Evidence · 01
The September 28, 2022 Recording
One file. Multiple custodians. Years of questions.
I
The Interview
On September 28, 2022, CSLB Investigator Amanda Martinez interviewed Zachary and Angela Minor at the Napa County District Attorney's Office. Napa County Investigator Robert Yeager recorded the interview using a county-issued digital recorder.
220723_0161.MP3
II
The Transfer
The original email documents the transmission of the Dropbox link directly to Martinez.
III
Confirmation
“I spoke to her on the telephone and confirmed she received the link/interview.”
Yeager wrote that once he confirmed that the recording had been “collected/retained by the CSLB,” he deleted the recording from Dropbox and his recorder because the case was outside Napa County's jurisdiction.
This is Yeager's account.
IV
CSLB's Later Account
Changing explanations, date by date.
October 2024 · As relayed by a Sonoma County prosecutor
Martinez said the transmission email had automatically deleted after two years and the recording was no longer on Dropbox.
Agency / Defendant PositionApril 21, 2025 · Amanda Martinez
“I was able to access the recording initially.” … “The report Jessie signed included the information from our September 28, 2022 meeting in Napa.”
Agency / Defendant PositionSourceS006July 9, 2025 · Amanda Martinez
“The recording was done by Napa DAs office, not CSLB.” She wrote that it was digitally stored on the cloud and “self-deleted off the cloud-based system.”
Agency / Defendant PositionSourceS007July 11, 2025 · Jessie Flores
The matter was handled by Napa County, and CSLB was not in a position to respond or provide information regarding the issue.
Agency / Defendant PositionSourceS008
Compare the Record
Statement A · April 21, 2025
Amanda Martinez
“I was able to access the recording initially.”
Statement B · July 9, 2025
Amanda Martinez
“The recording was done by Napa DAs office, not CSLB.” It “self-deleted off the cloud-based system.”
Why Plaintiffs say it matters
Plaintiffs contend that describing the recording solely as a Napa cloud file does not address whether CSLB obtained, accessed, or retained its own copy after Martinez's confirmed receipt and initial access. These are different descriptions; whether they are inconsistent remains disputed.
V
Forensic Recovery
After repeated records requests and escalating efforts to locate the recording, Napa County Investigator Joseph Perry used forensic tools on the original recorder. The deleted audio was recovered around August 20, 2025. It was booked into evidence and provided to relevant parties.
“IT downloaded it and I have a copy saved.”
VI