T8 — A University-Owned Property Near The Site Was Likely Used

:::caution Legal Disclaimer Tyler Robinson is charged, not convicted, and is presumed innocent. Nothing on this page states as fact that any living person committed a crime, destroyed evidence, or acted improperly. Court filings in this case are subject to a gag order and sealing, so the public record is incomplete by design. :::

What We Contend

A specific university-owned property near the site was used in connection with the operation. That is a contention this exercise would attempt to prove. It is not a finding this site asserts, and every sentence below is written on the assumption that it might be wrong.

This is the most reachable thesis in the whole of Appendix A, and that is the first thing to say about it. Every other thesis in this section runs into something. Some need a federal agency to waive a privilege. Some need a constitutional ruling on a novel question. Some need a stage of the case that has not been reached. This one needs a subpoena duces tecum to a university for its own property records — the single most routine instrument in civil and criminal practice, granted every day in every courthouse in America. There is no gateway page in front of it. Nobody has to declassify anything. No judge has to decide anything hard. A clerk issues it and a records officer answers it.

The property is a large single-family house at 691 West 925 South, Orem, about a quarter-mile north of the campus edge. Utah Valley University bought it in 2019 for $900,000 and its own Board of Trustees described it as "contiguous to campus" with "excellent access… from Campus Drive," saying it "could be used for hosting events or housing campus visitors." Those are the institution's own words in its own minutes. The ownership record is clean, public and uncontested.

And the street is not a street this exercise chose. The State chose it. On 11 September 2025 — the day after the killing — a Utah County officer swore a geofence warrant whose Search 3 polygon is described in the affidavit as "Utah Valley University Parking lot 'K' and north across 'College Drive' to W 925 S street and to the North-West to S799 W Street." The same affidavit says a contractor working in a neighbouring yard saw a man run through the trees into the neighbourhood, and that "the first street the suspect would have come to is, W 925 S st." Two more polygons, Searches 4 and 5, cover the two intersections the affiant identified as that neighbourhood's only exits. The State fenced this block on day two and asked Google who was standing inside it. On the public record it does not appear to have asked the university who was authorised to be inside the house it owns on that same block.

Two routes reach much of this material, and a lawyer uses both, for different reasons. Utah's Government Records Access and Management Act — Utah Code § 63G-2 — lets any person demand records from a public institution. It is free, it is public, it needs no judge, and the response clock is roughly ten business days. A subpoena duces tecum under Utah Rule of Criminal Procedure 14 is slower and narrower, but it is enforceable, it is returnable to the court, and a GRAMA classification is not an answer to it — § 63G-2-207 contemplates disclosure under subpoena or court order regardless of how a record is classified. So the sequencing is: GRAMA first, because it costs nothing and starts a clock that runs while you do other work, and the subpoena behind it, because the institution can refuse a records request and cannot refuse the court. This institution has in fact already refused part of a records request, which settles the question of whether the second instrument is needed.

Now the part that matters more than any of it, and it is the reason this page is written the way it is. Occupancy records establish who was authorised to be somewhere. They do not establish who was there. They establish nothing whatever about what anybody did. A key register that shows a fob issued in August 2025 proves that a fob was issued in August 2025 — no more. A utility series that shows household load in September proves that something in the house drew electricity. A thesis that overclaims on this point is worse than no thesis at all, because it hands the State an easy win on the one line of inquiry that costs nothing to run.

Say the limits out loud, because a page that does not is not doing its job. An occupancy record is a record of permission, not of presence. A key register records an issue and a return, not a use. A card-reader log — if one ever existed here — records a credential at a door, not the person carrying it. A utility series records load, which distinguishes an occupied house from an empty one and distinguishes nothing else at all. None of these documents, alone or together, can place a named person inside a room, and none of them can say what anyone did there. What they can do is answer a much smaller question that nobody has publicly asked: was this building in use in the relevant window, and does the institution that owns it know who was authorised to be in it? This page therefore asks the institution for records and asserts nothing about any person.

A word about the word "likely." The statement this thesis carries is that the property was likely used. That is a stronger word than the evidence currently supports, and this exercise is not going to pretend otherwise. What the record supports today is that the property is on the street the State fenced, that it is owned by a public body with a records officer, and that nobody appears to have asked. A defense attorney does not need "likely" to serve a subpoena; a defense attorney needs a good-faith basis and a defined window, and both exist. The honest posture is to serve the instrument at the strength the facts actually carry — a reasonable line of inquiry on a street the State itself drew a polygon across — and to let the return move the word up or down. If the return moves it down, this page moves it down.

One absolute constraint governs everything below. Any current or former occupant of this property is a living private person. This page does not name any of them, does not describe any of them into identifiability, and does not suggest that any of them did anything. If a return identifies a person, that identification belongs to counsel and the court, under seal — not to a public page.

The Chain Of Reasoning

Each link is a fact this site already holds, and each carries the page that holds it.

The killing happened on a campus with a residential block immediately north of it. 691 West 925 South sits about a quarter-mile from the northern edge of campus — walking distance, not the several miles that real-estate aggregators imply. The distance error is the aggregator's, and the university's own board paperwork corrects it.
The State's own affiant put the escape route onto that street. Geofence warrant SW3212601, sworn 11 September 2025 and returned 23 September 2025, records a contractor's account of a man running through the trees, and states that "the first street the suspect would have come to is, W 925 S st." Held in the legal documents archive.
The State drew a search polygon across it. The Search 3 geofence runs "north across 'College Drive' to W 925 S street," for the twenty-minute window 12:15 to 12:35 p.m. MDT on 10 September 2025. Searches 4 and 5 cover the neighbourhood's two exits.
Detectives then canvassed that block for video, and it worked. Warrant SW3213811, sworn 12 September 2025, states: "Following the shooting, detectives canvassed homes for video footage. Investigators located surveillance camera footage dated 09/11/2025 from the location of 680 W 925 S, Orem, Utah." The block page sets out the court record on that footage.
One property on that block belongs to a public institution. Utah Valley University holds title to 691 West 925 South on live Utah County serial 36:443:0006, by warranty deed Entry 46392-2019, recorded 24 May 2019. The full deed chain runs Broderick, Markides, Theobald, then the university.
A public institution keeps records about its own property, and it can be made to answer for them. Occupancy agreements, bookings, key registers, card-reader logs, work orders, parking permits, insurance schedules and utility accounts all exist as a matter of ordinary administration. Utah's GRAMA statute reaches many of them and a subpoena reaches the rest.
This institution has already answered a records request in part, and refused the remainder. UVU released 112 pages, acknowledged that further responsive documents exist, and declined to release them. That is precisely why the enforceable instrument matters: a records request can be refused, and a subpoena returnable to the court cannot be brushed off the same way.
No warrant in the set we hold reaches this property, or the university's records about it. Twenty-seven search warrants are held, numbered 3212261 through 3229461. None names any residential address on West 925 South, and none is directed at the university for occupancy, keying or access-control data. There is no warrant for the campus crime scene itself either.
Nothing in either certified transcript touches any off-campus property. Day 4 and Day 5 were searched. Every house and residence hit is the St. George apartment or the parents' home in Washington, Utah.
The defense already knows how to run this exact argument — at a different address. On certified Day 5, Michael Burt drew from ATF examiner Caitlin Oliver the concession that "it's reasonable to assume that anyone living in the household could have contributed to DNA found on an object found in that household." The who-else-was-authorised-to-be-there argument is in counsel's demonstrated practice.
The State's own paperwork disagrees with itself about the one piece of block evidence it does hold. Warrant 3213811 says the vehicle parked at approximately 00:23 hours and remained until approximately 01:20 hours. Warrants 3213501 and 3214771, resting on an FBI special agent's account of the same Nest camera, say approximately 1247 hours and 0135 — and 3213501 also dates the event to "September 11, 1025." Preliminary-hearing coverage has reported the same parking event at about 00:30. Three sworn documents, three figures. That is a clock-and-foundation problem on the only camera anybody has named on this street, and it is a reason to go to the institutional records rather than to rely on the neighbour's device.
The State's exhibit set contains exactly one property's doorbell footage. The 3 April 2026 opposition to continuing the preliminary hearing lists, among the State's late disclosures, "doorbell surveillance from a single property (provided January 21, 2026)." The 6 May 2026 exhibit list carries it as Exhibit 13, Bates 15215–15226, alongside a written Rule 1102 statement from an occupant of that residence. One property, on a canvassed block, in a capital case.
The institution's cameras produced evidence in this case without visible compulsory process. The geofence affidavit states that "Video surveillance was obtained from UVU showing the roof of the Losie Building" and lists campus surveillance among the affiant's sources. So the university was already a cooperating evidence source in this investigation. An entity that hands over footage voluntarily is an entity that can be asked, in writing, what else it holds — and there is no record that it was.
Therefore the contention. A property owned by a public body, on the street the State itself fenced, has records that would show whether anyone was authorised to be inside it in the relevant window — and those records are obtainable today, by two independent routes, with nothing standing in the way. That they have not visibly been obtained is the gap this thesis names.

The Day-One Track

Our AI defense attorney has been counsel of record since 12 September 2025. On these items the difference that date makes is stark and easy to state: the paper survives and the electronics do not.

This is also the clearest illustration in the section of a point that is easy to state and easy to forget: the paper on this list is immortal and the electronics on it are not. A deed does not expire. A work-order history does not roll off. A meter reading is an accounting record and an accounting record is kept for years, because somebody may need to reconcile a bill. A card-reader event is none of those things — it is operational telemetry, kept for as long as a facilities department decided was useful and no longer. The whole cost of a twelve-month delay on this thesis falls on the second category, and it falls completely.

When	What our attorney serves	What was still recoverable then	When the window closed
2025-09-12	Preservation letters — no court leave required — to the Utah Valley University records officer, to Rocky Mountain Power, to Dominion Energy Utah and to Orem City, naming the service address and asking that nothing be purged	Everything. Card-reader events, camera footage, work-order history, meter reads, all inside their ordinary retention cycles	Rolling; each custodian's own schedule
2025-09-15	GRAMA request to the UVU records officer under Utah Code § 63G-2 for occupancy, use, reservation, work-order and key-issuance records for the property, January–December 2025	The 10-business-day clock starts almost twelve months earlier than it did	Does not close — but the answer gets thinner as systems roll
2025-09-17	Subpoena duces tecum under Utah R. Crim. P. 14 to the university's custodian of records, the day after the first appearance, with a Rule 902(11) custodian declaration demanded on the return	The electronic access-control event log for every door, at a point inside every plausible 30-to-90-day retention window	Roughly Dec 2025 on a 90-day schedule. Closed
2025-09-17	Same subpoena, camera item: the inventory of every institutional camera whose field of view includes the property frontage, its configured retention, and preserved footage for 8–12 September 2025	Institutional video, at the outer edge of a common 14-to-30-day cycle	Roughly Oct 2025. Closed
2025-09-19	Third-party subpoenas to the two investor-owned utilities for the full interval and monthly consumption series at the service address, January 2024 forward	The series — and it is still recoverable, because it is an accounting record	Still open. This is the one item on the list a year did not cost us
2025-09-22	Subpoena and parallel GRAMA to Orem City for the municipal water, sewer and refuse account, the rental-dwelling licence file, the permit history and the code-enforcement file	All of it, and it is documentary	Still open
2025-09-24	Rule 14 subpoena to the university for the camera inventory covering the property frontage, the configured retention on each camera, and every litigation hold placed since 10 September 2025	The inventory and the footage. One of those still exists	Footage roughly Oct 2025. Closed. Inventory: still open
2025-09-26	Rule 16 demand to the Utah County Attorney for the canvass log behind the sworn sentence in warrant 3213811 — addresses knocked, cameras seen, footage taken or declined	The log, and it is a government record with a retention schedule	Still open

Four rows closed, three rows open. That ratio is why this thesis is worth filing today rather than mourning. The half of the rider that was perishable is gone. The half that was documentary is exactly as obtainable this morning as it was on 12 September 2025.

The Gap Analysis

#	What we would do, and of whom	Stage and date	Witness took the stand?	Asked on the record we hold?	How we checked
1	Serve a subpoena duces tecum on the custodian of records, Utah Valley University: "Produce the complete property file for 691 West 925 South, Orem — acquisition, occupancy, booking, keying, electronic access control, work orders, utility accounts, parking permits, insurance and camera coverage — for 1 January 2024 through 31 December 2025, with a Rule 902(11) custodian declaration."	Rule 14 subpoena; available from the first appearance onward. Our date: 2025-09-17	n/a — records demand	Not found	T2 — the archive holds 374 PDFs against 867 docket rows; no subpoena to the university appears in it
2	Subpoena Rocky Mountain Power and Dominion Energy Utah: "Produce the full monthly and, where retained, interval consumption series for the service address from 1 January 2024, and state every period in which service was disconnected, suspended, or billed at a minimum charge with no consumption."	Third-party subpoena; available now and unaffected by the delay	n/a — records demand	Not found	T2 — no third-party utility subpoena in the archive we hold
3	To Sgt. Jennifer Faumuina, on the certified record: "You told this court that officers were canvassing the area and that you did not know the specifics. Who did know the specifics, and is there a written canvass log?"	Preliminary hearing cross; 9 July 2026	Yes — 7 and 9 July 2026	Partly — the canvass was raised, and she answered "I don't know the specifics"	T1 — certified Day 4 searched for canvass; three hits, page 87 and page 116
4	Rule 16 demand to the Utah County Attorney's Office: "Produce every canvass log, worksheet and neighbourhood-contact sheet behind the sentence in warrant 3213811 reading 'Following the shooting, detectives canvassed homes for video footage', and state whether 691 West 925 South appears on it."	Rule 16 discovery; available now	n/a — records demand	Not found	T2 — warrant SW3213811 held and read; no responsive filing in the archive
5	To Sgt. David Hull: "The geofence affidavit in this case draws a polygon running 'north across College Drive to W 925 S street.' At the time that boundary was drawn, did anyone ask the university who was authorised to be inside the house it owns on that street?"	Preliminary hearing cross; 6 and 7 July 2026	Yes — 6 and 7 July 2026	Not checkable — Days 1, 2 and 3 exist here only as machine transcriptions of the pool feed	T4 — the certified Day 1–3 transcripts do not exist outside the court
6	To Sgt. Faumuina: "The only 'swipes' in your testimony are hand marks on a rooftop ledge. Did anyone in this investigation obtain an electronic access-control swipe log for any building, on campus or off it?"	Preliminary hearing cross; 9 July 2026	Yes — 7 and 9 July 2026	Not found	T1 — certified Day 4 searched for swipe, badge, access; all five swipe hits are physical marks on the roof ledge
7	GRAMA request under Utah Code § 63G-2 to the UVU records officer for any lease, use agreement, reservation, work order, key-issuance or occupancy record for the property, 1 January – 31 December 2025	Citizen or investigator route; no court leave; roughly a 10-business-day clock	n/a — records demand	Not found — and the institution has already released 112 pages, acknowledged more exist and refused further release	T3 — GRAMA reporting summarised on this site, not a filing we hold
8	To ATF examiner Caitlin Oliver: "Would the same reasoning apply to any residence — that anyone authorised to be inside it could contribute DNA to an object found inside it?"	Preliminary hearing, defense direct; 10 July 2026	Yes — 10 July 2026	Asked — established at the St. George apartment, page 57; not extended to any other address	T1 — certified Day 5 searched; the exchange is verbatim in the record
9	Subpoena the university for the camera item alone: "An inventory of every institutional camera whose field of view includes this property or its frontage, the retention period configured on each, and every hold applied since 10 September 2025."	Rule 14 subpoena; the inventory survives even where the footage does not	n/a — records demand	Not found	T2 — no such subpoena in the archive; the affidavits show UVU video was obtained without any compulsory process in the set we hold
10	Motion to compel the geofence returns for Searches 3, 4 and 5 of warrant SW3212601 — the Google production for the polygon that crosses this street	Rule 16 motion to compel; available now	n/a — records demand	Not found	T2 — the warrant and its 23 September 2025 return date are held; the return document itself is not
11	Demand Exhibit 13 in Bates form — "Doorbell camera surveillance 9/10/2025," Bates 15215–15226 — together with the written Rule 1102 statement listed at the same exhibit number	Rule 16 / exhibit production; available now	n/a — records demand	Not found — we hold zero of the State's 34 preliminary-hearing exhibits as documents	T2 — the 6 May 2026 State's witness and exhibit list
12	To Detective Michael George Carle, Utah County Sheriff's Office, the affiant on warrant 3213811: "You swore that detectives canvassed homes for video. Did you knock on any of those doors yourself, and whose report were you summarising?"	Rule 602 foundation; a witness we would call	Not known to have testified	Not found	T3 — he is not on the certified witness roster we hold
13	To Detective Carle: "Warrant 3213811 says the vehicle parked at 00:23 and left at 01:20. Warrants 3213501 and 3214771 say 1247 hours and 0135. Hearing testimony has been reported at about 00:30. Which figure is native to the device, and where does the difference come from?"	Cross on the block evidence; foundation and clock accuracy	Not known to have testified	Not found	T2 — all three affidavits held and compared line by line
14	Subpoena and parallel GRAMA to Orem City for the municipal water, sewer and refuse account and consumption series, the rental-dwelling licence file, the permit history and the code-enforcement file for the address	Third-party subpoena plus GRAMA; available now	n/a — records demand	Not found — no listing, licence or code file has surfaced	T2 — no third-party or municipal subpoena in the archive we hold
15	To Sgt. Faumuina: "Your command post was in the Fugal Building, on campus. Did this investigation ever treat any university-owned building off the main campus as a place to be examined?"	Preliminary hearing cross; 9 July 2026	Yes — 7 and 9 July 2026	Not found	T1 — certified Day 4 searched for university, UVU, campus, 925; the two 925 hits are index artefacts, not testimony
16	Preservation letters — not subpoenas, no court leave needed — to the university, to both utilities and to Orem City, naming the service address	Available from the first day of the representation. Our date: 2025-09-12	n/a	Not found — with the honest caveat that preservation letters are never filed and would look identical whether served or not	T2 — the archive we hold is filings only, and this instrument is not one
17	Attach a Rule 902(11) custodian certification to every return so the production self-authenticates as a record of a regularly conducted activity under Rule 803(6), and no live witness is needed to put it before a jury	Trial preparation, after bind-over	n/a	Not yet due — and a step not yet due has not been missed	T2 — the case has not been bound over; argument was set for 1 September 2026
18	To the custodian of records, on the return: "Is this property on the campus electronic access-control system, and for how many days does that system retain a card-reader event before it is overwritten?"	Hearing on the subpoena return	n/a — records demand	Not found	T2 — the retention setting is a durable configuration record and survives the events it governed
19	To the custodian of records: "Did the institution receive any request from any law-enforcement agency, state or federal, for records concerning this property, and if so, on what date?"	Hearing on the subpoena return	n/a — records demand	Not found	T2 — this is the question that converts a silence into a fact either way
20	To Sgt. Brian Davis: "Forty government agencies are identified in the discovery in this case. Did any of them examine any building on West 925 South, and is there a report of it?"	Preliminary hearing cross; 8 and 9 July 2026	Yes — 8 and 9 July 2026	Not found — and the certified record records no cross-examination of this witness that day	T1 — certified Day 4; the record shows the defense passed on cross

Where this chain breaks the State's case

It does not break the mechanism link and it does not pretend to. It breaks the completeness link. The State will ask a jury to accept that the residential corridor north of campus was searched, that everything relevant was found, and that nothing was left unexamined. On its own sworn paperwork the State fenced this street, identified it as the suspect's first street on foot, and canvassed it for video — and then, so far as any public record shows, never asked the public institution that owns a house on it a single question about that house. The gap is not in what the State found. It is in what the State never asked to be looked for, which is the question that beats "are you sure?" every time.

What would defeat this thesis

A produced UVU property file showing the house was vacant across the relevant window — no key or fob issued after a date well before September 2025, no booking, no card-reader event, no work order — corroborated by a utility consumption series flat at standby load through August and September 2025. That would end this thesis outright, and this section would say so on its front page. It is a real and available result, it is the single most likely result, and the utility series in particular cannot be curated: a meter writes it, a billing system keeps it, and nobody involved in this case has ever had a reason to touch it. Name the documents so the test can actually be run and scored: the key register, the booking or reservation record, the computerised-maintenance-management-system ticket history, and the Rocky Mountain Power monthly consumption series, for 1 August through 30 September 2025. Four documents. If all four say empty, this thesis is finished, and finishing it would be a good day's work — because the same four documents are the only honest route to the opposite answer.

The instruments that serve this thesis

Subpoena The University For Its Own Property Records — the Rule 14 subpoena, the twelve-item Schedule A rider, the GRAMA parallel, and the narrow-first strategy that survives a motion to quash
The House Frontage Camera Canvass — the door-to-door log, the retention arithmetic, the one-page preservation letter, and the Rule 16 rider for the State's own canvass file

There is no gateway instrument in front of either of them. That is unusual in this appendix and it is the practical fact a reader should take away: no privilege has to be pierced, no agency has to be persuaded, no novel constitutional question has to be decided first. The court issues the subpoena and the records officer answers it.

How This Reaches A Juror

This page serves Route 2 — the investigation itself. It needs no alternative perpetrator, no foreign state, and nothing at all about the mechanism of death. It needs only the completeness of a process the jury cannot inspect for itself.

"On the second day of this investigation, the State drew a map. It drew a line across one residential street north of that campus and told a judge, under oath, that this was the first street the man they were looking for would reach. Then they knocked on doors along it. And on that street there is a house — owned not by a private family but by the university itself, bought for nine hundred thousand dollars, sitting on more than an acre. A public building, with a records officer, a key register, a card reader on the door and an electricity bill. All the State had to do was ask. There is no record that anybody ever did. You are being asked to be sure — not probably, sure — about what happened on a street the State itself fenced, on the strength of an investigation that never opened the file on the one building on it that had a file."

This is deliberately not Route 1. It says nothing about whether a rifle round or an explosive device caused the fatal wound, and it does not need to. Route 2 asks a different question and it asks it of the process rather than of the physics: can a jury inspect the investigation it is being asked to rely on? Here it cannot, and the reason is unusually clean — the missing step is not a classified holding or an agency refusal. It is a form nobody filled in, addressed to a public university that answers records requests as a matter of statute.

That is also why this thesis survives an unfavourable answer. If the records come back and show an empty house, the defense has spent a subpoena and lost nothing; the theory closes and the section says so. If the records come back and show the building in use, the defense has a fact the jury can hold. And if the records do not come back at all — if the institution declines and the court has to compel it — that refusal is itself the thing counsel puts in front of a jury. On this instrument every outcome is usable, which is the definition of a cheap question worth asking.

One thing counsel would not say in that closing, and the discipline matters: nothing about who was in the house. Not a name, not a description, not an insinuation. The argument is complete without one, and it is stronger without one, because the moment a defense names an unproven occupant the prosecutor stops defending the investigation and starts defending a private citizen — which is a fight the defense loses in front of a jury and deserves to lose.

What Would Have To Be Obtained

REACHABLE — a private-party or institutional subpoena, or a court order on material the State already holds. No agency has to waive anything.

The complete UVU property file for the address: acquisition record, administering department, occupancy and use agreements, bookings and reservations, the key register, work orders, insurance and risk-management file, parking permits. Subpoena duces tecum, Utah R. Crim. P. 14. Also largely reachable by GRAMA, Utah Code § 63G-2 — cheaper, public, no judge, roughly a 10-business-day clock, and refusable, which is exactly why the subpoena sits behind it. GRAMA's judicial-process provision, § 63G-2-207, contemplates disclosure under subpoena or court order regardless of how a record is classified.
The utility consumption series from Rocky Mountain Power and Dominion Energy Utah. Third-party subpoena, because both are investor-owned rather than public bodies. This is the best single item in the whole thesis and it deserves saying why: it is held by a third party with no stake in this case; it is machine-generated, because a meter writes it and nobody types it; it is kept for billing rather than litigation, so it was never curated with this case in mind; it has a long retention period because it is an accounting record; and an occupancy pattern is legible in it without any human being asked to remember anything. A house drawing baseline standby load and then a household load — or drawing nothing at all — tells you whether anybody was living in it, and it tells you on a date axis.
The Orem City file: municipal water, sewer and refuse account and consumption, rental-dwelling licence, permit history, code-enforcement complaints. Public body, so GRAMA reaches it, though customer detail may be classified private and require the subpoena anyway.
The State's canvass log and the collection reports behind warrant 3213811. Rule 16 demand or motion to compel. It costs the State nothing to produce, it touches no classified holding, and a refusal is also an answer — if no canvass log exists, the State swore to a canvass in a warrant application and cannot produce the record of it.
The geofence returns for Searches 3, 4 and 5 of warrant SW3212601, and the State's Exhibit 13 in Bates form.
The written Rule 1102 statement of the occupant listed at Exhibit 13, which is one of five sworn written statements in this case that have never been public.
The administering department inside the institution — which office signs work orders for this property, and who its facilities manager is. That single answer names the live witness for everything else on the list, and it is the first question on any return.
The retention configuration of the institution's access-control platform and its camera system, in writing. Even where the data is gone, the configuration is a durable record, and it establishes what could have been preserved if anyone had asked in September 2025.
An inventory and a privilege log, item by item, for anything withheld or redacted, naming the specific GRAMA subsection or other authority relied on — the same discipline the institution applied to its own earlier supplemental production.

UNREACHABLE, OR NO LONGER EXISTING — and saying so is part of the honesty of the page.

The electronic access-control event log for the property, if it was ever on the institution's platform. Card-reader systems are commonly configured to retain events for 30 to 90 days. Twelve months on, it is almost certainly gone, and no order recovers it. What survives is the retention setting itself, which is a durable configuration record and is worth asking for on its own.
Institutional camera footage of the frontage from September 2025, for the same reason. The camera inventory survives; the pictures do not.
Any federal agency's own file on this property, if one exists. That is not reachable by a Rule 14 subpoena and is not claimed here to be.
Anything that would establish what a person did inside the property. No record on this list can do that, and no page in this section should pretend otherwise.
Any private cloud recording from a neighbouring camera on the block that its owner did not download. Consumer doorbell tiers commonly retain nothing at all or thirty to sixty days, and local DVRs commonly overwrite at fourteen to thirty. Those windows shut in the autumn of 2025 and nothing reopens them.
The discovery corpus itself, which is governed by the 15 October 2025 Order for Discovery Protection and will never be filed. If a university property file is already inside it, the public will not learn that from the docket.

The Honest Counterargument

The boring explanation fits every document already in hand, and it is probably the true one. A university bought an adjacent house in 2019 to expand its footprint north, said so in public board minutes, described it as a place for events and visitor housing, and then owned it uneventfully for six years. Institutions do this constantly. That an assassination happened a quarter-mile away six years later is a fact about the campus, not about the house. Thousands of homes sit near a university.

The claim underneath this thesis is thinner than the thesis is. In the master investigation file, the staging allegation is a single unattributed, undated sentence with no named author and no described evidence. This exercise should be candid that a twelve-item subpoena rider is a heavy instrument to hang on one sentence, and that a court asked to enforce it would be entitled to say so.

The strongest on-block evidence belongs to a different address, and blurring them is the mistake this page must not make. What is actually in the court record is Ring or Nest video from 680 West 925 South — a neighbour's camera, a cooperating witness, and a car on a street rather than a person in a house. The citizen video said to show a vehicle at 691 has never been produced frame by frame for these pages and may simply be a retelling of the 680 footage. The block page keeps those claims separate and this page keeps them separate too. If the strongest on-block fact in the file is about a neighbour's doorbell, then the honest description of this thesis is a reasonable line of inquiry on a street the State itself fenced — not the pursuit of a known lead.

Counsel may already hold the answer and be right to say nothing. The discovery corpus in this case is enormous: 45 productions through August 2026, 29,237 files, a 12.1-terabyte drive, more than a million Discord communications, at least 25,253 cell-site location records, 40 identified government agencies. A university property file is exactly the mundane material that would sit inside that corpus without ever generating a filing. If it shows an empty house, a defense attorney who knows that will never raise the subject in open court, and would be right not to. A defense does not volunteer a dead end.

The timing objection is real. The case has not been bound over; oral argument was set for 1 September 2026. At a probable-cause hearing the only question is whether the State has shown enough, and on certified Day 5 the State pressed exactly that point, asking the court to keep the proceeding inside its scope. Spending the court's patience on a university's key register before that threshold is cleared is a defensible thing to decline to do, and holding a third-party records demand for the trial phase is a sequencing choice rather than a lapse.

Proximity is what an innocent explanation predicts too, and that cuts hard. The purchase paperwork says the university bought this house because it is contiguous to campus. Closeness to the campus is therefore not a coincidence that needs explaining — it is the stated reason the institution owns the building at all. Any argument that runs "it is suspiciously close" is arguing against a fact the seller and the buyer both put in writing in 2019, and a competent prosecutor would read those minutes to the jury and sit down.

The geofence polygon proves the State looked, not that the State missed something. Drawing a search area across a street and asking Google who was in it is the opposite of ignoring a neighbourhood. So is knocking on its doors. The strongest reading of the affidavit is that investigators identified the escape corridor within twenty-four hours and worked it hard, and a jury told that story will not be troubled that one particular building on it never generated a separate report.

And a rider this broad invites a motion to quash that would have force. Utah R. Crim. P. 14 lets a court quash or modify a subpoena where compliance would be unreasonable or oppressive, and two years of every work order, every card swipe, every parking permit and every insurance file for one house is the shape a court calls a fishing expedition. The answer is to serve narrow and grow: occupancy, keying, access control, utilities and the custodian declaration first, tied to 1–30 September 2025, with the rest reserved for a supplemental rider if the first return shows anything at all. A subpoena that survives is worth more than a subpoena that is right.

Finally, and most uncomfortably for this page: the urgent half of this thesis expired a year ago. If the card-reader log and the frontage video are past retention, then what made this instrument time-critical died in the autumn of 2025, and what remains — deeds, work orders, key registers, insurance files, utility bills — is documentary, durable and obtainable at any time. That argues for doing it later rather than never. It does not argue that it was not worth doing on day one, and it does not make the remaining half less worth having. But a reader who comes away thinking a subpoena served this month would recover a swipe log has been misled, and this page will not mislead them.

Sources On This Site

:::danger Theoretical Exercise Only This page is a theoretical exercise. It is a written simulation of how an idealised defense attorney might approach this case. We make no claim that there is any problem with the current defense attorney, with any member of the defense team, or with any decision they have made.

Real capital defense is conducted under a gag order, with sealed filings, and on the basis of full discovery that the public has never seen. Counsel of record know facts we do not. A step described here as "not on the public record" may already have been taken privately, may have been considered and rejected for good reason, or may not yet be due at this stage of the case. Silence in the public record is not evidence of a failure.

Nothing here is legal advice, a criticism of any licensed attorney, or an allegation of professional misconduct. :::

This website's author is @HolonCitizen on X and YouTube/@HolonCitizen. Follow me there.

What We Contend​

The Chain Of Reasoning​

The Day-One Track​

The Gap Analysis​

Where this chain breaks the State's case​

What would defeat this thesis​

The instruments that serve this thesis​

How This Reaches A Juror​

What Would Have To Be Obtained​

The Honest Counterargument​

Sources On This Site​