FULL — Kristin Ramsey makes first court appearance in Ashley Okland murder case, pleads not guilty

[0:28] Thank you for your courtesy. You may be seated. We will open our record. We're here in case number [0:46] FECR 051688, State of Iowa versus Kristen Ramsey. Ms. Ramsey is here today in person [0:59] with her counsels of record, Mr. Parrish, Mr. Brandon Brown, Ms. Westhoff-Gentry. The state [1:08] likewise appears here today through their counsel of record, the county attorney, Mr. Schultz, [1:18] the assistant county attorney, Ms. Loving, and Mr. Brown, who appears here as well from the Iowa [1:25] Attorney General's office. Ladies and gentlemen, we have a large crowd here today, and so I want to [1:35] start by saying that we are here today to conduct a hearing, and the outcome of this hearing, the [1:42] court recognizes is important to all concerned. As presiding judge, it's my duty today to ensure [1:52] that this hearing is conducted with dignity and respect so that each side, when they leave this [1:59] courtroom, can say after the hearing has been held that a fair hearing was held. Therefore, let me say [2:09] at the outset to the members of the audience, though this is a public courtroom and a public hearing, [2:19] justice dictates that there be no disruption from anybody here that could affect the outcome or which [2:27] could prejudice either side. Therefore, to ensure a fair hearing, I'm going to put the following rules [2:35] of decorum in place. Number one, upon entering or leaving the courtroom, please do so quietly so [2:45] as not to interfere with these proceedings. If you have a seat, please remain seated unless you are [2:54] entering or leaving the courtroom. Do not converse in audible tones while court is in session so that you [3:02] can be heard by the court of the parties because that would distract from these proceedings here today. [3:10] No outbursts by any person will be tolerated and if there are any outbursts, they will be dealt with [3:18] immediately by the court and any offending party will be removed from the courtroom. I think the easiest [3:25] way to convey what I mean is that I expect you all to conduct yourself in the same manner that you would [3:32] want people to conduct themselves if you were a party to this case. Now, I will not repeat this going [3:41] forward and I expect to know that you will each conduct yourself accordingly. With that, let's proceed [3:48] to the hearing that is before the court today. Before we came into open court, the defendant filed a written [3:57] arraignment which the court has reviewed and I will enter a not guilty plea as set forth in the written [4:06] arraignment in the record. The defendant has waived her right to a speedy trial. So the first item of business [4:14] will be to pick a trial date and so Mr. Schultz, I'll turn to you first. What do you propose as a trial [4:21] date? Thank you, your honor. Your honor, we expect discovery to be lengthy in this matter. I believe it'll [4:34] take defense expect some time to be able to get through that and so I don't know if we can go off the [4:43] record, your honor, and talk to defense and see if we can come up with a mutual date. Very well, if that's [4:49] acceptable to the parties, when we take a recess, we'll see if we can come up with a date. Mr. Parrish, [4:55] is that acceptable to you and your client? Yes, your honor, that is acceptable. Very well, and we'll handle that [5:01] before we conclude today and after I hear the input of the parties, we'll set a trial date and the next [5:07] court proceeding in this case. There are two other matters the court needs to hear and decide. The first I [5:16] want to address is the defendant's motion which has been filed, I believe, on April the 8th. Excuse me, [5:23] that was the resistance was filed on April 8th. The original motion was filed on March the 19th. The [5:39] motion is the defense motion to quash the search warrant and for protective order. Mr. Parrish, I understand [5:46] that you are the one who's going to be arguing that motion. Is that right, sir? That is correct, your honor. [5:50] And Mr. Parrish, I appreciate the courtesy but you can be seated, sir. Okay, thank you. [5:55] And Mr. Parrish, I would turn it over to you for any record you want to make in support of your [6:00] motion. Judge, with that motion, as the court is aware, we filed an exhibit from an expert witness. [6:10] Mr. Schultz and I had some initial discussions about that. It's the phone, your honor, which we did not [6:19] identify, but it is the phone that was taken in 2026. In that phone, according to our expert's opinion, [6:30] I think Iowa Forensics is the company. And your honor, I would object just for the fact that we're [6:37] going to be discussing an exhibit that was provided past the deadline. The court had done an original [6:45] order stating that the parties needed to submit exhibits by the 8th. The state didn't see this [6:50] exhibit till today. And so I'd ask that we strike the exhibit from the hearing today, your honor. [6:58] Your response, Mr. Parrish? Well, I thought our off-the-record discussion and the prior discussion, [7:04] I can limit my argument solely to the prior discussion that Mr. Schultz and I have had about it. [7:10] Your honor, it's your discretion as to whether or not you think this exhibit will give you some [7:16] guidance in the decision. I think it's a common sense type of exhibit. He doesn't go into any [7:22] details about the specific phone. So I don't think that's the issue, but I think we all have common [7:28] sense that your phone might have what you call personal information, such as communications with [7:34] counsel. Second of all, it would have information related to medical records. I get all of my [7:40] medical records on my portal, on my phone, and I think most people do nowadays. So it's that type [7:46] of information that we believe should be restricted. Specifically addressing the issue of whether or [7:52] not it should be late or not, I'm not sure the state has filed any exhibits. Mr. Schultz told me as late [7:59] as last night they did not plan to file any exhibits. Mr. Parrish, I'm sorry to interrupt you, but let me just [8:06] deal with this exhibit issue first and we'll give you a chance to make your argument. So, Mr. Parrish, [8:11] just so I understand, are you offering the exhibit or not? Yes, we believe the exhibit should be [8:17] presented. I think the court in its discretion to see whether or not it is informative to the court [8:24] as to what type of information might be private. But I'm sure with the number of cases I've handled [8:28] with this area, I can make a professional statement. But we think the exhibit ought to be accepted by the [8:33] court. The state has a copy of it, they can review it, they can determine whether or not they see [8:40] something that's objectionable about it. We would leave it at that judge. Mr. Schultz, just so I [8:47] understand, you're not asking to continue the hearing, you're just asking to exclude the exhibit, [8:51] is that correct? Yes, Your Honor. And so tell me what the reason is for the exclusion? Well, Your Honor, [8:58] the court had entered an order that we exchange exhibits prior to the hearing. I believe they needed [9:05] to be exchanged and filed by Wednesday of this week at 4 30. That was not done in this case. This exhibit [9:12] was filed this morning. It doesn't provide us an opportunity to really respond to it, other than to [9:20] verbally, I guess, get into it. We don't have our own expert now to rebut anything that Mr. Parrish is [9:26] stating. I'd ask the court to strike it, and if not, then give it limited weight. So I guess that's why I asked the [9:34] question about the continuance. You're not asking for additional time to hire your own expert to [9:40] counter the exhibit, is that correct? Correct, Your Honor. We're not asking for continuance. Very well. [9:45] Well, the court hasn't seen the exhibit, so Mr. Parrish, I'm going to reserve ruling as to whether [9:51] or not I consider the exhibit because I haven't had a chance to review it, but I will admit it into [9:57] evidence. The question is going to become whether or not the court gives consideration to it. So with that [10:02] understanding, Exhibit A is admitted. I appreciate that, Judge. Now, I would say not arguing the [10:10] exhibit, what it goes to, we have to first of all determine what type of phone our client had in [10:16] their possession that was seized. Mr. Schultz and I had a lengthy conversation in his office about what [10:23] information may be private and what information might be subject to their access. I will say this, [10:33] we have no issue with the access to the information that the state is seeking, because I think we [10:41] discussed whether or not we would be actually asking for what's called a protective order with regard to [10:47] privacy matters or whether or not there would be information that the state feels might be important. [10:55] So I would say Judge is really a common sense application to this. I've discussed how in the [11:01] past judges have handled this matter, which they have said this is certain information in federal court [11:09] is handled by they will do what they call a taint team. That taint team will look at that information. They will [11:20] decide, well, is it attorney-client privilege? Is it medical records coming from a certain doctor? Is it her [11:29] son's medical records that would be irrelevant to anything? Or the conversation, all the privileged areas such as [11:36] spousal privilege, that is protected. We don't think the state in their initial warrant, and I believe Mr. [11:44] Schultz has properly indicated, they have not actually issued the warrant yet. And I get that, [11:49] because I believe he indicated he was going to hold up until you would give us some direction as to how [11:55] that should be handled. I will tell you from my experience how we've handled it before, either with [12:01] the tape team, which is just automatic in federal court. In state court, a few state court judges [12:09] have said, okay, let an independent examiner have it, as opposed to the DCI. My last experience was with [12:15] the DCI, where the DCI had actually seized the phone, asked the judge for a warrant, and there was private [12:22] information on that phone, and the judge assigned an independent forensic examiner to look at it to exclude. [12:32] Under what's called the Cellbrite software download, in that instance, they download everything. [12:41] They just put it on a software, everything goes into it. So that means that with regard to Ms. [12:48] Ramsey's phone, all her private information would go to the government without any of the protected [12:55] mortals. So all we're saying is, I think we can work out an agreement with them, where if they wanted to, [13:01] we could say, okay, this is excluded. But we would want our expert there watching that download to [13:07] make sure that private information is excluded. Clearly, they have a right to some of the information, [13:14] and that might be on it, may be relevant to them. I think they're entitled to get it. But a private, [13:20] protected information under the protected area that is statutory in Iowa, they are not entitled to have [13:27] it without a specific request to you. Does that conclude your argument, Mr. Briggs? [13:32] It does, Your Honor. Thank you. Very well. Mr. Schultz. Thank you, Your Honor. Your Honor, [13:36] just for the record to be clear, search warrants are secret, and they're secret for a reason. But I will [13:42] clarify, because I want to clarify the record. A search warrant was originally done, which allowed us to [13:49] seize electronics, including the phone of the defendant. Another search warrant was issued, [13:57] but not executed, because we are waiting to see what this court is going to do. And so I want to be [14:03] clear on that point. It's not something we would normally argue about, because these are usually secret. [14:10] But in this case, since it's being discussed today, I want to be clear on that. You know, [14:16] the reason we have search warrants is to protect the rights of citizens under the Fourth Amendment of [14:23] the Constitution in Article 1, Section 8 of the Iowa Constitution. It protects us from unlawful seizures. [14:32] It also protects our right to privacy. But the reason we have a search warrant is to balance those rights [14:39] with the interest that the state has in order to collect evidence when a crime is committed. And so, [14:45] to me, when I look at the rules of criminal procedure, there's no rule that allows the court [14:54] to create boundaries on a search warrant or after the fact. The court actually, there's a process in [15:01] place under the rules that allows the court to look at the evidence that's presented, weight the [15:07] statements from law enforcement, from probable cause, and then make a determination on whether to sign the [15:13] warrant or not. And that is the balance that struck under the law to protect the rights of citizens, [15:20] but also protect the interest of the state in looking for evidence and investigating evidence [15:26] of a crime. To me, what the defense is asking is that if I were to show up to a house with a search [15:35] warrant that's been lawfully entered, that a defendant and their attorney can stand at the door and say, [15:40] wait, you can't search the house. You have to, you can only search this room or that room or that room, [15:47] and that's not, but that's not what's in the warrant. The way the law works and has been working for [15:53] hundreds of years is it provides protection for the defense, for the defendant, if there's something [16:01] illegally searched or obtained to file a motion to suppress and to suppress the evidence. And that is [16:16] what in this case that should happen. The defense shouldn't be able to stop the state from going in. [16:23] If they go into the house and find evidence that's relevant, that's not in the search warrant, [16:28] they're required to go back to the court and apply for another search warrant. And it'd be no different [16:33] in the case of a cell phone. If we were to go through the cell phone and find something that [16:38] wasn't in the parameters that the court signed in the search warrant, we would be required to come back [16:44] to the court with another search warrant to search the, the, for the items, uh, that are relevant. [16:50] If something is privileged, then the court will make that determination after the fact, [16:55] through a motion to suppress saying that the state's not allowed to use that evidence and that there's [17:01] no case law. There's no rules of in criminal procedure that allow for the court to put boundaries [17:10] after the search warrant has been signed. And so in this case, your honor, we're asking the court to [17:19] allow us to, to execute the search warrant and any for any future search warrant that we may, uh, ask for [17:27] in the future to allow us to do the investigation that we are allowed to do under the law. Thank you, [17:35] Your Honor. Mr. Schultz, what's your response to the defense's argument that perhaps this phone contains [17:45] attorney-client privilege? While I agree that's an evidentiary privilege, but still, if there was [17:52] attorney-client privilege on this device, you wouldn't be asking for that, would you? We would not be, [17:57] and it's not, and it wouldn't be inside the search warrant. And so if the, if the police officers were [18:03] to run into that, they would skip over it because it's not part of the search warrant. And that's how [18:08] it's done in every other case in the state. And that's how it's always been done. We are creating a [18:14] legal fiction, in my opinion, to allow defense to attack the investigation before we even know. And that's, [18:23] it's not allowed in under federal rules and it's not allowed under our state rules. [18:29] Thank you, Mr. Schultz. Is there anything else you'd like to make part of the record regarding [18:34] this motion? No, Your Honor. And Mr. Parris, since it's your motion, [18:39] I'll give you the last word on the motion. Thank you, Your Honor. I refer the state to [18:42] Riley v. California. And Mr. Parris, I appreciate the courtesy. Oh, I'm sorry. It's just an old habit I can't [18:48] break, Judge. I appreciate it. Uh, yes. Um, I would refer the state to Riley v. California, [18:54] which was the first United States Supreme Court case to deal with it. And then all these cases [19:00] have come down since that time. I think your question was spot on. What if there's a attorney [19:05] client? So does the state then have a right to go in and pull up that attorney client stuff, [19:10] let the DCI look at it? And this is, oh man, look what we got. But also we have another unique factor [19:15] in this case. It's 15 years old, Judge. What stuff they're looking for is 2026. So, uh, part of our [19:24] issue is going to be, well, where's the data from the phone from 2011? First of all, [19:30] did you go in there and spoil it? We don't know yet because they haven't given us that information. [19:34] But also in 2026, they're asking for information. Uh, it's kind of like, uh, the other day when they [19:40] are digging in the backyard in 2026 related to information from, uh, 2011. Um, so Riley v. California [19:50] is kind of the seminal case where the United States Supreme Court say, hey, phones are just [19:55] like, uh, rooms as, uh, uh, as has been eloquent. It's described by, uh, uh, Mr. Schultz. So what the [20:03] Supreme Court has said, you gotta be careful. You gotta go get a warrant because they used to search [20:07] them without warrants, as you probably know, your honor. But now that these, you have these cell phones, [20:12] you just can't go into them. Every case judge I have been involved in, in federal court, [20:18] where that issue has come up, they have a taint team. Now I know this is not federal court. This [20:21] is state court. In state court, every motion we file for a protective order says this. It's not [20:28] super complicated. It just says, look, if you get, uh, information that is private and you can't see it, [20:37] if it's a cell bright download, that's why they won't talk about it because they know the cell bright [20:41] download downloads everything. They don't have any eyes to see attorney client privilege, medical records, [20:47] stuff like that. That's why it's so important, your honor, for you to take a look at that. [20:52] And if necessary, Mr. Schultz feels he needs an expert. We're happy to, to debate it, but we're [20:58] happy to give him everything he's entitled to. Uh, we just don't want to give him our client's medical [21:03] records or conversation with her spouse, but conversation with, uh, if it's a priest or minister, [21:10] she's not, they're not entitled to get it. Now there may be certain circumstances that they could get [21:14] this under, but not on some general warrants that we're going to go on a, on a, on a search of her [21:20] cell phone. I wouldn't want people to have my cell phone because it has every medical record I've ever [21:24] had on it. And that's the same thing that, uh, Ms. Ramsey is entitled to protect. So, uh, I think it's [21:32] an easy solution, your honor. That's all I would say. Your honor may be heard briefly. Go ahead. [21:38] I would, I would just ask the court to look at our, our brief that we filed and I, and I do want to point [21:43] out that these privileges are testimonial privileges. I understand counsel, your position. [21:48] Thank you, your honor. Mr. Parrish, anything else? No, your honor. Thank you so much. Um, [21:52] Mr. Parrish, uh, I would like the benefit of having you to, to submit a proposed language with a proposed [22:00] order, excuse me, with language that you propose. That doesn't mean I'm going to grant it, but I want [22:04] to see the parameters of what you're requesting specifically. And counsel, once he does that, [22:09] you certainly can, uh, file any proposed response that you'd like. Okay? Thank you, judge. Very well. [22:14] Thank you, your honor. Okay. The next matter of business today is the last matter of business, [22:19] and that's the defendant's motion for bond review. Uh, Mr. Brown, I understand you're going to be [22:26] presenting the evidence on that. Is that correct? Uh, yes, your honor. Argument. My, we don't have [22:31] witnesses, but yes. I'm sorry. It's all right. I forgot there was two Mr. Browns. I apologize. Oh, [22:35] I'm sorry. I thought you were, I saw who you were looking at, but we are not related. Fair enough. [22:41] So Mr. Brandon Brown, excuse me, if you are ready to present evidence, you may do so. Your honor, [22:47] before we present evidence, do you have a problem if we deal with the issue, uh, first of all, of the [22:54] nature of the offense and then, um, in my opening, uh, to the court and then Mr. Brown then would deal [23:01] with the witnesses. Uh, if you, I, if you want me to deal with it afterwards, I'm happy to. Yeah, here, [23:05] here's what I'd like to hear. I'd like to hear all the evidence to be offered. Sound [23:08] like the state does not have any evidence. Then I'd like to hear the arguments of counsel regarding [23:13] what you believe the court should do. Okay. Thank you. And you don't mind us splitting that [23:17] point. No. Because we won't get into the nature. Thank you. Appreciate that. Mr. Brandon Brown. [23:24] Thank you, honor. May it please the court. The court is well aware of the factors that must consider [23:30] when Mr. Brown, I'm sorry. Maybe I wasn't clear. I'd like to hear the evidence. Yeah. Yeah. I'm just [23:36] going to give you a brief summary of what we'll expect from our witnesses. I don't need to hear [23:41] that. Just present the evidence. Fair enough. Um, we would call our first witness then Christy [23:46] Williamson, your honor. Okay. No, that's fine. Okay. Ma'am, if you come forward, when you're ready, [24:05] face me and raise your right hand, I'll swear you in. Do you solemnly swear or affirm that the testimony [24:12] you're about to provide be the truth, the whole truth, and nothing but the truth? Please be seated. [24:18] Ma'am, that microphone in front of you, you can move your chair to get a little closer. If you [24:25] could make sure to speak into it so we can all hear you, that would be appreciated by the court. [24:30] Counsel, when you're ready. Thank you, your honor. Uh, good morning, ma'am. Would you mind stating your [24:34] name first and last and spell them for the record? Christy Williamson, K-R-I-S-T-I-W-I-L-L-I-A-M-S-O-N. [24:45] Ms. Williamson, do you reside here in the state of Iowa? I do. Where do you live? Osceola. And do you [24:53] reside in Osceola with anyone? My husband. Okay, sorry. Are you currently employed? Yes. Um, in terms [25:06] of the length of employment, how long have you been gainfully employed, ma'am? Since I was 16. And do you [25:13] have any criminal history? No. Can you tell the court, um, how you know Chrissy Ramsey? Chrissy and [25:23] I went to school together. Um, she came in sixth grade. Um, and what school did you go to? Woodward [25:31] Granger. And can you tell the court generally what size of class would you have at Woodward Granger? We [25:39] had a very small class. Um, I would say 20 to 25. In a, in a small class like that, I suspect that the [25:47] circle of friends is all pretty close. Is that fair to say? Very much so. Um, and having a small [25:55] class size like that, not only do you get to know your classmates as friends, but I suspect you also [26:00] get to know their, uh, family as well. Is that correct? Yes. Do you know Chrissy's family? I do. Can [26:07] you tell the court a little bit about Chrissy's family? Uh, they're good people. Um, it throughout [26:15] school, you know, we always did different things. We had slumber parties, that sort of thing. Um, [26:20] and going over to Chrissy's house was always fun. It felt like home. Um, she had several cats and a [26:27] dog, Duncan. Her siblings were great. Chris and Julie were great. Good people. Did you always feel [26:36] welcome in their home? Always. It felt like, it felt like home. You always felt safe at their home? [26:42] Always. Now I understand you currently live in Osceola, is that correct? I do. And up till Chrissy's [26:49] time of arrest, she was in Woodward. Is that your understanding? Right. Now you had told the court [26:54] that you had, um, went to school with Chrissy until graduation. Um, have you kept in contact with [27:00] Chrissy at all since graduation? Um, through social media, her mom, um, you know, through town people. [27:12] But while you were in school, would you agree that you knew her through middle school, junior high, [27:18] and high school, those critical periods, uh, where character development and personality [27:24] development were occurring? Yes. Can you tell the court a little bit about Chrissy's character [27:30] that she exhibited as you knew her and as she developed it through those, uh, important [27:35] developmental years? She was a sweet person, um, from day one, sixth grade. Uh, very caring, [27:43] compassionate, um, self selfless person. She would do anything for anyone. Did she have a lot of friends? [27:55] She did. Everyone. Everyone liked her. She got along with everybody. Is that correct? She did. What kind [28:03] of activities would you do with Chrissy while you knew her in school? Um, school things, of course. Um, [28:11] I think we were seventh grade basketball cheerleaders. I think we were only two at that time. Um, [28:18] and then in junior, senior year, we were on the competition squad. Tell the court a little bit [28:24] about that. Um, it was a group of 10 girls and Chrissy was a co-captain. Um, that was probably the [28:33] funnest two years of my life. Did a lot of things for the group. We qualified for a national cheerleading [28:43] championship in Anaheim, California. Um, we all went and parents went, my parents went, [28:53] had a great time, great memories. Um, in terms of how she acted outside of school, [29:04] did you ever see any behavioral problems? No. How about in school? Did you observe [29:08] any behavioral problems? No. Um, was Chrissy a positive person? Always. What would you say [29:17] about her in terms of her compassion? Um, she was always caring, willing to help, um, no matter what, [29:27] no matter who it was, just always, always there wanting to talk. If you needed to talk, [29:35] she'd make you laugh if you needed to laugh. Did she just a good person? Did she take any [29:42] leadership positions at any activities in school? Uh, right. She was, um, the co-captain of [29:48] cheerleading and let's see, that's all I can think of right off the top of my head right at the moment, [29:53] but a very well-respected person all throughout high school. Everybody wanted to be around her, [30:01] liked her. And her reputation through school? Excellent. What was she like in terms of trying [30:10] to attain popularity? Did you observe anything along those lines? She didn't try to be popular, [30:16] she just was, because everybody liked her. She was a good person to be around. Did you ever see [30:24] any evidence of bad character being exhibited by Chrissy? No. How was her temperament as you knew [30:31] her throughout school? She is probably the most even-tempered person I know. I have never seen [30:37] this girl be angry, mad, or upset, ever, ever. If I were to ask you what was the worst thing that you [30:49] ever saw Chrissy do, what would you say? Well, traditionally, in high school, as cheerleaders [31:01] of the football team, we may have TP'd the football players' houses. That is the worst I've ever seen. [31:10] Was Chrissy a helpful person? Did she demonstrate empathy for and care about people throughout [31:19] school? Yes. Was she responsible? Yes. How so? Well, she showed up every day, for one. She was very loyal. [31:30] You could count on her. She always did her school work, of course. She was always there for cheerleading [31:38] practice, always. You could just depend on her. Good attendance? Good attendance. She was invested in all [31:45] of her activities? Yep. She took everything she did seriously? Yes. You said you knew her family, [31:52] you spent time with her family. How would you describe her family in terms of their character and [31:56] their- Very similar. Chrissy and Julie are awesome people, always have been. Very loving family, [32:07] welcoming again, and well-liked in the community. Very upstanding citizens. Now, you are aware Chrissy's [32:17] been charged with the, uh, murder in the first degree. Is that right? I am. Uh, you, we've talked [32:22] about that. You've read about that. You're aware of that? Yes. And even knowing that, uh, you are here to [32:29] offer your insight and your opinions about Chrissy to the court, um, because you know that we're asking for [32:35] her bond to be reduced. Is that correct? Yes. Okay. Based on the characteristics and the values that you saw [32:42] Chrissy develop and exhibit during middle school, junior high, and high school, do you think that [32:50] Chrissy poses any reasonable danger to the community? No. Uh, based on the characteristics and the values [32:57] that you saw Chrissy develop and exhibit through middle school, junior high, and high school, do you [33:03] feel that she would in any way flee or not show up for her required court appearances? No. I have no [33:10] other questions, Your Honor. Cross examination. Thank you. Mrs. Williamson, is that correct? Yes, [33:17] that's correct. Uh, we've never met before, correct? I don't think so. All right. You live in Osceola [33:23] currently. Is that right? I do. And how long have you lived there? Oh, 23 years. And what's your, [33:31] what's your employment? What specifically do you do? I work for the state of Iowa and I schedule [33:39] hearings, um, send out orders, all things. Do you work for the court system or the clerk's office? Yes. [33:47] Yes. Okay. Ms. Williamson, your day-to-day involvement with the defendant, uh, Kristen Ramsey, [34:00] was whenever you were much younger. Would that be true? That is true. Okay. So, um, so middle school [34:10] would have been like the early to mid-1980s, would that be right? Yeah. And what year did [34:16] you graduate from high school? Ninety-one. Okay. And, uh, the defendant been, have been in your class [34:22] at Woodward? Yes. So she would have graduated in 91? Yes. And then your lives would have separated at [34:28] that point. Would that be true? True. So you didn't have any regular contact with her after 1991, [34:34] would that be true? Just through, you know, the community. My mom still lives there, my sister still [34:39] lives there. And I still have friends there. So other people would tell you about things that [34:45] the defendant might be doing, things of that, correct? Sure. She wouldn't have consulted you on [34:51] large life matters, would that be true? No. Uh, so anything that she would have been doing with her [34:56] business, um, with real estate, she doesn't consult you about that correctly? No. No. You don't have any [35:02] conversation with her about business dealings, correct? No. Or her financial condition? No. Nothing [35:08] along those lines? No. Has she ever asked you for a loan or asked you for any money or anything of [35:14] that nature? No. Right. Uh, prior to Kristen Ramsey being charged, uh, with murder in the first degree, [35:20] when would have been the last time you would have had any communication with her? Probably shortly after [35:26] graduation, I, I would presume. I, I cannot think when the last time was, but I kept track of her. I think [35:36] we kept track of each other. We just meant, may not have spoke. So I think if things would have changed [35:42] with regard to her demeanor, her personality, uh, things that she would have been involved with, [35:48] uh, you would not have had any direct knowledge of that, correct? No. Are you aware of any drug use that, [35:56] um, Kristen Ramsey has engaged in? No. Uh, anything that would have, uh, would relate to [36:03] methamphetamine or marijuana? No. Would it surprise you if those drugs were in her presence? [36:11] Absolutely. Uh, what about firearms? Did you ever see or know Kristen Ramsey to [36:16] use a firearm? No. Uh, would it surprise you if there's information that she had used a firearm [36:21] in the past? Yes. Even if it would have been legally, would that be true? Yeah. I, I would be [36:28] surprised. I have no further questions. Any redirect counsel? Just briefly, just so we're clear, [36:53] the physical distance is why you no longer have any more contact with Chrissy. Is that fair to say? [36:58] Correct. There was no falling out or anything like that? No, no. We just [37:01] live separate lives. No further questions. Thank you. Ms. Williamson, you can return to your chair. [37:05] Thank you. Please call your next witness. Thank you, Your Honor. We would call Jean Grell. Mr. Grell, [37:24] sir, if you come forward, I'll swore you in when you're ready, sir. Please raise your right hand. [37:35] Sir, do you solemnly swear or affirm that the testimony you're about to provide to be the truth, [37:40] the whole truth, and nothing but the truth? Yes, sir, I do. Please be seated. Mr. Grell, if you could likewise [37:47] move your chair close to the microphone so you can speak into it, so we can all be sure to hear you, [37:51] I'd appreciate it. Counsel, when you're ready. Thank you, Your Honor. Will you please state your [37:57] first and last name and spell them for the record, sir? Yes, my given name is Eugene. That's E-U-G-E-N-E. [38:06] The last name is spelled G-R-E-L-L. Mr. Grell, my understanding is that you are somewhat hearing [38:15] impaired. Is that correct? That is correct. Okay. If there's at any point that I'm speaking too loud [38:21] or not loud enough, would you please let me know? I certainly will. Okay. Do you currently live here [38:29] in the state of Iowa? Yes, I do. And what town do you reside in? I live in Woodward. Okay. Are you [38:36] currently employed, sir? No, I am officially retired. In terms of past employment, can you outline for the [38:44] court what you've done over the course of your life? Yes, I have a BA from Augustana University in [38:51] Sioux Falls in education. I have an AMS from Creighton University in Omaha in school administration. And [39:00] then in terms of employment? My first job was in Southwest Iowa and I was a teacher for seven years [39:11] with special needs children while I worked on my degree over at Creighton in school administration. Then [39:19] I became a middle school principal, which you only do when you're young, I found out. I became unhappy with [39:33] education at that stage in life. And so I opened my own restaurant in a small town in Southwest Iowa. [39:40] My son, my wife and I ran it. Then I was approached by a convenience store chain owned by the Kroger [39:48] Corporation over in Omaha to come to work for them because I had both business experience and the [39:55] educational background. And so I became a professional trainer working with, first of all, store level [40:03] employees. Then I moved up to building them an assistant manager training program and finally [40:10] doing seminars for the managers of the store level. When Kroger downsized in the late 1980s, [40:20] sorry, I knew my job was going to go away. That's usually what happens when corporations downsize. And [40:26] so I started looking for a job. I took a job down in Falls City, Nebraska for only one year as their [40:33] elementary principal. I guess the only way to put it is my wife and I could never get used to the [40:45] Nebraska culture. And so I applied for a job and took a job up in Northwest Iowa, [40:52] not too far from where I originally grew up. And in that school district, I was initially their [40:59] elementary principal. Then when the school combined with the school district to the west of us, I [41:08] became both the elementary principal and their curriculum coordinator. Yeah, I've done lots of [41:21] things in my life. My wife was life flighted from Omaha, from Spencer, Iowa to Omaha and had two different [41:34] types of transplants done. And so I retired at the young age of 53 to care for her the rest of her [41:44] life. She lived 13 more years. And during that time, whenever she was medically stable, I then took part-time [41:52] jobs. So I have worked for CPAs, a local firm, during their tax season. When they were done with me, [42:03] then I would move over and worked for both ACE and Hy-Vee as their garden center coordinator, [42:11] manager, whatever you want to call it. I also worked for the county here in the auditor's office [42:20] for the last time, this last past election, because first of all, my hearing is getting [42:28] questionable and because my age is advancing. So with them, I worked again during the entire [42:40] election process getting things set up. In fact, I'll head over and make sure they're online to do [42:46] what they're supposed to be doing in the upcoming election in June. [42:51] How about volunteering? Are you doing volunteering as well? [42:56] Yes, my son tells me I have retired at least 12 times. He's probably a little shy on that. It's [43:05] probably more than that. I have done social ministry on all of the Lutheran Church over in Perry, [43:12] which is where I go to church and where one of the Ramsey members also attends. Social ministry [43:20] involve a lot of things. We operate a bedding service out of the church, especially when the [43:30] packing plant was still there. Tons of people being pulled in by Tyson who come with nothing. And so [43:39] the church purchases bedding that they can check out. Then we started a co-op program with the Optimist [43:47] Club in town. They now purchase the children's beds and the church purchases the adult beds. [43:55] And then as part of that, I just went out to the other churches in the area. And so we did [44:01] socks and underwear drives for the school. We did coat drives in the fall. I started a [44:11] furniture bank in a donated storage space. Those types of activities in social ministry. I also help [44:19] at the local Woodward food pantry after having worked at the Perry food pantry prior. I also did [44:28] something called Harvest for the Hungry where I went out through all of northern Dallas County and [44:33] found people who had garden produce or field produce. And I delivered that to the food pantry. [44:41] So then while being in Woodward, did you get to know Chrissy Ramsey and her family, Mr. Grell? [44:48] I'm sorry, could you say that again? [44:51] He said, yeah, during your time in Woodward, did you get to know Chrissy Ramsey and her family? [44:56] Yes, sir. When I and my wife moved to Woodward to be closer to our grandchildren who were living over in [45:03] and Granger, we moved into the lot where Chrissy's and Toby's house would have been prior to the tornado [45:18] that came through in 2005. A builder had built a spec house there and we bought that home. So we were [45:24] actually neighbors across the street to them. What was the first occasion you had to meet Chrissy [45:31] and her family? From memory, it was that she and Toby came over and introduced themselves as well as [45:40] Toby's parents because we were right across the street, kind of wanted to know who the new folks [45:44] in town were. And for the record, Toby is Chrissy's husband, is that correct? That's correct. Sorry, [45:51] I should have explained. That's okay. And then Toby's parents also are your neighbors across the street, [45:57] is that right? His mom still lives here. His dad's across town now, but yeah. So how long then have [46:07] you known Chrissy and her family? We moved in October of 2007, so give or take about 18 years. And during [46:16] that roughly 18-year period of time, you've been their neighbor right across the street? That is correct, [46:22] except for this final year. Because of the rising cost of property taxes and insurance in my home, [46:32] I simply decided to move into an apartment. So this last year, I haven't been their neighbor. [46:39] Are you still in Woodward? Oh yes. And when you were neighbors with the Ramseys for roughly 18 years, [46:48] and I know it could be weather dependent, but how long or how often would you see the family? [46:54] Again, very seasonally in the summertime, all the time, because I am in retirement, a gardener. So [47:02] I'm either out in my garden or in my yard. And so they would be out caring for their lawn or things [47:09] on the house. The dogs would be out running, running the lot. I set out to read a great deal in front yard. [47:17] I don't know that for a fact that whether they did or did not see me, but when my wife died in 2015, [47:29] I often used what some of the members of my support group for grief suggest, and that's what's called [47:41] cold therapy, where actually she died in March. And so because of all of the flashbacks that I had [47:50] caring for her and all the things that had to be done to her, I would go out and sit on the front [47:55] steps, which faces their house. And in the cold, with just basically t-shirt on, makes you slow down [48:07] and takes your mind off of all these things that keep coming back. [48:10] Do you have conversations with Chrissy and Toby and Tanner throughout those years? [48:15] Yeah, I call that across the fence. I have to say I'm very fortunate to have moved into [48:23] best of small town Iowa neighborhood. Just briefly some examples. There's an older woman behind me [48:37] who used to come over and swipe rhubarb out of my garden. And I caught up with her one day, [48:46] was not upset, but told her I would bring it over to her house from that point on. And she was insistent. [48:52] No, she's somewhere between 80 and 90 years old. And she was insistent. She was going to use her cane [48:59] and get over there and get it. And I said, well, you help yourself. And then whenever her kids would show [49:03] up, I would go over and say things to them like, well, your mom's been over stealing rhubarb again. So [49:10] the neighbor directly behind me, her parents are older. She lived with them. Dad had Alzheimer's. And [49:18] so she would ask me to come over and watch them while she ran for medication or groceries, that kind [49:27] of thing. The neighbor next to her, which is also behind me, scraped the alley, which the city general [49:36] you'd not get done in time for me to get out when it was snowy to get over to my job at the CPA office. [49:45] What about the Ramsey family? It sounds like there was a lot of neighborly things being done. What [49:50] about Chrissy or her family? What kind of neighborly things would they do? [49:54] Well, I guess the one that would stick out most in my mind. I mean, we talked across the street, [50:01] not the fence. But the sticks out in my mind is Chrissy would often send Tanner, her son, over to [50:11] scrape my front parking and the sidewalk up to my house. And I, of course, would come out with money [50:18] and he would refuse it, which gave me an indication of what she was like. I'm an older person not taking [50:30] advantage of. And so my workaround for that was I knew when Tanner's birthday was because we had lived [50:38] beside him for so long. And so I'd stuff the money into a birthday card. And of course, he got it. And [50:45] Chrissy couldn't say anything. So what kind of observations did you make about Chrissy and her [50:52] character based on your experience of being her next door across the street neighbor for 18 years? [51:00] I would have to use words like humble, kind, very mild mannered person, meek, and very devoted to [51:21] to her family. She raised a good son, Tanner, didn't she? Oh, my gosh. So good that he dates your [51:27] granddaughter now, right? That's correct. When did the two start dating? When they reached high [51:33] school. But Tanner and I have known each other a lot longer than I would have to tell you that [51:40] this is very unusual for a young male, at least in my experience as an educator. Tanner would come up [51:51] and sit beside me at activities where he was not directly involved and sit and just talk. And usually, [52:00] young men, from my experience, once they reach that middle school, high school age, [52:08] you're the last thing that they want to have contact with. So you would attend his sporting events, [52:14] though? Yes. I attend all sporting events, all activities. But it would include things like, [52:22] you know, National Honor Society, those kinds of things, too. Yeah, I'm pretty loud person. [52:27] And so I set up in the stands and usually nobody wants to sit in front of me. And a lot of the [52:36] parents in our, at least in our district, will sit out in the outfield or they'll stand along the fences [52:43] at football season because they want to be closer to the action. So yeah, during halftime or during, [52:51] uh, in between innings, um, I would usually go out and give them a bad time for lack of a better word. [52:59] And, uh, Santa talked to them and they would be saying, Oh, we heard what you yelled at the referee [53:05] or whatever. So Christie would be at all the baseball games. Is that correct? Oh, both parents very, [53:12] very supportive. She'd be at all the football games. Is that correct? Yes. Would you see Toby and [53:17] Chrissy being involved at Halloween handing out candy and the like in the neighborhood? Yeah, [53:23] he used to, uh, dress up. We were one of only a couple of houses on that end of the street and [53:28] he'd be out there. Uh, um, yeah, given the, given the little ones a bad time and then sending them [53:33] over to my direction. So let me ask you, did you ever observe or notice any disturbances coming from the [53:40] Ramsey home? No. Um, and back then I had my hearing. So, um, no, I've never heard anything [53:49] kind of nature. You know that Chrissy has been charged with first degree murder. Is that right? [53:57] I certainly do. And again, you know that you're here to offer your insight and experiences and [54:03] opinions based on what you observed of Chrissy over the 18 years you've lived next to her because [54:09] we've asked the court to reduce her bond. Is that right? Yes, I do understand that. [54:14] Now, if the court were to grant our request and reduce her bond, uh, do you believe, [54:22] would you have any reservations about Chrissy returning to your town and to the neighborhood [54:27] where you, uh, lived for 18 years? The best way to answer that is, um, my grandchildren grew up in my [54:40] son and daughter-in-law's house and their babysitters were I and my wife. And as two educators, [54:48] you don't get by with much. And if I knew something was going on in that home, [54:54] she would not have been allowed to be there. I would have gone to my son and his wife and [54:59] they would have said no. Do you believe based on your experiences and your observations of Chrissy [55:06] over the last 18 years that she poses a risk of harm to your community? I'd have to say she's the last [55:13] person in that town that I would think examination. Thank you, Judge. Uh, Mr. Grell, good afternoon. [55:26] I don't think we've ever met. Is that correct? We have never met, sir. Um, you are a neighbor to the [55:34] Ramses. Is that right? That is was was for the first 17 years. Yes. Okay. When did you cease being a [55:42] neighbor to the Ramses? Um, I moved into the apartment in May of last year. So almost a year now. And [55:50] whenever you lived near the Ramses, that would have been across the street. Is that correct? [55:54] Directly across the street. That's correct. And your interactions with them would have been [56:00] normally as a neighbor, most of it like out in the yard, see them on the street, things of that [56:05] nature. Is that correct? Yeah. Around town, whatever it may be, or the sporting events or activities at [56:10] school. Correct. So most, if not all of your interactions with Kristen Ramsey would have been in [56:16] a public setting. Would that be true? That's pretty much true. Uh, you've never been in the [56:22] Ramses home? I think only once. Um, when I moved, um, Tanner had taken an apartment off campus at the [56:31] University of Iowa and needed a bed. And I was trying to get rid of a lot of stuff. And so I helped them [56:36] get the bed over to their house. That's about the only time I've been inside. Right. So you've never [56:41] been, other than that, you've never been in their home, correct? That's correct. Uh, are you aware of any [56:46] drugs in the Ramsey home? No, I've never seen any evidence of that. And I've worked with a lot of [56:55] people in social management. I understand. I'm just asking what you observed. Yeah. Okay. And you [57:00] wouldn't have observed any methamphetamine, wouldn't have observed any marijuana in their home? No. [57:04] Correct. Never used or never observed either one of them using drugs. Is that correct? That's correct. [57:10] Would it surprise you if those types of drugs were found in their home? Yeah, it would surprise me [57:16] based on my interactions. And are you aware that a number of firearms were in the Ramsey home? I had [57:24] no idea they had guns. If you knew that Kristen Ramsey committed a murder, if you knew that, [57:43] would your opinion of her change? I'm gonna object, Your Honor. That's not an evidence. This is a character [57:49] witness. The objection is overruled. The witness can answer. It's a hypothetical. Restate it for me, [57:57] please. If you knew that Kristen Ramsey committed a murder, would that change your opinion? I would [58:07] have to say is... That's all I'm asking is whether or not it would change your opinion. You said no. [58:12] You didn't need to have a chance to finish. It's a yes or no question. All right, hang on. The witness [58:17] can answer the question. Go ahead, sir. What I would say is, um, as with many of the neighbors from all over [58:27] western Iowa, um, they would continue to be neighbors for life. It would not matter to me. Any redirect, [58:36] counsel? Mr. Grell, sir, you can return to your chair. Thank you. Please call your next witness. [58:44] Thank you, Your Honor. Um, we would call Julie Boyles. Very well. Come forward, ma'am. When you're [59:06] ready, I will swear you in, just like I've sworn the other people. When you're ready, face me and raise [59:10] your right hand. Do you solemnly swear or affirm that the testimony your boss provide to be the truth, [59:19] the whole truth, and nothing but the truth? Thank you. Please be seated. Because it appears you may be [59:27] soft-spoken, I want to make sure you position that microphone, and if you need to move your chair, [59:31] please do so so we can all be sure to hear you, okay? Yes, sir. Thank you. When you're ready, [59:36] counsel. Thank you, Your Honor. Ma'am, will you please state your first and last name and spell them [59:40] for the record? Julie Boyles, J-U-L-I-E-B-O-Y-L-E-S. I'm sorry. How's that? Is that better? Mm-hmm. [1:00:01] And Ms. Boyles, you are Chrissy's mother, correct? Yes. Where do you presently live? [1:00:07] Johnston. And are you married? Yes. How long have you been married, ma'am? Since 1983. And, uh, [1:00:16] who is your husband? Chris. And Chris has been Chrissy's stepfather since 1983 then, [1:00:25] is that correct? Correct. Can you tell us a little bit about your husband? [1:00:28] Uh, he's a pretty calm individual. He doesn't get riled up, doesn't make judgments. Um, [1:00:40] he's a lot like my dad. What did he do for employment, ma'am? He worked for the post office [1:00:48] for 30 years. Did, uh, Mr. Boyles serve in the military? Yes. Do you know where he served? [1:00:57] Uh, he was, he was in the National Guard for seven years. Okay. Um, did your husband serve [1:01:06] overseas? Yes. When would that have been? Uh, he was in the Gulf War, so. How long was he overseas, [1:01:15] do you recall? Um, from December of 90 to May of 91. And Chris took pride in being Chrissy's stepfather. [1:01:31] Would you agree? Yeah. It sounds like when Chris was serving overseas, there was some concerns he may [1:01:39] not make Chrissy's high school graduation. That's right. What happened? Um, he had, Chris had a friend [1:01:47] in, um, his unit. It was based out of Perry. It was a transportation unit in Perry. And, uh, Ronnie had [1:01:55] gotten sent home earlier, and he also was a pilot. When Chris's transportation unit got into [1:02:07] stateside and got to Missouri, uh, Ronnie said he would go down and get Chris and fly him home to [1:02:14] make sure he was home for Chrissy's graduation. But the weather wasn't good. So he drove down to get [1:02:23] him and got him back home about an hour before graduation. Chrissy and Chris have been close [1:02:29] their lives, haven't they? Yeah. Are you employed ma'am? No, I'm retired. What did you do prior to [1:02:37] retirement? I was the insurance and billing manager for a counseling clinic in Urbandale. [1:02:42] How long did you do that? 33 years. Any criminal history? No. How about Chris, [1:02:49] your husband? Any criminal history? No. Um, does Chrissy have siblings? She has a brother, [1:02:57] an older brother, a younger sister. She has a bonus brother and a bonus sister. Where do those [1:03:04] folks live ma'am? Um, one brother lives in Madrid. One brother lives in Pleasantville. Sister lives in [1:03:12] Harrisonburg, Virginia. And the other sister lives in Minburn. Has, uh, some of her friends and family [1:03:19] turned out to support her for the bond review hearing? Yeah, several. Are they present behind [1:03:25] her? Yes. Including Tanner, her son? Yes. Chris, your husband? Yeah. Toby, her husband? Yeah. Tell us, uh, [1:03:38] a little bit about Toby. Toby's been in our home, um, prior to he and Chrissy dating, um, because he was [1:03:51] friends with, with our two sons. And so it wasn't till, um, Toby was a senior that, um, and Chrissy was a [1:04:02] freshman that they started dating. And so Chrissy would have dated Toby her freshman year? Is that [1:04:10] right? They went to his senior prom. She was a freshman. Have they been together ever since? Yes. [1:04:17] High school sweethearts? Yes. And Toby's family. Do you know Toby's family? Oh yeah. Yeah, of course. [1:04:24] Do, does Toby's family live in and around, um, the same community where Chrissy and Toby live in Woodward? [1:04:34] Yep. Jody lives just a block away with her family. And, um, and Shannon and Dan live in Granger with [1:04:41] their family. One more person we haven't mentioned who is here today is Chrissy's grandfather. Is that [1:04:48] correct? Mm-hmm. What's his name? Malin Conaway. And that's your father? Malin, M-A-H-L-O-N Conaway, C-O-N-A-W-A-Y. [1:04:59] And he's here, right? Yep. He's right up. How old is, uh, Chrissy's grandfather? Um, dad will be [1:05:08] 101 in August. Can you tell the court a little bit about your father? He's lived a rather [1:05:13] extraordinary life. Would you agree? Yeah, he's pretty extraordinary. He, he's, um, a very proud [1:05:20] World War II veteran. He's received several medals. Um, he's the 2024, um, Iowa veteran, a VFW Veteran [1:05:35] of the year. He's received the French, um, Legion of Honor. We have to call him Sir. Um, but, um, he's [1:05:46] so well-loved in Perry and so well-known in Perry, um, because of his service. The French Medal of [1:05:53] Honor that, or the French Legion of Honor, is that the highest military honor, the French? Yes, [1:05:58] it is. What did he receive that for? Do you know? Um, for his help with liberating France. What did, um, [1:06:06] your father do after he returned? After dad came home from the war, he drove, [1:06:11] he drove, uh, for Rouen transport. Um, I'm, I'm thinking dad drove for 30 years. He's hard of [1:06:20] hearing. He would correct me if he could hear me probably. But yeah, it was, he was one of the first [1:06:25] few that worked for John Rouen. Um, as Chrissy grew up in the home, you had pets around. Is that right? [1:06:34] Oh yeah, we have a lot. Your family members would come and go and play with her? Yeah. How would you [1:06:39] describe her upbringing? Um, it was just, it was just a loving home. We're, um, we care about each [1:06:49] other. We're very close-knit. Um, we have a lot of fun together. Chrissy, um, sounds like she, she was a, [1:06:58] uh, cheerleader? Yes. Did she do anything else for extracurricular and co-curricular activities? [1:07:03] She danced since she was probably five. For how long? Until she graduated from high school. [1:07:11] Well, um, was she a hard worker? Yeah. Did she keep jobs? She did. She, um, helped, um, defray the costs [1:07:21] of dance lessons by working in, for, and teaching kids in dance studio. She worked in the daycare in, [1:07:29] uh, Granger. She worked for the marina, Sailorville Marina. Did she, um, get positive [1:07:37] reviews from people she worked for? Yes. Um, Pam and Mike Finistead had the Granger, um, daycare, [1:07:47] and they also were their, the hosts for Chrissy and Toby's wedding. And Vern Eden owned the marina [1:07:54] in Sailorville. And he told me several times that if everybody worked as hard as Chrissy, he wouldn't [1:08:01] have any problems at all. How would you describe Chrissy's character? She's the most loving person. [1:08:13] That I know. She's caring. She's compassionate. She's considerate. She loves Tanner to the ends of [1:08:25] the earth. She would do anything for him. Did she have any, um, enemies growing up? No. Did she ever [1:08:35] have a rebellious streak growing up? No. Did she have a curfew when she lived at home? We never did that [1:08:43] to her because she, she always respected a good time to be in. 10, 30, 11 o'clock. She was home. It was, [1:08:51] we didn't need to put a curfew on her. Now you lived in a small community. That's correct. Did you ever [1:08:57] hear anything from community members complaining about your daughter or anything along those lines? No. [1:09:03] Did you ever even have to ground her? No. What kind of activities, um, did you enjoy doing with Chrissy? [1:09:16] Well, probably one of the most fun things we did. We both loved the Eagles. And so we would go to [1:09:24] Eagles concerts together. Anything else? We enjoyed, um, the day after Thanksgiving, [1:09:32] going shopping. We'd plan that whole day out. We'd, back when the Des Moines Register had, [1:09:43] was big and they had the big day after Thanksgiving newspaper. We'd plan our whole day. My mom would [1:09:52] bring down her newspaper so we could have the Yonkers coupon out of there. And we had our [1:09:59] delivery. So we had that one and Chris had run over to the quick trip and get another paper. So [1:10:06] when it was Annie and Chrissy and myself going shopping, we all had that $10 coupon we could spend. [1:10:12] Um, my understanding is you do not drink any alcohol. Is that right? No. Your husband, [1:10:18] Chris does not drink any alcohol. Do you know the last time that you've ever seen Chrissy drink any [1:10:23] alcohol? Honest, I honestly can't. Do you know whether Chrissy has ever used any illegal drugs or [1:10:32] controlled substances to your knowledge? No. Um, Chrissy's son Tanner was born in 2015. Is that right? Yes. [1:10:42] Now you, as a mother and a grandmother, had a very unique opportunity to observe Chrissy as a mom [1:10:50] over Tanner at a very young age. Is that right? That's right. Why don't you tell the court about that? [1:10:55] They lost their house in the tornado in Woodworth. So Tanner was three months old. They lived with us [1:11:06] along with their two dogs and, um, Jack and Jake, Jack and Junior. And, um, we had three dogs and we had [1:11:17] two kitties. And so it was a full house. How did, uh, Chrissy handle being a new mom being displaced by [1:11:28] a natural disaster like that? She, very calmly, very, uh, resilient. She would go to work. She'd come [1:11:42] home and she'd work on what she needed to gather for the insurance companies. She'd have to go through [1:11:48] room by room and try to remember what was in each room and itemize. I mean, how many bobby pins did you [1:11:59] have? I mean, it was just that kind of detailed, but she was, that was what she had to work on for [1:12:06] her family to get back home to the home that they were trying to get built. And as Tanner grew, how [1:12:14] would you describe their relationship? Pretty tight. Tanner's like Chrissy. He's just a calm, [1:12:24] straightforward, compassionate, caring. He will sit and talk. Like Mr. Grell said, he'll just sit and talk [1:12:33] with you, look you in the eye and have conversations with you. I don't, he's my dad's hundredth birthday [1:12:41] party last year. I had him meet my high school girlfriends that came from my dad's birthday party. [1:12:48] And Tanner was just involved with them, talking to them like he had known them forever. He was [1:12:54] interested in what they had to say. Chrissy's the same way, exactly the same way. Was Chrissy involved in [1:13:02] Tanner's activities throughout junior high and high school? Oh yeah. She never missed anything. [1:13:06] Uh, what about, um, fundraisers and things like that? Was she involved in those? Tell the court about [1:13:13] that. She, um, they had, the junior class raises money in Woodward for the senior prom, a junior, [1:13:21] senior prom, and also their, their senior trip when they become seniors and, um, the cap and gown. And so [1:13:31] she would work the concession stands like other parents would to raise that money for their kids. [1:13:38] Tanner, um, excelled, uh, not just athletically, but academically as well. Yeah. He's a member of [1:13:43] the national honor society. Was he, um, academic all conference for baseball and football? Yes. [1:13:49] Um, did he receive scholarships coming out of high school? Yes, he did. Yes, he did. Who would Tanner [1:13:55] attribute a lot of his, uh, success to? Both his parents, both of them. Is the family structured and [1:14:03] responsible? They are. And they made, and Tanner grew up knowing his, that he needed to be responsible [1:14:10] as well. Now, um, that Tanner's off to school has, how has Chrissy's role as a mother changed? Have you [1:14:20] seen that? It was, you know, like any parent sending their child off to college, it was tough to let him go. [1:14:29] And Tanner was, is their whole life and Boyd was gone, but I would tell her, you know, you just, [1:14:38] it's just a change and you're gonna find a different avenue. You're gonna enjoy this next chapter [1:14:47] with Tanner going to college and they have. Tanner still comes home and visits? Yes. Does he bring all [1:14:53] his laundry home? Oh my, yeah. The last, the last time he was home, he's smiling at me right now. The [1:15:00] last time he was home, he brought, uh, Chrissy was telling me, oh, he brought all his laundry, [1:15:07] even all his bedding mom. And I said, well, I know you love it. So, you know. She still enjoys taking [1:15:13] care of everybody. Yes, she does. Now, one of the requests we made to the court was to potentially [1:15:20] appoint a custodian for Chrissy if she were to be released on bond in the community. Um, would you [1:15:27] be willing to serve as a custodian? Yes. Um, which would mean if Chrissy violates the terms and conditions, [1:15:34] you would have to report that to the court. Would you be willing to do that? Yes. And if necessary, [1:15:39] would, could Chrissy live with you if that were necessary? Yes. Based on you knowing Chrissy her whole [1:15:47] life, do you have any reasons or concerns, um, that Chrissy could pose harm to the community if [1:15:55] she were released? No. Um, do you think she would flee if she were released? No. I know, uh, one concern [1:16:06] that the state raised in its resistance was she may harm herself. Yes. And I feel like you would be in the [1:16:16] best position to discuss that and, uh, allay those concerns. Would you tell the court [1:16:22] from your perspective whether that's a legitimate concern? No. She would never, ever, ever do that [1:16:28] to Tanner. She would never leave him. No. Cross-examination? Uh, the state has no questions [1:16:38] for Ms. Boyles. Ms. Boyles, you can return to your chair as well. Does that conclude the evidence [1:16:47] that the defense wishes to offer in support of the motion? We would just formally move Exhibit A, [1:16:53] which had roughly 70 plus pages of support letters into the record if that hasn't been accepted yet, [1:16:59] Your Honor. Is there any objection to the exhibit, which is the, I think it's about 72 pages of support [1:17:07] letters from community members on behalf of the defendant? Does the state object? No, Your Honor. That [1:17:12] exhibit is admitted. Um, just to, uh, confirm again, the state does not intend to offer any evidence. Is [1:17:20] that correct? We do not have any witnesses or other evidence to offer. That's correct. Your Honor, [1:17:25] we have a professional statement to make at this time when pursuant to what we discussed, uh, prior to, [1:17:32] uh, the hearing starting with regard to- And this is going to be separate than your argument? Is that right, sir? [1:17:37] It will, Judge. Very well. Then go ahead. Thank you, Your Honor. Uh, may it please the court and counsel, [1:17:42] Ms. Ramsey is 53. She's been employed for 14 years at the same job at Midland, title of escrow. And I would [1:17:51] present this, Your Honor. The record should show as a, uh, professional statement. She's lived in Dallas [1:17:57] County, um, her entire life. She has no, uh, criminal record, one speeding ticket approximately 15, 18, [1:18:06] uh, years ago. She's never lived out of state. She has few family members, uh, living out of state. [1:18:15] She has taken vacations. The vacations have been in Florida. One was the visit [1:18:20] with her, uh, grandfather who had moved down there at one point. Um, the gentleman who is the, uh, [1:18:26] the war veteran and hero. Uh, she and her husband would drive down to, uh, visit with them. Her health [1:18:33] is good. As a matter of fact, uh, when she was, uh, initially interviewed, uh, by, uh, the sheriff's [1:18:40] office, which is a well-run, uh, Jill, uh, Your Honor, I want to, uh, the gentleman in charge of [1:18:46] it, uh, has done an outstanding job there. Um, uh, when she was given the sheet, uh, they checked on [1:18:55] her. Uh, she had, uh, no, no emotional drama to the extent that they felt she needed additional help. [1:19:03] They did one interview. Then they did an interview approximately 14, uh, days later. Um, she's had no [1:19:10] disciplinary, uh, issues. As a matter of fact, in the four visits that, uh, Mr. Brown and I have gone [1:19:16] there, uh, and, and just passing, uh, the, uh, staff, uh, which is an excellent staff indicated, uh, [1:19:24] she had no issues there. Um, she indicates she can follow any conditions of the bond that the court [1:19:33] would set on her within the parameters of what we will discuss, uh, later. Uh, all the firearms have [1:19:39] been removed, uh, from the home, uh, that was directed, uh, by our office to have that accomplished, [1:19:46] uh, if the court were to allow her to go back home with those conditions, uh, she would work if a job, [1:19:52] uh, became available. And, uh, I believe judge, uh, that's all the record, uh, that, uh, we would, uh, make [1:20:03] at this time and ask the court to accept that as a professional statement on behalf of, uh, oh, thank you. [1:20:10] Uh, she has no, uh, passport and has never had one. Very well. Mr. Brown, uh, do you have any, um, [1:20:20] questions for Mr. Parrish? Obviously a professional statement is evidence and you have the right to [1:20:25] cross-examine if you wish. I just have one point of clarification on employment, if I could. Um, [1:20:32] is, is the job that she had before she was arrested still available to her if she is released? We don't [1:20:39] think so. We've not explored that because we've been busy working on the, uh, this matter, but, uh, [1:20:45] we've not, uh, we've not explored that, right? Thank you very well. The court will, uh, accept Mr. [1:20:52] Parrish's professional statement as evidence and we'll consider it as part of the evidence presented [1:20:57] here today. Um, we have been going for almost an hour and a half, so I'm going to take a 15 minute [1:21:02] recess, 15 minute recess. When we come back, I'll be hearing the arguments of counsel starting with [1:21:08] the defense, followed by, uh, the state. Then again, because, um, the defense is the moving party, [1:21:16] I'll give the defense the last word. So we'll be at recess for 15 minutes. Thank you. Be seated. [1:39:22] Before we turn to the arguments of the parties on the motion, I had an opportunity to discuss with [1:39:38] the parties during our research, recess, excuse me, our next proceedings in this case. The parties [1:39:45] have agreed and the court will approve the request to set trial for January 11th, 2027. January 11th, [1:39:55] 2027. The next hearing I'm going to set in this case is a status conference for June 19th at 1 30, [1:40:04] June 19th at 1 30. The court is setting that, uh, so I can touch base with the parties, see how the [1:40:13] discovery or exchange of information is progressing. And so we can see if there's any further hearings [1:40:19] that need to be held. So I will enter an order in writing, uh, in the next day or two, reducing that, [1:40:28] to writing of those future court dates. With that, thank you for your patience, counsel. Mr. Parrish, [1:40:34] when you're ready, sir, I'll hear your argument regarding your motion for bond review. [1:40:38] I, I am, I am ready, judge. Uh, may it please the court and counsel. Uh, judge, if this is any [1:40:45] guidance, I'm going to read from a transcript of proceeding, uh, in your courtroom in August of 2020, [1:40:54] where, uh, there was a contested bond issue. And at one point you, uh, pointed out to both counsel, [1:41:01] one was Joe Chris, the other one was Jonathan Calzi. You said, I would say that ultimately, [1:41:06] whether or not these charges hold water will be the responsibility of the jury, not the court. [1:41:13] At this stage of the proceedings, I understand that there's a factual dispute between the parties, [1:41:20] and I'm not going to resolve that here now. That will be for the jury to resolve. And judge us from a [1:41:27] transcript. I gave you the date, uh, at a Polk County, uh, matter, August 21st of 2020. Uh, and judge, [1:41:35] if that's your, uh, belief in philosophy, obviously, uh, we all change as we, time moves, but that's a [1:41:42] pretty, um, uh, statement as to where we are in terms of this case, because you have seen the pleadings [1:41:50] that have shown the incredible fight that we have on the facts. Now, whether or not they developed [1:41:57] properly or developed, um, um, in dispute from our discussions and where we are, we are dealing with [1:42:04] a case 15 years old, where we all know there are incredible gaps. And from what they we've been [1:42:11] shown, there is nothing. With that in mind, judge, I'd like to address briefly the three factors. [1:42:24] And I'm not going to dwell on the nature of the offense based upon your statement, the danger to [1:42:31] the community that's been addressed. As a matter of fact, in their cross-examination and in the [1:42:40] failure to reduce any exhibits or a single witness, um, the, and I know the burdens on us by preponderance, [1:42:49] the state has not challenged that to any extent that should cause you to say, well, [1:42:57] let's keep the bond where it is. It doesn't work. They would have have to establish some way [1:43:03] for you to believe we didn't meet our preponderance. The risk of flight, the factors, judge, [1:43:10] that should be considered. She's lived here. Uh, Ms. Ramsey lived here her whole life. Her [1:43:16] family lives here. Her heart and soul resides in Woodward, Iowa. The trips that she's talked about [1:43:25] being out of state, not having a passport, having a strong familial connection, uh, establishes that, [1:43:35] uh, she's tied to this community. She has no criminal record, one speeding ticket. That is significant [1:43:44] because not only does it show something about her, her life, but also her character. I will talk [1:43:54] briefly, very briefly about the pleadings filed by the government, uh, in this case. Clearly they're [1:44:02] upsetting, uh, but, uh, we have to respond to that and I think we've done a decent job of responding. I [1:44:11] will say this though. One of the most distressing things to me about their pleading was the fact [1:44:19] from earlier discussions, I was led to believe they had clearly acknowledged that Ms. Ramsey had [1:44:28] nothing to do with the drugs in the house in 2011 when they had a search warrant or 2026. If I'm wrong, [1:44:36] that's fine. But that's what we were led to believe. I will make a professional statement [1:44:40] with regard to that. But if they are now saying that, um, and the firearms, let me, uh, make this [1:44:49] statement, which I think is fascinating about the, uh, investigation to this matter that goes to the [1:44:55] nature of the offense. In 2011, they saw firearms in the home. Did they tell you how many they seized? [1:45:02] I'll tell you. Zero. 2026, they went to the same home, to the home, and they claimed they saw firearms. [1:45:12] How many did they seize? Zero. We've told you in our professional statement that we've asked that the [1:45:22] firearms be removed from the home. So that deals with this idea, which I think is the most troublesome [1:45:28] aspect of the state's case about this is not a safe home for Ms. Ramsey to go back to. So we believe, [1:45:36] Judge, that we've addressed those issues directly, but I was a little concerned, confused, and actually [1:45:43] didn't understand their pleading on that issue. But a pleading doesn't make the case. If they thought [1:45:49] it was an issue, they could have presented a witness or two, a professional statement or so, [1:45:57] but they can't, and they know they can't. So Judge, we will ask you to, um, not consider those factors [1:46:09] and allow her to be set up. And I think the terms that we have presented, Judge, and I know from [1:46:17] our thoughts that you have, um, ideas as to whether or not, let's say, other bond issues that have been [1:46:27] issued in Dallas County, Polk County, other county, may not carry, uh, significance. But I think we've [1:46:33] battled that out also in our pleadings. And I, knowing as I do, I know you've read it. So you know where [1:46:38] that battle is? And, and, and I would just point out one factor, Judge, that is more general in terms [1:46:45] than what I would call, uh, a tit for tat as to who gets out on bond. Those are factors that, uh, [1:46:54] makes a case unique. What are the factors in this case? Well, one is that it's 15 years old and they've [1:47:01] not presented one iota of physical or any other type of evidence to show that anything has changed, [1:47:08] except the name of the investigators. That's it. But also, uh, what, uh, is important, uh, in this, [1:47:18] uh, aspect is that we have presented what we believe is a case that shows the first part of [1:47:29] her life. And people say, well, character is formed at five years, right? That's what we say. That's what [1:47:35] we believe. That's why we read our kids, their children books, because we want to impact that [1:47:40] character. Well, the state cross-examined, uh, Ms. Witt by saying, well, you'll, you stop seeing her. [1:47:47] But at 12th, 12th grade, Judge, we all know most of the significant characters in a personal life [1:47:55] is established. Let's go further. What was the next expect? A person who lives across the street, [1:48:02] and, of course, their only cross-examination was, well, you only saw her as a neighbor for 17 years. [1:48:09] If I don't know my neighbors for 17 years, Judge, and what they're doing and what the car is going [1:48:13] back and forth, I don't know much. So I ask you to consider that as a factor. This gentleman who was [1:48:20] a principal, who knew people well, who interacted, who talked about, uh, Tanner and what he was like [1:48:27] and going to his game and talking to him like he was concerned and involved in the conversation, [1:48:33] that's pretty unique, Your Honor. And that becomes because of his mom and his dad. Now, what about [1:48:45] the last person? Her mother, the father of this great, uh, war veteran who's sitting back there. And [1:48:53] I went back to talk to him and I said, you're one of my heroes. My dad was in World War II, but he was [1:48:58] stationed in Africa during World War II. And, uh, he came to my office and I said, I just want to take my [1:49:04] picture with you, uh, and, uh, share what you did. And, uh, in his comment to me, he said, I said, were [1:49:12] you afraid? Were you fearful? He says, only once. Once when I got there and after I left, my fear was [1:49:17] no longer there. But I said, I researched you and I could not believe, uh, the feats that you had, uh, [1:49:24] fighting for France. And he was the same young man. I make that point to say, the same person who's sitting [1:49:31] back there who she used to go visit in the summer, Ms. Ramsey would go visit in the summer with her [1:49:37] husband to keep a relationship with him. And the one who now goes back and forth, uh, to his house [1:49:44] when she was out because she loves him and he loves her back. So that is significant. It shows the [1:49:52] incredibly strong family ties. We put a map in our exhibit, Judge, that shows how these, these folks [1:49:59] live in relationship to each other, all in close contact. Even a friend from high school, they talked [1:50:06] about how they still stay in contact, her gentle nature, how she responds to things, how she, uh, [1:50:16] reacts, even at the jail, how she has had no disciplinary, uh, action over there. It's also important [1:50:24] to show a little bit about her, uh, character, uh, your honor. Um, I'm not going to dwell [1:50:36] on a lot of this and a lot of this judge. I think in terms of bond issues and stuff, [1:50:41] this court understands, uh, we do not present, uh, Ms. Gentry because, uh, obviously she was going [1:50:47] to make a professional statement about Golan Park. That's out of Dallas County, but I don't think that's [1:50:53] necessary to do, but let's talk judge just briefly, uh, in my argument about the, uh, strength of the [1:51:01] evidence. I will say this, your honor, you've tried a lot of cases in Iowa. So have I. [1:51:08] In 66 of the 99 counties, I have tried cases. A lot of them first degree murder cases. And in [1:51:16] these murder cases, your honor, in state court, this is the first time I've ever walked in where [1:51:22] there's a grand jury been assembled. The first time. And when I read the transcript over two [1:51:29] weekends and read it again, I was stunned. But it doesn't matter whether I'm stunned or not. [1:51:38] When I heard the officers say, Hey, we've charged somebody. We got a lot of work to do. [1:51:44] I was stunned again. And I don't even watch TV that much. It just popped up. So that tells you, [1:51:51] judge, they have problem. When the, uh, the state tells me, well, this is all we got. This is our [1:51:57] entire case. When you read it, judge with your experience and with the experience that we have [1:52:04] here, we understand there are issues. You don't wait 15 years and then you say, okay, let's make [1:52:10] a go of it. But that's not your decision right now. I agree. That's not what you have to decide. [1:52:15] What you have to decide. Is she going to run? It's just no place to go. She doesn't even have [1:52:19] a passport. Is she a danger? 17 year neighbor says, no. What does her mom say? No. Is she going to harm [1:52:27] herself? No. If there was some evidence of that judge during that evaluation that she had when she [1:52:33] first got to the jail, obviously we would be hearing it over and over again, but we don't. [1:52:42] Prior criminal record, absolutely nothing. Person who served as a third party custodian, [1:52:51] actually in federal court, not to say that they do it better. I don't think they do. [1:52:55] God, don't quote me on that, but I don't think they do, but they allow third party custodians. [1:53:01] But does she need one? We don't think judge, based upon the evidence that's been presented here, [1:53:06] her conduct at the jail, her life experiences, her close-knit family, she doesn't need that. [1:53:14] She should be able to go to her lawyer's office, plow through this truckload, they called it truckload [1:53:20] of evidence that they're going to give us, that they've collected over 15 years, as opposed to [1:53:25] sitting in the jail with us visiting two or three times a week or doing that. That's not a factor, [1:53:33] but judge, I think you can consider that, balance that out with who she is, what her life has been [1:53:39] like, and the incident. And one of the most interesting factors, judge, I found, was that, [1:53:51] is that, and I don't know, I'll put it in a nice way, we haven't seen all the documents from the grand [1:54:00] jury yet, and we're very interested in seeing it, but this grand jury pushed back. You know, [1:54:07] this old saying about, well, you can indict a ham sandwich, I know this hasn't happened in a couple [1:54:12] of cases around the country right now, but the interesting thing, this grand jury pushed back, [1:54:17] and the most fascinating part about the time the grand jury pushed back, these law enforcement [1:54:22] officers said stuff that just didn't make any sense. That's what happened, and when you read it, [1:54:29] if you probably have read it already, that's part of the strength of the case that you should look at. [1:54:35] Judge, no prior criminal record ties to Iowa. She's willing to stay away from the family. [1:54:41] It's not going to be an issue with her being in contact with the Oakland family for 15 years. [1:54:48] She's done that. If there's a need, I think that's our call or her call, our family calls, [1:54:56] if she needs to go for any type of mental health examination. She's willing to take a drug test [1:55:03] if that's necessary to get it done. They would allow an inspection of the home to go in to see [1:55:10] if those weapons are removed. In case I just finished in Adams County, that was one of the requisites that [1:55:15] we had. Obviously, you can put it in your order saying no firearms in the home, no drugs in the house, [1:55:23] and have an inspection. She can be subject to a pre-trial release condition. She's willing to do [1:55:29] all of that. A bracelet? Do I think you have to go that far? I don't think so, Judge, based upon the [1:55:35] evidence that's been presented here. But we are putting those options on the table for you to consider. [1:55:43] And let me close with just a couple of matters that are really distressing from what the state did in [1:55:52] their pleadings. They claim there was a witness, but they don't acknowledge that one of the witnesses [1:56:01] that they claim was practically blind and didn't identify anyone. They claim that they have some [1:56:10] type of new evidence, but not one single iota of new forensic evidence was brought to the grand jury's [1:56:18] attention. They claim they have a timeline, but yet they had a broken clock and the person who couldn't [1:56:28] see had to punch the clock to make the sound, and the time was off. They claim they have a motive that [1:56:36] they tried to hint to through cross-examination. But the motive, I don't even want to say it, but it's pure [1:56:45] speculation. They claim they had some physical evidence, it would seem, but no physical evidence. [1:56:53] The phone records have not been disclosed yet in this matter. And, Your Honor, let me just say one [1:57:06] thing before closing about the strength of evidence. And your experience in this area, [1:57:10] you've done a lot of cases, and so is Mr. Brown and Mr. Schultz. All right, just picture with me one [1:57:17] second. You have a person, let's say of interest, who's there for an hour or so, and you think they [1:57:29] fired a firearm. They would say, well, we don't have all the technical stuff out there that we used to [1:57:34] have. But what's the old-fashioned way, Judge, 15 years ago? You did an anemone and barium test. [1:57:45] That was so simple. They take reports and they have new people look at it and say, this is good [1:57:56] enough to pass muster. So we use those, Judge, and I know you've indicated in your prior ruling and your [1:58:05] philosophy, at least, that the fights that we have going on and will be going on for a while [1:58:13] is not something you have to decide. But the evidence otherwise, Judge, we've met the preponderance. [1:58:20] The state, you can only consider that cross-examination questions. They were weak at best, [1:58:28] and we believe that we've addressed the ones that we thought had been resolved because they knew better. [1:58:35] Now, maybe they're going to tell you something different right now, but when we started this case, [1:58:40] that's not where it was. And you didn't hear one person come up and say, they've seen her with drugs, [1:58:49] they've seen her with firearms, we found this bullet somewhere. Judge, we asked for a reasonable bond. [1:59:00] That's all we're asking for so she can prepare to defend herself and do it while she's out with a [1:59:10] family who loves her and who she loves back. This is a unique case. It is a unique case, [1:59:20] and we're asking you, Judge, to follow the evidence that was presented during the bond issue [1:59:27] and give us a fair bond. That's all we want today. Thank you, Judge. [1:59:31] Thank you, Counsel. Next, I'll hear from the state. [1:59:35] Thank you, Judge. The state's position here is that the bond set currently in the amount of $2 [1:59:45] million, cash only, be maintained. There are a number of considerations that the court can take [1:59:52] into account that involve the totality of the case involving the minutes of the grand jury, the minutes [2:00:00] of testimony that have been filed, and considering all the facts and circumstances in this case. [2:00:07] There's a whole laundry list of considerations the court takes into account pursuant to Iowa Code [2:00:15] Chapter 811.1 subparagraph 2, I believe is the correct citation. Basically, what the court is looking at [2:00:25] in terms of all those factors relates to making a determination sort of as to the future. [2:00:35] Is there a reasonable assurance the defendant is going to appear at all the court proceedings [2:00:40] that she'll do what she's required to do? Is her release or does her release constitute or will it [2:00:48] will it will there be a consideration that it would jeopardize the personal safety of her [2:00:55] or another person or persons? Chief among those considerations that the court has to take into [2:01:01] account are the nature and circumstances of the offense. I find it interesting that the defense [2:01:09] argues here, well that's not that important, and then goes through and tells you how bad our case is. [2:01:17] Without having done any discovery in this case, there's been no motion for discovery. They haven't [2:01:22] looked at our complete file. They've not asked to look at our complete file. We have an open discovery [2:01:28] policy. They know that. Yet throughout this argument today and through the pleadings that we've seen [2:01:35] from the defense, they seem to make it sound like we're keeping things from them or, you know, stating [2:01:45] things that they're never going to have, which is not the case. So let's look at the nature and [2:01:52] circumstances of this. It's the first consideration the court makes in the laundry list of things that's [2:02:01] in chapter 811. This is a class A felony. The defendant is facing a life sentence without the possibility [2:02:08] of parole if she is convicted. The nature of the charge in and of itself creates a situation where [2:02:16] a defendant is more likely to flee. Once she understands the nature of the case against her, [2:02:23] which includes the evidence, not only that was presented to the grand jury, and all the evidence, [2:02:29] by the way, presented to the grand jury is part of the investigative file, but once she's faced with [2:02:36] that, in our estimation, it makes her more likely to flee. It also potentially puts other persons in danger. [2:02:45] You know, her life is different now. It was several weeks ago. She's not charged with class A felony. [2:02:54] Now she is. That changes any person's circumstances. She has had access to weapons in the past. [2:03:02] There's no assurance the defense can give us that she will not continue to have access to weapons. I [2:03:08] don't think there's anything they could really say that would keep us or would provide an assurance to [2:03:15] the court in particular that she would not have access to weapons. Concerning the circumstances of [2:03:23] this offense, Mr. Parrish has spent some time here this afternoon assailing the investigation and what has [2:03:32] been done that needs to be addressed. I'm not going to go through all the details. I'll address the [2:03:39] matters that he raised, but this case has been thoroughly investigated. This was not a case that [2:03:45] where our investigators said, hey, let's look at this case, and then the next day we were filing it. [2:03:52] There's been a considerable amount of time, effort, and energy that has been put into [2:03:59] this case over a number of months that they've been working on it. [2:04:05] Leads that the defense raises in the pleading they filed yesterday concerning other potential [2:04:13] suspects, those leads have been exhausted. The defendant, there was a reference that she had [2:04:20] gone to get help from a colleague. That's not accurate. She did leave the scene after the shooting [2:04:26] happened as she returned. There was about a 15 minute period where that happened. The defense has [2:04:33] raised the lack of physical evidence like DNA, blood spatter, gunshot residue, that even if those things [2:04:41] did exist, they would really have no significant bearing on the investigation. The gunshot residue, [2:04:49] I find it interesting that they raised that one in particular. [2:04:53] Our laboratory at the DCI has not done gunshot residue testing for 15 plus years because of the lack of [2:05:03] reliability of gunshot residue testing. So anyway, given those things, I mean, I agree with Mr. Parrish in [2:05:14] the sense that, yeah, this will all come out at some point, but the facts, the nature of the case, [2:05:22] the nature of the crime, and the circumstances are factors that the court has to consider. Again, [2:05:39] Judge, under the circumstances of this case, given what sentence that is facing the defendant, [2:05:48] if she is convicted, taking all, you have all of the details. There is a front end timeline to this [2:05:56] offense that occurred. It's 1 56 PM. It has to do with an email that Ashley Oakland sent that was [2:06:04] unrelated to the homicide, other than it was, she was making plans for that night. And then there's a [2:06:14] 911 call that is made on the back end of it. That's a very tight timeline. Given that in conjunction with [2:06:20] the witness who observed Kristen Ramsey in the area, her statements that she made to police, [2:06:27] which can only best be described as inconsistent, are such that the nature of this case, the circumstances [2:06:36] of this case demand a higher bond. And that's where we would ask that the court place that it was set [2:06:42] initially at $2 million cash only. And we would ask that it remain there. Thank you. Mr. Brown, I have [2:06:50] not made any decision, but I want to have the benefit of full information. Should I decide to [2:06:59] change conditions of release and lower bond? I obviously have the ability to add other conditions [2:07:05] of release. Are there any that the state would be requesting? Judge, we, if, if under any circumstances, [2:07:12] if the defendant is released under any conditions, even if she were able to post a million dollar [2:07:20] or multimillion dollar cash bond, we would ask that she'd be placed under the supervision [2:07:25] of the Department of Correctional Services. We asked that she'd be placed on an ankle monitor and [2:07:32] put under the most restriction the court would be allowed. There may be other conditions I'm not [2:07:37] thinking of at the moment. I know there's been a history, at least with one other defendant, where she [2:07:43] was placed under house arrest. I think that was a reference that was made in another case I did with Ms. [2:07:49] Gentry. And if that restriction were available to the court, we would ask that be imposed as well. [2:07:55] But we would ask for the, for lack of a better term, the tightest restrictions the court could [2:08:00] place upon her, should she post any, any bond, including a cash bond. Thank you, counsel. Mr. [2:08:07] Parrish, sir, again, since it's your motion, I'll give you the last word. [2:08:12] Of course. Go ahead, Mr. Brown. Thank you, honor. [2:08:17] May it please the court. It sounds like the state is primarily relying on the nature and circumstances [2:08:23] of the offense. And to support that, they want to turn the court's attention to the minutes of [2:08:29] testimony, which are the grand jury transcripts. But we want to remind the court to not put as much [2:08:36] weight and emphasis on those minutes and those transcripts as the state wants, because under the [2:08:41] rules of criminal procedure, that same book that the state held up at the beginning of this proceeding [2:08:48] and relied on does not require the state of Iowa to allow us to present any evidence on behalf of [2:08:55] Chrissy at that time. And furthermore, those grand jury rules that they rely on require no evidence of [2:09:04] mitigation or no exculpatory evidence be presented during the grand jury testimony. So essentially, [2:09:11] all of these hundreds or thousands of leads they received, none of that was presented. [2:09:19] All of the potential exculpatory evidence that is included in a file that we, for the very first [2:09:25] time here, heard that there's an open file policy when just moments ago we were back in chambers and we [2:09:32] were told that it would not be disclosed because it doesn't want to be done in a piecemeal fashion was [2:09:37] available to us. So we're a little bit concerned about some of the statements that are being made [2:09:42] here today to the court on the nature and the circumstances. When we don't have a lot of this stuff, [2:09:48] the court hasn't seen the exculpatory evidence and we believe there is exculpatory evidence in there [2:09:53] because of past press statements that were made at the time of the offense, leads that were explored, [2:10:00] that were never presented. So again, when we're talking about the nature and circumstances and [2:10:05] relying on the testimony and the transcripts, be cautious, be careful because we haven't had our turn [2:10:12] and we are waiting for the discovery and we will defend this case on the nature and the circumstances. [2:10:18] Now also, in terms of there's no assurance that can be given to the court on flight or things like that, [2:10:28] judge or access to guns, which is what we heard in the state's argument, I mean the court can give [2:10:35] assurances and they're called court orders. If there is a situation, take it out of the context of this case, [2:10:43] there's a dispute between two married folk. There is a no contact order that is entered. That no [2:10:49] contactor gives assurance that somebody's going to be protected, that gives assurance that somebody's [2:10:54] not going to be within the vicinity of that person. That same kind of assurance can be given in this case [2:11:00] through a court order, preventing Chrissy from having access to firearms, to anything else that the [2:11:05] court is concerned about. So absolutely, the court can give assurances to the community that Chrissy [2:11:11] doesn't pose a risk of harm because the court has directed her to, and there's contempt for that, [2:11:16] and there's revocation of bond and all of those consequences that would be available. So yes, [2:11:22] this court absolutely can give assurances to the public. Now, I'm not going to belabor the other [2:11:30] factors because they overwhelmingly support a drastic reduction in bond in this case. The state focused on [2:11:39] one or two, but we have family ties. We have seamless employment over Chrissy's entire life. [2:11:45] We have her character. We have discussed there's no mental health issues. There is a lifetime length [2:11:53] of residency in the community. There's no record of convictions. Sans a speeding ticket. There's been no [2:11:59] issue with court appearances because she's never been in trouble before. All of these factors, [2:12:03] your honor, support that dramatic reduction in bond. Now, I know every case is different, [2:12:10] but the prosecutors did cite to two cases out of Dallas County where the defendants, I believe, [2:12:17] started out with a $1 million bond. One of those cases, I'm not sure if a bond review was even asked. [2:12:23] In the other case, the defendant had a pretty significant criminal history that the state relied [2:12:29] on for the million-dollar bond to remain where it was. And if those are million-dollar bonds in those [2:12:34] cases, we feel like that should be the ceiling where the court starts considering this case [2:12:41] and go down from there. And if you look at all of those factors, they do support what we're asking, [2:12:46] which is a $100,000 bond. We would be able to post an unsecured 10% of that amount to the clerk of court. [2:12:53] We would agree to electronic monitoring. We would agree to a curfew. We would agree to being appointed [2:13:00] a pretrial release officer with the Department of Correctional Services or any other designee that [2:13:05] the court deems appropriate. You heard unequivocally the evidence in this case, including over 70 pages [2:13:12] of community support. You heard from witnesses who Chrissy is. Her character, since she was a child [2:13:19] until now, has been unwavered. There's no evidence that there is anything different in who she is now [2:13:26] and is against who she was then. That's why we're asking that the bond be reduced to the request that [2:13:31] we made. Thank you, counsel. Well, I want to end where I began by acknowledging that I understand that [2:13:42] the outcome of this hearing is important to all concerned. I have an important responsibility to make [2:13:50] a determination of the motions that are pending before the court. And just so the parties know [2:13:59] and the people here watching know, the court has discretion in this proceeding. But my discretion is [2:14:11] just not unlimited. It's not my whim. There are certain factors that I have to decide and have to consider, [2:14:20] including the law, a number of characteristics of the defendant, a number of factors. I've heard [2:14:29] evidence today, and I've heard arguments of counsel. And I want to take some time to consider those [2:14:36] arguments, to look at the evidence more clearly, again, in light of what I've heard here today, [2:14:43] so I can make the best decision I can on what I've heard and what will, in this case, be a suitable bond, [2:14:51] whether or not the bond should be modified. In making my determination, it's important the public know that [2:15:00] a bond is not meant to punish somebody. The defendant is presumed innocent. On the flip side, [2:15:09] there's been a finding of probable cause that the defendant committed a very serious crime. The court [2:15:17] will have to give thought to what I've heard, and I intend to issue a ruling in writing. I'm hopeful by [2:15:25] the middle of next week at the latest. I want to close by saying to counsel that I appreciate your [2:15:33] efforts today, representing your respective positions. You've given me a lot to think about, [2:15:40] and I appreciate your advocacy, because in order for me to make the best decision I can, [2:15:46] it's incumbent upon me to hear from both sides putting forth their best arguments. So thank you [2:15:53] for that. Hopefully that will sharpen my decision making. I also want to close by thanking the members [2:16:00] of the community or interested party who came here today to watch. Your behavior lived up to what I [2:16:07] expected. This is an important matter. It needs to be conducted with dignity, and you've lived up to [2:16:14] that. So thank you very much. With that, we are adjourned.