The time of death was estimated based on the fact she was already in rigor by 7 am. They left her body down there for so long I think that is about the only thing they could have used to estimate the time of death. Rigor takes 3-4 hours to develop so they estimated it before 3 am. So I don't believe she could have died as late as 5 am (not enough time to develop rigor) but before 3 am I believe it's wide open. I think she could have died quite a bit earlier than 3 am.
Oh, that's right, the rigor wouldn't fit. I didn't know they said before 3 am. I think the window then is probably more like 10/11 pm-3 am. Too bad they didn't try to estimate TOD right after she was found around 7 am, huh?