Filed: 10/30/2024 9:21 AM

Carroll Circuit Court

Carroll County, Indiana

STATE OF INDIANA ) IN THE CARROLL CIRCUIT COURT 1

)SS:
COUNTY OF CARROLL) CAUSE NO.08C01-2210-MR-000001
)
STATE OF INDIANA )
)
v. )
)
RICHARD ALLEN )

THE ACCUSED’S SECOND MOTION TO ADMIT EVIDENCE OF ODINISM/

NORSE PAGANISM/ RITUALISTIC KILLING AND ALSO MOTION TO
ADMIT EVIDENCE CONCERNING ELVIS FIELDS AND BRAD HOLDER AS
THIRD-PARTY SUSPECTS

Comes now the accused, Richard Allen, by and through counsel and moves

this Court to admit certain evidence that this Court thus far has prevented the

defense from presenting to the jury, pursuant to its September 4, 2024, order

granting the State of Indiana’s April 29, 2024, Motion in Limine. In support of

said motion, the defense states the following:

1. On October 23, 2024, the defense has previously filed his first “Motion to
Admit Evidence of Odinism/Norse Paganism/Ritualistic Killing.

2. Since that motion was filed, additional evidence has been elicited through
testimony and other evidence that further opened the door to the
admission of Odinism/Norse Paganism/Ritualistic Killing.

3. Also, since that October 23, 2024, motion was filed, additional evidence
has been elicited through testimony and other evidence that opened the
door for the defense to bring in evidence that third party suspects Elvis
Fields and Brad Holder were involved in the killing of the victims.

Additional evidence admitted during trial that supports introduction of

Odinism/Norse Paganism/Ritualistic killing evidence

4. On Wednesday October 23, 2024, forensic pathologist Kohr testified that:

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 a. Possibly 2. Possibly 3. Possibly 4 instruments were used to cut the
necks of Abigail Williams and Liberty German.
b. That in his autopsy report Dr. Kohr believed that some cuts may
have involved the use of a serrated instrument, and other cuts may
have involved the use of a non-serrated instrument, providing the
possibility that more than one person was involved in the murders.
c. During his testimony, Dr. Kohr backtracked somewhat, but still did
not exclude the possibility that the injuries to Abigail Williams and
Liberty Williams were caused by both a serrated and a non-serrated
instrument.

5. Also, since the trial began, the prosecution admitted certain crime scene
photographs into evidence, including photographs of the crime scene in
which the sticks on the girls were clearly visible to the jury, allowing the
defense to ask questions concerning the sticks on the girls.

6. Any competent trial lawyer would ask a variety of questions concerning

the unusual way that the sticks were placed on the victims, and it would
be ineffective for the trial lawyer to not ask questions concerning the
sticks placed on the victims.

7. On Saturday October 25, 2024, Lt. Jerry Holeman from the Indiana State
Police testified to the following:
a. On cross examination, Lt. Holeman testified that it was his belief
that the sticks/branches found on the girls were used by the killer to
conceal the bodies.
b. On redirect, Prosecutor McLeland asked Lt. Holeman if another
reason that the sticks/branches were found on the girls was
something called an “undoing.” Lt. Holeman responded, “yes”

8. Through Dr. Kohr’s testimony it was determined that it is feasible that

multiple people using multiple knives, supporting the defense theory that
Odinists/Norse Paganists were involved in the murders.

9. As Dr. Perlmutter testified to on August 1, 2024, knives are a classic sign

of Odinists/Norse Paganism culture and that knives are classically used in
ritualistic killings.

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10. Dr. Kohr’s testimony revealed that perhaps as many as 4 knives were
used, and at least one of those knives may have been serrated, supporting
the defense belief that multiple Norse Paganists/Odinists using multiple
knives were involved in the murders.

11. Furthermore, upon viewing the crime scene photographs that have been
admitted into evidence, there are no obvious drag marks to the naked eye,
nor were there any police reports or charts that showed drag marks at the
crime scene. Even blood spatter expert Pat Cicero admitted that he could
observe no drag marks on the crime scene photographs that he reviewed.

12. The fact that there is no evidence of drag marks support that more than
one person was involved in the murders, including two or more people
needed to lift Liberty German’s body (explaining why there was no drag
marks) from where she was killed to where she was ultimately found,
supporting the possibility that multiple Norse Paganists/Odinists were
present and participating in the murders.

13. As it relates to Lt. Holeman’s testimony, when Lt. Holeman answered

“yes” when asked if another theory of why the sticks were on the bodies
was because of something called an “undoing”, his testimony is yet
another reason provided by the State of Indiana as to why the sticks are
on the girls.

14. The questioning of the prosecution and the answer of Lt. Holeman
pertained to yet another explanation (an “undoing”) as to why the sticks
were found on the girls and therefore the prosecution opened the door to
the defense’s alternative theory as to why the sticks were found on the
girls.

15. The defense has its own theory as to why the sticks are on the girls and
Richard Allen has a 6th Amendment right to provide that theory to rebut
the State of Indiana’s theories, including the prosecution’s latest theory
that the sticks are related to an “undoing”.

16. Additionally, blood spatter expert Pat Cicero opined and/or the
prosecution led the jury to believe through questioning that Liberty
German was moved to her final resting place to conceal the body.

17. The prosecution’s line of questioning of Pat Cicero was pursued by the
prosecution on direct examination and opened the door to the defense
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 offering alternative theories as to why the body was placed in its final
resting place and why the sticks were placed on the girls. The defense
theory is that Liberty German’s and Abigail Williams’s final resting place
was related to Norse Paganism/Odinism and a ritualistic killing.

18. Richard Allen has a 6th Amendment right to present its theory of why the
victim’s body was placed in its final resting place and why sticks/branches
were placed on her body.

19. The defense believes that both Liberty’s and Abigail’s bodies were placed
there because of the desire of Odinists to pose the body and form sticks on
the body in an arrangement for reasons only understood by the
person/people that murdered the victims; Dr. Perlmutter has testified as
to how the sticks would only have meaning to the people who were
involved in the murders.

20. Additionally, the defense expert (Dr. Dawn Perlmutter) indicated in the
August 1, 2024, hearing that the arrangement of sticks was not an
undoing, as an undoing is typically an attempt by the killer or killers to
provide dignity to the victim. Hallmarks of an undoing might be closing
the eyes and mouth of the victims. In this case, the girls’ mouths and eyes
were open and one victim was displayed naked in an undignified manner.
This would be inconsistent with an undoing. The defense should have the
opportunity to explain what it believes is an “undoing” and how the crime
scene does not exhibit an “undoing”.

Evidence introduced before and during trial that supports the introduction
of 3rd party suspects Elvis Fields and Brad Holder

21. On Saturday October 25, 2024, Lt. Holeman was asked a question about
how many people were involved in the murders of the victims.

22. Lt. Holeman offered that only one person was involved in the murders.

23. After offering that only one person was involved in the murders, Lt.
Holeman offered the following: as part of his reasoning for believing that
only one person was involved in the murders is that (based on his training
and experience) when more than one person is involved in a crime, there is
often a point in time when one of the participants will discuss the crime or
reveal the crime, whereas when it is only one person, it is much easier to
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 contain that secret. That was Lt. Holeman’s theory that supported his
belief that only one person committed the murders.

24. Since September 18, 2023, the defense has consistently maintained that
evidence supports that Elvis Fields was a participant in the murders
along with Brad Holder and others.

25. According to Lt. Holeman’s theory (as testified to under oath on October
25, 2024) if it is true that Elvis Fields and Brad Holder were both involved
in the murders, then it is likely that one of them will have admitted to
being involved in the murders or providing incriminating statements
concerning being at the murders.

26. Evidence exists that supports the defense contention that multiple people
were involved in the murders and also supports Lt. Holeman’s theory that
if multiple people are involved in a crime that at least one of them will
reveal the crime to others.

27. For example, blood spatter expert Pat Cicero testified that it is possible
that both girls were killed at the same time, which would indicate that
more than one person was involved in the crime.

28. Additionally, Pat Cicero also admitted that one explanation for Abby
having no blood on her hands is that while her neck was being cut,
someone else held her hands down.

29. Law enforcement conducting the investigation into the murders have
interviewed one suspect (Elvis Fields) who (a) asked inculpating questions
to a state trooper, and (b) has connections to those who have incriminating
evidence on their social media as well as a direct connection to one of the
victims.

30. Therefore, evidence exists that multiple people were involved in the
murders, rendering all purported alibis as suspect due to the ability for
the ringleader to claim an alibi while others are doing his bidding in terms
of abducting the victims.

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31. Brad Holder’s first alibi, for example, would allow him to be in Delphi no
later than 2:30 pm, perhaps earlier, while Elvis Fields and others
abducted the victims and held them awaiting Holder.

32. In 2018, law enforcement pulled Elvis Fields in for questioning to the
Rushville Police Department and at the end of the interview took Elvis’s
DNA and then explained to Elvis their reason for taking his DNA.

33. At the conclusion of the interview, Trooper Kevin Murphy drove Elvis
back to his home.

34. After Trooper Murphy dropped Elvis off at his (Elvis’s) home, Elvis walked
toward his home then turned around and approached Kevin Murphy’s car.
After getting close to Trooper Murphy’s vehicle, Elvis asked Trooper
Murphy: if my spit is found on one of the girls, but I have an explanation
for it, would I still be in trouble?

35. DNA analyst Stacey Bozinovski testified at the end of her cross-
examination on October 28, 2024, that a person’s spit can be analyzed for
DNA.

36. Additionally, evidence exists that supports that Elvis Fields was
mimicking Brad Holder’s (who lived 125+ miles away and should have no
ties to Elvis Fields) Facebook posts, or that Brad Holder was mimicking
Elvis Fields’ Facebook posts months before the victims were abducted.

37. Elvis Fields has claimed under oath that Brad Holder was actually
mimicking Facebook posts that Elvis’s Fields had posted.

38. Brad Holder’s son (Logan) was dating Abby Williams and Brad Holder had
evidence that exhibited Holder’s knowledge of a crime scene on his social
media that no one else should know, meanwhile 125 miles away Elvis
Fields who seemingly would have no reason to know Brad Holder even
existed: (a) followed Brad Holder on Facebook, mimicking his posts (or
vice-versa) and (b) was making statements that inculpate him as to being
involved in the murders, including the expectation of the possibility that
his (Elvis’s) spit might be found on the girls. However, this would not be

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 surprising based upon Lt. Holeman’s October 26, 2024, testimony that
when multiple people are involved in a crime, someone will ultimately
reveal the crime.

39. Additionally, evidence from Brad Holder’s social media supported the
concept that others assisted him in committing the murders and moving
the bodies as Holder posted a meme on his Facebook page a few days after
the girls were murdered and the theme and words from that meme have
become more important due to testimony that has been elicited during the
trial.

40. According to blood spatter expert Pat Cicero, Liberty German’s 200-pound
body was in fact moved from one location to another.

41. Also, pursuant to blood spatter expert Pat Cicero, there were no drag
marks that could be seen on the crime photos.

42. Therefore, evidence supports that Libby’s body was moved from one
location to another and that two or more people would have been needed
to carry the body since no drag marks existed. Certainly, it would be
highly unlikely that one man alone could accomplish that task.

43. On February 17, 2017 (three days after the murders) Brad Holder posted
these words on his Facebook page:

“Your ‘Real’ Ones Don’t Judge You or Ask a Bunch of Questions.

They help you move the body and never speak of it again.” (emphasis
added)

44. The fact that Brad Holder had content on his social media that mimics the
crime scene (unknown to the public at that time) and additionally that he
posted words concerning how real friends would help him move a body
supports the theory that Brad Holder and others were involved in the
murders. The fact that Brad Holder has told multiple stories about
whether he had ever met Abby Williams (ranging from he never met her
to he met her one time to he met her two times) along with all the other

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 evidence provided in the Franks memo supports that third party suspect
evidence should be made admissible.

45. Additionally, the evidence previously provided to this Court in the Franks
memo as well as admitted into evidence on August 1, 2024, provided proof
that Elvis Fields did not have an alibi that could be substantiated, but
quite the opposite: Elvis Fields’s alibi is sketchy as his version of his
whereabout on February 13, 2017 runs counter to those who allegedly
were with him on that day. In other words, no one could keep their stories
straight about Elvis’s whereabouts on February 13, 2017.

46. Lt. Holeman’s October 26, 2024, testimony leaves the jury under the
mistaken belief that no evidence exists that multiple persons were
involved in the murders and that no other suspects have made any
statements that inculpates them in the crimes (thus supporting Lt.
Holeman’s theory that when multiple people are involved in a crime, at
least one of them will ultimately reveal the crime).

47. At the time of his October 26, 2024, testimony, Lt. Holeman was fully
aware that evidence existed that Elvis Fields made inculpatory
statements concerning being present at the scene and at the time that the
victims were murdered.

48. At the time of his October 26, 2024, testimony, Lt. Holeman was fully
aware that evidence existed that Elvis Fields of Rushville Indiana had a
connection with Brad Holder from Logansport Indiana and in fact said
evidence produced from the law enforcement investigation showed that
Brad Holder and Elvis Fields were mimicking one another on Facebook.
49. At the time of his October 26, 2024, testimony, Lt. Holeman was fully
aware that evidence existed that Brad Holder’s son (Logan) dated Abby
Williams.

50. At the time of his October 26, 2024, testimony, Lt. Holeman was fully
aware that Brad Holder had evidence on his social media consistent with
signatures left behind at the crime scene, including a mimicked crime
scene photograph that looked eerily similar to the way that the bodies
were posed on the ground of the woods and photographs of sticks laid

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 down on the ground and a similar pattern of sticks found on Abby’s body
in the form of a hand drawn pattern on the wrist of Brad Holder, among
other incriminating items, including a post about ‘real’ friends helping
move bodies.

51. At the time of his testimony, Lt. Holeman was aware that Odinists/Norse
Paganists had been investigated as being involved in the murders.

52. At the time of his testimony, Lt. Holeman was aware that both Brad
Holder and Elvis Fields possessed knives, and that Brad Holder used
knives as part of his Odinism religion.

53. At the time of his testimony, Lt. Holeman was aware (or should have been
aware) that Brad Holder possessed a 40-caliber handgun.

54. At the time of his testimony, Lt. Holeman was aware (or should have been
aware) that Brad Holder’s 40 caliber handgun was never collected, test-
fired or compared to the bullet allegedly found at the crime scene.

55. Therefore, the jury has been misled into believing that law enforcement’s
only available evidence only supports that only one person was involved in
the crime, when Lt. Holeman’s own words on the stand, evidence from the
law enforcement investigation and trial testimony from Dr. Kohr, Pat
Cicero and Lt. Jerry Holeman would support the defense theory that
multiple people were involved in the crimes. This is true because Elvis
Fields has provided inculpatory statements and had a social media
connection with Brad Holder, and Lt. Holeman has indicated that when
multiple people are involved in a crime, it is his experience that one of the
participants will ultimately reveal the secret of the crime. It is also true
because a substantial amount of evidence supports that Brad Holder’s
social media contained words and images that are consistent with the
crime scene and also consistent with creating or showcasing an alibi at 2
am on February 14, 2017 when for the only time in his life he claimed in a
Facebook post that he was at the gym (as Holder stated under oath in
deposition). Holder’s social media is also consistent with others being
involved and assisted him in moving the bodies.

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 56. Richard Allen possesses a 6th Amendment right to rebut Lt. Holeman’s
theory that one man – and only one man – was involved in these murders,
especially when Lt. Holeman’s reasoning for believing that only one man
was involved in the murders is debunked by the evidence detailed herein,
including Elvis Field’s inculpatory statement that supports Lt. Holeman’s
belief that when multiple people are involved in a crime, ultimately one
person will reveal the commission of the crime.

57. Additionally, as previously detailed, Richard Allen possesses a 6th

Amendment right to present evidence that those involved in Norse
Paganism/Odinism were involved in the murders and posed the girls and
placed the sticks on the girls in certain arrangements for reasons that are
very personal to the people that committed the crimes.

58. Defendant files this motion currently, in part, for purposes of a ruling in
anticipation of the need to contact our witnesses if the Court reverses his
ruling.

Respectfully Submitted,

/s/ Andrew Baldwin

Andrew Baldwin, #17851-41

/s/ Bradley Rozzi

Bradley Rozzi, #23365-09

/s/ Jennifer Auger

Jennifer Auger, #21684-41

CERTIFICATE OF SERVICE

This is to certify a copy of the foregoing pleading has been provided to all counsel
of record for the opposing party, via IEFS this same day of filing.

/s/ Andrew Baldwin

BALDWIN PERRY & WILEY, P.C.

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