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CROSS JO LUNA

Prosecution
● Attack credibility/Impeach
○ Mr. Luna, you grew up with Mr. Kuang right?
■ Yes, I …
○ You received funding for your education from the Ashlock crime family right?
■ Yes
○ Mr. Luna, you were close with Mr. Kuang when growing up with him, correct?

○ And you are currently not being paid for your testimony right?
■ No
○ How many cases have you personally worked on involving the members of the crime
family
a. If they say not that many or unsure - But on your witness statement you stated,
¨Just over half of the cases I have personally worked on have involved some
member or 29 members of the Ashlock family.
○ If they say the correct answer, move on.

○ Dr. Luna, you most often testify for the defense right?
■ -if they say an unsure answer saying no or anything other than a yes say- But
according to your witness statement you said, I quote “We most often testify for
defense” of course referring to your time at Moorhead Mueller and Consulting.
■ If they say yes ask- And in your witness statement you said and I quote, ¨. I am
consulting for this case as a personal favor to Jay Kuang.” correct?
○ And half of those defense cases were with the Ashlock crime family, correct?
■ yes
○ Interesting, and you have been involved in many cases involving the Ashlock crime
family correct?
■ If they say yes - ask next question
■ If they say more then skip next question


Redire

Thank you. I would now like to redirect you attention to your professional work.

You wrote a paper on the bias towards prosecution in toxicology consulting, correct?
This paper criticizes the role of the prosecution in toxicology consulting, correct?

I want to be clear that this fatal level of BAC is extremely uncommon, and it would take the
average person around 30-40 drinks to reach that threshold of 0.60%.
I am aware that there was heavy drinking at the festival on the night of August 1st; however, I
am unaware whether or not all three of the deceased council members were partaking, and, if
so, to what extent

So then you agree with Dr. Kodatt that alcohol poisoning is uncommong

33 minutes
DIRECT ALI KODATT
Prosecution
● Establishing Credentials
○ Where did you receive your education?
■ I received a Bachelor's degree of Chemistry from the University of Alabama in
1993 and my Doctorate of Medicine at Tulane University in 1997.
○ Can you state your relevant professional experience?
■ I have been the medical director and physician of Little Hamlet General since
2013 with a specialty in toxicology. From 2005-2013 I worked as a toxicology
and medical specialist in Boston at the Massachusetts State Forensic Laboratory,
and between 2000 and 2005, I worked as an educator and lecturer at Tilly
Medical School on toxicology.
○ Do you have any relevant affiliations or memberships?
■ Sure, between 2001 and 2003 I was in the John Hopkins fellowship in medical
toxicology and between 1997 and 200, I was a resident in general practice at
Aurora St. Luke’s Medical Center in Wisconsin. As for professional
memberships, I am a fellow of the American College of Medical Toxicology and
a member of the Association of Rural Physicians.

● Have you ever met the defendant Jay Kuang?


a. Yes I’ve met him several times
● What was the first time?
a. When one of the locals, Mr. Moon fell sick to a gas leak, Mr. Kuang assisted me in
treating him?
● In what way?
a. He seemed to know a lot about the treatment, it was carbon monoxide poisoning, he
helped in assisting as he got a respirator for treatment.
● Would you say he seemed experienced in the topic as if he had done it before?
a. Yes very
● What was your second interaction with Kuang?
a. His dog Dendro fell ill
● Were you able to diagnose it?
a. I figured out that it was poisoning but I wasn’t able to decipher what kind.
● Do you think it could have been cyanide poisoning?
a. Yes, possibly
● And, Dendro, the dog, how would he most likely have been exposed to it?
a. Most probably, first hand
-------------
○ Dr. Kodatt are you familiar with the autopsy report conducted by yourself.
■ Yes I am
■ If we get down pretrial
○ Your honor id like to show the witness people’s exhibit 14 which was pre admitted during
pre trial matters
○ the autopsy report created by Dr. Kodatt as Prosecution Exhibit 14.
○ Your Honor May I bring into evidence the autopsy report created by Dr. Kodatt as
Prosecution Exhibit 14.
○ Are you the custodian of this public record”
○ “Is this your signature?”
○ When did you make this record
■ On the night the council members died (this is really important make sure
they say this exactly)
○ And are these types of reports standard practice for your office?
■ Yes
○ And do your duties include doing autopsies
■ Yes
○ And has this document been altered since you last saw it?
■ No
■ Everything above this point is the spell to summon this evidence into court.
Really important both you and your witness say these words exactly or else
you’re going to have a harder time bringing in the report
○ If yes and no objections: your honor I’d like to enter this document into evidence via
rule 902(11) as a self-authenticating document because it complies with the
requirements of rule 803(6)a-c
Okay thank you
- (IF THIS DOESNT WORK) below
■ Do you recognize this document
■ yes
■ What is it?
■ An autopsy report
■ Where did you get this document when you saw it before?
● Remember, Kodatt is the custodian of records here, he’s basically
saying he got it from himself
● Basically you want to have them say “well of course I’ve seen this
document before, i wrote it.”
■ Has it changed since you last saw it?
■ Might be able to do a 902 self-authenticating document argument to get past
all this. Look at rule 902(4) and see if you think that the autopsy report is a
certified copy of a public record
● If so, all you need to ask is “are you the custodian of this public
record” and “is this your signature?”
○ How are you apart of this case
○ Are there any standard methods you used to generate this autopsy report
■ Yes and i followed them
○ Are these methods common in the toxicology field?
■ Absolutely, these are the standard in analytical methods utilized in detecting
poisonings.
○ What are those methods
■ Look at the body for signs for cause of death
■ Then urine tests
■ Then blood tests
○ Did you follow those methods?
■ The bodies had the following symptoms….
■ Then i used urine tests
○ Dr. Kodatt how exactly did you conduct the autopsy on the deceased victims?
■ I used several methods applied in the field of toxicology.
○ Dr. Kodatt what is the standard acceptable cyanide content for an average person?
■ The WHO standard for acceptable cyanide is about .5 mg/L
○ What level did you find in the victims?
■ A level of .9 mg/L
○ What was your conclusion based on the autopsy
■ It was cyanide poisoning
○ And Dr. Kodatt what are the symptoms of cyanide poisoning?
■ IF OBJECTED WE'VE SET THE FOUNDATION THAT dR. LUNAIS A
QUALIFIED MEDICAL EXPERT AND ESTABLISHED APART OF
KODATTS EXPERIENCE AND TRAINING HE HAS CERTIFICATIONS IN
TOXICOLOGY
■ WHAT METHODS ARE USED TO DETERMINE POISONING
■ ARE THESE METHODS WIDELY USED IN THE MEDICAL COMMUNITY
■ DID YOU USE THESE METHODS
■ Blue tinge, decreased oxygen flow to the tissue, muscle spasms, lactic acid
buildup, pink lividity
○ How is cyanide most effectively administered?
a. It can come in all shapes and forms, but to be ingested and take effect it would be
in food or drink.
○ Is there any possibility that cyanide poisoning could occur other than being directly
administered?
a. Many common fruits such as apple seeds, and apricot pits contain cyanide but the
odds of such a death occurring would require hundreds of pits or seeds consumed
leaving chances to be very unlikely.
○ Now Dr. Kodatt are there any likely alternative possibilities to explain the deaths of the
council members?
■ Based on my past experiences in Little Hamlet carbon monoxide poisoning could
be argued for
○ Are there any other possibilities to explain the deaths of the council members?
■ The only other likely cause that comes to mind is alcohol poisoning.
○ Are there any reasonable conclusions that lead to alcohol poisoning?
■ Although there was heavy drinking throughout the festival, fatality from alcohol
is an extremely uncommon occurrence as council members would need a 0.8%
Blood to Alcohol content to even reach dangerous levels
○ And how much alcohol would the council members have to consume in order to prove
fatal?
■ Around 30-40 bottles of alcohol would need be consumed
○ Did you notice these levels of intoxication within the deceased?
■ No I did not
○ DR KODATT IN YOUR PROFESSIONAL OPINION WHAT IS THE MOST LIKELY
CAUSE OF IN THIS CASE

No further questions

Re-Direct:

Dr. Kodatt are you experienced in the methods and procedures used in autopsies?

Did you have adequate materials to conduct autopsy reports in little hamlet .
Have you practiced an autopsy beforeautopsy s?

Have you ever published any research on toxicology?


- NAME DROP THE PUBLICATIONS from resume

Did these publications detail methods used in autopsies?

Does published medical research require extensive expertise?

In your expert opinion, could you have published medical research without fully understanding
the subject?experience or strong qualifications?

No further questions
Direct Nickson
Prosecution
● Introduction
○ Are you a resident within Little Hamlet
■ Yes, I am
○ What is your occupation within Little Hamlet?
■ I am the only sheriff and law enforcement officer in town
○ Have you had any interactions with the defendant Mr. Kuang, prior to his arrest?
■ Yes
○ Sheriff Nickson, can you please describe your first interaction with Mr. Kuang?
■ Yes, I first met kuang when he arrived in his car on May 1, 2021. Since little
hamlet is a small town outside of tilly there's only one entrance in which i'm
usually posted by. The moment I laid my eyes on Kuang I did not like him. I first
saw his dog in the car and was immediately disgusted. I have nothing against
dogs but Jay´s was ugly, smelly, and way too hairy. He also began telling me his
plans to set up a restaurant on 5th Street. That was the restaurant my closest
friend Ellyson Allen used to own before she passed away. I knew Jay was only
here to make trouble for my town, and to this very moment I know it was a
mistake to let him in.
● Find transition question
○ What led you to the decision to attend the festival?
■ There were a large number of people attending the event and I was posted to keep
peace within the square, so this ended up pulling me away from my usual post at
the entrance of the town.
○ And at the festival did you see the council members interacting with Mr. Kuang?
■ Yes, the council members told Jay how they did not like his food and it was
obvious that Jay was furious. There was a heated discussion since many of the
council members had also been drinking a lot that night. The council members
began insulting Jay, specifically talking about his dog and as I remember Jay
Kuang told them that they should disappear and if they wanted poison, it could be
arranged.
● Transition question
○ After seeing the heated debate between the defendant and the council members, how did
the issue dissolve?
■ Kuang left in a very mad manner and I could tell that he was furious, I wanted to
follow him but the council members asked me to stay to help clean up the broken
glass.
○ Did Kuang return to the scene after?
■ Yes Jay came back with his last course, it was a

Did they appear to be queasy?

● Was by himself for the last course of the meal (COULD HAVE COMMITTED THE
CRIME AND TRY TO GET AWAY WITH IT *CONDUCT*)

Cross Jay Kuang


Prosecution
- Focus on the negative interactions he had with the council members
- Pick at the reasons they hated him and the nasty things they said to him
- Get im to agree with those things on the record
- ^^use it in your closing to how mean

Braden Benjamin Direct

Good evening/morning Mr. Benjamin


1. Are you currently employed?
a. Yes i’m a council member in LH
2. And how long have you done that?
a. About 20 years
3. What made you decide to be on the council for so long?
a. As a direct descendant of the founding fathers of Little Hamlet, I strive to
uphold my family’s legacy and give back to the community I so love.
4. So is it fair to say that you knew the other members fairly well?
a. Yes
5. Can you describe your relationship with the other council members
a. Debnath and I were cordial but had our disagreements. She called me nepo
baby. Maloney and I grew up together so we know this town and its history
really well. Finally Shapiro was a good person, but would sometimes get
locked into analysis paralysis which made it hard to make decisions.
Ok that’s really great. I’d like to turn now to the night of the festival if that’s ok with you? -
- Yeah sure (you don’t really have to answer this, the attorney, can just go to the next
question, this is just to help them frame the exam to help the jury keep up)
6. Mr. Benjamin, did you attend the festival with the other council members?
a. Yes I sat at the same table as them for the majority of the festival.
7. So would you say you were in a good position to see and hear what was going on
that night?
a. Absolutely
8. And did you see Jay Kuang that night?
a. Yes i did he came over to our table a few times throughout the night
9. And what happened during those interactions
a. Talk about how Jay blew up at the council members and called them
heartless pigs and said they could be poisoned and stuff like that.
10. Did anything else happen during that conversation?
a. Yes he broke a bottle on the ground.
11. Did he say anything after the conversation?
a. Yes he was muttering “If you want poison I’ll give you poison” and “I’ll kill
them” while walking past.
12. And what did you do after that?
a. Me and Natalie got up and left
13. And when you left could you still see the council members’ table?
a. Yes I was still close enough to see what was going on over there pretty well.
14. When did Jay reappear?
a. At about 10 pm he returned with the 3rd course.
15. Did you see Jay interact with the council members?
a. Yes he had a cart of cake that he was wheeling over to them, it was rather
unusual because I never noticed cake being on the menu.
16. What happened in that interaction?
a. He handed out three slices of cake, said something to them and then walked
away.
17. And what did council members do with the cake?
a. They ate it, and looked like they were enjoying it well enough.
i. Last part may get objected to. If so, that’s fine, the important thing is
that they ate it. Yeah ok
18. And what happened then?
a. Well i wanted to talk to Kuang to try and connect on a human level so I went
up to him and asked if he would have a piece of cake with me
19. Did he respond?
a. Yes he said that he was watching his sugar intake, I insisted but he wouldn’t
budge.
b. If this gets objected to as hearsay, say that it’s admissible under rule 801
non-hearsay as an opposing party statement. Do that for any statement
Kuang makes. Ok
c. If for some reason the objection is sustained, then just reask the question like
“without going into specifics, what did he say?”
20. So you didn’t see him eat any cake ever?
a. No i didn’t
21. And was there any cake left over on the cart?
a. Yes there were two pieces left.
22. Did you see Jay after the festival?
a. Yes. He instructed his sous chef, Kat Li, to clean up everything in the square
and leave everything “spotless”.
23. So do you think he threw away the cake that he almost served you?
a. Absolutely. They were very thorough in getting rid of everything
24. No further questions
Only use this opening statement if Nickson is testifying on pros or Kuang is
testifying on the defense. It requires that you get his criminal past out and
Benjamin, Kat, Kodatt, and Luna don’t have that.

At around 10:30pm on August 1 2023 council member Rao Maloney was gasping for
air in her final moments. Her husband frantically on the phone begging for help,
help that would arrive too late to save her. Across town, council members Emily
Debnath and Shapiro were meeting similar fates. What did they all have in
common? Earlier that night, they all got on the bad side of one man: Jay Kuang.
Earlier that night, Kuang had lost his temper and screamed at the council members
when they criticized his cooking. At that moment he made a plan, a plan that would
end with three families losing loved ones and a town losing three of its most
dedicated servants.

But let me tell you about Jay Kuang. He seems like an ordinary guy/girl, a restaurant
owner in LH. But in his past life, he was a poisoner for the Ashlock crime family. He
made it his business to know poisons and deploy them against unsuspecting
targets. For years he plied his craft, until one day, he decided he wanted out. So he
made himself a deal and in exchange for putting the rest of his family behind bars,
he got to start over in LH.

But it seems old habits die hard and when the council members crossed Jay Kuang,
he couldn’t let it slide. Kuang had agreed to cater the LH festival, an act that put
him in direct control of nearly 40 people’s lives. Things seemed to be alright at first.
The first course came and went without incident. But during the second course,
that’s when things changed. Jay Kuang approached the council members and asked
how the food was. All the council members did was say how they really felt- it
wasn’t their favorite. A harmless enough sentiment, but Jay Kuang saw it differently.
He yelled at the council members and stormed off back to his house where no one
could see him to prepare the final course of the evening.

He returned with a cart holding a piece of cake for each council member. What they
didn’t know, was that that slice of cake would be their last. They ate the cake, which
Kuang had laced with cyanide and sure as the sun rises in the east and sets in the
west, they died 30 minutes later.
Jay Kunag, for his part, was adept at covering his tracks from his time with the
Ashlock family and he had almost completely covered any evidence of the crime.
Almost. But bodies don’t lie and our expert, Ali Kodatt is going to show you how
even someone as adept with poisons as Kuang still leaves a trace.

No one deserves what happened to council members Maloney, Debnath, and


Shapiro. And Kuang does not deserve to walk away a free man for his actions. The
law is clear, and the facts will show that Jay Kuang had the requisite intent to kill
and engaged in conduct that caused the deaths of three people. We can’t bring
them back ladies and gentlemen, but we can help LH heal and the only way for LH
to heal is for Jay Kuang to be off the streets. By the end of this trial you will see that
prison is the only place fit for him.
Cross examination of Kat Li (D witness)

Part 1:
1. Good evening/morning Ms. Li
2. You said it’s your dream to become a professional chef right?
3. And you moved to Copenhagen to pursue that dream right?
4. So would you say that being a chef is extremely important to you?
Part 2:
5. So you must have been pretty devastated when your restaurant here in Tilly got shut
down right?
6. You must have been pretty upset when the reviews called your cooking “abysmal”
right?
7. And you didn’t have another job lined up when you met Kuang right?
Part 3:
8. So you met Kuang because he was a regular in your restaurant right?
9. And he told you that he really liked your cooking right?
a. Opposing counsel might object based on hearsay here. If that happens, tell
the judge that this is permissible because it is not hearsay as it is a party
opponent statement (allowed under rule 801) and also that the statement is
not for the truth of the matter asserted, but rather to show her state of mind
and how she felt about Kuang
10. And after your restaurant got shut down Kuang offered you a job at his restaurant as
a sous chef, right?
11. Would you say you owe Jay Kuang for giving you the chance to pursue your dream?
a. Ultimate question ok here because it’s in her statement. If she says yes, move
on. If she says no, then ask “isn’t it true you said in your statement that ‘I
definitely owe it to Jay for giving me the chance to pursue my dreams
further?’ if still no, “would looking at your statement refresh your
recollection?” if yes, show her the statement and point out the area where
she says it and tell her to look up once she’s done reading. Once she does, ask
“does that refresh your recollection.” yes, “alright then is it true that you said
you ‘owe it to jay for giving you another chance to pursue your dreams
further?’
b. If witness keeps answering no and wont give you the obvious answer, move
on. Bring it up in closing.
Part 4:
12. I want to turn to the night of the festival
13. You said you were with Jay the whole time, right?
14. You said you cooked and baked with him all night?
15. But you weren’t able to see him every single second of the night were you?
16. At one point, he left for about 25 minutes right?
17. And you didn’t know where he was then right?
18. But didnt you testify that you were with him the entire night
a. If she answers “he was getting supplies” then ask “ok, what supplies did he
get?” when she answers “I don’t know,” ask “so it’s possible he was doing
something else during that time right?”
19. So he could have been doing anything during that time, as far as you were
concerned right?
20. Also, you said you ate some of the leftover desert right?
21. And that was from the same batch that was served to the council members right?
22. Ok, do you know if anyone saw you eat the cake?
23. So Kuang didn’t see you eat the cake?
24. Nickson didn’t see you eat the cake?
25. Ali Kodatt didn’t see you eat the cake?
26. Braden Benjamin didn’t see you eat the cake?
a. Get through as many of these as you can before the opposing council objects.
If it’s overruled, keep going. If it’s sustained, ask “did anyone involved with
this trial see you eat the cake?”
27. So no one else involved with this trial saw you eat the cake right?
28. And you threw the cake away afterwards right?
29. No further questions.
Cross Kuang
Pros
● Ms. Kuang you were a member of the Ashlock crime family
● And you were offered a position as poisoner by your Uncle
● And you conducted several criminal activities including premeditated murder as the family’s
poisoner
● How many people were injured or killed as a result of your crimes?
○ If she says she doesn’t know, ask “so you don’t know how many people you’ve killed?”
(then whatever she says to this, just move on)
● Ms. Kuang after you left the Ashlock Crime Family from there relocated to Little Hamlet did you
bring any companions or loved ones?
● Do you consider Dendro a good companion
● The councilmembers made disparaging remarks against Dendro on a regular basis
■ If there is an objection for hearsay - You said that you felt the council members
dislike your dog, right?
● You said you would kill anyone who hurts Dendro
○ “I’m not lying when I say that I would kill anyone who mistreats Dendro.” ”
○ You might get objected to on this, can’t pul straight out of a witness statement. Just ask as
if it’s the truth “and you would hurt anyone who hurt dendro right?
● Did the council members insult Dendro?
● Did you become very tense after said insults?
○ No-But you became so heated that you threw a bottle on the ground did you not?
● Now Ms. Kuang you have met Dr. Kodatt prior to your arrest
● And one of those times, you stated your interest in poison was resparked
○ “My interest in toxic substances and their antidotes was reignited around May 25, 2022”
● And this means you are still knowledgeable of poisons
○ No - Well you helped Kodatt treat a poisoned patient
○ So you didn’t know how poisons work when you successfully helped Kodatt treat the
patient
■ Yes, but I forgot - You forgot your expert-level understanding of poison
chemistry in the span of under a year?
● In your direct examination you stated wine contains 10-20% hydrocyanic acid, that is factually
incorrect as wine contains less than .05 mg/L at most of hydrocyanic acid. We got the source from
Kodatt’s direct
● Did you speak with the council members prior to the festival? A yes or no will suffice.
● You proposed the festival use your catering services
● Which of the council members opposed your bid
● And Shapiro expressed skepticism towards your proposal
● Now after your argument with the council members you were furious weren’t you?
○ No - But as you said before you became so angry you smashed a bottle on the ground, is
this not an outburst?
● During the festival, you were absent for a 25 minute period
● During that time no one was with you
● Meaning during that time no one saw what you did
● No one but yourself directly saw how the cakes were prepared
● And those cakes, which no one saw you prepare were served to the council members
● And after the councilmembers consumed the cake, they died did they not?

No Further Questions You Honor

Re-Cross

Ms. Kaung, even though you left your


● Now Ms. Kuang you have met Dr. Kodatt prior to your arrest

● And one of those times, you stated your interest in poison was resparked
○ “My interest in toxic substances and their antidotes was reignited around May 25, 2022”
● And this means you are still knowledgeable of poisons
○ No - Well you helped Kodatt treat a poisoned patient
○ So you didn’t know how poisons work when you successfully helped Kodatt treat the
patient
■ Yes, but I forgot - You forgot your expert-level understanding of poison
chemistry in the span of under a year?

Ms. Kaung how many people have you murded?

Ms. Kuang yes or no , you committed premeditated murder in the past?

Ms. Kuang you conducted this murder with an extensive knowledge of poison, yes or no?

Ms. Kuang you still have extensive knowledge of poisoning do you not?

And Yes or No, you said to the councilmembers, “You want poison, that can be arranged”

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