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2019 Federal TrialtranscripttranscriptChristopher Mills — Direct/Cross - Day 20 - 2019 Federal TrialFBI Special Agent Christopher Mills described evidence collected at 8 Hale Drive and answered defense questions about the devices and conditions at the search.
Tanya HajjarTeny Rose GeragosPaul DerOhannesian IINicholas G. GaraufisChristopher MillsMS. HAJJARCourt ClerkChristopher MillsTHE COURTMS. GERAGOSMR. DerOHANNESIANdirectcross
9 pages·3 witnesses·3,011 lines
Nicole completed testimony amid disputes over contemporaneous messages and their admissibility. An FBI agent described evidence seized at 8 Hale Drive, and Jay began testifying about recruitment, collateral, and contact with Raniere.
← Day 19Day 21 →
DirectDirectChristopher Mills — Direct Christopher Mills Tanya Hajjar

MS. HAJJAR: The Government calls Christopher Mills.

(The witness takes the stand.)

COURT CLERK: Please raise your right hand.

Do you solemnly swear the testimony you shall give to the Court will be the truth, the whole truth, and nothing but the truth, so help you God?

COURT CLERK: Please have a seat and please state and spell your full name for the record.

CHRISTOPHER MILLS: My name is Christopher Mills. First name C-H-R-I-S-T-O-P-H-E-R, last name M-I-L-L-S.

THE COURT: All right, you may inquire.

MS. HAJJAR: Thank you, Your Honor.

(Continued on the following page.)

C H R I S T O P H E R M I L L S, called as a witness by the Government, having been first duly sworn/affirmed by the Courtroom Deputy, was examined and testified under oath as follows:

DIRECT EXAMINATION BY MS. HAJJAR

MS. HAJJAR: Good afternoon, Agent Mills.

CHRISTOPHER MILLS: Good afternoon.

MS. HAJJAR: Where do you work?

CHRISTOPHER MILLS: I currently work at the FBI in New York City.

MS. HAJJAR: And are you a Special Agent?

MS. HAJJAR: How long have you been a Special Agent with the FBI?

CHRISTOPHER MILLS: About three years.

MS. HAJJAR: Are you currently assigned to a particular squad?

CHRISTOPHER MILLS: Yes. I am on a squad known as C-2; like I said, in the New York office.

MS. HAJJAR: Are you familiar with a criminal investigation into Keith Raniere?

MS. HAJJAR: When did you first become involved in that investigation?

CHRISTOPHER MILLS: I first became involved in -- towards the end of 2017 and roughly into the beginning of 2018.

MS. HAJJAR: And what types of investigative steps have you taken as part of this investigation?

CHRISTOPHER MILLS: I have assisted with the delivery of subpoenas to various individuals, as well as participation in a search and an arrest.

MS. HAJJAR: Drawing your attention to March 27th, 2018, were you involved in executing a search warrant on a property?

MS. HAJJAR: Where was that?

CHRISTOPHER MILLS: That was 8 Hale Drive in Halfmoon, New York.

MS. HAJJAR: And, Agent Mills, can you just generally describe to the jury what the process is for conducting the search of a residence?

CHRISTOPHER MILLS: Sure. So, a search warrant that we conduct is generally carried out in -- in the morning. So usually around 6 or 7:00 a.m. We will arrive at the residence and, of course, confirm that we are at the proper residence at that time. After we approached the residence, we will then do what we call a knock-and-announce, in which we will attempt to find out if anyone is presently inside the residence, whether they're asleep or awake or what have you.

If we attempt to knock and announce again and no response is received, then we may have to force entry in a number of different ways. So if we do, then we will force entry due to no one being present and conduct a sweep or a check of the residence to ensure that no one is present. And once we've done that, make sure no one's there and everyone is safe, then we'll proceed with the search, itself, which would start with the taking of photos.

MS. HAJJAR: And is that the process that took place in the search of 8 Hale Drive that day?

MS. HAJJAR: Did you have a specific role in the execution of the search warrant at 8 Hale Drive?

CHRISTOPHER MILLS: Yes. So my role was, as being one of the agents present, I was to assist with evidence collection and documentation, as well as being responsible for the taking of the photos on that day.

MS. HAJJAR: What time did you get to 8 Hale that day?

CHRISTOPHER MILLS: It was approximately 7:00 a.m.

MS. HAJJAR: And was there a team with you?

CHRISTOPHER MILLS: There was a team, mostly comprised of agents from the New York office, as well as the Albany office.

MS. HAJJAR: And what happened after you arrived at 8 Hale Drive?

CHRISTOPHER MILLS: So as mentioned in the process, we arrived at the scene, the residence, and conducted the knock-and-announce. We did that a few times, communicating who we were and that we had a search warrant. And after waiting a reasonable amount of time, determined that no one was present at the residence and made forced entry.

MS. HAJJAR: Was anyone in the residence?

CHRISTOPHER MILLS: There was no one present.

MS. HAJJAR: What did you do in the course of executing the search warrant?

CHRISTOPHER MILLS: So as we entered the room or entered the residence, like I said, we want to make a sweep of the residence to make sure no one else is present. We didn't have any indication anyone was, but, of course, we want to still make sure for safety. And we checked out the first floor, as well as the second floor, and found that no one was home. And at that point we determined it to be acceptable to start the search at that point.

MS. HAJJAR: Approximately what time was the search completed?

CHRISTOPHER MILLS: We finished the search and left the residence around 12:30 p.m.

MS. HAJJAR: Can you describe the residence?

CHRISTOPHER MILLS: Sure. So, the residence was a two-story townhome. It was a small sidewalk that led to the front entrance. And after you entered the first floor, there would be a kitchen on your immediate left and if you continued to walk forward, you would enter immediately into the living room of the first floor, which had a large piano in the left corner, a couch on the right side, and a spiral staircase in the far corner. And there was also a small bathroom on the first floor.

If you proceeded to the staircase in the far corner and went upstairs, you'd be immediately -- immediately see a bathroom, which had a sauna in it. If you continued to move through the bathroom, the sauna would lead to a hot tub and a small living or seating space. And above this -- above the hot tub and the seating space was a lofted bed. And then along the walls of the second floor were white boards, which were near an office space that had computer desks and chairs.

MS. HAJJAR: Your Honor, can I show something to the witness for identification only?

THE COURT: Yes, you may.

BY MS. HAJJAR:

MS. HAJJAR: I am showing you, Agent Mills, what's marked for identification as Government Exhibit 501.

Do you recognize this exhibit?

MS. HAJJAR: What is it?

CHRISTOPHER MILLS: So, this is a sketch of the -- of the residence showing the first -- first and second floor, as well as the loft.

MS. HAJJAR: And does this diagram fairly and accurately depict the layout of 8 Hale Drive?

MS. HAJJAR: Your Honor, the Government offers Government Exhibit 501 into evidence?

MS. GERAGOS: May I just confer with Ms. Hajjar briefly, Your Honor?

THE COURT: Yes, you may.

(Pause.)

MS. GERAGOS: No objection.

THE COURT: All right, Government Exhibit 501 is received in evidence.

You may publish to the jury.

MS. HAJJAR: Thank you.

(Government's Exhibit 501 was received in evidence.)

(Exhibit published.)

BY MS. HAJJAR:

MS. HAJJAR: All right, Agent Mills, can you see this?

MS. HAJJAR: And so does this diagram depict the two floors of 8 Hale Drive and then the lofted area you described?

MS. HAJJAR: Can you show us where on Government Exhibit 501 you entered the residence?

MS. HAJJAR: You should be able to draw.

CHRISTOPHER MILLS: Yes. (Indicating) so just where the green line is, just to the left of the letter C would be the front door.

MS. HAJJAR: And where did you go from there, in terms of initiating the search?

CHRISTOPHER MILLS: So, we had a team that entered the residence. So, obviously, we keep moving in different spaces. You see the bathroom right away there on your right side (indicating.) We proceeded to move forward towards the open area here (indicating) with some agents moving towards the kitchen and some agents moving towards the living room (indicating.) And then once again, once we determined that the space is clear and no one else is present, then we would have made movements towards the spiral staircase in the corner.

MS. HAJJAR: Which led to the second floor, which is depicted to the right of that?

CHRISTOPHER MILLS: Right. So then the spiral staircase up here (indicating) in the top right corner of the second -- second floor sketch, which led then to this space (indicating), which is the second floor bathroom, which also contained the sauna. And then proceeding through there to the area which had the hot tub.

So the lofted bed was positioned above the hot tub, which is depicted in the third part of the sketch. And then finally from there moving into the hot tub and seating room area, which opened up into this space over here (indicating) which had the white boards and computer tables and desks.

MS. HAJJAR: That's the office?

CHRISTOPHER MILLS: That would be the office space.

MS. HAJJAR: Agent Mills, you testified that your role was, in part, to take photographs?

MS. HAJJAR: Can you explain that process to the jury and what the point of that is?

CHRISTOPHER MILLS: Sure. So the -- the photographs are taken at the very beginning of the process and we just refer to them as entry photographs. And we want to take photographs of the initial entry that we make to determine, of course, that we're at the right address and what the view of the entryway is.

We also want to assign a letter to each space or room of the residence. So you see the letters on this sketch here represent those spaces or those rooms in which we are taking the photos. So that way when we take the photos, we can identify which room or space they came from.

And as we move throughout the residence, we take photos of various items, different views of each room, as well as photos of each identified piece of evidence.

And then as we proceed from that, we would take exit photographs on the way out to show how we left the residence and what it was like when we left, basically.

MS. HAJJAR: Was there a written log that accompanied your photographs?

CHRISTOPHER MILLS: Yes, we always complete a -- a photo log every time we do a search.

(Continued on the following page.)

BY MS. HAJJAR: (Continuing.)

MS. HAJJAR: Did you complete the photo log in this case?

MS. HAJJAR: What about the written description that accompanied the log?

MS. HAJJAR: Can I show the witness something marked for identification, Your Honor?

THE COURT: All right.

BY MS. HAJJAR:

MS. HAJJAR: Agent Mils, I'm showing you what's been marked for identification as Exhibit 502. Do you recognize this exhibit?

MS. HAJJAR: What is it?

CHRISTOPHER MILLS: This is the photo log which identifies the photos by each number. It identifies the location where they were found -- where the photographs were taken, I should say.

MS. HAJJAR: The Government offers 502 into evidence.

MS. GERAGOS: No objection.

THE COURT: Government Exhibit 502 is received in evidence.

(Government Exhibit 502 received in evidence.)

(Exhibit published.)

BY MS. HAJJAR:

MS. HAJJAR: On the top, Agent Mills, does that reflect the date on which the photographs were taken?

CHRISTOPHER MILLS: Yes, March 27, 2018.

MS. HAJJAR: And this is the location, 8 Hale Drive Half Moon, New York?

MS. HAJJAR: Can you tell us what's going on here; the list of photo numbers and the description?

CHRISTOPHER MILLS: Sure. The photos and the far left column is the number which corresponds to the order in which they were taken and then "Description" is describing where the photos were taken. So, for example, number six was in room A. So that would indicate that that was a photo, of course, taken in Room A and the various descriptions are just helpful background for information on where the photos were taken.

MS. HAJJAR: And this exhibit has several pages of all the photographs that were taken?

MS. HAJJAR: Your Honor, may I show something else to the witness?

THE COURT: Go ahead.

MS. HAJJAR: Agent Mills, I'm showing you what's marked for identification as Government Exhibit 502-A. Do you recognize this disk?

MS. HAJJAR: And what is it?

CHRISTOPHER MILLS: This is the disk that contains all the photos.

MS. HAJJAR: Your Honor, the Government offers Government Exhibit 502-A.

MS. GERAGOS: No objection.

THE COURT: 502-A is received in evidence.

(Government Exhibit 502-A received in evidence.)

(Exhibit published.)

MS. HAJJAR: Agent Mills, have you identified a subset of photographs that you chose to show the jury?

MS. HAJJAR: And do these photographs depict the areas that were searched as well as the items that were covered as part of that search?

MS. HAJJAR: At this point we would like to switch the PowerPoint, Your Honor.

THE COURT: Is this in evidence?

MS. HAJJAR: It is. All the photographs are in evidence, Your Honor.

THE COURT: All right.

(Exhibit published.)

BY MS. HAJJAR:

MS. HAJJAR: Agent Mills, I'm showing you Government Exhibit 502-A-1. Is this the first photograph that you took?

MS. HAJJAR: Could you describe what it depicts?

CHRISTOPHER MILLS: This is the photo log which is completed every time we conduct a search and in this one it's identifying the date, March 27, 2018, with myself listed as the photographer and the location, 8 Hale Drive, Half Moon, New York.

MS. HAJJAR: And then the second photograph, is this entrance to 8 Hale Drive?

CHRISTOPHER MILLS: Yes. And that's what the address 8 depicted above the entryway is.

MS. HAJJAR: And turning to the next, 502-A-3, is this what the property looked like when you opened the door, when you entered?

MS. HAJJAR: Turning to 502-A-5, can you explain what the A is?

CHRISTOPHER MILLS: Sure. So the A represents -- in this case it's the kitchen. So the A represents the first space or room that we came across entering the residence and it's just labeled for the sake of organization.

THE COURT: So you placed that label on the wall, is that it?

THE COURT: Go ahead.

BY MS. HAJJAR:

MS. HAJJAR: Is that the same area that was depicted in the sketch that we looked at a moment ago?

CHRISTOPHER MILLS: Yes. The photos would correspond to the sketch with the appropriate layout.

MS. HAJJAR: Okay. Turning to the next slides, 502-A-6 and A-7, are those photographs depicting 8 Hale Drive from the kitchen?

MS. HAJJAR: And that spiral staircase at the far end of the residence, is that the spiral staircase you described earlier, Agent Mills?

MS. HAJJAR: And turning to 502-A-10, what -- where was this photograph taken, what does it depict?

CHRISTOPHER MILLS: So this was taken in the far right corner of the first floor living space. So this is basically the view from standing right next to the spiral staircase and this is looking into the other corner of the room as well as the far corner of the room where the kitchen was and there's a large piano in that corner.

MS. HAJJAR: What's on the piano?

CHRISTOPHER MILLS: I believe it was mothballs. There was a tarp originally on top of the piano and when we removed it just to make sure no one else was present, there appeared to be a large number of mothballs present.

MS. HAJJAR: And then turning to 502-A-12, is this the spiral staircase at the end?

MS. HAJJAR: That leads to the second floor?

MS. HAJJAR: Agent Mills, looking at 502-A-20, what does that photograph show?

CHRISTOPHER MILLS: So, this is the second floor of the residence and that is the hot tub and then the background of the photo looking farther into the picture is the sauna.

MS. HAJJAR: And the hot tub is covered with boxes it looks like? It was covered up at the time you arrived at the property?

CHRISTOPHER MILLS: Right, so there was a cover on it as well as several boxes and other items on top of that.

MS. HAJJAR: Now, turning to Government Exhibit 502-A-24, can you describe what this photograph depicts?

CHRISTOPHER MILLS: Sure. So this is the second floor. This is the office space so you can see the white board on the right along with -- a long desk or table and several computers and computer chairs.

MS. HAJJAR: And is this the white board as it appeared to you at the time?

MS. HAJJAR: Can you describe, did you notice anything about what's written on the white board?

CHRISTOPHER MILLS: There's some items on the white board that seemed to be drawings or depictions of what was currently located inside the residence on the second floor. So, for example, the drawing on the middle right there, the refrigerator, microwave and toaster was also found -- that exact setup was found in the residence as well, just on the other side of the room. And there were other various written things with math equations and just various words and letters.

MS. HAJJAR: And Agent Mills, again, this photograph was taken on March 27, 2018 when you entered the property?

MS. HAJJAR: Have you reviewed what's in evidence as Government Exhibit 175?

MS. HAJJAR: Okay. I'm going to turn back to a still from that, what's in evidence as Government Exhibit 175. And just turning to a still from that video clip, can you describe what's in the back of what's depicted on the white board in Joint Exhibit 175-A-1?

CHRISTOPHER MILLS: So, what's written on the white board in this photo here appears to be pretty much unchanged from the white board that was seen on March 27, 2018.

MS. HAJJAR: And do you see on the left -- on the left side of this exhibit above the monitor, there's a drive with a blue lit-up circle?

MS. HAJJAR: Can you indicate that on Government Exhibit 175-A-1?

CHRISTOPHER MILLS: (Indicating.)

MS. HAJJAR: And that is directly to the left of the drawings that you're describing on the white board?

MS. HAJJAR: And then turning back to Government Exhibit 502-A-26. 502-A-27 and 28, these are more photographs of the white board?

MS. HAJJAR: And this is on March 27, 2018?

MS. HAJJAR: What is -- turning to 502-A-30, what is -- and 31, what do these slides depict?

CHRISTOPHER MILLS: So this is the lofted bed which was led to by a set of stairs and the bed was above the hot tub.

MS. HAJJAR: Now, showing you Government Exhibit 502-A-32, can you describe what this photograph depicts?

CHRISTOPHER MILLS: Sure. So the there's a note there with the number one. So number one represents evidence item number one. So, in this case, this photo was taken underneath the desk or table and was assigned number one based on being the first evidence item that was found.

MS. HAJJAR: And what's the point of photographing where evidence is found?

CHRISTOPHER MILLS: So we want to photograph -- we call it "in place" to photograph where this item was found and in this case the item was found directly below the desk or table.

MS. HAJJAR: And is this item, item one, reflected on the photographic log that you looked at -- that you showed the jury earlier?

CHRISTOPHER MILLS: It's not the first photo. It's the first item.

MS. HAJJAR: The item one?

CHRISTOPHER MILLS: Evidence item one.

MS. HAJJAR: Item one noted on that log?

MS. HAJJAR: Your Honor, may I approach the witness?

THE COURT: Yes, you may.

(Counsel approaches.)

BY MS. HAJJAR:

MS. HAJJAR: I'm going to show you, Agent Mills, what's marked as Government's Exhibit 520 and 524. Have you seen these exhibits?

MS. HAJJAR: What are these?

CHRISTOPHER MILLS: So, this camera here is the camera that was inside the bag of the item identified as item number one and then this is the card found inside of this camera.

MS. HAJJAR: And Government Exhibit 520 is the camera and 524 is the card inside that camera?

MS. HAJJAR: Your Honor, the Government offers Government Exhibit 520 and 524 in evidence.

MS. GERAGOS: No objection.

THE COURT: All right. Government Exhibits 520 and 524 are received in evidence.

(Government Exhibits 520 and 524 received in evidence.)

BY MS. HAJJAR:

MS. HAJJAR: Showing you 502-A-33, is this the same -- is this the same camera as Government Exhibit 520 and the bag that you found it in?

MS. HAJJAR: Your Honor, may we just switch the ELMO for a moment?

(Pause in proceedings.)

MS. HAJJAR: Thank you Your Honor. I just want to show -- publish Government Exhibit 520.

(Exhibit published.)

MS. HAJJAR: Agent Mills, what's the make of the camera?

CHRISTOPHER MILLS: It's a Canon camera.

MS. HAJJAR: Turning your attention to the back of Government Exhibit 520, can you read the serial number or the number that's listed at the bottom?

CHRISTOPHER MILLS: Sure. It's 1420908348.

MS. HAJJAR: And can you see below that where it says "Canon Incorporated"?

CHRISTOPHER MILLS: Yes. It says "Canon Incorporated, made in Japan."

MS. HAJJAR: And Government Exhibit 524, this is the card that was in the camera at the time?

MS. HAJJAR: What happens when you recover a piece of digital evidence like Government Exhibit 520 and 524?

CHRISTOPHER MILLS: So, when we receive -- when we recover digital evidence, we have a process in which we bring the digital evidence back to our office and if we want the evidence to be reviewed, we would submit a request to our CART team. And the CART is the Computer Analysis Response Team and they is have specialists who are computer evidence examiners who would review that evidence for us or assisted us in reviewing the evidence with us.

MS. HAJJAR: And is that what happened in this case with Government Exhibit 520?

MS. HAJJAR: Your Honor, may I switch back to the PowerPoint, please? Thank you.

BY MS. HAJJAR:

MS. HAJJAR: So turning now, Agent Mills, to Government Exhibit 502-A-34, can you describe what this photograph shows?

CHRISTOPHER MILLS: I don't have anything on the screen.

THE COURT: I am sorry. Go ahead.

MS. HAJJAR: Can you describe what this photograph shows?

CHRISTOPHER MILLS: Yes. So this is the still of the same office space as seen before and item number two, which is on top of the bookshelf here, is a gray or silver hard drive.

MS. HAJJAR: Is there -- and this is directly to the left of a white board with a lot of equations on it?

CHRISTOPHER MILLS: Yes. So the white board with the equations is to the right and the book shelf to the right with the hard drive to the left.

MS. HAJJAR: Your Honor, may I approach the witness?

THE COURT: Yes, you may.

(Counsel approaches.)

BY MS. HAJJAR:

MS. HAJJAR: I show you what's been marked for identification as Government Exhibit 502. Showing you what's marked for identification as Government Exhibit 503. Do you recognize this exhibit?

MS. HAJJAR: What is it?

CHRISTOPHER MILLS: This is a hard drive. The brand is, I believe, Western Digital.

MS. HAJJAR: Is there a serial number on that exhibit?

CHRISTOPHER MILLS: Yes. It is WCAS81365334.

MS. HAJJAR: Your Honor, the Government offers Government Exhibit 503 into evidence.

MS. GERAGOS: No objection.

THE COURT: All right. Government Exhibit 503 is received in evidence.

(Government Exhibit 503 received in evidence.)

BY MS. HAJJAR:

MS. HAJJAR: Agent Mills --

MS. HAJJAR: I'm sorry, Your Honor, may I switch the ELMO just for a moment?

THE COURT: Sure. Go ahead.

BY MS. HAJJAR:

MS. HAJJAR: I wanted to show you, Agent Mills, the back of Government Exhibit 503 where you read the serial number. Do you see that?

MS. HAJJAR: Do you see up top where this device was manufactured and assembled?

CHRISTOPHER MILLS: Yes. It says "Assembled in Thailand with drive manufactured in Malaysia or Thailand."

MS. HAJJAR: Do you see the front of Government Exhibit 503, the circle?

MS. HAJJAR: Agent Mills, was this one of the devices that was also provided to CART for their analysis and review?

MS. HAJJAR: Your Honor, if I could move back to the PowerPoint.

THE COURT: Go ahead.

BY MS. HAJJAR:

MS. HAJJAR: Turning then to -- skip to 502-A-46, can you describe what this photograph depicts?

CHRISTOPHER MILLS: Sure. So this is, once again, underneath the desk or the table in the office space. And you see item number 14, so that's evidence item number 14, the gray or silver hard drive.

MS. HAJJAR: Just going back for a moment --

MS. HAJJAR: Can I approach the witness, Your Honor?

THE COURT: Yes, you may.

MS. HAJJAR: I'd like to show the witness what's been marked for identification as Government Exhibit 506.

(Counsel approaches.)

BY MS. HAJJAR:

MS. HAJJAR: I'm showing you actually what's marked as 560, Agent Mills. Do you recognize this exhibit?

MS. HAJJAR: What is it?

CHRISTOPHER MILLS: It's the hard drive and brand LaCie.

(Continued on the following page.)

DIRECT EXAMINATION BY MS. HAJJAR: (Continuing)

MS. HAJJAR: Was that the item 14 that you recovered from 8 Hill Drive?

MR. DEROHANNESIAN: Your Honor, the Government offers Exhibit 560.

MS. GERAGOS: No objection.

THE COURT: Received in evidence.

(Government's Exhibit 560 received in evidence.)

MS. HAJJAR: Agent Mills, can you read the serial number on this drive as well?

CHRISTOPHER MILLS: It is 164400534.

MS. HAJJAR: Agent Mills, was Government Exhibit 560 one of the devices that was provided to CART for analysis and review?

MS. HAJJAR: During the course of your search of 8 Hill Drive, did you see papers and documents addressed to Keith Raniere?

MS. HAJJAR: And did you see letters and other items also addressed to Keith Raniere?

MS. HAJJAR: Did you have any further involvement with searching these items after they were provided to CART?

MS. HAJJAR: No further questions, Your Honor.

THE COURT: Cross-examination.

CrossCrossChristopher Mills — Cross Christopher Mills Teny Rose Geragos

CROSS EXAMINATION BY MS. GERAGOS:

MS. GERAGOS: Good afternoon, Agent Mills. My name is Teny Geragos. I represent Keith Raniere. Nice to meet you.

CHRISTOPHER MILLS: Good afternoon.

MS. GERAGOS: I just have a few questions for you.

MS. GERAGOS: I will be using the ELMO, Judge.

THE COURT: Very well. Here you go.

MS. GERAGOS: I will start with what we were just looking at, which is, this is 502-A-34 and I guess this is pretty dark here. This is Government Exhibit 503, which is just what we are looking at. Do you see the blue light there?

MS. GERAGOS: That was only in Government Exhibit 175; correct?

CHRISTOPHER MILLS: I believe so, yes.

MS. GERAGOS: Was this plugged into anything?

CHRISTOPHER MILLS: I would not know at that moment.

MS. GERAGOS: Okay. Did you personally retrieve it?

CHRISTOPHER MILLS: Did I personally retrieve the device itself?

CHRISTOPHER MILLS: For evidence collection, yes.

MS. GERAGOS: But you just don't remember if it was actually plugged into anything?

CHRISTOPHER MILLS: I don't recall, but I did not unplug it.

MS. GERAGOS: Okay. And then item number -- I'll move to the next one.

Actually, I will go to Government Exhibit 502-A-42. We didn't look at this on direct. Can you see -- I will zoom in -- these are addressed to someone named Monkey; correct?

MS. GERAGOS: And it has hearts next to the name?

MS. GERAGOS: Okay. And lastly, Government Exhibit 502-A-46, is this underneath the desk we were just looking at?

MS. GERAGOS: And this was Government Exhibit 560. That's the one you just identified on direct examination; correct?

MS. GERAGOS: Was this plugged into anything?

CHRISTOPHER MILLS: I don't recall.

MS. GERAGOS: Did you personally retrieve this device?

MS. GERAGOS: There were a number of books on the book shelf; correct?

MS. GERAGOS: There were about five book shelves of books?

CHRISTOPHER MILLS: Approximately, I would say so, yes.

MS. GERAGOS: Did you seize all of those books?

MS. GERAGOS: Just some of the electronic devices?

CHRISTOPHER MILLS: Some of the electronic devices and some of the books.

MS. GERAGOS: Just one last question. Government Exhibit 502-A-51, we didn't look at this on direct, but this was taken from the shelf as well; right? I mean, sorry, the desk?

CHRISTOPHER MILLS: I believe this was on top of the desk.

MS. GERAGOS: On top of the desk. Can you tell this has human pain schedule here? Can you tell? I know it is hard to read.

CHRISTOPHER MILLS: Not really, no.

MS. GERAGOS: And 502-A-52, is that a calculator also that you took?

CHRISTOPHER MILLS: I believe so, yes.

MS. GERAGOS: All right. Was the door of the house locked when you got there?

MS. GERAGOS: It was. And you had to enter and then see if anybody was inside?

MS. GERAGOS: Nothing else, Your Honor.

THE COURT: Thank you.

Anything else?

MS. HAJJAR: No, Your Honor.

THE COURT: The witness is excused. You may stand down, sir.

THE COURT: You're welcome.

(Witness steps down.)

THE COURT: The Government may call its next witness.

Continue to next page8.Jay — Direct (Part 1)