When Morris was finished, it was my turn again. I moved quickly to the lectern.
“Brief redirect, Your Honor,” I said.
“Proceed, Mr. Haller,” the judge intoned.
“Sergeant Sanger, when Mr. Morris went over your career and commendations, he seemed to leave one item out,” I said. “Isn’t that correct?”
“I don’t know what you’re talking about,” Sanger said.
“Well, I’m talking about that pin you’re wearing on your uniform above the breast pocket. What is that for, Sergeant Sanger?”
I had seen the pin the day before, but it was only after reviewing Sanger’s testimony that I realized what I could do with it.
“That’s a badge for qualifying at the sheriff’s range,” Sanger answered.
“The shooting range, you mean?” I asked.
“Yes, the range.”
“To get a pin like that for your uniform, you have to do more than qualify, don’t you?”
“It’s given to the top percentage of shooters.”
“What percentage is that?”
“Top ten percent.”
“I see. And what is a pin like that called?”
“I don’t know.”
“It means you are an expert marksman, does it not?”
“I don’t use gendered words.”
“Okay, how about the word shooter instead of marksman? That pin you proudly wear on your uniform means you qualified as an expert shooter, does it not?”
“I’ve never used those words.”
In a show of frustration, I raised my hand and then dropped it down on the lectern with a thud. I asked the judge if I could approach the witness to show her an exhibit previously accepted by the court. After permission was granted, I carried over the photos of Lucinda at the shooting range.
“Can you identify the people in that photo?” I asked.
“Yes,” Sanger said. “It’s Robbie Sanz and his then-wife, the defendant, Lucinda Sanz.”
“You mean the petitioner?”
“Yes, the petitioner.”
She said it in a sarcastic tone.
“Thank you,” I said. “Now, in the second photo in your possession, you have the man you identified as Robbie Sanz using his hands to improve the posture and stance of his then-wife. Is that correct?”
“Yes,” Sanger said.
“As you are a law officer and a shooting expert, with the commendation to go with it, can you tell me what stance the petitioner is learning in that photo?”
“It’s the high-ready stance.”
“Thank you, Sergeant Sanger. I have no further questions, Your Honor, but the petitioner reserves the right to recall the witness at a later stage of the hearing.”
“Okay,” Coelho said. “Mr. Morris, do you wish to re-cross?”
“No, Your Honor,” Morris said. “The State is ready to move on.”
“Sergeant Sanger, you are excused,” Coelho said. “Mr. Haller, call your next witness.”
Keeping to my plan, I called Deputy Keith Mitchell. He was brought in from the hallway, placed under oath, and seated in the witness stand. He was a large Black man with a shaved head. His biceps stretched the sleeves of his uniform shirt to their limit. I moved back to the lectern with my legal pad. I didn’t bother asking the judge to rule that Mitchell was a hostile witness.
After a few preliminary questions that established that Mitchell was a member of the same anti-gang unit as both Roberto Sanz and Sanger, I got down to the meat of his testimony.
“You are a big man, sir,” I began. “How tall are you?”
Mitchell looked confused by the question.
“Uh, six four,” he said.
Morris stood up.
“Your Honor, can we keep the examination to things pertinent to the case?” he asked.
“Sorry, Your Honor,” I said. “I’ll move on.”
Coelho frowned.
“Don’t meander, Mr. Haller,” she said.
“I won’t, Your Honor,” I said. “Deputy Mitchell, you were at the crime scene on the night of Roberto Sanz’s murder, correct?”
“That is correct,” Mitchell said.
“But you were off duty, were you not?”
“I was.”
“How did you come to be there?”
“The department sent out a text alert that there had been an officer-involved shooting in the AV, and then like maybe ten minutes later another member of our unit called me and said it was Robbie who got shot. We were close, Robbie and me, so I went to the house.”
“And that was Stephanie Sanger who called, correct?”
“Correct. Sergeant Sanger.”
“Was she a sergeant at that time?”
“Uh, no. Not then.”
“And where were you when Deputy Sanger called you?”
“I was at my home in Lancaster.”
“What is your home address?”
Mitchell hesitated and Morris jumped up to object to revealing the witness’s home address to the public.
“Your Honor,” Morris said. “This could put this witness and his family in danger.”
“I withdraw the question,” I said before the judge had to rule.
“Very well,” the judge said. “Proceed.”
Morris nodded his approval like he had once again scored some kind of point over me.
“Deputy Mitchell, let’s go back to that night,” I said. “Were you part of the investigation of Deputy Sanz’s death?”
“No, I was not,” Mitchell said.
“But on the evidence report, it says you had possession of the gunshot-residue pads taken during the examination of Lucinda Sanz. Is that true?”
“Yes. That evidence was handed to me by another deputy to safeguard until investigators were on the scene. When the homicide investigators arrived, I handed the evidence over.”
“What exactly was the evidence?”
“As I recall, it was two GSR pads in an evidence bag.”
“And which deputy gave that bag to you to, as you say, safeguard?”
“Sergeant Sanger. I mean, Deputy Sanger at the time.”
I paused and looked down at my pad and braced myself for more pushback on my next line of questioning.
“Deputy Mitchell,” I finally said, “were you aware that Deputy Roberto Sanz was a member of a sheriff’s clique that had become the focus of an FBI invest—”
“Objection!” Morris practically shrieked before I could finish my question. He jumped to his feet.
“Assumes facts not in evidence,” he said. “Counsel for the petitioner is again trying to cloud these proceedings with innuendo he has absolutely zero evidence to support.”
“Mr. Haller, response?” the judge said.
“Thank you, Your Honor,” I said. “If allowed to continue with the petition, these facts will come to light.”
The judge considered this for a long moment before responding.
“Once again, I’m going to hold you to that, Mr. Haller,” she said. “The witness may answer.”
“Your Honor,” Morris said. “This is highly—”
“Mr. Morris, did you not hear the court’s ruling?” Coelho said.
“Yes, Your Honor,” Morris said. “Thank you, Your Honor.”
Morris sat down and all eyes returned to Mitchell. For dramatic effect, I asked the question again.
“Deputy Mitchell, were you aware that Deputy Roberto Sanz was a member of a sheriff’s clique that had become the focus of an FBI investigation?”
Mitchell hesitated in case Morris wanted to try a new objection, but the assistant AG remained quiet.
“No, I was not aware of that,” Mitchell said.
“At the time of Sanz’s death, were you a member of a sheriff’s clique called the Cucos?” I asked.
“No, I was not.”
“Were you ever questioned by the FBI in regard to being a member of a sheriff’s clique?”
“No, I was not.”