Every Discrepancy, Side by Side

These are the places where the State’s own records disagree with each other, or where a record the State’s papers mention is missing or was never tested. There are 62 here: 49 where two records say different things, and 13 gaps. The words in yellow are quoted exactly from the record named under each entry.

Only entries where both sides were read in the documents themselves are posted. More than a hundred more come from recorded interviews and trial audio; each goes up after it is checked by ear against the recording. The documents themselves are on Every Document, by Date and the record pages in the menu. Records that should exist but do not are listed on Missing Records.

The prosecutor’s letters and the State’s brief (12)

1The prosecutor’s letter vs. the police report: who knew about Brown’s proffer
Two records say different things
One record says
The State’s April 8, 2024 letter to defense counsel: “We did not learn of the proffer until the day before.”
Another record says
Det. Stokes’s supplement: Brown’s November 1, 2021 proffer was attended by two assistant district attorneys from the same office (Leslie Longshore and Colin Campbell), a federal prosecutor and an ATF agent.
Records: State letter 4/8/2024; Stokes Supplement CA
2“Brown has entered a guilty plea” before the plea existed
Two records say different things
One record says
The same April 8, 2024 letter: “Brown has entered a guilty plea to his federal charges.”
Another record says
Brown’s federal docket (1:21-cr-00001, E.D. Tenn.) still had an open plea-agreement deadline of May 15, 2024, later moved to August 14, 2024. His plea agreement (Doc. 80) was signed September 12, 2024 and file-stamped September 13, 2024, and his change-of-plea hearing was October 4, 2024: all after the letter and after he testified.
Records: State letter 4/8/2024; Doc. 80; federal docket (CM/ECF)
3“Only this gun” vs. the State’s own firearms examiner
Two records say different things
One record says
State’s appeal brief, page 21: the bullet “could only have been shot out of the red SCCY pistol.”
Another record says
TBI firearms report (Exhibit 53): the bullet “bears the same class characteristics” and “the damaged condition of the bullet ... precludes a more conclusive determination.”
Records: State’s Br. 21; TBI Ex. 53
4Sworn testimony about blood the lab says wasn’t there
Two records say different things
One record says
At trial Lanham testified Randall bled “a lot” in the camper (as quoted in the State’s brief, p. 27).
Another record says
TBI (Exhibit 49): “The items tested from the camper did not indicate the presence of blood.” The State’s brief concedes it.
Records: State’s Br. 27; TBI Ex. 49
5The State’s own witness report vs. the State’s brief
Two records say different things
One record says
Det. Gunn’s Supplement 4: Lauren Delaney came on her own; Brittany told her Randall “was shot inside the camper”; Holland told her “he didn’t shoot LESLIE.”
Another record says
The State’s appeal brief: “Lauren’s last name is not in the record.”
Records: Gunn Supplement 4; State’s brief
6The State’s brief gives Brown two different motives
Two records say different things
One record says
State’s brief, page 16: Brown helped “because of their shared membership in the Vice Lords gang.”
Another record says
State’s brief, page 30 (citing trial Vol. XIII 447, 449-50): Brown said “It ain’t got nothing to do with Vice Lords ... did it for money.”
Records: State’s appellee brief, pp. 16 and 30
7Who checked on Randall at the house
Two records say different things
One record says
State’s opening statement: “They would go out occasionally, check on Mr. Leslie, see his condition” (official transcript Vol. 1 p. 16).
Another record says
Trial testimony as the State’s brief describes it: everyone was ordered “inside the house, leaving the victim in the car,” and only “after about two and a half hours, someone went outside” (XI 110-12; State’s brief p. 16).
Records: Trial transcript Vol. 1 p. 16; State’s brief p. 16
8Eight to ten people outside, and the officer saw none
Two records say different things
One record says
The State’s brief: “Several other people were at Defendant’s house” (XI 96). On cross-examination the witness put it at 8 to 10 people.
Another record says
Officer Gerity saw no gathering. Asked whether he would have stopped if he had seen 8 to 10 people: “Yes ... I would have rolled my window down” (official Vol. 1 pp. 59-60; State’s brief p. 15).
Records: State’s brief pp. 15-16; trial transcript Vol. 1 pp. 59-60
9A transcript the State says is not in the record
Two records say different things
One record says
State’s brief, page 28, footnote 3: “A transcript of that May 6, 2024, hearing is not in the record.”
Another record says
Trial court docket: “4/17/2025 - TRANSCRIPT OF PRETRIAL CONFERENCE, HEARD ON MAY 6, 2024, FILED IN OFFICE ON APRIL 17, 2025.”
Records: State’s brief p. 28 n. 3; rule docket 4/17/2025
10The gang-evidence request: withdrawn, then made out loud twice
Two records say different things
One record says
State’s brief, page 28: “the State agreed it would not introduce any evidence of gang membership.” Docket 5/6/2024: “REQUEST FOR 404 (B) HEARING WITHDRAWN STRICKEN.”
Another record says
Docket 5/14/2024: “ORAL MOTION BY THE STATE FOR RULE 404 (B) HEARD AND DENIED.” Docket 5/15/2024: the same motion “HEARD AND GRANTED.”
Records: State’s brief p. 28; rule docket 5/6, 5/14 and 5/15/2024
11“Three murder convictions ... the State is unsure”
Two records say different things
One record says
State’s brief, page 45: “From where Defendant arrives at three murder convictions, the State is unsure.”
Another record says
Case 311081 (first degree premeditated murder) was marked “REPLACED” on 4/10/2024 but not dismissed until a judgment signed January 15, 2025. On sentencing day, October 25, 2024, murder charges were open in both 311081 and 317210. The prison record lists 317210 Count 2 as “First Degree Murder.”
Records: State’s brief p. 45; 311081 dismissal judgment; TDOC record
12“Defendant and the victim sat on the patio”
Two records say different things
One record says
State’s brief, page 16: “Defendant and the victim sat on the patio for another thirty to forty-five minutes” (XI 123).
Another record says
The same page of the same brief says the victim’s body had already left in the Lancer with Brown.
Records: State’s brief p. 16

Police reports, sworn affidavits and evidence logs (25)

13The NIBIN gun lead nobody could find
A record that should exist is missing or untested
One record says
An ATF NIBIN lead linking a gun in this case to another shooting was created June 11, 2020.
What is missing
On September 29, 2022 an assistant DA emailed: “I am just checking to make sure there are no NIBIN Reports as there are none in the case file.” Donyell’s pro se discovery motions had been denied July 13, 2021.
Records: ATF NIBIN lead 6/11/2020; email 9/29/2022; rule docket
14An evidence inventory dated before its own entries
Two records say different things
One record says
Every page of Evidence Inventory 20-052168 is stamped “Report By Inv McElroy 634, Date & Time 6-17-20 @ 1113.”
Another record says
The same pages carry entries dated August 3, 2020 and October 1, 2020. The original ends at Item 176, “END OF REPORT.” The version “Updated 10-2-20” adds Item 177. Items 178 to 180 are missing.
Records: Evidence Inventory 20-052168, both versions
15Item 177 described two different ways
Two records say different things
One record says
Inventory: “97 live ‘TW 69’ rounds on a desintirating [sic] belt. Trunk of a Pontiac Grand AM registered to Randall Leslie.”
Another record says
CSU follow-up report: a “plastic bag in the trunk with numerous live rifle rounds.” The Grand Am went to Precision Towing on June 3, 2020 and was processed October 1, 2020, with no seal or hold record in between.
Records: Inventory; McElroy follow-up report; tow record
16Gloves sworn to be in police custody before police had them
Two records say different things
One record says
Search warrant affidavits, paragraph 6: “3 pair of gloves ... All the items located ... are in Chattanooga Police custody.”
Another record says
Inventory items 1 to 4 (May 29, 2020) hold no gloves. Gloves first appear as items 129, 130 and 134, from the Lancer, on June 13, 2020. No glove was ever tested.
Records: Affidavits ¶6; Evidence Inventory
17Brown’s 9mm: four stories of where it came from
Two records say different things
One record says
Stokes’s initial report, in Brown’s words: “under the passenger seat.” Officer Shelor: “under the driver seat.”
Another record says
The search warrant affidavit says a relative of Randall’s mother found it. The federal indictment says it was “seized from Derik Adam Brown on May 28, 2020.”
Records: Stokes initial report; Shelor report; affidavit ¶6; federal Doc. 1
18The murder weapon’s box was in Randall’s own bedroom
Two records say different things
One record says
Inventory item 24: the State’s murder weapon is an SCCY pistol, serial 637445.
Another record says
Inventory item 154: “Box for SCCY Pistol, Serial 637445 ... under the dresser,” at Randall Leslie’s apartment, 5113 Highway 58.
Records: Evidence Inventory items 24 and 154
19A stolen police gun in the evidence, theft report missing
A record that should exist is missing or untested
One record says
NCIC, June 10, 2020, on Smith & Wesson SD40VE FZJ3685: “STOLEN GUN ... OCA/18-125302 ... ORI IS CHATTANOOGA PD.”
What is missing
Report 18-125302 is not in the file.
Records: NCIC printout 6/10/2020
20“Neighborhood information” that named a house no one named
Two records say different things
One record says
Stockton affidavit, paragraph 10: “Mr. Leslie was shot inside 4088 Teakwood Drive and transported to 6305 Stockton Drive.”
Another record says
Blount’s June 3, 2020 entry of the same family information: a house “off Bonny Oaks Drive then taken to an unknown location in Georgia,” and officers “did not believe there was enough probable cause.”
Records: Stockton affidavit ¶10; Blount entry 6/3/2020
21One interview, three different clocks
Two records say different things
One record says
Kiara Carson’s June 8, 2020 interview: the interview-room video clock reads about 4:02 PM; the affidavit says “approximately 1606 hours.”
Another record says
Stokes’s initial report puts the same interview at “approximately 1846,” after 6:30 PM.
Records: Disc 5; affidavit ¶8; Stokes initial report
22Reports approved while the star witness was still being interviewed
Two records say different things
One record says
Sgt. V. Miller approved the Conry supplement at 10:42 AM and the Stokes proffer supplement at 10:43 AM on December 9, 2021.
Another record says
Brittany Lanham’s interview-room clock that morning runs from 10:10 AM to 11:52 AM.
Records: Supplement approval stamps; Disc 14
23The shots-fired call: two report numbers, no video
Two records say different things
One record says
Officer Gerity’s memo on the May 27, 2020 6:35 PM call is numbered 20-051755, with in-car video “No” and body camera “No.”
Another record says
Stokes’s initial report cites the same call as 20-052155.
Records: Memo 20-051755; Stokes initial report
24Randall’s phone: “no activity since 5/28,” sworn after police tracked later activity
Two records say different things
One record says
Search warrant affidavits, paragraph 7 (June 8, 2020, repeated July 22 and August 6, 2020): “no activity on the Mr. Leslie’s cell phone since 5/28/2020.”
Another record says
Investigator Stokes’s own report: “6/11/2020 Investigator Gunn and I tracked Randall’s Gmail account to the America Best Value Inn on Lee Hwy,” and on 6/12/2020 he pulled store video “in regards to the Randall’s Gmail account signal.”
Records: Affidavits ¶7; Stokes initial report
25One sworn affidavit, two different times
Two records say different things
One record says
Affidavits, paragraph 2: “On 5/27/2020 around 1800 hours, Kiara Carson located Mr. Leslie’s vehicle at 4088 Teakwood Drive running,” and paragraph 8: as she arrived “she observed police in the area.”
Another record says
The same affidavits, paragraph 9: patrol responded “on 5/27/2020 at 1835 hours.” The call memo: “Occurred: 05/27/2020 18:34 ... Arrived: 05/27/2020 18:35.”
Records: Affidavits ¶¶2, 8, 9; memo 20-051755
26When the body was found, and where it went
Two records say different things
One record says
Stokes’s report and the affidavits, paragraph 12: the body was located “at approximately 1417 hours.”
Another record says
The case synopsis: “approximately 1500 hours ... transported to the TBI lab for an autopsy.” The autopsy: pronounced “6/21/2020 at 1550,” and taken “to Forensic Medical” at 850 R.S. Gass, not the TBI lab.
Records: Stokes initial report; affidavits ¶12; synopsis; autopsy MEC20-2121
27An interview of Brown that the lead detective’s report leaves out
A record that should exist is missing or untested
One record says
Brown’s federal plea agreement, paragraph 4(f): “On June 1, 2020, Detective Corey Stokes ... interviewed the Defendant at the Coffee County Jail.”
What is missing
Stokes’s own report: he was assigned the case on 6/8/2020, and the first Brown interview it lists is “On 6/10/2020 Investigator Noble and I traveled to Coffee County.”
Records: Federal Doc. 80 ¶4(f); Stokes initial report
28The emergency phone request: Sprint or T-Mobile
Two records say different things
One record says
The June 8 affidavits, Stokes’s report and two later affidavits, paragraph 7: the emergency request form was faxed “to Sprint.”
Another record says
The 561 phone affidavit, paragraph 7: “to T Mobile.”
Records: Affidavits ¶7
29Both crime-scene reports written after the indictment
Two records say different things
One record says
Crime scene investigator McElroy’s initial and follow-up reports are both dated “3-17-21,” and both were reviewed 04/07/2021.
Another record says
Stokes’s supplement: the case went to the grand jury 3/9/2021, and “On 3/12/2021 the Grand Jury returned a True Bill.”
Records: McElroy reports; Stokes Supplement CA
30The Lancer swabs: credited to one person, collected by others
Two records say different things
One record says
Evidence inventory items 106-115 (Lancer DNA swabs, 6/11/20): “By: JM634” (McElroy).
Another record says
McElroy’s own follow-up: other officers “had collected DNA swabs and processed it for latent prints”; he only “photographed” the Lancer. The only tow record is dated 6/13/20.
Records: Evidence Inventory 20-052168; McElroy follow-up; tow record
31A fingerprint lifted and then never logged
A record that should exist is missing or untested
One record says
McElroy’s follow-up: “I collected a latent print from the front passenger exterior area of the vehicle.”
What is missing
Inventory items 91-101 list swabs and scales, but no latent print. None of items 91-100 appears in any TBI report.
Records: McElroy follow-up; Evidence Inventory; TBI reports
32The Canik serial number does not match its box
Two records say different things
One record says
Evidence inventory item 23, the Canik pistol: serial “T6472-20-BH-02468.”
Another record says
Evidence inventory item 153, from Randall’s apartment: the box, “Serial 20BH02466.”
Records: Evidence Inventory items 23 and 153
33Randall’s own gun is missing from the evidence
A record that should exist is missing or untested
One record says
Sgt. Emery’s supplement: Randall left “his firearm in his vehicle.”
What is missing
Every gun from the Lancer is attributed to someone else, and inventory item 137 is an empty “Blackhawk left handed holster. Under the drivers seat.”
Records: Emery supplement; Evidence Inventory item 137
34The complaint number “corrected,” then never used
Two records say different things
One record says
Stokes’s report: “6/23/2020 Correct Complaint# 20-20-052161.”
Another record says
Evidence kept being filed under 20-052168, the kidnapping number: the 8/3/20 lab submission (“existing complaint number 20-052168”), Item 177 in October 2020, the ATF letter of 1/12/21, and the TBI reports from 2020 to 2023.
Records: Stokes initial report; CSU submission; ATF letter; TBI reports
35Federal agents in the case from June 2020, with no reports
A record that should exist is missing or untested
One record says
Stokes’s report: “6/18/2020 ATF agent Gordy and I traveled to Coffee County Jail to interview Brown again,” and on 6/23/2020 a phone was “released to ATF Agent Moon for downloading.”
What is missing
No ATF interview report, phone extraction or comparison is in the file.
Records: Stokes initial report; discovery file
36“Kidnapping” in the sworn affidavits, “Missing” in the detective’s report
Two records say different things
One record says
Affidavits, paragraph 4: officers “responded to a report of a kidnapping at 5012 Renezet Drive.”
Another record says
Stokes’s own report: officers went to 5012 Renezet Drive where “Ms. Harden reported Mr. Leslie as Missing.”
Records: Affidavits ¶4; Stokes initial report
37The ballistic lead dated before the gun was found
Two records say different things
One record says
The NIBIN case was created “6/1/2020 11:45:31 AM” with “Occurrence: 5/29/2020” and the comment “1 hit(s) Found 5013 Jarred Rd.”
Another record says
Inventory item 22 places that pistol at 6305 Stockton on 6/9/20 at 0739, “under a wood chest.” The CPD firearms form and TBI exhibit 016-a both say “from 6305 Stockton.”
Records: NIBIN record; Evidence Inventory item 22; TBI report

The lab and the medical examiner (8)

38The bullet in the wall at Teakwood never went to the lab
A record that should exist is missing or untested
One record says
CSU initial report: “A bullet projectile was located in the sheetrock behind the door” at Teakwood (inventory item 7).
What is missing
No Teakwood bullet appears in any of the three TBI reports.
Records: Johnson CSU report; TBI reports
39The back seat where the State says he died was never examined
A record that should exist is missing or untested
One record says
CSU report: “the possibility of blood on the back seat and seat belts.”
What is missing
TBI, December 15, 2022: “023-a Rear seat ... No examination was performed.”
Records: McElroy report; TBI report 12/15/2022
40The victim reference sat in the lab untested
A record that should exist is missing or untested
One record says
Stokes obtained a DNA reference from Randall’s mother on June 15, 2020.
What is missing
TBI, October 30, 2020: “010-a Elimination swabs from Cherie Harden ... No examination was performed,” while the same report asks police to “submit a victim ... standard.”
Records: TBI report 10/30/2020
41No one is named as finding the body
A record that should exist is missing or untested
One record says
Autopsy MEC20-2121: the body was “discovered ... by law enforcement.”
What is missing
No finder is named, and no Marion County recovery report, scene log or scene photographs are in any version of the file.
Records: Autopsy MEC20-2121; discovery file
42“Bloody clothing” that tested negative for blood
Two records say different things
One record says
McElroy’s report: “bloody clothing.” Inventory item 62: “T shirt with suspected blood.”
Another record says
TBI report of 10/30/20: “002-a Shirt from 6305 Stockton Drive ... did not indicate the presence of blood.”
Records: McElroy initial report; Evidence Inventory item 62; TBI 10/30/2020
43A shirt logged into two places at the same time
Two records say different things
One record says
TBI: received from Michele Johnson on “8/3/20 ... 9:20 am” (011-a shirt, 012-a undershirt).
Another record says
Johnson: “I submitted the items to the Property & Evidence Division on 8-3-20 at 1436hrs.” The property sheet: “Items 164-168 added to Property sheet 8.3.20 @ 1436 hrs.”
Records: TBI 10/30/2020; Johnson CSU report; property sheet
44Two lab exhibit numbers that appear nowhere
A record that should exist is missing or untested
One record says
Across the three TBI reports, the exhibit numbers run 001-013 and 016-026.
What is missing
Exhibits 014 and 015 appear in none of them.
Records: TBI reports 10/30/2020, 12/15/2022, 2/21/2023
45The sheet, the hair and the pocket document
Two records say different things
One record says
Autopsy: “found wrapped in a sheet”; scalp hair “black, curly, and arranged in braids”; “A document in the pants pocket suggested the identification.”
Another record says
Inventory item 174: “Hair from item #173 - appears reddish/brown.” No document appears among items 164-176, and none of items 173-176 was sent to the TBI.
Records: Autopsy MEC20-2121; Evidence Inventory items 164-176

Court records, orders and dockets (17)

46Arraigned five weeks after judgment
Two records say different things
One record says
Order of November 21, 2024: “This cause came before the Court on November 21, 2024 upon arraignment of the Defendant ... the Defendant enters a plea of Not Guilty,” made “nunc pro tunc” to April 10, 2024.
Another record says
The judgments were entered October 25, 2024. The docket for November 21, 2024 shows no hearing, no transport and no appearance.
Records: Order 11/21/2024; rule docket 317210
47The clerk’s docket says life without parole; the court papers say life
Two records say different things
One record says
Docket, October 25, 2024: “LIFE WITHOUT THE POSSIBLITY OF PAROLE.”
Another record says
The State’s own June 7, 2024 response: “The State did not seek the punishment of life imprisonment without the possibility of parole.” The Count 2 judgment form checks “Life.”
Records: Rule docket 10/25/2024; State response 6/7/2024; judgment
48“No prejudice” in April, “fast-approaching trial” in November
Two records say different things
One record says
April 23, 2024: the defense motion to continue is denied (“the witness list remained the same”).
Another record says
November 22, 2024 order finding the case extended and complex: “counsel had to prepare quickly and thoroughly for the fast-approaching jury trial.”
Records: Rule docket 4/23/2024; order 11/22/2024
49A lawyer still listed after Donyell was on his own
Two records say different things
One record says
Donyell proceeded pro se after counsel’s withdrawal was granted August 16, 2024.
Another record says
The live docket listed “Attorney: MACNEILL JR, DAVID W” from November 21, 2024 to about April 15, 2025, the whole time his pro se motions sat, with no order removing him.
Records: Rule docket 317210
50“Each of the grounds” vs. “I’m not seeing it”
Two records say different things
One record says
July 14, 2025 order denying the motion for new trial “on the merits as to each of the grounds requested.”
Another record says
At the June 13, 2025 hearing (p. 11) the court said each issue would be judged (“They will. They will.”) and then: “I’m not seeing in the motions for new trial where issuance of a search warrant is raised as an issue.”
Records: Order 7/14/2025; MNT transcript 6/13/2025
51Second degree murder, with “1st” circled
Two records say different things
One record says
The verdict: “GUILTY OF SECOND DEGREE MURDER.” The judgment form: “Convicted Offense Name: Second Degree Murder ... TCA: 39-13-210.”
Another record says
The same form: “Conviction: Class (circle one) (1st) A B C D E,” with “1st” circled.
Records: Judgment 317210 Count 1
52Advisory counsel’s job, described three ways
Two records say different things
One record says
Trial court order of 8/22/2024: advisory counsel appointed “to assist the Defendant in the prosecution of his post-conviction petition.”
Another record says
Advisory counsel’s own appeals-court motion (filed 7/21/2025): appointed “to assist the Defendant with his sentencing hearing and motion for new trial.” Appeals court 3/17/2025: “the remaining trial court proceedings.”
Records: Order 8/22/2024; CCA motion 7/21/2025; CCA order 3/17/2025
53The appeals court tells the waiver story two ways
Two records say different things
One record says
Court of Criminal Appeals, 3/17/2025: “On August 16, 2024, the Appellant waived his right to counsel ... Following a sentencing hearing on October 25, 2024, the trial court entered judgments.”
Another record says
Court of Criminal Appeals, 10/15/2025: “After the entry of the judgments of conviction, the Appellant waived his right to counsel.”
Records: CCA orders 3/17/2025 and 10/15/2025
54A case dismissed during the appeal, and a motion not heard because of the appeal
Two records say different things
One record says
The 311081 dismissal judgment was signed 1/15/2025, while the appeal was pending.
Another record says
Docket 1/30/2025: “DUE TO CASE PENDING IN COURT OF CRIMINAL APPEALS; MOTION FOR NEW TRIAL NOT TO BE HEARD.” The appeals court then ruled, 3/17/2025, that “[t]he trial court retains jurisdiction over the case pending the court’s ruling on any timely filed motion,” and that the motion “was timely filed.”
Records: 311081 judgment; rule docket 1/30/2025; CCA order 3/17/2025
55The new-trial hearing dates
Two records say different things
One record says
Order denying the motion for new trial: “This cause came before the Court on June 13, 2025 and July 3, 2025.”
Another record says
Docket: “CASE RESET JULY 2, 2025”; “7/2/2025 MOTION FOR NEW TRIAL HEARD AND CONCLUDED.” The transcript: “HEARD ON JULY 2, 2025.”
Records: MNT order; rule docket; MNT transcript
56A request to represent himself, in the minutes but not on the docket
A record that should exist is missing or untested
One record says
Docket, 5/14/2024: lists only the State’s 404(b) motion. No self-representation entry.
What is missing
Court minutes, 5/14/2024: “an oral Motion for self representation was made and denied by the Court.”
Records: Rule docket 5/14/2024; court minutes 5/14/2024
57The minutes for the last day of trial say nothing about the removal
A record that should exist is missing or untested
One record says
Court minutes, 5/16/2024: “the defendant in person with his attorney David Macneill ... Closing arguments heard. ... The charge of the jury was then read.”
What is missing
Donyell was removed during the State’s closing and kept out through the closings and the jury charge (State’s brief pp. 43-44, citing XV 658, 695-96).
Records: Court minutes 5/16/2024; State’s brief pp. 43-44
58A “Rule 404(b) hearing” three months after the verdict
Two records say different things
One record says
Docket, 8/16/2024: “MOTION TO WITHDRAW GRANTED; RULE 404 (B) HEARING HELD AND ACCPETANCE AND APPROVAL OF DEFENDANT’S WAIVER.”
Another record says
A waiver hearing falls under Rule 44(b), which the 8/22/2024 order cites. Nothing under Rule 404(b) was pending after the verdict. The lawyer’s fee claim copies the docket wording word for word.
Records: Rule docket 8/16/2024; order 8/22/2024; fee claim
59Continuances for the State, denials for the defense
Two records say different things
One record says
The State’s continuances were granted 10/21/2022 and 5/15/2023 (“TRIAL DATE OF MAY 23, 2023 CANCELLED”).
Another record says
The defense continuance was denied 4/23/2024, partly because Donyell “had been in custody since his initial indictment in 2021” (State’s brief p. 38). His speedy-trial demands of 1/11/2022 and 1/13/2023 have no ruling on the docket.
Records: Rule docket; State’s brief p. 38
60Motions “not received by the Court” that the docket shows as filed
Two records say different things
One record says
Order of 11/13/2024, footnote 1: the motion to proceed as indigent and the motion for case materials “were not received by the Court.”
Another record says
Docket, 11/8/2024: “MOTION FOR INFORMA PAUPERIS INDIGENCY FILED / MOTION FOR CASE MATERIALS FILED.”
Records: Order 11/13/2024; rule docket 11/8/2024
61The promised time to read the transcript
Two records say different things
One record says
Order of 11/13/2024: the new-trial motion was set for 1/31/2025, and “The Court will not require the Defendant to proceed ... until Defendant has been provided adequate opportunity to review the trial transcript and to amend.”
Another record says
The trial transcripts were filed 2/4/2025. On 1/30/2025 the docket says the motion is “NOT TO BE HEARD.”
Records: Order 11/13/2024; rule docket 1/30/2025 and 2/4/2025
62Jail credit on one count starts years late
Two records say different things
One record says
Count 5 judgment: jail credit runs only “4/10/24 to 10/25/24.”
Another record says
Count 2 judgment: jail credit starts 3/17/2021. The State said the superseding indictment was “the same facts.”
Records: Judgments 317210 Counts 2 and 5

The prosecutor’s letters and the State’s brief (12)

1The prosecutor’s letter vs. the police report: who knew about Brown’s proffer

2“Brown has entered a guilty plea” before the plea existed

3“Only this gun” vs. the State’s own firearms examiner

4Sworn testimony about blood the lab says wasn’t there

5The State’s own witness report vs. the State’s brief

6The State’s brief gives Brown two different motives

7Who checked on Randall at the house

8Eight to ten people outside, and the officer saw none

9A transcript the State says is not in the record

10The gang-evidence request: withdrawn, then made out loud twice

11“Three murder convictions ... the State is unsure”

12“Defendant and the victim sat on the patio”

Police reports, sworn affidavits and evidence logs (25)

13The NIBIN gun lead nobody could find

14An evidence inventory dated before its own entries

15Item 177 described two different ways

16Gloves sworn to be in police custody before police had them

17Brown’s 9mm: four stories of where it came from

18The murder weapon’s box was in Randall’s own bedroom

19A stolen police gun in the evidence, theft report missing

20“Neighborhood information” that named a house no one named

21One interview, three different clocks

22Reports approved while the star witness was still being interviewed

23The shots-fired call: two report numbers, no video

24Randall’s phone: “no activity since 5/28,” sworn after police tracked later activity

25One sworn affidavit, two different times

26When the body was found, and where it went

27An interview of Brown that the lead detective’s report leaves out

28The emergency phone request: Sprint or T-Mobile

29Both crime-scene reports written after the indictment

30The Lancer swabs: credited to one person, collected by others

31A fingerprint lifted and then never logged

32The Canik serial number does not match its box

33Randall’s own gun is missing from the evidence

34The complaint number “corrected,” then never used

35Federal agents in the case from June 2020, with no reports

36“Kidnapping” in the sworn affidavits, “Missing” in the detective’s report

37The ballistic lead dated before the gun was found

The lab and the medical examiner (8)

38The bullet in the wall at Teakwood never went to the lab

39The back seat where the State says he died was never examined

40The victim reference sat in the lab untested

41No one is named as finding the body

42“Bloody clothing” that tested negative for blood

43A shirt logged into two places at the same time

44Two lab exhibit numbers that appear nowhere

45The sheet, the hair and the pocket document

Court records, orders and dockets (17)

46Arraigned five weeks after judgment

47The clerk’s docket says life without parole; the court papers say life

48“No prejudice” in April, “fast-approaching trial” in November

49A lawyer still listed after Donyell was on his own

50“Each of the grounds” vs. “I’m not seeing it”

51Second degree murder, with “1st” circled

52Advisory counsel’s job, described three ways

53The appeals court tells the waiver story two ways

54A case dismissed during the appeal, and a motion not heard because of the appeal

55The new-trial hearing dates

56A request to represent himself, in the minutes but not on the docket

57The minutes for the last day of trial say nothing about the removal

58A “Rule 404(b) hearing” three months after the verdict

59Continuances for the State, denials for the defense

60Motions “not received by the Court” that the docket shows as filed

61The promised time to read the transcript

62Jail credit on one count starts years late

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