1.Julie Cramer — Direct/Cross/Redirect/Recross
615 linesTHE COURT: At this time the Court calls State of Wisconsin vs. Steven Avery, Case No. 05 CF 381. We're here this morning for a continuation of the trial in this matter. Will the parties state their appearances for the record, please.
MR. KRATZ: Good morning, your Honor, State appears by Calumet County District Attorney Ken Kratz, Assistant Attorney General Tom Fallon, Assistant District Attorney Norm Gahn, all appearing as special prosecutors.
MR. STRANG: Good morning, as well. Steven Avery is here in person; Jerome Buting and Dean Strang on his behalf.
THE COURT: Thank you. Mr. Kratz, at this time you may call the State's next witness?
MR. KRATZ: Thank you, Judge. The State would call Julie Cramer to the stand.
COURT CLERK: Please raise your right hand.
JULIE CRAMER, called as a witness herein, having been first duly sworn, was examined and testified as follows:
COURT CLERK: Please be seated. Please state your name and spell your last name for the record.
JULIE CRAMER: Julie Cramer, last name is C-r-a-m-e-r.
MR. KRATZ: Ms Cramer, if you could be so kind as to pull the microphone a little bit closer, we'll probably be able to hear you a little bit better. Good morning, Ms Cramer.
DIRECT EXAMINATION BY ATTORNEY KRATZ:
MR. KRATZ: Tell the jury, if you would, please, what, if any, involvement you were asked to have in the search for Teresa Halbach.
JULIE CRAMER: I'm with Great Lakes Search and Rescue Canine and I handle a search and rescue dog. And we were asked to come and help with the search for Teresa Halbach.
MR. KRATZ: How long have you been involved in search and rescue?
JULIE CRAMER: I started training search dogs in 1989.
MR. KRATZ: Do you know how many search dogs you have trained?
JULIE CRAMER: I'm handling, currently, my sixth and seventh dog. The dog that I work now is my fourth human detection or cadaver dog.
MR. KRATZ: Do you work with a specific organization?
JULIE CRAMER: Our organization, Great Lakes Search and Rescue, is a group of volunteers. We respond to any -- any agency request, whether it's law enforcement, fire rescue, emergency management.
MR. KRATZ: How long has that organization been together?
JULIE CRAMER: Great Lakes was founded in 1992 and incorporated in 1993, so we have been together 14 years.
MR. KRATZ: The agencies that you assist, including law enforcement; do you assist any civilians in civilian type searches?
JULIE CRAMER: We never respond to civilian requests. If a family member of a missing person calls us, we refer them to their agency. We get involved with civilians on search scenes, but we always assist agencies.
MR. KRATZ: Let's talk about the dogs themselves. Are there different kinds of dogs for different kinds of searches?
JULIE CRAMER: Sure, within the scope of search and rescue dogs there are tracking dogs, like bloodhounds. There are area search dogs that pick up the scent of a person in clear areas. And then there are cadaver dogs or human remain detection dogs. They have two different names. And we have all the types of dogs within our search team.
MR. KRATZ: Do different kinds of breeds need -- Let me ask you this way, is a specific kind of breed selected most often for these different kinds of searches?
JULIE CRAMER: Yes, usually you select a breed that is most adaptable to that kind of search. Bloodhounds are known for their ability to track people. A lot of the German Shepherd breeds are used for area searches. Within the human remains detection, you want a dog that's very high drive and able to do the work. I handle a Belgian Shepherd.
MR. KRATZ: What does high drive mean?
JULIE CRAMER: A dog that will keep working in spite of bad weather, will find the same thing over and over, or if you look for very small scent sources, because we also look for evidence, not just whole bodies.
MR. KRATZ: Is there a certification procedure for dogs?
JULIE CRAMER: Yes, there is. Within our dog team we have a set of credentials that the dog has to train for a year and then pass testing to show that they are -- are qualified to do the work. And then, depending on what part of the country you live in, there's various testing that you need. We have met all the testing available to us at this time.
MR. KRATZ: What kind of training goes into a specific kind of dog; in this case, a human remains detection dog?
JULIE CRAMER: A lot of time. A lot of hours. Brutus, the dog that I worked on this case has about 6,000 -- had about 6,000 logged hours at the time that he responded to this case.
So it's a weekly, monthly, daily commitment of our handlers to work with their dog in the area of expertise.
MR. KRATZ: The certification -- or to obtain a certification, does that require some field testing; in other words, that you actually go out in the field and have to demonstrate the reliability of the dog?
JULIE CRAMER: Yes, it does. And that has to be recertified annually to a set of standards. The dog has to be able to perform in different environments: Wilderness, human contamination. They have to work set up problems set by an outside evaluator and they have to show that they can reliably locate the source that was set up for them, both on land and water, depending on your certifications.
MR. KRATZ: There is a photo in front of you; it's Exhibit No. 128. Can you tell us what Exhibit 128 is.
JULIE CRAMER: That is a picture of my dog, Brutus, and I. This was our team picture taken this past year. Brutus is a 10 year old Belgian Malinois, which is one of the types of Belgian Shepherds. And he is certified in human remains detection, both land and water.
MR. KRATZ: All right. You said that Brutus was 10 years old, can you give the jury a little background on Brutus.
JULIE CRAMER: I obtained Brutus when he was about 18 months old, from a dog shelter. We do a lot of recycling of dogs. I started working with him as my partner then. He and I have been certified within our team here in Wisconsin and in northern Illinois for the last eight years.
MR. KRATZ: Now, even though he had been certified eight years ago, you had mentioned that the certification process, especially for Brutus, is an annual event; is that right?
JULIE CRAMER: Yes.
MR. KRATZ: Does Brutus have a track record or history that you can explain to the jury?
JULIE CRAMER: Brutus has an extensive track record. He seems to find the detection of human remains to be something easy for him, like a labrador with ducks. And he has worked hard at it for all these years.
We have been on numerous searches and he's established a track record in northern Illinois and Wisconsin as a dog that works in blood evidence and human remains detection.
MR. KRATZ: How many human remains detection cases has Brutus been asked to assist on?
JULIE CRAMER: He's been out -- I have been out myself on about 200 human remains detection cases. Brutus has accompanied me -- he is my third cadaver dog -- on about 150 of those. We have been successful in about 70 cases.
MR. KRATZ: All right. When you mean -- or when you mention the word successful, what does that mean?
JULIE CRAMER: That there's actually been something located in the area we search. Establishing credibility for a dog is a little bit hard because sometimes we're not in an area where there is anything. So sometimes you search really hard and there is nothing there.
But Brutus does both land and water. And he's worked hard and there have been about approximately between 70 and 80 documented cases where he has correctly indicated at something that's later been determined to be part of a case or human remains.
MR. KRATZ: On the flip side of that, has Brutus ever indicated human remains when they weren't there; in other words, has -- I don't know how to gently ask this. Has Brutus ever been wrong?
JULIE CRAMER: We have not found Brutus to be wrong in that we were able to say that he just barked to bark. There have been times where what he has found is not related to a case.
For instance, if he's working septic systems, sometimes there have been barks where we have learned over the years and through training that we take things that you watch for with dogs. He has to -- He is alerting not to a specific person, but to the source that he is trained to find.
One time we searched an area where there were more than one -- there was more than one source. We did locate three different sources; the agency was only looking for one.
MR. KRATZ: All right. Now, Brutus isn't the only dog that you have handled in the human remain detection area; is that right?
JULIE CRAMER: That's correct.
MR. KRATZ: And Brutus -- Do you have other dogs, or are you aware of other human remain detection dogs?
JULIE CRAMER: Yes. On our team -- On our team, Great Lakes Search and Rescue Canine, there are three certified human remain detection dogs right now and three dogs in training that actually hope to certify this year for the first time.
We also affiliate with a team out in northern Illinois that has four dogs that have passed their testing. So, if we were called today to a search, we would have access to seven human remain detention dogs that we know to be qualified.
MR. KRATZ: And you are familiar with not only the credentials, but the track record of all those dogs; is that right?
JULIE CRAMER: Yes.
MR. KRATZ: What's the rank for Brutus among those human detection dogs?
JULIE CRAMER: It sounds like a bias, because he's mine, but right now he is the most experienced human remains detection dog that we have available to us.
MR. KRATZ: All right. In front of you, also, is an exhibit, Exhibit No. 129. It's a piece of paper. Can you tell us what that is, please.
JULIE CRAMER: That was Brutus' testing; that was his land cadaver evaluation testing in 2005, which would have been the last evaluation test he took prior to the call on this case where he did pass.
MR. KRATZ: And, again, indicating a certification as to his ability to perform these human remain detection functions; is that right?
JULIE CRAMER: Correct. And there's both an area of wilderness and urban. Urban, in the human remains detection dog, is an area of human contamination: down buildings, interiors. So he passed both his wilderness and his urban human remain detection testing in 2005.
MR. KRATZ: I'm going to ask you to just explain that a little bit further. What are wilderness detections and is that easier to do; then, let's talk about the urban. All right.
JULIE CRAMER: Okay. Usually, when you start to train a dog, you start with wilderness because it's a natural environment. And to pass that test, the dog goes out and finds a person, for instance, someone who would be hiking in the woods and would be deceased, or in a natural environment.
Normally, that's done first and then you proceed into urban, which is the -- if you follow urban the whole way, you could actually look at, like, collapsed structure dogs. But Brutus and I haven't worked that far into it. We have maintained in this area rather than going to the national response for hurricanes and disasters and that kind of thing.
We do urban human remain detection. It means he was certified to go into a building to find people, go into piles of rubble. He's worked in landfill and junkyard areas that have contamination and he's still able to find remains.
MR. KRATZ: All right. Before we get into this case, there is one area that I found interesting and perhaps the jury might, is you said water detection. What is that?
JULIE CRAMER: Dogs are very successful in helping locate drowning victims. And too many times people think dogs can't find in water, but they can. When a subject is underneath the water, they are still giving off scent and so we train dogs to be placed in boats and go out. And when they smell the correct scent, they give an indication, in most cases a trained bark indication. And that helps assist divers in locating where to dive to find -- to recover the body.
MR. KRATZ: How is a human remain detection dog, or the scent given off, different than, let's say a bloodhound, a live scent search that we do?
JULIE CRAMER: The scent isn't given off any differently, but the difference is when a person is alive. Your scent is very specific. Each of us smells differently. It's almost as individual as a fingerprint would be.
And so a live dog, a bloodhound, is given an article of clothing and they go out and follow that scent as it comes off a person. When a person dies, your body begins to decompose. And it's that -- that chemical and gas changes in the body that a human remains detection dog is trained to find.
And that human remains smell the same. We all start to smell the same after we're deceased. And so a human remains detection dog is trained to find that smell as opposed to dead animals, dead fish, or other smells. So it's a similar type of training, but they are trained on different sources.
MR. KRATZ: All right. Let's move, then, to the 5th of November of 2005. Was your organization asked to assist in this search effort?
JULIE CRAMER: Yes.
MR. KRATZ: And did you respond to the -- what's now known as, or what the jury now knows as the Avery Salvage Yard?
JULIE CRAMER: Yes, we did.
MR. KRATZ: Tell the jury what happened when you got there?
JULIE CRAMER: We were paged at approximately 1:00 in the afternoon. We arrived on scene at 2:30 and we were held at the roadblock. At approximately 3:30, they requested a dog team trained in human remains detection to come and clear an area within the Avery Salvage Yard; specifically, they wanted us to check a car crusher.
MR. KRATZ: There's an exhibit, Ms Cramer, that's been received as Exhibit No. 86, that the jury has seen before. This is a larger version of that. Will this exhibit allow you or help you explain what you and Brutus did on the evening of -- of the fifth?
JULIE CRAMER: On this -- At this first time, we were asked to just bring one dog team down, so we took our most advanced dog, our most experienced dog, which would be Brutus. And we responded what would be kind of from the bottom left corner of that photo. We came up the roadway to the area that would be a car crusher. We would have entered this way and we came in and, I believe -- is this the car crusher?
MR. KRATZ: Yes.
JULIE CRAMER: We were asked, first, to clear that location.
MR. KRATZ: What does clear that mean?
JULIE CRAMER: Take the dog through and determine if he's giving any trained indication of human remains. When Brutus smells what he believes is human remains, he barks; he gives me a bark indicator. So we did check this car crusher and we did not get any indicator at the car crusher.
MR. KRATZ: All right. Where did you then take Brutus?
JULIE CRAMER: They then asked us to proceed through the area of cars that were crushed, right in here. And we did do that.
MR. KRATZ: Was there any indication of human remains?
JULIE CRAMER: He did not give any indicators there.
MR. KRATZ: Where did you go then?
JULIE CRAMER: Then they asked us to clear along this ridge way down there.
MR. KRATZ: I need to stop you, Ms Cramer. When you say they, who are you talking about?
JULIE CRAMER: There were investigators with us and I don't have names, without referring to a report, but several law enforcement investigators that went with Brutus and I. My husband, Bob, served as my backup.
MR. KRATZ: When a officer asks you, generally, or in this case, specifically --
JULIE CRAMER: Mm-hmm.
MR. KRATZ: -- were they hinting to you or giving you any indication of what it is that they wanted Brutus to look for?
JULIE CRAMER: No. No. They are very careful not to do that. Again, here, at this time, on the 5th of November, we had no information for -- to ourselves, other than we were helping with a missing person case.
So we first checked the car crusher here. We worked up here. Then there was a line of cars up along a ridge, that's actually kind of a elevated ridgeway, and they asked us to clear that group of cars next.
MR. KRATZ: And did you and Brutus do that?
JULIE CRAMER: Yes. And in that area, Brutus did give a trained indication. It was a vehicle that was underneath some brush and there was a blue tarp there. And he did indicate. He went to this vehicle very quickly. He came back to me and sat and gave his trained indication, which was a bark. I asked him to show me again. He went back to the same vehicle, barked and returned to me again.
MR. KRATZ: You asked him to show you again; what does that mean?
JULIE CRAMER: Sometimes when a dog is in a big area, they bark, we ask them to pinpoint. He had initially approached this vehicle that was -- That is the vehicle that we approached.
MR. KRATZ: Let me just stop you there. I put on the screen and I didn't mean to interrupt you. But Exhibit No. 31 has now been placed on the screen for the remainder of your testimony. Why don't you go ahead and tell us what, specifically, Brutus did.
JULIE CRAMER: We would have been approaching from the back. The manner in which we were clearing, we're coming this way. And Brutus works off leash, so he ranges a distance from me.
He ran up to a vehicle that looked like that and he was at the back doorway, kind of where the wheel was, where the wheel cover was. He came back to me and he barked. And the law enforcement back there with me asked if he was alerting and I said yes. And normally, when he alerts, I ask him to show me; he returns to the source that he has found.
He then came back and he was very interested in this area. I recall because I was worried he was going to knock this piece of plywood over. He was alerting on the side of the vehicle, barking, placing his paw on the vehicle.
MR. KRATZ: Now, alerting on a vehicle, as his trained handler and working with him in 150 of these cases, what if anything did that tell you?
JULIE CRAMER: That told me that Brutus felt that he smelled blood or some type of human remain at that vehicle. I did ask backup, the law enforcement, if they wanted us to clear the interior of the vehicle. They said, no, please secure your dog. So, called him to me and secured him.
MR. KRATZ: So Brutus alerted twice on this vehicle; is that right?
JULIE CRAMER: Mm-hmm. From the back, behind the piece of plywood and from the side here.
MR. KRATZ: I don't know if you are able to answer this, Ms Cramer, but is there a level of confidence that you can attribute to Brutus; in other words, how he was barking at you, confidence as far as his alert?
JULIE CRAMER: There is. Sometimes the dogs will -- they will -- they will have a scent. For instance, they might be downwind of a scent and they will bark, but it will be kind of a -- you can tell they are smelling something, but it means you need to investigate further. Other times they definitely have a source.
This was definitely an indicator where he wanted -- What he wanted me to do, what Brutus wanted me to do was open this door for him. We did not do that, but in some cases, you know, he would proceed into the source. So he was confident that he wanted me to come right there. That's as close as he felt he could get to what he was smelling. So he pawed the vehicle and barked.
MR. KRATZ: All right. You said law enforcement asked you to secure your dog; what does that intend?
JULIE CRAMER: That just means put him on a leash. Whenever we respond, we aren't investigators, so we do what we're told. Sometimes they simply want to see what a dog does in an area. Other times they need to do other things.
In this case, I asked if they wanted me to approach the vehicle; they said no, secure your dog. I put him on a leash. And then we were actually taken back, away from the vehicle at that time.
MR. KRATZ: Your team, that is the team of cadaver dogs, or human remain detection dogs, were they used later that evening?
JULIE CRAMER: Yes, we were used, actually, for five days. We were used later that evening. Brutus and I were redeployed. We had other dogs deployed into the salvage yard, so, yes.
MR. KRATZ: Let's talk about you and Brutus. After Brutus alerted -- By the way, do you remember the weather that night?
JULIE CRAMER: Yes, it was getting uglier and uglier. There was sleet. It was windy. And as darkness approached it really got -- the visibility got bad. It was freezing rainy snow.
MR. KRATZ: All right. By the way, does that weather condition affect Brutus' reliability or ability to find the scent?
JULIE CRAMER: It would depend on the area. It definitely cuts down the distance from which a dog can work. Because, obviously, if it's snowing and rain is coming down, the dog can't find something from far away. One of the reasons I have selected him is he is really durable. So he doesn't care if it's raining or snowing; he just has to get in closer to his source to be able to find it because he can't smell something on the breeze like he would have on a nice day.
MR. KRATZ: The question, Ms Cramer, what was the weather like when Brutus first alerted on this vehicle; was that a factor at all?
JULIE CRAMER: The first alert, it was still just threatening. It worsened as the evening went on. I don't recall that at the time we first worked, that it had started to sleet yet. It was just looking ugly.
MR. KRATZ: You said that Brutus, with your assistance, then was asked to check some other areas; can you tell us about that, please.
JULIE CRAMER: That evening?
MR. KRATZ: Yes.
JULIE CRAMER: The next assignment, we did work some more in that particular area of the salvage yard. We did work around. There was a pond right there, so we checked the perimeter of the pond and we checked a few rows of vehicles there. Then we were returned to base. And then we began to check some buildings.
MR. KRATZ: Let me go back to Exhibit No. 86 and ask if you recognize the trailer in what would be the northwest corner of the Avery salvage property?
JULIE CRAMER: This trailer?
MR. KRATZ: Yes.
JULIE CRAMER: Yes. We did search that building, that evening.
MR. KRATZ: Who is we?
JULIE CRAMER: Brutus and I.
MR. KRATZ: All right. And were there any alerts that Brutus found from within the building itself?
JULIE CRAMER: Within that building, we did get one trained alert in a bathroom area.
MR. KRATZ: Thereafter, Ms Cramer, was Brutus taken outside of the trailer?
JULIE CRAMER: Yes. The intention had been to work the perimeter outside the trailer. Brutus proceeded toward -- between this garage and this trailer and was extremely agitated. But there was a dog -- By this time it had gotten dark and it was sleeting. There was a dog barking. I leashed Brutus as to not engage the dog. I wasn't aware of how long the dogs chain was or what type of interaction the two dogs would have.
MR. KRATZ: Specifically, Ms Cramer, behind the garage, do you see a darkened area on the photo or Exhibit No. 86?
JULIE CRAMER: Yes.
MR. KRATZ: Could you point to that with your laser pointer, please. Did Brutus ever, or was he allowed to ever search behind that garage, in that area?
JULIE CRAMER: Not that evening. The marker that I used was this white tank. He was at that tank and was barking. But beyond the tank, I couldn't tell where the German Shepherd reached, so I called him back to me and leashed him at that time. Then what he did is he ran -- he was pushing to go this way and he actually ran kind of back in this direction, toward another dog.
MR. KRATZ: Ms Cramer, I'm going to show you what's been received for identification as Exhibit No. 50, 5-0; do you recognize that dog?
JULIE CRAMER: That would be the dog, that I believe, that was barking at us that night in the dark.
MR. KRATZ: And this area, what appears to be a burned out area, was this dog near the location that is seen in Exhibit 50?
JULIE CRAMER: From my recollection, that's very similar to where the dog was located. If I'm orientated to this picture, the white tank would be somewhere right over here. That's as far as my dog and I approached right then. We weren't aware how long his chain was.
MR. KRATZ: So the night of the 5th of November, Brutus wasn't able to check this area for human remains; is that right?
JULIE CRAMER: That's correct.
MR. KRATZ: The last question that I have for you is the training that Brutus may have had in detection of burned or incinerated human remains. First of all, is it possible for a human remain detection dog to be trained in that field?
JULIE CRAMER: Yes, it is. And prior to this case, we had obtained cremated remains for training purposes. One of the sources used in Brutus' 2005 test was cremated remains.
At that time we had not worked that in the field, but we had used it in certification. Since the time of this case, Brutus has successfully located some cremated remains on another case.
MR. KRATZ: All right. And so although not given an opportunity to find cremated remains that evening, if given the opportunity, do you have an opinion as to whether Brutus would have been able to do that?
MR. STRANG: Objection, speculation.
MR. KRATZ: (By Attorney Kratz)~ Not talking about the results, but would he have been certified or trained in those detections?
JULIE CRAMER: Yes.
THE COURT: Just a second. Mr. Strang.
MR. STRANG: Speculation.
THE COURT: Parties wish to argue?
MR. KRATZ: Judge, the dog is certified in that area, that's all I'm asking.
MR. STRANG: And I think the testimony was he wasn't then.
(Court reporter couldn't hear.)
MR. STRANG: I believe the testimony was, or the implication was, that he was not certified at the time.
THE COURT: Mr. Strang, why don't you ask some additional foundation questions.
MR. KRATZ: Mr. Kratz, you mean?
THE COURT: I'm sorry, Mr. Kratz.
MR. KRATZ: (By Attorney Kratz)~ Was Brutus certified at that time in the detection of cremated human remains?
JULIE CRAMER: There is no specific test for that. One of the sources on his 2005 evaluation was cremated remains. He did successfully locate that in an evaluation setting.
MR. KRATZ: So, let me ask it this way: In the past, that is, prior to November 5th, 2005, Brutus has been successful in identifying cremated human remains; is that right?
JULIE CRAMER: Yes.
MR. KRATZ: Your Honor, I will move the admissions of, I think it's Exhibit 128 and 129 at this time, otherwise I have no further questions. Thank you.
THE COURT: Any objection to admission of the exhibits?
MR. STRANG: I don't.
THE COURT: Very well, the exhibits are admitted.
CROSS-EXAMINATION BY ATTORNEY STRANG:
MR. STRANG: Good morning, Ms Cramer.
JULIE CRAMER: Good morning.
MR. STRANG: Several minutes ago, you commented that at the moment you can't remember the name of law enforcement officers without looking at your report; when did you prepare a report of this case?
JULIE CRAMER: I prepared a report of this case in November of '05.
MR. STRANG: And do you have that with you today?
JULIE CRAMER: I don't have it with me.
MR. STRANG: Maybe we should just approach, your Honor, briefly.
(Sidebar taken.)
MR. STRANG: (By Attorney Strang)~ Would you bear with me just a second and we'll see if this is helpful or it may be of some use in refreshing your recollection. I will just leave it with you. I don't know that we'll need it, so we won't mark it for the moment, but you can have it if you need it.
Now, I gather that you have got at least two -- two living beings you describe as a partner; one is your husband Bob?
JULIE CRAMER: Yes.
MR. STRANG: And the other is Brutus?
JULIE CRAMER: Yes.
MR. STRANG: And it sounds like maybe you handle some other four legged partners as well?
JULIE CRAMER: Yes.
MR. STRANG: Where do you and your various partners live?
JULIE CRAMER: We live in Cedar Grove, Wisconsin.
MR. STRANG: Give me a rough idea, is that Sheboygan County?
JULIE CRAMER: Sheboygan County.
MR. STRANG: Do you have a TV? Do you have a television?
JULIE CRAMER: Yes.
MR. STRANG: You do, okay. And you are responding here on November 5, 2005?
JULIE CRAMER: Yes.
MR. STRANG: Do you suppose you had had your television on at any time between -- let's say 10:00 on November 3, 2005 and the time you came up to Manitowoc County from Cedar Grove?
JULIE CRAMER: Actually, we were at a map and compass training in Milwaukee and we were not at home at the time of the call. We responded from the nature center in Milwaukee County.
MR. STRANG: Okay. That was a conference that you were attending?
JULIE CRAMER: It was map and compass training for the canine team.
MR. STRANG: When you arrived, up in Manitowoc, or actually in what I will call the Avery salvage property --
MR. STRANG: And I'm going to ask Mr. Kratz if he would put exactly that one back up on the screen, 86; is that right? Maybe we'll -- What I'm interested in is, I want to have the crusher and the pond and the southern ridge.
MR. KRATZ: How's that?
MR. STRANG: Sure, just great.
MR. STRANG: (By Attorney Strang)~ So by the time you got up here, it's 2:30 and you are detained out at the check in point back up by Highway 147 for about an hour?
JULIE CRAMER: Yes.
MR. STRANG: Come in, and you describe for us the route you went, and I don't need to repeat that, but I did want to pick up on the car under the tarp, okay?
JULIE CRAMER: Okay.
MR. STRANG: Was the car under the tarp when Brutus approached that particular car?
JULIE CRAMER: Wasn't really under a tarp. There was a blue tarp near the vehicle. It had wood on it and there was a series of cars in a row, but the blue tarp is how I recollected where that car was.
MR. STRANG: Sort of tented over the car?
JULIE CRAMER: Yes, kind of on the side.
MR. STRANG: What do you mean by on the side?
JULIE CRAMER: Tented partially over that car on the front end of the car.
MR. STRANG: But Brutus didn't have to go under the tarp to get to the rear passenger wheel well, for example?
JULIE CRAMER: No, he did not.
MR. STRANG: He did not have to go under the tarp to get to the rear cargo door area?
JULIE CRAMER: No, he did not.
MR. STRANG: And those were the two places where he barked?
JULIE CRAMER: Yes.
MR. STRANG: And at that point, the sleet probably had not started, is your recollection?
JULIE CRAMER: That's my recollection.
MR. STRANG: The wind hadn't picked up yet?
JULIE CRAMER: No.
MR. STRANG: And then, what you went, then, is, further -- South is up in this picture, okay. We all know that. I'm just going to suggest that to you. So to the right is west?
JULIE CRAMER: Yes.
MR. STRANG: You sort of worked further west along that line and then around the perimeter of the pond a little bit?
JULIE CRAMER: Yes.
MR. STRANG: Now, setting aside partner Bob and the other -- any other partners in your life. Let's talk about partner Brutus for just a minute. Brutus is a dog?
JULIE CRAMER: Yes.
MR. STRANG: Does Brutus get some time to just be a dog?
JULIE CRAMER: Yes.
MR. STRANG: Does he live with you?
JULIE CRAMER: Yes.
MR. STRANG: Inside dog?
JULIE CRAMER: Yes.
MR. STRANG: And does -- When Brutus is off duty and just kind of hanging out being a dog, does he ever behave like a lot of other dogs?
JULIE CRAMER: Yes.
MR. STRANG: Does he bark?
JULIE CRAMER: Rarely.
MR. STRANG: But he will sometimes bark?
JULIE CRAMER: Yes.
MR. STRANG: For example, when he's telling you things, when he's telling you, please, open the door for me on the Toyota; he's doing that by behaviors, correct?
JULIE CRAMER: Right.
MR. STRANG: He hasn't mastered English?
JULIE CRAMER: No.
MR. STRANG: Or any other language you speak?
JULIE CRAMER: No.
MR. STRANG: So barking is one of the things he does that will tell you, as his partner, what it is he wants.
JULIE CRAMER: Barking is the behavior we have reinforced for cadaver recovery, yes.
MR. STRANG: And you described even, for the jury, that sometimes -- my word now -- you get sort of a tentative bark when something is in the wind, so to speak, and sometimes, again my word, more of a definitive or determined sort of bark?
JULIE CRAMER: Yes.
MR. STRANG: And the art of this is interpreting -- your interpretation of the gradations between those two sort of barks?
JULIE CRAMER: Yes, and proving it in evaluation.
MR. STRANG: And will Brutus tend to bark when he's confronted with, say a German Shepherd?
JULIE CRAMER: Yes.
MR. STRANG: Is he interested in other dogs?
JULIE CRAMER: Not primarily, if the dog barks at him, he will bark back.
MR. STRANG: Mm-hmm. And does he like to sniff other dogs in the way that dogs introduce themselves particularly?
JULIE CRAMER: He's not as interested in dogs as some but, yes.
MR. STRANG: When you are working him, he gets a break from time to time?
JULIE CRAMER: Yes.
MR. STRANG: Probably every hour or so?
JULIE CRAMER: Depending on circumstances, yes.
MR. STRANG: He gets some sort of a reward at a break time?
JULIE CRAMER: Yes, water.
MR. STRANG: Water. And by reward, I don't necessarily mean a dog bone or something, but a scratch on the ear, some -- some sort of reinforcement that he's appreciated?
JULIE CRAMER: Yes.
MR. STRANG: And that would include water, typically, for Brutus?
JULIE CRAMER: Yes.
MR. STRANG: Now, you -- I'm going to use a sort of a fancier word than Mr. Kratz did, but you just straighten me out if you don't understand me, because I sort of suspect you will. In handling canines or trained dogs, one of the things you are interested in is false positives, true?
JULIE CRAMER: Yes.
MR. STRANG: A false positive here would mean an alert that the dog gives when, in fact, there is no source on which the dog would have been trained to alert?
JULIE CRAMER: That would be a false positive.
MR. STRANG: Okay. You are also interested in false negatives, true?
JULIE CRAMER: Yes.
MR. STRANG: A false negative would be when, for example, as a matter of a training exercise, you know, or someone knows, because usually this would be done blind to you, correct?
JULIE CRAMER: Correct.
MR. STRANG: But someone who has set up the training exercise knows that there is a scent source on which the dog has been trained, correct?
JULIE CRAMER: Correct.
MR. STRANG: If the dog covers the area in which the scent source is hidden, but fails to give an indication or alert, that would be considered a false negative?
JULIE CRAMER: Correct.
MR. STRANG: In other words, the dog missed it?
JULIE CRAMER: Yes.
MR. STRANG: And that was a mistake, because we know it's there?
JULIE CRAMER: Right.
MR. STRANG: All right. What is, or now doesn't matter so much, but as of November 5, 2005, what was Brutus' rate of false negatives?
JULIE CRAMER: Brutus' rate of false negative would be very low. I would have to refer to a lot of logs because it's about 6,000 hours of training. He very rarely has missed a source. I can't say never, but very rarely.
MR. STRANG: And, indeed, the false negative rate is not something you have ever calculated for Brutus?
JULIE CRAMER: No.
MR. STRANG: What was his rate of false positives in November, 2005?
JULIE CRAMER: False positives are, when you are training a cadaver dog, the bigger concern because the dog is trying to please a handler.
MR. STRANG: Yes.
JULIE CRAMER: But Brutus worked through that about five years earlier. His rate of false positive has also been very low as his training progressed with his age.
MR. STRANG: So, up until about five years before this, let's say 2000, roughly, Brutus had a noticeable and unacceptable rate of false positives?
JULIE CRAMER: Not unacceptable. When you shape a behavior with an animal, any animal, you are always building toward that perfect behavior. And so with a dog that is very intense in what they are doing, a false negative -- a false positive, I'm sorry, would be initially an attempt to please a handler.
And that's what you train for. And until that reaches an acceptable level, you normally can't pass an evaluation. That's the reason that we pass certification testing, is when we feel that the dog is at a level that is reasonable. And Brutus did that a long time ago, at his age.
MR. STRANG: About five years ago?
JULIE CRAMER: He has actually passed that for eight years; seven years at the time of the case.
MR. STRANG: All right. But you have not calculated a false positive rate for him, either?
JULIE CRAMER: No.
MR. STRANG: So as you sit here today, you don't know what the false positive rate is, other than your sense is that it's very low.
JULIE CRAMER: Correct.
MR. STRANG: To be entirely fair, it's very difficult with task dogs like this to know what's a false positive out in the field?
JULIE CRAMER: That's true.
MR. STRANG: Because sometimes you may not necessarily find the scent source that the dog correctly is finding?
JULIE CRAMER: That's correct.
MR. STRANG: So the falseness, so to speak, may be the human inability to find a scent source that the dog does smell?
JULIE CRAMER: Right.
MR. STRANG: Okay. Now, in that regard, these dogs have just enormously sensitive capacity for smell?
JULIE CRAMER: Yes.
MR. STRANG: This is called the olfactory sense, correct?
JULIE CRAMER: Yes.
MR. STRANG: People like you who, for 18 years, have been training dogs like this, have no idea how it is that this olfactory smell -- or sense of the dog gets so well developed?
JULIE CRAMER: That's true.
MR. STRANG: What you know is, that it is, correct?
JULIE CRAMER: Yes.
MR. STRANG: So if you are working a human remains dog, if you are working a human remains dog in specific, in this part of the world, let's say Wisconsin, northern Illinois, you sometimes have to go back and try to learn, if you can, are their native American Indian burial grounds in the area, for example?
JULIE CRAMER: Yes.
MR. STRANG: Because the dog may pick up on human remains that are 1,000, conceivably 2,000, years old, true?
JULIE CRAMER: That would be possible.
MR. STRANG: You have to be aware of, maybe from the local historical society, was there a 19th century cemetery or family burial plot in the area that I'm working, because the dog may be picking up those remains?
JULIE CRAMER: Yes.
MR. STRANG: You have to be aware of the locations of mortuaries and, for example, whether you are downstream, as a matter of the water table, from the septic system of a mortuary or crematorium?
JULIE CRAMER: Yes.
MR. STRANG: But all that said, what the dog really is smelling is decomposing human remains, correct?
JULIE CRAMER: Yes.
MR. STRANG: Human remains meaning human tissue, skin, bone, muscle, ligament, that sort of thing?
JULIE CRAMER: We train on that and blood, bone.
MR. STRANG: And exactly, very good, and that's exactly where I was going. So we have human tissue and also human bodily fluids, correct?
JULIE CRAMER: Yes.
MR. STRANG: A dog will hit on decomposing blood, or should, if properly trained, correct?
JULIE CRAMER: Yes.
MR. STRANG: Other human bodily fluids, a dog will hit on conceivably --
JULIE CRAMER: Yes.
MR. STRANG: -- correct? And so what happens is, the minute tissue comes off us, for whatever reason, or lands on the ground, a process of decomposition begins, correct?
JULIE CRAMER: Correct.
MR. STRANG: This is an ordinary biochemical process?
JULIE CRAMER: Yes.
MR. STRANG: There are bacteria in the human body at all times and then other bacteria on the ground, or grass, or in the environment, that will begin to breakdown human tissue?
JULIE CRAMER: You are sort of speaking, though, of life scent, scent coming off a live person. A human remain detection dog needs a source of either blood, or teeth, or hair, to give off that scent.
MR. STRANG: Correct.
JULIE CRAMER: What's coming off you is live scent.
MR. STRANG: I understand that. That's why I'm saying the minute human tissue hits the ground or is no longer connected to me, for whatever reason, that's what I'm talking about, okay?
JULIE CRAMER: Okay.
MR. STRANG: Are you with me? I'm not talking about while my tissue is on me or in me? Okay?
JULIE CRAMER: Right.
MR. STRANG: But let's say now that -- that I have cut myself, okay? Badly enough to be dripping blood all over. After I faint, and you folks have to revive me, we can worry about the dog. But let's say I'm doing that, and at that point the -- the blood drips on the floor are going to begin to decompose?
JULIE CRAMER: Yes.
MR. STRANG: And we don't think of that immediately, but that's biochemically what's going on at that point, correct?
JULIE CRAMER: Yes.
MR. STRANG: And if it were a good day or a normal day, the typical day for Brutus, if you brought him into this courtroom a day, or two, or a week, or a year after I had bled all over the carpet, assuming no one had, you know, been successful in so cleaning the carpet as to remove all scent of my decomposing blood, you would expect an alert?
JULIE CRAMER: Yes, I would.
MR. STRANG: In training these dogs, it is not uncommon for you to use, I guess what politely could be called medical waste?
JULIE CRAMER: We obtain it from a coroner, but I think that's what you are asking me.
MR. STRANG: Yeah. That is, actual human remains?
JULIE CRAMER: Yes.
MR. STRANG: Although, not necessarily an entire cadaver?
JULIE CRAMER: No.
MR. STRANG: Or corpse?
JULIE CRAMER: No.
MR. STRANG: Other than a sort of specialized farm in Tennessee, under the control of the University of Tennessee, there really isn't a training or proving ground in this country where an entire corpse or cadaver would be used for the purpose of training dogs?
JULIE CRAMER: That is correct.
MR. STRANG: There are essentially three ways to train the human remains dogs that you have described for us here. One would be to use something like a pig carcass.
JULIE CRAMER: We do not do that.
MR. STRANG: Right. And most responsible human remains dog trainers no longer use a pig carcass or parts of a pig, correct, in training?
JULIE CRAMER: Correct.
MR. STRANG: Because although pigs are very similar to humans in some ways, the fact is that there will be -- or a dog may be able to detect differences in decomposing pork or pig carcass as opposed to decomposing human remains?
JULIE CRAMER: That's correct.
MR. STRANG: Another, if we go up the scale then in reliability, another way to train or test or prove these dogs is to use something called pseudo corpse, true?
JULIE CRAMER: That's correct.
MR. STRANG: That's a chemical compound that's produced commercially and available for sale?
JULIE CRAMER: We do not use that, but I'm aware of the product.
MR. STRANG: And the trend, you know, in your business, is moving away from using pseudo corpse, or this chemical product, correct?
JULIE CRAMER: Correct.
MR. STRANG: But at least the idea of pseudo corpse is that it's supposed to mimic very closely the collection of gases that emit from decomposing human tissue?
JULIE CRAMER: Yes.
MR. STRANG: That's at least the theory, correct?
JULIE CRAMER: Mm-hmm. Yes.
MR. STRANG: And then the most reliable and third or final means of training or proving a human remains dog would be to use actual human remains of some kind, correct?
JULIE CRAMER: Correct.
MR. STRANG: Now, these might be obtained lawfully from a coroner's office.
JULIE CRAMER: All of our sources are obtained lawfully.
MR. STRANG: Right. And that's why -- that's why I said that. I understand you do this lawfully. And that's off the table, okay. So when I say obtaining human remains, it's understood you are doing this lawfully.
JULIE CRAMER: Yes.
MR. STRANG: Fair enough. But a coroner's office might be one source.
JULIE CRAMER: Yes.
MR. STRANG: Hospitals might be another source?
JULIE CRAMER: Not for us, but I'm sure you could.
MR. STRANG: For other people in this business?
JULIE CRAMER: Mm-hmm.
MR. STRANG: Okay. But what is obtained, then, without becoming completely indelicate, is some small quantity of some sort of human remain, not a corpse or a cadaver?
JULIE CRAMER: That's correct.
MR. STRANG: The dog, then, is alerting to, or is trained to recognize the package, if you will, of gases and scents that are released in the decomposition or the breaking down of this sort of human tissue.
JULIE CRAMER: Yes.
MR. STRANG: If we were chemists we would be talking about esters and alchemies as the source of these odors.
JULIE CRAMER: Okay.
MR. STRANG: Is that --
JULIE CRAMER: You are okay. I'm not a chemist.
MR. STRANG: Okay. I mean is that something you heard --
JULIE CRAMER: Yes.
MR. STRANG: -- or ever been taught?
JULIE CRAMER: Yes.
MR. STRANG: Okay. I couldn't begin to tell you which esters and which alchemies, but this is the chemist's name for the molecular structure of these gases that are given off.
JULIE CRAMER: Okay. Yes.
MR. STRANG: One of the gases that decomposing human tissue gives off actually is very common, commonly understood, and that's methane?
JULIE CRAMER: Yes.
MR. STRANG: But that's only one of the gases, correct?
JULIE CRAMER: Right.
MR. STRANG: So one of the challenges if you are going to work a dog in a landfill, for example, is to train him not to hit only on methane.
JULIE CRAMER: Correct.
MR. STRANG: Correct, because landfills give off all kinds of methane --
JULIE CRAMER: Correct.
MR. STRANG: -- true? That's because any sort of living tissue in either the animal or plant kingdom, as it decomposes, will release methane gas?
JULIE CRAMER: Yes.
MR. STRANG: You are not interested in that, per se, you are interested in methane only to the extent that that is part of the cocktail of odors and gases that decomposing human tissue gives off?
JULIE CRAMER: That's correct.
MR. STRANG: But a landfill is a challenging site --
JULIE CRAMER: Yes, very.
MR. STRANG: -- for a human remains dog, for this reason?
JULIE CRAMER: Yes.
MR. STRANG: Likewise, a salvage yard, have you ever worked a salvage yard before?
JULIE CRAMER: Not this large a salvage yard, no.
MR. STRANG: But you have been to that type of scene?
JULIE CRAMER: Yes.
MR. STRANG: Okay. And one thing you know that you have in salvage yards is some number of cars.
JULIE CRAMER: Yes.
MR. STRANG: Some of those cars are just old and they went kaput and stopped running and somebody towed them off to the salvage yard?
JULIE CRAMER: Yes.
MR. STRANG: But some of them, though, were wrecked or ruined in car accidents?
JULIE CRAMER: Yes.
MR. STRANG: Car accidents, unfortunately, sometimes cause human beings to bleed?
JULIE CRAMER: Yes.
MR. STRANG: Sometimes profusely bleed?
JULIE CRAMER: Yes.
MR. STRANG: When the car is towed off after the wreck, ordinarily no one has made any effort to clean up the blood, or worse, of the human remains in that wrecked car.
JULIE CRAMER: That's true.
MR. STRANG: So a salvage yard, particularly one this size, with over 4,000 wrecked cars, is also a challenging environment for a dog?
JULIE CRAMER: Yes.
MR. STRANG: You had here, as a matter of fact, a number of alerts from Brutus to cars in the salvage yard?
JULIE CRAMER: Yes, we did.
MR. STRANG: Most of those, I'm just going to set aside the Toyota that you described, most of those human beings later decided, didn't have any relevance to the investigation, correct?
JULIE CRAMER: That would be up to the investigators.
MR. STRANG: Right. I mean, your job was simply to say, Brutus is barking, he is alerting on the trunk of this car, or the backseat of this other car.
JULIE CRAMER: That's right.
MR. STRANG: The investigators take it from there?
JULIE CRAMER: Yes.
MR. STRANG: But it would not surprise you to learn that investigators, then, may have decided there is another source of human remains here and it means nothing?
JULIE CRAMER: Yes.
MR. STRANG: This dog, Brutus, never was scented, if you will, for Teresa Halbach?
JULIE CRAMER: No, you don't scent human remains detection dogs.
MR. STRANG: Right. And this "scent" is normally a noun, not a verb, as we just used it. Let's explain that a little bit. By scenting a dog, what that means, in your special field, is if we have a search and rescue dog, a bloodhound typically, but not necessarily exclusively, could be a beagle or something, correct?
JULIE CRAMER: Correct.
MR. STRANG: What we would do is give an article of clothing; a shoe, a shirt, something that's known to belong to the missing person?
JULIE CRAMER: Yes.
MR. STRANG: Let the dog smell that or get the scent of that item of clothing, correct?
JULIE CRAMER: Yes.
MR. STRANG: And then ask the dog, on leash or off, whether he can find the scent?
JULIE CRAMER: That's correct.
MR. STRANG: And then to follow the scent.
JULIE CRAMER: Yes.
MR. STRANG: So it's not -- So for those dogs, it's not so much an alert process as it is being trained in the process of leading a handler along the path of the scent, if the scent is detected?
JULIE CRAMER: Yes.
MR. STRANG: Brutus was not given Teresa Halbach's scent?
JULIE CRAMER: No.
MR. STRANG: Because you don't do that with the human remains dog?
JULIE CRAMER: That's correct.
MR. STRANG: Brutus, then, to the extent he was alerting on the Toyota, could not tell you whether he was smelling the remains of Teresa Halbach?
JULIE CRAMER: That's correct.
MR. STRANG: He could not tell you whose remains, obviously, he might have been smelling?
JULIE CRAMER: That's right.
MR. STRANG: He could not tell you whether it was human bodily fluid or human tissue that he was smelling?
JULIE CRAMER: That's right.
MR. STRANG: He could not tell you whether the person who left the body tissue or the bodily fluid was alive or dead?
JULIE CRAMER: That's right.
MR. STRANG: What he could tell you was that someone has left some sort of human remains here?
JULIE CRAMER: That's correct.
MR. STRANG: In the example I gave of my cutting my hand and bleeding all over the floor, presumably I could be rendered first-aid, or I could put a little bandage on, or something, and I would go on just fine.
JULIE CRAMER: That's correct.
MR. STRANG: Some people might not be happy that I'm going on just fine, but I would go on just fine, right?
JULIE CRAMER: Right.
MR. STRANG: But, nonetheless, Brutus would alert on human remains on the floor?
JULIE CRAMER: Yes.
MR. STRANG: So the label of a cadaver dog is one that you rightly tend to shy away from a little bit and prefer human remains detection dog?
JULIE CRAMER: I prefer it, because sometimes we're looking for evidence not corpses.
MR. STRANG: Not corpses, exactly. And in any event, unless you find a corpse, there is no way to know that an alert means a corpse?
JULIE CRAMER: You would normally look for what source the dog was hitting, whether it was a corpse or material.
MR. STRANG: Tissue or fluid.
JULIE CRAMER: Mm-hmm.
MR. STRANG: And by fluid, let's -- let's get specific about that. Menstrual blood?
JULIE CRAMER: Yes.
MR. STRANG: Semen?
JULIE CRAMER: Yes.
MR. STRANG: How about saliva?
JULIE CRAMER: Yes.
MR. STRANG: By tissue, let's get a little more specific; skin?
JULIE CRAMER: Yes, the only -- the only thing I guess I want to say is, in a way you seem to cross over into live scent. You know, I'm sloughing skin off.
MR. STRANG: Right.
JULIE CRAMER: My cadaver dog isn't going to hit on that. There has to be a piece of a finger, a pool of blood. So, that's like with saliva, if somebody talks and spits saliva, my dog isn't going to hit on it. Now, if there was a large quantity of saliva that was allowed to sit long enough, I may or may not get a hit. I haven't actually tested that.
MR. STRANG: But -- But you might.
JULIE CRAMER: Correct.
MR. STRANG: Yeah. And it's a very good point. So there is a volume issue here?
JULIE CRAMER: Yeah. You can't just -- Live scent would be skin sloughing off. That would be something that a bloodhound would be much more interested in than a cadaver dog.
MR. STRANG: Or -- Or even if he we don't think of it as live, I mean, sloughed off skin cells aren't dead?
JULIE CRAMER: Plus, they stop. There's only a life span on that. If you would have -- That's why a tracking dog needs to be brought on scene, they like to say within 72 hours, because at some point that stops being an effective source for that dog.
But if there is an actual tooth, or a finger, or a pool of blood, that, then, is going to give off a source -- a scent that the dog will hit on.
MR. STRANG: And lasts much longer --
JULIE CRAMER: Yes.
MR. STRANG: -- conceivably?
JULIE CRAMER: Yes.
MR. STRANG: Right down to the example we started with, you know, the native American who died a thousand years ago?
JULIE CRAMER: Correct.
MR. STRANG: But the -- What I guess the point is, again, as you said, a tooth; it could be bone material; it could be skin, if in sufficient quantity; could be muscle tissue, correct?
JULIE CRAMER: That's correct.
MR. STRANG: The dog will alert to all of these things, regardless of whether the person who left it is alive or dead?
JULIE CRAMER: That's correct.
MR. STRANG: Did I understand you correctly -- and we're probably -- probably done with Exhibit 86 -- I don't know, let's find out if we need another photo. You -- You were shown on direct examination a photo that had a trailer down in sort of a diagonal opposite corner of this property?
JULIE CRAMER: Yes.
MR. STRANG: If we call that Steven Avery's trailer, is that something you recognize?
JULIE CRAMER: I worked in that trailer, yes.
MR. STRANG: And you know it -- you know it to have been the home of Steven Avery?
JULIE CRAMER: I do now.
MR. STRANG: Okay.
JULIE CRAMER: I did not at the time I searched it.
MR. STRANG: Fair enough. But you do now. Did you work Brutus through that entire trailer?
JULIE CRAMER: Yes. We entered in through the door and worked the interior.
MR. STRANG: From stem to stern?
JULIE CRAMER: As much as investigators asked me to search, yes.
MR. STRANG: Well, and was that from one end to the other?
JULIE CRAMER: Yes.
MR. STRANG: The one alert that you got was in the bathroom?
JULIE CRAMER: Yes.
MR. STRANG: The bathroom of a home is a place where one would not uncommonly find human bodily fluid?
JULIE CRAMER: That's true.
MR. STRANG: Traces of urine, for example.
JULIE CRAMER: Yes.
MR. STRANG: Not -- If there's a man living and using the bathroom, one would not uncommonly find traces of blood, at least if he's someone who shaves in the morning?
JULIE CRAMER: That's true.
MR. STRANG: So what the source, again, of the alert was, you are not able to say?
JULIE CRAMER: No.
MR. STRANG: Neither was Brutus?
JULIE CRAMER: No.
MR. STRANG: Did you work to the master bedroom, the bedroom at the far --
JULIE CRAMER: Yes.
MR. STRANG: -- upper left here?
JULIE CRAMER: Yes.
MR. STRANG: No alerts in the master bedroom?
JULIE CRAMER: No.
MR. STRANG: Did you have a chance to work Brutus in the -- inside the attached -- or the detached garage, that's about square in the middle of the portion of Exhibit 86 that we have on the screen?
JULIE CRAMER: No, we did not. We only worked as far as the tank where he was barking and then he skirted around to another area.
MR. STRANG: Meaning he ran up along to the east here, to the left?
JULIE CRAMER: Yes, he ended up proceeding behind the next building.
MR. STRANG: Where did he go?
JULIE CRAMER: There was an area of four burn barrels which he barked at.
MR. STRANG: Oh. This is what you now know to be the Janda trailer?
JULIE CRAMER: I don't know whose trailer that is.
MR. STRANG: But it was a blue trailer --
JULIE CRAMER: Yes.
MR. STRANG: -- just east of Mr. Avery's garage?
JULIE CRAMER: Yes.
MR. STRANG: And there were four burn barrels in the back?
JULIE CRAMER: Yes.
MR. STRANG: He alerted on those?
JULIE CRAMER: Yes.
MR. STRANG: Where did he go from there?
JULIE CRAMER: There was another dog barking. The weather at this point was very bad so they asked me to secure him. And we then returned to base.
MR. STRANG: And the other dog was over by this blue trailer?
JULIE CRAMER: Yes. And we exited the property off site of this picture. We came out to the road.
MR. STRANG: Were you actually handling dogs before 1989?
JULIE CRAMER: Not in the search and rescue capacity.
MR. STRANG: Understood, but were you working with trained dogs, guide dogs --
JULIE CRAMER: Yes.
MR. STRANG: -- or other human assistance dogs?
JULIE CRAMER: Yes.
MR. STRANG: Okay. Dogs have been a passion of yours for a long time?
JULIE CRAMER: Yes.
MR. STRANG: You have worked with hundreds of dogs?
JULIE CRAMER: Yes.
MR. STRANG: Maybe thousands?
JULIE CRAMER: Maybe.
MR. STRANG: Those have included all kinds of shepherds?
JULIE CRAMER: All breeds.
MR. STRANG: And specifically a range of shepherds, correct?
JULIE CRAMER: Specifically shepherds, yes.
MR. STRANG: Okay. A Belgian Shepherd here; you have worked with German Shepherds?
JULIE CRAMER: Yes.
MR. STRANG: And if someone asked you, do you think you could have approached and handled the dog behind Mr. Avery's garage?
JULIE CRAMER: I didn't have enough contact to know that. The weather really was a factor.
MR. STRANG: Sure.
JULIE CRAMER: And I -- I was concerned about my working partner at that time. The dog was sounding off, whether that was aggressive or not, we didn't really stop to make that determination.
MR. STRANG: Fair enough. So I guess the answer is maybe, maybe not?
JULIE CRAMER: We could not have worked that area without removing that dog from the site. I won't work my dog with somebody else's dog chained in the area. So we couldn't work the area, but I could make a determination on whether I could have handled that dog or not.
MR. STRANG: Okay. Have you met dogs you couldn't handle?
JULIE CRAMER: Oh, yeah.
MR. STRANG: Okay.
MR. STRANG: That's all I have. Thank you. Thank you, very much.
THE COURT: Mr. Kratz, any redirect?
MR. KRATZ: If I could have just a moment, Judge.
REDIRECT EXAMINATION BY ATTORNEY KRATZ:
MR. KRATZ: Mr. Strang asked about false positives and false negatives, have you had an experience, specifically with Brutus, where Brutus alerted, found a scent that was originally believed to have been a false positive that actually turned out to be an accurate reflection of some evidence?
JULIE CRAMER: We had two, both in 2005, that come to mind. In one case we were called to a drowning situation where it was believed a driver and his vehicle -- the driver had Alzheimer's -- had entered a canal in northern Illinois. Brutus gave a very definitive alert in an area that would have been logical where the vehicle could have been gone in. Divers looked without success for two days. We cleared scene.
I was very concerned about that as a false positive. Bothered me a lot in training. Some weeks went by and we received a call from the agency that as a barge had gone through taking corn in this canal, they had struck something and in finding out, it was the vehicle. It had obviously gone in with enough force it was silted into the river. They were able pull to the vehicle out and the driver was within the vehicle.
That was an example of what looked to be a false positive that was true. We also had an evidence kind of case, same kind of thing.
MR. KRATZ: Let me just -- My point is that Brutus has been found --
JULIE CRAMER: Yes.
MR. KRATZ: -- before, to be accurate, when even humans --
JULIE CRAMER: When we thought --
MR. KRATZ: -- couldn't find what --
JULIE CRAMER: -- he was wrong, yes.
MR. KRATZ: That's all I have of Ms Cramer, Judge.
MR. STRANG: I'm just taking one last look at the report. I probably will have no further questions, but if I could just have a moment or two.
THE COURT: Go ahead.
RECROSS-EXAMINATION BY ATTORNEY STRANG:
MR. STRANG: The area of the four burn barrels, Brutus actually alerted on two of the barrels?
MR. KRATZ: Objection, beyond the scope of redirect.
MR. STRANG: It is, I'm just getting a chance to look at the report. It is beyond the scope of redirect.
THE COURT: All right. How many questions are you looking to ask?
MR. STRANG: I think two.
MR. KRATZ: That's fine, Judge, he can.
THE COURT: Very well.
MR. STRANG: (By Attorney Strang)~ I have asked one already; he alerted on two of the barrels?
JULIE CRAMER: Yes.
MR. STRANG: And the alerts go with extreme animation and excitement?
JULIE CRAMER: Yes.
MR. STRANG: That's all I have. Thanks.
MR. KRATZ: Nothing further. Thank you.
THE COURT: Very well, the witness is excused.
JULIE CRAMER: Thank you.
MR. KRATZ: Can we approach, just briefly, Judge?
THE COURT: Sure.
(Side bar taken.)
THE COURT: Members of the jury, we're going to get started on the next witness, but if you want to stand up and stretch a bit now, you can, that's fine.
All right. At this time, Mr. Kratz, you may call your next witness.