STATE OF ARKANSAS

V. LANE HILL Mock Trial

 2025 Arkansas High School Mock Trial Competition
State of Arkansas v. Lane Hill

The Arkansas Bar Association Mock Trial Committee welcomes your participation in our
2025 competition. In this year’s case, the defendant, Lane Hill, has been charged with
murdering business partner, Zoe Caine. Zoe Caine apparently had a gambling problem and
had been unlucky for some period of time. Thinking her luck would change, Zoe borrowed
money frequently from a local loan shark, Lou Carboni. However, Zoe’s luck didn’t change
and, under pressure for payment from Lou, Zoe started stealing money from the business.
However, with skyrocketing interest and continued gambling losses, Zoe’s debt to the loan
shark was still over $200,000, even after she had drained the business dry. Carboni had
already given Zoe several physically violent “messages” indicating the debt was to be paid –
“or else.” In the meantime, Lane hired an accountant to determine why the business was in
the red. When Lane learned Zoe had been stealing from the business and had driven it to the
point of bankruptcy, Lane allegedly became enraged and threated to kill Zoe. A few days later,
Zoe was found dead. Through a Buy-Sell Agreement and insurance policy, Lane would
become a half million dollars richer. Who murdered Zoe?

We are pleased again to partner with the U.S. District Court for the Eastern District of
Arkansas to host at the U.S. Federal Courthouse in Little Lock on February 28-March 1, 2025.
All teams (unless there is a bye) will compete in four rounds of competition, and the top two
teams will meet at the State Championship. The state champion will represent Arkansas at
the National High School Mock Trial Championship, to be held in Phoenix, Arizona, on May
8-10, 2024.

Students – You will experience what it is like to prepare for and present a case before a judge
and jury. Working with your teams and coaches, you will learn to evaluate information and
respond quickly. As you prepare, you will sharpen your public speaking and presentation
skills. The greatest benefit is the opportunity to learn how the legal system works. By studying
and understanding courtroom procedure, you should become more comfortable with the
legal system. Your interaction with Arkansas’s finest attorneys and judges will give you a
glimpse of the different interpretations of trial procedure and different approaches of
individual members in the legal arena.

Teacher Coach, Attorney Coach, or Judge – We strongly encourage you to focus on the goal
of participation, rather than stressing competition, while preparing your students. Your
contributions of time and talent are making experiential educational opportunities available
to Arkansas students. Your participation is an essential key element to the success of the
program. Be proud of the impact you have made on the lives of these students.

Case Introduction 1 Version 1.2

The Mock Trial Committee would like to acknowledge:

• The Oregon Classroom Law Project, the authors of the original case, and the South
Carolina Bar Law Related Education Committee and Mock Trial Subcommittee, who
gave us permission to adapt their case for the 2025 Arkansas High School Mock Trial
Competition;
• The Mock Trial Case Selection Subcommittee (Robert Coleman, Brooke Gasaway,
and Adam Jackson); and
• The teachers, judges, and attorneys who volunteer their time to prepare students for
competition.

This case is a work of fiction. The names, characters, businesses, organizations, places,
events, and incidents herein are the product of the authors’ imaginations. This case is meant
to provide an opportunity for students to explore legal issues and is not meant to provide
commentary on any of the issues raised in the case.

Version History

1.0 - Original version of the case released October 21, 2025. Pursuant to Rule 7.3 of the Rules
of Competition, questions regarding the case will be answered and published in future
updates. All questions about the case should be sent Michele Glasgow, Mock Trial
Coordinator, at [email protected].

1.1 – Released December 12, 2024, in response to errors found in Version 1.0. (See Case
Q&A on next page.)

1.2 – Released January 7, 2025, in response to error found in Version 1.1 (See Case Q&A on
next page.)

Case Introduction 2 Version 1.2

Case Q&A:

Q: As I’ve been reading the case for this year, I think I've noticed a couple of typos (written
below). The dates on which some of these incidents took place switches between 2024 and
2018, which, as you can imagine, could change how my team approaches the case majorly.

Page 3; Criminal Information: “on or about March 24, 2018”

Page 23; Dee Haiden's Affidavit; Line 33: “On the morning of March 26, 2018,”

If these are not typos and I am mistaken, please let me know and I will adjust accordingly.

Response: Yes, these are typos. The case has been updated and republished.

Q: Our team has been reading through the case and has noticed an inconsistency in an
exhibit. In exhibit 5, the Buy-Sell Agreement made by Lane Hill and Zoe Caine says that the
agreement was made on June 14th, 2021. However, at the bottom of the Buy-Sell agreement,
the signatures are dated June 14, 2024. Considering that Zoe Caine died in March of 2024,
we believe this might be a typo as there would be no way for Caine to sign this after her death.
Thank you for your time.

Response: The signatures are incorrect and should reflect the date that the agreement was
made, June 14, 2021. The case has been updated and republished to so reflect.

Case Introduction 3 Version 1.2

 IN THE CIRCUIT COURT OF NATURAL COUNTY, ARKANSAS
CRIMINAL DIVISION

STATE OF ARKANSAS

v. CASE NO. ARMT2025

LANE HILL

CRIMINAL INFORMATION

I, Prosecuting Attorney, 25th Judicial District, in the name, by the authority of, and on

behalf of the State of Arkansas, Natural County, charge the Defendant, LANE HILL, with the

crime of violating Arkansas Code Annotated § 5-10-101, Capital Murder, committed as

follows, to wit: That Lane Hill did, in Natural County, on or about March 24, 2024, commit the

crime of Capital Murder in that the Defendant, Lane Hill, did with premeditated and

deliberate purpose caused the death of another person, Zoe Caine, at the Southberry’s

Restaurant located at 38 Southberry Square, Natural County, Arkansas, against the peace

and dignity of the State of Arkansas.

I swear, under penalty of perjury, that the forgoing representations are true.

Tyrone Wynne
Tyrone Wynne

Criminal Information 4
 IN THE CIRCUIT COURT OF NATURAL COUNTY, ARKANSAS
CRIMINAL DIVISION

STATE OF ARKANSAS

v. CASE NO. ARMT2025

LANE HILL

PRETRIAL HEARING ORDER

1. Trial Setting: All pretrial issues have been resolved, and this case is ready for trial. This

case is hereby set for trial on February 28-March 1, 2025. The case is to be tried on the issue

of guilt only. Sentencing, if necessary, will be decided at a separate hearing.

2. Use of Photographs of the Victim: Because the parties have stipulated to the cause of

death of the victim, the judge has sustained the Defendant's objection to showing photos of

the victim's body and injuries on the grounds that those photos would be unnecessarily

cumulative of the testimony of Dee Haiden and that, as a result, those photos would be

substantially more prejudicial than probative. Exhibit #7 is not part of the photo exclusions.

3. Stipulations: The parties stipulate to the following. No witnesses may contradict

knowledge of the facts contained in the stipulations:

a. The signatures on the witness statements are authentic and signed under oath by

each witness.

b. The jury charges are accurate in all respects. No objections to jury charges may be

raised.

Pretrial Hearing Order 5 Version 1.2

 c. The criminal information is valid. The Defendant may not challenge the criminal

information as deficient.

d. The autopsy of Zoe Caine concluded that Caine died as a result of hypothermia.

Hypothermia causes the body to be pale and waxy, not cyanotic, because the blood

withdraws from the skin by the body’s defensive mechanisms to avoid loss of heat.

e. Time of death could not be determined from typical physical examination of the body,

i.e. body temperature, because the body was chilled to 35 degrees F.

f. The autopsy results dated the cigarette burns found on Caine to have occurred two

weeks prior to death, and strangulation of neck, non-life threatening, to have

occurred a week prior to death.

g. Fingerprint analysis shows that Hill’s fingerprints are on the padlock to the cooler,

cooler door, and kitchen knife. Carboni’s fingerprints were not detected on the

padlock to the cooler, cooler door, or doors to the restaurant.

h. Exhibits #2, #3, #4, and #5 were made at or about the time of the events by a person

with knowledge of the events and are kept in the course of regularly conducted

business activity, and it is the regular practice to make such records. Exhibits #2, #3,

#4, and #5 do not need to be introduced through the custodian of the records.

i. Exhibit #7 is the original photograph taken by Detective Haiden at the scene of the

crime and accurately depicts the victim and the surroundings at the time of Detective

Haiden’s investigation.

Pretrial Hearing Order 6 Version 1.2

 j. Exhibit #9 is a true and accurate copy of the original note from Zoe Caine provided by

Defendant Hill shortly after being charged with the murder. The handwriting

contained in Exhibit #9 has been confirmed to be that of Zoe Caine, per expert

handwriting analysis. The original note disappeared from the evidence room prior to

analysis. Therefore, the dating of the handwriting on the note cannot be determined.

Exhibit #9 is admissible, without objection.

k. A spreadsheet was obtained from Zoe Caine’s residence that confirmed money was

owed to Lou Carboni. Neither side may contest that this document existed or

contained anything further. The remaining balance on the spreadsheet owed to Lou

Carboni was $208,500.

l. The financial audit prepared by Jo Walker showing Zoe Caine stole $273,958 is not in

dispute nor is the Supplies Unlimited invoice. Examples of the types of theft are

included as exhibits and may be used.

m. Following the closing of Southberry’s, John Croswell accepted a sous chef position at

a restaurant in Ontario and is unavailable to testify. John Croswell is not a suspect.

n. For purposes of Mock Trial allowing roles to be gender neutral, no issue will be raised

if Lou Carboni and CJ Morgan are performed by opposite genders in reference to

sharing a prison cell.

4. Witnesses: The designated witnesses, and only these witnesses, may be called at trial.

Only the party sponsoring their testimony may call them, but they may call them in any order:

Pretrial Hearing Order 7 Version 1.2

 Prosecution Witnesses Defense Witnesses
Jo Walker Lane Hill
Dee Haiden CJ Morgan
Lou Carboni Davis Young

5. Exhibits: Both parties have collectively identified the following exhibits, which have been

pre-marked and may be offered into evidence by either party. Except as provided in the

stipulations, no party has waived any objection to the admissibility of any exhibit.

a. Exhibit 1: Walker’s Curriculum Vitae

b. Exhibit 2: Ticket Order and Cash Register Tape

c. Exhibit 3: Deposit Slip and Cash Register Tapes

d. Exhibit 4: Check and Check Register

e. Exhibit 5: Buy-Sell Agreement

f. Exhibit 6: Investigation Report

g. Exhibit 7: Photo Inside Southberry’s Cooler

h. Exhibit 8: Padlock Receipt

i. Exhibit 9: Menu Notes

j. Exhibit 10: Young’s Curriculum Vitae

k. Exhibit 11: Autopsy Report for Zoe Caine

l. Exhibit 12: Diagram of Southberry’s

IT IS SO ORDERED, this 31st day of October, 2024.

Kesha May
The Honorable Kesha May

Pretrial Hearing Order 8 Version 1.2

 IN THE CIRCUIT COURT OF NATURAL COUNTY, ARKANSAS
CRIMINAL DIVISION

STATE OF ARKANSAS

v. CASE NO. ARMT2025

LANE HILL

JURY INSTRUCTIONS1

A. The Jury: Finders of the Facts

Under our Constitution and Code of Laws, only you – the jury – can make the findings
of fact in this case. I am not permitted to tell you how I feel about the evidence which has
been presented. And, throughout this trial, I have intended to be fair and impartial toward
each of the parties involved.

To determine the facts in this case, you will have to evaluate the credibility – or
believability of witnesses. You are the sole judges of the credibility of the witnesses, and, in
passing upon their credibility, you may take into consideration many things, such as:

(1) How would you describe the appearance and manner of the witness on the
stand, sometimes referred to as the demeanor of the witness?

(2) Was the witness forthright or hesitant?

(3) Was the witness's testimony consistent, or did it contain discrepancies?

(4) What was the ability of the witness to know the facts about which they testified?

(5) Did the witness have a cause or a reason to be biased and prejudiced in favor of
the testimony they gave?

1
These jury instructions should be used for the purposes of the 2025 Arkansas High School Mock
Trial Competition only. They should not be relied upon for any other purpose. Further, these
instructions reflect the law that will be used for the 2025 competition and may not reflect the current
law in the state of Arkansas.

Jury Instructions 9 Version 1.2

 (6) Was the testimony of the witness corroborated or made stronger by other
testimony and evidence, or was it made weaker or impeached by such other
testimony and evidence?

You can believe as much or as little of each witness's testimony as you think proper.
You may believe the testimony of a single witness against that of many witnesses – or just
the opposite.

Of course, you do not determine the truth merely by counting the number of
witnesses presented by each side. Throughout this process you have but one objective – to
seek the truth, regardless of its source.

B. Circumstantial Evidence

There are two types of evidence generally presented during a trial – direct evidence
and circumstantial evidence. Direct evidence is the testimony of a person who asserts or
claims to have actual knowledge of a fact, such as an eyewitness. Circumstantial evidence
is proof of a chain of facts and circumstances indicating the existence of a fact in issue. The
law makes absolutely no distinction between the weight or value to be given to either direct
or circumstantial evidence. Nor is a greater degree of certainty required of circumstantial
evidence than of direct evidence.

You should weigh all the evidence in the case in arriving at a verdict.

C. The Judge: Instructor of the Law

The same Constitution and laws which designate and make you the finders of the
facts also make me the instructor of the law. You must accept the law as I give it to you. If I
am wrong, there is another place and time for that error to be corrected. But for now, you
must accept the law as I give it to you – and I caution you that it does not mean what you
think the law should be, but what I tell you it is.

D. Instruction:

You have been selected and sworn as the jury to try this case of the State of Arkansas
against the Defendant, Lane Hill. The Defendant is charged with Capital Murder in violation
of Ark. Code Ann. 5-10-101. The Criminal Information in this case is the formal method of
accusing the Defendant of the crime. The Criminal Information is not evidence and you
should not allow yourselves to be influenced against the Defendant by reason of the filing of

Jury Instructions 10 Version 1.2

the Criminal Information. The Defendant has pled not guilty to the charge. A plea of not guilty
puts at issue each element of the crime with which the Defendant is charged. A plea of not
guilty requires the State to prove each element of the crime beyond a reasonable doubt. The
Defendant is presumed innocent of the crime and this presumption continues unless and
until, after consideration of all the evidence, you are convinced of the Defendant’s guilt
beyond a reasonable doubt. The Defendant must be found not guilty unless the State
produces evidence that convinces you beyond a reasonable doubt of the existence of each
element of the crime. It is your responsibility as jurors to determine the facts from the
evidence, to follow the law as stated in the instructions from the presiding judge, and to
reach a verdict of not guilty or guilty based upon the evidence.

We will now have opening statements of the counsel. Statements and arguments of
counsel are not evidence. The purpose of opening statements and closing arguments is to
assist you, the jury, in making a decision in this case; however, that decision must be based
upon the evidence in this case, which consists of the testimony delivered under oath in this
trial, any documents or other items introduced into evidence during this trial, and the
stipulations of the parties.

E. Closing Instructions:

(1) Introduction:

Now that all the evidence has been presented, it is my duty under the law to give you
the instructions that apply in this case. The instructions contain all rules of the law that are
to be applied by you and all the rules by which you are to weigh the evidence and determine
the facts at issue in deciding this case and reaching a verdict. You must consider the
instructions as a whole. All the testimony and evidence that is proper for you to consider has
been introduced in this case. You should not consider any matter of fact or of law except that
which has been given to you during the trial of this case.

It is your responsibility as jurors to determine the facts from the evidence, to follow
the rules of law as stated in these instructions, and to reach a fair and impartial verdict of
guilty or not guilty based upon the evidence, as you have sworn you would do. You must not
use any method of chance in arriving at a verdict but must base your verdict on the judgment
of each juror.

(2) Elements of the Charge:

Jury Instructions 11 Version 1.2

 In this matter, Defendant is charged with the offense of capital murder, under Ark.
Code Ann. § 5-10-101. To sustain this charge, the State must prove the following things
beyond a reasonable doubt:

That with the premeditated and deliberated purpose of causing the death of another
person, Defendant caused the death of Zoe Caine.

In order to find that Defendant acted with a premeditated and deliberated purpose,
you must find that they had the conscious object to cause death and that they formed that
intention before acting, as result of a weighing in the mind of the consequences of a course
of conduct as distinguished from acting upon sudden impulse without the exercise of
reasoning powers.

It is not necessary that this state of mind existed for any particular length of time, but
it is necessary that it was formed before the homicidal act was committed.

“Purpose”—A person acts purposely with respect to the results of their conduct when
it is their conscious object to cause the results.

If, after considering all the evidence, you conclude that the State has proven beyond
a reasonable doubt that the Defendant committed the crime of Capital Murder in violation
of Ark. Code Ann. § 5-10-101, you must return a verdict of guilty as to this charge on the jury
verdict form. If, on the other hand, you conclude that the State has failed to meet its burden
of proving beyond a reasonable doubt that the Defendant committed the crime of Capital
Murder in violation of Ark. Code Ann. § 5-10-101, you must return a verdict of not guilty as to
this charge on the jury verdict form.

(3) Presumption of Innocence and Reasonable Doubt:

The Defendant is presumed innocent, and the presumption continues unless, after
consideration of all the evidence, you are convinced of the Defendant’s guilt beyond a
reasonable doubt. The State has the burden of presenting the evidence that establishes the
Defendant’s guilt beyond a reasonable doubt. The Defendant must be found not guilty unless
the State produces evidence which convinces you, beyond a reasonable doubt, of each and
every element of the crime alleged.

“Beyond a reasonable doubt” is defined as “proof of such a convincing character that

you would be willing to rely and act upon it without hesitation in the most important of your
own affairs.”

Jury Instructions 12 Version 1.2

(4) Evidence – Definition:

Evidence is the testimony received from the witnesses under oath, stipulations made
by the parties, and the exhibits admitted into evidence during the trial.

(5) Evidence – Inferences:

You should consider only the evidence introduced while the court is in session. You
are permitted to draw such reasonable inferences from the testimony and exhibits as you
feel are justified when considered with the aid of the knowledge that you each possess in
common with other persons. You may make deductions and reach conclusions that reason,
and common sense lead you to draw from the facts that you find to have been established
by the evidence in this case.

(6) Felony Information and Indictments Not Evidence:

Again, the Felony Information or Indictment in this case is the formal method of
accusing the Defendant of a crime. It is not evidence of guilt. You should not allow yourselves
to be influenced against the Defendant by reason of the filing of a Felony Information or
Indictment.

(7) Judicial Rulings:

The Court has made rulings in the conduct of the trial and the admission of evidence.
These rulings should have no bearing on the weight or credit to be given any evidence or
testimony admitted during the trial, nor should they be considered by you in any manner to
indicate the conclusions to be reached by you in this case.

(8) Objections:

From time to time during this trial, the attorneys have made objections that I have
ruled on. You should not speculate upon the reasons why objections were made. If I
approved or sustained an objection, you should not speculate on what might have been said
or what might have occurred had the objection not been sustained by me.

(9) Credibility of Witnesses:

It is your responsibility to determine the credibility of each witness and the weight to
be given the testimony of each witness. In determining such weight or credibility, you may

Jury Instructions 13 Version 1.2

properly consider: the interest, if any, that the witness may have in the result of the trial; the
relation of the witness to the parties; the bias or prejudice of the witness, if any has been
apparent; the candor, fairness, intelligence, and demeanor of the witness; the ability of the
witness to remember and relate past occurrences; and, the means of observation and the
opportunity of knowing the matters about which the witness has testified. From all the facts
and circumstances appearing in evidence and coming to your observation during the trial,
aided by the knowledge that you each possess in common with other persons, you will reach
your conclusions. You should not let sympathy, sentiment, or prejudice enter into your
deliberations, but should discharge your duties as jurors impartially, conscientiously, and
faithfully under your oaths and return a verdict as the evidence warrants when measured by
these instructions.

(10) Punishment:

You are only concerned with the guilt or innocence of the Defendant. You are not to
concern yourselves with punishment.

F. Verdict Instructions:

After you have retired to consider your verdict, a member of the jury is selected as
your foreperson and then you begin your deliberations. The foreperson is to maintain orderly
deliberations but should have no greater influence on the deliberations than any other
member of the jury. Your verdict must be unanimous. When you have agreed on a verdict,
your foreperson will sign the verdict form, and you will, as a body, return the verdict form in
open court.

Jury Instructions 14 Version 1.2

 IN THE CIRCUIT COURT OF NATURAL COUNTY, ARKANSAS
CRIMINAL DIVISION

STATE OF ARKANSAS

v. CASE NO. ARMT2025

LANE HILL

VERDICT FORM

We, the jury, empaneled and sworn in the above-entitled cause, do, upon our oaths, find as
follows:

As to indictment ARMT2025, for Capital Murder, Ark. Code Ann. § 5-10-101, we the jury find
the Defendant:

Guilty

Not Guilty

Jury Foreperson

Jury Verdict Form 15 Version 1.2

 Statement of Jo Walker

1 1. My name is Jo Walker. I am 66 years old. I am a certified public accountant (CPA) in

2 private practice in Winston, Arkansas. A copy of my curriculum vitae is marked as Exhibit #1.
3 I graduated summa cum laude from the University of Arkansas (UofA) in 1981 with a Bachelor
4 of Science in Accounting. I was recognized as the top student in my class.

5 2. After graduating from UofA, I was highly recruited by what were then considered the
6 Big Eight CPA firms. I went to work for Arthur Andersen in Chicago as an auditor; which was
7 well before its demise from the Enron and WorldCom debacles. And in case you missed the
8 headlines back in 2002, Arthur Andersen was convicted for obstruction of justice for
9 shredding documents relating to its audit of Enron, and the firm agreed to surrender its
10 licenses. Although the United States Supreme Court unanimously reversed Arthur
11 Andersen’s conviction in 2005, the firm had already lost nearly all of its clients. I hate to even
12 mention my prior association with Arthur Andersen. However, when I was at the firm, it had
13 the reputation of supporting the highest standard in the accounting industry. I was quickly
14 recognized as a star at Arthur Andersen. I was promoted quickly and assumed the role of
15 manager after only three years. The usual track for a manager position there was four to five
16 years.

17 3. I left Arthur Andersen in 1984 to establish a firm of my own, Account-Abilitee, ironic

18 given my Arthur Andersen connection. We are a six-member firm, offering our clients full-
19 service accounting expertise. In addition to audit work, I specialize in forensic accounting.
20 Forensic accountants are trained to look beyond the numbers and deal with the business
21 reality of the situation. According to research conducted by the Association of Certified
22 Fraud Examiners (ACFE), U.S. organizations lose an estimated seven percent of annual
23 revenue to fraud. Based on the estimated U.S. Gross Domestic Product for 2016 - $18.57
24 trillion – this percentage indicates a staggering estimate of losses around $1.29 trillion
25 among organizations, despite increased emphasis on anti-fraud controls and recent
26 legislation to combat fraud. My mission as a fraud examiner is to reduce the incidence of
27 fraud and white-collar crime and to assist the client in detection and deterrence.

28 4. Lane Hill contacted me on February 26, 2024, to employ my services. I made a

29 presentation that afternoon at the local Chamber of Commerce entitled “Realizing Your Full
30 Potential.” The presentation touched on various business and financial practices to increase
31 profitability, including stronger internal controls to prevent or deter employee theft. Lane
32 came up to me after the meeting and asked if I would undertake a financial investigation and
33 make recommendations for increasing profitability for the business. I learned that Lane Hill
34 and Zoe Caine were partners in their restaurant, Southberry’s. At the time, there was no

Statement: Jo Walker 16 Version 1.2

35 suspicion of fraud or wrongdoing. Lane wanted to know why the business was in the red
36 when customers were steady, and it seemed business was good. Lane and Zoe had been in
37 the restaurant business for three years.

38 5. A study conducted by the University of Central Florida in 2011 concluded that the
39 highest failure rate in the restaurant industry was during the first year. Approximately 26
40 percent of restaurants fail in the first year; 19 percent fail in the second year; and, 14 percent
41 fail in the third year. While it is not unusual for a restaurant to fail in the first three years, it
42 was a bit surprising to hear Southberry’s was in the red because I was aware of some “good
43 buzz” for them in the community and positive critic reviews in The State newspaper.

44 6. I toured the restaurant facilities the following day, Tuesday, February 27th, to get a feel
45 for the day-to-day management and an overview of the financial records and record keeping
46 of the business. I advised Lane that in order to do a complete financial review, audit, and
47 forensic investigation, I would need complete access to all accounting records. I could start
48 the audit on March 5th at the restaurant. The audit would take up to two weeks. I would
49 charge a flat fee of $6,500. I would work on the premises, so I could have access to all of the
50 records and Southberry’s could continue business as usual. The arrangement also gave me
51 the opportunity to make observations of suspicious activity I might not otherwise see. Lane
52 agreed to the arrangement. I typically start audits on Mondays, but since the restaurant was
53 closed on Sundays and Mondays, I started Tuesday, March 5th. Also because this was a
54 young restaurant, I required advance payment. Lane paid me out of personal funds.

55 7. During my brief discussions with Lane, I could tell Lane was accounting challenged.
56 Lane has great creativity with food preparation, restaurant style, and service, but more or
57 less left Zoe Caine to handle the financial matters of the business. I was not present when
58 Lane informed Zoe about me being hired to do the forensic investigation, so I cannot state
59 what her reaction was. I did not notice anything particularly suspicious about Zoe’s behavior
60 when I was performing my forensic accounting work for the two-week period. Well, maybe
61 there were two times I recall when Zoe was back in the office area with me. At the time, I had
62 some cancelled checks, bank statements, and ledger cards on the desk. Zoe accidentally
63 spilled coffee all over the records, twice. At first, I thought it was an accident. The second
64 time, I thought Zoe was either especially clumsy or perhaps was doing something more
65 sinister in obliterating the records. Also, I did overhear a few conversations with Zoe on the
66 phone – once the first week I was there, and then two or three more times the following week.
67 Zoe told the person on the phone “I promised you I would get the money, please give me
68 time.” And “There is no need to use threats. You will get your money.” And “Yes, I remember
69 what happened last time when the payment was not timely, please don’t, that won’t be
70 necessary. I will pay you, I promise.” Zoe was upset by the calls but did not seem scared.

Statement: Jo Walker 17 Version 1.2

71 Initially, I thought Zoe’s conversations were with a vendor. In the restaurant business, if you
72 cannot pay your bills, the deliveries stop, and the business will go belly up. In retrospect after
73 learning about Zoe’s gambling problem and that she stole from Southberry’s, I think these
74 telephone conversations were probably between Zoe and Lou Carboni. Lou was probably
75 threatening Zoe if she did not pay her gambling debts. I never heard who was on the other
76 side of the conversation or what the caller said. Zoe never spoke about it with me. During the
77 first week I was there, Zoe came into the restaurant and had a burn mark on her arm. Another
78 time she had bruising around her neck, like someone had grabbed her neck hard. I did not
79 ask any questions, but I do notice details others might miss.

80 8. During the two-week period I was at the restaurant, I frequently saw a person in the
81 shadows in the alley across the street from the restaurant’s back door. At the time, I assumed
82 it was a person who worked at the business across the street taking a smoke break. I now
83 recognize the person lurking in the alley was Lou Carboni. Despite the darkness in the alley,
84 there was a light right above the back door entrance to the restaurant.

85 9. Restaurants are notorious for losing money due to employee theft. The most common
86 cash fraud scheme is skimming. Skimming is the process by which cash is removed from the
87 company before it enters the accounting system. Retail establishments where cash is used
88 frequently – particularly restaurants – are vulnerable to this type of scheme. A related type of
89 scheme is to ring up a sale for less than the actual amount. The fraudster then pockets the
90 difference between the actual sale and the amount on the register tape. Employees may also
91 ring up a sale and then void the same sale, thereby pocketing the cash from the register.

92 10. An employee who collects the cash and also makes the bank deposit has an excellent
93 opportunity to misappropriate company funds. For example, an employee in the food
94 services industry might receive the daily receipts from the cashier, along with the cash
95 register tapes. The employee would then mutilate the register tapes, so the tapes could not
96 be read. With the evidence now destroyed, the employee would pocket a portion of the day’s
97 receipts and deposit the balance. If the daily deposit amounts are not compared with the
98 cash register tapes, the fraud can go undetected.

99 11. Checks can also be an instrument for fraud. Employees with signature authority on a
100 company bank account can make checks payable to cash or to themselves personally.
101 Someone with check signatory authority can simply write a check to himself or to cash, mark
102 the check void in the company’s check register and then write an inflated amount of another
103 check written in the check registry to offset the amount of the voided check. When the bank
104 statements are received, the employee merely removes the print out page showing the
105 cancelled checks.

Statement: Jo Walker 18 Version 1.2

106 12. In performing my forensic investigation, I reviewed the following financial and
107 business records: general ledger, journal entries, adjusted journal entries, trial balances,
108 checking accounts, cancelled checks, deposit slips, cash register tapes, order tickets, and
109 vendor invoices. I also personally interviewed Lane Hill and Zoe Caine, as well as a couple
110 of the restaurant employees to understand the flow of money and internal controls used by
111 the company. Although both Zoe and Lane had authority to sign checks, Zoe primarily
112 assumed that role. Lane managed the kitchen staff, the menus, ordering food supplies,
113 scheduling employees, reservations, and keeping the customers happy. Zoe primarily
114 operated the cash register during business hours, ordered food and supplies, and managed
115 the financial aspects of the business.

116 13. During the second week of my investigation, I started to strongly suspect Zoe Caine
117 had been stealing from the restaurant. I do not believe I mentioned my suspicions to anyone.
118 I seem to recall both Zoe and Lane asking me how the investigation was proceeding, but I
119 typically do not make any comments until my investigation is complete. In my view, it is
120 important to have all your facts and figures together before any conclusions are announced.

121 14. After I had completed my two-week forensic investigation, it was evident Zoe had
122 been taking cash from Southberry’s for some time. I found evidence of each of the typical
123 theft schemes mentioned previously. For example, skimming had occurred. There were
124 several instances where one of the waitstaff had a carbon copy of an order ticket in their
125 book, but the order was not included on the cash register receipt for the day. An example of
126 this is shown in Exhibit #2. The check marks on the cash register tapes are my notations for
127 cross-checking the order tickets for that day. I cannot say for certain the skimming is
128 attributed to Zoe. Someone else could have been managing the cash register at the time.
129 However, in looking at the events as a whole, there are events I can directly connect to Zoe.
130 For example, certain daily cash register tapes did not match to the deposit made. These
131 deposit slips were written in Zoe’s handwriting and were part of her normal job
132 responsibilities, not the responsibility of any other employee. Thus, as you will see from
133 Exhibit #3, the deposit slip for Friday and Saturday’s sales was in the amount of $587.93 on
134 Monday, February 12, 2024, even though the cash register tapes show receipts from Friday,
135 February 9th in the amount of $2,299.61 and Saturday, February 10th for $3,089.57. Finally,
136 I found checks written to cash or to Zoe that were shown as void in the check register but
137 cleared the bank. In order to balance the account, another check in the check register and
138 ledger accounts was manipulated to increase the payment to cover the amount of the
139 “voided” check to Zoe. Exhibit #4 is an example of this occurrence. There is a check register
140 entry for check #1098 paid to Supplies Unlimited in the amount of $3,093.45. However, I
141 found the Supplies Unlimited invoice paid with check #1098 written in the amount of $93.45.

Statement: Jo Walker 19 Version 1.2

142 15. In total, I uncovered 67 instances of theft committed by Zoe Caine totaling $273,958
143 over the past two years. It appears no theft occurred from the restaurant during the first year
144 in operation. Of the 67 instances of theft, more than half occurred in the six-month period
145 prior to March 2024. Unfortunately, the theft has left Southberry’s with little to nothing.
146 Southberry’s was operating at a net loss of $164,554 and had a negative cash flow.

147 16. I broke the news to Lane on Friday, March 15, 2024, about 4pm. I informed Lane that
148 my forensic investigation revealed Southberry’s was insolvent due to numerous occasions
149 of theft by Zoe Caine totaling $273,958. At first, Lane appeared to be in shock, repeating
150 several times, “How could this happen?” The more I explained to Lane the specifics of the
151 theft and giving Lane examples of the skimming, check fraud, and deposit manipulation, the
152 more I saw pure rage on Lane’s face. Lane seemed consumed by rage saying, “Well, I’ll make
153 Zoe pay for this. She won’t make a fool out of me.” “You have done your job. You can leave. I
154 will confront Zoe alone.”

155 17. On that same day, I left the building when I realized I had left behind my favorite
156 mechanical pencil on the desk in the office area. When I went back to retrieve my pencil, I
157 overheard Lane talking to Zoe in strained but controlled hush tones. I could not hear
158 everything being said clearly because I was standing near the kitchen door to the hallway by
159 the office and the kitchen employees were making loud noises as they pulled out pots and
160 pans in preparation for the dinner crowd. But I am pretty sure I heard Zoe say something
161 about gambling and that Lane and Zoe had to come up with the money right then. I also recall
162 hearing Lane threaten to kill Zoe. I do not know the exact wording Lane used because of the
163 background noise. And then I heard Lane say quite clearly, “You’ll get your just desserts.”

164 18. While I was reviewing the company records, I had also come across a buy-sell
165 agreement for the restaurant. The buy-sell agreement states in the event of death of either
166 partner, the other partner shall be the beneficiary of a $500,000 insurance policy. A copy of
167 the buy-sell agreement is attached as Exhibit #5. So, upon Zoe’s death, Lane was to receive
168 a $500,000 payout from the insurance policy. It is not unusual, however, for partners in a
169 business to have a buy-sell agreement in place, funded by insurance. Actually, it is smart
170 business to plan for contingencies of someone’s death and what happens to a partnership
171 interest in the business. You do not want the family coming in and trying to manage the
172 business too. You want to be able to buy them out.

173 19. Following the horrible death of Zoe Caine, Detective Haiden with the Winston Police
174 Department interviewed me for further information about the financial audit. Lane disclosed
175 the audit to Haiden, which is why Haiden came to me.

Statement: Jo Walker 20 Version 1.2

176 20. I believe I have an excellent reputation among my peers in both audit work and
177 forensic accounting. All of my peer review examinations have yielded outstanding results. I
178 did have one malpractice action filed against me about five years ago relating to tax
179 preparation work I had performed, specifically with a car dealership’s inventory. My
180 insurance company paid a small nuisance settlement to make it go away, but the settlement
181 papers specifically state that I deny liability.

WITNESS ADDENDUM

I have reviewed this statement, and I have nothing of significance to add at this time. The
material facts are true and correct.

Signed,

Jo Walker
SIGNED AND SWORN to me before 8:00 a.m. on the day of this round of the 2025 Mock Trial
Competition.

Anthony Roberts
Anthony Roberts, Notary Public
State of Arkansas
My Commission Expires: 10/24/27

Statement: Jo Walker 21 Version 1.2

 Statement of Dee Haiden

1 1. My name is Dee Haiden. I am 43 years old. I am an investigator with the Winston

2 Police Department. I am a twenty-year veteran of law enforcement and hold a bachelor’s
3 degree in Criminal Justice from Arkansas State University. During my career, I have been
4 involved in every type of criminal investigation at the local, state, and federal levels. For six
5 years, I served as a member of the Arkansas Task Force on Organized Crime, working in an
6 undercover capacity. I use the information I learned during my time as an undercover agent
7 to investigate crimes where there is a suspicion of organized crime involvement. I currently
8 work closely with the Metro Gang Task Force, the Winston Police Department, and the FBI
9 office in AR. Besides my duties at the Winston Police Department, I am an adjunct instructor
10 at the AR Criminal Justice Academy and the Federal Law Enforcement Training Center
11 (FLETC) in Brunswick, Georgia. I have also been a guest lecturer at the National Advocacy
12 Center.

13 2. As an investigator for the Arkansas Task Force on Organized Crime, I made countless
14 arrests and testified against many men and women connected with organized crime. I have
15 received numerous awards for my work including the Police Medal of Valor, Meritorious
16 Service Medal, and the AR Law Enforcement Officers Association Officer of the Year Award
17 in 2014. My efforts have also been the focus of a story in Newsweek, ABC Television News
18 Program 20/20, and Dateline NBC.

19 3. I get irritated when people bring up the two times I was investigated by the Office of
20 Professional Responsibility (OPR) for possible corruption and connections to the mob. OPR
21 used to be called internal affairs. I was accused of evidence tampering and rigging the case
22 involving Lou Carboni and Lou’s brother Diamond Joe, so they could avoid conviction.
23 Nothing could be further from the truth. I swore to myself there would be another day when
24 I would bring them down. Bringing up the OPR investigations is an underhanded attempt by
25 defense counsel to discredit me and let a guilty person go free. It was a long time ago and
26 nothing came of the investigations. I was never indicted, never suspended, and never
27 reprimanded. Naturally when you have infiltrated the mob, there is always a blur in the public
28 or outsider’s view as to where your loyalties are. If you are going to play the part of an
29 undercover agent, you have to be convincing or you do not survive, and I was pretty good at
30 acting. Truth be known, I wanted nothing more than to nail Lou Carboni for the heinous
31 crimes Carboni orchestrated. Yes, I developed connections with Lou Carboni, but only to
32 use them against Carboni and other violent loan sharks.

33 4. On the morning of March 26, 2024, I was called to the scene of a homicide by the
34 initial responding patrol officer. Co-owner of Southberry’s Restaurant, Zoe Caine, was

Statement: Dee Haiden 22 Version 1.2

35 discovered padlocked in the kitchen’s walk-in cooler. The officer on scene correctly
36 identified it as a homicide. The body was inside the cooler, which only locks from the outside
37 with a padlock. Upon my arrival, I automatically thought this was a mob hit.

38 5. The restaurant was closed on Sundays and Mondays, which explained the long
39 exposure in the cooler without earlier discovery. John Croswell, the sous chef, discovered
40 the back door of the restaurant unlocked at 07:15 on Tuesday, March 26, 2024. Croswell then
41 discovered the body locked in the cooler 15 minutes later and immediately called 911 and
42 then called co-owner, Lane Hill. When Croswell was interviewed, there was nothing else of
43 value to add. Upon my inspection of the kitchen and office areas in the restaurant, nothing
44 was out of place or disturbed to indicate a struggle. Caine’s purse with cell phone, wallet,
45 and keys was undisturbed in the bottom right drawer of her desk. After charging and
46 powering on Ms. Caine’s cell phone, it did not have a passcode and it reflected a missed call
47 at 22:04 on Saturday, March 23, 2024. Upon further interviews of kitchen staff, it was noted
48 a person had been lurking in the alley across from the kitchen’s back door to the restaurant
49 for a couple of weeks. No further relevant information was discovered.

50 6. The crime scene techs finished documenting the evidence on hand and
51 photographed the position of the body and the word “Killer” along with the start of another
52 letter spelled out in bacon, marked as Exhibit #7. The Coroner’s office took possession of the
53 body and transported it to the morgue. As the Coroner’s van was leaving, I spoke with, Lane
54 Hill. Hill seemed to have been the last person to talk to the victim at 22:30 on Saturday,
55 March 23, 2024. Caine was going to stay later according to Hill because she wanted to jot
56 down some additional menu ideas for the following week. No notes to that effect were found
57 in the investigation; however, Hill’s legal team later turned over the original menu note to the
58 police department while keeping a copy. Also, I am not in control of the evidence room, so
59 the accusation that I tampered with the evidence is ridiculous.

60 7. Hill stated the cooler was unlocked at the time Hill left the restaurant, and Caine was
61 going to lock up the cooler after checking the inventory for the following week’s menu, shut
62 off the lights, and lock up the restaurant for the night. Further, Hill revealed the results of a
63 forensic audit of Southberry’s books and showed me the final report dated March 15, 2024.
64 Hill had confronted Caine that day about the results of the audit. Caine admitted to Hill that
65 she had stolen money from the restaurant. Hill told me the imminent closing of Southberry’s
66 would ruin Hill both professionally and personally. This would be caused by not only the loss
67 of revenue from Southberry’s, but also Hill’s personal loans from the startup of the
68 restaurant. After Caine’s admission, Hill was trying to come up with a way to help Caine pay
69 back the loan shark. Hill did not know to which loan shark the money was owed, but Caine
70 had referenced someone named Lou. That is when I thought the suspect was local loan

Statement: Dee Haiden 23 Version 1.2

71 shark/mobster, Lou Carboni. Hill also mentioned having seen a person in the alley across
72 from the restaurant’s back door upon leaving on the evening of March 23rd. I asked Hill to
73 look at a photo array on my tablet and attempt to identify the person seen in the alley. From
74 the photo array I set up, Hill positively identified Lou Carboni.

75 8. After the interview with Hill, I went to Caine’s home. It was apparent she had not been
76 home since Saturday, March 23. She had not retrieved her mail or collected her Sunday,
77 Monday or Tuesday newspapers. At Caine’s residence, I also found a printout of a computer
78 spreadsheet showing that Caine owed Lou Carboni over $200,000. It was then I knew that
79 even if I did not have Carboni for murder, I was going to nail Carboni for loan sharking.

80 9. As noted in the autopsy report, marked as Exhibit #11, Zoe Caine died of hypothermia
81 due to prolonged exposure to 35-degree temperatures inside the locked cooler. The Coroner
82 could not tell me exactly when Ms. Caine died from hypothermia, only that it likely took more
83 than 20 hours before the hypothermia was severe enough to kill her. Based on the actual
84 body temperature at time of discovery, it was likely Caine had been in the cooler more than
85 50 hours. In the autopsy report, the Coroner noted that Caine’s weight, height, and age were
86 factors to consider with hypothermia. For example, a person who is 35 years of age and say
87 150 pounds in weight would lose 1.5 degrees per hour of core temperature when exposed to
88 a cold environment. The type and amount of clothing would also impact heat loss as well. In
89 this instance, Caine weighed significantly less than average and so it is likely that her body
90 temperature loss per hour would have been increased. When Caine was discovered, she
91 was wearing a thin spring dress.

92 10. It is ironic for anyone to accuse me of trying to pin this murder on Lane Hill as a
93 scapegoat to let Carboni go free again. The reason I was called into this case is because it
94 initially appeared like a mob hit. We had an eyewitness identify Lou Carboni outside
95 Southberry’s on the Saturday evening of March 23, 2024. According to Hill, Caine admitted
96 threats on her life by Lou and showed evidence of violent physical “messages,” such as
97 cigarette burns on her arms and bruising around her neck from choking, which happened
98 when Caine had not come up with the last two payments. Being iced in a cooler is a typical
99 mob hit because it sends a message to others who owe loan sharks money. Not to mention,
100 being locked in a cooler is an agonizing way to die over a long period of time. Based on that
101 evidence, I arrested Carboni for loan sharking and the murder of Zoe Caine. My investigation
102 report documents my findings and conclusions, marked as Exhibit #6.

103 11. After obtaining counsel and making a deal with the prosecutor’s office, Carboni made
104 a statement admitting to tailing Caine for two weeks for money owed. While keeping an eye
105 on Caine, Carboni witnessed Lane Hill pointing a knife at Caine in what looked like a heated

Statement: Dee Haiden 24 Version 1.2

106 discussion, then Lane forced Caine back into the restaurant at knife point. Carboni
107 witnessed Hill leaving the restaurant around 22:30 and waited an additional hour for Caine
108 before leaving. Carboni never saw Caine leave the building.

109 12. My first and foremost responsibility is to uphold the law. I had to maintain my
110 objectivity throughout my investigation regardless of how much I might have wanted to
111 implicate Carboni. Once the information began to lead me away from Carboni as a suspect,
112 I interviewed Jo Walker, the forensic accountant who investigated Southberry’s financial
113 records. Walker told me the audit had been completed and clearly showed that Caine stole
114 $273,958 from the restaurant. Southberry’s was essentially out of cash and would have to
115 close. Walker also told me about the buy-sell agreement for a deceased partner’s interest in
116 the business, which named Hill the beneficiary should Caine die. Finally, Walker disclosed
117 overhearing an argument between Hill and Caine about the theft of money, which occurred
118 after releasing the results of the audit to Hill on March 15, 2024.

119 13. After my interview with Jo Walker, I went to Southberry’s to ask Hill some follow-up
120 questions and to look for additional evidence including the knife referenced by Lou Carboni.
121 I located a knife that matched the description given by Carboni and took it into evidence. Hill
122 agreed to go to the police station to provide fingerprints for comparison with those taken
123 from the cooler, padlock, and knives. Hill’s fingerprints matched those taken from the knife,
124 padlock, and cooler door.

125 14. Two things gnawed at me. First, I would have expected to find some additional
126 physical violence to have occurred prior to Caine’s hypothermia. Typically, mobsters like to
127 rough up the victim before pronouncing the death sentence. A strong message to other
128 potential deadbeats is paramount. In this case, there were no signs of struggle with another
129 individual or physical violence. According to the Coroner’s report, there was no physical
130 abuse associated with the cause or timeline of death. Although there were signs of previous
131 abuse visible, none were recent enough to be associated with Caine’s being assaulted or
132 forced into the cooler. She did, however, have bruising on her hands most likely from banging
133 on the door to signal for help. Second, according to my interview with Hill, Caine had been
134 making payments to Carboni. So, Caine continued to be a source of income for Carboni.
135 Loan sharks typically do not cut off a source of revenue unless it dries up completely or if the
136 loan sharks feel threatened. I did not see that to be the case for Caine.

137 15. Upon completing my investigation, it became clear to me that Hill, not Carboni,
138 murdered Zoe Caine. Motive was clear. Walker informed Hill that Caine was stealing money
139 from the restaurant. Caine’s death was a payback in more ways than one – not only for
140 vengeance, but also to collect $500,000 through the buy-sell agreement. Hill was angry

Statement: Dee Haiden 25 Version 1.2

141 when first learning about the theft and the company’s bankrupt condition. More than one
142 witness heard Hill threaten Caine. Plus, Hill had the opportunity. Carboni had staked out
143 Southberry’s the night of March 23 and overheard the two arguing outside the restaurant.
144 Carboni also witnessed Hill brandishing a kitchen knife and forcing Caine back into the
145 restaurant right after a sudden rain shower.

146 16. Unfortunately, there is no accurate way to establish time of death merely by observing
147 the body since it was chilled to such a low temperature. Thus, as a police detective, I am
148 trained to use other means, such as witnesses, neighbors, unopened mail, or other
149 testimonial or physical evidence. The last person who was with Caine was Hill. It is obvious
150 this was no accident. The padlock to the cooler was locked from the outside. Plus, Caine
151 told us what happened through her own words. She identified her assailant’s name on the
152 cooler floor using bacon strips stored in the cooler. Before she died, Caine spelled out
153 “Killer” with the start of another letter as seen in the photograph marked as Exhibit #7. As
154 you can also tell, another piece of bacon was starting to be laid out. Had Caine not
155 succumbed to the hypothermia, she would have finished spelling the killer’s name.

156 17. Additionally, it became quite evident this murder was not committed in the heat of
157 passion, but rather was premeditated. Southberry’s had been operating for three years prior
158 to this incident. Hill purchased a lock for the cooler upon learning Caine was stealing from
159 the business. Hill contemplated and planned the whole thing out, forcing Caine into the
160 cooler, locking her in over the weekend, and making it appear the loan sharks were making a
161 typical mob hit. But Hill was careless. Hill’s fingerprints are all over the lock to the cooler, the
162 cooler door, and the kitchen knife. In addition, Hill did not realize there was a witness lurking
163 in the dark shadows in the alley facing the back door of the restaurant. We did not find
164 Carboni’s fingerprints anywhere in the restaurant, but several places around the lock and
165 cooler were smudged. At that point, I had enough evidence to arrest Lane Hill for the murder
166 of Zoe Caine. After Carboni met with the prosecutor and provided the statement implicating
167 Hill, all Carboni’s charges were dropped.

168 18. CJ Morgan might have tried to reach me to tell me about something with this case, but
169 I never spoke with Morgan. Sure, I know a detective generally follows all leads, but not in this
170 instance. I knew every minute I spoke with Morgan was a minute wasted of my life I would
171 never get back. After all, Morgan has given false testimony or a false tip in the past in an
172 attempt to get a lesser sentence. Morgan is a notorious con-artist, always looking for another
173 angle to play. Morgan was not worth my time.

Statement: Dee Haiden 26 Version 1.2

 WITNESS ADDENDUM

I have reviewed this statement, and I have nothing of significance to add at this time. The
material facts are true and correct.

Signed,

Dee Haiden
SIGNED AND SWORN to me before 8:00 a.m. on the day of this round of the 2025 Mock Trial
Competition.

William Smith
William Smith, Notary Public
State of Arkansas
My Commission Expires: 12/08/27

Statement: Dee Haiden 27 Version 1.2

 Statement of Lou Carboni

1 1. My name is Lou Carboni. I am 41 years old. I never needed college. I learned what I
2 needed to know on the streets of New Jersey, where I was born and raised. I dropped out of
3 high school at the age of 16 to go into the family business. Our business is all up and down
4 the east coast. I moved to Arkansas to take on more responsibility for the family. I have been
5 in the family business for about 25 years. The family business is your garden variety regular,
6 ordinary sanitation company. You offer a service, you get paid for that service just like any
7 other service provider.

8 2. I occasionally loan money to people. Those loans are interest bearing loans like a
9 bank loan. I do not see the need for promissory notes. People know they owe me when I loan
10 them money and I expect them to pay. I do not need a piece of paper to get them to pay me.
11 That is not how I do business. If someone does not pay me, I firmly remind them their
12 payment is due and then bada boom, bada bing – they find a way to come up with the money.
13 Yeah, Zoe Caine needed a reminder or two. I can be very persuasive. I am not a loan shark –
14 that would be illegal. I am not a member of the mob or organized crime. All I know about the
15 mob I learned from the movies. I know nothing about how the mob kills people.

16 3. I am testifying in this case because the prosecutor made me an offer I could not
17 refuse. By testifying and telling the truth, the prosecutor agreed to drop the charges against
18 me for loan sharking because of my “business deal” with Zoe Caine.

19 4. This is not my first scrape with the law. The cops have had it in for me for a while –
20 always looking to nail me with something. Now and then they have busted me for some petty
21 crime to flex their muscles. I am not scared. I never did time for more than a year. My rap
22 sheet started back when I was in juvy. In 1999, I was convicted of theft of less than $1,500
23 and had to do some road crew work. In 2000, I was convicted of assault in the second degree.
24 I got a suspended sentence and was on probation for a year. In 2008, I was convicted of
25 extortion. Then, in 2017, I was charged with bribery and never convicted, which is the case
26 involving Detective Haiden. Haiden was accused of tampering with evidence, but the case
27 was a sham. In 2018, I was charged with criminal threat. The state said I threatened this guy
28 I loaned money to. The case got thrown out because the state’s key witness disappeared. In
29 September 2024, I was charged with assault in the second degree, which is still pending. The
30 state said I strangled some guy. Can you believe it? I am not worried about that charge either.
31 These things have a way of going away.

32 5. The state also tried to pin Zoe Caine’s murder on me. No way. I may not be squeaky
33 clean, but I am not a murderer. You can ask anybody. Why would I kill Zoe? She was making
34 good on what she owed me. Sure, I was keeping tabs on her. Sometimes folks who owe me

Statement: Lou Carboni 28 Version 1.2

35 some dough think about skipping town. If Zoe left town it would be to look for a big score.
36 She always wanted to get in on some action. Mostly she would go to goulash joints looking
37 for a live game. A goulash joint is a restaurant or bar running a regular card game hidden in a
38 back room. A live game is a game with lots of betting action. She was often playing the rush
39 – she enjoyed a short run of good luck by winning a very large pot of money in one hand.
40 Before Zoe started the business, she would, at times, gamble for six days straight in a week,
41 eight hours a day for several weeks, losing thousands of dollars. Recently, Zoe had become
42 a desperate gambler looking for a big score to erase her many personal and business debts.
43 She frequently was tapping out – you know, losing her entire gambling bankroll and then
44 having to stop playing. But she was not a pigeon, you know, an unsophisticated gambler. I
45 would have stopped her if I thought she was dead money. Dead money is an inexperienced
46 player who has virtually no chance at winning. I believed she still had a few aces up her
47 sleeve. It is not smart business if I invest in losers, now, is it?

48 6. At the time of her untimely death, Zoe owed me over $200,000 due to her gambling
49 losses, but she had made good on nearly $300,000 of gambling losses before then. I never
50 concerned myself much with where Zoe got her money. It is not my problem where the
51 money comes from as long as I get my money. Time was running out on the balance Zoe
52 owed, so I started keeping closer tabs on her. I wanted to make sure payments were coming.
53 I have been accused of burning and choking Zoe, but that never happened. Zoe was a
54 smoker. She could have burned herself accidentally. I did not threaten her. Sure, I asked her
55 about when she was going to pay me, but that was the extent of our conversation.

56 7. I tailed Zoe for the two weeks before she died. On the night of March 23rd, I staked out
57 Southberry’s across the alley from the back door to the restaurant sitting in my black Caddy
58 starting around 9:00 p.m. You can see the alley I was parked in on the diagram marked as
59 Exhibit #12. Zoe was outside in the alley smoking a cigarette. The restaurant closed at 10:00
60 p.m., so it was after hours and I thought everyone else had left. To my surprise, Lane Hill,
61 who I later identified, came storming out of the restaurant’s back door and started arguing
62 with Zoe. Hill was in a fit of rage. I did not hear the entire conversation because my cell phone
63 vibrated and distracted me, but I heard almost all of it. Hill said Caine had ruined the
64 business, the restaurant was going to be bankrupt, and was going to have to close, yadda-
65 yadda-yadda, all because of her gambling debts. It was then that I realized the money paid
66 to me most likely was coming from Southberry’s all along. Then I saw Hill brandish a kitchen
67 knife and point it at Zoe forcing her back into the restaurant. I could see everything pretty
68 clearly – that is until the very end as they were going back in the restaurant when we had a
69 quick rain shower. The alley is only 15 feet wide. And there is a security light that beams
70 directly over the restaurant’s back door to the restaurant. I know it was a knife I saw because
71 it glimmered when the overhead security light shone on it when it was at an angle. The knife

Statement: Lou Carboni 29 Version 1.2

72 blade was about ten inches long. I was parked in the shadows, so I am sure Hill did not see
73 me. At the time of my release from jail, I identified Hill in a line up at the Winston Police
74 Department as the person I saw arguing with Zoe that night and forcing her back into the
75 restaurant at knife point. I did not do anything or say anything at the time because, as you
76 can tell from my rap sheet, me and the cops do not always get along so great. I later saw Hill
77 leave alone that same night around 10:30 p.m. I waited for another hour and then left, but I
78 never saw Zoe leave the restaurant. I later told the same thing to Haiden.

79 8. I was charged initially with killing Zoe and loan sharking. Like I said before, I did not do
80 it. Haiden was hoping it was me. I still did not say anything about what I saw because I did
81 not know at the time how Zoe died or where she was located. So, I did not realize how
82 relevant my observations might be. Plus, until I had my attorney with me to make a deal on
83 the loan sharking charge, I was not about to say anything about tailing Zoe because she owed
84 me money.

85 9. While in jail, I shared a cell with CJ Morgan. Whatever Morgan is saying I said while we
86 were in jail together is a flat out lie. It has to be Morgan’s way of getting some deal. Morgan is
87 a con artist. Morgan probably thought I would be willing to pay some hush money. Morgan
88 got stuck in the lie when the charges against me were dropped. Why would I confide in
89 Morgan? That makes no sense.

WITNESS ADDENDUM

I have reviewed this statement, and I have nothing of significance to add at this time. The
material facts are true and correct.

Signed,

Lou Carboni
SIGNED AND SWORN to me before 8:00 a.m. on the day of this round of the 2025 Mock Trial
Competition.

C.H. Gallant
C.H. Gallant, Notary Public
State of Arkansas
My Commission Expires: 12/5/27

Statement: Lou Carboni 30 Version 1.2

 Statement of Lane Hill

1 1. My name is Lane Hill. I am 29 years old. I grew up on a farm in rural Arkansas where
2 life was pretty simple. We were self-sufficient and made a lot of our own food on the farm
3 including butter, cheese, sausage, and ice cream. I suppose making food from home is what
4 got me interested in the culinary arts. After high school, I made the giant leap and moved to
5 New York to attend the Culinary Institute of America (CIA). Moving to a big city from a rural
6 community was an eye-opener. I was pretty naïve, and I probably still am today. At the CIA, I
7 trained with world-renowned, classically trained chefs. It was the time of my life. After 38
8 months in the program, I received my bachelor’s degree. It was my dream to one day open
9 my own restaurant, but I was only 21 and I needed to gain more experience and raise some
10 funds. I moved back to Arkansas to be closer to my family yet be in a city that could offer me
11 a decent wage and experience. I was thrilled when I landed a position at Boley’s, one of
12 Winston’s top-rated restaurants. I worked there for four years and developed my skills in a
13 variety of areas. I initially started as a pantry chef, making salads and cold appetizers such
14 as elaborate fruit plates. I also worked as a poissonier, or fish chef, and as a pastry chef,
15 which was my passion. After those first two years, I was asked to step in as a saucier, the
16 person who is responsible for sautéing and making all of the sauces for the restaurant. The
17 next year, I became sous chef, which is the second in command. If I took any time off, I used
18 it only to further my skills. I enjoyed entering culinary ice sculpting competitions. I worked
19 long and hard during those years – six days a week, usually ten-hour days. But the sacrifices
20 were worth it, especially if it would help me reach my goal of owning my own restaurant one
21 day.

22 2. I met Zoe Caine at a conference of the Southeastern Culinary Association. The

23 conference was about owning your own restaurant. Zoe was one of the speakers. She
24 seemed very knowledgeable about the management and finances of owning a restaurant
25 business. She graduated magna cum laude from Taylor and King University with a double
26 major in Food Service Management and Accounting in 2016. She was extremely bright and
27 energetic with an air of sophistication. She came from money and was well connected. You
28 could tell she had already started to make her mark on the culinary world. After the
29 conference, I made a point of meeting her. She was looking to open a fine dining restaurant
30 in Winston. She needed a co-partner who could focus on the food preparation aspects of the
31 business. This was the perfect opportunity to further my dream of owning a restaurant. She
32 convinced me Winston was the best place to start. She knew what she was doing. If we
33 started somewhere in a busier part of the state, we would be one of a thousand places and
34 the rent would be high. Instead, we would have a niche in Winston and started a fine dining
35 restaurant.

Statement: Lane Hill 31 Version 1.2

36 3. We found a great place in Southberry Square and Southberry’s was born. We planned
37 everything for the restaurant from theme, layout, menus, staffing, ordering, keeping the
38 books, etc. We agreed we wanted to be closed on Sundays and Mondays since those were
39 the two slowest days for restaurants. When it came to funding the restaurant and the profits,
40 we agreed to a 50-50 split on everything. We each were bringing our respective talents to the
41 table, excuse the pun. We agreed we would both contribute the same working capital. She
42 already had a substantial bankroll of cash to contribute for the start-up. It was like nothing
43 for her to come up with the $100,000. I suppose to be perfectly honest, in a way I resented
44 her for already having so much money on hand for the start-up. I have never been in a
45 position where cash was so readily available to me. I grew up modestly and had been
46 skimping and saving while working at Boley’s. I emptied my savings of $40,000 and had to
47 take out personal loans for the other $60,000 of my share of startup funds. As a result,
48 everything I owned in my entire life and for some time into the future would be invested in
49 this restaurant. I had invested sweat equity, too. Of course, I knew it was a risk. With the start
50 of a new business, especially a restaurant, there is always the risk of failure. And if it failed, I
51 would probably have to file bankruptcy for not only the business, but personally as well.

52 4. Zoe took care of all the financial aspects of the business. In hindsight, I should have
53 paid more attention to what she was doing, but I trusted Zoe and we each had our own area
54 of expertise. I handled all aspects of the food preparation and presentation, including menu
55 selection, working with vendors to order food products, and preparing the food or directing
56 the food preparation. While Zoe was fully in charge of finances and management, she also
57 had creative ideas for food presentation or preparation. Every now and then she would jot
58 her menu suggestions for the following week on a piece of paper and leave it for me or John
59 Croswell, our sous chef. On the other hand, I have never understood financial statements or
60 accounting, which Zoe took care of for us. When we were starting up the restaurant back in
61 June of 2021, it was her suggestion to put in place a buy-sell agreement funded by insurance.
62 Initially, I did not understand its purpose, but I agreed to sign because she said it was good
63 for both of our protection. The buy-sell agreement was in place in the event one of us died,
64 paying out $500,000 to the surviving partner. She said the income flow from the restaurant
65 would pay for the policy. Now, I am thankful she had the buy-sell agreement in place because
66 it will save the business and me personally. I think of it as her way of making things right after
67 stealing from the business. I plan on re-opening after I am cleared.

68 5. When we opened in June 2021, Southberry’s took off right from the start, soon
69 becoming the talk of the town. We had rave reviews from food critics in The State paper, The
70 Winston Journal and AR Today. We were even featured in The Winstonian, a local magazine.
71 The restaurant continued to grow over the next three years. We had a steady flow of
72 customers – some loyal customers from the beginning and new customers every day. Often

Statement: Lane Hill 32 Version 1.2

73 it was difficult for our customers to get a reservation for a Friday or Saturday evening unless
74 they called weeks in advance. Zoe and I were contemplating opening a new dining
75 experience near the Thurmond Theater in downtown Winston where we would serve
76 desserts exclusively for the after-theater crowd. Zoe had already worked up the business
77 plan and we decided to call it “Just Desserts.”

78 6. I was surprised when Zoe told me we were running in the red, because business was
79 going so well. My initial thoughts were perhaps our prices were not covering our expenses
80 sufficiently. So, when I saw the Chamber of Commerce presenting a seminar on February
81 26, 2024, on the topic “Realizing Your Full Potential” talking about making your business
82 more profitable, I thought I could sharpen my business sense. The timing was perfect for me
83 to attend the seminar. Zoe had told me about our financial woes the week prior, and the
84 seminar was on a Monday when the restaurant was closed. I attended the presentation and
85 spoke with Jo Walker, an accountant, immediately after the presentation. Walker was one of
86 the speakers at the seminar. A copy of Walker’s curriculum vitae, marked as Exhibit #1, was
87 included in the presentation materials. I hired Walker to do an audit of the business to see
88 where we could improve – perhaps negotiate with vendors more or change our pricing. I also
89 learned during the seminar that restaurants and retail business have a lot of opportunity for
90 employee theft. I wondered if our food inventory was “walking off” with some of the
91 employees in the evenings. So, the following day I purchased a key and padlock to secure
92 the food inventory in our cooler. Exhibit #8 is a copy of the padlock receipt. The only ones
93 who had a key to the padlock were Zoe, John, and me. Zoe told me she thought it was a good
94 idea to use the padlock to protect our inventory in case the employees were helping
95 themselves.

96 7. Jo Walker came out Tuesday, February 27th and did an overview of the restaurant and
97 the financials. I agreed to hire Walker for the two-week audit starting Tuesday, March 5th.
98 Walker required payment in advance. I paid the fee of $6,500 out of my personal funds since
99 the restaurant did not have the cash on hand. When I told Zoe about doing the audit, she did
100 not seem nervous or act suspicious. In retrospect, she always was cool as a cucumber
101 regardless of the situation. I suppose having a poker face was a practiced skill from her
102 gambling experiences. Or maybe she thought she had hidden her tracks well enough that I
103 would not find out she had stolen so much money from the business. I had seen her
104 gambling in action on a dinner cruise once. Later, Zoe played it off as family money lost and
105 it was no big deal. Family money or not, it was hard watching Zoe being urged on by a “friend”
106 known as Morgan, who was causing her to lose more money.

107 8. Business went on as usual those next two weeks during the audit. Zoe came in
108 regularly to do her work as she had in the past. Walker continued to do the audit. When I

Statement: Lane Hill 33 Version 1.2

109 would ask how it was going, Walker would say, “It is a work in progress.” Then on Friday,
110 March 15th, I got the shock of my life. Walker informed me the audit was complete and Zoe
111 had been stealing from the business – nearly $300,000! I was stunned. I could not imagine
112 why she would steal from me – from us.

113 9. I asked Walker for some examples to show me how the theft took place. Walker
114 indicated Zoe was stealing from Southberry’s in a variety of ways. The first way was
115 skimming. There were several instances where one of the waitstaff had a carbon copy of a
116 ticket order in their book, but the order was not included on the cash register tape for the
117 day. Walker showed me an example of this, which is marked as Exhibit #2. Walker showed
118 me check marks on the January 13, 2024 cash-register tape showing the ticket orders.
119 Walker found a ticket order for that day not entered. Walker was not sure for certain if the
120 skimming was attributed to Zoe because someone else could have been managing the cash
121 register at the time. However, when Walker looked at all of the stealing events as a whole,
122 there were events Walker could directly connect to Zoe. For example, certain daily cash
123 register tapes did not match to the deposit made. These deposit slips were written in Zoe’s
124 handwriting, and were part of her normal job responsibilities rather than the responsibility of
125 any other employee at Southberry’s. Walker showed me a deposit slip, marked as Exhibit #3,
126 in the amount of $587.93 on Monday, February 12, 2024. The problem was that the deposit
127 slip did not add up to the cash register tapes from Friday, February 9th in the amount of
128 $2,299.61 and on Saturday, February 10th for $3,089.57. Lastly, Walker found checks written
129 to cash or to Zoe that were shown as void in the check register but cleared the bank. In order
130 to balance the account, another check in the check register was manipulated to increase
131 the payment to cover the amount of the “voided” check made out to Zoe, which is what
132 Walker showed me in Exhibit #4. The Supplies Unlimited entry was for $3,093.45 when it
133 should have been entered as $93.45 according to the invoice. I could not figure how Zoe
134 learned to do this.

135 10. Sure, I was angry at the time when Walker first told me the news. Who would not be
136 angry? I probably even said some things in haste, but I was not angry enough to kill her. It did
137 not even cross my mind! Sure, I said, I was going to make Zoe pay for this – but I meant
138 financially. Zoe would have to find the money to make it right. She had lots of rich relatives
139 to help come up with the money.

140 11. I confronted Zoe about the thefts after Walker left the restaurant. I was angry but
141 controlled. I asked Zoe where the money had gone. She admitted to me she was a gambler
142 and was in a temporary slump the past six months. She said she was in serious debt to a
143 loan shark she called “Lou.” She never mentioned a last name for Lou. Zoe told me she owed
144 Lou over $200,000 and she had already paid over $300,000, most of which came from the

Statement: Lane Hill 34 Version 1.2

145 restaurant. She also had borrowed money from her rich folks to pay off some of her other
146 gambling debts, but her parents told her that it was the last time they were going to bail her
147 out. Zoe explained to me she had become desperate because Lou had threatened to kill her
148 if she did not come up with the money. Zoe described instances where Lou had choked her
149 or put a lit cigarette to her arm. I saw the burn marks on her arm and the bruises on her neck.
150 I do not know how I did not notice them before. This was a whole new world that was foreign
151 to me.

152 12. Yes, I felt betrayed by Zoe, but at the same time, I felt scared and sad for her. She was
153 in serious trouble. Her addiction to gambling ruined a promising career in the restaurant
154 business. Zoe said she could string Lou along a little longer. And in response I said, “No, you
155 need to come up with the money right now, or you could get killed.” Maybe my naïveté was
156 still working overtime, but I thought there might be a way to help her and get the business
157 back on track. I told her I would loan her the money to pay off the debt, and in exchange she
158 had to agree to seek professional help for her gambling addiction. Zoe agreed. I said I would
159 also get her “Just Desserts” partnership interest. Honestly, I was not thinking everything
160 through at the moment because all of this took me off guard. I do not even know how I was
161 going to come up with the $200,000 to help Zoe out of her jam. I was broke. I had put
162 everything into the business and according to Walker, we were going to have to file for
163 bankruptcy.

164 13. You can only imagine how worried I was the week following my conversation with Zoe
165 on the 15th. I kept trying to come up with solutions. I did not sleep a wink after that. I was
166 trying to brainstorm ways to get money for Zoe to get her out of this nightmare. I thought
167 maybe Zoe’s best way to get out of this mess was to turn Lou over to the police for loan
168 sharking. I went on the internet and Googled “loan sharking” and found out her contract with
169 Lou was void under the law. I thought she could go to Lou and say if the loan was not voided
170 according to the law, she would have no choice but to turn Lou into the police department.

171 14. On Saturday, March 23rd, after the dinner crowd and the kitchen staff had gone for
172 the evening around 10:00 p.m., I decided to tell Zoe my solution to her problems. Zoe
173 stepped out of the kitchen door to smoke a cigarette and ignored her cell phone ringing as
174 we walked outside together. I told her I could not think of a way to pay Lou because she had
175 taken so much money out of the restaurant. Southberry’s was bankrupt and would have to
176 be closed. I explained the idea of Zoe telling Lou to void the contract or be turned over to the
177 police. Zoe did not think Lou would be receptive to the idea and we argued over it. Finally,
178 Zoe came to her senses and agreed. I did not see anyone in the alley when we were talking.
179 Besides, we had a quick downpour of rain and were soaked before we got back inside. I never

Statement: Lane Hill 35 Version 1.2

180 reported this conversation to the police after Zoe was murdered because I was afraid if I said
181 anything, Lou would come after me to collect on Zoe’s loan.

182 15. Early April, Detective Haiden asked to meet me at Southberry’s to ask me some
183 follow-up questions and to see the place again. Haiden confronted me with Lou Carboni’s
184 statement. Carboni is lying about me threatening Zoe and “brandishing a knife” – that is
185 ridiculous! Carboni obviously does not want to be nailed for Zoe’s murder. Of course my
186 fingerprints would show up on the kitchen knife, the padlock, and the cooler door.
187 Southberry’s is my restaurant. My fingerprints are all over the restaurant. I worked in the
188 kitchen and would touch all of those things numerous times throughout the day. The kitchen
189 knife would have been washed that evening and run through our sanitizer. I do not know if
190 washing the knife would have eliminated my fingerprints, but I might have picked up the knife
191 after it was washed for food preparation. I do not remember now. If I were going to murder
192 Zoe, why would I do it at the restaurant where we work and leave my fingerprints on a knife?
193 I also never hesitated when Detective Haiden asked me to go down to the station to give my
194 fingerprints. Does willingness to help sound like someone who is guilty? I was arrested on
195 April 5, 2024 for Zoe’s murder.

196 16. The last time I saw Zoe was about 10:30 p.m. on the night of March 23, 2024. I was
197 ready to lock up for the evening, but Zoe was going to stay later and jot down some ideas for
198 next week’s menu. Days after Zoe’s death I found the note she wrote marked as Exhibit #9,
199 which had slipped behind one of the kitchen work stations. The note had her menu ideas for
200 the following week. Back to that night – I started to lock up the cooler, but Zoe told me she
201 would do it because she had to check and see if we had the necessary ingredients for next
202 week’s menu. She said she would lock up the cooler and the back door when she left. As I
203 was leaving through the kitchen back door, I saw a person in the shadows in the alley about
204 50 feet away next to a black Cadillac. The next Tuesday, I returned to the restaurant after a
205 frantic call from Croswell that Zoe had been found dead in the cooler. I provided the
206 investigator on the scene, Detective Haiden, a diagram of Southberry’s, marked as Exhibit
207 #12, which is an accurate representation of the restaurant’s layout, as well as the street and
208 alley. When Zoe was found murdered, I told Detective Haiden about the person I saw. As a
209 result, Haiden showed me some pictures on a tablet, which is when I was able to identify the
210 person I saw as Lou Carboni.

211 17. My legal team was smart to keep a copy of Zoe’s note before turning over the original
212 to the police, which was lost in the evidence room and now Exhibit #9 is the copy and not the
213 original note. Given Detective Haiden’s prior history of evidence tampering, which had been
214 all over the news, I know now why Zoe’s original note, Exhibit #9 disappeared. The folks at
215 the police department probably could have done scientific testing to figure out when Zoe

Statement: Lane Hill 36 Version 1.2

216 wrote the note on the night of her death or gotten her fingerprints. Who knows? Either way,
217 the original note could have provided evidence pointing to my innocence. I am certain Lou
218 Carboni is responsible for Zoe’s murder. I would not and did not kill Zoe. We made amends
219 and were going to figure out a solution together.

220 18. I know the insurance policy for the buy-sell agreement is $500,000, as noted in Exhibit
221 #5. The insurance money has not been issued yet because there is a clause in the buy-sell
222 agreement if a beneficiary under the policy intentionally caused the insured’s death. I did not
223 kill Zoe and that money should be mine. The restaurant never re-opened after Zoe’s death
224 and I am in the hole for substantially more money than ever before. I should have never been
225 arrested for Zoe’s murder. I am the “fall guy” for a mob hit carried out by Lou Carboni and
226 covered up by the corrupt investigator Dee Haiden.

WITNESS ADDENDUM

I have reviewed this statement, and I have nothing of significance to add at this time. The
material facts are true and correct.

Signed,

Lane Hill
SIGNED AND SWORN to me before 8:00 a.m. on the day of this round of the 2025 Mock Trial
Competition.

Michala Watson
Michala Watson, Notary Public
State of Arkansas
My Commission Expires: 4/3/27

Statement: Lane Hill 37 Version 1.2

 Statement of CJ Morgan

1 1. My name is CJ Morgan. I am 27. I grew up in Hartford, Connecticut. I had a rough home

2 life, so I ran away when I was 17. I have moved around a lot since then – mostly down south
3 – and used my charming personality to make ends meet. I am not going to lie to you. I have
4 definitely had my run-ins with the law. In 2017, I was convicted of credit card fraud. I also
5 served time for check fraud in North Carolina in 2018 and again in 2020. In 2021, I was
6 charged with insurance fraud, but the charges were later dropped. About a year or so ago, I
7 left North Carolina because it was getting a little hot for me with the law and some people
8 thought I had scammed them. I swapped one hot place for another and came to Arkansas. I
9 came to Winston looking for a new life. I thought I could put the past behind me and start
10 over. I am shooting straight here – I stole someone’s identification information and got busted
11 for it on March 19, 2024.

12 2. I am serving my time in the county jail because the identity theft charges were not
13 serious enough to land me in the Arkansas Department of Corrections (ADC). When you do
14 time in the local jails, there are always people coming and going for various reasons. My last
15 cell mate got convicted of a fourth DUI and got transported over to ADC to do some serious
16 time, which left me with an empty bed. Lou Carboni got arrested for loan sharking and
17 murder of Zoe Caine. My cell was open, which is where Carboni landed. We had run into
18 each other several times before at some of the clubs. I was looking for an easy target and
19 Carboni was shaking someone down for some money owed. You see, Carboni had a
20 reputation around town as a loan shark – someone who lends money at an excessive rate of
21 interest. I stayed out of Carboni’s way. I could be trusted because I never turned Carboni in.

22 3. Sometime after Carboni was put in my cell, we are chatting you know, like “what are
23 you doing time for” and yadda yadda yadda. Carboni mentions being in for the murder of Zoe
24 Caine. I knew Zoe from some riverboat gambling cruises where we had been at the same
25 tables, but did not know she had been killed. Zoe had one foot in two different worlds, the
26 business world and the gambling world, and she walked a fine line between the two. I met
27 Zoe a while back when she started talking to me on one of the gambling cruises in the bar.
28 She was distraught about some of her losses and had noticed how I was working some of the
29 tables over the evening. One thing led to another and I was telling her about the different
30 ways to scam money from people and businesses without them even knowing. She lit up
31 when I explained how easy it was to skim cash from a business, especially if you knew or
32 controlled who did the bookkeeping. We must have talked for three or four hours that night
33 about various ways to get rich without working – or at least how to pay off your bookie without
34 a lot of hassle.

Statement: CJ Morgan 38 Version 1.2

35 4. I had watched Zoe. She was a maniac. In poker, maniac means a player who plays
36 very loose and aggressive, often raising with almost anything. In the jail cell, Carboni called
37 her a “fish,” a poor player. Carboni said, “I should have had Zoe swimming with the fish a long
38 time ago.” Zoe was on a “tilt,” according to Carboni. A “tilt” is a poker term for a player who
39 has played too long, lost too much money, and no longer has any sense of judgment. Carboni
40 said, “Once you are on a tilt, you are making bad decisions and putting yourself in bad
41 situations.” Well, from my experience with Zoe, she was on a tilt every time I was at a table
42 she played. She had no sense of self-preservation or knowing when to walk away from a
43 losing table. Lady luck never stays long at a table, so you have to know when the house is
44 going to take you for everything.

45 5. Another time I ran into Zoe on a casino dinner lake cruise out of Hot Springs. Zoe and
46 Lane Hill were in Hot Springs for a hospitality and restaurant conference. I kept my distance
47 during the dinner. It looked like they were having a good time. After dinner, I sidled up to Zoe
48 at a Texas Hold ‘em table. I do not know where Hill was at the time. Zoe was on a tilt as usual.
49 I might have been cheering her on that each new hand was going to be her winner. Hill must
50 have walked back up while I was not looking. Suddenly, Hill spun me around and started
51 yelling at me to stop and Zoe had lost enough money. I said, “Hey back off,” and then Hill
52 threw a drink in my face. How rude.

53 6. Sometime later, I made a stop in at Southberry’s. I was hungry and thought maybe I
54 could get a free meal. Zoe recognized me, looking around like she was worried for a second.
55 When she saw her business partner was not in sight, she gave me a hug and seated me in a
56 back-corner table. I asked how business was. Zoe sighed and said business was good, but
57 not good enough to keep up with her “little problem.” I assumed she meant the money owed
58 to her bookie. Zoe may have been dramatic, but she told me she was out of options and
59 thought Carboni was going to kill her for the money. I could tell she was scared and physically
60 shaken. Her statements made me think Carboni was going to kill her. Turns out I was right to
61 think that. I did get an amazing steak dinner out of it. Zoe wondered if going to the police
62 would help in order to get out from under Carboni. I told her going to the police was a bad
63 idea and if she did, Carboni would be even more angry with her than if she simply had trouble
64 making payments. From where I was sitting, I could see into the kitchen area, including the
65 cooler where she later died – what an awful way to go. The restaurant is laid out like the
66 diagram marked as Exhibit #12. When I was heading out of Southberry’s and back up
67 Southberry Square, I know I saw Lou Carboni’s car parked at the edge of the alleyway
68 overlooking the back of Southberry’s. Carboni’s car was a black Cadillac clearly identifiable
69 with custom wheels and racing exhaust. Carboni was never subtle. Carboni always had a
70 habit of staying around where the people who owed money could easily see Carboni was
71 watching over them.

Statement: CJ Morgan 39 Version 1.2

72 7. So anyway, in the jail cell, Carboni starts telling me the whole story about how Zoe
73 was into Carboni for some big money. Carboni mentioned recently learning that Zoe had
74 “bled her business dry and was worthless.” Zoe could not even make payments for the
75 “juice” – the interest on Carboni’s loan. Apparently Carboni overheard Zoe say she was going
76 to threaten Carboni with going to the cops if Carboni did not walk away from her debt. Going
77 to the cops would have been a stupid thing to do. Like some loan shark is going to say, “I’m
78 scared. Please don’t turn me in, and I won’t make you pay me the money you owe me.”
79 Carboni says to me, with no emotion or nothing, like it was another day in the park, “So, I had
80 Zoe iced.” And when Carboni “iced,” it did not mean go to the refrigerator to cool down, if you
81 know what I mean. Carboni stated that the idea was to make Zoe suffer too, because it was
82 no longer about money since Zoe was thinking about turning Carboni in to the cops. So,
83 Carboni described forcing Zoe into a cooler for a slow and cold death.

84 8. Carboni also talked about doing a good job of “cleaning” referring to covering up any
85 tracks left behind to make sure it did not lead back to Carboni. Carboni further described to
86 me how gloves were worn so there would be no fingerprints found. Carboni was not worried
87 at all. Carboni dropped a hint about “having a connection on the inside.” Carboni never said
88 who it was, and I knew better than to ask.

89 9. Carboni did mention that Haiden was the detective investigating Zoe’s murder.
90 Haiden had been my arresting officer on some previous charges, so I knew who Carboni was
91 talking about. Anyway, I never turned Carboni in for loan sharking in the past, but murder is
92 something else. I tried calling Detective Haiden twice to report what Carboni told me, but
93 Haiden never took my calls. Haiden probably did not return my calls because one time I
94 ratted on someone else in jail and I might have gotten some facts mixed up.

95 10. Eventually, after the charges against Carboni were dropped and Zoe’s business
96 partner was arrested, I saw some newspaper articles about the upcoming trial and who the
97 attorneys were for Lane Hill. I reached out to Hill’s attorneys who came to meet me in jail to
98 hear what I had to say. The better side of me came out. I thought I should help an innocent
99 person. Hill was going to take the rap for this, which I could not let happen when I knew the
100 truth.

101 11. You know, I have no reason to lie. What do I get out of this? It is not like I am testifying
102 for the prosecution and getting a reduced sentence. And it is not like Hill has some dough to
103 pay for my testimony. There is no reason for me to make this stuff up. Plus, how would I know
104 so many details? And this lame story about me having to stick with a story once I started
105 down this road is crazy. I am in enough trouble as it is – I do not need perjury on my rap sheet,
106 too.

Statement: CJ Morgan 40 Version 1.2

107 12. I know you have to wonder why Carboni would blabber all of this to a low-life like me.
108 I am a nobody. I think I was a pawn for Carboni. Carboni probably wanted to get the word out
109 on the street that Carboni meant business to instill fear so people would pay their debts and
110 not go to the cops. When you are in the racket, the thing you have going for yourself is the fear
111 factor. I realize now why Carboni was not worried about saying anything to me about killing
112 Zoe. Turns out Carboni was right to be confident about “connections on the inside.”

WITNESS ADDENDUM

I have reviewed this statement, and I have nothing of significance to add at this time. The
material facts are true and correct.

Signed,

CJ Morgan
SIGNED AND SWORN to me before 8:00 a.m. on the day of this round of the 2025 Mock Trial
Competition.

Miriam Easley
Miriam Easley, Notary Public
State of Arkansas
My Commission Expires: 12/08/27

Statement: CJ Morgan 41 Version 1.2

 Statement of Davis Young

1 1. My name is Davis Young and I am 60 years old. I am a criminal justice professor at the
2 University of Arkansas (UofA). I have been back at my alma mater for more than a decade
3 now. After graduating from UofA in 1986, I went on to earn my master’s degree in Sociology
4 at the University of Pennsylvania, as well as my Ph.D. in Criminal Justice. I am also a licensed
5 private investigator in Arkansas. A copy of the abbreviated version of my curriculum vitae is
6 marked as Exhibit #10. Of course, I have had many more publications, such as journal
7 articles, chapters written for books, book reviews, and a host of seminar presentations and
8 lectures. I presume the abbreviated version of my curriculum vitae will demonstrate I am
9 well-recognized as an expert in the study of organized crime.

10 2. Reliable information about organized crime is not always easy to obtain. However, I
11 have devoted my research and teachings to organized crime, including the historical
12 background, theories and research, specific crime groups and their operations, and law
13 enforcement strategies to counter organized crime. I am currently a co-director of the
14 International Association for the Study of Organized Crime (IASOC), which is a professional
15 association of criminologists, researchers, teachers and students. Founded in 1984, IASOC
16 holds meetings in conjunction with the American Society of Criminology. IASOC works to
17 promote greater understanding and research about organized crime in all of its
18 manifestations.

19 3. A significant portion of my research and study has been on the type of crimes –
20 particularly murder – committed by people within organized crime. The underlying crimes in
21 organized crime are the typical selection of preferred mob rackets and methods: loan
22 sharking, sports betting, extortion, income tax evasion, income tax fraud, narcotics, and
23 human trafficking. Intimidation, violence, murder, and obstruction of justice are used to
24 further the goals of people in organized crime. The wise guy life is a sharp and cocky, cash-
25 driven subculture. Sure, they can come across as good fellas, and some are not complete
26 strangers to doing some good, but ultimately gangsters do their deeds through deception,
27 intimidation, violence, and murder.

28 4. Men and women within organized crime have a particular signature when committing
29 crimes, which takes one of two avenues: either committing the crime in such a heinous
30 fashion so as to send a message to other would be wrong-doers against the mob/mafia or
31 skilled use of hiding the crime or their connection to it. An example of the former is with a
32 public warning, such as the public hit on a sidewalk of Paul Castellano allowing John Gotti
33 to become head of the Gambino family.

Statement: Davis Young 42 Version 1.2

34 5. Organized crime’s use of hiding the crimes or their connection to the crime definitely
35 has its own signature. Each mob group has their own preferred style, but often word spreads
36 of another group’s style and sometimes there are copycats among the mob. And, compared
37 to a non-career criminal, it is far more sophisticated and skilled. We have probably all heard
38 of “swimming with the fishes” in which the mob would tie the victim to a cement block and
39 throw them in a body of water. Another popular “signature” method of the mob is to hide a
40 corpse in a false bottom of a casket of another person. Other disposal methods include
41 dismemberment, burial, or placing the body in the trunk of a car and having it crushed in a
42 junkyard.

43 6. One of the more notorious mob men is Richard Kuklinski, who earned the nickname
44 “Iceman” following his experiments with disguising the time of death of his victims by
45 freezing their corpses in an industrial freezer. The condition of the body is sometimes the
46 only means available for the coroner to estimate the time of death. Generally, body
47 temperature is used as an indicator of the post-mortem interval during the first 12 to 24 hours
48 of death. Kuklinski himself claims he used a Mister Softee ice cream truck for this purpose.
49 Later on, he said he got the idea from a hitman named Mister Softee, who drove a Mister
50 Softee truck to appear inconspicuous. Kuklinski’s method was uncovered by the authorities
51 when Kuklinski once failed to let one of his victims properly thaw before disposing of the
52 body on a warm summer’s night, and the coroner found chunks of ice in the corpse’s heart.
53 This methodology gained some popularity among those involved in organized crime in the
54 late 1990’s and into the 21st century. It is still fairly common today to find mob victims frozen
55 in industrial freezers.

56 7. I have reviewed Detective Haiden’s Investigation Report, marked as Exhibit #6. I have
57 also reviewed the autopsy report marked as Exhibit #11 and the diagram of Southberry’s
58 marked as Exhibit #12. In addition, I have seen the receipt for the padlock marked as Exhibit
59 #8 and a copy of the menu notes left behind by Zoe marked as Exhibit #9. It is my
60 understanding that due to the gruesome nature of the photographs of the decedent, these
61 photographs are not part of the evidence of this case with the exception of the photograph
62 of the victim’s dying message to identify her killer, which is marked as Exhibit #7. I did not go
63 to the crime scene, nor have I undertaken any independent physical examinations of the
64 victim or fingerprint analysis. I have, however, been to Southberry’s prior to Zoe Caine’s
65 murder. While I agree that Zoe Caine stole funds from Southberry’s, I am not convinced it is
66 the only reason Southberry’s is in such financial trouble. On the night I was there, I saw some
67 guests in my own dinner party experiencing problems with their meals. To my surprise, Lane
68 Hill, one of the owners, came over to our table and comped the entire table and not just the
69 ones having a problem. Comping entire tables can create large revenue losses and shows a

Statement: Davis Young 43 Version 1.2

70 lack of business sense. If Hill handled issues like ours every time something minor happened
71 with a meal, Southberry’s would be out of business quickly.

72 8. Based upon my review of the foregoing, and my extensive knowledge and expertise in
73 studying criminal behavior in organized crime, it is my opinion Zoe Caine was murdered by a
74 person involved in organized crime. The spreadsheet found by police at the home of Zoe
75 Caine showed payments made to Lou Carboni. Injuries on Zoe Caine’s body reinforce having
76 received previous “warnings” to pay. Late payments were punished in typical fashion by the
77 mob with cigarette burns and strangulation, both known signatures of Lou Carboni. Lou
78 Carboni somehow must have found out that Caine’s restaurant was going bankrupt. Caine
79 became a liability for Carboni, rather than a source of revenue, and even more so if Carboni
80 thought Caine would turn Carboni in to the cops.

81 9. I am familiar with Lou Carboni, who denies being a part of organized crime even
82 though this is clearly not the case. While Carboni is a money collector and/or minor enforcer,
83 Carboni is not important enough to order a hit or to follow through on a hit. Killing someone
84 would come from further up in the organization. In addition, organized crime tends to keep
85 money collectors far separated from those who carry out the hits.

86 10. The methodology used in this crime is also consistent with a mob hit. The use of an
87 industrial freezer or cooler to hide the victim’s time of death and the “cleaning” of the crime
88 scene is indicative of a sophisticated skill level of crime inherent in organized crime. This
89 method is completely inconsistent with the method and mode of a person committing a
90 crime in the heat of passion. Had Hill murdered Caine in rage over, say, theft of funds from
91 the business, a quick death would be more likely at the sharp end of a knife. This is what
92 happens when a person snaps in the moment – picking up the closest available weapon and
93 killing another person. In the case of a restaurant, knives are both plentiful and available. The
94 average person committing a crime of passion or in the heat of the moment would not lock
95 someone in a cooler, because said person would then have ample time to cool off (no pun
96 intended), calm down, and let the victim back out of the cooler before death became
97 imminent. With most people, “in the heat of the moment” is just that, not rational thought
98 but rather done on murderous impulse. Once the impulse is gone, regret and anguish take
99 over. Had Hill locked Caine in the cooler in rage over the theft of funds from the business, Hill
100 would have had a clear cool down period in which to reevaluate the situation and let Caine
101 out of the cooler prior to her death. In addition to that, a heat of the moment argument would
102 only be valid for March 15th when Hill first confronted Caine about the theft of funds. A full
103 week later, the impulse to kill would not remain, and especially not in such a slow and
104 agonizing way. This is the type of killing meant to send a message to others, and the message
105 is pay up or suffer horrifically.

Statement: Davis Young 44 Version 1.2

106 11. I am also extremely critical of the police investigation in this matter. I have done a
107 significant amount of research in the study of corruption in law enforcement. One reason the
108 mafia and mobs have survived and thrived for so many years is, in part, because of a few
109 corrupt police officers, who have lost or tampered with evidence, or tipped off the mob.
110 Detective Haiden should never have been assigned to investigate this case. Detective
111 Haiden was previously accused of tampering with evidence involving a bribe from Lou
112 Carboni, which on its face value makes Haiden suspect in my mind for any case in which
113 Carboni and Haiden could intersect. I am unconvinced Haiden exerted independence when
114 first arresting Carboni. The charges were later dropped and, I believe, it could have easily
115 been a ruse to throw us off. This entire murder investigation was compromised due to
116 Haiden’s involvement.

117 12. I have been paid $3,000 to render an expert opinion in this case. I came into the case
118 with no preconceived notions, and strictly looked at the facts as presented. I have spent a
119 total of four hours reviewing evidence, and then I have additional time incurred in providing
120 this statement as well as my testimony in court. I have testified in numerous cases in which
121 organized crime may be a factor. I have testified both for the prosecution and the defense.
122 Normally, my rate is $5,000 to render an expert opinion, but because I went to school with
123 one of the attorneys for the defense, I have discounted my rate as a professional courtesy.

WITNESS ADDENDUM

I have reviewed this statement, and I have nothing of significance to add at this time. The
material facts are true and correct.

Signed,

Davis Young
SIGNED AND SWORN to me before 8:00 a.m. on the day of this round of the 2025 Mock Trial
Competition.

A.G. Molli
A.G. Molli, Notary Public
State of Arkansas
My Commission Expires: 12/15/27

Statement: Davis Young 45 Version 1.2

 JO WALKER, CPA, CFE
513 South Main Street, Winston, Arkansas

Education
University of Arkansas
B.S. in Accounting – May 1981 Cum Laude, 3.75
Beta Alpha Psi - Accounting Major Honorary, Treasurer Top Accounting Student
Beta Gamma Sigma – Business Honorary Luca Pacioli Award

Certifications
Certified Public Accountant June 1981 to present
Certified Fraud Examiner June 2003 to present

Employment
Account-Abilitee, CPAs (owner) June 1984 – present
513 South Main Street, Winston, Arkansas
Full service accounting firm, providing a variety of accounting services to our clients including,
bookkeeping, general accounting, audit, tax management and preparation, personal financial planning,
and business valuation. Specialization in forensic accounting, conducting forensic investigations, utilizing
my accounting, auditing, and investigative skills. Instrumental to numerous investigations detecting
accounting fraud.

Arthur Andersen CPA May 1981- May 1984

33 W. Monroe, Chicago, Illinois
Manager. Consumer and Business Products Auditing Division. Audited financial statements of clients and
responsible for management of audit team. Promoted rapidly.

Memberships
Association of Certified Fraud Examiners (ACFE)
American Institute of Certified Public Accountants (AICPA)
AR Association of Certified Public Accountants (ARACPA)

Continuing Education
E-Fraud: Preventing and Detecting Technology-Based Crimes (ACFE; July 2023) Co-presenter
Money Laundering: Tracing Illicit Funds (ACFE; July 2022)
Advance Fraud Examination Techniques (ACFE; July 2021)
Computers in Fraud (ACFE; July 2019)
Contract & Procurement Fraud (ACFE; July 2018)
Auditing for Internal Fraud (ACFE; July 2017)
Fraud Prevention (ACFE; July 2016)
Investigating by Computer (ACFE; July 2015)
Conducting Internal Investigations (ACFE; July 2014)
Auditing for Internal Fraud (ACFE; July 2013)
Principles of Fraud Examination (ACFE; July 2012)
Building Your Fraud Examination Practice (ACFE; July 2012)

Exhibit 1 46 Version 1.2

 Southberry’s
1/13/24
1 Tuna Tartar $8.95
1 Bruschetta $4.95 01-13-24
1 Lettuce Wedge Salad $4.45 ✓ 96.34
1 Lettuce Wedge Salad $4.45 ✓ 83.24
1 Pork Medallions $19.95 ✓ 164.32
1 Chilean Sea Bass $21.95 ✓ 54.80
1 Roasted Asparagus $5.95 ✓ 97.66
1 Glass House Merlot $6.95 ✓ 123.76
1 Glass House Chardonnay $5.95 ✓ 114.93
1 Mini Baked Alaska $5.95 ✓ 82.54
1 Chocolate Cake $5.95 ✓ 66.44
✓ 79.91
Sub-Total $95.45 ✓ 85.56
SC Tax 5.73 ✓ 99.33
Total 101.18 ✓ 58.75
Tip ________ ✓ 93.99
Total ________ ✓ 65.00
✓ 74.45
✓ 92.34
✓ 123.98
✓ 78.78
✓ 116.43
✓ 224.56
✓ 95.87
✓ 183.24
✓ 48.56
✓ 64.34
✓ 114.56

✓ 2583.68

Exhibit 2 47 Version 1.2

 DEPOSIT
Coins 43.00 Saturday, 02-10-18
Southberry’s Cash 325.00 ✓ 36.54
Acct# 34533245 Checks 219.93 ✓ 46.78
Sub-Total 587.93 ✓ 86.98
Date: Less Cash Received 0 ✓ 99.00
Feb. 12, 2024 Total 587.93 ✓ 78.84
✓ 83.45
Fast South Bank, Winston, AR ✓ 92.34
✓ 77.44
Friday, 02-09-18 ✓ 154.36
✓ 39.65 ✓ 178.67
✓ 92.34 ✓ 183.77
✓ 99.00 ✓ 92.34
✓ 114.32 ✓ 144.68
✓ 178.67 ✓ 114.32
✓ 154.36 ✓ 86.45
✓ 86.45 ✓ 48.56
✓ 119.60 ✓ 93.25
✓ 45.54 ✓ 87.36
✓ 92.34 ✓ 136.45
✓ 136.45 ✓ 119.60
✓ 78.84 ✓ 98.46
✓ 91.70 ✓ 85.16
✓ 85.16 ✓ 48.56
✓ 123.55 ✓ 92.34
✓ 48.56 ✓ 178.67
✓ 78.84 ✓ 123.98
✓ 93.25 ✓ 91.70
✓ 44.21 ✓ 67.18
✓ 116.87 ✓ 93.25
✓ 46.78 ✓ 45.54
✓ 90.91 ✓ 123.55
✓ 143.22
✓ 99.00 3089.57

2299.61

Exhibit 3 48 Version 1.2

 Southberry’s #1099
38 Southberry Square, Winston, AR 29469

Date 02/27/24
Pay to the
Order of: Zoe Caine $ 3,000.00

Three thousand and 00/100 Dollars

Memo Zoe Caine

:548200: 648752: 01099

CHECK REGISTER
Transaction Payment Deposit,
Number Date ✓ BALANCE
Description Fee/Withdrawal Credit
11,345.22
1094 02/21/24 Let Us Produce 165.00 11,180.22

1095 02/21/24 Meat Market 465.00 10,715.22

1096 02/22/24 Vineyard Wines 455.85 10,259.37

02/22/24 Deposit 825.36 11,084.73

02/23/24 Deposit 923.45 12,008.18

1097 02/23/24 Laundry Time 122.35 11,885.83

02/24/24 Deposit 654.92 12,540.75

1098 02/27/24 Supplies Unlimited 3,093.45 9,447.30

1099 02/27/24 ** Void ** 9,447.30

1100 02/28/24 Let Us Produce 128.00 9,319.30

Exhibit 4 49 Version 1.2

 PARTNERSHIP CROSS-PURCHASE WITH BUY-SELL AGREEMENT

This Agreement is made June 14, 2021, by and between Lane Hill and Zoe Caine.

WHEREAS, the above-named individuals are partners doing business under the incorporated name
of Southberry’s, LLP at 38 Southberry Square, Winston, AR 29469, the respective partnership interests of
the partners being divided equally; and
WHEREAS, the partners desire to ensure the continuity of harmonious management of the
partnership by providing for the purchase of a partnership interest by the other partner in the event a
partner dies;
NOW THEREFORE, in consideration of the premises and mutual covenants contained herein, it is
agreed by and between the parties as follows:
FIRST: Upon the death of a partner, the surviving partner shall purchase and the legal
representative of the estate of the deceased partner shall sell to such surviving partner, the partnership
interest owned by the deceased partner for the price established in accordance with the provisions of
the SECOND and FOURTH Article.
SECOND: Unless and until a new value is established as herein provided, the value of the respective
partnership interest of the partners for purposes of this agreement is $100,000 each. At the end of each
fiscal year, the partners shall agree upon the value of their respective shares. If the partners have not
made such determination within two years of the death of a partner, an independent certified public
accountant shall determine the value of the deceased partner’s interest.
THIRD: In order to assure the availability of funds for the purchase of the partnership interest of a
deceased partner by the surviving partner, the partnership has purchased insurance on the lives of each
partner. The value of insurance on each of the partners shall be set initially at $500,000. Payment of
these policies shall be made from the LLC corporate accounts. The partners may purchase additional
insurance as deemed necessary.
FOURTH: Upon the death of a partner, the other partner may immediately collect the proceeds of
the policy on the life of the deceased partner. If the proceeds of all the policies on the life of the
deceased partner are not sufficient to purchase the deceased partner’s interest, the surviving partner
shall be obligated to pay the remaining balance to the deceased partner’s estate. If the proceeds of all
the policies on the life of the deceased partner are in excess of the purchase price of the deceased
partner’s interest, the surviving partner shall be entitled to any excess funds.
FIFTH: Should the death of one partner occur at the hand of the other partner, then the surviving
partner shall be excluded from any benefits laid out herein.
UPON PAYMENT of the purchase price of the partnership interest of the deceased partner the legal
representative of the estate of the deceased partner shall execute and deliver to the surviving partner
such instruments as shall be necessary to transfer complete title to the surviving partner.
IN WITNESS WHEREOF, the partners have executed this agreement the day and year first herein
above written.

Zoe Caine 6/14/21 Lane Hill 6/14/21

Exhibit 5 50 Version 1.2

 AGENCY ID WINSTON POLICE DEPARTMENT INCIDENT #
SC04719 Winston, Arkansas (501) 555-1234 47-108290911

INCIDENT REPORT
PRINT OR TYPE ALL INFORMATION
INCIDENT TYPE FORCED ENTRY PREMISE UNITS
COMPLETED TYPE VICTIM
TYPE ENTERED
Homicide – Body located in locked cooler 
YES NO YES NO Bus. 1 Individual

Business
 Government
YES NO YES NO  Other

INCIDENT LOCATION (SUBDIVISION, APARTMENT AND NUMBER, STREET NAME AND NUMBER) ZIP CODE WEAPON TYPE
38 Southberry Square – Southberry’s Restaurant 29469 N/A
EVENT

INCIDENT DATE 24 HOUR CLOCK TO DATE 24 HOUR CLOCK

03/27/24 07:30 03/27/24 12:45

VICTIM’S NAME (LAST, FIRST, MIDDLE) DATE OF BIRTH HEIGHT WEIGHT

Caine, Zoe (deceased) 05/13/82 5’3’’ 115 lbs.

ADDRESS CITY STATE ZIP CODE

169 King Charles Road Winston AR 29469

NAME (LAST, FIRST, MIDDLE) AKA
SUBJECT NO.1

FACIAL HAIR, SCARS, TATOOS, GLASSES, CLOTHING, PHYSICAL PECULARITIES, ETC.

ADDRESS CITY STATE ZIP CODE

SUBJECT (NO.1) USING: ARRESTED NEAR OFFENSE SCENE DATE / TIME OF OFFENSE DATE / TIME OF ARREST
ALCOHOL YES NO UNKNOWN YES NO
DRUGS YES NO UNKNOWN

3/27/24 – 08:00 - Called to the scene by Winston PD’s patrol office because of suspected homicide. Victim’s body

discovered lying on floor of restaurant’s cooler by restaurant cook, John Croswell.

NARRATIVE

03/27/24 – 08:30 – Arrived on scene. Controlled and assessed scene. Diagram of restaurant is a separate document.

Body does not appear to have been moved or compromised. Victim appears to have died from hypothermia; the body is pale

and waxy. There appears to be no recent outward signs of physical trauma to victim or evidence of physical disturbance in

cooler or restaurant. Will wait for conclusions of autopsy. Body lying on floor of restaurant cooler next to bacon spelling
TYPE (GROUP) TOTAL VALUE
PROPERTY

STOLEN
DAMAGED
BURNED
RECOVERED
SEIZED
SUBJECT IDENTIFIED SUBJECT LOCATED
 YES

 NO NO 
 ACTIVE
 UNFOUNDED
 ADM. CLOSED  ARRESTED UNDER 18
 ARRESTED 18 AND OVER
 EX-CLEAR UNDER 18
 EX-CLEAR 18 AND OVER
ADMINISTRATIVE

REASON FOR EXCEPTIONAL CLEARANCE: 1.  OFFENDER DEATH. 2.  NO PROSECUTION 3.  EXTRACTION DENIED

4.  VICTIM DECLINES OPERATION 5.  JUVENILE NO CUSTODY
REPORTING OFFICER DATE 24 HR CLOCK APPROVING OFFICER DATE UNIT NUMBER

Inv. D. Haiden 04/05/24 17:23 Lt. Solomon 04/05/24 4618

FOLLOW-UP INVESTIGATION REQUIRED

 YES  NO

Exhibit 6 51 Version 1.2

 AGENCY ID WINSTON POLICE DEPARTMENT INCIDENT #
SC04719 Winston, Arkansas (501) 555-1234 47-108290911

SUPPLEMENTAL INVESTIGATION REPORT

PRINT OR TYPE ALL INFORMATION)
DATE 03/27/24

“Killer” and the start of another letter. Victim holding an additional slice of bacon in hand next to bottom of last letter –

appears to attempt to spell another letter. Victim shows signs of non-recent physical trauma – ¼” round burn marks on inside
of right arm; bruising on neck consistent with someone grabbing her at neck. Victim also shows bruised hands from
attempting escape from the locked cooler. No evidence of break-in at restaurant. Inspected the premises and nothing was

out of order. Purse, keys, wallet, and cell phone of the victim were in her desk drawer. Nature of death, use of cooler, is

consistent with mob hit.

03/27/24 – 09:20 – Interviewed Croswell and other kitchen staff. Victim was co-owner of restaurant. Witnesses state
victim’s body had not been moved prior to my arrival. Croswell arrived at restaurant through an unlocked kitchen back door at
07:15. No sign of disturbance noted by witness. Approximately 15 minutes later, Croswell unlocked padlocked door to
cooler and discovered body and called 911 and Lane Hill. Only Croswell and restaurant owners, Zoe Caine and Lane Hill,
have keys to lock doors to restaurant and cooler. Padlock is new to cooler and staff. Some inconsistency in remembering to
SUPPLEMENTAL NARRATIVE

lock cooler at the end of the day. Croswell and kitchen staff do not know who would want to harm Caine. Kitchen staff
observed someone lurking in alley across the street frequently, and most recently on Saturday, March 24th. Victim was seen
and heard from last on the evening of Saturday, March 24th at Southberry’s up until closing time. Several witnesses
observed (now identified) Carboni in alley across from back of restaurant door for a couple of weeks.

03/27/24 – 10:00 – Interviewed Lane Hill, co-owner of Southberry’s. Hill was last to see Caine at 22:30 on March
24th at Southberry’s. According to Hill, on Saturday, Caine stayed behind to make notes for the following week’s menu.
No such note was located. Caine was going to look at inventory in cooler and then intended to padlock cooler door when
leaving. Hill states the cooler door was not locked before leaving. Hill had recently purchased a padlock for the cooler, due
to concerns of employee theft. Keys for the restaurant and cooler padlock were distributed only to Croswell, Caine, and
Hill. As Hill was leaving the restaurant March 24th, Hill noticed a person standing in the shadows in the alley across the
street next to a black Caddy. After being shown a photo array on the investigator’s tablet, Hill identified the person as Lou
Carboni. Hill stated about recently hiring a forensic accountant, Jo Walker, to determine cause for company’s
financial struggles despite steady business. Walker’s investigation revealed Caine had been skimming from the business. Hill
questioned Caine about thefts on Friday, March 16th. Caine explained to Hill she liked to gamble, but had been unlucky
lately, and thus, had borrowed money from a loan shark, Carboni. Caine owed Carboni over $200,000. According
to Hill, Caine had been physically accosted with cigarette burns on the arm, and had been choked by Carboni to come
up with past due payments. So, Caine took money from the business. According to Hill, Caine said she had become
REPORTING OFFICER DATE 24 HOUR CLOCK SUPERVISING OFFICER

Inv. D. Haiden 04/05/24 17:23 Lt. Solomon

Exhibit 6 52 Version 1.2

 AGENCY ID WINSTON POLICE DEPARTMENT INCIDENT #
SC04719 Winston, Arkansas (501) 555-1234 47-108290911

SUPPLEMENTAL INVESTIGATION REPORT

PRINT OR TYPE ALL INFORMATION)
DATE 03/27/24

desperate to pay off the debt because her life had been threatened by Carboni. Hill offered to give Caine a
personal loan to pay off the debt if Caine sought help for her gambling addiction.

03/27/24 – 11:30 – Interviewed remaining restaurant staff. Consistent statements as offered by kitchen staff. No one

had seen Caine since Saturday evening, since the restaurant was closed on Sunday and Monday.

03/27/24 – 12:45 – Went to victim’s residence. No disturbances to residence. Unopened mail from Saturday, March 24th
and newspapers from Sunday, Monday, and Tuesday were lying on front steps undisturbed. Voicemail messages
unretrieved on cell phone and home phone from Saturday thru present. No unusual calls or mail. Saw printout of computer
spreadsheet of debt owed specifically to Lou Carboni showed balance of $208,500.
SUPPLEMENTAL NARRATIVE

03/30/24 – Autopsy results show death caused by hypothermia. Bruising to hands noted. Likely from banging on cooler
door. No other physical trauma relating death noted. Exact time of death cannot be determined through physical
examination of the body since it was not frozen. Autopsy dates cigarette burns to have occurred two weeks prior to death
and strangulation of neck, non-life threatening, to have occurred less than one week prior to death.

03/30/24 - 13:30 – Carboni was read Miranda rights. Carboni refuses to make statement, and requests to have lawyer
present. Carboni was arrested for loan sharking and murder.

03/30/24– 17:20 – There were some smudged and clear fingerprints found. Carboni’s fingerprints were not found on
padlock to cooler, cooler door, or doors to restaurant, per fingerprint analysis.

03/31/24 – 11:00 – Carboni, in presence of counsel, provided statement. Caine owed Carboni over $200,000 due to

gambling losses. Carboni says Caine was making payments and had been tailing Caine to make sure she did not skip
town. Carboni was present the night of March 24th in alley across the street from Southberry’s back door to restaurant
starting from about 21:00 until approximately 23:30. Carboni observed Hill arguing with Caine and telling her she ruined the

business, and Southberry’s was bankrupt and would not be able to continue to operate. Then Carboni saw Hill brandish a
kitchen knife and point it at Caine making her go back into the restaurant. Carboni later saw Hill leave alone at 22:30.
Carboni waited for another hour and left. Caine never left while Carboni was there.
REPORTING OFFICER DATE 24 HOUR CLOCK SUPERVISING OFFICER

Inv. D. Haiden 04/05/24 17:23 Lt. Solomon

Exhibit 6 53 Version 1.2

 AGENCY ID WINSTON POLICE DEPARTMENT
INCIDENT #
SC04719 Winston, Arkansas (501) 555-1234
47-108290911
SUPPLEMENTAL INVESTIGATION REPORT
PRINT OR TYPE ALL INFORMATION)
DATE 04/02/24

04/02/24 – 10:15 – Interviewed Jo Walker. Confirmed had undertaken forensic accounting investigation at the request of
Hill due to financial struggles in the restaurant business. Walker stated the audit began on March 6, 2024 and completed
the work on March 16th. Walker discovered Caine had been skimming from Southberry’s. Total sum stolen by
Caine was $273,958. Walker stated Hill appeared enraged when learning of the theft and Hill said “Caine would pay for
this.” Walker overheard Hill confronting Caine later on the 16th and Caine would get her “just desserts.” Walker also
overheard parts of a phone conversation between Caine and unknown person making promises for payments and threats
being made.” Walker was questioned further about financial aspects of Southberry’s. The restaurant is insolvent.
Walker advised Hill the business would need to be closed. Walker stated that Hill is the beneficiary of a $500,000
insurance policy for a buy-sell agreement for a deceased partner’s interest in the business.

04/02//24 – 14:30 – Met Hill at Southberry’s for additional questioning. Confronted with Carboni’s statement. Hill was
SUPPLEMENTAL NARRATIVE

adamant it was all lies, and it was Carboni’s way of escaping murder. Several paring knives and one 10” knife were located
in the kitchen. Knives were collected and sent to the lab for fingerprint analysis. Hill consented to go to the station to
provide fingerprints on the same day.

04/04/24 – Additional fingerprint analysis results received. Fingerprint analysis shows Hill’s fingerprints are on padlock
to cooler, cooler door, and the kitchen knife with a ten inch blade.

04/05/24 – 16:00 – Carboni released. Hill arrested.

REPORTING OFFICER DATE 24 HOUR CLOCK SUPERVISING OFFICER

Inv. D. Haiden 04/05/24 16:50 Lt. Solomon

Exhibit 6 54 Version 1.2

Exhibit 7 55 Version 1.2
 Winston Lock & Key
531 Veterans Highway
Winston, AR 29469

02/27/24 12:33 pm

1 Lg. Padlock w/ Key $ 19.49

2 Extra Keys $ 1.98

Subtotal $ 21.47

Tax (7%) $ 1.50

Total $ 22.97

Cash Paid $ 23.00

Change $ .03

Thank you for letting

us serve you.
Come again.

Exhibit 8 56 Version 1.2

 Stuffed eggplant with house Pomodoro sauce

Jumbo lump crab cakes and marinated

portobello mushroom stacks

Beef tenderloin medallions tartar drizzled with

balsamic cream sauce and blue cheese crumbles

Parmesan crusted sea scallops with

with a garlic butter and white wine reduction
sauce

Zoe

Exhibit 9 57 Version 1.2

 DAVIS YOUNG, PH.D.
CURRICULUM VITAE

Education
University of Pennsylvania
Ph.D. in Criminal Justice 1990
M. A. in Sociology, 1988
University of Arkansas
B.A. in Sociology, magna cum laude 1986

Present Positions
Criminal Justice Professor, University of Arkansas
University of Arkansas, 2006 – present, Department Chair, 2016 – present

Co-Director International Association for the Study of Organized Crime

New York, New York 2007 – present

Prior Academic Appointments

Professor, Department of Criminal Justice
University of Pennsylvania, Pennsylvania 1995 – 2006

Assistant and Associate Professor, Department of Criminal Justice

Temple University, Pennsylvania, 1990 – 1995

Memberships and Positions:

International Association for the Study of Organized Crime (IASOC), 2007 – present
Consultant, National Criminal Justice Commission, 2012 – 2014
American Society of Criminology, President 2009 – 2012
Task Force on Law and Enforcement, President’s Commission on Organized Crime, 2004 – 2012

Honors and Awards

Distinguished Leader in Criminal Justice, Academy of Criminal Justice Sciences
American Society of Criminal Justice, Fellow 2006 – present
Fulbright Research Fellowship, 2000 - 2001
Special Dissertation Research Grant, University of Pennsylvania 1990
Graduate School Fellowship, University of Pennsylvania 1988 - 1990

Publications
No Law and Order: Organized Crime New York: John Wiley, 2016
Wiseguys Finish First New York: John Wiley, 2011
Kuklinski: The Iceman Cometh New York: Harper & Row, 2008
Organized Crime: A Study in Methodology of Crimes Simon and Schuster, 2006
Bent Cops and Tampered Evidence Indiana University Press, 1990

Exhibit 10 58 Version 1.2

 STATE OF ARKANSAS – NATURAL COUNTY BUREAU OF INVESTIGATIONS
DIVISION OF FORENSIC SCIENCES - RECORD OF CORONER
Name of Deceased Zoe Caine County Ross
Age 35 Height 63” Weight 115 lbs. Date of Birth 05/13/88
Time of Death Undetermined Date of Death 03/26/24
MANNER OF DEATH
( ) Natural ( X ) Homicide ( ) Suicide ( ) Accident ( ) Undetermined ( ) Other
PURPOSE OF REPORT
( X ) Autopsy ( ) Limited Dissection ( ) External Exam ( ) History Review
PERFORMED BY Chandler Covington, M.D. Date 03/28/24 Hour 12:05pm
APPROVED Stephan Bonner, M.D. Date 03/29/24
CAUSE OF DEATH
Initial Examination: The body is that of a female adult, approximately 63” in height, and weighing 115 lbs.,
consistent with the stated age of 35 years.
Autopsy Findings: In careful review of the body, there were no signs of struggle with another individual or
physical violence. The body did appear pale and waxy. Upon collection of the body, the body temperature was
at 35 degrees Fahrenheit. Based on the temperature of the body and location of where the body was found in
a restaurant cooler, it is determined that Ms. Caine died as a result of hypothermia. Hypothermia is the
reduced body temperature that happens when a body dissipates more heat than it absorbs. In humans, it is
defined as a body core temperature below 95 degrees Fahrenheit. For Ms. Caine’s weight, it most likely took
more than 20 hours before the hypothermia was severe enough to kill Ms. Caine. And, based upon the actual
body temperature at time of discovery, it was likely Ms. Caine had been in the cooler more than 50 hours.
Additional Notes: Previous injuries were noted to include cigarette burns on inside right arm in the healing
process occurring approximately two weeks prior to death along with fading bruises from what appears to be
forced choking around the base of the neck occurring approximately a week prior to death. Neither the
cigarette burns, nor the choking occurred in relation to her death. She did; however, have bruising on her
hands, which were most likely from banging against a blunt object such as the door to the cooler in which she
was found.
Cardiovascular: The heart is normal size and weight for patient’s age and appears structurally normal.
Respiratory: The lungs appear to be normal size/weight. Tissue is abnormal due to smoking.
Hepatobiliary: The liver appears to be normal.
Gastrointestinal: The typically formed tongue, esophagus, gastroesophageal junction, serosal stomach
and gastric mucosa are without note. The stomach, large bowels, and small bowels appear normal.
Toxicology: Nothing abnormal found in blood system.
Other Procedures:
1.
Documentary photographs obtained.
2.
Blood, urine, bile, and vitreous are submitted for toxicological analysis.
3.
Head and body hair is submitted.
4.
Clothing is submitted for volatile determination.
Autopsy Findings: At the time of death, this was an otherwise healthy 35-year-old except for smoking.
Cause of Death: Hypothermia / Homicide

Exhibit 11 59 Version 1.2

 38 Southberry Square

Exhibit 12 60 Version 1.2