Subpoena The University For Its Own Property Records

:::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. :::

The One Thing We Would Do Differently

Serve a subpoena duces tecum on the records custodian of Utah Valley University for the complete property file of 691 W 925 S, Orem — acquisition, occupancy, booking, keying, electronic access control, work orders, utility consumption, parking permits, insurance and camera coverage — with a certified custodian declaration attached to the return.

On this section's own priority scheme, this is one of the most reachable instruments in the whole of Appendix A, and it is worth saying that plainly before anything else. A subpoena duces tecum asking a university for its own property records is routine practice. It requires no agency to waive a privilege, no constitutional ruling, no classification review, no gateway motion, and no cooperation from any federal partner. It is the kind of paper a district court signs without a hearing.

The property is real and the ownership is documented. Utah Valley University bought 691 W 925 S in 2019 for $900,000 from a private family, on warranty deed Entry 46392-2019, recorded May 24, 2019, live Utah County serial 36:443:0006, Lot 2 Plat J College Heights, 1.239 acres, a 7,486-square-foot house built in 1980. The university's own Board of Trustees called it "contiguous to campus" with "excellent access… from Campus Drive", and said it "could be used for hosting events or housing campus visitors." Tax notices mail to 800 W University Parkway — the main campus address. The house is about a quarter-mile north of the campus edge, a few minutes' walk from the courtyard.

The house is also inside the State's own search geography. Search 3 of geofence warrant SW3212601, sworn September 11, 2025 and returned September 23, 2025, defines a polygon its own affidavit describes 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", for the window 12:15 p.m. to 12:35 p.m. on September 10, 2025. Two further rectangles in the same warrant cover "the area around 725 W 800 S" and "the area around 600 W 800 S" — the two intersections the affiant identified as the exits from that neighbourhood. The State drew a fence around this street on the second day of the investigation. It asked Google who was standing in 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 street.

Two routes reach much of the same material, and a lawyer uses both for different reasons. Utah's Government Records Access and Management Act — Utah Code § 63G-2 — lets any person, including a defense investigator, demand records from a public institution. It is cheap, it is public, it needs no judge, and the response clock is roughly 10 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. GRAMA's judicial-process section, Utah Code § 63G-2-207, contemplates disclosure under subpoena or court order notwithstanding how a record is classified. So: GRAMA first, because it is free and starts the clock; the subpoena behind it, because the institution can refuse GRAMA and cannot refuse the court.

There is a second reason this particular house is an unusually productive target, and it has nothing to do with the allegation attached to it. A privately owned home generates almost no records. There is a deed, a tax bill, a utility account, and after that, silence. A home owned by a public university generates an entire institutional layer that a private house never produces: a facilities work-order system, a key register, an access-control platform, a risk-management schedule of insured locations, a parking-permit database, a booking or assignment system, a purchasing trail, and a records officer whose job is to answer for all of it. Public ownership was framed on the ownership page as a fact that cuts in more than one direction. For a defense lawyer it cuts one way only: it means the questions have documented answers, and a subpoena can go get them.

That is not a hypothetical refusal. In Government Records Office Case No. 2026-004, a Judicial Watch requester's GRAMA request to UVU for records of evidence removal and the courtyard paving was denied on December 15, 2025 for want of "reasonable specificity" under Utah Code § 63G-2-204(1)(a)(ii), partly reinstated on internal appeal on January 8, 2026, and then defended before the Government Records Office with redactions under § 63G-2-305(10)(a)-(c), § 63G-2-305(11), § 63G-2-305(12) and § 63G-2-302(2)(d), plus one record withheld in full. The university's stated ground for the law-enforcement redactions was the "ongoing criminal investigation and prosecution" — which is to say, this case. A citizen asking a public body for records in the middle of a capital prosecution runs straight into that wall. A defendant in that prosecution, holding a court's subpoena, does not.

That same public filing is also a free map of where to serve. Utah Valley University identified, in its own signed response, the people who conduct its record searches and who hold the operational files: an assistant GRAMA records officer who canvasses departments, the Chief Administrative Officer who hears internal appeals, and the Associate Vice President of Facilities Planning, who the filing says coordinated the post-incident cleanup and the paving and who searched his own records and those of other personnel involved. Facilities Planning is the office that would hold a work-order history, a key register and a maintenance file for a university-owned house. The filing also points, under Utah Code § 63G-2-204(4)(b)(iii), to the state Division of Facilities and Construction Management as a possible custodian of records the university does not itself keep. None of those officials is accused of anything here; they are named in a public administrative filing as custodians, and a rider that names the right custodian is a rider that gets answered.

What The Defense Team Did Instead

The instrument itself is plainly in the defense's active toolkit. The docket carries a Notice of Subpoena Duces Tecum with a certificate of service dated April 1, 2026 — dockets 468 and 495, directed to the Utah County Sheriff's Department, signed by Staci Visser, Kathryn Nester, Michael Burt and Richard Novak. A separate subpoena for Sgt. David Hull sits at docket 288, dated January 12, 2026. This team issues third-party subpoenas as a matter of course.

The preservation fight is also on the record and it went early. Counsel filed a Motion to Preserve Evidence on October 8, 2025 (docket 75) under Utah Rule of Criminal Procedure 16 and Utah Code §§ 77-11c-301, -302, -303(3), -401 and -401(5)(a). Judge Graf granted it on October 20, 2025 (docket 107). The State moved to set that order aside on October 22, 2025 as prematurely entered under Utah R. Civ. P. 7(d)(1) and Utah R. Crim. P. 12(b), and filed a substantive response the same day seeking a materiality limit and a release mechanism.

Read the granted order's own words, because they are the whole point of this page. It orders "the Utah County Attorney's Office, its agents and any law enforcement agencies involved in the investigation of this case, to preserve all evidence in their custody or under their control." That is a preservation order aimed at the prosecution. It does not reach a university facilities department, a campus access-control platform, a card-reader vendor, an electric utility, or a gas utility — none of which is the State's agent, and every one of which runs an automatic retention cycle that overwrites data on a schedule nobody in the courtroom controls.

The occupancy line itself is one this defense team already knows how to run — which matters, because it means the instrument on this page asks for nothing outside counsel's demonstrated practice. On the certified transcript of preliminary hearing Day 5, July 10, 2026, Michael Burt examined ATF DNA examiner Caitlin Oliver — a defense witness, on direct — on precisely this reasoning, at a different address. He established that elimination samples had been requested from three named people "because you had information those people were associated with the house", and drew 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." That is the who-else-was-in-the-residence argument, run well, on a certified record, by counsel of record. The question this page raises is not whether the team can run it. It is whether anyone has run it at the other address — the one the State drew a search polygon through.

We checked both certified transcripts we hold to answer that, and this is the whole of the search. Certified Day 4 (July 9, 2026) and certified Day 5 (July 10, 2026) were searched for 925, house, residence, occupancy, university, UVU, campus, Ring, doorbell, canvass, key, swipe, badge, parking and utility. Every house and residence hit in those two days is the St. George apartment, in the Oliver DNA cross above. Neither certified day contains a line about 691 West 925 South, about university property records, or about any camera on that block. Preliminary-hearing Days 1, 2 and 3 are not certified — we hold only machine transcriptions of the pool feed, which are not the record — so what was or was not asked of Sgt. Hull on those days is something this page cannot state at all, in either direction.

The warrant set tells the same story from the State's side. The archive behind these pages holds 27 search warrants in this case, numbered 3212261 through 3229461. Not one of them is directed at 691 West 925 South, at any residential address on West 925 South, or at Utah Valley University for its property, occupancy, keying or access-control records. The affidavit for the geofence warrant states that "Video surveillance was obtained from UVU showing the roof of the Losie Building" and that campus surveillance cameras were among the affiant's sources — so the university's camera system produced evidence in this case, and it appears to have produced it without any compulsory process in the set we hold. There is also a 19-day gap in the warrant numbering between 3217131 on September 17, 2025 and 3229461 on October 6, 2025, and nothing at all after October 6, 2025. What sits inside that gap, we cannot say. What we can say is that the set we hold contains no warrant for the campus crime scene itself and none for this property.

What has not appeared in any public filing, docket entry or press account reviewed here is a records demand of any kind directed at this property. No public subpoena to the university for occupancy, keying or access-control data. No public preservation letter to a utility. No witness examined about what the university's own records show. That absence is a fact about the public record and it is the whole of what we assert. The filings in this case are subject to a gag order and are partly sealed, and the archive behind these pages holds 374 PDFs against 867 known docket entries, only 258 of which ever had a public PDF.

Where This Belongs In The Case

Stage of the case	When that stage runs	Status of this step
Preservation letters and a GRAMA request	From the first day counsel is retained; no court leave needed	Not visible on the public record
Subpoena duces tecum, Utah R. Crim. P. 14	From the first appearance onward; available now	Not visible on the public record
Preliminary hearing cross	July 6-10, 2026 — completed	Not found in the certified transcripts we hold
Rule 902(11) authentication and trial use	After bind-over; argued September 1, 2026	Not yet due

Witness Or Discovery Target

How it would be done	Target	Took the stand?	Status on the public record
Subpoena duces tecum to a records custodian	Utah Valley University custodian of records, 800 W University Parkway, Orem	n/a	No public subpoena to the university
Parallel GRAMA request, Utah Code § 63G-2	UVU GRAMA records officer; internal appeal to the Chief Administrative Officer	n/a	A Judicial Watch requester's parallel GRAMA appeal is Case No. 2026-004
Subpoena to a third-party utility	Rocky Mountain Power and Dominion Energy Utah, consumption series for the service address	n/a	No public subpoena
GRAMA plus subpoena to the city	Orem City — municipal water, sewer and refuse account; rental-dwelling licence; code file	n/a	No listing, licence or code file has surfaced
Cross-examination, subject not reached in the certified record	David Hull, Sgt., State's case agent on UVU surveillance and identification	Yes — July 6 and 7, 2026	Days 1-3 are not certified; we cannot say what was asked
Cross-examination, subject not reached in the certified record	Jennifer Faumuina, SBI crime-scene sergeant	Yes — July 7 and July 9, 2026	Certified Day 4 holds no line on any off-campus property
Direct examination — the same argument, at a different address	Caitlin Oliver, ATF DNA examiner, called by the defense	Yes — July 10, 2026	Examined on multi-occupant household DNA transfer; certified Day 5

Schedule A — the rider we would attach. Written as it would be served, for the period January 1, 2024 through December 31, 2025, for the real property at 691 West 925 South, Orem, Utah 84058, Utah County serial 36:443:0006:

Acquisition and account. The purchase file, the recorded warranty deed and closing documents, and the internal department, cost centre or account under which the property is carried on the institution's books, together with the name of the department that administers it.
Occupancy. All records identifying any person authorised by the institution to occupy, enter, reside at or use the property, including residency agreements, licences, use agreements, leases, sublicences, visiting-scholar or guest-housing assignments, contractor lodging arrangements, and any waiver or exception granted.
Booking and assignment. All reservation, booking, scheduling or event-assignment records for the property, in whatever system they are kept, including cancelled and amended bookings and the deletion or amendment log for that system.
Keying. The key register for the property: every key and fob issued, to which role, on what date, returned on what date, plus every rekey, core change and lock-hardware work order.
Electronic access control. The complete card-reader and electronic-lock event log for every door on the property, if the property is on the institution's access-control platform; the platform's name and vendor; its configured retention period; and its audit log of administrative changes to credentials and permissions.
Work orders and maintenance. The full computerised-maintenance-management-system history for the property, including cleaning, turnover, landscaping, alarm, HVAC, plumbing and grounds tickets, with the requesting department and the completion note on each.
Utility accounts and consumption. The account records and the full interval or monthly consumption series for electric, natural gas, municipal water, sewer, refuse and any telecommunications or internet service at the address, together with the retention schedule that governs them.
Parking and vehicles. All parking permits, permit applications, licence plates and vehicle registrations associated with the property or with any person authorised to occupy it, and any citation or tow record at or referencing the address.
Insurance and risk management. The risk-management file for the property, including the schedule of insured locations, any coverage description, any inspection report, and any claim or incident notice.
Cameras. An inventory of every institutional camera whose field of view includes the property, its frontage on West 925 South, or the driveway; the retention period configured on each; every retention or litigation hold applied to any of them since September 10, 2025; and any footage preserved from the period September 8 through September 12, 2025.
Custodian declaration. A written certification of the custodian of records complying with Utah Rule of Evidence 902(11), so the production is self-authenticating as a record of a regularly conducted activity under Rule 803(6) and no live witness is needed to put it in front of a jury.
A privilege and classification log. For anything withheld or redacted, the specific GRAMA subsection or other authority relied on, item by item — the same discipline the university applied to its own supplemental production in Case No. 2026-004.

The utility consumption series deserves its own paragraph, because it is the best item on the list. It is held by a third party, not by the institution whose conduct is in question. It is machine-generated — a meter writes it, nobody types it. It is kept for billing, not for litigation, so it was never curated with this case in mind and there is no motive anywhere in its chain to shape it. It has a long retention period because it is an accounting record, which means it is one of the very few items on this rider that is as obtainable today as it was in September 2025. 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. Electric and gas service at this address is investor-owned — Rocky Mountain Power and Dominion Energy Utah — so those two series need a subpoena, not a records request. The municipal water, sewer and refuse account sits with Orem City, which is a public body, so GRAMA reaches it, though customer detail may be classified private and require the subpoena anyway. That is exactly the sort of evidence a defense reasoning up from physical facts reaches for first, and it is the reason this instrument sits so high on the reachability list.

Item 10, the camera item, is the one with a deadline that has already passed, and it is worth being blunt about why it was on the day-one list. Mainstream reporting described ATF and local police going door to door through this neighbourhood in the days after September 10, 2025, collecting home-surveillance and Ring footage, and a homeowner on those streets later spoke publicly about the camera of his that recorded a figure walking toward campus. So the block was camera-covered and the block was canvassed. What no public record establishes is whether 691 itself was canvassed, whether any collected camera faces its driveway, or whether the university had a camera of its own with a view of that frontage — and a camera the institution owns is a different question from a camera a neighbour owns, because the institution is a public body with a records officer and a retention schedule and a legal duty to answer. The rider asks for the inventory and the retention period even where the footage is gone, because the inventory is a durable record and it proves what could have been preserved.

One absolute constraint governs everything above. Any current or former occupant of this property is a living private person, and this page does not name any of them and does not describe any of them into identifiability. The rider asks the institution for records. It asserts nothing about anybody. If the returns identify a person, that identification is a matter for counsel and the court under seal, not for a public page. Where a returned record is an education record, disclosure runs through the ordinary channel — the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g, and 34 C.F.R. § 99.31(a)(9), which permit disclosure under a lawfully issued subpoena with notice to the student — and that notice requirement is a reason to serve early, not a reason to skip the item.

The Questions That Were Not Asked

Addressed to Sgt. David Hull, the State's case agent on the campus surveillance and identification evidence, who testified on July 6 and 7, 2026:

Sergeant Hull, the geofence warrant in this case draws a polygon that its own affidavit describes as running "north across College Drive to W 925 S street." Who chose that boundary?
At the time that boundary was drawn, did you know that the university owns a house on that street?
Did anyone in this investigation ask Utah Valley University who was authorised to be inside 691 West 925 South on September 10, 2025?
Did anyone request the electronic access-control log for that property?
The affidavit says campus surveillance footage was obtained from the university. Was a written demand ever served for it, or was it handed over informally?
Was any litigation hold placed on university camera retention, and if so, on which cameras and on what date?
Was the door-to-door camera canvass in that neighbourhood logged address by address, and does 691 appear in that log?

Addressed to the custodian of records for the university, at a hearing on the return:

Which department of the university administers this property, and who signs its work orders?
Is this property on the campus electronic access-control system, and if it is, for how many days does that system retain a card-reader event before it is overwritten?
Was any retention hold placed on that system after September 10, 2025?
Does the institution hold a booking, reservation or guest-housing record for this property for any date in September 2025?
When was the last key or fob issued for this property before September 10, 2025, and when was the last one returned?
Did the institution receive any request from any law-enforcement agency, state or federal, for records concerning this property, and if so, when?

Addressed to the utility records custodians, on the return of the third-party subpoenas:

For the service address 691 West 925 South, Orem, what was the billed electric consumption, month by month, from January 2024 through December 2025?
Does your system retain interval data — hourly or fifteen-minute reads — for that meter, and for how long?
Was there any period in that range during which service was disconnected, suspended, placed on a vacancy rate, or billed at a minimum charge with no consumption?
In whose name was the account held, and did the account holder change at any point in that range?
Has any other party requested these records for this address since September 10, 2025?

Why A Defense Attorney Would Want This

Day-one date: 2025-09-15 for the GRAMA request and the third-party preservation letters; 2025-09-17 for the Rule 14 subpoena, the day after the first appearance. In mid-September 2025, every item on the rider was still live. Campus access-control platforms are commonly configured to retain card-reader events for 30 to 90 days, and university video systems commonly retain for 14 to 30 days — neither figure is a fact about this institution's configuration, which is itself an item on the rider. Served on September 17, 2025, a demand catches the September 10 swipe log with room to spare and catches September 10 video at the outer edge of an ordinary retention window. Served today, on September 1, 2026 — almost twelve months later — the swipe log is gone, the video is gone, and what survives is the paper: deeds, work orders, key registers, insurance files, parking permits, and the utility series. That is still a great deal. It is not what was there in September 2025, and the difference is entirely a function of when somebody asked.

A capital defense wins by breaking the causal chain or by showing the jury that the process it is being asked to trust cannot be inspected. This instrument serves the second route, and it serves it whether or not it produces a single document, because a refusal is also an answer. Three outcomes, and all three are useful. If the returns show an ordinary university-owned house — vacant, or used for the guest housing the trustees described in 2019 — the staging allegation is answered on paper and the defense stops spending money on it, which is worth having. If the returns show occupancy in the relevant window that nobody has ever accounted for, the defense has an off-campus location inside the State's own geofence with people in it and no investigative file. If the institution says the records do not exist, or the retention already ran, the defense can put in front of a jury that a homicide investigation drew a search boundary through a street, and that nothing produced in discovery shows the owner of the house on that street ever being asked what its own records said.

Written as counsel would say it to a jury, it is one sentence, and it is a sentence about the investigation rather than about any theory: "On September 11 they drew a map, and the map ran up this street, and they asked a search engine who was standing on it. Now look through everything they gave us and find me the page where anybody asked the university that owns the house on that street to open its own file." That argument needs no alternative perpetrator, no expert, and no contested science. It needs only the returns, or the absence of them, and either one is admissible.

It is also cheap and it is easy to grant. It asks a public institution for the sort of document every landlord in the country keeps. It touches nothing classified. It does not require the FBI to disclose anything. It does not require the court to rule on a constitutional question. A judge who would never order a federal agency to answer a subpoena signs this one from the bench — which is precisely why an instrument this modest should not be the last one tried.

Be exact about what this can and cannot show, because the temptation to overreach here is real. Occupancy records establish who was authorised to be somewhere. They do not establish who was actually there — an authorisation is a permission, not an observation, and a card-reader event proves a credential was presented, not who was holding it. And nothing in this rider establishes what anybody did. A person lawfully housed in a university guest property in September 2025 has done nothing, and the records would look identical either way. Any page or argument that slides from "authorised" to "present" to "involved" has stopped doing law and started doing insinuation, and a jury can feel the difference.

The Honest Counterargument

The most likely truth is the boring one, and it fits every document already in hand. 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 the assassination happened a quarter-mile away is a fact about the campus, not about the house, and thousands of homes sit near a university. The claim that anything was staged from this address is, in the master file, a single unsourced, undated sentence with no named author and no described evidence — and this exercise should be candid that a subpoena rider is a heavy instrument to hang on that sentence.

The block-level evidence also belongs to a different address, and this exercise should not blur them. What is in the court record is Ring or Nest video from 680 West 925 South showing a vehicle consistent with the grey Dodge Challenger parking across the street at about 00:30 on September 11, 2025. That is 680, not 691, and it is a car on a street rather than a person in a house. A citizen video that places a Challenger at the university-owned property has not been produced frame by frame for these pages and may simply be a retelling of the 680 footage. If the strongest on-block fact in the case file is about a neighbour's camera, then the honest description of this rider is that it is a reasonable line of inquiry on a street the State itself fenced, not the pursuit of a known lead. Reasonable lines of inquiry are worth serving. They are not worth overstating.

Counsel may also already hold the answer. The State's discovery production in this case is enormous — 45 productions through August 2026, 29,237 files, a 12.1-terabyte drive, more than 25,000 cell-site location records. If the university's property file is somewhere in that corpus and 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.

There is a timing objection too, and it is a real one. The case has not been bound over; oral argument on bind-over was set for September 1, 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 remind all parties that this was a probable-cause hearing and lodging a standing relevance objection to material it said exceeded that scope. Spending the court's patience on a university's key register before the case has cleared that threshold is a defensible thing to decline to do. Holding a third-party records demand until the trial phase is a strategic choice, not a lapse.

A rider this broad also invites a motion to quash, and the objection would have force. Utah Rule of Criminal Procedure 14 lets a court quash or modify a subpoena where compliance would be unreasonable or oppressive, and a demand for two years of every work order, every card swipe, every parking permit and every insurance file for a single house is exactly the shape a court calls a fishing expedition — particularly where the stated basis is one unsourced sentence. The honest answer is to serve it narrow and grow it: items 1, 2, 5, 7 and 11 first, tied to a defined window of September 1 through September 30, 2025, with the rest reserved for a supplemental rider if the first return shows anything. A subpoena that survives is worth more than a subpoena that is right.

And the strongest objection of all: the perishable half of this rider is already gone. If the swipe log and the frontage video are past retention, then most of what made this instrument urgent expired in the autumn of 2025, and what remains — deeds, work orders, 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.

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.

The One Thing We Would Do Differently​

What The Defense Team Did Instead​

Where This Belongs In The Case​

Witness Or Discovery Target​

The Questions That Were Not Asked​

Why A Defense Attorney Would Want This​

The Honest Counterargument​

Sources On This Site​