Opening statement: To put it simply, there is simply no credible evidence to establish the guilt

of Travis Mitchell beyond a reasonable doubt.

Witnesses Questions to ask

Crown witness 1: 1. What evidence did you find in the house of 1352 Juniper St?
Constable Drake 2. Are you certain that the shoes you found belong to the accused?
3. Are the shoes found a common pair?
a. Can the shoesprints be traced back to Mr. Mitchell in any
way?
4. Was the hair and fingerprints found the same as Mr. Mitchell’s
5. Did you find Ms. Sims’ calculator?
a. Is it a common calculator?
b. What brand of calculator is it?
6. Did you find Mrs. Sim’s missing purse?
a. Where was it located?

Crown witness 2 1. Are you certain that exhibit 6 is your wife’s calculator?
2. Is it a common type of calculator?
a. What brand?

Crown witness 3: 1. How did this investigation start?

a. What was claimed in the tip?
2. Is it unlawful to lie to Mr. Mitchell?
a. Did you lie to Mr. Mitchell during any procedures?
3. Did you know that Travis Mitchell is mentally handicapped from
the beginning of the investigation?
4. Did you coerce Mr. Mitchell into giving the evidence you were
looking for?
a. During your show and tell, after Mr. Mitchell could not
identify the proper house, did you point at the correct
house and ask him directly?

Crown witness 4: 1. Do you consider yourself to have proper training to estimate IQ?
2. What type of training do you have?
3. Do you have specific training in psychiatry?

Defense witness 1: 1. When did you give Mr. Mitchell the calculator?
2. What brand was the calculator?

Defense witness 2: 1. How would you describe Mr. Mitchell’s personality?

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 2. Would Mr. Mitchell agree to committing acts he did not?

Defence witness 3: 1. Did Mr. Mitchell talk about Sgt Haney at all?
2. Did Mr. Mitchell feel threatened by your comments during
discussions?
3. Did Mr. Mitchell claim innocence before the threats?

Evidences Weaknesses

Exhibit 6: - A very common calculator

Mrs. Sims calculator
- Mr. Sims could not be certain that the calculator belonged to his wife
- The calculator was found on the same school grounds as the purse
- Mrs. Couture can testify to giving Mr. Mitchell the calculator after
coming back from school, albeit an odd time to. However, the
calculators are not even the same brand.
- Correlation does not mean causation.

Exhibit 8: Shoes - Common type of running shoe, could not be traced to Mr. Mitchell
prints outside/inside - The size was only similar and not the right one, as backed up by
house Constable Drake’s statements.

Exhibit 9: Purse and - When asked where the bag and knife was thrown, Mr. Mitchell led
calculator Sgt. Haney to some arbitrary place, meaning he did not know where it
was thrown to begin with.
- Mr.Mitchell said he admitted things he did not do to get Sgt. Haney
off of him, it is reasonable to say that this evidence cannot be used as
well.
- The purse was found lying clearly visible on the sideway beside a
highschool, not thrown into a field.
- The calculator? Found on the school grounds as well. And far from
the bag, meaning it did not fall out of the purse.

Fingerprints and hair The fingerprint and hair found in the house of Cleo Sims did not match
Mr. Mitchell at all. Nor of Mr or Mrs Sims. Therefore this evidence
cannot be used either.

He’s “Cunning” How cunning can a man with an estimated IQ of 80 and a very
agreeable personality can be? Any reasonable person would say not
very, if at all.

1. The admission of guilt made by Travis Mitchell were not true but rather were things said
by a mentally handicapped young man hoping to obtain some relief from the insistent

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 questioning of overbearing and unfair police officer.s
○ The testimony of Dr. Berman and the evidence given by the undercover police
officer, Cst. Kake, supports this submission
○ Travis, according to Dr. Susan Berman, is very passive and dependent on
authoritative individuals. And, under interrogation, he would confess to things he
did not commit.
○ Dr. James Vinos estimates Mr. Mitchell's IQ to be around 80, implying that he
may fail to comprehend the breadth of the matter and is easily coaxed.
2. When Travis Mitchell was taken on a “show and tell” tour by Sgt. Haney, he was not able
to identify the house where Cleo Sims was murdered.
○ Sgt. Haney pointed to the house for Travis Mitchell, and Sgt. Haney did not point
to any other house first or multiple houses before or after the initial coercing.
3. His “confession” to Dr. James Vinos cannot be used as evidence for the following reason.
The questions took place very late at night, 11:30pm, after a long day of intense
interrogation with Sgt. Haney (from 10 am). Already a stressful day, this is no time for a
mentally handicapped man to be questioned further. Mr. Mitchell, like I've said before,
admitted to telling untrue facts and admissions to get Sgt. Haney off his back. This is no
different.

Closing Statement: To wrap this all up, this whole investigation started because of a tip from an
unknown person that Sgt Haney received. And in the tip it states Roland Mitchell is the murder,
not Travis Mitchell. What makes this tip credible in any way? Furthermore, the whole
investigation started over the shoes, calculator and purse. Which we already covered, have no
basis to stand on. This man is innocent and cannot be charged on grounds beyond a reasonable
doubt.

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