FILED

1 CARSON CITY DISTRICT ATTORNEY

JASON D. WOODBURY
2 District Attorney
Nevada Bar No.: 6870
3 885 East Musser Street, Suite 2030
Carson City, Nevada 89701
4 T: 775.887.2072
5 F: 775.887.2129
jwoodbury@carson.org
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8 IN THE JUSTICE COURT OF CARSON TOWNSHIP

9 IN AND FOR CARSON CITY, STATE OF NEVADA

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In re:
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~~§~ The Coroner of Carson City's CASE NO.:
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~t; inquest concerning the death of
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CLINT GARETT MALONE. DEPARTMENT:
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~"' 16 PETITION FOR CORONER'S INQUEST
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17 COMES NOW, Jason D. Woodbury, CARSON CITY DISTRICT ATTORNEY, in

18 the name of and by the authority of the STATE OF NEVADA, and petitions this Court

19 to convene and preside over a coroner's inquest concerning the death of CLINT

20 GARETT MALONE in Carson City, State of Nevada, on or about February 15, 2020.

21 This Petition is made pursuant to NRS 259.050(5) and CCMC 9.13.200(2) and is based

22 on the following :

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 1 1. Pursuant to NRS 259.050, with the assistance of the Carson City Sheriffs

2 Office, 1 I have made an investigation into the death of CLINT GARETI

3 MALONE which occurred on February 15, 2020 in Carson City.

4 2. NRS 259.050(5) provides: "[T]he holding of a coroner's inquest is within the

5 sound discretion of the district attorney or district judge of the county."

6 3. Based on the investigation in this matter, I have determined a coroner's

7 inquest would be appropriate under the circumstances and hereby request

8 that this Court convene and preside over a coroner's inquest in accordance

9 with NRS 259.050- .145 and CCMC 9.13.200- .290.

~ 10 4. Based on the investigation, I am aware of the following individuals who have

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13 CARSON CITY CORONER WITNESSES:
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:;3 ~ :! 14 • Ruth Rhines, SENIOR DEPUTY CARSON CITY CORONER
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~ j ~ 15 Expected subject of testimony: Senior Deputy Rhines participated in the

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16 investigation of the circumstances incident that resulted in the death of

17 CLINT GARETI MALONE.

18 • Sue Cocking, DEPUTY CARSON CITY CORONER

19 Expected subject of testimony: Deputy Cocking participated in the

20 investigation of the circumstances of CLINT GARETI MALONE's death.

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The Sheriff of Carson City is the Carson City Coroner as well. NRS 259.020; CCMC 9.13.020(3).
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 1 LAW ENFORCEMENT WITNESSES:

2 • Sgt. Steven Olson, CARSON CITY SHERIFF'S OFFICE

3 Expected subject of testimony: Sgt. Olson was the lead detective in the

4 investigation of the circumstances of CLINT GARETT MALONE's death .

5 • Sgt. Morgan Tucker, CARSON CITY SHERIFF'S OFFICE

6 Expected subject of testimony: Sgt. Tucker assisted Sgt. Olson's

7 investigation of the circumstances of CLINT GARETT MALONE's death.

8 • Sgt. David LeGros; Sgt. William Richards (Ret.); Detective Brett

9 Bindley; Deputy Christopher Arrison; Deputy Myles Foutz; Deputy

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~~ Bruce Pendragon; and Deputy Ben Stryffeler, CARSON CITY

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that resulted in the death of CLINT GARETT MALONE and participated
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17 in the investigation of that incident.

18 • Deputy Gage Mead, CARSON CITY SHERIFF'S OFFICE

19 Expected subject of testimony: Deputy Mead recovered a black folding

20 knife and set of keys from Derek Sheldon.

21 • Records Custodian, CARSON CITY SHERIFF'S OFFICE DISPATCH

22 CENTER

23 Expected subject of testimony: The records custodian of the Carson City

24 Sheriffs Office Dispatch Center may provide and authenticate recorded

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 1 communications relating to the incident that resulted in the death o

2 CLINT GARETI MALONE.

3 EXPERT WITNESSES:

4 • Henry McNett, M.D., WASHOE COUNTY REGIONAL MEDICAL

5 EXAMINER'S OFFICE

6 Expected subject of testimony: Dr. McNett performed the autopsy on

7 CLINT GARETI MALONE on February 18,2020.

8 • Laura M. Labay, Ph.D., NMS LABS

9 Expected subject of testimony: Dr. Labay completed a toxicological

analysis of blood samples collected from the body of CLINT GARETI

MALONE during Dr. McNett's autopsy.

• Kolby Hicks, Criminalist, CARSON CITY SHERIFF'S OFFICE

Expected subject of testimony: Criminalist Hicks was the assigned

criminalist who photographed and collected evidence from the scene o

the incident which resulted in the death of CLINT GARRET MALONE and
w"'"' who observed, photographed, and collected evidence from the autopsy
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17 of CLINT GARRET MALONE.

18 OTHER WITNESSES:

19 • Larry Arnold

20 Expected subject of testimony: Upon information and belief, Mr. Arnold

21 had a physical altercation with CLINT GARETI MALONE and stabbed

22 him multiple times with a sharp instrument, causing his death.

23 • Amber Arnold

24 Expected subject of testimony: Upon information and belief, Amber

25 Arnold is the spouse of Mr. Arnold and was present during all or some of
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 1 the alleged altercation between Mr. Arnold and CLINT GARETT

2 MALONE.

3 • Antonia Martinez Acosta

4 Expected subject of testimony: Upon information and belief, Antonia

5 Martinez Acosta resided near the Arnold residence on the night of the

6 incident which resulted in the death of CLINT GARETT MALONE and

7 had an encounter with CLINT GARETT MALONE shortly before the

8 incident that resulted in his death.

9 • Ashley Combest; S.C. (a minor with a date of birth in July, 2005;

brother of Ms. Combest); Austin Healy; Lyndsay Meservey; Joey

Porter; Lily Porter

Expected subject of testimony: Upon information and belief, Ms.

Combest, S.C., Mr. Healy, Ms. Meservey, and Mr. Porter encountered

CLINT GARETT MALONE at a party he attended shortly before the

incident that resulted in his death.

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• Yuleidy Chavarria-Altamirano; Michael Garcia; Carol Kneese
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17 Expected subject of testimony: Upon information and belief, Mr. Garcia,

18 Ms. Chavarria-Altamirano, and Ms. Kneese encountered a person

19 matching the description of CLINT GARETT MALONE after he left the

20 above-referenced party and before the incident that resulted in his death.

21 • Derek Shelton

22 Expected subject of testimony: Upon information and belief, Mr. Sheldon

23 recovered a knife and set of keys while removing furniture from the

24 location of the incident resulting in the death of CLINT GARETT

25 MALONE.
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 1 • Tashina Wugnema

2 Expected subject of testimony: Upon information and belief, Tashina

3 Wugnema was involved in a relationship with CLINT GARETT MALONE

4 at the time of the incident and attended the party preceding the incident

5 with CLINT GARETT MALONE_

6 • Katrina Malone

7 Expected subject of testimony: Upon information and belief, Katrina

8 Malone is the purported ex-spouse of CLINT GARETT MALONE, was

9 interviewed by Sgt. Olson during the investigation, and claims to have

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..... 10 information material to the incident that resulted in the death of CLINT
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II) Expected subject of testimony: Upon information and belief, Ms_ Gascon
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encounters and communications between Larry Arnold, associates of Mr.
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17 Arnold, and CLINT GARRET MALONE that preceded the incident

18 resulting in his death .

19 5. Based on the investigation, I am aware of 103 items of evidence which are

20 or may be relevant to the issues to be addressed at the coroner's inquest in

21 this matter. A more particular description of these exhibits is reflected in the

22 Initial List of Exhibits which is attached hereto and marked as Exhibit 1.

23 6_ Based on the number of exhibits, the number of witnesses and the extent o

24 their expected testimony, I estimate the duration of the coroner's inquest in

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 1 this matter to be approximately three days, not including time necessary for

2 deliberations of the jurors.

3 WHEREFORE, Petitioner, Jason D. Woodbury, CARSON CITY DISTRICT

4 ATTORNEY, respectfully requests that this Court issue an order convening a coroner's

5 inquest concerning the death of CLINT GARETI MALONE over which this Court will

6 preside.
7 DATED this 13th day of January, 2021.
8 CARSON CITY DISTRICT ATTORNEY

istrict Attorney
Nevada Bar No.: 6870
885 East Musser Street, Suite 2030
Carson City, Nevada 89701
T: 775.887.2072
F: 775.887.2129
jwoodbury@carson.org
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 1 VERIFICATION

2 1. I, JASON D. WOODBURY, declare:

3 2. I am the District Attorney of Carson City, State of Nevada.

4 3. I verify that I have read the foregoing Petition for Coroner's Inquest and that

5 all factual representations contained therein are true of my own knowledge,

6 except for those matters therein stated on information and belief, and as to

7 those matters, I believe them to be true.

8 I declare under penalty of perjury of the laws of the State of Nevada, that the

9 foregoing in true and correct.

DATED this 13th day of January, 2021 .

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 In re: The Coroner of Carson City's inquest
concerning the death of CLINT GARETT MALONE

Justice Court of Carson Township

in and for Carson City, State of Nevada

Petition for Coroner's Inquest

Exhibit Index

Exhibit No. Description Pages

1 Initial List of Exhibits 4

(proposed)
EXHIBIT 1

EXHIBIT 1
 INITIAL LIST OF EXHIBITS

No. '. : .\1 - ~.-

Nature of Exhibit DescfiiJ1tion of Ext1ibit

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1 large mounted photo Map of 900 block of Woodside Drive
2 Photo Deceased's Nevada driver's license
3 Photo Deceased (face)
4 Photo Deceased (profile)
5 Photo Deceased's shirt
6 Video recording 999 Woodside Drive #1 08 surveillance footage
7 Audio recording Martinez call to emergency dispatch
?A Document Transcript of Martinez call to emergency dispatch
8 Photo Exterior of 957 Woodside Drive (1 of 2)
9 Photo Exterior of 957 Woodside Drive (2 of 2)
10 Photo Cars in driveway adjacent to 957 Woodside Drive
11 Photo Eyeglasses on ground, distant
12 Photo Eyeglasses on ground, close
13 Photo Front of eyeglasses
14 Photo Side of eyeglasses
15 Item Evidence container with eyeglasses
15A Item Eyeglasses
16 Audio recording Arnold call to emergency dispatch
16A Document Transcript of Arnold call to emergency dispatch
17 Photo Exterior of 973 Woodside Drive (1 of 4)
18 Photo Exterior of 973 Woodside Drive (2 of 4)
19 Photo Exterior of 973 Woodside Drive (3 of 4)
20 Photo Exterior of 973 Woodside Drive (4 of 4)
21 Photo Entry to 973 Woodside Drive
22 Photo Interior of 973 Woodside Drive bottom floor (1 of 6)
23 Photo Interior of 973 Woodside Drive bottom floor (2 of 6)
24 Photo Interior of 973 Woodside Drive bottom floor (3 of 6)
25 Photo Interior of 973 Woodside Drive bottom floor (4 of 6)
26 Photo Interior of 973 Woodside Drive bottom floor (5 of 6)

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 INITIA L LIST OF EXHIBITS

NO'. Nature ef Extrtibit .E D es cr-i~ti o n of Exhibit I

27 Photo Interior of 973 Woodside Drive bottom floor (6 of 6)

28 Photo Interior stairs in 973 Woodside Drive
29 Photo Interior of 973 Woodside Drive toward front entry
30 Photo Larry Arnold full body
31 Photo Larry Arnold right palm
32 Photo Larry Arnold right palm with measurement
33 Photo Larry Arnold back of both hands
34 Photo Larry Arnold back of left hand
35 Photo Larry Arnold back of right hand
36 Photo Larry Arnold injury to back of left hand
37 Photo Larry Arnold injury to hand with measurement
38 Photo Larry Arnold left palm up
39 Photo Larry Arnold injury to left side of midsection, distant
40 Photo Larry Arnold injury to left side of midsection, close
41 Photo Larry Arnold injury to left midsection with measurement
42 Photo Larry Arnold jacket front
43 Photo Larry Arnold jacket back
44 Item Evidence container with Larry Arnold jacket
44A Item Larry Arnold jacket
45 Photo Larry Arnold shorts front
46 Photo Larry Arnold shorts back
47 Item Evidence container with Larry Arnold shorts
47A Item Larry Arnold shorts
48 Photo Knife on counter, angle 1
49 Photo Knife on counter, angle 2
50 Photo Knife, close
51 Photo Knife with measurement
52 Item Evidence container with knife
52A Item Knife

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 INITIAL LIST OF EXHIBITS

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No. ~ature of Exhibit" Descr.i~tion of Exhillit
53 Video recording Deputy Pendragon body-worn camera footage
54 Video recording Deputy Arrison body-worn camera footage
55 Video recording Deputy Gault body-worn camera footage
56 Video recording Deputy Foutz body-worn camera footage
57 Video recording Deputy Loyola body-worn camera footage
58 Video recording Sgt. Richards body-worn camera footage
59 Document Crime scene log
60 Photo Decedent's shirts and knife sheath
61 Photo Decedent's shirts
62 Photo Deceased's shirt, back
63 Photo Deceased's shirt, back with measurements (1 of 2)
64 Photo Deceased's shirt, back with measurements (2 of 2)
65 Item Evidence container with deceased's shirt
65A Item Deceased's shirt
66 Photo Deceased's undershirt, front
67 Photo Deceased's undershirt, back
68 Photo Deceased's undershirt, back, close
69 Photo Deceased's undershirt with measurements (1 of 2)
70 Photo Deceased's undershirt with measurements (2 of 2)
71 Item Evidence container with deceased's undershirt
71A Item Deceased's undershirt
72 Photo Knife sheath (1 of 3)
73 Photo Knife sheath (2 of 3)
74 Photo Knife sheath (3 of 3)
75 Item Evidence container with knife sheath
75A Item Knife sheath
76 Photo Redskins lanyard
77 Item Evidence container with Redskins lanyard
77A Item Redskins lanyard

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 INITIAL LIST OF EXHIBITS

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No. Natl!lre of. Exhibit Qes cri ~tion of Exhibit
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78 Photo Coffee table, distant
79 Photo Coffee table, close
80 Photo Keys, side one
81 Photo Keys, side two
82 Item Evidence container with keys
82A Item Keys
83 Photo Black knife, closed
84 Photo Black knife, open
85 Item Evidence container with black knife
85A Item Black knife
86 Item Evidence container with black cell phone
86A Item Black cell phone
87 Photo Deceased's back at scene
88 Photo Deceased's back
89 Photo Deceased's back, cleaned
90 Photo Wounds A-D, unlabeled
91 Photo Wounds A-D, labeled
92 Photo Wound A
93 Photo Wound B
94 Photo Wound C
95 Photo Wound D
96 Photo Wounds E and F, unlabeled
97 Photo Wound E, labelled
98 Photo Wound F, labelled
99 Photo Deceased's left profile, head and shoulder
100 Photo Wound below decedent's left ear
101 Photo Wound G, labelled, distant
102 Photo Wound G, labelled, close
103 Document Autopsy Protocol