- 12 IneeonUCTlo?' a I :1 14% Ii 15% 11th, 1974. The State has charged Warren Leslie Zomioide vicitim, 1 17%with First Degree Murder for the July llth, 1974, zs?occurring between 1972 and 1974, in Clark C0unty. moorowoeo? - ,?w?gqmw%~ wwhwe?evia9n. 3- I?v IN THE THE STATE OF WASHINGTON . A w. - ?enf 2g IN AND FOR THE COUNTY OF CLARK ?ea eo_- .zruiaWASHINGTON, . . Plaintiff, No. 1 2 6 4 7am V5.7 MEMORANDUM IN OPPOSITION . I .. . T0 DEFENSE MOTION TO LESLIE FORREST.- BASED ON PREH we: gag-F? acousnmlon 9 Defendant Krista Blake, wee last seen alive on Forrest slaying of 13EMS. Blake. It is the State's position that the Blake homici?e lygis but an isolated occurrence in a series of unsolved homicides i Such homicides, Zl?have been under continual investigation since January of 1972. gah To fully understand the complexity of this case as well as the.x:? ESEongoing nature of said investigation, any inquiry relative to 24 the above captioned 26:10 January, 1972 27" 28 11 February, 1972 29' 30 329 March, 1972 31 3? ?Memorandum 1 25 disappearance of Jamie R. case must begin with the January 10th, 1972, Grissom. Jamie R. Grissom reported missing. Clark County Case #?2?8456. No leads at this time. Barbara Ann Derry, a later homicide victim. Clark County Case #?2~86848. Was last seen hitchhiking on State Highway 14 fr0m Vancouver, Washington. Unidentified body, homicide victim, was located in the grist mill in the northern part of Clark County. i. i il 1331 March, 1972 The unidentified body located is identified as that of Barbara Ann 2? Derry, date o? birth 1/21/54. White i! female. 35 El May, 1972 Identification of Jamie R. Grissom is located in the Dole Valley area. i I No additional leads as to the where- 5E abouts of Jamie R. Grissom at this ii time. SH ?31 March, 1972 - Active investigation of the Barbara Ithrough January,._ Ann Derry homicide continues by . 8 1973? my- - 'I?aeveral Clark County investigators. 19 January, 1973 Detective Songer is assigned the 9 'tu continuing investigation of the ?.Barbara Ann Derry homicide and 10 continues active investigation of this case primarily concentrating 11 on associate contacts through May of 1973. 12., ?25 January, 1974 Detective Songer is continuing 15 the investigation of Barbara Ann Derry concentrating on selected 144. . suspects who have originated through other agency similar 15. cases. 16 31 May, 1974 Gloria Nadine Knutson is last seen 17 in the downtown Vancouver area. i H4 June, 1974 Gloria Nadine Knutson is reported 133 as a missing person to Sgt. C. Hansen, Vancouver Police Department. 19: ?20 January, 1974 - Follow~up regarding Gloria Knutson 20% continues by Officer Slocum, Vancouver Police'Department- Contact is made 21? at that time with Knutson's parents. No active leads are developed at this 225 time. - I 23ill July, 1974 Krista K. Blake is last seen in the area of 29th and Street, 24? Vancouver, Washington. 25:16 July, 1974 Sgt- Garry Lucas, Clark County i Sheriff's Office is contacted by 25: an associate of Gloria Nadine i Knutson who gives additional 273 information that she was in fact 5 last seen in the downtown 285 Vancouver area on 31 May. 1974. 29?1"! July, 1974 White female by the name of?a . is abducted from 50 the Ridgefield area. Clark County Sheriff's case #7?w7085. 51 ?518?Ju1y. 1974 ?mm. located 52-. ghemorandum 2 gap :1 ,22 July, 9'22 July, 1 E22 July, i I '3 1974 1974 1974 1974 1974 26221 September, 27 28 $1974 1 October, 29' 50 '2 October, 1974 31. 527 ?MemorandUm ?2 August, 1974 22n4 August,-1974 - . 4&24 August, 1974 1974 .w at Takes Mountain and reports her abduction to Deputy Pillsbury of the Clark County Sheriff's Office. Officer Griffith, Vancouver Police Department continues follOw- up on the disappearance of Gloria Nadine Knutson by contacting' additional associates. No additional leads are developed at this time. reinterviewed by Deputy Pillsbury and further submits to a polygraph examination administered by Dr. Walter Lindsay. Deputy Pillsbury contacts two additional witnesses. One Willa Esteb and a Richard Lahti who gave additional information in regards to the sighting of the blue van in the area of Takes at the time of. fies abduction. Detective Dick Stanley of the Clark County Sherift's Office is assigned the continuing investigation into the abductr ion of and at this time no additional invest gative leads are developed. Mrs. Colleen Blake of Rowland Heights, California, reports via letter to the Clark COunty Sheriff's Office that her daughter, Krista_K. Blake, is missing. 'This letter is subsequently transferred to Detective Buller of the Clark County Sheriff's Office but no investigative leads are observed at this time. Carol Valenzula is last seen in the area of downtown Vancouver. Carol Valenzula is reported as a missing person to the Camas Police Department. Friends of Carol Valenzula recontact the Camas Police Department to report that she is still in fact missing- There are no.investigative leads at this time. Detective Songer is continuing the investiga? tion into the Barbara A. Derry homicide by contacting additional suspects. is abducted from the Portland area, raped, assaulted and left for dead in the area of Crown Park, Clark County, Washington. A search warrant is served in the residence of Warren Leslie Forrest and Warren Leslie Forrest is arrested for the kidnap and assault on I I ZEE 1E3 October,'1974 5E9 October, 1974 26330 27? October, October, October. October, October, October, October, I October, :October, October, 285? November, 29' SO :1 52} 1974 1974 1974 1974 1974 1974 1974 19?4 1974 1974 1974 {Memorandum 4 ?1 r. >1 _l .. Dean Morgan, Public Defender?s Office is appointed defense counsel for Warren L- Forrest. u? Warren Forrest enters a plea of not guilty and not guilty by reason of insanity and further the court appoints experts to evaluate Warren L. Forrest. A line-up is conducted during whicl?. identifies Warren Leslie Forrest as her kidnapper and as the person who assaulted her. also attends this I .line~up and is unable to identify Warren Leslie_Forrest as the subject who abducted her. Two sets of bones believed to be of human origin are found in the Dole Valley area. - Search by several investigators and other persons continues in the Dole Valley area for additional bones and the investigation is initiated concerning itself with the identification of two victims. *?Comparison of both sets of bones found in the Dole Valley area are compared with dental charts of Gloria Nadine Knutson with negative results. - One of the sets of bones found in the Dole Valley area is identified as the remains of Carol Valenzula. The husband of Carol Vaienzula is held as a material witness in the Clark County Jail. Warren L. Forrest signs a waiver of speedy trial. Detective John Howard recontacts Fred Laddusaw regarding the dise appearance of Krista K. Blake and Mr. Laddusaw is unable to provide any new information. Dr. Guy A. Parvaresh is appointed to examine and evaluate Warren L. Forrest. The investigation into the Valenzula and unidentified victim homicide centinues. The FBI is contacted for a source of identification on the unknown victim and investigation into the Valenzula homicide continues concerning itSelE with associate and suspect contacts. ':12 November, 1974 i '21 November, 1974 20 November, 1974 8 January, 1975 23 January, 1975 January, 1975 February, 1975 27) 28 29 50 March, 1975 March, 1975 ill June, 1975 September, 1975 31 52 :October, 1975 VMemorandum 5 Deputy Greg'Connors 05 the Clark County Sheriff?s Office reinterviews or additional information and gains no additional investigative leads from her. Willa Sarah and Richard Lahti are recontacted for additional information but no new investigative leads_are gained into the abduction of ih'??a Dr. Dean Harris is additionally appointed to examine Warren L. Forrest and evaluate .his condition. . A background check of Warren L. Forrest _is continued by detectives assigned to the investigation of the assault. Dr. McElhaney is additionally assigned a defense expert for Warren L. Forrest. Warren L. Forrest is acquitted on grounds of insanity. ~Warren L. Forrest is Committed to Western State Hospital, Ft. Steilacoom, Washington. Clark County Sheriff's Office receives a letter from Dean Morgan advising that he is still, at that time, representing Warren L. Forrest and that he wished that no investigators interview Warren L. Forrest. Jan Perez is interviewed and informs Clark County Sheriff's Office investigators that'she cannot divulge any information regarding information she receives from Warren L. Forrest- A meeting is held at Seattle Police Department comprised of investigators from several northwest police agencies regarding their suspect, Theodore Bondy, and their cases which involved the death of several young female victims. Attending that meeting were investigators from the Clark County Sheriff's Office. The purpose being to compare our cases at that time with theirs. Continued attempts are being made to identify the unidentified female victim found in the Dole Valley area. Missing persons files on the west coast are again checked for attempts to identify the unidentified female victim. The Valenzula homicide investigation continues, however, no new investigativa is? . 3 . 327 December. 1975 4i 5 5 22 March, 1976 3 May of 1976 10 11 11 mil2 13.12 14_ 1 i 15% 16513 ?Memorandum 6 1 ?July, 1976 July, 1976 July, 1976 July, 1976 July, 1976 July, 1976 July, 1976 fJuly, 1976 July, 1976 June, 19?6 July, 1976 leads are discovered. Investigation continues concerning itself with the identification or the unidentified _?emale victim from Dole Valley. Through approximately December of 1976, Detective Songer continues the investiga? tion of the Barbara Ann Derry hOmicide recontacting associates and suspects. Progress report is received from Western State Hospital regarding Warren Leslie Forrest. Detective Davidson continues attempts at the identification of the unknown female - victim in Dole Valley. Set of bones believed to be of human origin are found in a shallow gravesite at Tukes Mountain, Clark County, Washington. Excavation of this gravesite begins. Interviews with Clark county Parks and Recreation employees are initiated. Fred LaddUSaw is again interviewed regard-~ ing the disappearance of Krista Blake. Conference is held with the Chief Criminal Deputy and investigators of,the Clark County'Sheriff?s Office regarding the _similarities with this victim currently found and with the assault which occurred at the same location in July of 1974. These remains are identified as those of Krista K. Blake. Intensified investigation into the background of Warren L. Forrest is initiated. The blue van previously owned by Warren L. Forrest is relocated and re?searched. Investigation into the Blake homicide continues and associates of Krista K. Blake are located and interviewed and interviews of some of the associates of Warren L. Forrest are began at this time. This continues through 30 July, 1976. A letter is received from the Public Defender?s OEfice addressed to Detective Davidson denying his request to interview suspect, Warren L. Forrest. Detective John Howard recontacts a sister of Jamie Grissom. No additional information leads are developed at this time. ZSZ August, 19?6 Evidence received. The evidence located during the investigation of the Blake a; homicide is transferred to the Washington State Crime Lab in Seattle. 4i is August, 1976 Detective John Howard recontacts i and at this time becomes aware of a severe vision problem and 6: further becomes aware that during the lineeup conducted on 10 October, 1974, 7 did not have her glasses with her at that time. 3 . 9? August, 1976 Attempts are made to gain the military records of Warren E. Forrest. 10b? August, 1976 An additional progress report is received by Judge Skimas from Western State?s Mental 11 Hospital regarding Warren L. Forrest. '125eptember, 1976 Detective Davidson continues attempts of the identification of the dnknown female 13 - victim from Dole Valley and further continues the investigation_into the 14 Valenzula homicide. If not previously added, 28 July, 1976, search dogs are 15E utilized in several additional areas o? 1! Clark County including several Clark County Parks and Recreation Department 17? property for additional human remains. I None are located. 185 September, 1976 Advised by the Department of the i} Military that military records for 195 Warren L. Forrest would not be ii made available to us. 20 :2 . bctober, 1976 Nationwide broadcast is made regarding 21F the unidentified female victim from the ii Dole Valley area. 221 - becember, 1976 Detective Songer is continuing the 23; . investigation of the Barbara'Ann E. Derry homicide recontacting some 24L selected suspects. No additional new leads are developed at this time. 25' 21 December, 1976 - Detective Davidson recontacts 26- and allows her to _1 observe a photographic laydown which 27% includes photograph of suspect, . Warren L. Forrest. 28. .. _,uapi a .. at this time, identifies Warren Forrest as the person who 29 abducted her and assaulted her on 17 July, 1914. 30 December, 1976 Detective Davidson continues Case -51 - #250, Valenzula and unidentified victim. Renews attempts at identify" SZI ing the unidentified victim. demorandom I ?l 1 2 3 4? UV 6 H17 March, 1977 i 5 ilg'May, 1977 i I 1 August of 1977 August through lDecember, 1977 10 January, 1978 _10 January, 1978 326 January, 1978 iJanuary, 197B "17 March. 1978 :24 March, 1978 23. 29 50 51 52 4Memorandum 8 Progress report received from Western State's Hospital regarding Warren Forrest by the court. Correspondence received from the Washington State Crime Lab regarding the evidence in the Krista Blake case. The renort indicating a need for suspect hair samples prior to completion of the evidence analysis. Detective Davidson intensifies efforts at identifying the unidentified female victim at Dole Valley by contacting Dr. Snow of the Aeromedical Institute, FAA Oklahoma for a facial reconstruction and further enters information regarding this victim in the international publicam tions for missing persons. His efforts provide no new information or additional leads. Detective Davidson begins to compare- all of the facts involved in the afore~ mentioned cases. He further?begins to rough chart the MO similarities in these cases in an attempt to organize subsequent investigation. A state's appointed to evaluate Forrest. expert is Warren L. A discovery order is granted by the court ?or information prior to the release of Warren L. Forrest from Western State?s Hospital- Final report is received from Western State's Hospital regarding Warren L. Forrest with the recommendation for his release. Partial records received by the ?rosecuting Attorney?s Office from Western State's Hospital in response to the discovery order. Warren L. Forrest is examined and evaluated by Dr. Edward M. Scott of Portland, the state?s osychiatric expert- A conference is held between the Prosecuting Attorney's Office and Clark County Sheriff's Office investigators and it is determined that an intensified investigative eonrt should take place concentrating on the afore* mentioned missing persons and homicide cases in anticipation of a release hearing by Warren L. Forrest. Detective Haas and Detective Zorn are assigned to investigate 1 2; F21 March, 1978 .1 i 4 r' 124 March, 1978 5 28 March through 9 30 March, 1978 10 11 30 and 31 March, 1978 12 13 14 15 31 March, 1978 I 16 3 April, 1973 17 13 19p 0 ?April. 1978 203 zz?npril, 1978 I 23% EApril, 1978 24 is 2553 April, 1978 26; ES April, 19?8 27; . 23 1 :5 Aprilr i978 29-through 10 April, $1978 50 5 April, 19?8 31: 52$ :1 ?Memorandum - 9 'similarities to date. and organize these prior cases on a fulltime basis. Warren L. Forrest and his attorney, sign a waiver of confidentiality for the release of mental health records. Detective Zorn and Detective Haas begin case organization which involves compiling and centralizing all prior reports and compiling 3 5 card case files thus putting a massive amount of reports in a useable form for any subsequent investigation or prosecution. A case synopsis is compiled which summarizes the total investigative efforts and case Planning conferences conducted with members of the Clark County Sherif??s Office, Clark County Prosecuting Attorney?s Office and Pierce County Sheriff's Office to formulate a definitivs plan for the subse* quent investigation and prosecution. Comparisons betWeen our cases and two unsolved Pierce County homicides are.studied. All evidence involved in the aforementioned homicide cases is compiled from different locations in the Sheriff?s Office evidence system and placed in a centralized location in-a safe in the Clark County Sheriff's Office Additional materials are mailed to Dr. Edward M. Scott to provide him with more information on victim, case and suspect background. An associate list of Warren L. Forrest is begun. Intensified background profile o? Warren L. Forrest is initiated. Clark County personnel records pertaining to Warren L. Forrest are received. Additional evidence is compiled which includes centralization of all photographs that had been taken during prior investigations. Additional public records pertaining to Warren L. Forrest are researched. Forensic dentist is contacted in an additional effort to identify the Dole Valley unidentified victim. 11 il !i 5 . 1U11 April, l978 2% 17 April, 1978 through 23 June, 1978 - 22 April, 1973 10 11 12 15 27 April, 1978 14 28 April, 1978 15 16 i 3 E25 April, 1978 17} 18? I [Me of 1978 19%? 20? 21is May, 1978 22i 233 244 '1 8 25?16 May, 197 of 1978 27* 23'15 May. 1979 29 through 13 July, V1978 SD 312 June, 1978 52% i I jMemorandum 10 'Search Dog Association, Additional evidence items which had not been submitted to the Washington State Crime Lab are transferred to that location for additional laboratory analysis. A calendar of Warren L. Forrest's back~ ground is initiated in conjunction with the background investigation. Detective Zorn initiates recontacts with all witnesses involved in the Blake investiga~ tions and also in the Grissom missing person case. An additional search of Dole Valley and Tukes Mountain utilizing search dogs from the Northwest German Shepherd Approximately ten sets of additional bones are located at this time. The bones located during this search are transferred to the Clark County Coroner. Additional evidence in the form of photo" graphs are transferred to the Washington State Crime Lab; Conference is conducted with investigators from the Multnomah County Sheriff's Office for purposes of comparing several unsolved, similar homicide cases. Background investigation continues, witness recontacts continue and additional public records pertaining to Warren L. Forrest are researched. Bones of an unidentified human person are located in the area of Lackamas Lake._ Detective Paul Brown and Detective Bush of the Clark COunty Sheriff's Office are assigned to the initial investigation of an apparent homicide. These remains are identified of those of Gloria Nadine Knutson. Detective Maas assists Detective Bush with the continuing investigation into the homicide of Gloria Nadine Knutsen. Detective Bush is assigned to the continuing investigation into this homicide case and to date haS'completed major associate contacts. Case information packages are compiled and contact initiated with Dr. David Kessler and Dr. Seymour Pollock of I 1 g?g June, 1978 3% 4?8 June, 1978 H14 June. 1978 113 June, 1978 16 June, 1978 12 27 June,'1978 1 {26 June, 1978 16419 June, 1978 18?22 June, 1378 #22 June, 1978 28 Jone, 1978- 25%12:Ju1y, 1978 24$ 25?? July, 1978 26.} 2?_13 July, 1978 29 so 13 July, 1978 51- 3 r; iMemorandum 11 California. Contact is initiated with the FBI Behaviorial Science Unit in Washington D.C. for additional assistance. Dr. Edward Scott interviews the wife and parents of Warren L- Forrest Jail records are researched to build on the associate list pertaining to Warren L. Forrest. Detective Haas is contacted by a citizen who provides an additional investigative lead on the Barbara Ann Derry homicide. Radio logs from the Clark County Sheriff's Office are researched for calls adjacent to the dates and times of the female disappearances. Military records pertaining to Warren L. Forrest are received. Report from Dr. David Kessler is received Which indicates to investigators that he concurs with the findings of Dr. Edward M. Scott, state's expert. Dr. Edward M. Scott initiates interviews with selected witnesses from the Wightman, Blake investigations. School records are researched for additional investigative leads. All officer notes are compiled. Additional information package is transferred to Multnomah County Sheriff's Office for more intensified study of case similarities. Clark County Coroner reports that all bones tound by the search dogs were found to have been from animal origin. A pro?essional artist is utilized to sketch Some MO similarities in this case.- A meeting and conference takes place between Robert Russler, Special Agent with the FBI Behaviorial Science Unit and Detective Haas and Chief Deputy Prosecuting Attorney Dennis Hunter- One of the living victims, now is accompanied to Tukes Mountain by Detective Mass and an i I 1 i ?i 5&1? July, 1978 43 5. 6E19 July, 1978 3 19 July, 1978 10 12 July, 1978 11 12 August, 1978 13 14:21 August, 1978 I I i I 22 23g30=August, 1978 8 24:6 September, 1978 25?7~9 September, 6&1978 27il2 September, ?1978 28: 29114 September, "1978 SD .15 September, 51?19?8 52: i 1 ?Memorandum 12 24 August, 1978 25 August, 1978 30 August, 1978 September, 1978 additional interview is conducted and an additional crime scene sketch is made. - Contact is initiated with Mr. Ray Bellgard. Chief Investigator of the Santa Cruz County District Attorney's Of?ice for additional case assistance. Background investigation on Krista K. Blake is intensified. Public records are obtained and family contacts are continued. Additional school records pertaining to Warren L. Forrest and Jamie L. Grissom are researched. - Clark County Prosecuting's O?fice reviews crime scene photographs, slides and video tape pertaining to the Krista K. Blake investigation. Dr. Edward M. Scott interviews additional selected witnessEs.' Associate interviews of Warren L. Forrest are initiated. Additional interviews at Western State Hospital are conductedl The Washington State Crime Lab is requested to conclude their examinations and compile their report. M0 experts from the California State Department of Criminal Justice are scheduled for contact with Clark County Sheriff's Office investigators. This investigation continues- Investigative log to date. Associate and witness interviews. Associate and witness interviews. VIA and Charting with California Department of Justice. H?interview art ist reconstruction and scene photographs obtained. Crime scene sketching of Crown Park Additional suspect background investiga~ tion cont. ii 1118 September, 5197a Bl - .?19 September, 3}1978 4:19 September, ?1978 5% 5:20 September, 20 September, 9 1978 ?9 21 September; 1978 . ID, 111 25 September, 12 1978 13%25 September, r19?8 14 15 25 September, 11978 163 H26 September, 1751978 ti 13:26 September, #1978 9y i 20?27 September, 1u1978 I E2 October, 1978 23?2 October, 1978 24; 5:3 October, 1978 25 i3 October, 1978 2; 528 September, 2321978 2933 October, 1978 50:4 October, 1978 rs?i. I 3; Based 515 :s iHemorandum 13 Colombian Library researched. Additional associate interviews. Additional witnesses (Arvidson Mildred Laddusaw) located and interviewed. Additional associate interviews. Gates interview and scene photographs. Investigation regarding County employees with keys to parks property and DMV investigation on same. Additional photographs compiled. In?estigation regarding Suspect Reserve Associates. VIA charting finalization. Additional associate interviews. Additional evidence to Washington State Crime Laboratory (Darts). Additional associate and witness interviews. Researched purchasing records for add- itional evidence. Additional witness interview (Renee Bradseth) Medical records pertaining to treatment of Wightman obtained and transferred to custody oE coroner. Dr. Hamilton interviewed. Dr. Brady interviewed. Additional witness interview (Schleichart). Search of Skyline Burnside conducted for additional evidence. upon the ongoing investigation outlined abover . the position of the State that no delay has occurred in 1 lathe formal accusation of Warren Leslie Forrest in the above- 1 . . ??captioned case. Even should the court find a delay (as that 4?term is used in the cases}, the defendant has not demonstrated 5iactual prejudice as required by Fifth Amendment due process and Glease law concerning pre?accusation delay. Should the court find a a 7%that the defendant has demonstrated actual prejudice any I 3 I"delay" is reasonably justified by the complex nature of this 9 case, insuf?icient evidence to charge the defendant until the 10 information was filed, and the ongoing investigation concerning 11 six homicides. Dismissal, therefore, is not warranted. 12 15 II. THERE HAS BEEN NO DELAY IN THE FILING OF CRIMINAL CHARGES IN THE PRESENT CASE. 14 15 As indicated above, an ongoing investigation concerning 16 six homicides which occurred in Clark County between 1972 and 17 E1974, and the defendant's involvement in those homicides centinues 18? Eto the present. At this time, the state is awaiting the final 19 report of the criminalist at the Washington _State Crime Laboratory 20 as.to certain items of evidence involved in the Blake homicide and 21 Ithe abduction. In addition, the State has continued tc 22 seek out and interview potential witnesses, and to gather addition 25 :evidence. 24% 25L E?nited States Supreme Court cases and the leading Washington It will be.c1ear from a discussion of the facts of two gcase concerning pre~accusation delay, that the term "delay" as 79 Insed by the courts contemplates the deference of formal accusation 23? Ebf the defendant for a period of time after the investigation 29; =toncluded and all the evidence is gathered- is The three cases are: 50 v. Marion, 404 U.S. 307, 30 463, 92 455 [1971); 31. lb. 5. v- 431 U.S. ?83, 52 752, 97 2044 511977}; State v. saga, a wn.App. 481, 507 p.2a 159 (1973). 32 Memorandum 14