Defense Investigation

Documents from Adnan’s Defense Team

After his arrest, Adnan’s family hired attorneys Douglas Colbert and Chris Flohr, who tried, although unsuccessfully, to get him out of jail on bail. After a few weeks, Colbert and Flohr helped Adnan’s family to hire another lawyer to prepare for trial, and in April 1999 Maria Cristina Gutierrez was hired. Some evidence from her files appears below.

There is some other evidence available that hasn’t yet been integrated into this page. During the February 2015 PCR hearing in Baltimore Gutierrez’s files (incorporating Flohr and Colbert’s records) became part of the official court records. Only a few dozen pages, of several hundred, are publicly available. The prosecution selected some and published them during their appeal to COSA, you can find details on a separate page – with the reference type “A-XXXX”. None of the Syed Appendices that were submitted to COSA were published and we have no explanation why.

Defense Team

Douglas Colbert – Adnan’s lead bail attorney
Chris Flohr – Colbert’s assistant attorney

Maria Tina Gutierrez – Adnan’s lead trial attorney
Andrew Davis, Thor Daniels – private investigators working for Adnan. Davis worked for both Colbert/Flohr and then Gutierrez, Daniels just worked for Gutierrez
Mike Lewis, Kaliope Parthemos, Ali Pournader, Julie Remey – law clerks, paralegals and/or law students working for Gutierrez’s firm: Redmond, Burgin & Gutierrez
Rita Pazniokas, Mark Martin, Phil Dantes, Bill Kanwisher – Attorneys working at Redmond, Burgin & Gutierrez
Michael Millemann – attorney from another firm who briefly represented Adnan during the State’s attempt to disqualify Gutierrez

Evidence Reviews

Gutierrez and/or her team inspected the physical evidence collected by Baltimore Police. There are several drafts of their write ups, but we don’t have a complete or final copy. These reviews are helpful because they often give a much more detailed description than the Police records, where many items were logged collectively. E.g. “Items from the Back Seat” from the Police records vs listed items, with details such as the style, size and color of clothing, what brand of perfume bottle was found inside Hae’s purse, details of what is on a particular receipt.
Combined pages posted on Rabia’s blog, various dates 11/3, 11/8 and 11/12/1999.
Undisclosed pages relatinng to Hae’s car
Undisclosed section about the Exxon Receipt (in Hae’s car) from Jan 5, 1999

Evidence Collected

Adnan’s AT&T Bill
Prayer Notes that Adnan and Bilal went through on 1/13/999 in anticpation of Adnan’s 1/14/99 talk at the mosque
Combined (searchable) extracts from Becky’s Notebook
Individual pages: Adnan’s Character; Adnan’s and Hae’s Relationship; Adnan’s Behavior When Hae Went Missing; Adnan’s Behaviour At The End Of The Relationship

Interviews with Adnan

Handwritten notes 7/13/99 prepared by clerk from visit to Adnan in jail, mention of Asia McClain in library
Memo 8/25/99 from Gutierrez clerk written after visiting Adnan in jail, describing filming in detention center, relationship with Jay, Adnan’s memories of January 13th
Handwritten notes 8/25/99 prepared by Adnan describing his day on 1/3/99
Memo 10/6/99 from Gutierrez clerk describing Hae being upset about Jay cheating on Stephanie
Memo 10/12/99 – lengthy interview by Gutierrez clerk of Adnan, regarding Hae’s diary and his relationship with Hae
Memo 1/15/00 from Gutierrez clerk written after visiting Adnan in jail with his thoughts after the first trial. Describes his thoughts on Officer Adcock, Nurse Watts, Debbie and the “I am going to kill” note, track, and Jay, including his relationships with Stephanie and Jenn

There are more memos about Flohr’s visits to Adnan in the defense files,.

Other witness investigations

Undated snippet from defense files stating that Jay told Tayib Adnan showed him Hae’s body at a gas station and he helped Adnan bury the body
Undated handwritten notes from defense files to contact a medical examiner
Undated handwritten notes from defense files about Asia, Jay, Stephanie
Notes 3/10/99 from defense investigator Drew Davis about interview with Sis from Southwest Video about Jay’s work schedule
Memo 3/10/99 from defense investigator Drew Davis describing his interview with Stephanie at her home
Memo 3/11/99 from defense investigator Drew Davis describing his interview with Stephanie at Hae’s memorial service
Memo 8/4/99 from clerk Kali P to Gutierrez summarizing the police’s anonymous call memo and summarizing an interview with Adnan’s brother Tanveer and mother about Yaser Ali.
Memo Updated 8/4/99 – titled “Information in file concerning Jay Wilds,” author unknown
Memo 8/21/99 – from clerk Ali P to Gutierrez summarizing an interview with Adnan’s brother, also called Ali here)
Handwritten Statement of Neighbor Boy 9/3/99 given to defense investigator Drew Davis
Memo 9/3/99 – Davis attempted to interview Jay
Memo 10/16/99 – one of Gutierrez’s clerks lists the boys on the indoor track team, matches names and order of list from the Woodlawn High School yearbook who medaled in track
Memo 12/15/99 – Describes alibi witnesses that Davis would need to contact
Undated handwritten notes by Gutierrez clerk about Jay‘s third interview, but likely during or between the first and second trials
Undated handwritten notes in Gutierrez’ own handwriting about Davis’s interview with track coach Michael Sye (that was probably on 3/33/99)
Handwritten notesĀ 12/14/99 by Gutierrez about Dr M Korell‘s testimony (about the autopsy), notes undated but likely taken made 12/14/99 during the direct, first trial.
Memo 1/21/00 from Gutierrez law student clerk summarizing Ja’uan‘s police interview
Memo 1/14/00 from colleague to Gutierrez with message from assistant track coach Russell, noting subpoena had been misaddressed to his former employer, Woodlawn High.
Memo 2/2/00 from Gutierrez clerk documenting efforts to look into Jay‘s sentencing for accessory after the fact and Mr. S.‘s indecent exposure charges


Single page To Do list, undated – handwritten, not clear if it’s by Davis or one of Gutierrez’ clerks
Notes undated – handwritten, by Gutierrez, topics include Debbie, Jay
Notes undated – handwritten, by Gutierrez, on Jenn P’s 2/27/99 statement
Billing Summary 3/31/99 from Andrew Davis, describing work for bail hearing
Gutierrez Bill 06/29/99 – for work done by Martin and Gutierrez from 4/7/99 to 6/29/99
Bilal’s Waiver for Gutierrez 07/09/99 – allowing her to work for Adnan after having earlier represented Bilal at the Grand Jury
Task List 9/4/99 – lengthy defense task list discussed on Undisclosed
Extracts from March 1999 report into Don’s alibi by Andrew Davis.
Memo 9/16/99 suggesting Gutierrez was confusing the Acosta Martinez case with Adnan’s case

See also the Pre-Trial and Discovery page:

The Defense Investigation Continues . . .