OH v. Andrew Griffin Day 4

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All right.

Speaker 2 (28:51):

Stand on the step, face me. Raise your right hand, please. Do you swear the testimony you're about to give will be the truth, the whole truth, nothing but the truth, so help you God?

Bryan Lacy (29:00):

I do.

Speaker 2 (29:00):

Have a seat.

Judge (29:06):

Sir, do you object to being filmed?

Bryan Lacy (29:08):

I do not.

Judge (29:11):

Okay. Thank you.

(29:11)
You may proceed.

Mr. Kinsler (29:16):

Good morning.

Bryan Lacy (29:17):

Good morning.

Mr. Kinsler (29:18):

Sir, would you please state your name for the record?

Bryan Lacy (29:21):

My name is Bryan Lacy.

Mr. Kinsler (29:23):

Would you spell both your first and last name?

Bryan Lacy (29:25):

Sure. B-R-Y-A-N L-A-C-Y.

Mr. Kinsler (29:29):

What do you do, sir?

Bryan Lacy (29:31):

I'm a special agent with the FBI.

Mr. Kinsler (29:33):

And what do you do as a special agent with the FBI?

Bryan Lacy (29:38):

I'm currently assigned to the Cincinnati Division Columbus office, and I'm on a violent crime and gang squad.

Mr. Kinsler (29:47):

How long have you worked for the FBI?

Bryan Lacy (29:49):

I've worked for the FBI since 2010.

Mr. Kinsler (29:52):

And what sort of training and experience do you have... Let me ask you this way. I'm sorry. What sort of education do you have?

Bryan Lacy (30:00):

My background, my educational background is I have a Bachelor of Science in Mechanical Engineering from the University of Akron, and I have a Master's of Business Administration from Kent State University.

Mr. Kinsler (30:12):

Do you also receive specialized training to become an FBI agent?

Bryan Lacy (30:15):

Yes, I did.

Mr. Kinsler (30:17):

And what was that?

Bryan Lacy (30:18):

So basically, it's a FBI Academy in Quantico, Virginia. Most people have seen or heard about it on TV. When I went through, it was 22 weeks where you learn about the law, you get trained in firearms, you get trained in defensive tactics, and all sorts of other training over the course of those 20 weeks. And assuming you pass all those phases and pass your physical requirements, firearm requirements, at the end of that, you become a special agent with the FBI.

Mr. Kinsler (31:02):

What sort of work do you do at present for the FBI?

Bryan Lacy (31:04):

My current assignment, as I mentioned, I'm on a violent crime squad in Columbus. So I investigate violent crimes, robberies, homicides, and other stuff. But I also have a collateral duty called CAST.

Mr. Kinsler (31:18):

And what is CAST?

Bryan Lacy (31:20):

CAST stands for Cellular Analysis Survey Team, and it's approximately 100 FBI special agents and task force officers that specialize in historical mobile device or cell site analysis. And we do that in order to locate phones in real time, such as in kidnapping or fugitive investigations. We do that to show where a phone was historically, such as in homicide investigations or robbery investigations. And we also do extensive training to our federal, state, and local partners on the same methodology that we use.

Mr. Kinsler (32:04):

And do you receive specialized training to do this?

Bryan Lacy (32:07):

Yes. The specialized training that we go through to become CAST certified is approximately 230 hours and it's over the course of a year and a half to two years. And it starts off with just kind of a basic introduction into historical mobile device location analysis, looking at records, showing where a phone was approximately, or a mobile device was approximately at a date and time. The next phase of that is you get introduced to creating reports. And not only do I want to know where the phone is, but I want to be able to create a report and show others. And for purposes of testimony in court, do that as well. The third phase of that is called critical incident readiness assessment. It's over the course of three days, you're given scenarios one at a time. In each scenario, you have to, under a time limit, look at the records, try and figure out where a phone was and then create a report simulating a command post environment.

(33:12)
We do that over the court. We do that five times. Those are all graded. And depending on how you do, if you're in the top part of the class, you get invited to the final phase of our training, which is called certification. Our certification involves, it's four weeks total. The first week involves training from the Florida Institute of Technology on radio frequency theory. The second week involves meeting with cell phone providers, AT&T, T-Mobile, Verizon. We meet with their law enforcement group. They show us the records or we go through the records, ask questions about the records. And then we also meet with the network engineers, who manage and optimize and run the networks, get a little deeper into how cell phones and cell sites work. And then the third week we get the tools and the software accounts set up and training on how to make and create these maps.

(34:08)
And then the final week of that, we're given a scenario and asked to look at the records and create a report. And then we go on a mock trial in front of senior cast members. And then only if we pass all those phases, do we become CAST certified. And then every year since I've been certified, which was 2022, we go back to an annual recertification course in which all of us get together for four days and we again meet with providers, social media companies, to talk about the type of records that are available for historical location analysis. And we also get case studies from other agents and task force officers around the country to hear what has worked in their areas.

Mr. Kinsler (34:54):

And have you provided cell site analysis in the past?

Bryan Lacy (34:59):

Yes, I've done it in cases over 200 times.

Mr. Kinsler (35:03):

Okay.

Bryan Lacy (35:00):

... done it in cases over 200 times.

Christopher Kinsler (35:03):

Okay. Are you able to do this work without the actual cell phone?

Bryan Lacy (35:07):

Yes, I am. Yes.

Christopher Kinsler (35:08):

And how is that possible?

Bryan Lacy (35:10):

So basically what we do is when a cell phone has been identified as associated with a subject or a victim in a case, we can go to the provider of that cell phone and ask for call detail records. And we analyze the call detail records.

Christopher Kinsler (35:30):

Approximately how often do you analyze call detail records?

Bryan Lacy (35:33):

I do it pretty much daily, and since I've been an FBI agent, I've done it well over 200 times. Or I'm sorry, since I've been CAST certified, I've done it well over 200 times.

Christopher Kinsler (35:45):

Have you had opportunities to validate the analysis you do with other data?

Bryan Lacy (35:51):

Yes. So there's several ways to validate it. One way might be is if you actually get the cell phone, sometimes cell phones themselves will store your location on it, your precise latitude and longitude, and we compare that with what the records say to validate it. But probably most frequently what we do is we actually, as I mentioned, fugitives and kidnapping situations, we actually in real time give a location, approximate location of a phone and go out and find that phone in that location.

Christopher Kinsler (36:24):

Have you used historical cell site analysis in located fugitives? That's what you just were asked.

Bryan Lacy (36:28):

Yes. Yes.

Christopher Kinsler (36:30):

Have you previously testified as an expert in historical cell site analysis?

Bryan Lacy (36:34):

Yes, I have. Seven times total, five in the State of Ohio.

Christopher Kinsler (36:39):

Okay. Your Honor, I'd like to move to qualify him as an expert in cell site analysis.

Speaker 5 (36:44):

No objection, Your Honor.

Judge (36:45):

All right. Then the jury will regard this witness as an expert in, is it cell phone?

Christopher Kinsler (36:51):

Cell site analysis, Your Honor.

Judge (36:52):

Cell site analysis.

Christopher Kinsler (36:56):

Can you briefly explain how cell phone communicates with the cellular network?

Bryan Lacy (37:00):

So a cell phone is a radio similar to a radio in a vehicle that receives a signal from an antenna or a station in town that you listen to your favorite music or a talk show. The main difference between a cell phone and a radio in your vehicle is that a cell phone will not only receive a signal, a radio signal, but a cell phone will transmit a radio signal so that the party on the other end can hear you talk as well as you hearing them, thus enabling two-way communication.

Christopher Kinsler (37:39):

What is the cell tower and what purpose does it serve?

Bryan Lacy (37:42):

So a cell tower is a structure or a pole that's in an area that has... It's stationary typically, and it has antenna mounted to them and it communicates with your cell phone, but the cell tower more importantly is also connected to the public telephone network. So it enables you, once you've connected to that cell tower, then you can make that phone call or send that text. It also connects your cell phone to the internet so you can browse, stream, check out your Facebook page, et cetera.

Christopher Kinsler (38:18):

Is there a standard distance between cell towers?

Bryan Lacy (38:21):

There is not a standard distance between cell towers. So I made the analogy of the vehicle radio. If you're tuned into your favorite radio station, it's maybe coming out of Wheeling and you start to drive westbound, at some point you're going to lose that radio station signal. Well, that would be no good if cell phones operated that way. So what cell phones do is they place cell towers based on the geography, based on the population, so that as you travel or you're mobile, your phone will be in constant contact with a cell tower. So as one cell tower gets weaker, your phone conversation or data session, whatever it is transferred to another cell tower that is providing a better signal.

Christopher Kinsler (39:07):

How are cell towers typically configured?

Bryan Lacy (39:11):

Typical cell towers are configured, a cell tower provides 360-degree coverage generally to an area and they accomplish that by sectorizing them. And typical cell towers have three different sides or three different sectors.

Christopher Kinsler (39:26):

So what is that sector?

Bryan Lacy (39:28):

A sector is basically just an antenna that's mounted on top of that cell tower and it's pointed in a certain direction. And each of those sectors is more or less for that cell tower spaced 120 degrees apart. So if you were to have three of those, then you would have your 360 degree of coverage.

Christopher Kinsler (39:47):

And I think I understand you say that it's typical to have three?

Bryan Lacy (39:49):

Yes.

Christopher Kinsler (39:49):

Is it always three?

Bryan Lacy (39:52):

It's not always three. I believe in the past there were some six-sided cell towers. I don't see those. I've not seen those, but what I have seen is more the omnidirectional towers, meaning you might see in more of an urban environment, a little antenna mounted on top of a telephone pole and it provides 360 degrees of coverage, but it also provides typically a much smaller coverage area to fill in gaps where there might be dead zones in a city where a building might be blocking the signal from the bigger cell phone tower.

Christopher Kinsler (40:30):

Okay. And I guess circling back to not the... I'm sorry, you called it omnidirectional tower?

Bryan Lacy (40:36):

Yes, I did.

Christopher Kinsler (40:37):

The more typical three-sided, is it always... I think you testified that those are typically arrayed, so each one is pointing at 120-degree angle?

Bryan Lacy (40:46):

The sector provides coverage of approximately 120 degrees. They're not always spaced like a perfect... We'll get into that. There's a visualization further in the report if we can get to that and I'll be able to explain it better.

Christopher Kinsler (41:02):

What is an azimuth?

Bryan Lacy (41:04):

The azimuth is something... So I mentioned before, call detail records for a phone, for a subject or victim phone are provided by the cell phone provider. They also provide what we call a cell tower or a cell site list. That cell site list gives the latitude and longitude of that cell tower, but it also gives you the azimuth of the sector and the azimuth is basically a heading or direction. So if your azimuth is zero degrees, and again, there's a visualization that I'll show you here, but if your azimuth is zero degrees, that means that your radio frequency signal is directed at the zero degree or due north azimuth.

Christopher Kinsler (41:49):

Who provides the tower location information for your analysis?

Bryan Lacy (41:53):

The cell phone provider provides it.

Christopher Kinsler (41:56):

And that's just telling you what information?

Bryan Lacy (41:59):

That tells you the latitude and longitude of the cell tower and also as mentioned, the azimuth of that sector of that cell tower.

Christopher Kinsler (42:09):

What is a cell phone doing when it's simply powered on but sitting idle?

Bryan Lacy (42:13):

So when a cell phone is on just sitting there and idle, not in the middle of a text or a call or a data session, your cell phone's constantly scanning the radio frequency environment and keeping a list of radio frequencies from cell sites in the area and it's ranking those. So it always has a ranking of the best signal down to the lowest signal that it can see. And it does that so that when you go to initiate a call or receive a call or send or receive a text, the cell phone is going to pick the best cell signal that the cell phone sees and use that tower for the communication.

Christopher Kinsler (42:53):

And what or who determines which tower handles the communication?

Bryan Lacy (42:59):

Sorry, I was getting a little ahead of you there. The cell phone itself determines what cell tower, it tells the provider or the network what cell tower is going to use for that initial communication. And that's when the record is logged. When you make that call, that information is recorded. "This is the cell tower that was used," and the cell phone picks that tower.

Christopher Kinsler (43:24):

Does the phone always communicate with the nearest tower?

Bryan Lacy (43:27):

No, not always. I would say most of the time, yes, it does. But again, cell towers are based large part on geography as well. So if you live maybe in a valley and there's a cell tower that's on the other side of that valley, other side of a hill, maybe that cell tower doesn't... The closest one doesn't reach your phone, but maybe there's one a little further off that's also in the valley. Maybe your cell phone... Radio frequency works by line of sight, so maybe your cell phone receives that signal, sees that as a stronger signal, so it might use a farther cell tower. But generally, most of the time it's the closest cell tower.

Christopher Kinsler (44:08):

What records does cellular providers maintain regarding these communications?

Bryan Lacy (44:12):

As I mentioned before, they have call detail records. And when I say call detail records, basically it's used for billing purposes, so they know how many minutes of calls you've made, how many text messages you've sent, how much data you've used. And these call detail records, think of it like a phone bill from a cell provider. It includes the date and the time of the activity. It includes the parties involved in the activity, who received the call, what phone number made the call. It includes a duration if it's a call or a data session. And then different from your phone bill, the call detail records also have the cell site that was used during that activity.

Christopher Kinsler (44:58):

Were you asked to assist an investigation conducted by Belmont County Sheriff's Office of the homicides of Tom and Angela Strussion?

Bryan Lacy (45:06):

Yes, I was.

Christopher Kinsler (45:07):

Okay. And what role were you asked to play?

Bryan Lacy (45:11):

So I transferred to the Cincinnati division in 2019, and so in 2021, I was assigned to the Cambridge Resident Agency at that time. And so I covered eight counties in Southeastern Ohio, including Belmont County. So at that point in time, I was a case agent and responded. I believe I went out there the day of, that it happened in response to a call from Belmont County. We had worked on other cases in the past, so I went out and did that. And then about halfway through the investigation in 2022, I became CAST certified. But primarily my role was as we took some of the evidence from Belmont County. We submitted it to our lab, FBI lab. We took some cell phones. We did some extractions of the data on those cell phones. When I say we, not me, myself, other agents did that work and provided those results to Belmont County.

(46:17)
And then when I became certified, my role, and slightly before that, because I was getting introduced to that was to... We did cell tower dumps in this case and we looked for... That's the process of you know a crime happened at a certain time, you go to the provider and say, "Give me all phone numbers that were connected to towers in the area around that time." So I would get phone numbers from Belmont County Sheriff's Office and run those phone numbers in what we call these tower dumps to see if that's a device or a subject we should explore further. It's just a lead at that point.

Christopher Kinsler (46:55):

And so for this case, you were asked to do one of those CAST analysis, is that correct?

Bryan Lacy (47:05):

Yes, I was.

Christopher Kinsler (47:05):

And did you prepare a report of that analysis?

Bryan Lacy (47:08):

Yes, I did.

Christopher Kinsler (47:15):

Okay. Your Honor, may I approach?

Judge (47:39):

Yes.

Christopher Kinsler (47:46):

Before we get to your report, does every provider maintain their own towers?

Bryan Lacy (47:50):

Yes. Every provider maintains their own towers. When I say every... the big three providers, AT&T, T-Mobile and Verizon all have their own towers. So if you have an AT&T phone, it's going to show up in the records of the AT&T cell tower. If you have a Verizon phone, you'll be on the Verizon cell tower, especially nowadays when the networks are mature and pretty much every provider provides coverage in most locations, unless you're in one of those unfortunate locations that gets no coverage. So yes.

Christopher Kinsler (48:24):

You've been shown what's been marked as State's Exhibit 142. Do you recognize that?

Bryan Lacy (48:28):

I do.

Christopher Kinsler (48:29):

And what is that?

Bryan Lacy (48:30):

This is my historical mobile device location analysis report that I prepared for this case.

Christopher Kinsler (48:40):

Your Honor, I move to publish Exhibit 142.

Speaker 5 (48:43):

No objection, Your Honor.

Judge (48:44):

You may proceed.

Christopher Kinsler (49:00):

I think we kind of covered the introduction. I'm going to move on, and I think you've described cell towers for us in sectors. The first several pages of your report, am I correct, some of the background information that you've already provided to the jurors?

Bryan Lacy (49:12):

That is correct.

Christopher Kinsler (49:14):

I'm looking at page four. Is this a helpful... Does this diagram illustrate one of the points you were making?

Bryan Lacy (49:22):

Yeah. So as we were talking about azimuth and sectors before, this particular slide is the center of the illustration on the right is if you were looking top down at the cell tower. We've all seen these cell towers along the side of the highway, these metal structures with antenna mounted to the top, like triangular shape antenna or structure on the top with antenna mounted to them. So these are the sectors. So what we get from a provider is an azimuth. So if we're given a cell phone during a certain activity used, this cell tower, sector number one in this case, we would know that the radio frequency during that activity was aimed at zero degrees due north. If we were given sector two, we would know that that was aimed... The azimuth would be 120 degrees, so the radio frequency is broadcast out at 120 degrees, so to the southeast.

(50:26)
And the way I like to think of that is if I was to turn off all the lights on this room, and I don't remember which way due north is, let's say due north is that way and I had a flashlight and I aimed at due north, that's what the radio frequency signal would look like if you could see it. So the center of that area, due north would be the strongest radio signal. And then as you went out to the sides of that 120-degree coverage, the radio signal would weaken as you got out to the sides. And like I said, in the three sector setup, each sector provides approximately 120 degrees of coverage before it will switch over to another sector.

Christopher Kinsler (51:08):

So when you're getting this information and it's telling you, for example, in this case, if it's telling you sector one and you described, is that just a fancy way of saying that the call came from generally that direction or the phone was generally in that direction?

Bryan Lacy (51:20):

The phone was generally in that direction, yes.

Christopher Kinsler (51:24):

And to be clear, you can't say precisely where that phone was?

Bryan Lacy (51:27):

I cannot say precisely from these records where the phone was.

Christopher Kinsler (51:36):

We're looking at the fifth page of your report, and I think you've kind of touched on this, but if you don't mind explaining the diagram, the three sector illustration.

Bryan Lacy (51:44):

Sure. So on the last page, I showed all three sectors, but on this page, this is what you'll see in the maps that are following here. The little blue dots, if you look at the illustration on the upper left, you have a map of an area, the little blue dots on that map represents other cell towers in the area, and then the wedge-shaped thing, pie-shaped thing up at the top of that illustration indicates the sector. So I'm not showing all three sectors like I was in the other map. I'm only indicating the sector that was utilized during that activity. There's also a little shaded in area. Might be a little hard to see. No, I think you can see it.

Christopher Kinsler (52:28):

Excuse me, Special Agent Lacy, do you have a pointer up there at the desk? I can give you one if you don't.

Bryan Lacy (52:34):

Is this a pointer?

Christopher Kinsler (52:34):

Yes, please. If you don't mind.

Bryan Lacy (52:37):

This little shaded area, if I can be still there. That little shaded area is not indicating that the phone is in that shaded area. It's indicating that the radio frequency is utilizing that sector, basically. So I'm not saying that's where it is. So if I was to look at that illustration, I would say the phone is somewhere to the southeast, was located somewhere to the southeast of that cell tower, somewhere between that cell tower where the sector is shown, and then you'll see another blue dot there down below 27. It's kind of hard to see on the screen, but this little blue dot down there. The phone would be somewhere in that approximate area between the two.

(53:21)
On the right-hand side of the box, you'll also see these on the screen. This is the detail of the activity, right? So number one in that screen is the cell site, cell ID number. That's the number that the network uses assigns to that particular cell site. Number two there is the date of the record from the call detail records of a subject's or victim's phone. Three is the time. Four is the type of activity, incoming outgoing call or data session. Five is duration, if appropriate. And then six is the other party involved in that communication, the other phone number involved in that communication. Now, in this case, we have multiple phones, so I've also highlighted records by color. So when you see red here, sometimes I'll refer to it as the red phone, there'll be other colored phones here, blue phone, green phone, and I'll show them on the same map just to kind of simplify whose phone is using what cell tower at what point in time. So that's one of the ways that we do it. So in the...

Christopher Kinsler (54:34):

Sorry about that.

Bryan Lacy (54:35):

No, it's fine. So in the illustration box, the example that I'm showing above, the target number, which was the red phone ending in 4775, made an outgoing call to a number ending in 3870 at 7:03 AM on 9/21/2021, and the call lasted for 24 seconds. You'll see these call out boxes on the following slides.

Christopher Kinsler (55:03):

And I think your report, if I'm correct, is you're kind of broken it down into parts. What is this first part we're going to be talking about?

Bryan Lacy (55:09):

Okay. So this first part, I have it broken down. As I mentioned before, there's a total of one, two, three, four, five, total of six phones that I have map records for. So this first part is the red phone ending in 4775, we have attributed to the subject's phone. The second phone, the green phone ending in 7299, we have attributed to Thomas Strussion's phone. And then the third phone number that I'm going to show, the blue phone ending in 1057 is for Angela Strussion. And we're going to look at the time period from September 19th to 21st of 2021.

Christopher Kinsler (55:50):

I want to touch on this. So the phone numbers we're talking about, who gives you that information?

Bryan Lacy (55:56):

The Belmont County Sheriff's Office and they also... The Belmont County Sheriff's Office, you get these call detail records I'm talking about through search warrants. The Belmont County Sheriff's Office got search warrants for these phone numbers and sent me the records to analyze.

Christopher Kinsler (56:14):

[inaudible 00:56:11] Is it fair to say the information you're getting is coming from Belmont County Sheriff's Office?

Bryan Lacy (56:18):

That is correct, yes.

Christopher Kinsler (56:19):

And that includes identifying these phone numbers?

Bryan Lacy (56:22):

That is correct.

Christopher Kinsler (56:24):

When I say identifying, I guess the person that they associate with that phone number?

Bryan Lacy (56:28):

That is correct, yes.

Christopher Kinsler (56:29):

And you mentioned the first one, the phone number ending in 4775, it's subject phone. How did you come to be aware of that phone?

Bryan Lacy (56:37):

So a series of interviews were done at some point. There was mention of some other parties involved in this case, and I think we got those records. When I say we, Belmont County got records for this other individual. An FBI analyst went through those records and found a call to an individual that just looked out of place one time only during the timeframe of the homicides or around the time of the homicides or within a day. And then that analyst came to me and said, "Hey, I got this phone number. Do you mind double checking it in the tower dumps that I had mentioned earlier?" So I went to our tower dump and I looked at the phone number and it was on the tower dump, meaning that it was in the area of Belmont around the time of the crime.

(57:42)
So then with that phone number, I believe we called Belmont County Sheriff's Office and informed them that we found a number of interest. But again, like I said before, that's just a lead at that point. A lot more work has to go into it after that point. So we called Belmont County Sheriff's Office, informed them of that number, and I believe they got a search warrant for that phone number and the historical records for that phone number.

Christopher Kinsler (58:06):

Okay. And that analyst's name?

Bryan Lacy (58:09):

Yeah, he's analyst Brian Warcholak.

Christopher Kinsler (58:15):

Okay. And Brian Warcholak's testified previously to the jurors, he provided that information that ultimately led to you having tower records for this phone, the subject phone?

Bryan Lacy (58:24):

Yeah. He discovered this phone number that then we shared with Belmont County to get records on, yes.

Christopher Kinsler (58:30):

I'm looking at, I think, or we are looking at page seven of your slide or your report, excuse me. What are we looking at here?

Bryan Lacy (58:39):

So here for the target phone or the subject phone ending in 4775, along with the call detail records, we also get subscription information, so we kind of can tell when a phone has been activated. So we found that this phone was activated on September 19th of 2021 at around somewhere in the five o'clock hour Central Time. I should mention that these upcoming slides, I'm always going to show the times in local time. I didn't mention that earlier, but some of the time zones in this case are in Central, some are in Eastern, but the map is always going to display things in the local time zone that I'm talking about.

(59:24)
So what we see here is there's a Walmart from the ledge in the upper left-hand corner in Marion, Illinois. And what we see is a cell tower that was used to activate the phone between 5:48, the upper call out box to the upper right, the upper blue box here to the upper right, is showing the cell site that was used close to the Walmart, the time of 9:19, when that subject phone had activity utilizing that cell tower between 5:48 PM and 6:07 PM, and then another cell tower that had activity closer to the interstate, a little bit to the southeast of the Walmart, had activity off of that cell tower at 6:07:39 PM and 6:11 PM, basically showing the initial activation and activity on the cell phone ending in 4775.

Christopher Kinsler (01:00:29):

Stating the obvious here, but what does initial activation mean?

Bryan Lacy (01:00:32):

So everybody knows when you get a phone and you can go to a cell phone provider, AT&T, T-Mobile, and they will activate your phone. In other words, they will take the serial number of that phone and update their computer with, "This phone number is assigned to this phone and therefore it is activated." So then you can send and receive calls or do data transactions on that phone. If it's a prepaid, you can do that yourself. Just you can activate it yourself through text messages or through a phone call to the network provider.

Christopher Kinsler (01:01:03):

And that's what's happening here?

Bryan Lacy (01:01:04):

That's what's happening here, yes.

Christopher Kinsler (01:01:06):

You mentioned this, but we're in CDT. What does that mean?

Bryan Lacy (01:01:10):

Central Daylight Time.

Christopher Kinsler (01:01:12):

And how is that different from our time here in Ohio?

Bryan Lacy (01:01:17):

So they're one hour behind us here in Eastern Ohio.

Christopher Kinsler (01:01:25):

And I've advanced to page eight. What is the new information here?

Bryan Lacy (01:01:30):

So this is the same map or information about the cell site that was used and then overlaid with a receipt that I was provided by the Belmont County Sheriff's Office. And this is the receipt of the phone that was purchased from Walmart that we're talking about here. And I know that's the phone because I've highlighted there in yellow down there. Walmart recorded the serial number of that phone, the IMEI or International Mobile Equipment Identification, basically a serial number, that number is the same number that's in the cell phone records for the number ending in 4775. The date and time on that is 9/19 of 21 at 5:05 PM, so slightly before it started having activity on the network.

Christopher Kinsler (01:02:21):

And you're referencing the bottom of the receipt when you say the time?

Bryan Lacy (01:02:24):

Oh, yes. Yes. Yes, I am.

Christopher Kinsler (01:02:25):

And to be clear, is that military time or is that 12 or 24-hour time?

Bryan Lacy (01:02:29):

24- hour time.

Christopher Kinsler (01:02:35):

Page nine, can you explain to the jurors what this map is depicting?

Bryan Lacy (01:02:42):

So this map is a wider picture here that basically spans from Illinois all the way over to Ohio and Pennsylvania area in terms of the area. I'm leaving off at the last time from the previous slide around 6:11 PM Central Time and covering a timeframe all the way up to September 20th at 3:43 AM. So what is that? A little over six, seven, eight, nine. And they're one hour behind us. So what is that, about eight, nine hours? So what I'm showing here is the bottom left-hand corner. You start with the blue. Sorry. You got the Walmart shown there in the initial activation and I call out that activity there in that call out box. It's the same one we just saw. Then the next activity here is near Prospect, Kentucky at 10:53 PM. Then you have activity near Cincinnati, Ohio at 12:08 AM on the 20th. And then finally ending at 3:43 AM on the 20th in Belmont, Ohio. And these are cell tower activity.

(01:04:05)
I'm showing all the cell towers that were utilized during that time, basically showing travel. What I've left off of this map is all the dots that I talked about before. I'm not showing every cell tower along the way because if I did, you wouldn't be able to see this. It would be so many of them. There's thousands. So basically I'm showing travel from Walmart. There's a point of interest here in the middle that we'll cover. I'm calling it Bridge Toll in Prospect, Kentucky. I have another slide to address that in a second, but travel basically from Walmart to the area of the crime scene.

Christopher Kinsler (01:04:45):

Page 10 of your report, what does this map depict?

Bryan Lacy (01:04:48):

So on this slide, this is kind of a zoomed in for the timeframe that I was talking about in Prospect, Kentucky. I'm showing that there's a cell site activity here along the interstate. And, I'm sorry, I can't read the number, it's so small, what interstate that is, but there's an interstate here that crosses the Ohio River or a bridge that crosses the Ohio River. There's activity on the west side, a data activity session on the west side on the 19th at 10:52 PM. And then there's activity on the east side from a cell tower on the east side at 10:53 PM. Again, data. And I'm showing the orange spot as location of a license plate reader or a surveillance camera that captured something and that's on the next slide.

Christopher Kinsler (01:05:44):

So two things. You mentioned that this point here, it's data. What does that mean?

Bryan Lacy (01:05:53):

So I talked about call detail records. Data records are similar. So when you initiate a data session or you're in the middle of using a data session, your phone records... Mainly for billing purposes so that cell phones can make money, your phone records when that data session was started or initiated or continued, the cell phone company logs and the date and the time and the cell tower that was used. Very similar to a phone call or a text message.

Christopher Kinsler (01:06:20):

When something like this event or this activity is happening at 10:52 and 09 seconds, excuse me, 10: 52:09 PM on the 19th, does that necessarily mean the user is using the phone or actively activating the phone?

Bryan Lacy (01:06:35):

Well, the user is probably using the phone, but they don't have to be actually holding it and manipulating it. There could be many things that could be happening. Could be streaming something, music could be streaming, video. You could have some type of a map program up that's constantly feeding your phone data. You could be doing none of those and maybe somebody posts something on your Facebook page and you get a notification pop up on your Facebook. That's also a data thing that you didn't have any input in that happening. It just, the data is sent to your phone at that particular point in time.

Christopher Kinsler (01:07:17):

Okay. So is it fair to say that when you have one of these activities, it could be user initiated, meaning users actually interfacing with the phone. Is that correct?

Bryan Lacy (01:07:26):

That is correct, yes.

Christopher Kinsler (01:07:28):

Could it also be just a program or an app that the users opened that's running?

Bryan Lacy (01:07:33):

Yeah, your phone is constantly using data.

Christopher Kinsler (01:07:35):

And it could also be neither of those two things, but you got a notification or something else that's sort of coming from outside the phone?

Bryan Lacy (01:07:43):

That's correct, yes.

Christopher Kinsler (01:07:43):

Okay. You also mentioned the road. If I zoomed in, would you be able to see which road it was?

(01:07:57)
Oops. Your Honor, may I?

Judge (01:08:38):

Yes.

Christopher Kinsler (01:08:41):

Could the witness just step up and look at the big screen? I'm having trouble zooming in on it.

Bryan Lacy (01:08:47):

It looks to me like-

Speaker 5 (01:08:47):

Your Honor, we're good with this. Go ahead.

Christopher Kinsler (01:08:49):

Go ahead. If I told you it's 265.

Bryan Lacy (01:08:51):

I was going to say it looks to me to be 265.

Christopher Kinsler (01:08:54):

Okay. Thank you.

Bryan Lacy (01:08:54):

Yeah.

Christopher Kinsler (01:09:01):

We've advanced to page 11 and this appears to be the same map with some additional information. What is that?

Bryan Lacy (01:09:06):

So this is a still shot of a photo that was provided to me by Belmont County Sheriff's Office of a surveillance video or a license plate reader that captured a motorcycle, individual on a motorcycle. And the date of this time was 10:52:44 Eastern Daylight Time, which this photo was captured basically to show that this photo was captured in between the two cell tower usages for that phone that ends in 4775, the target or subject phone.

Christopher Kinsler (01:09:53):

Page 12, what does this map depict?

Bryan Lacy (01:09:59):

So with the target phone ending in 4775, I left off on-

Bryan Lacy (01:10:00):

... good phone ending in 4775. I left off on three slides ago showing the travel around 3:43 AM. So basically I'm showing where this phone, the target phone was on September 20th, 2021 between 3:43 AM and 9:18 PM of the 20th. The legend up at the top left is the crime scene, the victim's address in Belmont, Ohio. And as I mentioned before, I'm showing cell towers on this one, the blue dots are the cell sites in the area. So basically showing that in this timeframe, this red phone was in the general area of Belmont, Ohio. At some point, it looks like the phone goes a little bit to the west towards St. Clairsville. I'm sorry, to the east towards St. Clairsville. There's some activity there, middle of the day, but then the phone goes back over towards Belmont early evening-ish.

Christopher Kinsler (01:11:07):

So you indicated at the top there, the activity summary, this is from September 20th, 2021 at 3:43 AM. Is that the first time this subject phone connects with any of the towers depicted in this map?

Bryan Lacy (01:11:22):

Yes.

Christopher Kinsler (01:11:23):

And at least on this display or in this page, page 12, it continues till 9:18 PM on the same date. Is that right?

Bryan Lacy (01:11:30):

That's correct.

Christopher Kinsler (01:11:31):

You mentioned the crime scenes called out and the legend here is the actual location or best approximation of the actual location this red box here?

Bryan Lacy (01:11:40):

That's correct, yes.

Christopher Kinsler (01:11:41):

And that's the 67140 Trails In Drive, Belmont, Ohio?

Bryan Lacy (01:11:45):

Yes.

Christopher Kinsler (01:11:49):

Throughout all this time, all these activities on here, are any of these calls?

Bryan Lacy (01:11:54):

No, this is all data activity.

Christopher Kinsler (01:12:04):

We're moving to page 13. What does this map depict?

Bryan Lacy (01:12:07):

So page 13, we're going to look at the red phone, the subject phone. And as I mentioned before, the green phone 7299, that's Thomas Strussion's known phone. And then 1057 was Angela Strussion's phone. And what I'm starting with, starting at 9:28 PM, and I should call out the legend here again, the crime scene is shown, the red box here, calling out Salsa Joe's Elm Grove restaurant in Wheeling, West Virginia shown here on the map. And if we start in the bottom right corner of this map, you see some activity, some data sessions from the green phone. This is where I mentioned that these... Because it's green, I know it's the green phone. I know that's Tom Strussion's phone. Green phone had some activity in the area of Salsa Joe's. And then I've shown all the cell towers that we use. So this activity goes from 9:52 to 9:54.

(01:13:11)
At 9:54, there's an outgoing call to the blue phone that's highlighted in blue. If you can see that, it's to Angela. And that call lasted 974 seconds. And then you can see another set of activity at 10:02 PM from the green phone. Looks like it's traveling eastbound, consistent with being along I-70.

(01:13:38)
And then finally, if you go to this further left hand call out box... I should mention, so the green phone down here at 9:28 is showing an outgoing call. I'm sorry, 9:54 is showing an outgoing call. That same call is shown here on the blue phone, the second line item down, it's getting an incoming call from the green phone. So basically I can tell the green phone here, the blue phone is here, so they're not together. But then if you look around 10:01, 10:13 PM, there's data sessions, the green and blue phone, both utilizing the same cell tower. And then at 10:15 here, 10:15:18, there's an incoming call to the blue phone from the green phone, Tom to Angela, and they're both utilizing the same cell tower. So these last two transactions are both parties of that and they're both using the same cell tower at that point in time.

Christopher Kinsler (01:14:37):

I want to make sure I heard you correctly. You're describing the movement of the green phone that's associated with Tom Strussion. That was westward, correct? From Elm Grove to Belmont.

Bryan Lacy (01:14:48):

Yes. Westward. Yes. The other thing to point out is there was no activity for the red phone during that window, no data activity that was mappable during that window. And also on that map, I've shown all the cell towers, but I didn't show all the timestamps of each cell tower just for clarity purposes, just so you can read it easier, not get too much information.

Christopher Kinsler (01:15:16):

In this timeframe, the blue phone that is associated with Angela Strussion and these various activities, I think you've mentioned calls. Are all of these... Is she always hitting off the same tower, her phone hitting off the same tower?

Bryan Lacy (01:15:29):

Yeah, her tower is hitting off the cell tower and sector that faces the general direction of the crime scene. Yes.

Christopher Kinsler (01:15:36):

The particular cell tower that you were just illuminating there, is that one located right off I-70?

Bryan Lacy (01:15:41):

It is. I believe it's at the rest stop on I-70.

Christopher Kinsler (01:15:48):

Page 14, what does this map depict?

Bryan Lacy (01:15:53):

So page 14, just stepping forward from the last activity left off at 10:15 PM with Tom Strussion's phone getting in the area of his residence, this picks up where that left off. So I'm looking at a timeframe between 10:16 PM and 11:37 PM. I'm zoomed into the crime scene here. And if you'll start on the bottom right-hand corner, show the cell sites that were used on September 20th. The green phone has a data session at 9:16. The red phone has a data session at 10:18. The blue phone has a data session at 11:01, and then the red phone has another data session at 11:18. All three phones are having data sessions around the same time using the same cell tower, closest cell tower to the residence, pointing in the direction of the residence. And then at 11:37 PM, there's a cell tower activity on a cell tower just west of the residence near Interstate 70 at 11:37 PM. For the red phone, I should say.

Christopher Kinsler (01:17:21):

And I should clarify, the data you have up here for this timeframe from 10:16 PM to 11:37 PM, these are all the activities for all three of those phones. So those phones are always depicted on this map. Is that fair?

Bryan Lacy (01:17:34):

That's correct, yes.

Christopher Kinsler (01:17:40):

And then page 15 of your report, what does this map depict?

Bryan Lacy (01:17:45):

So page 15 is leaving off or starting up where we've left off in the last slide. So if we're just looking at the target phone here, at 11:37 PM, we have this data activity up near Belmont, Ohio, and I'm basically showing travel to the southwest. I've indicated a couple different cell sites along the way. So you start at 11:37 in Belmont, 12:58 near Columbus, a cell site near Columbus at 2:38 AM, cell site near Cincinnati. Keep going, Louisville, Nashville. This bottom box is important. This is the call that I mentioned earlier that was discovered. There's a cell site activation here in Jackson, Tennessee. And specifically if we look at 7:03:13, there's an outgoing call to a number that ends in 3870, which I understand is another associate in this case.

Mr. Shamansky (01:18:53):

Object. Could we approach please?

Judge (01:23:24):

Yes.

(01:23:24)
Back on the record. Ladies and gentlemen of the jury, the parties need to have a discussion. So we're going to take a 15-minute recess. You can stretch your legs. Mr. [inaudible 01:23:32] going to take you back to the jury room. Just remember the orders of this court. Thank you.

(01:23:32)
All right, Mr. Shamansky, hold on for a moment. We're still on the record. We're outside the presence of the jury. As of right now, we have an objection from the defendant as to the witness's last statement he testified to. And then I understand the parties are attempting to resolve another issue. If you're unable to resolve either one, the court will rule from the bench prior to the jury coming back in. But as of right now, we're applying a 15-minute recess.

Mr. Shamansky (01:24:35):

Thank you, Judge.

Judge (01:24:36):

All right.

(01:24:36)
[inaudible 01:24:42]. We're back on the record outside the presence of the jury. Let's start with the state of Ohio. Where are we at with the issues raised by Mr. Shamansky?

Christopher Kinsler (01:44:10):

Your Honor, I think the first issue, if I understand it, was the witness referred to a person of a known associate. The state is okay with striking that answer. The state's going to proceed with another question rather than asking this witness the identity of that known associate or the person associated by the investigation with that particular phone number. We previously admitted state's Exhibit 25A. We're going to show that to him. It was testified to by another witness and ask him if that is the same phone number that he identified in the slide that we just saw, and ask him the subscriber information on that document that's associated with it and proceed from there.

Mr. Shamansky (01:44:51):

No problem with that, Your Honor.

Judge (01:44:52):

All right. Any other issues before the jury's brought in from the state?

Christopher Kinsler (01:44:57):

No, Your Honor.

Judge (01:44:57):

Mr. Shamansky?

Mr. Shamansky (01:45:02):

No, we're good, sir. Thank you.

Judge (01:45:03):

Okay.

Judge Berhalter (01:45:01):

Mr. Shamansky?

Samuel Shamansky (01:45:02):

No, we're good, sir. Thank you.

Judge Berhalter (01:46:58):

Okay. Mr. Barnes, please bring the jury in. Absolutely.

(01:46:58)
Please everyone be seated. Ladies and gentlemen of the jury, Mr. Lacy's last comment, specifically "known associate," is being stricken from the record. You're not to consider those two words for any purpose at all.

(01:47:09)
With that said, sir, reminding you, you're still under oath.

Bryan Lacy (01:47:19):

Thank you.

Judge Berhalter (01:47:20):

All right. And Mr. Kinsler, you may proceed.

Christopher Kinsler (01:47:20):

Thank you, Your Honor. I'm going to resume on Page 15 of State's Exhibit 114. Special Agent, we were speaking about, I think, the outgoing call depicted in this call-out box here.

Bryan Lacy (01:47:43):

Yes.

Christopher Kinsler (01:47:44):

And to be clear, that's taking place at 7:03:13 a.m.?

Bryan Lacy (01:47:49):

That is correct, yes. On the 21st, September 21st.

Christopher Kinsler (01:47:52):

Okay. You described that as an outgoing call?

Bryan Lacy (01:47:55):

That's an outgoing call, yes.

Christopher Kinsler (01:47:56):

From the subject phone to this number right here, 580-372-3870?

Bryan Lacy (01:48:03):

That is correct, yes.

Christopher Kinsler (01:48:04):

Okay. I'm going to show you something that's been previously marked as State's Exhibit 25A. First of all, have you seen this record before?

Bryan Lacy (01:48:16):

Yes, I have seen this before, yes.

Christopher Kinsler (01:48:18):

Okay. Can you tell us what sort of record are we looking at?

Bryan Lacy (01:48:22):

These are billing records associated with the phone number.

Christopher Kinsler (01:48:30):

I'm sorry, do you need me to zoom in?

Bryan Lacy (01:48:35):

Again, these are billing records for the phone number 580-372-3870.

Christopher Kinsler (01:48:43):

Okay. And who is the subscriber at that point?

Bryan Lacy (01:48:49):

It's listed at the top of this billing record as Carolyn Babcock.

Christopher Kinsler (01:48:55):

Okay. What does subscriber mean?

Bryan Lacy (01:48:56):

What does subscriber mean?

Christopher Kinsler (01:48:58):

Yes.

Bryan Lacy (01:48:58):

A subscriber is basically what name and information, address, the phone is registered to.

Christopher Kinsler (01:49:06):

Okay. You described these records as billing records?

Bryan Lacy (01:49:10):

Yeah, they're billing records I believe from U.S. Cellular.

Christopher Kinsler (01:49:13):

Okay. How does that differ from call detail records?

Bryan Lacy (01:49:16):

So I mentioned before, call detail records look like this, but billing records don't have cell site location information during the activity shown in these records. So this is just a standard bill you'd get in the mail or you'd get online emailed to you showing your activity for the month.

Christopher Kinsler (01:49:35):

So you've seen records for this particular phone number ending in 3870 from U.S. Cellular, is that correct?

Bryan Lacy (01:49:41):

Yes, I have seen these. Yes.

Christopher Kinsler (01:49:42):

Any of those records have the location data you're describing?

Bryan Lacy (01:49:45):

They do not.

Christopher Kinsler (01:49:46):

Okay. Do these carriers keep location data forever?

Bryan Lacy (01:49:50):

No. No. Each provider's different. U.S. Cellular, I think they keep their location data, the call detail records for one year.

Christopher Kinsler (01:50:00):

And I want to direct you to the bottom right-hand side. I'll illuminate it for you. There's a number 220. Is that the call we've been talking about?

Bryan Lacy (01:50:12):

Well, this is the U.S. Cellular record of that call, yes.

Christopher Kinsler (01:50:17):

Okay.

Bryan Lacy (01:50:17):

The record I'm referring to and on my slide is the call detail record on the red phone.

Christopher Kinsler (01:50:25):

Okay.

Bryan Lacy (01:50:26):

The target phone.

Christopher Kinsler (01:50:27):

But we're talking about two different ends of the same communication?

Bryan Lacy (01:50:31):

That's correct, yes.

Christopher Kinsler (01:50:32):

This would be the record for that phone number we've been talking about here, and then you were talking about the subject phone. You have records from that as well?

Bryan Lacy (01:50:41):

That is correct, yes.

Christopher Kinsler (01:50:46):

And we were speaking about your slide page, or excuse me, your report page 15, and you mentioned this outgoing call that we're just speaking out to the number ending in 3870. Was there any other ingoing or... Well, I should say, were there any other outgoing calls from the subject phone?

Bryan Lacy (01:51:06):

No, there were no other... During the timeframe that I looked at, no other outgoing calls from the subject phone other than this outgoing call referenced here.

Christopher Kinsler (01:51:17):

Did the phone accept any incoming calls during that timeframe?

Bryan Lacy (01:51:23):

No, the phone didn't have any incoming phone calls. The red phone, the target phone, did not have any incoming phone calls that it accepted.

Christopher Kinsler (01:51:32):

You also have a call-out here, this yellow box. What is that?

Bryan Lacy (01:51:39):

So a little bit hard to see. The yellow box in the bottom left-hand corner of the screen, that's an address I was provided for one of the Griffin addresses in Whitesboro, Oklahoma.

Christopher Kinsler (01:51:52):

Would that address be 30225 River Road-

Bryan Lacy (01:51:55):

Yes.

Christopher Kinsler (01:51:56):

... Whitesboro? And you have a call-out box here on the bottom left. What's the significance of that?

Bryan Lacy (01:52:04):

So with the records that we got back for the target phone, this was the last location activity, recorded location activity, for this target phone at 10:40 a.m. on the 21st of September, utilizing a cell tower in Benton, Arkansas.

Christopher Kinsler (01:52:31):

So am I correct in understanding your testimony today is this phone was activated on the 19th September, 2021, at about a little after 5:00 p.m.?

Bryan Lacy (01:52:39):

That's correct, yes.

Christopher Kinsler (01:52:43):

And then this phone, the phone associated with this number ceased communication within his system September 21st, 2021, at approximately 10:40 p.m.?

Bryan Lacy (01:52:54):

That's correct, yes. 10:40 a.m.

Christopher Kinsler (01:52:57):

I'm sorry. Thank you. 10:40 a.m. Page 16, are we moving on to another segment of your report?

Bryan Lacy (01:53:07):

Yeah. In this next section, we're going to take a look at the AT&T phone number ending in 0229 associated with Andrew Griffin and an AT&T phone number ending in 4885 associated with Aimy Chase. And these phone numbers also are highlighted in colors. The orange phone is the one that ends in 0229 and pink, purple, magenta is the phone number ending in 4885. And this is also from time period of September 18th to 21st, 2021.

Christopher Kinsler (01:53:45):

Page 17, what are we looking at here?

Bryan Lacy (01:53:51):

So if you look, we're looking at the activity of the phone ending in 0229, the orange phone in this case, from a period of 9-18, 8:27 p.m. to 9-19 at 3:11 p.m. Central Time. The yellow call-out box here is kind of hard to see in the middle of the screen. It's an address I was provided for Griffin, River Road in Whitesboro. Again, the blue dots are the cell sites in the area. And then if you'll look, starting with this call-out box here, you'll look at some cell site activity over on this cell site to the bottom right-hand corner of the screen. And the first activity there on 9-18 that we're calling out or that I'm showing is at 8:27 p.m. It's an incoming call, 458 seconds, from a phone number that we're going to look at later that's associated with Stacey Griffin.

Christopher Kinsler (01:54:59):

Okay.

Bryan Lacy (01:54:59):

And then you can see the cell tower it's using out in the general area of Muse or Whitesboro area.

Christopher Kinsler (01:55:08):

When you're looking at this cell tower that's displayed to the right, am I correct in thinking you have two different sectors illuminated there or two separate sectors demonstrated?

Bryan Lacy (01:55:18):

Yes. So there's two sectors illustrated here. So during this activity, some of the activity was off this sector pointing to the northwest and some of the activity was off this sector pointing to the northeast direction. I think a key thing to remember is these lines that are shown on a map, there's no lines drawn in the ground that says the cell tower signal ends right here. These are just showing the direction of the radio frequency signal. That doesn't necessarily indicate movement using different sectors. The phone could be right there in between, utilizing both sectors, depending on the signal strength at that given time. So I can't say one way or the other.

Christopher Kinsler (01:56:04):

So is it possible, even though if I'm understanding you correctly, you've illuminated this as a sector off to the east or northeast there. Is it possible the phone is outside those orange lines?

Bryan Lacy (01:56:17):

Yes, of course. Yes.

Christopher Kinsler (01:56:19):

Is it fair to say when we're talking about this, you're just getting general ID as a possible location of phone?

Bryan Lacy (01:56:24):

Yes. I just know the cell site and sector that the phone used and know a general area of a phone.

Christopher Kinsler (01:56:32):

Page 18, what are we looking at here?

Bryan Lacy (01:56:35):

So on the last slide, I left off with some activity up near... A cell site usage up near Talihina. So I'm starting this slide with that same activity. I'm sorry, 3:11 p.m. on the 19th, and I'm showing activity of the orange phone or the phone ending in 0229. I'm showing activity on that phone until 7:20 p.m. of Central Daylight Time. And basically what I'm showing here is travel of this phone.

(01:57:08)
So if you follow this diagram around and these cell towers that there's activity on, it's working in a clockwise motion there. Ending down with the last cell tower shown on this is a data transaction at 7:20 p.m. on the 19th. I think of note, there's an incoming call at 5:35 p.m. on the 19th and that call went to voicemail. It was unanswered, transferred to voicemail. I should point out to you that that purple call-out box down at the bottom of the screen there, that's an address I was provided for Cole in Hugo, Oklahoma.

Christopher Kinsler (01:58:00):

And so on this slide, all the activity that's registering every time this phone is connecting with the tower, is it true that it's data with the exception of this one incoming call?

Bryan Lacy (01:58:10):

That is correct, yes.

Christopher Kinsler (01:58:11):

And that one incoming call went to voicemail?

Bryan Lacy (01:58:13):

That is correct.

Christopher Kinsler (01:58:30):

Okay. And I'm just cycling back to the previous page, Page 17. On that one you've displayed on the September 18th, from 8:27 p.m. to September 19th at 3:11 p.m., these call boxes, there's actually several calls, both ingoing and outgoing and a number of those are answered; is that correct? Or number of incoming calls answered, and a number of outgoing calls.

Bryan Lacy (01:58:54):

Yeah, I guess I missed it too. On the 19th at 2: 09, the second-to-last line down there, there's an incoming call to the orange phone, the 0229 phone, that went to voicemail.

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