The Order on Franks I linked has additional details at pp17-18. So it's clear then that LE's expert wasn't "insisting on it" ( "it" being the initial date range prior to Nov 26th 2022, not a particular year for the vehicle at any time). Jmo
Agent Imel preferred 2011-13.
Franks Order
Page 18:
What the email chain shows is that, on
November 26, 2022, Agent Imel directed the FBI to "open up" their search to "2011-2016." Exh. D9 at Bates 15580. In doing so, he discussed the changes to the Hyundai Elantra in 2014 and 2017 and stated that he wanted a "better shot ofthe vehicle's front fog lights and rear reflectors." He further added, "rather not leave anything out better safe than sorry." Five minutes later he sent another email stating "yea I see the change in 2014 and [I'm]
not really a fan of the 2014 much prefer the 2011 2013 but wanted to lay that out have a good night. Will keep looking and send any new info I can come up with." Jd.
These emails demonstrate that it was Agent Imel's decision to open the date range to 2011-2016, despite his "prefer[ence]" for 2011-2013. Exhibit A accurately captures this decision by stating that the specialist initially believed it was a 2011-2013 but opened it up to 2011-2016 upon further review.
While Exhibit A did not call out that Agent Imel preferred narrower time frame, Defendant has not shown this omission to be exculpatory and material. Exhibit A is replete with evidence linking Defendant's vehicle and cell phone to Suspect Vehicle 1. Considered as a whole, it cannot be reasonably concluded that Agent Imel's "preference" for a narrower date range would have derailed the magistrate's finding of probable cause had it been included.
SAIs extension of the year range was Nov 26th. Why were they not, internally, looking for the expanded range? Why did the Nov 29th WSU discovery not become known until after Dec 19th?
SAI Stating he wanted a better shot of the fog lights and rear reflectors.
The recent 1112 images on Queen do not show fog lights nor rear reflectors IMO.
BP listed the main images in testimony:
So the first one was from
1112 King Road. It was a surveillance camera, an exterior surveillance camera on a house that was immediately to the northeast of 1122 King Road. There was some footage from
a Linda Lane camera, I forget the address off the top of my head. There was footage from the
A&W, which is at the corner of Lauder and South Main, or Highway 95. There was footage from an address on
Indian Hills. There was also footage from a
Ridge Road camera. And that's how we referred to them was basically by those names.
Which one, if any, showed fog lights and reflectors?
Maybe the 451 Paradise stills or screenshots from Ridge Road ?
MIL car ID
Email Nov 23

There is no continuous footage linking the vehicle at the 1112 King road footage and that from Ridge road. Additional surveillance footage depicts vehicles, but not identifiable vehicles.
JMO