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On 22 August 2016 the State filed a Conditional Application for Limited Remand, asking that if Adnan's cross-appeal was granted, could the case first go back to the Circuit Court as they had new evidence they wanted to submit. The State alleges that two sisters from Woodlawn High School have recently come forward to say they had knowledge in 1999 that Asia intended to lie for Adnan. Included with the application was an "Attachments" document. COSA did not publish this document, it was made public after the State provided a copy to Justin Fenton of the Baltimore Sun.


Observations about the Attachments file

(or just skip to the Index)

The structure of the Attachments file is rather unusual. It contains 60 documents in total, but unusually it is presented as 12 "Attachments" rather than as the 60 base documents. Each Attachments contains between 1 and 21 separate documents, including 5 that are repeated. There are 12 Attachment coversheets which do list the documents within them, but there is no overview, no contents page or index, and no page numbering. This all makes it difficult to navigate, which is why there is a need for a separate wiki page.

Many pages have markings such as A-0369 or B-0118. These relate to the two folders of evidence which the State submitted to the February 2016 PCR hearing. Folder A appears to be the files of defense attorney Gutierrez and Folder B from the Baltimore Police files. The State successfully argued that Undisclosed's use of trial attorney Gutierrez' files meant that Adnan's client privilege had effectively been waived and so they were submitted lock stock into evidence. They also included files of Chris Flohr, Adnan's attorney immediately after the arrest and for bail hearings. Because the State had introduced so many documents into evidence at the 2016 hearing, the press were swamped and did not report/display many of them despite the public interest.

The State's Remand brief and exhibits are, nominally, intended to persuade COSA that there is sufficient strong new evidence to deserves a Remand to the Circuit Court (instead of, say, bringing it to a retrial?). Intriguingly these Attachments mark a turning point in the State's publication strategy. They contained 60 separate documents, which outnumbers any earlier appeal filing (max 7), but also earlier State filings tend not to include documents which are established as part of the Court record. The largest previous State Exhibits file, accompanying the Sept 2015 Consolidated Reply has just 5 exhibits but references 19 already-on-the-record files. In these Remand Attachments, only 1-3 are not already in the COSA record, just 8 files, or 11 / 122 total pages (ignoring the 12 coversheets). Those 11 pages were also new to the public, and featured heavily in subsequent press coverage.

Taking a look at the Attachments from another perspective, 20 files or 41 / 122 pages were revealed here for the first time to the public and press, although they were already on the Court record (ie not the new to the relating to the Sisters). So, in terms of audience novelty, these Attachments have nearly four times as many pages directed purely at the public/press as were directed at the nominally intended audience, the Court of Special Appeals.

One other page had been tweeted, then deleted by Fenton in Feb 2016, the same journalist who publishes these files for the State and also the Consolidated Reply Exhibits and somewhat surreptitiously, the recent State Brief which combined their Appeal Reply and Cross Appeal (Appellee response) filings to COSA


Index of individual documents

The files making up the Attachments are listed below using the descriptions as given by the State. If a copy was already on the wiki we have linked to that, rather than hosting multiple copies of the same files.


As mentioned above, Attachments 1, 2 and 3 are not part of the Court of Special Appeals record but all other documents already were. So the annotation NEW solely indicates that documents were newly released to the public and the press in this filing.

Attachment 1


Attachment 2


Attachment 3


Attachment 4

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Attachment 5


Attachment 6

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Attachment 7

1. First Search of Adnan's Vehicle

2 Search of Adnan's Family Residence,

3. Second Search of Adnan's Vehicle

4 Adnan Syed's Person, (blood and hair samples)

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Attachment 8


Attachment 9

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Attachment 10


Attachment 11

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Attachment 12


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