Wyoming Court Papers.pdf - KELOLAND.com

Case 1:12-cv-00210-SWS Document 1 Filed 09/17/12 Page 11 of 22
"Oh fuck, they're not gonna get that to fingerprint."
"I say we hang fucking old Lance [i.e., Deputy Gehlhausen]
out to dry."
"I think so too but he seems to be resistant."
The LT members were concerned with the repercussions of not turning the exculpatory evidence
over; the Defendants came to the conscious decision and agreed to keep the exculpatory evidence
secret. As documented by the recordings, the Defendants knew the exculpatory nature of the
evidence and that they were required to disclose it, but instead decided to unconstitutionally
withhold the exculpatory evidence in violation of Mr. Willoughby's Constitutional rights.
16. At Mr. Willoughby's second trial, Defendants Hanson and Ketterhagen admitted
that they should have turned over the exculpatory evidence. In fact, Defendant Hanson agreed
under cross-examination that there was "no excuse" for not turning over the exculpatory
evidence.
17. The prosecuting attorney, Lucketta McMahon, said, in a recorded conversation
with Deputy Gehlhausen and testimony, that she knew about the existence of the report but did
not know the extent of the details contained in the report. McMahon was assured by Defendant
Hanson and the L T members that the report was not exculpatory and did not need to be turned
over to the defense team. She relied on the misrepresentations given by the Defendants.
18. Special Prosecutor, Tony Howard, testified at the hearing for a new trial that he
had no knowledge of the existence ofthe report. Mr. Howard further testified that had he known
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