Ramon C., RIF120947, Saved from the death penalty with a life verdict on September 15, 2010
This is the Article from when Addison won a capital murder case by saving his client from Death Row
This was a seven month's long trial, it was a battle to save Addison's client from Death Row from the
beginning to the end
Amazingly this is all the press the case got, capital murder trials were so common in Riverside County that they didn't get much press
- Charges: Murder (Penal Code § 187(a)) with a special circumstance of lying in wait (Penal Code § 190.2(a)(15)) with personal use of a firearm (Penal Code § 12022.53(d)).
- Exposure: Raymond was facing the death penalty.
- Outcome: The jury's verdict was life in prison without the possibility of parole (LWOPP). The jury verdict saved Raymond from Death Row.
A capital case jury trial that Addison did, and won, was the case of Ramon C. Defense attorneys consider any case where the client is facing the death penalty and is saved from Death Row an absolute win. The fight before the trial was to was to beat the gang special circumstance. Addison wrote and argued the Penal Code section 995 motion to eliminate the gang allegation. The trial judge denied the motion, however the appellate court agreed that Addison was correct and eliminated the gang special circumstance.
Raymond was accused of the execution style of killing a drug dealer, Juan S. Addison was lead counsel, which meant that he was responsible for all trial strategy decisions and guided the work of the other members of the defense team. His team did not just fight against the death sentence; they fought to win the case. The district attorney's case was the testimony of a methamphetamine user, Lisha L., who testified that Raymond shot and killed the drug dealer right in front of her. The defense was that Raymond did not know the drug dealer and, therefore, would not have been allowed in the house, was outside when the shooting occurred, and that it was, in fact, Lisha, the district attorney's snitch witness' ex-boyfriend, Erick E., who was the shooter. Addison presented forensic evidence that showed that Lisha's story could not have been true. The district attorney focused on Raymond's other accused violent crimes and his "eye witness." One of the highlights of the trial was when Lisha admitted that she was not only high on methamphetamine when the incident occurred, but was also high on meth when she testified in court. When she came to court to testify she had an active arrest warrant. The judge ordered her remanded into custody. Addison filed a motion to play Lisha's jail calls in front of the jury, as Raymond's jail calls had been played in front of the jury, so the jury could hear Lisha, in Addison's words, "In her natural habitat." Addison's motion was denied so the jury did not get to hear what Lisha was really like.
The jury found Raymond guilty of first-degree murder and found the special circumstance true. Addison and his team then went into the second phase, where they presented medical evidence and called witnesses from throughout Raymond's life. After a seven-month-long trial that was a battle at every step, the jury came back with a verdict, saving Raymond's life with a verdict of life in prison and rejecting the death penalty.
There were so many murder trials in Riverside at the time, including capital murder trials, that Raymond's case, over the seven months that it was in trial, did not get any press coverage. It wasn't until the verdict saving his life came in that there was a small article in the paper. That article is below.
This is one of the slides that Addison used in his closing argument
This is the verdict form from when Addison and his team saved Raymond from the Death Penalty
This is the Cebreros team, it's the fact phase investigator, the motions and appeals attorney, the paralegal,
Addison, Raymond and the Keenan Counsel Attorney
The story of Mr. 319
This is trial exhibit number 319 from Raymond's trial. He remains in Addison's office to this day. The exhibit was referred to throughout the trial as Mr. 319. He was presented by an expert witness that Addison had hired to explain the trajectory of the bullet and how the district attorney's snitch witness' testimony did not match the forensic evidence. While explaining the trajectory, the expert witness, Blaine Kern, used the Pythagorean theorem to explain where the gun would have to have been fired from at different distances to account for the trajectory of the bullet.
After the trial was over the clerk called Addison to tell him that he needed to go get Mr. 319 because they could not continue to store him. After taking pictures of him from all angles for the appellate record, Addison took Mr. 319 back to his office. He then called Blaine Kern and asked if Blaine wanted him back, to which he answered that he could no longer use Mr. 319 because he now had a hole in his chest with a dowel sticking out of it, not to mention that he had been written on when witnesses testified about him and of course also now had an exhibit tag on him. Addison offered to buy him from Blaine, but Blaine said that he didn't feel right charging Addison for him and offered to give Mr. 319 to him as a memento of the fight they had had together in court. However, Addison couldn't accept him as a gift because at the time he was a deputy public defender and couldn't accept gifts from clients or expert witnesses. Blaine then asked Addison if would store Mr. 319 indefinitely for him. Addison agreed to do that and Mr. 319 has been happily stored in Addison's office since 2010.
Mr. 319 is very spirted and enjoys being decorated for holidays and special events. He is below showing his Christmas spirit.
Mr. 319 has a sticker on his right chest. That sticker says, "Team Ramon Cebreros life verdict 09.15.10 a good to save a life." Addison's theme during his closing argument in the second part of the trial, the trial to determine if Raymond would get life in prison or the death penalty, was that, "Today is a good day to save a life." The jury clearly agreed with Addison, they came back with a life verdict.
This is the story of Mr. 319
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Sanchez Mass-Murder Suspect Nicolas Due Back in Court for Arraignment Tuesday | September 7, 2014 | Noozhawk | Giana Magnoli Law experts weigh in on costs to retry local gang leader | September 5, 2014 | Santa Maria Times | Rebecca Howes Paperwork Snafu Forces Judge to Postpone Hearing in Santa Maria Slaying Case | September 3, 2014 | Noozhawk | Janene Scully New Defense Attorney Assigned to Bank Robbery, Carjacking Case | August 27, 2014 | Santa Maria Times | Staff Reports Court Records Shed Light on Holzer Murders: Nicolas and Ex-Wife Juana Exchanged Accusations of Sexual Abuse Against Sons | August 21, 2014 | Santa Barbara Independent | Kelsey Brugger U-Haul murder case defendant granted reappointment of counsel | August 16, 2014 | Santa Maria Times | Rebecca Howes U-Haul murder case defendant granted reappointment of counsel | August 16, 2014 | Lompoc Record | Rebecca Howes Holzer Officially Charged with Murders, Appears in Court: DA Joyce Dudley Undecided on Whether to Pursue Death Penalty | August 14, 2014 | Santa Barbara Independent | Lyz Hoffman Quadruple Murder Suspect in Court | August 14, 2014 | YouTube | News Channel 3-12 Mass Murder Suspect Makes First Court Appearance in Fatal Stabbing of Family: Nicolas Holzer, accused of killing parents, sons at home near Goleta, does not enter a plea | August 13, 2014 | Noozhawk | Lara Cooper Isla Vista Man Accused of Rape Appears in Court | June 26, 2014 | Santa Barbara Independent | Kelsey Brugger Trial in Ibarra Murder-Torture Case Delayed Until November | March 18,2014 | Noozhawk | Gina Potthoff U-Haul murder trial delayed until November: Defendant granted right to represent himself | March 15, 2014 | Santa Maria Times | Rebecca Howes Judge: Godinez defense cold case 'dragging': Prosecutor says he's ready to proceed after many delays | February 14, 2014 | Santa Maria Times | Rebecca Howes Judge Denies Change of Venue in Ibarra Case: Superior Court Judge Rick Brown denied a motion to move the high-profile Anthony Ibarra murder case out of Santa Maria, and rejected three other defense motions Friday afternoon at Santa Barbara County Juvenile Court | February 8, 2014 | NBC News | Santa Maria Times Judge denies change of venue in Ibarra case: Solis, eight others charged in March U-Haul murder case | February 8, 2014 | Santa Maria Times | Rebecca Howes Change of venue denied in massive Ibarra murder case | February 7, 2014 | Santa Maria Times | Staff Report Judge Denies Request to Relocate Ibarra Murder Trial | February 7, 2014 | Noozhawk | Gina Potthoff Man Sentenced to Nine Years for DUI Injury Collision: Martin Maguire Struck Canadian Couple on Motorcycle Last May, Severing Their Legs | February 6, 2014 | Santa Barbara Independent | Kelsey Brugger Trial in Santa Maria cold case murder postponed for month: Godinez faces charge in '05 shooting death | January 14, 2014 | Santa Maria Times | April Charlton