THE COURT: All right. If you would please come forward, the clerk will administer the oath or affirmation.

SHAUNICE WARR

called as a witness herein, being first duly sworn, is examined and testifies as follows:

THE COURT: Please take the witness stand. Ma'am, go ahead and have a seat.

I would like to make sure that we can all hear your answers when you give them, so when you answer please speak into the microphone. You can adjust it, move it around if you need to. And would you spell your last name for me?

THE WITNESS: My last name is Warr, W-A-R-R. THE COURT: Okay. Thank you.

Mr. Hicks, you may proceed.

EXAMINATION

BY MR. HICKS:

Q And would you spell your first name?

A Shaunice, S-H-A-U-N-I-C-E.

Q Okay. And, Shaunice, in what town do you live? A I live here in Bisbee.

Q Okay. And who are you employed with?

A Federal government. I work for the Border Patrol.

Q And how long have you been with the Border Patrol Shaunice?

A Seven years.

Q What do you do as a Border Patrol Agent?

A We patrol the line. We look for those who have entered illegally, arrest them. We look for people who are bringing drugs into the country. Many different things like that.

Q In, in that capacity did you know Paul Adams?

A I did. He was an agent at my station when I started there in Douglas, Arizona.

Q In Douglas, Arizona.

A Yes, sir.

Q And can you tell the court, um, why was Paul Adams

terminated from Border Patrol?

A The first -- he was actually -- the first time he had given his car or loaned his car to an illegal, um, woman, that he was sleeping with actually. She was taking something illegal up to Phoenix, was pulled over; the registration came back to him. They put him on light duty, did an investigation. And what they did is they took his law enforcement away from him. So they took his badge, his gun, and gave him a missions support job.

The second time he was fired. He made terroristic threats against our station. And it's the Douglas Border Patrol station. He had to go to court for this. He had to go to classes, anger management. And then he had to reapply. They brought him back. And I believe he was at Naco station in the missions support roll for like a week when he was arrested, and obviously fired again.

Q Were you surprised that he had made terroristic threats against the Border Patrol station while he was a Patrol agent?

A Not at all.

Q Okay. Why?

A Um, he had talked about things like that before, um, just in passing. Or he would say: Oh, I'm joking around. Um, whenever he was angry he had a quick temper, quick, quick temper. And if you made him angry, he was going, like he was going to come for you. So that day he was angry at some supervisors; and, boom: I'm going to come back here, and what if people just started picking off as they come out of the station.

Q When you were in the room with Paul at the Border Patrol station did you make an effort to make sure that you were not the first person that he would confront?

A I was always personable to Paul. I would say hi because I was not going to be the first one when he went crazy to be shot basically. I knew his day would come. He was crazy. He just had this explosive personality. He -- I don't know how to explain it. He had a horrible temper.

And he — I mean, even other agents would say to me, you know: Hey, does that guy go to your church? And I said: Well, his wife and family go to my church; he comes to my church every now and then. Because they were like, he's, he's really weird, he's crazy, he gets that look in his eye. And I said: Oh, kind of like he might go postal? And they said: Yeah, kind of like that. They had seen his you were in the station with Paul, you always made it a situation where if he did go ballistic you would not be in the line of fire to start with?

A No.

Q And could get your gun out and do what you needed to do?

A Yes.

Q Yes?

A Yes. Yes, sir.

Q Did you also, um — you're a member of the Church of Jesus Christ of Latter Day Saints? A Yes, sir.

Q And Paul occasionally attended?

A Yes, sir.

Q And Leizza is a member, and her children are members?

A Leizza and her family, yeah, Leizza and the kids are. He had been ex-communicated, yes, sir.

Q Paul had been ex-communicated?

A Yes, sir.

Q In that role -- and let me ask you this too. Were you a friend of Leizza's?

A Yes.

Q And in the role of being a friend of Leizza's and being a member of the same church and being involved in that way, did you get to know Leizza?

A I did.

Q Okay.

A As well as anybody could get to know her.

Q And how long have you known Leizza?

A Seven years.

Q And would you say that you're her best friend?

A Probably.

Q And you've been around her a lot?

A Yes, sir.

Q Tell the court what was it during those years, how often did you go to the house, how often did you visit Leizza at home?

A Um, well, Paul didn't allow visitors at the house. wasn't able to go to the house for visits very often unless he was out of town, um, caring for his parents in San Diego, working in Tucson, that kind of thing. Then they would invite me over to the house. There was a couple of times he was working, she invited me over, um, to watch some programs that were on our church television, that kind of thing.

Q Okay. And did you also see Leizza and the children at church with Paul when Paul was in town; and when he wasn't in town?

A Yes. Leizza and the kids came every Sunday. Maybe they missed five in six years, five times in six years.

Q Okay. And did you observe any differences between when Paul was in town, differences in the children when Paul was in town and when Paul wasn't in town?

A Oh, definitely. I had all of the kids in my Sunday school class, the primary Sunday school class, the little kids. So I've had all of her kids with the exception of phonetic). She was young.

Um, when Paul was in town you could tell the kids were —— they would come in one of two ways. Either extremely combative and like touchy, fighting and everything. It was like there was just tension. And you could tell one thing would just set it off. And that's usually what would happen. We don't have many kids in our primary, so the Adams kids were the majority of them. Primary is the young kids, 12 and under.

Um, or they would come in, and it would be silent. They wouldn't look me in the eye. They wouldn't look each other in the eye. They weren't touching each other. They weren't, they weren't doing normal kid stuff.

10 When Paul was out of town — Paul went on an extended compassionate leave to take care of his parents for three months. When he did that the kids were kids. They were fun. They still picked at each other, but it was normal kid stuff. I mean, it's six kids under the age of nine, you know. They would pick at each other and stuff.

But they had fun. And that was who they were. They would act like themselves. So I, I could tell they -- they used to sit with me during the main meeting, during sacrament meeting, which is kind of like our main mass meeting. And then I taught them for the second two hours of our block. I could pretty much tell as soon as they came in for sacrament meeting when — what was going on.

Q And, um, did you have times when you spoke with Leizza personally about what was going on at her home?

A I did.

Q Okay.

A From the first time I went to church there I could tell there was something different about this family, something was going on. I have a bachelor's in psychology. I also was a college woman's basketball coach. I've dealt with kids. I've, I've lived around the world. I have known a lot of people. I know things about people. I've studied people. I could tell there was something off and something going on. And I would notice that she would hang out after church. And eventually I figured out it was because that's where Paul wasn't. It's the one place that she could go, that he would let her go, without being there. He gave her permission to go with the kids. So I would start hanging out after.

I was also called a visiting teacher. We have visiting teachers through —— you pair up and you visit, um, each other. It's a Mormon program, Jesus Christ of Latter Day Saints program. And I was assigned to Leizza. So I would hang out after church and talk with her and help with her kids. And I got to know her kids obviously really well as I taught them. And I got to know her well through hanging out after church with her.

Q Did there come a time — well, let me ask you this. Did Leizza ever talk to you about abuse?

A No.

Q Of her abuse?

A Not until after Paul was arrested.

Q Of him abusing her?

A Right. I tried to get her to. I asked every way possible. I asked the kids. There was fear in the house. I could tell because five-year-—olds give up everything. They will say anything in the middle of class -- my dog peed on the rug —- in the middle of Sunday school class. You know, we're studying the bible, and they just blurt out stuff.

These kids would not talk about their dad, what went on at home. And I asked, you know, in different ways and different means, and different kids. And I asked Leizza in different ways. But I could tell that there was a lot of fear in the house. The kids were afraid of something. She was afraid of something. So I knew something was going on, but I didn't know what it was.

Okay. After Paul was arrested did you talk to Leizza?

Yes, I did.

Okay. And what did she tell you at that time? She told me that there was a lot of physical abuse, that there was a lot emotional abuse.

Q Of who?

A Of her and the kids. Um, he threw things. He hit her. He hit the kids. He yelled at them incessantly. And the hardest thing I think for them was they didn't know what -- how he was going to be when they got home, or when he came home. So it was either he was great and let's go get ice cream; or, you know, shut up, I'm trying to do this and swearing at them and —- but they didn't know which one. So it was like walking on eggshells and tension at home because they didn't know how to act. They didn't know how he was going to react.

Q Did she ever she tell you? talk to you about —- what else did she tell you?

A Um, well, at she had found out, um, one point she did disclose to me that that Paul was molesting (phonetic). And, um, I had advised her to leave him. I knew something was going on. And I told her flat out she needed to leave him, pack her kids, pack her car, and go to San Diego and live with her family. Um, she told me after Paul was arrested that ——

Q Okay, let me back you up here.

A Sorry, sorry.

Q She told you after Paul was arrested that Paul had been molesting (phonetic)

25 A Just the one time I found out that she had found that out.

Q Okay. And so go ahead. You told her pack up,

leave.

A I told her I would help her leave. She didn't —-I said call me and let me know, and we'll make it happen. I'll take care of Paul.

Q What did you mean you'd take care of Paul?

A Um, I meant I wouldn't let him follow her. I would do what I needed to do, not to let her -- let him go after her. I knew something awful was going on in the house. I didn't know what it was. But by the time —— 12 she was pregnant with I knew she needed to get out of 13 the house.

Q Let me ask you, in your opinion Paul was a violent person?

A. Oh yeah, definitely.

Q And he was an unstable person?

A Very much so, up and down.

Q You could have taken care of Paul if Paul -- what? Including when she was leaving the home. Right?

A Uh-huh.

Q Including shooting him if you had to

23 A Yes.

24 Q Okay. But could you take care of Paul if he followed her to California?

A No.

Q Could you --

A And he would have.

Q And could you have taken care of Paul if he became erratic and killed her and killed every single one of their children?

A If I wasn't there? No

Q If you weren't there.

A No, no. And that scared me.

Q Was Paul capable of that?

MS. RANSOM: Objection, foundation.

THE COURT: Sustained.

MR. HICKS: Wait.

THE COURT: Sustained.

BY MR. HICKS:

Q The -- but in any event, you know, you could of —-— you made it clear to Leizza that she could leave, and you would make sure that she would be able to leave?

A Yes, sir.

Q What's Leizza's personality like?

A She's very different. Um, she has a hard time communicating. She doesn't communicate normally.

Q What do you mean by that?

A I don't even know how to describe it. It's kind of like if you've met somebody who has —- I don't know. I have a cousin who has high functioning autism and Asbergers's.

MS. RANSOM: Object to foundation. This is not a medical doctor.

THE WITNESS: I do have a cousin who has ——

THE COURT: Let me rule on the objection. I'll overrule that. She's talking about a cousin, presumably has knowledge within the family.

BY MR. HICKS

Q You're not saying Leizza has Asberger's or autism. ANo.

Q But you're saying ——

A I'm not trying to diagnosis her or anything like that. I'm saying she has similar characteristics, in that when you ask her a question she responds in a different way than any normal person I've ever met. She just, like socially she's, she struggles. She doesn't know how to act socially. She's ——

THE COURT: Can you give me an example? You mentioned that when you ask her a question she doesn't respond like people would be expected to respond. Can you —- give me an example, if you would.

THE WITNESS: I don't know. You ask her about her family, and she will respond about an incident or something that -- like one tiny incident that occurred, you know, five years ago or something like that. Like you're trying to ask about a current question. And I don't know if she doesn't understand your questions or she doesn't think linear. I'm not sure what it is. But she, like goes off on tangents that are very different than anybody I've ever met. You have to kind of like interpret what she's saying.

THE COURT: So if I understood you correctly, you might ask how is your family, and most people would say, oh, we're doing fine or, you know, I have some hard times coming up or something like that. But she would focus on some

incident that happened a long time previously, maybe years before ——

THE WITNESS: Right.

THE COURT: -- and tell you about that?

THE WITNESS: Right. And it usually didn't quite make sense to what you were talking about previous to that. THE COURT: Okay. You may proceed. Thank you.

BY MR. HICKS:

Q Is she a —- in your opinion, you know, there's

some people that are perceptive of the things around them and some that were oblivious. Which is she closer to?

A She's clueless, socially clueless. Yes, I would say that.

Q Clueless?

A She, yeah, she doesn't know things that are going on around. She's very naive. She doesn't recognize things that are happening around her.

Q And not just clueless, but clueless to an absurd degree?

A Yes. Her husband was sleeping with multiple women, and she didn't know.

Q As an example?

A As an example.

Q Let me, let me give you an example and ask you is this what you're talking about. I went over the presentence report with Leizza. And I said: If there's anything incorrect, Leizza, be sure you tell me. And at the end of it she said: I'm 35, not 32. And the, the Drakes (phonetic live at 103 Van Dyke instead of 101 Van Dyke.

MS. RANSOM: Objection, leading. Foundation, calls for speculation.

THE COURT: Yes, sustained.

BY MR. HICKS:

Q Is her, in other words, is her, are her responses linear, rather than understanding any kind of, of —-

A That's an example of how she answers questions oddly. Like to me, if I'm going to court, I'm not —- I don't care about the addresses; I don't care about my age. What I care about is the bulk of what's in the case. Like is my, are my legal things in order. Is what I said written down. Not addresses or things like that. Like that, who cares? Right?

Q Right.

A But is the bulk of my path in order; is that correct.

Q You're familiar that at some time during this case, and I forget when, Leizza was hospitalized for attempting to commit suicide?

A Yes, sir.

Q Tell us about that.

MS. RANSOM: Objection, relevance.

THE COURT: Overruled. You may answer.

THE WITNESS: She ——

MS. RANSOM: Your Honor, state will also make a lack of disclosure objection. State's never had any disclosure of medical records or anything related to this defendant, no ability to prepare for this hearing and rebut those sort of claims.

THE COURT: Mr. Hicks, response?

MR. HICKS: Your Honor, this is a mitigation hearing. The rules, I believe, are different. For example, hearsay is allowed. The fact that Leizza was in the hospital, placed involuntarily there for attempting to commit suicide, is relevant. And it's relevant —

25 THE COURT: Well, I overruled the relevance objection. Now the objection that I need to deal with is lack of disclosure.

MR. HICKS: I have been practicing for 30-some odd years. I have never seen a rule that you have to disclose everything that you're going to attempt to bring out ina mitigation hearing. It -- I don't know that any rule exists in that regard.

And I would argue that by definition we can not disclose everything that's going to be brought out in a mitigation hearing when we get the presentence report, um, a few days before, when we get letters of recommendation a few days before, when -- so I, I, I guess I would argue that if there is such a rule, that the court should, for the sake of attempting to know as much as possible prior to a sentencing in this case, understand the facts. I don't understand what the harm is.

MS. RANSOM: If I may?

THE COURT: Yes, go ahead. I'm going to rule on it, but I'll allow you to go ahead and reply.

MS. RANSOM: State made a specific request for disclosure of defense counsel before the pretrial hearing, so it would be Rule 15.E, written request for disclosure potentially relevant to proceedings. And of course defense under Rule 15.2 is required to provide documentation in support of its defenses.

THE COURT: Well, it's not so much a defense as it is something in mitigation. I will overrule the objection.

However, in the event, Ms. Ransom, that there's something in this testimony about the suicide attempt that you would want to explore to perhaps rebut, then make a request for a continuance of the balance of the hearing to allow that to be explored. I would consider that request at the time it's made.

The objection is overruled. You may proceed.

MR. HICKS: Your Honor, that's all I have on it. I simply want to bring out the fact that during the course of this case Leizza was hospitalized for attempting to commit suicide. And I wanted the witness to testify about that.

THE COURT: So was that it? I didn't know if we were going to hear more about that, or particulars of it, or anything along those lines.

MR. HICKS: No. That's it.

THE COURT: Okay.

MR. HICKS: The —— I think that's all I have of this witness. Thank you.

THE COURT: Thank you, Mr. Hicks.

Ms. Ransom, cross.

EXAMINATION

BY MS. RANSOM:

Q Good afternoon.

A Good afternoon.

Q Can you remind me of how to pronounce your name?

A Shaunice Warr.

Q Warr?

A Yes.

Q All right. Did you ever report Paul Adams' erratic conduct at Border Patrol to any of your superiors?

A Yes. We talked about -- I talked with my patrol agent-in-charge after he had made the terroristic threats. We had quite a long — actually a couple of long conversations about Paul.

Q All right. And how far into his Border Patrol career was the terroristic threats incident?

16 A Um, he had been in longer than me, so I'm not sure exactly.

Q Okay. Did you find him to be potentially violent as you previously described before the terroristic threats incident?

A Yes, sir. Yes, ma'am. Sorry.

Q But you've never reported it before the terroristic threats incident?

24 A No, ma'am.

25 Q Okay. And that was years and years and years of knowing him?

A No. Before that I had only known him for three-and-a-half years, three years.

Q Okay. Three-and-a-half years?

A At that point.

Q All right. You mention that you are, you think you're Mrs. Adams' best friend, the defendant?

A Yes, ma'am.

Q Okay. You met her at church?

A Yes, ma'am.

Q Does she have other people at people at church? the church that interact with her or are friendly with her? You've seen her interact with her?

A Yes, ma'am.

You've seen her interact with her?

Q How many?

A Most Mormons are pretty friendly, I would say. They're all friendly to her. It's hard to get to know her as a person. She's ——

Q Okay.

17 A —- kind of keeps things on the inside.

A But people were friendly with her?

A Oh yeah.

Q Did the church generally know about Paul Adams being ex-communicated? The church members?

A Yes, ma'am.

Q When that all happened were people supportive of the defendant?

A Yes.

Q And did anybody —- she was active in the church on certain groups. Correct?

A Yes, ma'am, she was active in church.

Q All right. What sort of, what sort of extracurriculars did Ms. Adams participate in within the church?

A Oh, at the church?

Q No, within the church, like piano and choir or?

A Oh, she played the piano for our primary.

Q And was she also active in choir?

A Um, I don't know if she was active in choir before he was arrested. She definitely was after. She wasn't while —- since I've known her and the time before Paul was arrested, she was not.

Q When did she join and start working on the piano for the church?

A Oh, she's been doing that since I've known her.

Q And you've known her for seven years?

A Yes, ma'am.

Q Are there practices related to the, to playing the piano?

A No. She usually just plays on Sundays. And she'll practice after. Or during while we're teaching the little kids, she'll play and practice.

Q Were there times where she needed to come and participate in activities by herself because her kids couldn't be watched?

A I, I don't know if she participated in, on any outside of Sunday activities.

Q All right. So if she told officers that?

A Before he, before he was arrested, I'm not sure. Q So if she told officers that there were times where she needed to go to church activities where the kids couldn't come, she would be mistaken in that respect?

A No, not, not to my knowledge. I didn't attend all of the extracurricular activities.

Q Okay.

A I can only speak to the ones that I was at. And I didn't attend many. I work midnights, so usually at night I'm heading for work.

Q Okay. You mention that Paul would be out of town and he — and you would come over when Paul was out of town?

A Yes, I came over a few times, yes.

Q And did Leizza ever express fear that, you know, you were helping her violate one of Paul's rules?

A Not while he was gone, no.

Q And you just would come over whenever you felt like it?

A No. They would invite me.

Q Well, after an invite would you come over?

A Yes.

Q How frequently did you visit when Paul was out of

town?

A Um, usually -- I didn't, I didn't visit that many times. He wasn't gone a lot. I came over a few times while in town but working. He went to work in Tucson for a bit. And then came over a couple of times while he San Diego, just when they invited me.

Q So the defendant would let you come over in violation of Paul Adams' rule even when he was working and could have come home early?

A Right. And he did come home when I was there, once or twice.

Q Okay. Was there any reaction of the family to him coming home?

A They all kind of looked like, like kind of like, oh crap, he's home. Um, Paul had a respect for me. He didn't respect any women really. But I pretty much ignored him because I didn't respect him at all. I can't get into what he is. But, so he didn't do anything while I was there. I can't say to what happened when I left. I was concerned after I left.

Q Did Leizza ever have bruises on her body at church?

A Not that I could see. She usually wore full length skirts.

Q Did the kids ever have bruises on their body?

A Not that I could see. They usually wore long sleeve shirts and pants.

Q Any of the kids ever blurt anything out about daddy hitting them or smacking them?

A No, ma'am. Not until after he was arrested.

After he was arrested they did.

Q And Leizza, after he was arrested, explained to you that there had been some abuse?

A Yes, ma'am.

Q Do you know how long after he was arrested she made these disclosures to you?

A Pretty soon. Same with the kids. As soon as they found out he wasn't going to be coming home, they talked to me.

Q When you say soon, what do you mean?

A I mean like the next couple of Sundays.

Q Within a few weeks?

A Yes, ma'am. As soon as they found out he wasn't going to ever be back, they felt comfortable talking.

Q Did Leizza Adams ever disclose to you that she had hit her kids?

A Um, she did. She told me that Paul had given her options. Either he would beat them or she had to. So she would do it so that it wouldn't be as brutal.

Q Did she tell you how often she beat her kids?

A No.

Q Did she tell you she aimed for clothing areas so there would never be bruises at church?

A She did not tell me that, no. She just told me that she was given an option.

Q Now I want to make sure I understand the timeline because it was bouncing around quite a bit.

A Yeah, I kind of jumped back and forth.

Q You said — did you ever offer to aid Mrs. Adams

in leaving?

A I offered when she was pregnant with for about the last year. I guess it was a year-and-a-half. I think was 18 months old when Paul was arrested. When she was pregnant with and from then out I said: You, you need to leave this guy.

Q But at that time she had never disclosed any sorts of abuse to you?

A No. I knew something was going on. But I didn't know -- was it sexual, was it physical, was it emotional. I didn't know what it was. But I knew from the way the kids acted, they -- the way she acted, there was something going on in the home. But I didn't know what it was. And I couldn't get them to tell me.

Q Is it possible that you had offered to the defendant to help her leave the home longer? Like more like five years back?

A No. I don't believe so. For sure I told her when she was pregnant with like you need to leave that house, like you need to leave him. You need -- I will go help you. At that point I had, um, the support of my fellow Border Patrol agents.

Q All right. And what prompted that conversation Mrs. Adams?

A I just felt like things were, I don't know, the were getting worse. It seemed like they were, I don't know, things were getting worse. There was more and more tension, more often. Um, just some ways that was acting, things like that. Just different. Like I've seen other kids that have been abused. I have studied some abnormal psych when I was, you know, in child psychology when I was getting my degree, things like that. Just like classic symptoms that we studied.

24 Q Did you talk to defendant about that and say: Obviously, your children are being abused?

A I said: Leizza, I know something is going on in your home. I need to know what is going on. Like nothing would ever be said. I said: You need to leave him.

Q Did you let her know that it wasn't only you but other Border Patrol agents that were supportive of and willing to aid her in leaving?

A Yes. Paul hadn't even told her that he was fired for the terroristic threats. And apparently I was the first one that told her that. And at that point I was like: You, you need to leave. Like you need — he's now risen to the point where he's out loud angrily threatened a federal agency. You should -- you need to pack your stuff. And you need to go home and pack your stuff in a van and get your kids and go.

Q And what was her response?

A Oh, and then she would start talking about something else. Anytime I got close to that conversation she would change the subject. And so I always left it with call me. If anything happens, you decide, you call me; and I will be there any time of the day, any time of the night. You call me.

Q And did she ever call you?

A Um, she texted me a couple of times but not about leaving. Um, I found out later Paul had cloned their phones. So a couple of times at church she would say:

Don't text me, don't call me. And I was like: That's kind of weird, you know, because I want to check in on you. And I found out later that he had cloned the phones so everything, all the texts she got and all the phone calls she got, he was also getting.

Q Would she likewise be able to see all of his activity on that cloned phone?

A No, no. She didn't see what he was getting. He saw what she was getting.

Q Do you know when that happened?

A I believe it was right -- I don't know this for sure. But it was right before the, like the year before the terroristic threats and right around the terroristic threats.

Q What year was the terroristic threats?

A It was oh, 2,000 -- well, when was he arrested? Because it was two years before he was arrested. So 2015? Give or take.

Q All right. And you said Paul was on an extended leave to California at some point?

A He took a couple of compassionate transfers to go help his parents.

Q And when were those?

A I don't know the years. They were three months. He got 90-day compassionate transfers from the Border Patrol.

Q And so he took three months at a time?

A Right.

Q And he was gone the whole time to your knowledge?

A Um, he may have journeyed back and visited once or twice during the time. But most of the time he was gone.

Q Is that during one of the timeframes when you had offered to help Leizza Adams leave?

A Um, no. He didn't go visit after, after she was pregnant with I don't think. I'm not positive on that. I didn't write down all the dates. I don't know.

Q Okay. But you believe that you had not offered to assist her to leave until she was pregnant with You don't think you did it before that?

A I think that is when I first, because I think that was right around the time that the terroristic threats and stuff like that. And I was like this guy's —— I mean, he just threatened a Border Patrol agency, you know. What would he do to his family? What would he do to our church? You know.

Q After 2015 did Paul Adams leave town to go to Tucson sometimes?

A He did while he was -- yes. I believe he was working as an Uber driver up there or something.

Q And that's some of the times when you would come visit?

A Uh-huh.

Q Is that a yes?

A Yes.

Q Just for the court reporter.

A Yes, ma'am. Sorry.

Q No problem. So how long would he be gone when he was up in Tucson working his second job?

A It would be different times, but I didn't always know.

Q Several hours?

A Oh yeah. Sometimes days at a time.

Q How many days at a time?

A It differed. I didn't always know.

Q Are we talking two to three or a week?

A Sometimes it was two to three. Sometimes it was a week. He has a brother who lives in Casa Grande, and he would stay up there.

A So this is after 2015?

A Yes, ma'am, because he was on administrative leave.

Q All right. You, you mention that Leizza Adams doesn't communicate like, like a standard person. Does she know right from wrong?

25 A Yes.

Q You mentioned she didn't know about affairs that her husband was having on her. Have you ever known of other women who had no idea that their husband was having an affair?

A Yes.

Q Sometimes people can hide those things pretty effectively?

A Yes, of course.

Q And I'm very confused about the, the conversation that you were talking about protecting Paul —- or protecting Leizza from Paul because it sounded like you were talking about in the context of him already being in pretrial detention. When did you have this conversation with Leizza that you would protect her from Paul if necessary?

A Oh, when I was telling her that she should leave

Q This is back in 2015?

A Right, when I told her she needed to pack up her stuff and go. And then one day she said: Well, what if Paul's there; I can't pack my stuff. And I said: I'll go with you. I'll go with you. I'll take care of Paul. Go pack your stuff and go.

Q You just said one day. It makes me feel that you had this conversation more than once.

A Yeah, I talked to her multiple times about leaving him.

Q All right.

A On Sundays.

Q During Sunday church you would talk to her about it?

A After church, yes.

Q And did you make it clear that you had a place for her and her kids to stay?

A No. Her family lived in San Diego. Her extended. 10 All of her brothers, her sisters, parents.

Q But you'd help her get there?

A Correct.

Q And so sometimes in response to that question she had a nice linear answer for you, some concern with other things?

A She had a concern that Paul might be at the house.

Q Okay.

A And another time she said: He'll follow me if I go somewhere.

Q All right. And what did you tell her?

A That I didn't have an answer for her because he would. He would have. And I said: Well, you'll have to go to the police in San Diego, you know.

Q Did you offer to help her with that or make sure that her family helped her?

A Yes.

Q Sounds like you pretty much had a plan laid out for her?

A I tried to, yes.

Q You seem like an organized person.

A (Laughing) I don't know if I would go that far.

Q You also made a comment about Leizza disclosing to you that she knew about Paul molesting the girls; or one girl? I mean, what was the content of that discussion?

A One girl,

Q And how did that come up?

A She was reading through her journal. And she had written it in a journal.

Q Did -- what did she write in the journal?

A That Paul had gone to our bishop and confessed. And the bishop called her in and let her know that she had stepped over a huge line in the sand that she had drawn before that. She had drawn a line saying if you ever touch my kids. So he called her in, said this happened, Paul confessed to me, he told me he did this to one of you needs to leave the house.

Q All right. What did Paul confess to doing to

A Sexually molesting her. Performing oral sex on her ——

A I didn't hear what.

Q -- is that what Ms. Adams said?

A She didn't tell me specifically what it was at

that point.

Q Okay. i! A She just said it was sexually molesting

Q So if she said to the probation officer that he performed oral sex on their child?

A That would count as sexual abuse.

Q Do you think she was accurately describing it to the officer?

A Yes, ma'am.

Q And do you know what year this was?

A I don't. I don't. I'm not sure. I just know it was in one of the journals she was reading.

Q Did she —

THE COURT: Well, excuse me. If I could follow up

on that. The question was a little bit ambiguous. Do you know what year this was? Because there are two possibilities here. First of all, what year if you recall was this conversation with Ms. Adams when she had her

journal? When did that conversation with you —— THE WITNESS: When did she tell me?

THE COURT: Yes.

THE WITNESS: It was this past year.

THE COURT: So it was after Paul's death.

THE WITNESS: Yeah. I didn't find out until after Paul was gone.

THE COURT: And the question that Ms. Ransom asked you, about what year did this happen, you were answering it in terms of the actual act by Paul against

THE WITNESS: Yes, your Honor.

THE COURT: And you don't know when that happened. THE WITNESS: I'm not sure what year the journal

was from or —— no.

THE COURT: All right. The presentence report contains a lengthy statement from Leizza Adams. And I believe she attributes that act, or at least the conversation with the bishop, to 2010. Do you have any way of indicating that that's correct? Incorrect? Or anything else to help us pinpoint the date?

THE WITNESS: I moved here in 2011. And it was before I moved here. And I mean that would make sense because the bishop that was the bishop who told her was released right before I got here in 2011, so that would make sense. 2010 would make sense.

THE COURT: 2010 would make sense?

You may proceed.

BY MS. RANSOM:

Q Thank you. What was the name of the bishop who participated in this disclosure?

A Do I have to tell you?

Q Yes.

A It was Bishop Herrod. Q How do you spell that?

A H-E-R-R-O-D.

Q And did Leizza tell you what she did in response to this disclosure?

A No. I was pretty astounded. But, yeah, she didn't, obviously she didn't leave him so —.

MS. RANSOM: All right. Nothing further. THE COURT: Thank you, Ms. Ransom.

And, Mr. Hicks, redirect?

MR. HICKS: None, your Honor.

THE COURT: Before you step down, you mentioned earlier in your testimony that Paul Adams had been ex-communicated. And normally secular courts like this one don't get involved in matters relating to church organization or membership. But I am trying to understand the timeline as best as I can. Do you know, and if you don't know it's fine, when Paul Adams was ex-communicated?

THE WITNESS: I don't know the year, your Honor. I'm not sure when exactly he was ex-communicated.

THE COURT: Do you know whether his status when you moved here and met the Adams family was that of having been ex-communicated?

THE WITNESS: I believe he was ex—communicated already when I moved here.

THE COURT: Okay. And if you don't know precisely when that happened, would it also be correct you really don't know why he was ex-communicated? Or do you know why?

THE WITNESS: I was told why. But not from him or the bishop. The bishop obviously can't talk about that.

THE COURT: Right. So you were told why by —just tell me the source of the information. Who told you?

THE WITNESS: Leizza.

THE COURT: Leizza told you?

THE WITNESS: Uh-huh.

THE COURT: I think I'll leave it there. Counsel, any additional questions based on my questions?

EXAMINATION

BY MR. HICKS:

Q Was it related to the disclosure that he had madeto the bishop about his daughter?

A No. It was--

Q Something different?

A Something different.

EXAMINATION

BY MS. RANSOM:

Q Did she need to read her journal to refresh her memory on why Paul was ex—communicated?

MR. HICKS: Objection, your Honor, argumentative.

THE COURT: No. Overruled. You may answer.

THE WITNESS: I was just trying to think. I don't know. I'm not sure actually because she just told me, so I don't know if it was, she had been reading her journals, because her former public defender had asked her to get all of her journals and read them. And during that time she was telling me information. And so I don't know if she read it in her journal or if it was — I don't recall if we were just talking about it and she told me.

BY MS. RANSOM:

Q So are you saying that the first time you learn of the basis for Paul Adams' ex-communication is, um, was after Paul Adams' arrest?

A I had heard rumors. But the first time I heard exactly what it was for, yes, was after his arrest.

Q So Leizza Adams had never told you why Paul was ex-communicated until after his arrest?

A Right.

Q How did that come up?

A I think I asked her. I was just curious.

Q Did she answer directly?

A She kind of beat around the bush. And then I kept asking her.

Q. And what did she ultimately answer as to why he was ex-communicated?

A The reason he was ex-communicated?

Q Yes.

A He had sex with his mother.

Q And—

A And he then told the bishop that he had.

Q And then she was told as well?

A Yes, I believe so.

Q And that was, again, years before Paul Adams’

A Yes, it was before he was arrested.

MS. RANSOM: Nothing further.

THE WITNESS: You mean that it happened? MS. RANSOM: Yes.

THE WITNESS: Yes.

BY MS. RANSOM:

Q And she knew that it had happened years before his arrest?

A Yes, that he was ex-communicated, yes, and what happened, yeah, in terms of being ex-communicated, yes.

Q All right. So Leizza Adams understood the basis for her husband's ex—communication years before his arrest?

A I believe so, yes.

MS. RANSOM: Nothing further.

THE COURT: Mr. Hicks, anything further to ask the witness?

MR. HICKS: No, your Honor.

THE COURT: Ms. Warr, thank you very much. You may go ahead and step down. Be careful of the step as you go.

And I believe, Mr. Hicks, Ms. Warr was your only witness at this point.

MR. HICKS: Well, I've got a little bit of an issue because I'm going to be quoting things from Leizza that she has written either for the court or for the

probation.

THE COURT: All right.

MR. HICKS: And I'm thinking now maybe I better call her.

THE COURT: Well, I'll leave that to you. If something is part of the presentence report, including the defendant's version, it's fair to quote it or argue with regard to it. That's perfectly fine. But if you want to call Ms. Adams, you may.

MR. HICKS: No, I'm okay then. I'm not going to.

THE COURT: All right. So no additional witnesses