Michael Knecht — Direct/Cross/Redirect/Recross
615 linesMR. CONRAD: The state calls Anthony Kniche.
The witness, MICHAEL ANTHONY KNICHE, was first duly sworn and testified as follows:
COURT CLERK: Have a seat in the witness stand. State your name again for the record. If you would, spell your last name, please.
MICHAEL KNECHT: My name is Michael Anthony Kniche.
DIRECT EXAMINATION
BY MR. CONRAD:
MR. CONRAD: Mr. Kniche, how are you doing, sir?
MICHAEL KNECHT: Great. How are you?
MR. CONRAD: Am I pronouncing that correctly?
MICHAEL KNECHT: Kniche.
MR. CONRAD: And where are you employed, sir?
MICHAEL KNECHT: Verizon Wireless.
MR. CONRAD: And what are your duties there?
MICHAEL KNECHT: In this capacity, I'm a custodian of records.
MR. CONRAD: All right. So, it's -- in its normal course of business, does Verizon keep records?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And does it keep call records?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Just generally speaking, what kind of records does Verizon keep in relation to phone accounts and call records?
MICHAEL KNECHT: Subscriber information, cellular data, which could be telephone calls, text message, data sessions.
MR. CONRAD: Okay. All right, and these have been previously shown to counsel. I'm going to show you what's been marked as State's Exhibit 268, and I'm going to ask you if you recognize that, sir.
MICHAEL KNECHT: I do.
MR. CONRAD: And what is that?
MICHAEL KNECHT: State's Exhibit 268 is Alex Murdaugh's telephone number 803-942-1227.
MR. CONRAD: Okay, and have you reviewed the contents of that CD?
MICHAEL KNECHT: I have.
MR. CONRAD: And what is the contents in that -- on that CD?
MICHAEL KNECHT: Subscriber information, cellular data information, text messages, anything related to billing purposes at Verizon Wireless.
MR. CONRAD: And was that -- were those records previously turned over to law enforcement?
MICHAEL KNECHT: In request to a search warrant, they were.
MR. CONRAD: All right, and you've reviewed those records, correct?
MICHAEL KNECHT: I have.
MR. CONRAD: And after reviewing them, are those true and authentic copies of the records that are kept by Verizon?
MICHAEL KNECHT: They are.
MR. CONRAD: And those are related to Alex Murdaugh's Verizon account, sir?
MICHAEL KNECHT: That is correct.
MR. CONRAD: With number ending 1227?
MICHAEL KNECHT: That's correct.
MR. CONRAD: All right.
MR. CONRAD: At this time, State moves to enter Exhibit 268 into evidence.
JUDGE NEWMAN: What says the defense?
MR. HARPOOTLIAN: No objection, Your Honor.
JUDGE NEWMAN: It's admitted.
(CELLULAR DATA MARKED AS STATE'S EXHIBIT NUMBER 268 WAS RECEIVED INTO EVIDENCE.)
MR. CONRAD: All right, I'm going to approach and hand you State's Exhibit 269, and you recognize that, sir?
MICHAEL KNECHT: I do.
MR. CONRAD: And what is that?
MICHAEL KNECHT: State's Exhibit 269, Paul cell phone, 803-842-7845.
MR. CONRAD: And have you had an opportunity to review the contents of that CD?
MICHAEL KNECHT: I have.
MR. CONRAD: And what is the contents of that CD?
MICHAEL KNECHT: Cellular information, subscriber information in response to a search warrant.
MR. CONRAD: Okay, and are the contents of that CD accurate -- true and accurate copies of the records kept by Verizon in the normal course of business?
MICHAEL KNECHT: They are.
MR. CONRAD: And at this time, the State would move to enter Exhibit 269 into evidence.
MR. HARPOOTLIAN: No objection, Your Honor.
JUDGE NEWMAN: It's admitted.
(CELLULAR DATA MARKED AS STATE'S EXHIBIT NUMBER 269 WAS RECEIVED INTO EVIDENCE.)
MR. CONRAD: And I'm going to hand you -- this is Exhibit, 265 so a little bit out of order. And do you recognize that, sir?
MICHAEL KNECHT: I do.
MR. CONRAD: And what is that?
MICHAEL KNECHT: State's Exhibit 265, Maggie cell phone, 803-842-9041.
MR. CONRAD: Have you had an opportunity to review the contents of that CD?
MICHAEL KNECHT: I have.
MR. CONRAD: What are its -- what are the contents of that CD?
MICHAEL KNECHT: Subscriber information, cellular data information in response to a search warrant.
MR. CONRAD: That's in relation to the number associated with Paul. Is that correct?
MICHAEL KNECHT: Maggie.
MR. CONRAD: Oh, excuse me, yes, Maggie. And what's the last four digits of that number?
MICHAEL KNECHT: 9041.
MR. CONRAD: Okay. All right, and that's Exhibit 265, correct?
MICHAEL KNECHT: That's correct.
MR. CONRAD: All right.
MR. CONRAD: And at this time, the State would move to enter Exhibit 265 into evidence.
MR. HARPOOTLIAN: No objection, Your Honor.
JUDGE NEWMAN: It's admitted.
(CELLULAR DATA MARKED AS STATE'S EXHIBIT NUMBER 265 WAS RECEIVED INTO EVIDENCE.)
MR. CONRAD: I'm going to approach and I'm going to hand you what's labeled as State's Exhibit 262. Do you recognize that, sir?
MICHAEL KNECHT: I do.
MR. CONRAD: And without reading any phone number, full phone number, what is that?
MICHAEL KNECHT: State's Exhibit 262, Claude Rowe records.
MR. CONRAD: All right, and have you had an opportunity to review the contents of that CD?
MICHAEL KNECHT: I have.
MR. CONRAD: And what are the contents of that CD?
MICHAEL KNECHT: Subscriber information, cellular information in response to a search warrant.
MR. CONRAD: And those are related to the account associated with Claude Rowe, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And there is a phone number associated. We're just not going to read it into the record. Is that correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: At this time --
MR. CONRAD: What number is that?
MICHAEL KNECHT: State's Exhibit 262.
MR. CONRAD: At this time, the State would move to enter Exhibit 262 into evidence.
MR. HARPOOTLIAN: No objection.
JUDGE NEWMAN: It's admitted.
(CELLULAR DATA MARKED AS STATE'S EXHIBIT NUMBER 262 WAS RECEIVED INTO EVIDENCE.)
MR. CONRAD: All right. I'm going to approach and hand you State's Exhibit 263. Do you recognize that, sir?
MICHAEL KNECHT: I do.
MR. CONRAD: And what is that?
MICHAEL KNECHT: State's Exhibit 263, Marty Cook.
MR. CONRAD: All right, and is there a phone number associated to that without reading it?
MICHAEL KNECHT: There is.
MR. CONRAD: And that's a Verizon phone number, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: What are the contents of that CD?
MICHAEL KNECHT: Subscriber information, cellular data information in response to a search warrant.
MR. CONRAD: And you've had an opportunity to review that, correct?
MICHAEL KNECHT: I have.
MR. CONRAD: And those are the -- a copy of the same records that were provided to law enforcement pursuant to a search warrant. Is that correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right, and what number was that again?
MICHAEL KNECHT: State's Exhibit 263.
MR. CONRAD: All right. At this time, the State would move to enter Exhibit 263 into evidence.
JUDGE NEWMAN: What says the defense?
MR. HARPOOTLIAN: I'm sorry, I couldn't -- whose number is that?
MR. CONRAD: State's Exhibit 263, which -- what's the name on that account?
MICHAEL KNECHT: Marty Cook.
MR. HARPOOTLIAN: No objection.
JUDGE NEWMAN: It's admitted.
(CELLULAR DATA MARKED AS STATE'S EXHIBIT NUMBER 263 WAS RECEIVED INTO EVIDENCE.)
MR. CONRAD: All right, I'm going to hand you State's Exhibit 264. Do you recognize that, sir?
MICHAEL KNECHT: I do.
MR. CONRAD: And what is that, sir?
MICHAEL KNECHT: State's Exhibit 264, Rogan.
MR. CONRAD: All right, and is there a phone number associated with that?
MICHAEL KNECHT: There is.
MR. CONRAD: All right, and we're not going to read that into the record, but have you had an opportunity to review the contents of that CD?
MICHAEL KNECHT: I have.
MR. CONRAD: And what are the contents of that CD?
MICHAEL KNECHT: Subscriber information, cellular data information in response to a search warrant.
MR. CONRAD: And the contents of that CD are an accurate copy of the original records provided by Verizon to law enforcement pursuant to a search warrant?
MICHAEL KNECHT: They are.
MR. CONRAD: Okay. All right, and that's Exhibit 264, correct?
MICHAEL KNECHT: Yes, sir.
MR. CONRAD: All right.
MR. CONRAD: At this time, the State would move to enter Exhibit 264 into evidence.
MR. HARPOOTLIAN: No objection.
JUDGE NEWMAN: It's admitted.
(CELLULAR DATA MARKED AS STATE'S EXHIBIT NUMBER 264 WAS RECEIVED INTO EVIDENCE.)
MR. CONRAD: All right, and I'm going to hand you what's marked as State's Exhibit 266. Do you recognize that, sir?
MICHAEL KNECHT: I do.
MR. CONRAD: And what is that?
MICHAEL KNECHT: State's Exhibit 266, Connor Cook records.
MR. CONRAD: All right, and is there Verizon associate -- an account associated with Connor Cook?
MICHAEL KNECHT: There is.
MR. CONRAD: Have you had an opportunity to review the contents of that CD?
MICHAEL KNECHT: I have.
MR. CONRAD: All right. What is the contents of that CD?
MICHAEL KNECHT: Subscriber information, cellular data information in response to a search warrant.
MR. CONRAD: All right, and that's a true and accurate copy of the records originally provided by Verizon to law enforcement pursuant to a search warrant?
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right, and what's that number you have again?
MICHAEL KNECHT: State's Exhibit 266.
MR. CONRAD: All right.
MR. CONRAD: At this time, the State would move to enter Exhibit 266 into evidence.
MR. HARPOOTLIAN: No objection.
JUDGE NEWMAN: Admitted.
(CELLULAR DATA MARKED AS STATE'S EXHIBIT NUMBER 266 WAS RECEIVED INTO EVIDENCE.)
MR. CONRAD: And the last one, this is State's Exhibit 267. I'm going to hand this to you. Do you recognize that, sir?
MICHAEL KNECHT: I do.
MR. CONRAD: All right, and do you recognize that?
MICHAEL KNECHT: I do.
MR. CONRAD: All right, and what is that?
MICHAEL KNECHT: State's Exhibit 267, Buster cellular information.
MR. CONRAD: And there's a number and a Verizon account associated with Buster's phone records?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And we're not going to read that number into the record, but have you had an opportunity to review the contents of that CD?
MICHAEL KNECHT: I have.
MR. CONRAD: And what is the contents of that CD?
MICHAEL KNECHT: Subscriber information, cellular data information in response to a search warrant.
MR. CONRAD: All right, and is that an accurate copy of the records originally provided to Verizon to law enforcement in response to a search warrant?
MICHAEL KNECHT: They are.
MR. CONRAD: All right, and what number do you have with you? What number is that again?
MICHAEL KNECHT: State's Exhibit 267.
MR. CONRAD: All right. At this time the State would move to enter Exhibit 267 into evidence.
MR. HARPOOTLIAN: No objection.
JUDGE NEWMAN: It's admitted.
(CELLULAR DATA MARKED AS STATE'S EXHIBIT NUMBER 267 WAS RECEIVED INTO EVIDENCE.)
MR. CONRAD: Okay. I'm going to hand you -- this is marked as -- on the back as State's Exhibit 270. Do you recognize that, sir?
MICHAEL KNECHT: I do.
MR. CONRAD: And what is that?
MICHAEL KNECHT: This would be a key that is used to explain the VoLTE call detail with cell site explanation.
MR. CONRAD: And does that originally come from a PDF provided with each of these search warrant returns?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And so that document would be found on each of those CDs, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right, and this is just a printed out version.
MICHAEL KNECHT: That is correct.
MR. CONRAD: But is it exactly similar to the explainer contained on those CDs, correct?
MICHAEL KNECHT: Yes, sir.
MR. CONRAD: And at this time, the State would move Exhibit 270 into evidence.
MR. HARPOOTLIAN: No objection.
JUDGE NEWMAN: It's admitted.
(EXPLANATORY KEY MARKED AS STATE'S EXHIBIT NUMBER 270 WAS RECEIVED INTO EVIDENCE.)
MR. CONRAD: All right, sir. So, let's talk about that document you have in your hands. I think you told us kind of what it is, but can you give us a little more detail? What does that do, and how does that help someone looking at these records?
MICHAEL KNECHT: In response to a search warrant, Verizon provides a key to be able to read their records that were provided, so this particular record is VoLTE call detail record key.
MR. CONRAD: Okay. All right. I'll take this to --
MR. CONRAD: And I think the ELMO is still up. We need the ELMO up, please.
(Break in proceedings.)
MR. CONRAD: Okay. So, looking at Exhibit 270, State's Exhibit 270, we see several columns of information across that. Is that correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Okay. Can you read from your screen there, sir? Can you read some of that information?
MICHAEL KNECHT: Yes, sir. The first column is record open date and time. The second -- would you like for me to read across?
MR. CONRAD: Well, let's lay a little more foundation. The records that are provided on those CDs -- and what -- they're in digital format, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And what program are they sent in?
MICHAEL KNECHT: Excel.
MR. CONRAD: Okay. Excel form, and that's a spreadsheet, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And so when we look at these records, they're all provided in columns in an Excel spreadsheet, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And each column, going left to right, is a different sort of information that is on the records, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right, and so we'll look at an example in a few minutes, but this is the key to look at to understand what each column is in reference to, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Okay. So, let's look at the far left column, and I believe that says record open date time. What does that mean, sir?
MICHAEL KNECHT: That would be the date and time the call record transpired in local time.
MR. CONRAD: In local time. Okay, and what's the second column from the left?
MICHAEL KNECHT: That would be the date and time the call transpired in Greenwich Mean Time.
MR. CONRAD: Okay, and Greenwich Mean Time, is that also known as universal time?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And on June 7th of 2021, do you know what the approximate offset for local time and Eastern time with Greenwich Mean Time? Would it surprise you if I said it was 4 hours' difference?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Okay. Going to the third from the left column, what is that?
MICHAEL KNECHT: That is the serving system ID.
MR. CONRAD: And what does that mean?
MICHAEL KNECHT: That's a network name on Verizon from which the call transpired.
MR. CONRAD: Okay, and what is the column next to that? I believe it's labeled NIU.
MICHAEL KNECHT: That would be the switch number that Verizon uses to route.
MR. CONRAD: Okay, and what is a switch, generally speaking?
MICHAEL KNECHT: It would be what's considered a hub for multi cell towers.
MR. CONRAD: So, multiple cell towers would be connected with one switch.
MICHAEL KNECHT: That is correct.
MR. CONRAD: And then going next cell ID, what is that called?
MICHAEL KNECHT: That would be the specific cell tower that the target number used to make the cellular data connection.
MR. CONRAD: Okay, and that's the actual tower that a particular call was routed to, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And the next column says cell face. What is that?
MICHAEL KNECHT: That would be the cell face that the cellular data connection transpired over -- there's typically three faces on each cell tower.
MR. CONRAD: Okay, and next we see market ID. What is that?
MICHAEL KNECHT: That is a switch number, so in some records it will have that listed. So, it's the same thing as the NID but looping it on a specific record which column would be used.
MR. CONRAD: Okay, and then next column it says END. What is that?
MICHAEL KNECHT: It's a six digit cell tower number. The first three digits is the market ID, and the last three digits is the tower identification.
MR. CONRAD: Okay. Next column says DIR. What does that show for, and what does it mean?
MICHAEL KNECHT: That's the direction that the call transpired over the Verizon network.
MR. CONRAD: And when you say direction, you mean incoming call or outgoing call, that sort of direction, not north, south, east, or west, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And the next column says MSISDN. What does that mean, sir?
MICHAEL KNECHT: That is the Verizon subscriber number that the record is for.
MR. CONRAD: Okay, and it says this is your target number, and that's in reference to the search warrant, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And so when a search warrant asks for records for a certain number, that's the target number, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And that's what that column identifies, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And next column says called number. What does that mean?
MICHAEL KNECHT: This is the number dialed to initiate a call. For inbound calls, this number will be the same as the mobile directory number MSISDN column, and the outcalls, this is the number your target dialed.
MR. CONRAD: Okay. So simplifying it, it's simply the number that was called when someone placed the phone call, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Next column is CBN. What is that, sir?
MICHAEL KNECHT: This is the calling party number that initiated the call. If the call is outbound, this column will be the same as the mobile directory number, MSISDN. If the call is inbound, this is the number that dialed your target.
MR. CONRAD: Okay, and the next column says SOU. What is that, sir?
MICHAEL KNECHT: Seconds of duration.
MR. CONRAD: Okay, and that's how long the call lasted, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And the next column says RAT. What does that mean, sir?
MICHAEL KNECHT: That is the type of cellular connection that the data session or call transpired over.
MR. CONRAD: And so we see several different categories underneath that. I see a 3G voice, 4G voice, and some others. What does that stuff mean?
MICHAEL KNECHT: The Verizon Wireless technology that's used to allow that call to take place.
MR. CONRAD: Okay. So, 3G and 4G are different types of technology Verizon uses?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And depending on which tower and where the phone is located a call could be routed over 3G or 4G. Is that correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Okay. Getting pretty close to the end here. The next column says VICE, v-i-c-e, end points. What does had a mean, sir?
MICHAEL KNECHT: It's a VoLTE connection with an end point. So, that's a type of device that can boost the Verizon signal. It's an indicator if that was used or not.
MR. CONRAD: Okay. The VO -- you call it a VoLTE. What is that?
MICHAEL KNECHT: Voiceover LTE. It's a type of technology, similar to the 4G.
MR. CONRAD: Okay, and that's a voice call that's routed over the digital network, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And finally we see VZWNE network extender, excuse me. What is that column, sir?
MICHAEL KNECHT: That is a device that allows consumers to connect to a network extender to boost their indoor coverage, so there will be a difference in the call type listed in the records.
MR. CONRAD: So, Verizon provides to certain customers network extenders for them to use in buildings to help them connect calls in buildings. Is that correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Okay, and if a call were routed through such a connector, it would be listed in that column.
MICHAEL KNECHT: That is correct.
MR. CONRAD: Okay.
MR. CONRAD: I would like to switch over to the laptop, please.
MR. CONRAD: And I'm going to hand you back Exhibit 270 in case you need to look at it here. And I'm going to pull up some of the records that were provided that we just talked about on the CDs. And the first one I'll pull up is one associated with Maggie Murdaugh. Her number ends in 9041. I believe that comes from exhibit -- that's State's Exhibit 265. Okay. So, we're going to scroll down and we're going to talk about a couple of these calls just so the jury understands, or can understand some of these records.
(Break in proceedings.)
MR. CONRAD: Okay. I've highlighted column 1846 on this spreadsheet. Can you see that, sir?
MICHAEL KNECHT: I can.
MR. CONRAD: Okay. So, let's walk through this particular call. All right. The far left column, Column A, we see a number there. What is that number, sir?
MICHAEL KNECHT: That's the phone number that was associated with the search warrant.
MR. CONRAD: Okay, and that's the 9041 number, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Okay, and call Column B, I see a date that says May 1st of '21. What is that date, sir?
MICHAEL KNECHT: That was the date that the search warrant started the request for the search warrant.
MR. CONRAD: Okay. So, when law enforcement sent a search warrant to Verizon, it requested date of records starting on May 1st. Is that correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: May 1st of 2021. And then the next column says June 10th of 2021. What is that date, sir?
MICHAEL KNECHT: That is the last day that was requested on the search warrant.
MR. CONRAD: Okay. All right. So, in this case June 10th was the last date from that search warrant.
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right. Okay. So, let's look at Column D. And what is Column D in this record?
MICHAEL KNECHT: That is the time that the actual call took place in local time.
MR. CONRAD: Okay, and what time is that?
MICHAEL KNECHT: 19:50 and 20 seconds.
MR. CONRAD: All right. Can you convert military to civilian time? Are you good at it?
MICHAEL KNECHT: I am not good.
MR. CONRAD: Okay. Generally you subtract 12. Is that correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: So, would that be 7:50 p.m.
MICHAEL KNECHT: That is correct.
MR. CONRAD: Okay. All right, and then the next column we see, it says June 7th of 2021 at 23:50. What is that column?
MICHAEL KNECHT: That's the record in Greenwich Mean Time.
MR. CONRAD: And so that's in the universal time, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And I'm -- can you convert that to local time? Subtracting 12, would it be --
MICHAEL KNECHT: It would be 11 --
MR. CONRAD: -- 50 p.m.?
MICHAEL KNECHT: -- 50 p.m.
MR. CONRAD: Next column there's a digit that says 13. What is that digit, sir?
MICHAEL KNECHT: Can you scroll to the top where I can see the header on that?
MR. CONRAD: Sure, and we're looking at Column I.
MICHAEL KNECHT: That is the cell face number.
MR. CONRAD: All right, and so that is the direction off of -- based off of what you previously testified to, that is the direction the call is in, the sector from the tower, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: I'm going to scroll back down. Bear with me, please.
(Break in proceedings.)
MR. CONRAD: Okay. We're back on June 7th, and we're back at Column 1846. So, we just said the 13 was the direction from the tower, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right, and so we see a number next to that that says 459. What is that number, sir?
MICHAEL KNECHT: That is the market ID.
MR. CONRAD: Okay, and market ID, again, what does that mean?
MICHAEL KNECHT: That would be the switch on Verizon Wireless network.
MR. CONRAD: Okay, and then next to that is Column K, and that says -- there's a digit that says 459240. What is that, sir?
MICHAEL KNECHT: That is the ENID. The first three digits are the switch; the second three digits are the cell tower information.
MR. CONRAD: Okay, and so that identifies the actual tower that that call was routed through, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And then next to that in Column L we see MO. What does that mean, sir?
MICHAEL KNECHT: Mobile originated.
MR. CONRAD: All right, and what does that mean?
MICHAEL KNECHT: The cell phone in question to this search warrant originated the call.
MR. CONRAD: So, this means this call was placed with Maggie's phone, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Okay, and then next to that we see a phone number in Column M, and it ends in 9041. Is that the target, a phone number?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And next to that we see a number that ends in 0853. What is that in Column M?
MICHAEL KNECHT: That was the number that 9041 dialed.
MR. CONRAD: Okay, and then Column O, and we see that 9041 number again. And remind us what that -- why that number is there again?
MICHAEL KNECHT: That was the number that dialed the 0853.
MR. CONRAD: Okay, and then next, Column P, we see a 165, a digit of 165. What does that mean?
MICHAEL KNECHT: That is time in seconds.
MR. CONRAD: Okay. So, that's how long the call lasted?
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right, and then Column Q, it says LTE. What does that mean?
MICHAEL KNECHT: That's the Verizon technology type that was used to make the call.
MR. CONRAD: Okay. So, this call was routed over LTE, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And that's a 4G technology?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Okay. So, let's look at the column below that, and that's Column 1847. And let's just go ahead and look directly at Column D, and that's a date where it says 202168010424. Remind us again what that column means.
MICHAEL KNECHT: Which column?
MR. CONRAD: Column D. We see the date of June 8th of 2021, and it's a time that says 01:04:24.
MICHAEL KNECHT: That is the time in Greenwich Mean Time.
MR. CONRAD: Okay. Now, you previously testified that in Column D, that time is normally provided in local time. Is that correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: But in this particular record, we see a time in Greenwich Mean Time, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Why is this -- in this particular call, why is it in Greenwich Mean Time?
MICHAEL KNECHT: Because this call connected to Verizon, but the call was not answered on the cellular connection and routed to voice mail.
MR. CONRAD: Okay. So, because the -- this call was not picked up, the call was routed to a Verizon server, right?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And because of that, Verizon reports the record in Greenwich Mean Time.
MICHAEL KNECHT: That is correct.
MR. CONRAD: But -- I hate to do this, but let's convert that back into local time. So, subtract four from 01:04:24, and would that yield a time of 9:04:24 in Eastern time, sir?
MICHAEL KNECHT: That would be correct.
MR. CONRAD: Okay. P.m., correct?
MICHAEL KNECHT: That's correct.
MR. CONRAD: All right. All right, and let's skip over Column I, Column J, and Column K. I believe you said previously Column K was the digit associated with the particular tower a call is routed through, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Well, here we see in this one NA. Is that what that says?
MICHAEL KNECHT: That is correct.
MR. CONRAD: What does that mean? Why does it say NA?
MICHAEL KNECHT: Well, the call didn't actually connect to a cell tower. When the call didn't answer, it routed to voice mail. It's an internal routing, so there would be no cellular data as far as cell tower information provided.
MR. CONRAD: Okay. So, a call was placed to the 9041 number, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And the 901 (sic) phone most likely rang, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: But no one answered.
MICHAEL KNECHT: That is correct.
MR. CONRAD: And so Verizon did not record a particular cell tower associated with that call. Is that correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right. Let's finish up with this record. Column M, again, that's the target number, correct, the 9041?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And then we see in calling Column N, as in November, 9041, again the same number, and what does that mean?
MICHAEL KNECHT: That means the 1227 number dialed the 9041.
MR. CONRAD: Okay. All right, and no one answered, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And I skipped over a column, Column L, that says MT. And what does that mean?
MICHAEL KNECHT: Mobile terminated.
MR. CONRAD: Okay, and so that call was not, in fact, completed, correct?
MICHAEL KNECHT: It was forwarded to voice mail.
MR. CONRAD: Okay. All right, and after that 9:04 p.m. phone call, we see multiple more calls to Maggie's phone, correct, or multiple, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right, and are any of those calls answered, according to records that Verizon keeps?
MICHAEL KNECHT: They are not.
MR. CONRAD: All right. I'm going to shift to pulling up the call records for the number ending in 1227, and that is State's Exhibit 268. And that's the number associated with Alex Murdaugh's phone, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right. Bear with me.
(Break in proceedings.)
MR. CONRAD: Let's look at Column 2371. All right, do you see that on your screen, sir.
MICHAEL KNECHT: Yes, sir.
MR. CONRAD: All right, and we see a time and Column D, and that says June 7, 2021, of 21:04:24. Is that correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And this time is in local time. Is that correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And a quick conversion on that -- or excuse, me, so no conversion is necessary on that. So, that's 9:04 p.m. and 24 seconds, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: And that is, in fact, the same time that we just saw in Maggie's records that we just reviewed, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right, and so we see if we look over in Column I, J, and K, we do have cell tower information for the outgoing call from Alex's phone, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right, and then we see the -- this is code MO, and what does MO mean again?
MICHAEL KNECHT: Mobile originated.
MR. CONRAD: Okay, and so that means this account was placing the call, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: The account ending in 1227. All right, and it was placed to the number ending in 9041, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: All right, and then looking below that, we're not going to review this line by line, but we see a number of other calls starting at about 9:04 p.m. and onward over the next hour or two of calls made from the 1227 account, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Okay.
MR. CONRAD: No further questions from the State for this witness.
JUDGE NEWMAN: By the defense?
MR. HARPOOTLIAN: May it please the Court, Your Honor? While he's looking for -- I apologize for the technology here.
CROSS-EXAMINATION
BY MR. HARPOOTLIAN:
MR. HARPOOTLIAN: So, you work for Verizon.
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: And you -- are -- you just deliver records to different people, or do you have a more, I say the word functional, but do you have a -- duties beyond just coming to court and delivering records?
MICHAEL KNECHT: Yes, sir. I work in executive relations, and I respond to subpoenas, other court records, and other type of cases that are associated with the executive relations team.
MR. HARPOOTLIAN: And obviously you have to have some understanding of what you're delivering, what these things mean, right?
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: And as I understand it -- and I'm going to ask you in a minute what some things mean. So, you see -- is this on? Can you see that?
MICHAEL KNECHT: Yes, sir.
MR. HARPOOTLIAN: Okay. So, if you look down, if you look down at 6/7, and if you look at -- I'm trying to find some consistency here -- those NAs in lines I and J with several calls above that, do you see those?
MICHAEL KNECHT: I do.
MR. HARPOOTLIAN: What does that mean?
MICHAEL KNECHT: That means that the call was routed to voice mail.
MR. HARPOOTLIAN: So, these are voice mails to Alex.
MICHAEL KNECHT: This record is for 1227, so based off of this record, 1227 dialed the 9041, but it was routed to voice mail.
MR. HARPOOTLIAN: So, that's him dialing out. But what about if you go up to 6/7 at 22:08, is that another -- is that a call out or a call in?
MICHAEL KNECHT: Is that the line that you have highlighted?
MR. HARPOOTLIAN: No. I'm talking about -- go up to 6/7 maybe --
(Break in proceedings.)
MR. HARPOOTLIAN: Is that an outgoing or ingoing call -- incoming call?
MICHAEL KNECHT: That was mobile forwarded, so it was forward to voice mail.
MR. HARPOOTLIAN: I get it's forwarded to voice mail, but was Alex making it or is -- somebody else was making it? Who initiated the call?
MICHAEL KNECHT: The 7845.
MR. HARPOOTLIAN: 7845? So, that was a call in to Alex --
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: -- and it went to his voice mail.
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: And tell me where I look on this to see what's outgoing and what's incoming.
MICHAEL KNECHT: Row L, or Column L, MO, NT, and MF.
MR. HARPOOTLIAN: Okay. So, MO means what?
MICHAEL KNECHT: Mobile originated.
MR. HARPOOTLIAN: That's he's the originating caller.
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: Okay. M -- what was the other one, MT? What does that mean?
MICHAEL KNECHT: Mobile terminated.
MR. HARPOOTLIAN: So, he was getting an incoming call.
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: And MF?
MICHAEL KNECHT: Mobile forwarded.
MR. HARPOOTLIAN: What does that mean?
MICHAEL KNECHT: Routed to voice mail.
MR. HARPOOTLIAN: So, there's two of them mean -- well, all of them mean voice mail, but what was the difference between MT, MO, and MF?
MICHAEL KNECHT: The direction of a call on Verizon's network.
MR. HARPOOTLIAN: Okay. Mobile terminated is he was making a call and it went to voice mail. MO is whoever called him initiated the call and it went to voice mail.
MICHAEL KNECHT: No. MO means the cellular subscriber in response to this search warrant made a phone call out.
MR. HARPOOTLIAN: MO. So, that would be Alex calling somebody and it went to voice mail.
MICHAEL KNECHT: Correct.
MR. HARPOOTLIAN: MT is somebody called him and it went to voice mail.
MICHAEL KNECHT: Mobile terminated means that our subscriber in response to the search warrant is the one that the call placed to and could have answered.
MR. HARPOOTLIAN: And so one of them is coming in because of voice mail. Another one is going out. It goes to voice mail, and MF is what?
MICHAEL KNECHT: No, sir. MO means mobile originated, a phone call transpired over our network. So, we could have answered the phone call; it would show up as MO.
MR. HARPOOTLIAN: We being who on this? If Alex had answered the phone call, it would have --
MICHAEL KNECHT: It would be mobile terminated because our subscriber answered the phone call.
MR. HARPOOTLIAN: Oh, okay. So, MO he answers it. Am I losing my -- are you losing me or am I losing you?
MICHAEL KNECHT: MO is mobile originated, so that means subscriber 1227 dialed out on Verizon's network.
MR. HARPOOTLIAN: Okay, and it was answered.
MICHAEL KNECHT: It could have been answered, yes. I mean, it was a call that transpired and it would create a cellular connection which would connect to a cell tower.
MR. HARPOOTLIAN: Okay. Not -- and it wasn't answered by voice mail.
MICHAEL KNECHT: Which record?
MR. HARPOOTLIAN: The MO.
MICHAEL KNECHT: MO is mobile originated, which means --
MR. HARPOOTLIAN: I got that part. I just want to know how you differentiate between these calls as ones going out, one is coming in, one is going to voice mail either way.
MICHAEL KNECHT: MF is mobile forwarding, so that call would have went to voice mail.
MR. HARPOOTLIAN: Whether he was getting it or giving it.
MICHAEL KNECHT: Well, if someone were calling him and he didn't answer, then it would be forwarded it voice mail.
MR. HARPOOTLIAN: That's MF.
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: Okay. I've got it, I finally get it. It took me awhile, but, again, I'm not a technological expert here. So, as you look at his calls to the extent of that they are made at certain times, you can figure out whether it was coming, going, or went to voice mail based on these records.
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: Now, could I see Maggie's phone for just a second, please?
(Break in proceedings.)
MR. HARPOOTLIAN: And these are her phone calls starting at 7:02, and when we get down to -- so tell me. After that 7:02 p.m., 23:02, when is everything after that -- well, when is the first time her phone goes to voice mail?
MICHAEL KNECHT: The 23:40 call went to voice mail. Then the next call log after that is mobile originated, which means there were two outbound calls made. And then after those two calls, the rest of the calls were routed to mobile telephone number 9041's voice mail.
MR. HARPOOTLIAN: When is the last time she made a call out?
MICHAEL KNECHT: 19:50:20.
MR. HARPOOTLIAN: What time is that in non-military time? 19:50 is --
MR. CONRAD: 7:50 p.m.
MR. HARPOOTLIAN: What? 7:00 p.m.?
MR. CONRAD: 7:50.
MR. HARPOOTLIAN: 7:50 p.m. That's the last call she makes out, right?
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: What about the last call she received and answered?
MICHAEL KNECHT: Well, the two calls that were mobile originated. After that, the rest of them are routed to voice mail.
MR. HARPOOTLIAN: Yeah, but what are the two calls after that?
MICHAEL KNECHT: Could you please highlight?
MR. HARPOOTLIAN: It's complicated, I know, even for you.
(Break in proceedings.)
MR. HARPOOTLIAN: And was there any inbound that were answered after 7:50?
MICHAEL KNECHT: There were not.
MR. HARPOOTLIAN: Okay, and -- so, how about look at this for 6/9 and 6/10, and it stops at 6/10. Are there any outgoing or incoming or -- in other words, any outgoing call, first of all, from that phone after -- on 6/9?
MICHAEL KNECHT: Mobile telephone number 9041 did not place a call outgoing.
MR. HARPOOTLIAN: Okay. What about any incoming calls?
MICHAEL KNECHT: The rest of the records are incoming calls that were routed to voice mail.
MR. HARPOOTLIAN: Voice mail. So, the calls coming into her routed to voice mail. No calls after 6/9.
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: Now, let me ask you this. Text messages, are they shown on these records? You charge for them, right?
MICHAEL KNECHT: They are in a separate record, yes.
MR. HARPOOTLIAN: Were you asked to produce those?
MICHAEL KNECHT: They are in the file.
MR. HARPOOTLIAN: They're in the file. It's just we're not looking at them here today.
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: And are they reflected on this kind of same format?
MICHAEL KNECHT: Very similar. They have a separate key to translate exactly what each column and row means.
MR. HARPOOTLIAN: But you produced those text messages for all of the phones we've talked about here today.
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: Were any other phone records subpoenaed from you other than the ones that have been put into evidence?
MICHAEL KNECHT: The only ones that I am aware of is the ones that I have been -- I received the records of.
MR. HARPOOTLIAN: Did you ask for more records than these?
MICHAEL KNECHT: I did not.
MR. HARPOOTLIAN: Did the search warrant designate records other than these?
MICHAEL KNECHT: We would have to review the search warrant.
MR. HARPOOTLIAN: You don't have it with you?
MICHAEL KNECHT: No, sir.
MR. HARPOOTLIAN: Beg the Court's indulgence for just a moment.
(Break in proceedings.)
MR. HARPOOTLIAN: So, what is the data retention policy for Verizon? How long do these records stick around?
MICHAEL KNECHT: Verizon maintains records for billing purposes for around 18 months. In response to a subpoena or search warrant, we do keep the detailed records on file for those search warrants.
MR. HARPOOTLIAN: But absent somebody serving a search warrant after 18 months, they're purged?
MICHAEL KNECHT: We no longer have that information on file typically.
MR. HARPOOTLIAN: Does anybody have them?
MICHAEL KNECHT: I mean, the billing information would be available, like, through My Verizon where you could go and look at your bill.
MR. HARPOOTLIAN: But this kind of information would not.
MICHAEL KNECHT: That is correct.
MR. HARPOOTLIAN: Okay, and when you indicate these calls went to voice mail, how long does a phone ring before it kicks into voice mail?
MICHAEL KNECHT: There's no set time.
MR. HARPOOTLIAN: Who sets it?
MICHAEL KNECHT: Well, it depends on how long it takes the network to locate the call. So, when you hear a ring when you're dialing someone, it's really just the network trying to locate. So, the phone itself may never ring if the network can't find you.
MR. HARPOOTLIAN: And that makes, say, two or three or four rings?
MICHAEL KNECHT: It can take two, three, up to six.
MR. HARPOOTLIAN: So, when my wife accuses me of being impatient and hanging up on her before she gets to answer the phone, you just told me it's because the network many instances has not connected with her phone yet.
MICHAEL KNECHT: The network is locating your phone. When you hear the ringing, the network is locating where you are on that network.
MR. HARPOOTLIAN: And that could take awhile. And so if I'm hearing five rinse and figured she's not going answer and I don't to leave a voice mail I hang up, and so there's just no voice mail. It's just an incomplete call on your records.
MICHAEL KNECHT: Well, I mean, if she didn't answer your phone call and let it go to voice mail, then it would ring out. The network --
MR. HARPOOTLIAN: Maybe I don't want to leave a voice mail. It rang four or five times. Can I hang up before she can get to the phone?
MICHAEL KNECHT: Sure.
MR. HARPOOTLIAN: That solves a mystery.
MR. HARPOOTLIAN: Thank you.
JUDGE NEWMAN: Any redirect?
MR. CONRAD: One quick question, Your Honor.
REDIRECT EXAMINATION
BY MR. CONRAD:
MR. CONRAD: Just to clarify, when the Verizon records indicate that a call is routed to voice mail, I believe you previously testified that could mean the phone itself rang, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: But there's another condition the phone could be in as well. If the phone is turned off and someone dials that number, what would the Verizon record indicate?
MICHAEL KNECHT: It would route to voice mail.
MR. CONRAD: It would look exactly the same, correct?
MICHAEL KNECHT: Correct.
MR. CONRAD: And there's no way to look at those records and tell whether a phone is off, just not answering, or potentially shutoff and otherwise not connected to the network, correct?
MICHAEL KNECHT: That is correct.
MR. CONRAD: Okay.
MR. CONRAD: Okay. That's all from the State. Thank you, Your Honor.
MR. HARPOOTLIAN: If I can just ask one --
JUDGE NEWMAN: Yes, sir.
RECROSS-EXAMINATION
BY MR. HARPOOTLIAN:
MR. HARPOOTLIAN: What about if it's in airplane mode? Would the same thing happen? It goes to voice mail, right? Airplane mode, it doesn't ring. It doesn't answer. It goes -- would it go to voice mail?
MICHAEL KNECHT: The network would still try to find where you're located. So, if you're in airplane mode, the network may not know where you are so it would still attempt to ring.
MR. HARPOOTLIAN: And these records don't give you any GPS location on the phones, correct? You can't get that GPS.
MICHAEL KNECHT: According to the records that I've seen, they have the cell tower information but not specific GPS.
MR. HARPOOTLIAN: And cell tower information, depending on how many cells are connecting, it sometimes -- I mean, it could be if you're in New York City and there's five cell towers, you would probably get it pretty close. But if you're in rural Colleton County, Hampton County, there is one over here and maybe one way down there, it's much more difficult to find a specific location, correct?
MR. CONRAD: Your Honor, the State is going to object. This witness is not qualified an expert on cell tower location.
MR. HARPOOTLIAN: Your Honor, he can say I'm not qualified to answer that.
JUDGE NEWMAN: Yes, sir.
MICHAEL KNECHT: That information --
JUDGE NEWMAN: Just a moment. Respond if you want to.
MR. CONRAD: The statement -- he can answer the question if he is able to answer the question. However, he's not qualified as an expert.
MR. HARPOOTLIAN: I don't --
JUDGE NEWMAN: All right. You may answer the question if you can.
MICHAEL KNECHT: I would have no way as knowing. I'm not qualified as far as the triangulation of cell tower information.
MR. HARPOOTLIAN: Is that what you were getting ready to say before you objected and said you weren't qualified, or is that something --
MICHAEL KNECHT: That would be a standard response.
MR. HARPOOTLIAN: You've never testified about locations of towers.
MICHAEL KNECHT: Repeat the question.
MR. HARPOOTLIAN: You've never testified about what cell phone tower location means in -- and how it's used.
MICHAEL KNECHT: I testify to the accuracy of the records that were provided.
MR. HARPOOTLIAN: Okay.
MR. HARPOOTLIAN: Thank you.
JUDGE NEWMAN: You may step down. Thank you.
(The witness exited the stand.)