suspect or anything like that,
17:13
Speaker 1: there's a lot of confusion and a lot of the
17:15
Speaker 1: pieces trying to be put together by the public. I've
17:21
Speaker 1: been a coroner for 16 years. We have had multiple
17:24
Speaker 1: victim murders in the past, but nothing, nothing like this,
17:27
Speaker 1: she said. Police said that they did not have any
17:30
Speaker 1: suspects and were still looking for whoever was responsible for
17:33
Speaker 1: the deaths of the four friends. So still no suspects,
17:37
Speaker 1: still nobody that they have on their radar, nobody that
17:40
Speaker 1: has crossed their, you know, desk, nothing like that. So
17:44
Speaker 1: the people in the community, obviously, they're not comfortable. And
17:48
Speaker 1: as we talked about earlier, people are leaving in droves.
17:51
Speaker 1: Would you stick around? If you were some college kid,
17:53
Speaker 1: would you stick around? I wouldn't. I'd be out of dodge.
17:56
Speaker 1: First of all, no reason to stick around if this
17:58
Speaker 1: kind of shit's going down. You know, you have professors
18:01
Speaker 1: are canceling classes and the school should just do the
18:04
Speaker 1: right thing and postpone the rest of these classes until
18:08
Speaker 1: they figure out what's going on or let these kids
18:10
Speaker 1: do this work online. We cannot say there is no
18:16
Speaker 1: threat to the community, Moscow Police Chief James Fry said
18:19
Speaker 1: at the press conference on November 16th. There is a
18:22
Speaker 1: threat out there, possibly. We do not have a suspect
18:25
Speaker 1: at this time, and that individual is still out there,
18:28
Speaker 1: he added. We cannot say there is no threat to
18:30
Speaker 1: the community. Well, it's nice that they backtracked on that,
18:33
Speaker 1: because previously when they first said that, that was just ridiculous.
18:41
Speaker 1: Fry said that two additional roommates had been home at
18:43
Speaker 1: the time of the killings, but they were not considered
18:46
Speaker 1: witnesses and are actively cooperating with the investigation. He said
18:51
Speaker 1: the 911 call came in at noon on Sunday morning,
18:54
Speaker 1: hours after authorities believe the four were killed. The morning
18:58
Speaker 1: of November 17th, Latah County Prosecutor, excuse me, Prosecuting Attorney
19:03
Speaker 1: Bill Thompson told Today that it certainly is possible there
19:07
Speaker 1: could be more than one suspect in the case. The
19:09
Speaker 1: fact of the matter is whoever is responsible for these
19:12
Speaker 1: murders is still at large, he said. The investigators do
19:16
Speaker 1: not know who that person is. So a little bit
19:20
Speaker 1: more as far as the autopsy results. And we have
19:24
Speaker 1: another article, another short article right here from the New
19:26
Speaker 1: York Post that adds even a little bit more. So
19:29
Speaker 1: let's get into this article real quick by Mark Longarello
19:33
Speaker 1: over at the New York Post. And let's catch up
19:36
Speaker 1: over here. Headline, University of Idaho murder victims were in bed,
19:41
Speaker 1: stabbed multiple times, according to the coroner. And that's what
19:44
Speaker 1: I wanted to talk about real quick and just add
19:46
Speaker 1: these couple of paragraphs because it added something that we
19:49
Speaker 1: didn't get. in that other article. So according to the coroner,
19:54
Speaker 1: these kids were stabbed multiple times and not just stabbed
19:56
Speaker 1: multiple times, but stabbed while they were in bed. The
20:02
Speaker 1: four University of Idaho students found slaughtered in an off-campus
20:06
Speaker 1: house Sunday were stabbed to death while in bed and
20:08
Speaker 1: it's likely they were asleep when attacked. The coroner has revealed. Yo,
20:12
Speaker 1: that is next level evil. These kids are sleeping in
20:17
Speaker 1: their bed and somebody attacks them while they're sleeping? Lotta
20:23
Speaker 1: County Coroner Kathy Mabbitt gave shocking new details on a
20:26
Speaker 1: Thursday night appearance on NewsNation Banfield as the killer or
20:30
Speaker 1: killers remain on the loose and the large knife, used
20:33
Speaker 1: in butchering the four college students, has yet to be
20:36
Speaker 1: recovered by cops. It was late at night or early
20:39
Speaker 1: in the morning, so it seems likely maybe they were sleeping,
20:43
Speaker 1: Mabbitt told Ashley Banfield. The coroner wouldn't say if the
20:46
Speaker 1: four victims were found in separate areas, but confirmed the
20:49
Speaker 1: bodies were found in beds. The stabbings were targeted in
20:53
Speaker 1: the chest and upper bodies of the victims, Mabbitt said.
20:57
Speaker 1: All right, right away, there's some inconsistencies. The 911 call
21:01
Speaker 1: said there was someone unconscious on the floor, and the
21:05
Speaker 1: 911 call came in from where? Who called that in?
21:08
Speaker 1: If they were all in their beds, how did anyone
21:10
Speaker 1: outside of this house stumble on them? The stabbings were
21:15
Speaker 1: targeted in the chest and upper bodies of the victims,
21:18
Speaker 1: Mabbitt said. It was a pretty large knife, so it's
21:20
Speaker 1: really hard to call them puncture wounds. It has to
21:23
Speaker 1: be somebody that's pretty angry in order to stab four
21:26
Speaker 1: people to death, she told Banfield. Victims Ethan Chapin, 20,
21:32
Speaker 1: Madison Mogan, 21, Zanna Kernodle, 20, and Kaylee Goncalves, 21,
21:37
Speaker 1: were stabbed multiple times in a house on King Road
21:40
Speaker 1: in Moscow, Idaho on Sunday. Mabbitt had previously called the
21:44
Speaker 1: rampage personal and said it was possible that some of
21:47
Speaker 1: the wounds on the body were defensive. There were no
21:50
Speaker 1: signs of sexual assault to any of the students killed,
21:54
Speaker 1: she said. So that's significant, too. What it tells us
21:57
Speaker 1: is it wasn't a crime of sexual nature, right? Somebody
22:01
Speaker 1: going in there, some kind of psychopath, rapist or, you know,
22:04
Speaker 1: Ted Bundy type. And according to what they're saying, but
22:08
Speaker 1: not saying here, was that this was somebody who was angry.
22:11
Speaker 1: So that leads me to believe that maybe there is
22:14
Speaker 1: some kind of, I don't know, beef with one of
22:17
Speaker 1: these kids with somebody else that needs to be investigated.
22:21
Speaker 1: Authorities have been trying to piece together the four's final
22:24
Speaker 1: hours as they say they were murdered sometime overnight, Saturday
22:28
Speaker 1: or early Sunday. Kernodle's father said in an interview with
22:31
Speaker 1: Arizona Family that the autopsy performed on Wednesday showed his
22:35
Speaker 1: daughter fought her killer to the end and had defensive
22:38
Speaker 1: marks on her. So they're saying that they were asleep
22:42
Speaker 1: or in bed. These people creeped up on him. Imagine
22:45
Speaker 1: you wake up to this. Bruises torn by the knife.
22:50
Speaker 1: Jeffrey Kernodle told the publication she's a tough kid. Whatever
22:54
Speaker 1: she wanted to do, she could do it. Kernodle had
22:56
Speaker 1: been in a relationship with Chapman. and the pair had
22:59
Speaker 1: been living together in the house with the other two
23:01
Speaker 1: victims and two others. Law enforcement authorities called the bloody
23:06
Speaker 1: crime the worst they have ever seen as the community
23:09
Speaker 1: remained shaken over the slaughter. Alright folks, so that's where
23:14
Speaker 1: we're at. Now we have the autopsy results, or at
23:17
Speaker 1: least a preliminary look at them. via these two articles
23:21
Speaker 1: and according to the coroner. So we'll see what else
23:24
Speaker 1: pops up and what other news is presented to us.
23:28
Speaker 1: And as that information becomes available, we'll add it to
23:31
Speaker 1: the catalog. All right, folks, that's going to do it
23:33
Speaker 1: for this one. If you'd like to contact me, you
23:35
Speaker 1: can do that at BobbyCapucci at ProtonMail.com. That's B-O-B-B-Y-C-A-P-U-C-C-I at ProtonMail.com.
23:45
Speaker 1: You can also find me on Twitter at B-O-B-B-Y underscore C-A-P-U-C-C-I.
23:51
Speaker 1: The link that I discussed can be found in the
23:54
Speaker 1: description box. What's up, everyone, and welcome back to the program.
23:59
Speaker 1: In this episode, we're going to dive right into the
24:02
Speaker 1: declaration of Veronica DeHeer, the expert who is defending Brian
24:07
Speaker 1: Kohlberger's request to have a change of venue. The Declaration
24:11
Speaker 1: of Veronica DeHeer, Ph.D. I, Veronica DeHeer, solemnly, sincerely, and
24:17
Speaker 1: truly declare and affirm as follows. 1. Experience and Qualifications
24:24
Speaker 1: I am the Director of Survey Operations of the Nevada
24:27
Speaker 1: Center for Surveys, Evaluation, and and Statistics and the Director
24:31
Speaker 1: of the Grant Sawyer Center for Justice Studies at the
24:34
Speaker 1: University of Reno. I received my PhD from the University
24:38
Speaker 1: of Nevada, Reno in Interdisciplinary Social Psychology. I have over
24:43
Speaker 1: 20 years of experience with survey research and have conducted
24:46
Speaker 1: over 100 surveys during my career, including the Behavioral Risk
24:51
Speaker 1: Factor Surveillance System, survey sponsored by the Centers for Disease
24:55
Speaker 1: Control and Prevention in Atlanta, Georgia, since 2006. I also
24:59
Speaker 1: teach a graduate-level course for judicial studies program at UNR
25:03
Speaker 1: entitled JS718 Scientific Research Method for Judges, which includes an
25:09
Speaker 1: entire section on survey methodology. I also serve as a
25:13
Speaker 1: guest lecturer for other UNR faculty for their graduate-level courses
25:17
Speaker 1: on topics related to survey methodology, and my full curriculum
25:21
Speaker 1: vitae was previously provided to the court in defendant Koberger's
25:25
Speaker 1: memorandum in support of a motion to change venue. Introduction.
25:30
Speaker 1: Counsel for the defendant in State of Idaho v. Brian C. Koberger,
25:34
Speaker 1: as part of my duties previously stated in my original
25:37
Speaker 1: expert report, requested I consider the prosecution survey critiques of
25:41
Speaker 1: a community attitude survey conducted by Dr. Brian Edelman and
25:45
Speaker 1: Research Strategies, Inc., and to give my opinion about the
25:49
Speaker 1: merit of those claims as they relate to the survey.
25:52
Speaker 1: I was provided with the defendant's motion for a change
25:55
Speaker 1: of venue, the prosecution's response to that motion, Dr. Edelman's
25:59
Speaker 1: declaration related to the survey results, the report written by Dr.
26:04
Speaker 1: Edelman related to the survey results, and a copy of
26:06
Speaker 1: the survey that was used for data collection. My declaration
26:10
Speaker 1: is based on my educational background and expertise in the
26:14
Speaker 1: field of social psychology and survey research and is independent
26:17
Speaker 1: of my employment at the University of Nevada, Reno. I
26:21
Speaker 1: give my opinion based on previous research in the field
26:24
Speaker 1: of survey research, the facts I know to be true
26:26
Speaker 1: based on the information in the survey report by Trial
26:29
Speaker 1: Innovations Incorporated, and the defense memorandum in support of a
26:33
Speaker 1: motion to change venue. My explanations are stated below. 3.
26:37
Speaker 1: Telephone Survey The Community Attitude Survey presented to me by
26:42
Speaker 1: the defendant's attorney was conducted to assess whether or not
26:46
Speaker 1: the media coverage had any effect on the potential jury
26:49
Speaker 1: pool prior to trial. The RDD, Random Digital Dialing Survey,
26:54
Speaker 1: was conducted in Latah County, Idaho, and in three other
26:57
Speaker 1: counties in Idaho, Ada, Canyon, and Bannock. The questions on
27:02
Speaker 1: the survey included general questions regarding respondents' attitudes toward the
27:06
Speaker 1: criminal justice system, as well as specific, detailed questions about
27:10
Speaker 1: the defendant's case, including the crime and the surrounding community,
27:15
Speaker 1: and questions related to their media and pretrial publicity exposure.
27:19
Speaker 1: According to Dr. Edelman's declaration, A telephone survey was conducted
27:23
Speaker 1: in Latah County. Comparison surveys were conducted in Ada County
27:27
Speaker 1: and Bannock Counties. Research Strategies Incorporated, which is based in Mobile, Alabama,
27:33
Speaker 1: was hired to field the telephone survey. Standard methodological practices
27:37
Speaker 1: related to the development of the instrument, interviewer training, sampling,
27:41
Speaker 1: and callbacks were closely followed. The survey instrument and methodology
27:45
Speaker 1: adhere to the professional standards and guidelines put forth by
27:49
Speaker 1: the American Society of Trial Consultants. All recognition questions were
27:54
Speaker 1: designed to describe the case using the language found in
27:56
Speaker 1: the media coverage. The surveys were in the field between
28:00
Speaker 1: March 5th and July 6th of 2024. Ultimately, 400 jury
28:05
Speaker 1: eligible residents in Latah County, 400 in Ada County, 200
28:09
Speaker 1: from Canyon County, and 202 from Bannock County completed the survey. 4.
28:14
Speaker 1: Response to State's Objection to Defendant's Motion to Change Venue
28:19
Speaker 1: I will address each item in order as enumerated in
28:22
Speaker 1: state's objection to defendant's motion to change venue. A. The
28:26
Speaker 1: survey data provided by Dr. Edelman is inadequate to justify
28:29
Speaker 1: a change of venue. 1. It is not reported how
28:33
Speaker 1: many individuals declined to take the survey, raising serious concerns
28:36
Speaker 1: about non-response bias. The prosecution states, A glaring omission in
28:41
Speaker 1: the data provided by Dr. Edelman is is the lack
28:44
Speaker 1: of any information about the number of individuals who were
28:46
Speaker 1: contacted but chose not to respond to the survey. This
28:50
Speaker 1: is important because non-participation bias can change the outcome of
28:54
Speaker 1: such a survey. CEG Scott Keeter, what low response rates
28:59
Speaker 1: mean for telephone surveys. Calling attention to the number of
29:03
Speaker 1: individuals declining to take the survey by the prosecution is
29:06
Speaker 1: a referral to the survey's response rate. On page 315
29:10
Speaker 1: of Dr. Edelman's report, telephone survey results, descriptive statistics, state
29:15
Speaker 1: of Idaho versus Brian Kohlberger. He provides a table indicating
29:19
Speaker 1: how many individuals declined to take the survey. Non-response bias
29:23
Speaker 1: occurs when those non-responders to a survey differ systematically on
29:27
Speaker 1: the nature of the source error from those who respond
29:30
Speaker 1: to the survey. In other words, bias only exists if
29:34
Speaker 1: there are statistically significant differences between those responders and non-responders
29:39
Speaker 1: in a system way. For the most part, non-response bias
29:43
Speaker 1: is measured based on those characteristics of the survey takers
29:46
Speaker 1: as compared to those characteristics of the non-survey takers, such
29:51
Speaker 1: as based on age, race, or gender. Research Strategies Incorporated
29:56
Speaker 1: and Dr. Edelman use the appropriate survey methodology mitigation strategies
30:00
Speaker 1: to counteract non-response bias, which I explain further below. Regardless,
30:05
Speaker 1: prosecution is claiming that the non-response bias has more to
30:09
Speaker 1: do with those who did not take the survey and
30:11
Speaker 1: states that the main and only reason the non-survey takers
30:15
Speaker 1: would have refused to take the survey is because they
30:17
Speaker 1: had no knowledge of any upcoming jury trial. Prosecution claims
30:21
Speaker 1: even go as far as to state that the reason
30:23
Speaker 1: there is non-response bias in the survey is because they
30:26
Speaker 1: did not have the knowledge about the upcoming jury trial
30:29
Speaker 1: they would have refused to take the survey. This hypothesis
30:33
Speaker 1: posed by the prosecution is called the leverage salience theory
30:37
Speaker 1: and results about the theory are mixed with respect to
30:40
Speaker 1: its impact on non-response bias. Groves 2006 reviewed 30 different
30:45
Speaker 1: studies estimating different variables that could contribute to non-response bias.
30:51
Speaker 1: After examining over 319 bias estimates from these studies, he
30:56
Speaker 1: concluded that non-response by itself is a poor predictor of
30:59
Speaker 1: bias magnitudes and non-response rates explain only about 11% of
31:04
Speaker 1: the variation in different estimates of non-response bias. Additionally, I
31:09
Speaker 1: would like to point out that response rate is not
31:11
Speaker 1: a simple calculation of the total number of surveys completed
31:15
Speaker 1: divided by the total calls made. There are many other
31:18
Speaker 1: items that go into the calculation of a response rate,
31:22
Speaker 1: including known and unknown eligible sample numbers, e.g. completes, refusals,
31:28
Speaker 1: answering machines for known eligible households, no answer, always busy,
31:32
Speaker 1: and ineligible sample phone numbers, e.g. businesses, fax machines, fast
31:37
Speaker 1: busy signals, disconnected numbers. The prosecution's own citation to research
31:41
Speaker 1: conducted by the Pew Research Center and other research conducted
31:45
Speaker 1: by their own organization found that Pew Research Center studies
31:49
Speaker 1: conducted in 97, 2003, 2012, and 2016 found little relationship
31:51
Speaker 1: between response rates and accuracy, and other researchers have found
31:54
Speaker 1: similar results. In addition, according to Groves 2006, as reported
32:04
Speaker 1: in Fowler et al. 2016, response rate is not a
32:08
Speaker 1: good predictor of non-response error, and recent research by the
32:12
Speaker 1: Pew Organization has shown that there are no statistical differences
32:16
Speaker 1: between surveys with lower response rates compared to studies with
32:20
Speaker 1: higher response rates. Finally, the prosecution uses direct quotes from
32:24
Speaker 1: the Pew Research Center 2017 article by Keeter, what low
32:29
Speaker 1: response rate means for telephone surveys, but conveniently omits other
32:33
Speaker 1: direct quotes from the article. As the Pew article explains,
32:37
Speaker 1: the telephone polls greatly overstate civic engagement, probably because of
32:41
Speaker 1: a non-response bias. As has been established in previous work,
32:45
Speaker 1: the people who answer surveys are likely to be the
32:48
Speaker 1: same people that are involved in their community's public life.
32:51
Speaker 1: They are joiners. Such a phenomenon could easily play a
32:54
Speaker 1: role here, where, at the very outset of the survey,
32:57
Speaker 1: Respondents were told that they were being asked for opinions
33:01
Speaker 1: about an upcoming jury trial. Here is the exact quote
33:04
Speaker 1: from the article. Telephone polls greatly overstate civic engagement, probably
33:09
Speaker 1: because of non-response bias. As has been established in previous work,
33:14
Speaker 1: the people who answer surveys are likely to be the
33:16
Speaker 1: same people that are involved in the community's public life,
33:19
Speaker 1: their joiners. Fortunately for pollsters, civic engagement is strongly correlated
33:25
Speaker 1: with political attitudes and or most other measures researchers attempt
33:29
Speaker 1: to study with surveys. It's clear that the prosecution quoted
33:33
Speaker 1: all but the very last line in the above quote,
33:35
Speaker 1: which is fortunately for pollsters, civic engagement, is not, emphasis mine,
33:41
Speaker 1: strongly correlated with political attitudes, or most other measures researchers
33:45
Speaker 1: attempt to study with surveys. Prosecution also ignores two related
33:50
Speaker 1: and contradictory important quotes, and the main conclusion of the
33:54
Speaker 1: same article, which is that The current study and prior
33:58
Speaker 1: research suggest that response rate is unreliable indicator of bias.
34:03
Speaker 1: And despite low response rates, well-designed and carefully weighted telephone
34:07
Speaker 1: surveys still produce accurate information about the political profile of
34:11
Speaker 1: the American public. The authors come to that conclusion regardless
34:15
Speaker 1: of a respondent's greater likelihood of being a joiner. Prosecution
34:20
Speaker 1: concedes that non-response bias can be mitigated by conducting follow-up
34:25
Speaker 1: incentives and training, but also states that these strategies only
34:29
Speaker 1: apply to individuals who would not participate in any survey
34:32
Speaker 1: and it does not mitigate non-response to a survey for
34:35
Speaker 1: someone that declines to take the survey because they have
34:38
Speaker 1: no opinion on the specific subject matter of the survey.
34:42
Speaker 1: Prosecution claims that Defendant flawed hypothesis is that if 98%
34:47
Speaker 1: of a self-selecting group who voluntarily chose to share opinions
34:50
Speaker 1: about an upcoming jury trial have heard about this particular
34:54
Speaker 1: upcoming jury trial, then 98% of all citizens who are
34:57
Speaker 1: summoned for jury duty will have also heard about it.
35:01
Speaker 1: The court should reject this illogical leap of faith and
35:04
Speaker 1: embrace more practical inference. It's more likely that a voluntary
35:08
Speaker 1: survey that begins by asking individuals to opine about an
35:12
Speaker 1: upcoming jury trial will over-represent individuals with knowledge about an
35:16
Speaker 1: upcoming jury trial. The position by the prosecution that those
35:20
Speaker 1: who have no opinion about the upcoming jury trial will
35:23
Speaker 1: not respond undermines the validity of all the research. Surveys
35:27
Speaker 1: are conducted daily all over the world about important political, economic,
35:31
Speaker 1: health-related topics, among others, and the courts and a number
35:34
Speaker 1: of large government agencies to make decisions and to create policy.
35:39
Speaker 1: These surveys include respondents who may have no opinion whatsoever
35:43
Speaker 1: about the subject matter of the survey. If respondents who
35:46
Speaker 1: took the survey were only interested in the topic and
35:49
Speaker 1: those who did not respond to the survey were only
35:52
Speaker 1: those not interested in the topic, all survey research would
35:55
Speaker 1: be considered completely invalid. While it's true that the salience
35:58
Speaker 1: of the topic of the survey is may increase participation
36:02
Speaker 1: in a particular phone survey as mentioned above, the name
36:05
Speaker 1: of the specific jury trial was not mentioned in the
36:08
Speaker 1: introduction of the survey conducted by the defense. If this
36:12
Speaker 1: statement by the prosecution were true, recognition rates and percentage
36:15
Speaker 1: of survey responders within each survey across all comparison venues
36:20
Speaker 1: would be equal to each other. That is, only those
36:23
Speaker 1: who knew about an upcoming trial would take the survey.
36:27
Speaker 1: In reality, the salience of the survey topic can also
36:30
Speaker 1: decrease response rates or increase non-response bias. However, following on
36:35
Speaker 1: the same line of reasoning as the prosecution, a respondent
36:38
Speaker 1: with no opinion on a topic would never be included
36:41
Speaker 1: in survey data, when in fact the opposite is true.
36:45
Speaker 1: Many survey response options in survey design are written with
36:48
Speaker 1: the idea that the respondent will answer with exactly a
36:51
Speaker 1: no opinion response so that the response option is offered
36:55
Speaker 1: to the respondent as a possible choice. as was the
36:58
Speaker 1: case in the telephone survey that was conducted by Research Strategies.
37:03
Speaker 1: For Defendant Koberger, just because a respondent has no opinion
37:06
Speaker 1: on the survey topic does not mean that can't or
37:09
Speaker 1: won't take the survey at all or won't or can't
37:13
Speaker 1: answer other questions. For example, in the telephone survey used
37:16
Speaker 1: specifically in this case, respondents were asked approximately eight questions
37:21
Speaker 1: before they were ever asked a single specific question about
37:24
Speaker 1: this case. and if they had not read, heard, or
37:27
Speaker 1: seen anything about this case. They were never asked general
37:31
Speaker 1: questions about their media habits, and all case-specific questions were skipped,
37:35
Speaker 1: see Survey Appendix B, page 74, in Brian Edelman's declaration,
37:40
Speaker 1: provided in defendant's memorandum in support of motion to change venue.
37:44
Speaker 1: There was no need for a respondent to quit or
37:46
Speaker 1: terminate the survey just because they did not have any
37:49
Speaker 1: opinion about the Kohlberger case. In fact, the skip pattern
37:53
Speaker 1: in the survey allows for a respondent to skip to
37:56
Speaker 1: question 17 if they state no on the two questions
37:59
Speaker 1: about recognition of the case. Therefore, the prosecution's argument is
38:04
Speaker 1: flawed in stating that there is no response bias for
38:06
Speaker 1: those people who refuse to take the survey just because
38:10
Speaker 1: they did not know anything about the case or because
38:13
Speaker 1: they were told the interview would be recorded. There are
38:16
Speaker 1: many reasons why a person could have refused to take
38:18
Speaker 1: the survey unrelated to the case at all, e.g. too busy,
38:22
Speaker 1: making dinner, not interested, driving right now, working, giving kids
38:25
Speaker 1: a bath in the middle of a doctor's appointment at
38:28
Speaker 1: the store. And there are many reasons why a person
38:31
Speaker 1: would terminate the survey in the middle of taking it.
38:34
Speaker 1: the non-response mitigation strategies that are used by competent survey organizations,
38:39
Speaker 1: such as a good survey design and interviewer training to
38:43
Speaker 1: include good refusal conversion strategies, incentives, follow-up calls, and statistical weighting.
38:49
Speaker 1: This is used on all non-responders, not just those individuals
38:53
Speaker 1: who would never take any survey, as the entire point
38:56
Speaker 1: of refusal conversion strategies and other strategies is to mitigate
39:00
Speaker 1: non-response bias. The prosecution argues that survey respondents should have
39:05
Speaker 1: been told exactly who was calling and asking these questions
39:08
Speaker 1: and why. Doing so would have created bias. Those who
39:12
Speaker 1: would not want the survey to be conducted related to
39:14
Speaker 1: the crimes because they would not agree to change venue
39:17
Speaker 1: for the defendant, for example, because they have prejudgment and
39:21
Speaker 1: believe the defendant is guilty, or who believes he should
39:24
Speaker 1: face justice in their county only because it's their community
39:27
Speaker 1: and it directly affects them, would lead not only to
39:30
Speaker 1: greater non-response bias and lower response rates, but it could
39:34
Speaker 1: also lead to greater biased responses to specific survey items.
39:38
Speaker 1: For example, a respondent who was told the introduction to
39:41
Speaker 1: the survey that its purpose is to help the defense
39:45
Speaker 1: move Mr. Koberger's trial out of Latah County may now
39:48
Speaker 1: refuse to take the survey completely because they do not
39:51
Speaker 1: want to help Mr. Kohlberger or possibly lie and say
39:54
Speaker 1: that they really did not know anything about the case,
39:57
Speaker 1: basically minimizing their knowledge. Telling them about a case could
40:00
Speaker 1: create a placebo effect. As in clinical trials, there's a
40:04
Speaker 1: person is told they are in the clinical condition where
40:07
Speaker 1: a new drug is being administered when in fact they
40:09
Speaker 1: are in the placebo group. Telling a respondent exactly why
40:13
Speaker 1: you're doing research study is the opposite of scientific research
40:16
Speaker 1: protocol in a research trial due to the demand characteristics
40:20
Speaker 1: generated when such knowledge is given to the participant. If
40:24
Speaker 1: a participant knows exactly why the study is being conducted,
40:27
Speaker 1: that knowledge may influence their behavior, that is, the respondent
40:31
Speaker 1: may change their behavior or response in a way that
40:34
Speaker 1: would give the researcher the outcome the respondent thinks the
40:37
Speaker 1: researcher is looking for due to social desirability, to be
40:41
Speaker 1: a good research participant. The prosecution also states this court
40:45
Speaker 1: must ask itself would an individual who was asked for
40:49
Speaker 1: their opinion about an upcoming jury trial continue a survey
40:52
Speaker 1: if they had no opinions about any upcoming jury trials?
40:56
Speaker 1: And once the survey started, would a prudent, thoughtful, and
40:59
Speaker 1: conscientious person who is reluctant to pass judgment with limited
41:02
Speaker 1: information opine to a stranger whether they believe a criminally
41:06
Speaker 1: accused is guilty of murder? I respond to this comment
41:10
Speaker 1: with the same reasons I provide above. Specifically, respondents may
41:13
Speaker 1: refuse to continue the survey for the same reasons they
41:17
Speaker 1: might refuse to start the survey in the first place.
41:20
Speaker 1: And those reasons may have nothing to do at all
41:22
Speaker 1: with the subject matter of the survey. To reiterate the
41:25
Speaker 1: quote above, prosecution states defendant's flawed hypothesis is that 98%
41:30
Speaker 1: of self-selecting group who voluntarily chose to share opinions about
41:34
Speaker 1: an upcoming jury trial have heard about this particular upcoming
41:38
Speaker 1: jury trial, then 98% of all citizens who are summoned
41:42
Speaker 1: for jury duty will also have heard about it. The
41:45
Speaker 1: prosecution claims that Dr. Edelman's statements and therefore Mr. Koberger's
41:49
Speaker 1: claims cannot be generalized to the entire jury pool. The
41:53
Speaker 1: prosecution stating that the defendant can only state that 98%
41:57
Speaker 1: of the survey respondents, a self-selecting group, even though they
42:01
Speaker 1: were randomly sampled, can claim that they're familiar with the
42:04
Speaker 1: case and its related events and not 98% of those
42:08
Speaker 1: summoned for jury duty. Even though the entire point of
42:11
Speaker 1: a random sample of participants is to be able to
42:14
Speaker 1: generalize the entire jury pool from which those summoned for
42:17
Speaker 1: the jury are ultimately drawn. Based on the report of
42:20
Speaker 1: the survey results provided by Dr. Edelman, which includes the
42:23
Speaker 1: survey methodology employed, I find the prosecution statement to be flawed. Dr.
42:29
Speaker 1: Edelman and Research Strategies Incorporated used the appropriate method of
42:33
Speaker 1: sampling telephone numbers from the community in a random manner
42:37
Speaker 1: in order to achieve 400 completed surveys in Latah County,
42:40
Speaker 1: 400 in Ada County, and 200 in each of the
42:44
Speaker 1: other two comparison venues, 202 in Bannock County. And Research
42:48
Speaker 1: Strategies also employed the appropriate survey methodology to minimize response
42:53
Speaker 1: bias and non-response bias following appropriate sampling and calling protocol.
42:59
Speaker 1: In survey research, it's customary practice to order an X
43:03
Speaker 1: number of sample pieces, i.e. replicates of telephone numbers, based
43:07
Speaker 1: on a formula that includes the incidence rate of the
43:10
Speaker 1: phenomenon of interest. It's also proper calling protocol to call
43:14
Speaker 1: sample replicates up to three times or more at different
43:17
Speaker 1: times of the day and on different days of the
43:19
Speaker 1: week in order to reach an eligible respondent until those
43:22
Speaker 1: replicates are called to completion. The number of completed surveys
43:27
Speaker 1: needed to represent an entire county district, i.e. the jury pool,
43:31
Speaker 1: is calculated via a power analysis, often conducted using a
43:35
Speaker 1: sample size calculator widely available for free use on the internet.
43:40
Speaker 1: The number 400 was the target sample size used in
43:43
Speaker 1: Latah and Ada counties, and when a sample size calculator
43:46
Speaker 1: is used, 400 is the typical number used to generalize
43:50
Speaker 1: to a population of over 20,000 people, with 95% confidence interval,
43:56
Speaker 1: and a 5% margin of error when a binary outcome, e.g.
44:00
Speaker 1: 50% yes or 50% no, is expected or the outcome
44:05
Speaker 1: is unknown. The most conservative response distribution that can be
44:10
Speaker 1: used in the sample calculator is a 50% that will
44:13
Speaker 1: yield the largest sample size regardless of response format, i.e. yes-no, 5-point,
44:19
Speaker 1: Likert scale such as strongly agree or strongly disagree. The
44:23
Speaker 1: random sampling that we use to achieve the target number
44:26
Speaker 1: of completed surveys allows for the ability to generalize the
44:30
Speaker 1: survey results to the entire jury pool. Research organizations such
44:34
Speaker 1: as the RAND Corporation and the Pew Research Center often predict,
44:38
Speaker 1: with accuracy, political poll results across the entire nation based
44:42
Speaker 1: on a random sampling of only 1,000 completed household surveys.
44:47
Speaker 1: For example, frequently asked questions and how can a small
44:50
Speaker 1: sample of 1,000 or even 10,000 accurately represent the views
44:52
Speaker 1: of 250 million plus Americans. The 200 randomly sampled completed
45:00
Speaker 1: surveys in the other counties could possibly be weighed to
45:03
Speaker 1: represent the larger populations in those districts in order to
45:07
Speaker 1: reduce the non-response bias, but the 200 completed surveys, even
45:12
Speaker 1: without this weighting, can still be statistically analyzed to provide
45:15
Speaker 1: meaningful information about those sampled in order to describe the
45:19
Speaker 1: community attitudes likely to be found in those jury pools.
45:23
Speaker 1: There will just be a slightly larger margin for error.
45:26
Speaker 1: Conclusion In conclusion, I do not find any supporting evidence
45:30
Speaker 1: for the prosecution's claim that the defendant has failed to
45:33
Speaker 1: meet his burden of showing that change of venue in
45:36
Speaker 1: this case is necessary based on the community attitudes survey
45:40
Speaker 1: conducted by Dr. Brian Edelman and Research Strategies Incorporated on
45:44
Speaker 1: behalf of the defendant. In fact, in my opinion, I
45:48
Speaker 1: find the opposite to be true. I declare under the
45:51
Speaker 1: penalty of perjury under the laws of the state of
45:53
Speaker 1: Nevada that the foregoing facts are true and correct. except
45:57
Speaker 1: as to the facts stated upon information and belief, which
46:00
Speaker 1: facts I believe to be true. This was signed by Dr.
46:04
Speaker 1: Veronica DeHeer, and it was dated August 19th, 2024. All right,
46:10
Speaker 1: so we'll wait for the response from the prosecution, and
46:13
Speaker 1: once we have that, we'll get it added to the catalog.
46:16
Speaker 1: But until then, that's going to do it for this one.
46:19
Speaker 1: All of the information that goes with this episode can
46:22
Speaker 1: be found in the description box.