Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 1 of 37 Pageid#: 84

2 IN THE UNITED STATES DISTRICT COURT

3 FOR THE WESTERN DISTRICT OF VIRGINIA

4 ABINGDON DIVISION

5 UNITED STATES OF AMERICA, )

)
6 Plaintiff, ) Criminal Case No.
) 1:20mj00084-PMJ/1:20cr00015-
7 vs. ) JPJ-PMS
)
8 COLE CARINI, )
) REDACTED TRANSCRIPT
9 Defendant. )
____________________________________________________________
10

11 TRANSCRIPT OF DETENTION HEARING

TESTIMONY OF KAREN CARINI ONLY
12 HONORABLE JUDGE PAMELA MEADE SARGENT PRESIDING
WEDNESDAY, JUNE 17, 2020
13
____________________________________________________________
14

15

16

17
A P P E A R A N C E S
18
On behalf of the United States:
19 Zachary T. Lee
Whitney D. Pierce
20 United States Attorneys Office
180 West Main Street, Suite B19
21 Abingdon, VA 24210

22 On behalf of the Defendant:

John Thomas Stanford
23 Federal Defenders Office
201 Abingdon Place
24 Abingdon, VA 24211

25 Proceedings taken by Certified Court Reporter and transcribed

using Computer-Aided Transcription

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 2 of 37 Pageid#: 85
2

1 (Testimony of Karen Carini commenced at 2:08 p.m.)

2 MR. STANFORD: Okay. I'm going to call Karen

3 Carini.

4 THE COURT: Ms. Carini, are you on the telephone?

5 MR. STANFORD: Unmute yourself, Karen.

6 MS. CARINI: Okay. Can you hear me now?

7 THE COURT: Yes, ma'am. Ms. Carini, we can hear you

8 well.

9 MS. CARINI: Okay.

10 THE COURT: If you'll listen carefully, I'm going to

11 have the deputy clerk place you under oath.

12 MS. CARINI: Okay.

13 THE CLERK: Do you solemnly swear that the testimony

14 you're about to give in this case shall be the truth, the

15 whole truth, and nothing but the truth, so help you God?

16 THE COURT: All right. Mr. Stanford.

17 MR. STANFORD: Thank you, Your Honor.

18 KAREN MICHELLE CARINI,

19 Called as a witness herein by the Defendant, having been first

20 duly sworn, was examined and testified as follows:

21 DIRECT EXAMINATION

22 BY MR. STANFORD:

23 Q. Karen, can you state your name and spell it.

24 A. Karen, K-a-r-e-n, Michelle, M-i-c-h-e-l-l-e, Carini,

25 C-a-r-i-n-i.

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 3 of 37 Pageid#: 86
3

1 Q. And, Ms. Carini, what is your relationship to Cole

2 Carini?

3 A. I am his mother.

4 Q. Okay. How are you employed?

5 A. I'm a retired teacher.

6 Q. And where do you live?

7 A. I live at Richlands, Virginia.

8 Q. And is that the residence that Cole was living at during

9 this incident?

10 A. Yes. He lived upstairs; I live downstairs.

11 Q. Okay. Who else lives there?

12 A. My son Russell, and myself, and my son Neil Carini.

13 Q. How old are they?

14 A. Neil is 20. RC is going to be a sophomore in high

15 school, he's 15.

16 Q. Okay. And where is Cole's father?

17 A. He has been absent from the family for ten years. He

18 only sends a support check but does not have any contact

19 whatsoever with his family or his children.

20 Q. Okay. Can you tell the Court briefly about Cole; sort of

21 his personality, any disorders that you know of. Just talk

22 about him generally.

23 A. Cole was diagnosed with ADHD/Autism in fourth grade and

24 compulsion problems. He hyper focuses on things. He would

25 not touch items for a while. In the fourth grade I had to get

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 4 of 37 Pageid#: 87
4

1 him intense therapy for that. And he thought he would catch

2 germs from things, so he touched everything with a white

3 Kleenex. So his teacher recommended him to get evaluated and

4 that's when he was evaluated. And he began his intense

5 therapy there, I've list it on a piece of paper for John, with

6 a therapist named Dr. Stephen Bentley, and he also saw

7 Dr. Keeling for his medications. Cole's been in some kind of

8 counseling since fourth grade and actively in counseling now.

9 And he is a very hard worker. He is not a vindictive person.

10 He's not angry. He doesn't hit back. He's very humble. He's

11 down on himself and needs to be able to see his own

12 self-worth. And I believe he's very intelligent. He was our

13 church liturgist. He worked for several people mowing their

14 yards. He had an employer, Michael Smith, who was a former

15 teacher, and he just built him a deck, put some birdhouses on

16 it. He's also very creative. When he focuses on the right

17 things, he's a very, very productive citizen, and I'm proud of

18 him.

19 Q. And, Ms. Carini, you say he does work by building decks

20 and other things, woodwork. Is it your understanding that the

21 nails and things that Agent Childers found, was that typical

22 stuff that he would use that on?

23 A. Yes. Cole was never very organized, and we had to work

24 on what's called executive functioning and that is your daily

25 life skills. So we had to constantly remind him don't bring

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 5 of 37 Pageid#: 88
5

1 tools in the house, those kinds of things, because he was

2 always working. He never, never sat still. And during the

3 day he would be mowing lawns, working to maintain the

4 properties for Michael Smith who has a lot of -- like I think

5 a trailer park. And Cole would work on the plumbing for

6 people if they needed it. And people would let them come in

7 their home. He's very likable. I don't believe he would ever

8 hurt anyone but himself.

9 Q. Okay. Is he currently receiving counseling?

10 A. Yes. At Healing Waters in Cedar Bluff he sees a

11 psychiatrist for medications to help him not hyper focus and

12 also to help him to sleep. Because Cole has always been a

13 very productive person. He can always stay busy. Even as a

14 child, he didn't really play with toys. He doesn't have a

15 cell phone. He's not into social media. He likes to produce.

16 I know losing his hand is going to be one of the worst things

17 that he'll have to adapt to.

18 Q. Let me stop you there. What kind of medication does he

19 receive?

20 A. He takes Adderall and Prozac.

21 Q. Okay. Is it your understanding that currently -- or at

22 least around this time that Cole was in a relationship?

23 A. Yes. And the girlfriend's name is Jamie King.

24 Q. Okay. And was that relationship sexual in nature?

25 A. Yes, it was.

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 6 of 37 Pageid#: 89
6

1 Q. Okay. Now another thing that's been brought up in the

2 complaint and the pre-trial services report is that several

3 years back in 2016 he had a state charge for possessing

4 explosives. Are you aware of that?

5 A. Yes. It was dismissed.

6 Q. Well, can you tell the Court the nature of that charge?

7 Did that involve making things like this case alleges?

8 A. He had gotten a Tannerite target. And when he shot it

9 off -- he had adapted how it shot off. But it was purchased

10 legally at a shop, Cabela's or -- I believe that's the name of

11 the shop -- by his aunt in Delaware. So when he got home on

12 New Year's Day, he used that. And for four years he was on --

13 well, he went through the case. It was dismissed. And for a

14 year he was on supervised probation and then he was on

15 unsupervised probation. And he complied every time. He met

16 all the requirements and conditions and passed.

17 Q. And that's why his case was dismissed?

18 A. Yes, on 9-9-19. And we all felt Cole was doing very

19 well. Even his counselor, Donna Offield. The people he was

20 interacting with, our family members, people he worked for, we

21 all felt he was doing very well.

22 Q. I was going to say, so you talked about how he was on

23 probation after he got convicted of that. Was he also on

24 pretrial release before the case was resolved or was he held

25 in custody pending the resolution of that case?

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 7 of 37 Pageid#: 90
7

1 A. He was in jail 15 days and then he came home with six

2 months of an ankle bracelet. And he was drug tested and

3 passed all those drug tests for the continuation of the case.

4 Q. Was his pretrial release ever revoked or did he do pretty

5 well on that?

6 A. He complied every time and he had no problems whatsoever.

7 Q. And so the case, it's my understanding, started January

8 of 2016 and it ended three years and nine months later in

9 September of 2019; correct?

10 A. That's right.

11 Q. So during that whole period, you know, absent maybe

12 15 days, he was being supervised and did pretty well?

13 A. Yes. He completed all conditions.

14 Q. Okay. Can you describe the day of this event. Where

15 were you? What was going on?

16 A. I had just gotten home from a doctor's appointment in

17 Abingdon. It was about 7:00 at night and Cole was upstairs, I

18 was downstairs, I believe that's how it was, and I was just

19 getting ready to take a shower because I was afraid COVID was

20 on me. So I put my gown on and went into the TV room to tell

21 my other child that I was back home. And while I was in

22 there, that is when Cole appeared in the entrance way and

23 says, "Mom, I need help. I've had an accident."

24 When I got home I saw a note on the door from the

25 neighbor that said, "Cole needs to mow and weed eat." So I

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 8 of 37 Pageid#: 91
8

1 had told Cole that, hey, you need to go weed eat. So I

2 thought maybe he was, you know, going to go weed eat. The

3 next time I saw him, he was standing there saying, "Mom, I'm

4 hurt."

5 Q. Okay. So did you take him to the hospital?

6 A. Yes. I called 911, but it wasn't coming quick enough and

7 Cole was going to drive himself to the hospital because he

8 wanted to live. He told me he was going to bleed to death. I

9 told him, "No, I'll put my clothes on and we'll go." I drove

10 him to the hospital. And the first people to talk to the

11 responders was Russell, my 15-year-old, his youngest brother.

12 Q. Okay. Did he -- at some point he was -- he was Life

13 Flighted to Roanoke; is that correct?

14 A. Yes, he was. X-rays were taken of his hands and that's

15 when I knew he had missing fingers on his left hand. He was

16 MedFlighted to Roanoke, and he was in a five-and-a-half-hour

17 surgery.

18 Q. Okay. And do you have any understanding of the kind of

19 pain medication he was on?

20 A. Yes. He was on four medications for pain. And they were

21 very --

22 Q. Four medications?

23 A. Yes, four medications for pain. And they're in the files

24 for Roanoke. But the doctor told me when I actually got to

25 speak with the hand doctor that did the surgery on his hand --

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 9 of 37 Pageid#: 92
9

1 my concern was that he would get a prosthetic for the hand.

2 Right now he has this on his left hand and the right hand has

3 a pin and that will come out. At the end of the month he'll

4 have to have that addressed, because he may be able to get a

5 prosthetic if he does physical therapy. And I want him to

6 have a chance to not be a cripple the rest of his life and to

7 have some sense of productivity. So we need to address not

8 only the mental needs of my son but the physical needs of my

9 son.

10 Q. Okay. I want to talk to you for a moment about some

11 other things in the complaint. There was mention, and you've

12 heard it already, of this note that was found that purports to

13 connect him to the incel movement. Do you have any knowledge

14 of that movement and what that's from?

15 A. Yes. That came from a bin in the red shed. And I had

16 been cleaning the whole home to make sure it is safe for my

17 family now. So, upon cleaning, I did find that bin and it was

18 from 2015/16. There were birthday cards in it from that year.

19 And he was enrolled in a criminal justice class where he did

20 case studies on particular people for the class. So that bin

21 was filled with videos and movies. Cole is a very sentimental

22 person that kept things. That's where I found other items

23 that would have been from that time period.

24 Q. The complaint talks about, again, these nails and bolts

25 and stuff found in the room. From your being in the room, did

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 10 of 37 Pageid#: 93
10

1 you find any evidence of nails or bolts stuck in the ceiling

2 from like --

3 A. No. The only thing on the ceiling was a little bit of

4 duct tape and some blood. But there was no shrapnel anywhere,

5 like embedded anywhere.

6 Q. Okay. The complaint also references that by this red

7 shed -- and this shed, is it your mother who lives directly

8 next door?

9 A. Yes. And we have an empty lot beside of that.

10 Q. Okay. And this shed is on her property; correct?

11 A. It's on that empty lot that she owns. But it was Cole's

12 shed and none of us ever went in it.

13 Q. What is -- what are those pipes from -- or the PVC pipes

14 and all of that?

15 A. Yes. We had a pool that we had, an in-ground pool, for

16 30 years and my mom just filled it in. So Cole was going to

17 put a shower and a sink in out there from the old pool house.

18 So he had engineered a way, sort of like Alaskan bush people

19 on TV, and Cole would do a lot of things like that all the

20 time; projects. And he was thinking, I can make my shed like

21 a little cleanup place so my mom wouldn't be yelling at me for

22 getting everything dirty in the house. So he had already

23 installed a sink and he had this shower out there to put the

24 pipings to it. And, in his mind, that was going to be a place

25 for him to be able to clean up and do before he would come

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 11 of 37 Pageid#: 94
11

1 into the real house.

2 Q. Okay. In the complaint it also mentions loose dirt that

3 was found around the shed. And I think the ATF mentioned in

4 that person's training and experience this was a place used to

5 detonate bombs or something. What is your understanding of

6 that?

7 A. Cole has dug a well and there are pipes coming out to be

8 able to assimilate the structure for the showering and using

9 the sink for water. That's when I was walking around the

10 building.

11 Q. Okay. It was also mentioned in the complaint that when

12 neighbors were interviewed that they would talk about hearing,

13 you know, popping sounds and stuff like that. Can you give

14 any insight into what those might be?

15 A. Yes. I live in a neighborhood where there are two people

16 who actively target shoot muzzleloader guns; Craig Hunsaker

17 and Timothy on the hill up here. And then there's also

18 fracking that goes on behind my house in West Port Cove and

19 they shot off in series of eight. So we still hear the

20 banging now. And it is a neighborhood with different types of

21 people here that it could be easily explained. We also live

22 very close to a railroad track and highway with lots of

23 traffic.

24 Q. Other than this incident, I mean, do you know if Cole --

25 you're home a lot, aren't you?

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 12 of 37 Pageid#: 95
12

1 A. Yes. I stay at home.

2 Q. Do you know of any other incidents or other incidents of

3 him just sort of setting off explosives throughout the day?

4 A. No, sir.

5 Q. Okay.

6 A. No, sir.

7 Q. Now, Ms. Carini, you say that you've -- or you've

8 thoroughly cleaned your house; is that correct?

9 A. Yes.

10 Q. And by that you mean you've tried to remove anything that

11 could be used in these kind of things, explosive devices;

12 correct?

13 A. I greatly appreciate Micah Childers. The officer was

14 very kind to me. I told him I was concerned. And he told me

15 sort of like what to look for; liquids in a fish bowl. So I

16 did get rid of exactly what he told me to do. I appreciate

17 that and told him I wanted to get help for my son.

18 Q. What did he tell you to look for?

19 A. A fish bowl with some clear liquid in it. Then also

20 upstairs he said there might be some Mason jars with clear

21 liquid in it. And then maybe out in the garage, look around

22 the perimeter for that thing. He said it would not be

23 volatile or explosive.

24 Q. Okay. And you were able to find things like that and

25 clear them out of the residence?

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 13 of 37 Pageid#: 96
13

1 A. Yes. I did find those three things he mentioned, and I

2 was very grateful for what he said to me. He was very

3 helpful.

4 Q. Okay. Now, right now the testimony has been that Cole's

5 room is upstairs and it sounds like at least you were

6 downstairs, maybe other people are downstairs. If Cole were

7 released and went home, is there any way you could

8 reconfigure -- have him come downstairs to be watched over

9 more closely?

10 A. That is our plan. And we feel he would do best in the

11 bedroom that would be downstairs as soon as you come in the

12 home and it would be the best place to be able to monitor

13 everything and for him to access, you know, because he's

14 handicapped. And I believe that would be the best room for

15 him. So we have rearranged the furniture and got it ready.

16 Q. Okay. As a retired school teacher, do you have the time

17 to give him constant monitoring?

18 A. Yes.

19 Q. Okay. Is there anything else right now that's a big

20 distraction in your life that would take you away from

21 monitoring him?

22 A. No, sir. I'm not working and do not have -- I'm single.

23 And my son's well-being is number one. And I really want to

24 help him to overcome this.

25 Q. Okay.

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 14 of 37 Pageid#: 97
14

1 MR. STANFORD: Your Honor, I think that's all I've

2 got right now.

3 THE COURT: Mr. Lee, questions?

4 Mr. Lee, do you have any questions?

5 MR. LEE: Yes, Your Honor, I do.

6 Can you hear me now?

7 THE COURT: Yes.

8 CROSS-EXAMINATION

9 BY MR. LEE:

10 Q. Ms. Carini, I first want to start talking about the 2016

11 incident you've discussed. Do you recall that incident?

12 A. Yes.

13 Q. As a matter of fact, you were present with your son when

14 law enforcement first responded to your residence, weren't

15 you?

16 A. Yes.

17 Q. And you were present when he was interviewed by law

18 enforcement?

19 A. Partially.

20 Q. Okay.

21 A. They separated us, you know, into cars, and they wouldn't

22 let us back in the home until 10:30 that night.

23 Q. Well that was -- that's not entirely true. In fact, at

24 one time point in time you and your son went into the

25 residence and collected up a bunch of things and brought it

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 15 of 37 Pageid#: 98
15

1 out to the police, didn't you?

2 A. No. I stayed on the outside of the home, and I told Cole

3 to go get the rest of the targets. There were four in the

4 pack and he had shot one off. So I told him to go get the

5 other three so they could see it. He was allowed back

6 inside -- he was headed to go back inside and they decided to

7 arrest him at that point. He was not allowed to go get it.

8 Q. Okay.

9 A. So he went and got it and gave it to them.

10 But, no, sir, I never went back in that house. And

11 if I went to the restroom, they would go with me before to --

12 Q. It's your testimony that all he was doing was being

13 involved with Tannerite?

14 A. At that point, that is what -- yes.

15 Q. Well --

16 A. In January of 2016.

17 Q. Okay. Were you present when Cole stated to law

18 enforcement on the day that they were at your house in 2016

19 that he was not shooting targets, he was making blasting caps

20 with the Tannerite? That he was putting gun powder in metal

21 pipes and blowing them up?

22 A. I don't remember the details of him saying all that. All

23 I remember is he said that he didn't just shoot the target,

24 that he had made blasting caps. That's what I recall.

25 Q. In fact, you and your son and -- either provided to or

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 16 of 37 Pageid#: 99
16

1 know that pieces of galvanized pipe that had been exploded

2 were seized from your residence, weren't they?

3 A. They searched -- they took a lot of stuff that day and

4 it's all listed there on a piece of paper. I'm not sure. It

5 was four years ago. But it's all on a piece of paper.

6 Q. And that piece of paper included firecrackers, partial

7 Co2 cartridges, galvanized end caps, fragments of galvanized

8 pipe, altered Co2 cartridges, three tubes of Tannerite, a

9 notebook, and some loose drawings. Does that sound about

10 right?

11 A. Yeah.

12 Q. Okay. So it's not just Tannerite we're talking about, is

13 it?

14 A. It's the items you mentioned.

15 Q. All right. So you weren't entirely truthful when you

16 said it was just about some Tannerite in your home, were you?

17 A. Well, sir, at that moment I was summarizing. I didn't

18 know I was going to have to -- I wasn't insinuating that it

19 was just something.

20 This is something that my son needs help for. I

21 want him to get the help he needs. I hope the Court has mercy

22 on him. I'm not here -- it's a not about defending my son.

23 It's about getting the help my son needs. The rest of his

24 life he's going to go around like this. So I want him to have

25 a chance at life, liberty, and pursuit of happiness.

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 17 of 37 Pageid#: 100
17

1 Q. Bottom line, Ms. Carini, in 2016 your son was making pipe

2 bombs, wasn't he?

3 A. I did not know that.

4 Q. Now you said that when -- June 2nd of 2020, when your son

5 blew his hand -- his fingers off that he was upstairs when you

6 got home; is that correct?

7 A. He must have been. I thought -- I didn't -- I yelled

8 out, "Hey, Cole, you've got this note on the door." And I'm

9 going to be honest with you, it's very shocking to see your

10 child in that shape. And the timeline is, basically, I got

11 him to the hospital and he's MedFlighted and he's alive. So

12 it's -- I had no idea what was going on.

13 Q. I want to go back to 2016. Your son had a semi-automatic

14 handgun in his room, didn't he?

15 A. No.

16 Q. Was there a pistol found in your house during the search

17 of it?

18 A. Not that I remember.

19 Q. Are you sure?

20 A. I don't remember. I don't remember. It's been four

21 years ago, and I've been through a lot of stress and so I do

22 not remember.

23 Q. And what actually happened in court is your son pled nolo

24 contendre and the charge was taken under advisement for two

25 years until September of 2019; correct?

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 18 of 37 Pageid#: 101
18

1 A. On 9-9-19 it was dismissed, and I was very grateful, very

2 hopeful.

3 Q. So going back to the date of the most recent incident,

4 you said you assume your son was upstairs and then the next

5 you saw him he was in front of you with his hands severely

6 injured; is that correct?

7 A. He was in the entranceway of the home where the blood

8 spatter is. And I have pictures of that. That's where he was

9 at. And he said, "I've had an accident and I need to get to

10 the hospital. I don't want to die."

11 Q. Okay. And that's not entirely the extent of what

12 happened, is it?

13 A. I was so concerned about getting him to where -- I was

14 in -- you can listen to the 911 call. I was in a state of

15 shock myself for hours afterwards. I don't even remember

16 driving to the hospital. I just remember --

17 Q. Okay. You're not in shock now, are you?

18 A. No, sir.

19 Q. Do you remember when Special Agent Childers interviewed

20 you about the incident?

21 A. I was giving him the key to get into my grandmother's

22 house, the next -- two days after.

23 Q. Okay. And he wanted to know what happened that night --

24 or that day; correct?

25 A. Yes.

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 19 of 37 Pageid#: 102
19

1 Q. And you started to talk about a lawn mower accident,

2 didn't you?

3 A. That's what my son had told me it was, and I believed my

4 son at the time.

5 Q. Actually --

6 A. Especially because of the note on the front door.

7 Q. But the agent stopped you and told you to tell the truth.

8 And then what did you tell the agent?

9 A. I told him the truth.

10 Q. You told him that you heard a pop or some sort of

11 explosion, didn't you?

12 A. No. He asked me if I had. And I had to stop and think.

13 And then I said, it wasn't like a -- it wasn't like an

14 explosion. No, I didn't hear anything that loud. It was

15 muffled.

16 Q. Well what did you hear?

17 A. Yeah, it could have been.

18 A muffled sound like a pop, pop bottle opening, Coke

19 can.

20 Q. And yet you still told law enforcement at the medical

21 center that this was a lawn mower accident; is that correct?

22 A. I never spoke to -- I was believing my son at that time.

23 There was a note on the door that said you need to mow and

24 weed eat.

25 Q. Okay. You never heard the lawn mower, never saw the lawn

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 20 of 37 Pageid#: 103
20

1 mower?

2 A. Well, he mowed up the road. And so, yeah, he had been

3 mowing earlier in the day. He had been working --

4 Q. How do you know that?

5 A. -- working on the lawn mower.

6 Well you can tell somebody, I don't know, just --

7 Q. You didn't see him, did you?

8 A. No. No, that's what he -- his routine.

9 Q. You don't --

10 A. That's what his routine typically was.

11 I'm sorry, I misspoke. I was gone to Abingdon that

12 day; you're correct.

13 Q. Tell us about your son's drug use.

14 A. I don't know about my son's drug use.

15 Q. You don't know anything about him using methamphetamine?

16 A. I do know that my son has told me that he has stopped all

17 that. And the only thing I could say is he hangs around some

18 people that he shouldn't. But I did not get in my son's --

19 he's 23 years old.

20 Q. So when I asked you to tell us about your son's drug use

21 and you say you don't know anything about that, that's not

22 true, is it?

23 A. I don't know the details about it, no, I do not.

24 Q. You know he used -- or at least used to use

25 methamphetamine; correct?

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 21 of 37 Pageid#: 104
21

1 A. At one point I do believe he did. I never seen him do

2 it. I've never seen my son do it so, therefore, I cannot say

3 100 percent.

4 Q. But you just testified he told you he wasn't doing that

5 anymore. Correct?

6 A. Right. But I have never seen my son take drugs.

7 Q. You know Miss King -- is it Jamie King? -- is that his

8 girlfriend?

9 A. Yes.

10 Q. She's a drug user, isn't she?

11 A. I do not know about Jamie King.

12 Q. Well, who are these other people that he hangs around

13 with that he shouldn't?

14 A. Neighbors.

15 Q. And why shouldn't he hang around with them?

16 A. They -- he shouldn't.

17 Q. And why not?

18 A. For reasons you stated.

19 Q. Well, I want you to tell me why he shouldn't.

20 A. Because he's worth more than that.

21 MR. LEE: Your Honor, I'd ask the witness to answer

22 the question, please.

23 THE COURT: Well, ma'am, if you know the answer to

24 the question, you have a legal obligation to answer the

25 questions truthfully.

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 22 of 37 Pageid#: 105
22

1 THE WITNESS: Because he has a drug -- he has a lot

2 of pending charges, and I don't want my children around those

3 kind of people. That's all I can say. I don't know the

4 person. I don't interact with those people. I just know what

5 he's being charged with.

6 BY MR. LEE:

7 Q. And what's he being charged with?

8 A. There's about 20 different things he's being charged

9 with. I looked them up and --

10 Q. What are they?

11 A. Driving without a license, using -- using meth, selling

12 drugs, transporting drugs, things like that. Child

13 endangerment.

14 Q. This is who your son hangs out with?

15 A. No, he does not hang out with that person. But he is a

16 neighbor that I have concern about that tries to use my son.

17 Q. Ma'am, you talked about this note that's been referenced

18 discussing Eric Rogers, who was a domestic terrorist and in

19 the third person a violent -- carried out a violent act. You

20 don't know where that was found, do you?

21 A. Micah Childers would have to tell you that.

22 Q. Okay. So you don't know where it was found.

23 A. He -- and I just heard him. He said he found it in the

24 red shed.

25 Q. Aside from being found in the shed, you don't know where

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 23 of 37 Pageid#: 106
23

1 that was found, do you?

2 A. I'm sorry, could you repeat that question?

3 Q. Aside from knowing that it was found in the shed, you

4 don't know where in the shed it was found, do you?

5 A. You would have to ask Micah Childers.

6 Q. Okay. So your testimony that it was in some red bin from

7 2015, you don't know that to be true, do you?

8 A. If it was found in the shed, I -- I was cleaning and

9 found items from that. But no, Micah Childers would have to

10 tell you where he found that. I didn't remove it.

11 Q. Okay. So your whole story that this is somehow related

12 to his criminal justice class, that's all speculation. You

13 don't have a basis for that, do you?

14 A. He was in a criminal justice class and did case studies,

15 yes, I do. And he kept those things. He even has his mace

16 agree (phonetic) workbooks that he kept, his nycotography

17 (phonetic) workbooks that he kept.

18 Q. Ma'am, my question is you don't have any basis to testify

19 that this note is in anyway related to his criminal justice

20 class, do you?

21 A. I believe that's where it came from. But if I have a

22 basis or -- I don't understand the question.

23 Q. It's pure speculation. You don't have any idea, do you?

24 A. Yes, I do have an idea. I have seen my son's work when

25 he did it in 2016.

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 24 of 37 Pageid#: 107
24

1 THE COURT: I'm sorry, Mr. Lee, for some reason

2 we're not picking up your sound.

3 MR. LEE: Your Honor, I was speaking to Agent

4 Childers. I muted it. May I have a second?

5 THE COURT: You may. That's fine, just as long as

6 we know.

7 MR. LEE: My apologies.

8 BY MR. LEE:

9 Q. Ma'am, what is this neighbor's name that you've been

10 talking about that's got the multiple charges?

11 A. He is Rodney Nichols.

12 Q. Rodney Nichols?

13 A. Yes.

14 Q. Okay.

15 MR. LEE: Your Honor, I don't believe I have any

16 further questions at this time.

17 THE COURT: Mr. Stanford, further questions?

18 MR. STANFORD: No, Your Honor.

19 THE COURT: Ms. Carini, help me just a little bit

20 with the timeframe here. Do you recall the day that your son

21 was injured? What day it was?

22 THE WITNESS: Yes. It was June 2nd, Tuesday, at

23 7:10 p.m.

24 THE COURT: And what time did you say that you

25 arrived home?

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 25 of 37 Pageid#: 108
25

1 THE WITNESS: I had gotten home probably about 6:30.

2 And I was walking outside for exercise, so I entered the home

3 about that same time he got hurt. Probably about five minutes

4 before.

5 THE COURT: So you'd been outside for about a half

6 an hour.

7 THE WITNESS: Yes. I was walking around. Probably,

8 you know, because I have a very bad back. And so I have to

9 walk to get -- to be able to -- just after sitting so long.

10 THE COURT: And did you observe your son outside

11 mowing.

12 THE WITNESS: I can't remember. I don't think so,

13 no.

14 THE COURT: Well, do you have a very big lot?

15 THE WITNESS: Yes. It's a very big lot with -- and

16 then he also mows up the road for the neighbor. And I found

17 that note on the door and I just said, you know.

18 THE COURT: Now, you said that you found a note.

19 Was it on your front door?

20 THE WITNESS: Yes. Because my neighbor said, "Cole,

21 it's time to mow and weed eat." He was wanting Cole to come

22 mow and weed eat.

23 THE COURT: And what neighbor was this?

24 THE WITNESS: He is a man named Bill Nuckles.

25 THE COURT: Any relation to the Mr. -- I think you

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 26 of 37 Pageid#: 109
26

1 said it was Mr. Nichols who was the other.

2 THE WITNESS: They're not related in any way.

3 THE COURT: So it looked like that Mr. Nuckles had

4 just left a note on the door for Cole to remind him that it

5 was time for him to mow and weed eat.

6 THE WITNESS: Right.

7 THE COURT: So when you were outside, you were home

8 about 30 minutes before you ever went inside?

9 THE WITNESS: Yeah, I was trying to get a little bit

10 of exercise for my back because I had been sitting. I was

11 just walking. Our black top is pretty big there. I was

12 trying to get in -- I have a lot of health problems. I was

13 trying to exercise a little bit before I took my shower and

14 relaxed for the evening.

15 THE COURT: All right. So while you were there, did

16 you hear anything odd? See anything odd while you were

17 outside the home?

18 THE WITNESS: No.

19 THE COURT: Okay. And so you went in the home, and

20 I think you said you went in, did you go to a bedroom or a

21 bathroom area or somewhere to change?

22 THE WITNESS: My bathroom, ma'am, is straight back

23 in my bedroom when you first come in and then the stairs is

24 here up to his facilities. And I had gone back there and I

25 put on, you know, my robe. I was going to take a shower, but

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 27 of 37 Pageid#: 110
27

1 I said I'm going to go tell my youngest son, I remember now

2 after sitting and thinking about it, I said I have to tell him

3 that I'm back home. And so that's when we heard like a, you

4 know, some kind of sound. And he appeared in the entrance

5 way, Cole did. And I was -- I mean, we were traumatized from

6 what we saw. I'm doing my best to tell the details to help my

7 son.

8 THE COURT: Well, I mean, what we need to do is tell

9 the details as truthfully as possible.

10 THE WITNESS: I am, ma'am. That's all I can tell

11 you is that I remember -- and I drove him to the hospital and

12 he was bloody. And there's blood everywhere where he was

13 standing.

14 THE COURT: So you heard -- describe what you heard.

15 Before you knew that your son had been injured, what did you

16 hear?

17 THE WITNESS: I was in the bathroom. I got the

18 note. I think Cole had gotten home himself. I can't

19 remember. It's kind of a blur. But when I got home, I went

20 in to the bathroom to take a shower. And I said, oh, I need

21 to go tell Russ that I'm home. I went down to the end -- it's

22 a 40-foot room. I was about 40 feet away, and I sat down in

23 my recliner and I looked over at Russ and said are you hungry?

24 Do you need something to eat? Things like that. Then we

25 heard that noise. Next thing I know, I see Cole there and

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 28 of 37 Pageid#: 111
28

1 he's got his hands bandaged, "Mom, I need to get to the

2 hospital. I don't want to die. I had an accident."

3 THE COURT: And so did he come downstairs?

4 THE WITNESS: I don't know, because I was in the

5 room where you can't see the stairs. And I just -- I stood up

6 and heard him say, "Mom, I need to go to the hospital." And I

7 saw him standing there. He had blood everywhere. You know,

8 it was in his face and everything was damaged. It was very

9 traumatic to my child and to me.

10 THE COURT: At that moment did you ask him what

11 happened?

12 THE WITNESS: No, I just was -- I called 911, and I

13 said look, my son's had an accident. Look, I don't want him

14 to die. You can listen to the 911 call. I went in my

15 bathroom and put my clothes on. I'm driving down the road and

16 Cole's like, they're not getting here soon enough, I'll just

17 drive myself. I don't want to die. I said no, I will take

18 you on. And so I took him to the hospital. And he bled in

19 the van too.

20 When we got there, he said I could get on out. He

21 said, "Mom, I can't open the door." And that's when I knew

22 something was wrong with his hands. I had never looked

23 because I was about to vomit.

24 THE COURT: But your testimony is you didn't -- when

25 he showed up there with all the blood, you didn't ask what

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 29 of 37 Pageid#: 112
29

1 happened.

2 THE WITNESS: No, ma'am. I'm trying to save my

3 son's life. You can listen to the 911 call. I was like help

4 me, help me. I was in a state of shock. I couldn't even

5 remember my name. It was so traumatizing. You can ask my

6 15-year-old. It's not something -- when you see someone in

7 that shape, it's very traumatic. And I'm struggling to

8 remember because it's very traumatic to me.

9 The last time I touched my son was to pick up pieces

10 of his hand that I found in his room. It's very traumatic to

11 me. I've been through a lot. I would have never laid my head

12 down in the house knowing that was in there, and I told that

13 to Mr. Childers.

14 THE COURT: So, I mean, you do believe now that an

15 explosion occurred in your son's bedroom; correct?

16 THE WITNESS: From the evidence that they have

17 shared, yes. And I am very, very alarmed by that. And I want

18 my son to get the help he needs. And I know my house is safe

19 now, but we need to address the needs of what's going on and

20 help. I ask you to have mercy.

21 THE COURT: When did you --

22 THE WITNESS: He hurt himself. But he's given

23 himself a life sentence with his maimed hands.

24 THE COURT: Ma'am, when did you find this, the

25 remains of your son's hand in his room?

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 30 of 37 Pageid#: 113
30

1 THE WITNESS: When I was cleaning his room --

2 because I have to live in this house. I don't have anywhere

3 else to go -- and so I was -- Mr. Childers told me there was a

4 couple things I needed to get rid of anyway. I was cleaning

5 up where they had looked through everything. Everything was

6 in disarray. But we have to live here. So I was cleaning and

7 I found three pieces of my son.

8 THE COURT: Now did I understand you to say that

9 your son was in therapy, actively?

10 THE WITNESS: Yes. Since fourth grade. I've always

11 had my son in some kind of counseling.

12 THE COURT: And did I understand you to say that he

13 was treating with a psychiatrist currently, before this

14 accident?

15 THE WITNESS: Yes, ma'am. He's on Prozac and

16 Adderall.

17 THE COURT: And what was he taking the Prozac for?

18 THE WITNESS: Depression. Anxiety. She said that

19 it would help him to -- with his moods. You know, not to be

20 down. He had very low self-worth. After the first case, you

21 know, he couldn't find a job. Lots of things. So it would

22 help him with his depression, which I think he was diagnosed

23 with depression. You'll have to look at the files and see. I

24 don't want to misspeak about something, you know, officially,

25 but I do believe that's what it was.

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 31 of 37 Pageid#: 114
31

1 THE COURT: Mr. Lee, further questions?

2 MR. LEE: Just briefly, Your Honor.

3 CROSS-EXAMINATION (continued)

4 BY MR. LEE:

5 Q. Ms. Carini, I want to take you back to the 2016 incident.

6 There was drug paraphernalia found in your home, wasn't there?

7 A. At that time I do believe there was. I do believe you're

8 right.

9 Q. Okay. And there was a container with a green leafy

10 substance believed to be marijuana found; correct?

11 A. Correct. Whatever is in that report is correct.

12 Q. Okay. A partial container of rifle powder, additional

13 Co2 cartridges, a Disruptor Avon shotgun round, and then a

14 number of bottle rockets. Does that sound right?

15 A. If it's in the report what they found, they would not

16 lie.

17 Q. Okay. So did you know your son was using drugs in your

18 house?

19 A. No, sir.

20 Q. So back in 2016 he was able to hide drug use and the

21 manufacturing of explosives from you; is that correct?

22 A. Yes.

23 Q. All right. And now fast forwarding to June of 2020, did

24 you know that your son was producing the highly dangerous

25 explosive TATP in your home?

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 32 of 37 Pageid#: 115
32

1 A. No, sir. I would have never laid my head down in that

2 house if I had knowed that.

3 Q. Okay. Did you know he was creating a pressure cooker

4 bomb in your house?

5 A. No, sir.

6 Q. Okay. So he -- if your testimony is to be believed, he

7 was able to hide all that from you also?

8 A. He was.

9 Q. And if your testimony is to be believed, when he blew off

10 almost all the fingers on one hand and severely damaged his

11 other hand, you believe that that was from a lawn mower

12 accident?

13 A. He -- I didn't see the wound. He had everything in a

14 tourniquet. So I believed him, yes. When he told me that, I

15 believed my son, yes.

16 Q. Okay. So he was able to hide the fact that he'd blown

17 his hand off almost from you; correct? if your testimony is to

18 be believed.

19 A. Yes.

20 Q. Okay. And yet you think you can adequately supervise him

21 if he's to be released to your home, knowing that he was able

22 to hide all of these things from you, convince you of this

23 lawn mower accident?

24 A. I am not a perfect person. Yes, he did hide things from

25 me. Do I think he's a different person after this accident?

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 33 of 37 Pageid#: 116
33

1 Yes, sir, I do believe that he would be safe. And I'm not

2 afraid of my son. I want to make it clear, yeah, he did hide

3 things from me, and I did not go into his room. I did not go

4 upstairs. I just beg mercy for my son. Whatever can be to

5 help my son.

6 MR. LEE: No further questions, Your Honor.

7 THE COURT: Mr. Stanford, further questions?

8 MR. STANFORD: Just one, Your Honor.

9 REDIRECT EXAMINATION

10 BY MR. STANFORD:

11 Q. Ms. Carini, if the Court does release him on bond,

12 sometimes the Court has people serve as a third-party

13 custodian, which means you'd have to monitor what he's doing

14 and actively go and check on these things. And if you saw any

15 way that he's violated his release conditions, you would have

16 to report that. And is that something you feel you'd be

17 comfortable doing?

18 A. Yes, sir.

19 Q. Okay. And you feel like you know what you're looking for

20 this time?

21 A. Yes.

22 Q. Okay.

23 MR. STANFORD: That's all I've got, Your Honor.

24 THE COURT: Ms. Carini, have you spoken with your

25 son since you talked to him at the hospital?

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 34 of 37 Pageid#: 117
34

1 THE WITNESS: Yes. We had a very good conversation.

2 THE COURT: And has he told you what happened to

3 him?

4 THE WITNESS: We have not discussed details. But my

5 son told me in an e-mail, "Mom, I felt more sorry for you than

6 me because no mother should see her son in that shape. I'm so

7 sorry."

8 And he wants to live a better life. He's not making

9 excuses. He knows what he did was wrong, what he did to me

10 was wrong. And he wants to have a better life. He knows he

11 needs help. And he can be helped. And that's the main thing

12 is that he was in a bad place. I think he -- I think he's a

13 different person now, you know, the shock of it, the injuries,

14 the lifetime of living differently with one hand. He has a

15 lot to -- a trauma. We all have trauma. And he needs those

16 trauma injuries -- I believe need to be addressed physically

17 so that he can use his hand to the best of his -- for the rest

18 of his life. If he needs physical therapy, I want him to get

19 it. You know, 39 hours after he had his hands repaired, he

20 was off of pain medicine and in jail. And he endured that.

21 And he's faithful and he prays. Did he do wrong? Yes, he

22 did. And he knows that he did wrong. And he is willing to

23 face the consequences for what he did is what he told me and

24 he wants to live a better life. And he hurt himself.

25 THE COURT: Ma'am, let me ask you this.

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 35 of 37 Pageid#: 118
35

1 You say he know he's done wrong. What has he said

2 to you that he did wrong?

3 THE WITNESS: That's all he said. He said, I know I

4 did wrong, you know, because he's maimed. He says, you know,

5 I know right from wrong. My son knows right from wrong and he

6 needs help. That's all he said. I mean, we were on the jail

7 phone and it's recorded. But when we were talking, you know,

8 I think that's the first step in getting help is knowing I

9 need it. And knowing that, you know, I want my son to get

10 help. I need you to help me.

11 THE COURT: Ma'am, my question to you is this: From

12 the time of this accident until today, have you asked your son

13 what happened to you?

14 THE WITNESS: I did. And he said he blew his

15 fingers off when he was making targets to shoot.

16 THE COURT: So he's now admitted to you that his

17 hands were injured in an explosion?

18 THE WITNESS: In just sort of like one or two

19 sentences, that's what he said. He did not intend to hurt

20 anyone. But he hurt himself more than anybody.

21 THE COURT: And you've heard the testimony today

22 with regard to what was found in your home; correct?

23 THE WITNESS: Yes. And I'm surprised by that. I am

24 shocked. I did not know what TATP looks like. I don't know

25 what peroxide and ammonia looks like. There's no way that I'm

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 36 of 37 Pageid#: 119
36

1 a scientist or chemist, I don't understand. After cleaning

2 the room up and Mr. Childers advised me, I understand a little

3 bit more about it. Now I know what it looks like. But I was

4 clueless. I really thought my son was doing well. So did his

5 counselor, the psychiatrist, the people he was working for.

6 THE COURT: All right. Anything further, Mr. Lee?

7 MR. LEE: No, Your Honor.

8 THE COURT: Mr. Stanford?

9 MR. STANFORD: No, Your Honor.

10 I will -- I don't have any more questions, if that's

11 what you were asking, of Ms. Carini.

12 The only thing -- yes.

13 THE COURT: Thank you, Ms. Carini.

14 (Testimony of Ms. Carini concluded at 3:00 p.m.)

15

16 INDEX

17 DEFENSE WITNESSES: PAGE

18 KAREN MICHELLE CARINI

DIRECT EXAMINATION BY MR. STANFORD 2
19 CROSS-EXAMINATION BY MR. LEE 14
CROSS-EXAMINATION (CONTINUED) 31
20 BY MR. LEE
REDIRECT EXAMINATION BY MR. STANFORD 33
21

22

23

24

25

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116
Case 1:20-cr-00015-JPJ-PMS Document 35 Filed 08/07/20 Page 37 of 37 Pageid#: 120

1 REPORTER'S CERTIFICATE

3 I, DONNA J. PRATHER, do hereby certify that the

4 above and foregoing, consisting of the preceding 36 pages,

5 constitutes a true and accurate transcript of my stenographic

6 notes and is a full, true and complete transcript of the

7 proceedings to the best of my ability.

8 Dated this 7th day of July, 2020.

10
DONNA J. PRATHER, RPR, CRR, CBC, CCP
11 Federal Official Court Reporter

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Donna Prather, CCR, RPR, CCP, CCB

Official Court Reporter for the U.S. District Court Western District of Virginia
(276) 628-5116 x8119