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Electronically Filed2/12/2021 3:41 PMSeventh Judicial District, Fremont CountyAbbie Mace, Clerk of the CourtBy: Eileen Parker, Deputy ClerkROB H. WOOD # 8229Madison County Prosecuting Attorneyrwood(%co. madison. id.us159 East Main StreetP. 0. Box 350Rexburg, Idaho 83440(208)356-7768(208) 356-7839IN THE DISTMCT COURT OF THE SEVENTH JUDICIAL DISTRICT OFTHE STATE OF IDAHO, IN AND FOR THE COUNTY OF FREMONTCase No. : CR22-20-0755STATE OF IDAHO,Case No. : CR22-20-0838Plaintiff,vs.LORINORENEVALLOW,AKA LORINORENEDAYBELL,RESPONSE TO DEFENDANT'S"DECLARED MOTION FOR ORDERDIRECTING ATTORNEY CLIENTPRIVILEGE COMMUNICATIONS"Defendant.The State of Idaho, by and through the Madison County Prosecutor's Office, acting as aspecial prosecutor in the above captioned case, hereby responds as follows:1. The StateofIdahohasno objectionto the Defendant'srequestto meet with Counsel inperson as long as proper Covid-19 safety precautions are followed. The State, however, does notsubstitute its ownjudgment for the MadisonCounty Jail in regards to what safety precautions arenecessary.2. The State objects to the Defendant'srequestthat security cameras in thejail be turnedoffduring visits but does agree that no audio recordings should be made by the Madison CountyJail of any such visits. The State has been informed by the jail that the security camera systemdoes not record audio. The State is further aware that a virtual box can be drawn around theDefendantand her Counsel so that security personnel monitoring security cameras cannot see theDefendant and her Attorney and any items on the table in front ofthem while they are meeting.RESPONSE
3. The State objects to the Defendant'srequest for a cell-phone for the Defendant. IdahoCode 18-2510 lists cell-phones as a contraband item for individuals detained in a detention facility.a. Idaho Code 18-2510(5)(c)(iv) prohibits any "telecommunication equipment orcomponent hardware including, but not limited to, any device carried, worn or stored thatis designed or intended to receive or transmit verbal or written messages, access or storedata or connect electronically to the internet or any other electronic device that allowscommunications in any form." A list of prohibited devices in said statute includes cellphones and laptops. The State is aware that the Defendants Lori Vallow Daybell and ChadDaybell both have access to laptops for the purpose of viewing Discovery. The Statebelieves that said laptops are not capable of transmitting messages and are not able toconnect to the internet and as such have been approved by the Madison and FremontCounty jails.b. The Defendant's Declared Motion for Order Directing Attorney ClientPrivilege Communications argues that the Defendant is being deprived of her SixthAmendment rights due to the Defendant being required to use Telmate to communicatetelephonically with Counsel. The Defendant already litigated these same facts at a bailreduction hearing on the Defendant's Amended Motion for Bond Reduction on or aboutMay 1, 2020 in Madison County Case No. 33-20-0302. It should be noted that theDefendant provided this Court with the State's responses to the Defendant's initial bailreduction Motion and Amended Motion in that case but did not provide her own initialMotion and Amended Motion. (The State has attached the Defendant's Amended Motionand Counsel's Declaration in Support of Defendant's Amended Motion for BondReduction as State's Exhibit's 1 and 2. The State has also attached affidavits of LieutenantRon Ball and Lieutenant Jared Willmore as exhibits 3 and 4, which were both introducedwhen this matter was first litigated. ) That Motion was denied due to the fact that theDefense provided no evidence that protected and privileged communications of theDefendant and her attorney were being recorded. The State respectfully requests that theCourt take judicial notice of the Madison County Magistrate Court's decision on theDefendant's Amended Motion for Bond Reduction. The Defendant has provided no newevidence that she and her legal counsel are unable to have confidential telephoniccommunications via Telmate.RESPONSE
c. Not only is the Defendantattempting to relitigate facts previously decidedbythe Court, she is also litigating those same facts through social media. On or about February5th, 2020, Mark Means, Counsel for Lori Daybell, published a series of "tweets" on thesocial media app "Twitter" in which he reasserts the false claim that the State is or haswrongfully recorded attomey/client conversations. Two of these tweets are attached asexhibit 5. Doubling down on claims already denied by the Court on social media onlyserves to create more pre-trial publicity.d. Every other inmate in the MadisonCounty Jail is required to use the Telmatesystem for telephonic communication with their legal counsel. The Defendant hasprovided no evidence or information justifying special cellphone privileges for theDefendant. The State is aware of no other inmate that has filed a motion requesting a cellphone due to the required use ofTelmate. The State is aware of no other claims by anyother defendant/inmate that their right to counsel is violated by the use of Telmate.e. In Footnote 8 on page 3 of the Defense's current Motion, the Defense states:i. "shortly after the initial bond hearing in this Madison County Case CR33-20-0302,Prosecutordisclosedto Counselthat one of theprivilege(d) communications between Counsel and Defendant wasaccessedby someonein hisofficebut waspromptly deleted. " (emphasisadded.)f. The State agrees that the State informed Defense Counsel that a phone callbetween Defendant and her attorney on March 7, 2020, was recorded by Telmate and washeardon the Telmate system by the Prosecutor'sOfficeon May 9, 2020. The State furtherinformed Defense Counsel that the Prosecutor's Office turned off the recording as soon asit realized it was a conversation between the Defendant and her Counsel. The Stateimmediately informed the Madison County Jail that the recording had been made andinformed the Jail that the phone number of Defendant's Counsel needed to be blocked.This is supported by State's Exhibit 6, a call log from the Madison County Jail. (Defensecounsel themselves usually inform a jail of their phone number so that attomey/clientphone calls will be protected. ) The State has redacted Counsel's phone number forpurposes ofthis response. Exhibit 6 is bates-stamped as it has been provided to the Defensein discovery. Despite the Defendant's assertion, said phone call was in no way privilegedRESPONSE
as the Defendant and Counsel were both informed at the beginning ofthe phone call that itwas being recorded and they chose to proceed with the call knowing it was being recorded.Further, Counsel for the Defendant had not taken the precaution ofinforming thejail ofhisphonenumberso thatthey could speakconfidentially. (Pleasesee UnitedSlatesv. Gann, 732F.2d 714 and United States v. Mejia, 655 F. 3d 126, both of which are further discussed inthe State's Second Objection to Defendant's Declared Motion for Bond Reduction inMadisonCounty Case CR33-20-0302.)DATED this/2 dayofFebruary, 2021.Rob H. oodSpecial ProsecutingAttorney for Fremont CountyRESPONSE
CERTIFICATEI HEREBY CERTIFY that on this IV day of February, 2021, that a copy of theforegoing RESPONSE TO DEFENDANT'S "DECLARED MOTION FOR S" was hand delivered,emailed, faxedor mailed to the followingparty as indicated:John PrioriohnfSjipriorIaw.comDU. S. MailDHand DeliveredDCourthouse BoxDFacsimile:File & ServeMark L. Meansmlm(S), means-law. comDEmailDU. S. MailDHand DeliveredDCourthouse BoxDFacsimile:File & ServeDEmailBy: y' / / 6 -RESPONSE
Electronically Filed4/2/2020 1:53 PMSeventh Judicial District, Madi on CountyKim Muir, Clerk of the CourtBy: Angie Wood, Deputy Cleric1Mark L Means (ISB 7530)2MEANS LAW and MEDIATIONMEANS LAW OFFICE, PLLC429 SW 5th Ave. Suite 1103Meridian, ID 83642Telephone: 208. 794. 31114Facsimile: 1. 866. 228. 34295Email: mlmfSmeans-law. comWebsite: www. means-law. comInstagram: lawvermark426Attorney for LORI NORENEVALLOW(AKA DAYBELL)7IN THE DISTRICT COURT OF THE SEVENTH JUDICIAL DISTRICT OFTHE STATE OF IDAHO, IN AND FOR THE COUNTV OF MADISON89Case No: CR 33-20-0302STATE OF IDAHO,10PLAINTIFF11Vs.AMENDED MOTION FOR BOND REDUCTION1213LORI NORENE VALLOW,AKA LORI NORENE DAYBELLDEFENDANT141516COMES NOW DEFENDANT, Mrs. Lori Vallow (Daybell), by and through her Attorney ofRecord, Mark L. Means of Means Law and Mediation and hereby move this Court pursuant to17Idaho Title 19 Criminal Procedure, Chapter 29 Idaho Bail Act, including 19-2903, 19-2904, 19182912, Idaho Criminal Rule 46, relevant Idaho case law/precedent, the Constitution for the1920United States of America as well as due process rights, and the like, for a reduction in bond.Defendant, by and though her Attorney of Record, asserts new facts have come to light21to support this motion since the previous motion bond hearing. Furthermore, this Declared22Motion is supported by a brief declaration filled concurrently with this Motion.23The Defendant respectfully requests oral argument on this motion before the24Honorable Judge Mallard.25That I Certify (or Declare) under penalty of perjury pursuant to the Law of the State ofIdaho that the foregoing is true and correct.26AMENDED MOTION FOR BOND REDUCTION - PG. 1STATE'SEXHIBITI
DATED thisDATED2day of AprilApril 2020.2020.daywLW%Z-7 2AW L, MeansMeansMr. Mark L.9101112121314l4151617181920212223242526AMENDED MOTIONMOTION FORFOR BONDBOND REDUCTIONREDUCTION -- PGPG. . 22AMENDED
CERTIFICATE OF SERVICEThe undersigned certifies that on thisday of April 2020, 1 caused a trueand correct copy of the FOREGOINGdocument to be forwarded by the method(s) indicatedbelow, to the following:MADISON COUNn PROSECUTING OFFICE159 E. Main St.P. O. Box 350Rexburg, ID 83440EfileEmail: rwood@lco. madison. id. us91011DATED thisday of April 2020.By%Z-% 2 Mr. Mark L. Means121314151617181920212223242526AMENDED MOTION FOR BOND REDUCTION - PG. 3
ElectronicallyFiled4/2/2020 1:53 PMSeventh Judicial District, Madi on CountyKim Muir, Clerk of the CourtBy: Angie Wood, Deputy Clert123Mark L. Means (ISB 7530)MEANS LAW and MEDIATIONMEANS LAW OFFICE, PLLC429 SW 5th Ave. Suite 110Meridian, ID 83642Telephone: 208. 794. 311145Facsimile: 1. 866. 228. 3429Email: mlmOmeans-jaw. comWebsite: www. means-law. comInstagram: lawvermark426Attorney for LORI NORENEVALLOW(AKA DAYBELL)7IN THE DISTRICT COURT OF THE SEVENTH JUDICIAL DISTRICT OFTHE STATE OF IDAHO, IN AND FOR THE COUNTY OF MADISON89STATE OF IDAHO,10PLAINTIFF11Vs.Case No: CR 33-20-0302DECLARATION IN SUPPORT OFDEFENDANT'S AMENDED MOTION FORBOND REDUCTION1213LORI NORENE VALLOW,AKA LORI NORENE DAYBELLDEFENDANT141516COMES NOW DEFENDANT, Mrs. Lori Vallow (Daybell), by and through her Attorney of17Record, Mark L. Means of Means Law and Mediation hereby declare in support of her Motion for18Amended Motion for Bond Reduction asfollows: Attorney Mark L. Means, beingfirst duly sworn upon oath,1920deposes, declares and says as follows:1.I am the Attorney of Record for the Defendant Mrs. Lori Vallow (Daybell).212. That on or about or about 3/24/20 I caused to be filed with this Court her Declared Motion22for Bond Reduction. To date no response/objection has been filed with the Court and despites23request for an oral in court hearing on the above motion, no notice of availability of the Court242526to hear such has been provided.3. That on or about 3/16/20 my office received approximately 1600 pages documents/recordsas well as approximately 14. 6 gigabytes of videos, photographs, electronic/intangibleAMENDED MOTION FOR BOND REDUCTION - PG. 1
123production and the like from the Madison County Prosecutor's office.It is reasonableanticipated that future production of documents, records, tangible/intangible records will beproduced to Defendant as acquired by the Prosecution totaling over 200 gigabytes/10,000 4pages of tangible records, etc.54. That on or about 3/30/20 I travelled to the Madison County Female Detention Center to meet6with my client in preparation for the forthcoming preliminary hearing and to review said7documents/records.895. That upon arriving at said Detention Center, I was required, with no attorney/client option,10to the sole option of communicating with my client in the public visitor meeting room, wall of11glass between attorney and client, over a recorded telephone line, upon which my client was12required to enter her inmate number for charges and consent to recording of said phone call1314prior to connection of the telephone lines. In addition, that I was told that the ONLY way thatmy client could review documents was to pass possibly sensitive documents/records by and15through a Detention Center Officer from the public (my side) room ". round and about."16through multiple security doors to the inmate (client's side). All of which would be out of17sight of the Attorney and Client.1819206. This procedure is unreasonable and En direct violation of the Regulations, Law andConstitution of the State of Idaho and the United States of America.217. This Detention Center procedure/unlawful restrictions have made it impossible to prepare for22said hearings, to communicate with my client in a confidential/privileged manner, and to23simple review productions of documents/records with my client to assist in her defense of24the pending charges/criminal complaint.258. That these unlawful restrictions, as well as no hearing allowed to date, on the previously filed26Motion to Reduce Bond, are in violation of my client's basic due process rights specifically butAMENDED MOTION FOR BOND REDUCTION - PG. 2
1not limited to: (1) defendant's rights to effective assistance counsel; (2) Idaho Rules of2Criminal Procedure; (3) Constitution of the State of Idaho; (4) Attorney Client Privilege; (5)3Code of Federal Regulations Title 28 Judicial administration. Chapter V Bureau of Prisons,4Department of Justice; (6) as well as violations of the Constitution of the United States5included but not limited to: Amendment V, VI, VIII, and IX.6Again, we respectfully request oral argument on this motion before the Honorable Judge789Mallard.That I Certify (or Declare) under penalty of perjury pursuant to the Law of the State ofIdaho that the foregoing is true and correct.10111213DATED this2day of April 2020. &tKtMr. Mark L. Means14151617181920212223242526AMENDED MOTION FOR BOND REDUCTION - PG. 3
CERTIFICATEOF SERVICEThe undersigned certifies that on thisday of April 2020, 1 caused a trueand correct copy of the FOREGOING document to be forwarded by the method(s) indicatedbelow, to the following:EfileMADISON COUNT)' PROSECUTING OFFICE159 E. Main St.P. O. Box 350Rexburg, ID 83440Email: rwood@lco. madison. id. us91011DATED thisday of April 2020.By%'Z-X Mr. Mark L. Means121314151617181920212223242526AMENDED MOTION FOR BOND REDUCTION - PG. 4
Electronically Filed4/30/20202:42 PMSeventh Judicial District, MadisonCountyKim Muir, Clerk of the CourtROB H. WOOD # 8229Madison County Prosecuting AttorneyBy: Angie Wood, Deputy Clerknvuodfu cD. iiiatlison. Kj. us159 East Main StreetP. 0. Box 350Rexburg, Idaho 83440Telephone: (208) 356-7768Facsimile: (208) 356-7839IN THE DISTRICT COURT OF THE SEVENTH JUDICIAL DISTRICT OFTHE STATE OF IDAHO, IN AND FOR THE COUNTY OF MADISONMAGISTRATE DIVISIONSTATE OF IDAHO,Plaintiff,CaseNo. :CR33-20-0302V.LORI NORENE VALLOW, AKA LORINORENE DAYBELL.AFFIDAVIT OF Lt. RON BALLDefendant.STATE OF IDAHO ):ssCounty of Madison )I, Lt. Ron Ball ofthe RexburgPoliceDepartment,being first duly swom underoath,deposes and states as follows:1.The information contained herein is true and correct to the best of my knowledgeand belief.2.3.I am the Lieutenantofthe RexburgPolice Department Detective's Division.On or about March 31"or April 1s', 2020, 1 was listening to jail phone calls of theabove named defendant.4.5.AFFIDAVITI began listening to a phone call made on March 31s'. The phone call was betweenthe defendant and a male whose voice I did not recognize. The conversation veryquickly turned to the status of court hearings and that the male speaker had someinterviewslined up. Themalevoice thensaidsomethingto theeffectof"I can'ttalkabout it right now becausethey're listening."Once I heard the statement "they're listening, " and due to the statements regardingcourt hearings and interviews the male said he was going to conduct, I becamey STATE'SIPage1 of 2
concerned tliat this conversation was between the defendant and her attorney. 1quickly hit "stop" on the Telmate playback software and ceased listening to the call.6.7.Very soon after hearing the phone call I discussed it with Special Agent Ricky Wrightof the FBI and concluded that I should call the jail.I called the jail and spoke with Lt. Jared Willmore aiid infonned him that a callbetween the defendant and her attorney had been recorded.Further your affiant sayeth naught. RESPECTFULLYSUBMITTEDthis ' 0 dayofApril,2020.LJLt. Ron BallRexburg Police DepartmentDetective's DivisionSUBSCRIBED AND SWORN to before me this 5G day ofApril, 2020. 5 \ Z z2/ ' !otary pubiicf Y \:*" . If.': - AFFIDAVITiotary Public--.Residing at: RexburgMyCommission Expires: /l li/l Page 2 of 2
Electronically Filed4/30/2020 2:42 PMSeventh Judicial District, Madison CountyROB H. WOOD # 8229Kim Muir, Clerk of the CourtBy: Angie Wood, DeputyClerkMadisonCounty ProsecutingAttorneyrwoodfucu. madison. id. us159 East Main StreetP. 0. Box 350Rexburg, Idaho 83440Telephone: (208) 356-7768Facsimile: (208) 356-7839IN THE DISTRICT COURT OF THE SEVENTH JUDICIAL DISTRICT OFTHE STATE OF IDAHO, IN AND FOR THE COUNTY OF MADISONMAGISTRATE DIVISIONSTATE OF IDAHO,Plaintiff,Case No. : CR33-20-0302V.LORI NORENE VALLOW, AKA LORINORENE DAYBELL,AFFIDAVIT OF Lt. JARED S.WILLMOREDefendant.STATEOF IDAHO ):ssCounty of Madison )I, Ll. JARED S. WILLMORE, ofthe Madison County Sheriffs Office, being first dulysworn under oath, deposes aiid states as follows:1.The information contained herein is true and correct to the best of my knowledgeand belief.2.I am the Lieutenant charged with supervision over the Madison County Detention3.On March 5 , 2020, in response to phonecalls I hadreceived from defenseCenter. I have been in this current supervisor)' role since December of 2016.counsel in the above-captioned case, I sent defense counsel the following textmessage: "This is LT. Willmore. Just so you have it, the jail number is 208-372-5002. You can schedulemeetings with the Control operator. Feel free to call meas well with any questions."4.On March 20"', 2020, the Detention Centerrestricted the Detention Center toEssential Personnel only due to concerns over Covid-19and in responseto CDCguidelines for correctional facilities.5.AFFIDAVITOn March 25' , 2020, Governor Little announced a state-wide stay-at-home order.Page 1 of 4
On March 30'h, 2020 and March 3 la, 2020, defense counsel, Mark Means, visitedhis client, Lori Vallow, in the Madison County Female Detention Center. Defensecounsel did not notify the Detention Center either time that hewas coming. TheDetention Center does not require defense counsel to set an appointment.However, due to the Covid-19 safety protocols put in place, the Detention Centerhad no advanced noticeto preparefor an in-person meetingbetweendefensecounsel and their client.7.Due to the CDC guidelines and the Governor's stay-at-homeorder, the vastmajority ofall attomey/client meetings have been telcphonic, Pursuant toMadison County policy and procedures, none of these conversations have beenrecorded.8.9.On March 30"', defense counsel for the defendant came to the Detention Centerand asked to visit his client. He initially met with Corporal Ryan Walker andasked if he could meet with his client face-to-face. Corporal Walker informedMr. Means that he could meet with his client in the public visitor room due toprecautionary measures the Detention Center was taking to prevent the spread ofCovid-19 to inmates and Detention Center workers. Corporal Walker alsoinformed Mr. Means that he would check to see if the phones ill the visitor centercould have the recording function turned off.Corporal Walker contacted Sgt. Mark Backstein, who also works at the DetentionCenter, and asked if the recording ofphone calls in the public visitor center couldbe turned off.10.Sgt. Backstein called me and inquired about turning off the recording of phoneconversations in the public visitor center.11.12.13.I informed Sgt. Backstein that the recording could be turned off, and I thenproceeded to turn the recordingofffor the period of24 hours.Corporal Walker informed defense counsel that the recording had been turned offon both phones in the public visiting center.Defensecounsel then had a conversation with the Defendantin thepublic visitorcenter on a phone. That call was not recorded.14.While that call was not recorded, I have reviewed call logs ofMarch 30"' and cansee that the call was made. I have attached a copy of that call log as "Exhibit A" tothis affidavit.15.On March 31", defense counsel for the Defendant again came to the DetentionCenter and asked to meet with his client. On this date, he initially met withDeputyPam Hollist and informed her that he had paperworkhe needed to havehis client sign. Deputy Hollist took the paperwork from defense counsel in thelobby and took it to the Defendant in the public visitor center, where theDefendant sigiied the paperwork. Deputy Hollist then returned the paperwork todefensecounsel in the lobby. At that time, defensecounsel informed DeputyHollisl that lie needed to speak with his client. Deputy Hollist allowed him toeiiter the visitor center to speak with the Defendant on the phone.AFFIDAVITPage 2 of 4
16.17.Defense counsel never asked Deputy Hollist to turn off the recording software.Defense counsel had two phone calls with the Defendant. Both phone calls wouldhave given the standard Telmate warning that the phone calls were subject tomonitoring and recording. It should be noted that the call on March 30"' would18.not have played the warning that the call was subject to monitoring and recordingbecausethat warningis not played when phone calls are not recorded.At no time during those phone calls did defense counsel ask Deputy Hollist, orany other Detention Center personnel, to turn offthe recording program as it hadbeen turned off on March 30 .19.Defensecounsel's visits on March 30thand March31"areboth documented byjail security footage. Defensecounsel can be seen takingpictures insidetheDetention Center on March 3 1s. The Detention Center rules are posted at theentranceto the visiting room. It is clearly posted that no picture takingis allowed.The no picture takingrule is in placeto provide security for the inmates andworkers of the Detention Center.20.Defense counsel's visits are further documented by the Defendant's "out of cell"log, which I have attached to this affidavit as Exhibit "B."21.The Detention Center wasnot immediatelyawarethat the phonecalls betweendefense counsel and the defendant were recorded.22.I learned thataMarch 31jail phonecallwasrecordedoneither March 31S IorApril 1stwhen I wascontacted by Lt. Ron Ball ofthe RexburgPolice Department.He informed me that as he was listening to jail phone calls he started listening to acall that he thought could be between the defendant and an attorney. He informedme that once he realized it may be an attomey/client conversation he stoppedlistening and called me to provide that information.23.OnceI received that information from Lt. Ball, I reviewedthe call logs and foundthe two phonecalls made on March 31s'. The first call took place at 14:53 andlasted one minute. The second call took placeat 14:55 and lasted 28 minutes. Iimmediately found it strange that the calls had been recorded because I had turnedoffthe recording on March 30th specifically for the same defendant and herattorney. I also found it strangebecause1 knew her attorney wasawaretherecording could be turned off in the visitor center. I called Telmate and informedthem that the 28 minute phone call needed to be removed from our records. I donot have the ability to delete phone calls. Due to what I perceived to be strangecircumstancesregardingthe recordingofthe calls, 1 purposefully left the 1 minutephone call on our records for evidence that those phone calls started with the24.standard warningthat the call wassubject to monitoringand recording.After I called Telmatc, I sliut down the recording in the visitor center for a periodof 365 days to insure that, in the event of any attomey/client visit, no other phonecalls would be recorded. Telmate tracks when the recording is turned off in thevisitor center for both phones in the female visitation center. 1 have attached thoseAFFIDAVITPage 3 of 4
records to this affidavit as Exhibits "C" and "D". These logs also shows that Iherecording for both phones wasturned offon March 30 . 2020.Further your aft'iant sayeth naught.RESPECTFULLY SUBMITTED this 'S&' dayofApril. 2020.i )C' C4 .Lt. 7ared Will moreSUBSCRIBEDAND SWORNto before me this B dayofApril, 2020. S5 f S ? / -SB,» ':' isq . xp 1. 4.:-Sul. '-. -o ' "'" . s /\ y /- /T W Notary PublicResiding at: RexburgMy Commission Expires: / Lf / 2 2 AFFIDAVITPage 4 of 4
https://www. intetmate. net/report/activity4/30/2020Report: Call Details - Vallow, Lori nStarting: 03/29/2020 08:31 Ending: 04/01/2020 08:3)Customize columns.IdInmate Destination Fid GroupPhoneDateTermination Minutes Area27808466233 w' 212- 3327804461933llow- 000-.000yaLori n 00001785Vallow, 000-000Lori n 00001785Vallow, 480-939Lori n 9475Vallow, 480-939Lori n9475Vallow, 808-212Lori n672127804217933va"ow'480:635Lorin 24012780239520327801745773yal'ow-00 00Lori n 0000Vallow, 808-212Lorin 6721Vallow, 808-212-27800377613 ' 27800289223 yauow'80 12Lori nPod1 ph1 /202 noanswer 228VK sTt tn 9729389327797208823Lori n6721Vallow,Lori nht43s;//www. intelmate. net/report/actjvityInterstateno answer2Interstateno ate30InterstatePod1 ph1 30InterstatePod1 ph1 /202 Podlphl! 2020Podlphlo 030Interstate30Interstate03/31/20201785 Pod 1Podlphl ' :0103/31/20201785Pod1 Podlphl /20201785Pod1 Pod1 ph1 0 /202 Female1785 Pod 11785Pod16721Vallow, 808-212-1Podlphl ' 1785Pod1Vallow, 808-212.278000746031785Pod1Lori n 6721Vallow, 808-212277998572131785Pod127798798043 :- l212' '785POC"Lori n03/31/202014:531785Pod1T-onInterstateph 1phi17S5InterstateFemalevSonphiT)2 14:1603/30/2020Pod 1 ph 1 'pg03/29/2020Pod 1 phi Q03/29/20201785Pod 1Podlphlpg '1785Pod 1Pod 1 ph 1 Qc '"""" incomplete 1Local
Inmate Out of Cell LogMadison Co IDDates:Cv:urOu'J'30. 2020 . 3. '31 2020[/fCt:'il T.J,J Scjn"PyaL rnunTiiL-l Scad .".' . - tt indtD CdfO Sci inIiNu;i !i.T fNo';iu . js sf.iiir-t.-nNS F. 'ofji:y C . nT»itinaPupuladon i \'. 's i,'*/(.lk)s. te E"tr /'2'W} Ot.'Oi'iUARtl'Ar-; Wl) . - . ;. . . ', : . ", rl MU.\; LI . ' \ !-1 t.li; . ; U l"( ., 'r'n;.rj-ili. i. k P. i'cfil pF O'i't tif!i" .: ;J*t?[]l'. [:i !:i)ifi i(l. ';l;UsSTATE'S5EXHIBIT
4/30/2020https://www.intelmate.net/report/audit list/170135?act type STAReport: User Activity AuditFemale Visitation ph 2 / 750,IdDateSubjectAction NoteUser[Female Visitation ph 2 / 750, 1 . Turn off recording265839203"-" Station 7oi35 Update from 2020-03-30 20:13:00 UTCto 2021-03-3120:13:OOUTC];-":.,Willmare[Female Visitation ph 2 / 750. I . Turn off recording126542591314:13Station 7oi35 Update from 2020-03-30 20:13:00 UTC to 2020-03-31 ,1,;;,Willmore20:13:00 UTC]STATE'SEXHIBITLLhttps://www. inte)mate. net/report/audit tist/170135?act type STA
https://www.intelmate. net/report/audit l»st/170145?act type STA4/30/2020Report: User Activity AuditFemale Visitation ph 1 / 750, 2IdDateSubjectAction NoteUser[Female Visitation ph 1 / 750, 2 Turn offrecording 126583917313:37Station[70145 Update from 2020-03-3020:13:00UTC to 2021-03-3120:13:OOUTC][Female Visitation ph 1 / 750, 2. Turn offrecording1265425903 ' '.14:13 u Stalion o Update from 2020-03-30 20:13:00UTC to 2020-03-3120:13:00UTC]https://www. in1elmate. net/report/audiUisfcF170145?actJype STAy};,Willmorew'illmore
ivicti n. iv i cca i 10 i-uvv "ivicai 10. TI iWhen attorney clientcommunications are or wererecorded, when attorney is deniedaccess to meet with his client formonths (is the current case inMadison County, never the case inFremont) when witnesses arecoached on what they want tohear. one must ask their self.Q 17U?091 Mark Means Law @Means. -4h .Finally, one must ask yourself, whenthe defense has to fight for theproduction of evidence, when list ofwitnesses for the state is produceda year or so after charges are filed,when attorney clientcommunications are or werewrongfully recorded,QeusQQ?
5/4/2020https://www. inte[mate. net/report/activityReport: Call Details - FacilityStarting:01/01/2020 15:39 Ending:05/04/2020 15:39 Destinations matching: {"0" "20879431I1"}Customize columns.IdInmate Destination Group Phone Date27704959463 Vallow,Lorin2770214753327702111603"ow'yaLorinya llow'n27702087663llow.yaLori nPod 1Termination Minutes End timePod 1 03/07/2020ph 1115:4303/07/2020Destination notesProsecutor Wood advised thiswas an Attorney number.3/9/20 @16:28Prosecutor Wood advised thisPod 1 03/06/2020pot" ph"l' 20:29" " " """iwer03/06/2020was an Attorney number.20:313/9/20 @16:28Prosecutor Wood advised thisPod I 03/06/2020podl phi' 20:23'"""" answer 3was an ATtomev numder.3/9/20 @ 16:28Prosecutor Wood advised thisPod 1 03/06/2020podl ph"l' 2o:lT"""n answCT 3was an Attorney number.3/9/20 @16:28STATE'SEXHIBIThttps://www.intelmate. net/report/activityjzVallow/Daybell0051551/1
COMES NOW DEFENDANT, Mrs. Lori Vallow (Daybell), by and through her Attorney of Record, Mark L. Means of Means Law and Mediation and hereby move this Court pursuant to Idaho Title 19 Criminal Procedure, Chapter 29 Idaho Bail Act, including 19-2903, 19-2904, 19-
