"NARRATOR:" "In the criminal justice system the people are represented by two separate yet equally important groups, the police who investigate crime and the district attorneys who prosecute the offenders." "These are their stories." "RITTER:" "I already started writing." "So what happens if you stop?" "They fire you?" "You got it." "Oh, I'm sure." "So maybe you can tell me when it is okay to park here?" "Read the signs." "I've read them, I just can't understand them!" "Call the police!" "Call the police!" "Oh, my God, somebody call the police!" "Jogger tripped over the body around quarter to seven." "Hell of away to start the day." "Yeah." "What's left of the body, anyway." "Whoa." "What's that supposed to mean?" "You'll see." "Detectives, right over here." "Hey, the call that came in said there was one victim." "Species bias." "One woman, one dog." "Jack Russell, I think." "You think?" "Both mauled to death." "Mauled?" "You mean..." "Something cut her throat out and then did a number on her arms and legs." "ED:" "What thing?" "They're saying a dog." "Animal Control's sweeping the park now." "You mean, we got a wild animal on the loose?" "Unless you believe in werewolves." "How bad is it?" "Pretty bad." "Oh, man." "You got an ID?" "CSU found these over there." "House keys." "Any collar on the Jack Russell?" "If he had one, it's not there now." "How about an age on the lady?" "Thirty-ish." "Maybe." "She's got a rock on her third finger but there's no wedding band." "Short engagement." "Thorax ripped open, larynx crushed." "Then Cujo proceeded to rip her apart like a rag doll." "Both arms were severed, one of her legs." "Jane Doe and her four-legged companion were definitely done in by one very strong, very savage animal." "Your woman at the scene thought it might have been a werewolf." "Teeth marks are definitely canine." "What kind of dog are we talking about?" "Oh, hard to tell at this point." "There's too much tissue damage." "But if Animal Control catches the damn thing, we can do a dental impression." "Also, if there's still human flesh in its teeth, we can run the DNA, see if it matches the victim." "ED:" "God, what a way to go." "Getting mauled by a dog." "If it's any consolation, the victim had a hearty meal." "The lady, not the dog." "Blueberry muffin and coffee, just before the attack." "Thanks." "And no one reported a lost dog?" "Not that we know of." "Animal Control's still searching the park." "Maybe it was a stray." "Oh, I'd hate to think this was anything but an accident." "Someone sickin' a dog on another person like that." "In this town, you never know." "Well, what about the woman?" "There wasn't much left to work with." "And her prints aren't in the system." "The only thing left at the scene was her house keys." "Well, she was probably out for a run with her dog." "The M.E. says she had a meal." "Yeah." "Coffee and a muffin." "You don't eat before you work out, do you, Detective?" "I'm not going to even ask you." "Oh, you're saying she just finished her jog." "And was close to home." "Blonde in a jogging suit?" "Sure, I've seen somebody like that, try every two minutes or so." "Well, this woman was in the park between 6:30 and 7:00 this morning." "She had a little dog with her." "They all got little dogs and they're all nasty." "BRISCOE:" "Not much of a pet lover, huh?" "I was referring to the owners." "Well, she had shoulder-length hair, she was wearing a black jogging suit, dog was a Jack Russell." "There is a woman comes by most days with a dog like that." "Sundays, she picks up The Times." "You ever notice which direction she went?" "Towards Broadway, I think." "Thanks." "Bye-bye." "Sounds like Sandra." "Fifty-fifty low fat latte with a twist." "Cute little dog." "Sandra have a last name?" "(SIGHS) I guess so, but she wouldn't tell me." "Good lookin' chick, I hit on her, but she wasn't interested." "Said I was too young, be like dating one of her students." "Oh, she was a teacher?" "Yeah." "She'd come in sometimes, mark papers." "ED:" "You have any idea where she taught?" "Some private school." "Sometimes she came in, wore a baseball cap." "Had an "A" on it." "H ELLER:" "Sandra." "Miss Meekin." "She's been at Ashfield almost three years." "Then today she just didn't show up." "No call, no message, not like her at all." "Oh, we're very sorry to have had to tell you like this." "I never imagined." "(SIGHS) Sandra was a lovely young woman." "She taught English, coached our volleyball team." "BRISCOE:" "ls there a contact number?" "Rich." "Her fiancé." "Will somebody from the police be notifying him?" "Yeah, we'll take care of that." "(BELL RINGING)" "I left work as soon as I found out." "Came straight home." "I guess a part of me still expected her to be here." "Who dies this way?" "We're really very sorry." "You know, it was my turn to take Max to the dog run this morning." "Only I had an early meeting." "Maybe I could've fought back." "Our people say no one would have stood a chance against this dog." "What kind was it?" "BRISCOE:" "We're not sure yet." "Are you telling me that the dog that killed Sandy is still out there?" "Animal Control is combing the park as we speak." "You mentioned a dog run just before?" "Yeah." "In the park." "It's a few blocks from here." "Sandy would go for her jog, pick up some coffee and walk over and let Max play with the other dogs." "(DOGS BARKING)" "They don't have to be on leashes here, Officer." "Detective." "And, yeah, we know that." "Can we ask you a couple of questions?" "Sure." "About what?" "Do you recognize this woman?" "Oh, that's Sandy." "Of course." "And that's Max." "Why?" "I'm sorry to tell you," "Ms. Meekin was attacked by a dog not too far from here." "Oh, my God." "That was Sandy?" "Somebody spoke to the search crew this morning, but you're still looking?" "Do you know if Sandy had any problems with the other owners?" "Someone with a dog that could have done something like that?" "No." "I mean, everybody knows each other pretty well here, and the dogs are all familiar with one another." "There was this one person." "BRISCOE:" "Who's that?" "Ah, he comes by now and then with his Rottweiler." "She's fairly bossy with the smaller animals and some of the owners spoke to him about it, and I'm pretty sure Sandy was one of them." "Do you know his name or where he lives?" "No, I'm sorry." "But I know he recently got a ticket from the park police for not having his dog on a leash." "BRISCOE:" "Thanks." "Okay." "(KNOCKING on DOOR) (nos BARKING)" "Mr. Manos?" "Yeah." "What do you want?" "Would you chain up the dog, please?" "What's this about?" "Lock it up." "Lock it up!" "All right." "Wait one minute." "All right." "Hold on." "Nitro!" "In the room." "In the room." "Good dog." "(BARKING CONTINUES)" "You be quiet now." "Nitro?" "So?" "You in the park this morning with that dog, Mr. Manos?" "Why?" "Yes or no?" "Yes." "Did some of those people at the dog run complain about her again?" "The way we heard it, you have a pretty aggressive animal." "She minds me." "You know a woman named Sandy Meekin?" "No." "Who's that?" "Woman lived a few blocks from here." "Owned a Jack Russell." "Some people at the dog run thought you two had a dispute a few weeks ago." "(CELL PHONE RINGING) Excuse me." "(SOFTLY) Well, some of the dogs been bothering Nitro." "Well, she looks like she can take pretty good care of herself." "What's that supposed to mean?" "The woman this morning was brutally mauled by a dog." "Nitro's very sensitive." "Then you wouldn't mind Animal Control conducting a saliva test." "What for?" "Lennie." "There was another attack in the park." "They got the dog." "See, I told you it wasn't Nitro." "Cute name, though." "Everybody all right?" "It was just laying on some rocks there looking at us." "I just went over to make sure the dog was okay, and... and then it was like on top of me." "Eric pulled him off me somehow." "I don't know how I did it." "I never ran so fast before in my life." "Where's the dog?" "Crew's cornered it at a pedestrian tunnel." "(BARKING FIERCELY)" "MAN 1:" "We've just gotta hit it." "MAN 2:" "All right." "Hey, why don't you tranquilize it?" "We did." "That's when my officer got bit." "We'll shoot the damn thing if we have to." "Hey, you're Animal Control." "Control it." "(SNARLING)" "Come on now." "Come on over here." "Get it." "Come on." "(BARKING CONTINUES)" "Okay." "Now!" "(SNARLING)" "Easy boy, easy." "That's a good boy." "Okay." "ED:" "I think he likes you, Lennie." "On second thought..." "Hey, check it out, he's got a collar." "I'll take your word for it, man." "No tag." "But he's definitely not a stray." "(BARKING)" "Rodgers says the bite marks match up." "Which means this dog is our killer." "And we're sure it's not a stray?" "ED:" "Dog has a collar." "What are we doing to find the owner?" "We got uni's canvassing the neighborhood with the dog's picture." "Animal Control says he's a well-nourished, groomed, wormed, 20 month old male." "Has all his shots." "Someone loves this monster." "Not quite." "The report says the dog's been tortured, probably some time ago." "The fur's grown over his scars." "Lieutenant, looks like we might have caught a break." "Uniforms find a witness?" "Wonderful world of technology." "A microchip implanted in the ear?" "Think of it as a doggie LoJack." "Not unusual with purebreds." "Actually, these babies can start at four grand." "I've had new cars that cost less." "So, how do we retrieve the information?" "Scanner." "And that's gonna tell you who the owner is?" "Just hit "last entry"." "I already ran it." "Ah, Glen Malloran." "ID number for the dog." "Phone number for Glen." "Montauk." "Mr. Malloran's listed in the breeder's guide licensed by the American Kennel Association." "No violations, no complaints." "Until now." "MALLORAN:" "Can't be one of mine." "It's your microchip, it's your dog." "What's the chip number?" "(DOGS BARKING) If it's the one I'm thinking of," "I can't believe he'd be involved in an unprovoked attack." "He was really good-natured, sweet." "Hey, I'm sure you know your animals, but this dog practically decapitated a woman and almost took another girl's arm off." "I bred that dog's sire and bitch back five generations." "There wasn't a mean one in the line." "ED:" "So do you think Pit Bulls are born mean?" "Naturally, when the genetic traits for strength and tenacity have been enhanced, there's a heightened physical response, an aggressive nature not found in other breeds, but that can be controlled." "With the right trainer." "So you're saying that once they're weaned, it's all up to the owner?" "More or less." "Dogs don't kill people, people kill people." "People with dogs like that." "Hey, any animal can be turned into a killer, canine or human." "Your line of work, you probably know that." "So who did you sell the dog to?" "A company called Pound Partners over in Brooklyn." "BRISCOE:" "And how was the dog shipped?" "Some guy used to drive out here in a blue pick-up." "You mean, he drove out here more than once?" "And if you don't mind my asking, what happened to the other dogs?" "What other dogs?" "This company bought five more from me just last year." "Two Pits, two Dobies, and a German Shepherd." "Guard dogs, they said." "(DOOR SLAMS OPEN) ED:" "Police!" "We have a warrant for the premises." "On the plus side, I don't hear any barking." "Maybe they were trained not to bark." "Well, that's a cheerful thought." "Hit it." "Damn!" "It's like an SM club for canines." "These bastards were training 'em to fight." "Oh!" "This is Donald Keller He drives for this beverage distributor." "He's here every night." "He was just telling me that he hasn't seen anybody in the last couple of days." "I'll tell you the truth I ain't really sad to know they're gone." "You have a problem?" "I'd come home from a shift, those damn dogs howling and barking all night long." "ED:" "Why didn't you ever call anybody?" "You seen those dogs?" "(SCOFFS)" "I ain't gettin' involved, especially with those characters traipsing in and out." "What kind of characters?" "Oh!" "They'd come in all kinds of cars, music blaring." "Get out with dogs wearing masks, you know, like, Hannibal Lecter." "We were told it was a company that sold guard dogs." "I don't know nothin' about that." "Hey, did you ever see a guy driving a blue pick-up truck?" "Uh, yeah." "White guy." "Maybe 30, 35." "You didn't happen to get a plate number?" "No." "But it was a Chevy." "Chevy Sierra." "All right, man, thanks." "Hey, listen, if you see that dude again, would you please give us a call?" "All right." "Gives a whole new meaning to the term "doggie bags."" "Seven dogs." "All dead from a drug overdose." "Somebody got scared." "What was going on there?" "From what we saw, they were fightin' those dogs." "And they close up shop right after Sandra Meekin's death." "Yeah." "It's gotta be more than just a coincidence." "Well, who owns the building?" "Well, believe it or not, the city." "The place has been in foreclosure for almost three years." "The original owner's in Florida." "He says that he lost the place in a tax proceeding." "He didn't know anything about the Pound Partners company or the dogs." "And we ran the corporate name through Albany." "The paper trail ends up at a P.O. Box in Schenectady." "Well, please tell me we have at least a lead on the owner." "Well, just on the two guys who supposedly ran the operation." "And the cars they drove." "A red sports car and a blue Chevy pick-up." "Well, they kept these dogs so they had to feed 'em." "So let's canvass the local markets." "Maybe someone can make an ID." "Mid-thirties." "Receding hairline." "Yeah." "Guy comes in every couple of weeks, buys a ton of ground beef." "Sometimes I put some bones aside for him." "Do you ever get a name?" "No, I mean, I know his face, but just enough to say hello." "Actually, one of these kids may know him." "He usually helped him carry the stuff out." "Hey, what's the name of the guy comes in here and buys all that meat for those dogs?" "I think Bill." "He drive a blue truck?" "Yeah." "That's him." "ED:" "Hey, you ever get a last name or some reference to where he lives?" "No." "But he comes out with a pharmacy bag sometimes." "Pharmacy's in the back?" "Yeah." "I got it." "He's got one of those silver bracelets," "I think for like diabetes or something." "Thanks." "That's him." "Hey, Bill." "Sorry, do I know you?" "We're gonna get real well acquainted from here on in." "Put your hands on the truck." "READE:" "What do you guys want from me?" "Lennie, check this out." "READE:" "Hey, what's goin' on here?" "What did I do?" "Looks like dried blood." "All I did was take care of the dogs." "You got a funny way of taking care of 'em." "You wanna consider revising your previous statement?" "We have a witness who ID'd you from the kennel as the guy who bought the dogs." "And at the supermarket, where you bought the food." "Look, I just worked there, ran errands and such." "BRISCOE:" "So, I suppose those bloodstains we found were from you delivering T-bone steaks?" "ED:" "You do realize you're on the hook for a manslaughter charge, don't you?" "What are you talking about?" "One of your dogs attacked a woman in a park." "She was killed." "I'm telling you, those dogs aren't mine." "I just look after them." "ED:" "Then whose were they?" "(SIGHS)" "Now's not the time to get shy, Bill." "You know, you've got about 30 seconds before we write this up as a homicide." "Guy's name is Leon." "But I don't think that's his real name." "But he's the owner." "He's the one who pays me." "BRISCOE:" "Where does he live?" "No clue." "Someone's gonna feel this woman's pain." "You sure you want that person to be you, Mr. Reade?" "Look, a couple of times Leon had me take some of the dogs to a vet." "The guy there knows him pretty well." "Write down the address." "(SIGHS)" "Now we'll see how you feel livin' in a cage." "Leon brought his dogs here for their shots, that's all." "We were led to believe that Leon wasn't his real name." "That's the only name I knew." "How did he pay you?" "Cash." "What'd you do for him?" "I took care of some of his dogs." "Did you keep a medical record of that?" "(CHUCKLING) Oh, I'm not sure." "He's not sure." "I think I read somewhere you're supposed to do that." "What kind of drug do you use to put a dog down?" "Sodium Phenobarbital." "Ah, that's the drug that killed those dogs over at Leon's place." "I wouldn't know anything about that either." "And what about dog fighting, what do you know about that?" "ED:" "You know, they put two dogs in a pit, and they fight each other till one of them dies." "Yeah." "I hear it attracts a real low-class clientèle." "I also heard that they place wagers on the outcome." "I mean, without a friendly wager, it's just two dogs ripping each other apart, right?" "You realize you could get your license revoked if people knew you were working dogfights." "ED:" "Especially if you supplied drugs and didn't keep any medical records." "You know how to do anything else besides veterinary work, Doc?" "What happens if I tell you what I know?" "Well, we report to the D.A." "how you showed a true spirit of cooperation." "Then maybe we don't take you to jail tonight." "And my license?" "(CHUCKLES) Don't get greedy, Doc." "He was training the dogs to fight." "I'd patch them up as best as I could." "A few days ago, he asked me for the Sodium Phenobarbital." "ED:" "Leon did?" "His real name is Ralph Carson." "He's on parole, I think." "(SIGHS) And you risked your license for this guy?" "I gamble." "I got behind." "Ma'am, do you know the man that owns that car?" "I know him enough not to know him!" "Is he home?" "Came in about an hour ago." "Do you know if he has any dogs in there with him?" "I haven't heard 'em in a few days." "First time in a year." "(SCOFFS) It's about time you people showed up." "The way he treats them animals." "What type of dogs are we talking about?" "Mean ones." "Ralph Carson." "Police." "CARSON:" "Give me a minute!" "Carson, open the door!" "Come on!" "Open it now." "What?" "Where's he goin'?" "BRISCOE:" "We have a warrant to search the premises." "For what?" "Well, this would be a good start." "The house is full of drugs and syringes." "Oh, this is not good, Ralph." "I want a lawyer." "Hey!" "What's down there?" "Huh?" "Put your hands behind your back." "For what?" "You're under arrest?" "For being a sick bastard." "Now shut your mouth before I put one of these on you." "You have the right to remain silent." "Anything you do say can and will be used against you in a court of law." "You have the right to an attorney..." "CARSON:" "I don't know what dogs you're talking about." "This dog!" "Never seen it before." "You know what this dog did?" "It ripped the throat out of a young school teacher." "We know about Pound Partners." "We know where you fought the dogs." "We know where you kept them." "Under the law, that makes you the owner." "You know what that means?" "That means you're looking at a manslaughter charge." "Oh, manslaughter?" "You can't put that on me!" "BRISCOE: (SCOFFS) Just watch us." "We're gonna tack 10, 15 years onto your parole violation, Ralph." "The only way you can help yourself is to tell us who had the dog." "Otherwise, it's you." "I just ran the fights, sold some dogs, that's all." "For who?" "Hey man, the D.A.'s right behind that window." "You show her how remorseful you are for what this dog did, she might cut you some slack." "Who had the dog?" "You talk to this guy, you don't let on you heard from me." "Who?" "His name's Danny Miller." "The whole damn dog business is his idea." "He's the one who told me to shut the place down." "You know, after the lady got killed." "He'll know who had the dog." "Where is this Danny Miller?" "Attica?" "According to Carson, Miller runs the whole show from a prison cell." "Apparently, selling attack dogs to ex-cons for dog fights is a pretty good business." "What's Miller in for?" "Multiple homicides." "And Carson claims Miller knows who had the dog that attacked this woman in the park?" "That's his story." "How did Miller set all this up?" "Believe it or not, he used the prison law library." "I pulled all the corporate files for this Pound Partners from Albany." "They're actually well-prepared." "Probably not what the Supreme Court had in mind when they gave prisoners access." "A post office box in Schenectady, New York." "Since Miller couldn't pick up the mail," "I faxed over Carson and Reade's arrest photographs." "No one at the post office recalls ever seeing them." "So who was the messenger?" "Let's get Miller down to Rikers for an interview." "What about Carson?" "Wait on the manslaughter charge." "Hold him on a parole violation." "Okay." "I'm doing 25-to-life, twice." "What're you gonna do, take away my cigarettes for being a dog lover?" "JACK:" "We have telephone records showing that you placed a collect call to Ralph Carson's home one day after Sandra Meekin was attacked in Riverside Park." "Who?" "She was killed by a dog purchased from your company, Mr. Miller." "Hey, Ralph's a friend of mine." "I wanted to say hello." "We think you were giving him orders to shut down your business." "Which means you already knew about the dog attack." "I don't know what you're talking about." "You don't get newspapers in maximum security, Mr. Miller." "Or the 6:00 news." "Somebody told you about what happened." "Probably the person who had the dog." "I got nothin' to say about any of this." "It's that kind of thinking that got you two life sentences, Mr. Miller." "Like I said." "I guess we're gonna find out what it gets you this time." "What now?" "He won't talk to us here." "We find out who he did talk to at his base of operations." "Attica?" "You don't have to go, you just have to call." "Well, could you check your records for a Ralph Carson." "You're sure?" "Okay, thank you." "Danny Miller's been confined to a maximum security cell block for almost four years." "That's 2317 in a cell." "Plus he has no friends or family and his last visit was more than two years ago." "So how does he run a dog business from inside a prison cell without anyone's help?" "He has a lawyer." "She's up there almost once a week." "A lawyer?" "Sherri Quinn." "She's handling his appeal." "And who's this Roger Quinn?" "Her husband." "Another lawyer?" "A C.P.A." "They both visited Miller the day after the dog attack." "SERENA:" "Why did you visit Mr. Miller so often?" "I'm not sure our relationship with Danny Miller is any of your business." "Presumably, you've both heard of attorney-client privilege." "Well, Mr. Quinn is not an attorney." "Roger is employed by me on behalf of Mr. Miller." "His efforts are attorney work-product, hence privileged." "You represent Miller on a homicide appeal." "How does a C.P.A. fit into that?" "I don't think it would be appropriate for me to comment on that." "Well, in any event, we're investigating new criminal charges." "What new criminal charges?" "Your client was involved in a dog breeding business." "What does that have to do with us?" "According to prison reports, you're the only visitors he's had in years." "SERENA:" "There is no way he could've run this business from prison without your help." "Mr. Miller's corporation had a post office box in Schenectady." "You own a house in Schenectady." "It's possible we assisted Danny in certain business ventures." "But I can assure you, we broke no laws." "Pit Bulls, Dobermans, Rottweilers." "Your client was training fight dogs." "Dogs being taught to kill." "One of them mauled a woman to death while she was jogging in a public park." "Why are you telling us this?" "Because you visited him in prison the day after the attack." "We visit Danny a lot." "JACK:" "So we noticed." "According to your phone records, after every visit you placed a call to Ralph Carson." "You pulled my office phone records?" "Most of those calls were to clients." "ROGER:" "This man, Carson, he gave us breeding lines and pictures of the dogs, we passed those along to Danny." "And that is all we did." "Sandra Meekin had her throat ripped out by a dog trained to do exactly that." "If either of you assisted Miller in the sale of this dog without disclosing the danger..." "I don't think we have anything more to say on the subject." "So we still can't place this dog with its owner?" "Carson claims he has no sales records." "The Dog Man of Attica isn't talking." "So, who are the Quinns protecting?" "Not Miller." "The man's already serving two consecutive life terms." "What happens when we do put this dog with someone, Jack?" "We look long and hard at a homicide charge." "(EXHALES) That's a tough charge to make with what we've got." "This is no ordinary dog." "This is a 70-pound Pit Bull trained to fight." "There are hundreds of them in the city." "In some neighborhoods, they're a status symbol." "Someone's twisted idea of machismo." "(KNOCKING ON DOOR) I just ran the Quinns through the computer." "Turns out Danny Miller is not the only convicted murderer" "Sherri Quinn represented." "Warren Shane?" "Guy's on parole." "Seems to have taken issue with the quality of Ms. Quinn's work at his murder trial." "She took out a restraining order against him three months ago for making death threats." "So you think the Quinn's themselves could have had the dog?" "Shane's threat would explain their being in the market for this kind of dog." "And they live on the Upper West Side, just a few blocks away from where Sandra Meekin was attacked." "They also set up Miller's business." "Let's get a warrant." "This is an outrageous intrusion of our privacy." "Come on, Counselor." "You've read a search warrant before." "Why don't you and your husband just stand back and let us do our jobs." "What are you looking for?" "Evidence that you were in possession of a dog." "There's no dog here." "Yeah, well, your neighbors seem to think you had one a little while ago." "They're saying it was a Pit Bull." "No dog bowls, no dog food." "There." "Now, Detectives, if there's nothing else," "I'm afraid I'm going to ask you to leave." "Hey, Lennie!" "Check this out." "Same thing over here on the couch." "What did this then?" "(SIGHS) Sherri Quinn, Roger Quinn." "You're both under arrest for the murder of Sandra Meekin." "You can't!" "It was a stray." "It ran away." "ED:" "You took in a stray Pit Bull?" "I am telling you, it was not our fault!" "You're howlin' at the moon, Counselor." ""Docket Number 3699, People v. Sherri and Roger Quinn."" "Manslaughter in the Second Degree, one count each." "This is nothing more than a tragic accident." "The People give notice of our intention to present this tragic accident to a Grand Jury." "Well, if you ever really do present your case, defense hereby serves cross grand jury notice." "Both my clients intend to testify." "JUDGE PATE:" "I'll hear the People on bail." "SERENA:" "The defendants are accused of recklessly causing the death of Sandra Meekin." "Complaint's a little fuzzy on the how, Your Honor." "SERENA:" "The Quinns knowingly possessed an extremely dangerous Pit Bull, Your Honor, which they recklessly exposed to the public resulting in a woman's death." "The People have no way to prove this is the same animal unless we're talking about conducting some sort of doggie line-up here." "Tell me we're not talking about that, Miss Southerlyn." "SERENA:" "DNA samples taken from the defendants' home, as well as dental impressions cast from their furniture indicate it's the same dog, Your Honor." "BEHRENS:" "They still have no eye-witnesses, Your Honor." "No way to prove the actual circumstances of the attack." "The circumstances are that this victim was literally torn limb from limb by their dog." "We have no idea what caused this attack." "Whether this woman did something, whether it was her own dog that provoked it." "Her scent, her perfume..." "Your Honor..." "Save it for trial, Mr. Behrens." "Meantime, the defendants are released on their own recognizance." "Judge, the defendants are facing substantial jail time." "If they're convicted." "Which is a big if, Miss Southerlyn." "(GAVEL BANGS)" "Their lawyer actually stood there and tried to blame Sandra Meekin's perfume for the attack." "And just how do we prove that's not what happened?" "JACK:" "It doesn't matter." "What, did the Court of Appeals change the burden of proof, while I wasn't watching?" "The Quinns' commission of the crime was complete with their possession of the dog." "A strict liability standard." "I like that." "JACK:" "We show the jury the attack was the reasonably foreseeable consequence of merely having the dog." "It's the same standard we apply to a loaded firearm everyday." "(PHONE RINGING)" "A.D.A. Southerlyn." "We're equating dogs and firearms?" "You know, that's a tough sell if the jury has so much as one dog lover on it." "Not any dog, Nora." "This dog." "You're kidding." "It killed Sandra Meekin, it attacked that other girl." "Where's it now?" "SERENA:" "This is impossible." "Being held as evidence." "SERENA:" "When?" "Okay." "I'll let him know." "The Quinns just filed a motion to dismiss." "Their lawyer is claiming the Quinns never knew how dangerous the dog was." "No one's disputing the tragic nature of the attack." "Tragic nature." "And no one's going to lay the blame on my clients, either." "These defendants possessed a lethal weapon in the form of an animal, took it to the park, lost control of it." "Which is only relevant if my clients knew the animal was lethal." "The dog was tortured, bred to fight by their client." "They had no idea about any of that." "As far as they knew, Danny Miller was running a legitimate business." "Judge, anybody who has a dog like that has to know how dangerous it is." "BEHRENS:" "And I have a dozen witnesses who'll testify that Pit Bulls make wonderful house pets." "And we'll have ones who'll testify that owning a Pit Bull, especially one who's been trained to fight, is the equivalent of owning a loaded firearm." "And therein lies the problem." "I'm not going to have this trial become a battle of experts." "Not as to the knowledge of the defendants." "Either the People can prove that the defendants were aware of the danger this dog represented." "Or they walk and go back to representing the Danny Millers of the world." "Careful, Miss Southerlyn." "(DOOR BUZZING)" "Have a seat, Mr. Miller." "I told you." "I got nothing to say." "You remember I said I'd let you know what your lack of cooperation was going to mean to you?" "What?" "Are you cutting off my movie privileges?" "I intend to charge you with Murder in the First Degree, Mr. Miller." "How're you gonna do that when you can't even make out manslaughter against the Quinns?" "Their crime was reckless, yours was intentional." "We brought along the penal law, so you can follow along." "You owned the dog, Mr. Miller." "You controlled its training and then you placed it without any warning to the new owners about the dangers it represented." "This is a bluff." "Is it?" "We think once a jury sees these photos, they won't be so picky about our theory." "Maybe you want to run this by Sherri Quinn?" "Of course, you can only have so much confidence in her legal abilities given your present circumstances." "Okay, murder two maybe." "But there's no way you get murder one." "When your crime was committed, you were serving a life term, Mr. Miller." "That elevates it to murder one." "That's only if I killed somebody on the inside." "Actually, that's not how the statute reads." "So, the real question is whether a jury thinks life without parole is enough punishment, given you're serving two life terms already." "We don't think they will." "JACK:" "Sherri Quinn that good a lawyer you'd risk your life for her, Mr. Miller?" "He threatened him with a lethal injection, Your Honor." "I merely pointed out the consequences if Mr. Miller refused to cooperate." "It's still coercion." "SCHOLL:" "It's pretty close to the line, Mr. McCoy." "But not over it, Your Honor." "The law prohibits me from forcing a plea by threatening the death penalty." "I never even offered him one." "But you're not prosecuting him." "It seems to me if you believe that Mr. Miller's testimony's coerced, you're free to try and demonstrate that in cross-examination, Counselor." "But if he's willing to testify that these defendants were aware of this dog's propensity for violence, your clients are going to trial." "JACK:" "Would you tell the jury your qualifications, Dr. Collin?" "I hold a degree in veterinary medicine from Cornell University." "Did you have an opportunity to examine and observe the Pit Bull that attacked Sandra Meekin?" "Yes." "The dog is an American Pit Bull." "Twenty months of age." "Approximately 70 pounds." "Overall, in excellent health." "Extremely assertive, aggressive." "JACK:" "How did you determine that?" "The dog shows an almost uncontrollable urge to dominate." "For example, when placed in a room with other dogs, no matter how big or how many, he can't resist an urge to bully them." "Is that typical of the breed?" "Pits have a propensity toward aggression." "It's only natural, they were originally bred to fight bulls." "In my opinion, that propensity in this dog was heightened to an extraordinary degree by its training and brutal treatment." "In your opinion, Dr. Collin, is this a safe animal to be around?" "No." "Now, Dr. Collin, would you give us some idea of the strength, of the physical capacities of this dog." "Pits of his size and age have been known to pull a 4,000 pound sled over 20 yards." "The average Pit can generate a bite-strength of about 2,000 pounds per square inch." "In lay terms?" "He can crush a human skull easily." "By contrast, the African Plains leopard, which feeds primarily on gazelle, produces 700 pounds per square inch." "Doctor, I show you People's Exhibit 12." "A through H, photos of the crime scene." "BEHRENS:" "Continuing objection, Your Honor." "Inflammatory." "Overruled." "JACK:" "Would you describe for the jury how those wounds were inflicted?" "The lacerations to the face and shoulders are typical of canine claw marks." "The deeper wounds, here and here, to the neck and throat, those are the product of bicuspids, molars." "In other words?" "In reconstructing the attack," "I believe the animal drove his victim to the ground by applying his body weight to the woman's torso." "Knocked her off her feet." "The dog then grabbed her by the throat, at first tearing away part of the upper thorax and esophagus, then holding and crushing the larynx." "JACK:" "The Medical Examiner has already testified that death from these wounds was inevitable, but not immediate." "That would be consistent with the attack style of the Pit, Mr. McCoy." "They disable, first, then hold on until death ensues." "In most cases, the victim would either bleed to death or suffocate on her own blood." "Nothing further." "How did you come to your conclusions concerning this dog, Doctor?" "COLLIN:" "Clinical physical examination, followed by several hours of observation." "You prodded and poked in other words, and then sat with the dog and watched it?" "Yes." "Did he bite you?" "I was very careful." "Did he try to bite you?" "As I said, I was careful." "Did he fall asleep while you were observing him?" "Yes." "At your feet, in fact, curled up?" "Yes, Counselor." "Isn't it fair to say, that when unprovoked, he can be a good dog?" "He has his moments." "But then, a gun is only dangerous when it goes off." "Move to strike, unresponsive." "The jury will disregard that last remark from the witness." "We had King about five weeks." "BEHRENS:" "You're referring to the Pit Bull we've heard testimony about?" "Yes." "In those five weeks, did the dog ever bite you?" "No." "Menace you in any way?" "No." "Your husband?" "No." "No he was gentle with us." "You just had to be slow and steady with him." "What happened in the park?" "We had him on the leash." "When we got to a footpath, we heard this dog barking." "What dog?" "A terrier." "It was running at us." "A lady in a jogging suit came running after it." "And then?" "King began to growl." "His hair was standing up on end." "He was afraid." "A 70 pound Pit Bull afraid of a little terrier?" "He was afraid for us, Mr. Behrens." "Roger and me." "Roger tried to grab the leash, to help me hold him." "But it broke." "And King went for the terrier." "That's when this woman tried to protect her dog." "What were you and your husband doing?" "Roger tried to stop it." "And?" "King had the terrier in its mouth." "It was dead already, I think." "But the lady kept on trying to get it away from him." "That's when King went for her." "It was so fast." "Then there was blood everywhere." "I am so sorry." "Nothing further." "Sorry, but not sorry enough to call 911." "She was already dead." "And the dog?" "I don't know." "It ran away." "And neither you nor your husband let anyone know about that either." "BEHRENS:" "Objection, Your Honor." "SCHOLL:" "Overruled." "We were in a state of shock." "JACK:" "Were you still in shock when you denied owning the dog?" "We were scared." "But not too scared to drive up and see Danny Miller in prison." "Not too scared, according to his testimony, to tell him about the attack and make him put down the rest of his dogs." "You didn't tell Mr. Miller to put down his dogs to eliminate potential evidence?" "Once we saw what King had done, we realized that Danny had lied to us about the type of dogs he was training." "So it's your testimony that you didn't realize how dangerous this dog was prior to that?" "We got the dog for protection, because of how he looked, but he was a good animal." "No." "Until that day I had no idea." "Because the dog had always been gentle with you?" "That's right." "(DOG SNARLING)" "(BARKING)" "(PEOPLE MURMURING)" "(GAVEL BANGING)" "Your Honor." "Mr. McCoy?" "Defendants claim the dog is gentle, Your Honor." "The jury has a right to decide for itself." "Bring the dog into the well." "JACK:" "Care to pet your dog, Mrs. Quinn?" "BEHRENS:" "Objection." "How about you, Mr. Quinn?" "Shall we take the muzzle off so you can pet your dog?" "(BARKING)" "BEHRENS:" "I move for an immediate mistrial, Your Honor." "SCHOLL:" "That's enough." "Show is over." "Mr. Quinn, take your seat." "You too, Mr. Behrens." "Mr. McCoy, remove that dog right now." "(SNARLING)" "I'll see everyone in my chambers." "What kind of a stunt was that, McCoy?" "Judge, the central issue is whether this dog was a lethal weapon waiting to go off or just a house pet provoked into defending its owners." "You must have done something to him." "You mean something other than torturing him?" "BEHRENS:" "Your Honor..." "I'm not declaring a mistrial, Mr. Behrens." "Your clients opened the door." "They've spent most of their time trying to convince the jury the victim caused her own death." "My own conclusion is that defense has been exposed, to say the least." "Make them an offer." "Man two." "They'll serve three-to-nine years." "BEHRENS:" "No." "Absolutely not." "We don't deserve that." "Don't force me to reconsider my decision on the mistrial, Mr. McCoy." "Two-to-six." "If the defendants reject that, the People will just have to live with the court's ruling." "SCHOLL:" "Mr. Behrens?" "Prison?" "You expect us to go to prison?" "My clients aren't interested in any jail time, Your Honor." "No, I'm sure they're not." "However, that's not up to them anymore, is it?" "I just got off with Animal Control." "The dog was put down." "Quinns' trial was the only thing keeping it alive." "Abused, tortured and now destroyed." "Almost makes you wish you could reverse the sentences."