**NOTE: the information provided below regarding each document are summaries with some commentary to provide some context and connection to relevant facts of the case. It is advised that you view both the information below, as a supplement, and the actual documents to ensure full comprehension of Sonny's case. The summaries and commentary are used to provide an understanding of the case."

**Color Code Legend for flag markers:

Pink (purple): Helen Mo’s direct statements, statements/description made by Helen Mo, and/or information relating to Helen Mo.

Yellow: information relating to the victim, Eric Liu, from this case, and any other victim information from Mo’s 1998 conviction, and/or victim-blaming remarks.

Green: Possible police or prosecution misconduct and ineffective assistance of counsel.

Orange (red): Gang-related information

Stipulation between Debora Lloyd and Gary Pohlson (Bates Stamp: 471 and 466) (p.1-2): Sonny’s public defender, Gary Pohlson, and Deputy District Attorney, Debora Lloyd, did a stipulation that prior to January 24, 2000, Helen Mo had obtained two prior serious felony convictions both for burglary. This stipulation was dated on August 21, 2002.

Interview of Mr. Terrence O’Hare (p. 3-4) : On April 5, 2007 at 11:10am, Sergio Robleto interviewed Deputy Probation Officer Terrence O’Hare, at the officers of the Los Angeles County Probation Department located within the El Monte Court house at 11234 East Valley Boulevard, El Monte, California.

According to Mr. O’Hare, Helen Mo was on probation and assigned to him because of her convictions for burglary and the use of computers to commit credit card fraud. He recalled that Mo was very bright and was surprised by the level of sophistication she displayed during the commission of the crimes she had been convicted of as she was a minor.

O’Hare recalled that Mo had a very sophisticated Modus Operandi, in that she had befriended a boyfriend and that while he was away, she was able to gain access to his house and lived there for quite awhile. He estimated that she had lived there for maybe four months. While there, she used the computer to commit credit card fraud and stole one or two cars.

He was not certain if Mo was in Wah Ching, but certainly did associate with them. O’Hare stated that he was concerned that she might be one but did not put it together until after the murder. O’Hare checked to see if Mo had been flagged as a gang member in their computer and stated that she was not flagged on their computer.

O’Hare did indicate that Mo and her instructor, Ms. Wilson, were very close. He felt that they were more than a teacher and assistant, as Mo saw her as a very close friend and confidant. O’Hare also recalled that he had to intervene to stop the visits by law enforcement that seemed to be getting too friendly with her.

On the day of the crime, O’Hare recalled that Mo came in and was very worried, fearing for her safety. He recalled that she had two cell phones and thought it was unusual because back in 2000, only drug dealers had two phones. Moreover, O’Hare remembered that Mo spoke about a club in Alhambra, where a meeting took place about a murder. Mo was a minor at the time and gained access to the club with the help of a security guard or doorman. O’Hare was told that the club was a hangout for Asian gang members. He recalled that he cautioned Mo at the time because he was treating her as a witness, and that if she got in trouble for going into an adult club, he would have to take action against her.

Prior to the day of the crime, O’Hare was informed from Mo that there was going to be a murder over the weekend, and that there was something going on in the Asian community. Yet no action was taken against Mo at the time when O’Hare was informed of this matter.

H. Supplemental report by Inv. Jacobsen. Int. of Helen Mo (p. 5): While Mo was being transported to Irvine PD, she called her mother and spoke to her in Mandarin. After her phone call with her mother, she was asked if her mom was mad or scared, and she said she was upset. Her mother stated that in the past, she made mistakes and they had forgiven her, but “this is murder, this is taking someone’s life away.” Her mother asked how she could do this. Mo then started crying and said, “He’s dead, what is the point? I’ll be in jail the rest of my life putting my family through this. I might as well say I did it right now.” She was then asked if there was something different that she wanted to say, and she said she couldn’t because “they” would come for her family. She then said, “Case solved, I drove him to Irvine, and I killed him, okay. I set his car on fire, okay. I tied him up and stuffed him in the trunk.”

She later stated, “If I say I killed him, will you still investigate?” She went on to say that she had told the detectives the truth, but they told her she was lying. According to this document, Mo began hanging out with gang members in 11^th grade. She later stated that Eric’s death was an accident.

Helen Mo’s 1^st Interview on 1/25/2000 p. 64 (p. 6-7): Helen Mo was interviewed by Investigator Keith Bacon and Investigator Gary Cain about possible causes for Yi Chen (Eric) Liu’s death. According to Mo, she stated that the “only other possibility would be Samuel, because he’s arrested for 13 years.” She also stated that she didn’t know whether if he was “trying to go revenge” for her. When asked on whether Samuel thinks she snitched him, she stated, “Probably.”

The later documents will discuss Helen Mo’s prior conviction in 1998 with her ex-boyfriend, Samuel Chang. While Mo was able to get leniency and received a probation for five years, Samuel Chang received a sentence of 13 years.

Helen Mo’s 1^st Interview on 1/25/2000 p. 67 (p. 8-9): In this interview, Helen mentioned some possible reasons for the people who supposedly “invaded her home.” She stated that it was possibly for the conversation she overheard at De Club or Samuel. She also stated that her parents were yelling at her about Samuel. This statement made by Helen Mo is false, as it contradicts a later investigative supplemental.

Investigative Supplemental p. 2 (Bates Stamp: 000338) (p. 10-11): As mentioned in the previous document, Helen Mo stated that her parents were yelling at her about Samuel. In this investigative supplemental, Helen’s mother stated that on the day in question, at least one of the boys had said something in English, and Helen later said that the conversation from the boy was, “It’s all your fault that Sammy is in jail.” The investigator believed that this reference is to Samuel Chang, who was Helen’s ex-boyfriend in 1998. Helen intentionally lied to the investigators about such statements to protect the other perpetrators.

Moreover, Helen’s brother, Tommy, have stated that everything had been “pretty normal since Helen got out of jail,” but never went in detail as to what that “normal” entailed, except for the fact that Helen often talked on the phone at 1,2, or 3 in the morning and that she often got pages or calls on her cell phone. (The next page is a redacted version of the previous page. The statement about the boy saying, “It’s all your fault that Sammy is in jail,” is blackened and blurred, in addition to the statement about Helen’s friend who brought the cleaning machine to her house on the day in question. This was the investigators’ attempt to alter and delete certain facts that would contradict Helen Mo’s statement).

(Samuel Chang)

West Covina Police Department Supplemental Report (Bates Stamp: 006857) (p. 13): This is a supplemental report from 1998. According to the report, Detective Harden and Detective Nalian were told by Officer Bogart that Samuel Chang wanted to cooperate and showed them the locations where he had stolen property from. Samuel told them that he went into a house on the East Side of the street but was unable to locate the exact location other than to say it was one of the approximately six houses south of Vine on Hollenbeck. He also told them about how he found a window open next to the front door, pulled the screen off, and climbed in. He later guided the detectives to a pawnshop in Covina, where he had gotten five hundred dollars for several rings and gold chains.

Though Samuel Chang was guilty of burglarizing three to four homes, he was not hesitant in disclosing the details of the crime. He even admitted that he burglarized those homes because he needed money for clothes and things. In contrast to Helen Mo, Helen admitted to the crimes she committed in 1998, however, it was on the basis that she was “used sexually and criminally” by Samuel Chang. At her court hearing for her 1998 conviction, she made the impression that she was the “victim” in the case, even though she had a major involvement in those crimes.

West Covina Police Department Suspect Report p. 1, 3-6 (Bates Stamp: 006858) (p. 14-18): This is a suspect report for Samuel Chang. As shown, Samuel was arrested for burglary. He was a student at the time attending Perdue University at Indiana. As noted, he didn’t have any gang affiliation at the time either.

The following properties were submitted to evidence: “Nike” shoes, gloves, a bag, a mask, scissors, a ring, bag/coins, a Canon camera, pens, calculator, diamond, and knives.

According to the narrative report, Officer Murray was dispatched to 2723 E. Larkwood regarding a possible burglary. The narrative report was written on 7/11/1998. A neighbor had seen a male and female Asian attempting to remove the screen from the victim’s residence, and that suspects were wearing gloves. Upon arrival, Officer Murray saw a black Nissan driving westbound towards him. The vehicle was driven by a female Asian (Mo) with a male Asian in the front passenger seat (Chang). After stopping the vehicle at Azusa Avenue, Officer Munn, Officer Plebani, and Officer Delmendo arrived to assist Officer Murray at the stop. Mo and Chang were detained afterwards. The officers later conducted a “field show up” of the two suspects. Officer Bogart advised Officer Murray that the witness had positively identified both suspects as the people he saw breaking into the house. Mo and Chang were arrested and arranged for booking at West Covina Police Department.

Officer Murray conducted an inventory search of the vehicle and found several items that appeared to be stolen from the residence. He then collected all the items and booked them into evidence. He also found a white glove under the front passenger seat and a black bag containing another white glove behind the driver’s seat. In the same bag, he found a pair of rubber gloves. On the driver’s seat, he found a gardening type face mask. Officer Murray formed the opinion that these items were used in the commission of the crime and seized them as evidence.

Officer Bogart and Murray interviewed Chang about the incident that took place on 7/11/1998. Chang stated that Mo was his girlfriend and that they have been dating for about a year. Chang picked up Mo at her house at approximately 0700 hours that morning, drove them both to his apartment where they both fell asleep. At around 1200 hours, they got up to go “look for a house.” They drove to the area where the burglary occurred. Chang then provided details on how he and Mo performed the crime. He also told the officers that he stole “cash, jewelry, cameras, a camcorder…” Even though the officers had recovered some of the stolen properties from the vehicle, Chang voluntarily return the stolen properties he had at home to the officers. He was also cooperative with the officers and showed the detectives where the burglaries happened.

Mo was later interviewed by Officer Murray and Bogart. She provided the same narrative as Samuel in terms of their relationship and what happened when the burglary took place. However, the officers noted that Mo originally told them that she knew nothing of the other burglaries that she and Chang committed. She eventually told the officers that she had been with Chang when the other burglaries were committed, although she was vague and evasive when asked specifics. The officers believed that Mo was trying to protect Chang. (This is mostly false because if it is true that Mo was trying to protect Chang, she wouldn’t have formed the impression on court that she was “used sexually and criminally.” After the commission of these crimes with Samuel, Mo had done another burglary without the help of Samuel, where she befriended another male friend and later stole his property, which included cars and other valuables. Mo claimed that she committed these crimes by herself, with the help of Samuel, who gave her instructions by phone. Mo was a minor at the time, and it is impossible for a minor to be stealing cars and other valuables all by herself. It is believed that Mo had some outside assistance besides Samuel. Unlike Samuel, who voluntarily gave information to the police, Mo was evasive towards the questions, as if she was protecting someone other than Samuel).

West Covina Police Department Juvenile Contact Report (Bates Stamp: 006863) (p. 19): This is a juvenile report of Helen Mo. She was 17 years old in 1998 and lived in 16025 Eugenia Street in Covina, where she attended Covina High School. The police noted that she had no gang affiliation; however, this is false. This report indicates that Mo was in 12^th grade when she was arrested on 7/11/1998. In another document from this present case, the investigators pointed out that Mo was involved in gangs since 11^th grade. This demonstrates that the officers did not looked into Mo’s gang affiliation or even considered in flagging her as a gang member in 1998.

Covina Police Department Crime Report (Bates Stamp: 006864) (p 20-21): This is a crime report for the victim, Martin Rodney, a tile contractor who resides in 2630 E. Larkwood Drive in West Covina in 1998. The officer also indicated that “there is a significant M.O. (Modus Operandi)” in the case and that “further investigation is needed.” On page 2 of the crime report, the officer also noted under the “Trademarks” section that the suspect pretends to be “seeking assistance.” Furthermore, the victim had physical security at his residence, specifically “standard locks” and “auxiliary locks,” as indicated in the report. (In a separate report, an officer was able to identify that Mo had a high level of sophisticated with such a young age. She was able to seek assistance from a locksmith by pretending to be locked out of her house and asked the locksmith to pick the locks for her. This level of sophistication that she displayed during the commission of the crimes was done without the help of Samuel).

West Covina Police Department Suspect Report (Bates Stamp: 006866) (p. 22-23): This is another suspect report that was dated 7/13/1998, two days after Samuel and Helen were arrested for a burglary. According to the report, the suspect was unknown and was seen driving from the scene. The suspect’s vehicle was dark in color, but unknown as to the license number and car description. The only description that the officers gave in the report was that the person was “male,” “21 years old,” “Chinese race,” “5’ 09’’,” 165 lbs.,” “medium build,” “short hair,” “clear complexion,” and “clean shaven.” Another suspect was also identified. The second suspect was described as “female,” “18-19 years old,” “Chinese race,” “5’ 03”,” 110 lbs.,” “medium build,” “straight back hair,” “clear complexion,” “light colored (gray) T-shirt with blue jeans.” No further investigation was done on these suspects. As a result, they were not arrested.

West Covina Police Department Consent to Search (Bates Stamp: 000223) (p. 24): This is a consent to search for Helen Mo, authorizing West Covina Police Officer Nalian/Harden to conduct a complete search of the premise at 3046 Gladys in Rosemead. This authorization was done on 8/21/1998.

West Covina Police Department Supplemental Report (Bates Stamp: 000220) (p. 25-26): This supplemental report was written by Detective Harden on 08/05/1998 at 1945 hours. Detective Nalian and Detective Harden interviewed Helen Mo in the West Covina Police Department jail. Mo stated that she was currently living with a woman and a small child at 3046 Gladys in Rosemead. She was unable to provide the woman’s name because she is Vietnamese and they both don’t communicate very well. The detectives were able to later identify the woman as Trinh Nguyen. Mo also stated that she rents a room from the woman for three hundred dollars a month. Mo was able to be in contact with Nguyen because her boyfriend, Samuel Chang, was in county jail with Nguyen’s husband. Mo told the detectives that Nguyen came with her to go shopping and had no idea what she was doing. Moreover, Mo told the detectives that the bed, computers, television, stereo, nightstand located in her room were all stolen property she had obtained by herself for her alone. To provide some context, Helen Mo was a minor during this time, around 16-17 years old. After the burglaries with Samuel Chang, she stole these properties by herself. She also called a locksmith and told him she had locked herself out of the house. The locksmith opened the front door to the house for her and she moved into her friend’s house to stay for several days. Her friend was Joseph Hsia, who lived at 1423 E. Rowland Ave. As a 16-17 year old, how could Mo moved the bed, computers, television, stereo, and nightstand all to her room at 3046 Gladys in Rosemead by herself? Samuel Chang is already out of the picture at this time, so there is no way that Mo could’ve done this by herself.

Mo told the detectives that after staying at Hsia’s house for a few days, she left with the black Honda Civic, belonging to the Hsia’s. She gave the other vehicle, a green Honda Accord to a male subject known to her only as “Affie.” Mo had no idea what his full name is or where he lives, but knew that he was a friend of the woman’s husband, who is in jail with her boyfriend, Samuel Chang. Furthermore, Mo told the detectives that she lived with another victim, Yuan Pei, for a period of time. She met Yuan Pei from church and while living with her, she applied for and obtained credit cards using Yuan Pei’s name. She had the credit cards sent to Pei’s house and intercepted them when the mail arrived at the house. She then moved to another victim’s house, Joseph Hsia, and began using the credit cards she had obtained using Pei’s name.

Notes from West Covina PD’s arrest report for Helen Mo (Bates Stamp: 000195-000197) (p. 27-29): This report was written by N. Berbiglia-Chan. Helen Mo was arrested in October 1998 for 496 (a)-possession of an earlier 10851 case. In August 1998, Mo assumed residence at victim’s house, while they were out of the country. At the time, Mo had used the victim’s credit cards to purchase items over the phone and computer, then had the items sent to the victim’s residence where she was staying. Mo then gave one of two vehicles, belonging to the victim, to a friend named Affie and took the other for herself. Mo discussed the theft and that she used the victim’s card to make several purchases.

At the time of arrest in October 1998, Mo was renting a room from Trinh Nguyen. She was told about the room from her boyfriend, Samuel, who is already in jail, with a man by the name of Henry, who is Trinh Nguyen’s husband. The detectives were unable locate Affie.

During August 1998, Tommy Mo, Mo’s brother, stated that he doesn’t know where Mo was at the time, so he filed a Missing Person’s report with the Sheriffs officer about a month prior to them talking to him. Tommy was contacted at 16025 Elgenia Ave., Covina, which is also Mo’s residence as listed in the juvenile contact report. There were two missing persons report that were on record. One was filed on 2/14/1998 and a second report on 7/22/1998.

A detective spoke to Jacob Chang, Samuel’s brother, who mentioned that a person named Kevin has been known to call Mo for Samuel. Kevin lives across from Jacob.

During a search at Mo’s temporary residence at Gladys, a piece of paper was found in the trashcan along with other evidence. The piece of paper has a name and number for Gary Woo (636) 864-0787. West Covina PD stated that their dispatch came up with the name of Gary Wu.

Penal Code Section 241.5 prohibits the disclosure of victims’ and witnesses’ addresses and phone numbers by law enforcement officers or employees of law enforcement agencies to persons who have been arrested or are potential dependents in a criminal action. Based on the previous page, Mo was able to get a contact information of a West Covina police officer, Gary Wu. According to this penal code, there is a prohibition for law enforcement officers to provide contact information to persons who have bene arrested or are potential dependents in a criminal action. In this case, Mo has been arrested for the crimes that she committed; however, it is highly suspicious that she would have a contact information of a law enforcement officer.

Document (Bates Stamp: 001357) (p. 30): This provides the contact information of Henry Tran, Trinh Nguyen’s husband. The address that was listed for Henry Tran was 8134 E. Emerson in Rosemead. In relation to this present case, the address of 8134 E. Emerson belongs to Johnny Quan, Li Da Liang’s best friend. Another address that was also listed for Henry Tran was 1225 ½ S. 2^nd Street in Alhambra. In relation to this present case, this address belongs to Doug Lim, one of the co-defendants in this present case.

Notes (Bates Stamp: 001282) (p. 31): This contain some notes that were made on 2/1/2000. The following information is listed on the notes:

8143 E. Emerson Rosemead: 626-285-7171

8134 E. Emerson Rosemead

1225 ½ S. 2^nd Alhambra: 626-570-5151

8134 E.

Tang, Fay J.: 3-99 4Y68838 90 Dodge Truck Wht.

Alhambra: Juv. Arrest Record.

Document (Bates Stamp: 000222) (p. 32): A detective from Mo’s 1998 case asked Helen about her reasons for committing these various crimes in 1998. Mo told the detectives that her parents wanted to take her back to Taiwan and she doesn’t want to go. She felt that her parents don’t care about her and what she wants to stay in the United States. Mo’s parents don’t know where she was living at the time and she was trying to remain hidden from them so as not to be forced to leave with them.

Mo was also questioned about the stolen properties that were found in her bedroom at the 3046 Gladys address. Mo gave her consent to search her room and recover the stolen property afterwards.

West Covina Police Department Juvenile Contact Report (Bates Stamp: 006288) (p. 33): This is a juvenile contact report for Helen (Tien Hsiang) Mo, dated 10/2/1998. This was a separate report from the burglaries with Samuel Chang. Mo’s residence as listed is 16025 E. Elgenia St. Covina, CA 91722. She was 17 years old at the time, attending Northview High school. As stated, Mo was also not flagged as a gang member.

West Covina Police Department Additional victims/witnesses (Bates Stamp: 000224) (p. 34): The victim/witness that is listed here is Michelle Holmes, with her information provided.

West Covina Police Department Supplemental Report (Bates Stamp: 000228) (p. 35): This was a report made by Detective Garcia Jr. from West Covina Police Department. Detective Garcia Jr. contacted Agent Holmes, who is assigned as the fraud agent for micro warehouse. Detective Garcia Jr. wanted her to check the records for the purchase of a laptop computer that was purchased using victim Hsia’s credit card on or about 8/10/1998. Holmes confirmed that there was a purchase that was made by phone on 8/8/1998 at approximately 2:43 am; however, there was no way to verify who had taken the order, since they rotate operators and it is not noted as to who took the order.

David Hsia’s statement from The Optima Card (Bates Stamp: 000226) (p. 36-37): This displays a series of charges on David Hsia’s credit card that totaled: $2,493.89.

Court transcript from 1998 (Bates Stamp: 006481-006485) (p. 38-42): This is the court’s transcript for Helen Mo’s 1998 conviction. Joseph Borges, Mo’s public defender at the time, advocated for Mo and stated that “she is really an exceptional candidate for help within the—the youth authority system. I would hope that the court would consider a minimal additional confinement time.” Mr. Richard Ceballos, deputy district attorney, gave a remark about Helen Mo and Samuel Chang,

“They elected, I think, independently of each other, to embark upon this crime spree where they were going to victimize whoever without—without regards to who those individuals were, whether it be family, friends, or strangers. And I certainly sympathize with the parents of this defendant because I—I think the parents are clearly well meaning, but they lost control of this defendant. This is a case where the defendant, as reflected in this diagnostic report, is apt to portray herself to a certain extent as a victim, as a follower who was led astray by Mr. Chang…I’m actually referring to page 10 on the fax report—actually, page 2 of the psychological evaluation, last paragraph where it states: ‘During the clinical interview, Helen presented as an intelligent, mature, young woman who now realizes how she was used sexually and criminally by the man she thought she was in love with.’ That’s what I take issue with because I simply don’t believe that’s the case here…Simply because the opposite gender is put into the picture, doesn’t mean that the person loses all sense of direction. That happens from time to time. And, obviously, that’s happened before with me. But, clearly, she knew what she was doing. And even at a certain point, once the boyfriend is out of the picture, she is continuing these criminal acts.” Mr. Ceballos continued and stated that Mo’s intent wasn’t to simply “live” at Hsia’s residence, but to burglarize it. “It wasn’t as innocent as she wants us all to believe. And I think she does that a lot. I think her intelligence has permitted her to become somewhat manipulative.” Furthermore, Mr. Ceballos suggested that Mo should “serve a significant portion of time because this is not a one-time incident. This is a series of crimes that occurred over a period of time. And this is—that wasn’t something simply where somebody is telling her what to do and she is simply following. She came up with ideas…Mr. Chang is not even with her.”

Court transcript from 1998 (Bates Stamp: 006490-006494) (p. 43-47): After receiving a letter from a victim, the court wanted to exercise leniency on Helen Mo, “And he’s pointed out it would be a tragic waste to not give her a second chance. That’s in essence, what he said in his letter. Cheryl Hanley is another teacher. She is asking for leniency and society would be best served if she were given the opportunity to obtain her degree… She ran away because of the threat to go back to Taiwan. The parents did exactly what any parents would do, would intervene when they see a – their child going down the wrong path. So, it’s certainly not the parents’ fault.”

The Court wanted to sentence Helen Mo to four years, but then suspended it and placed her on probation for the next five years,

“And you know how you felt this day as you’re sitting here and you thought you had the four years before the court said it would suspend it? How would you feeling if you came back before this court on a probation violation and the court lifted that stay and ordered you to go in for four years? You would feel just like you felt when you thought you had it, right? Wouldn’t that be terrible for you to go for four years?” Mo replied, “Yes, Your Honor.” The court reiterated that “it’s in your – within your control…and if your parents inform this court that you are in any way out of control. I’m going to bring you back in here for a hearing. You know that?” Mo replied, “Yes, sir.”

The court then calculated her credits and provided her the terms for her probation.

Municipal Court of Citrus Judicial District County of Los Angeles, State of California, Felony Complaint (filed on November 6, 1998) (p 48-75): Helen Mo had 7-8 counts for her 1998 conviction, but it was later reduced to 6 counts. These counts include the following charges: 3 counts of first-degree residential burglary, 2 counts for unlawful driving or taking of vehicle, and 2 counts of fraudulent use of access card.