STATB OF WISCONSIN : CIRCUIT COURT : MANITOWOC COUNTY

STATE OF WISCONSIN, )
)
Plaintiffl, )
) Case No. 05-CF-381
v. )
) Honolable Judge Angela Sutkiewicz,
STEVEN A. AVERY, Judge Presidirrg

Defendant.

AFFTDAVIT OF THOMAS E. PEARCB

Now comes your affiant, Thomas E. Pearce, and under oath hereby states as follows:

l. I am of legal majority and can truthfully and competently testify to the nratters contairred

herein based upon rxy personal knowledge. The factual statements herein are true and

correct to the best of my knowledge, information, and belief, I am of sound mind and

have not ingested arry alcohol that would impair my memory of the facts stated in this

affidavit.

2. I filst met Teresa Halbach when she was in hel senior year at Urrivelsity of Wisconsin at

Gt'een Bay. She interned at my photo studio to fulfill deglee requirements. After

graduatiug, Ms. Halbach began working for nre. After a period of time, we agreed that

Ms. Halbach should start hef own business that wor.rld opelate out of my str.rdio, located

at 1599 Westem Avenue, Green Bay, Wisconsin.

3. Ms. Halbach and I became good friends during our time working together.

4, Whenevet'Ms. Halbach knew she would be gone for an extended period of time, she

would tell nre. I rerneurber that she told me tlrat she would see ule at the str-rdio on

EXHIBIT

I nn
 Tltesday, Novetnber l, 2005. The stLrdio was not open on Mondays, so I would not have

cxpected to sce lrer or have any conlact with lrer on Octobcr 31, 2005. When she did not

art'ive at the str"rdio oti Noverrbel l, I was concerned. However',I knew that she had no

photo appointments scheduled for November l, so I figr"rled she was at horne or working

for AutoTrader.

s When Ms. l-lalbach did not appeal at the studio on Wednesday, November'2,2005, I

became vely concerned. I knew Ms. Halbach had planned on attending a business

marketing meeting on Wednesday rnorning and corning to work aftelward, sornetime

around I l:00 a.m. When she did not appear by l2:00 p.m., I callcd hcr ce ll phone.

Wlien I called her cell irhone, I leceived au autornated message that told me that Ms.

I-Ialbach's voicernail box was f'r-rll and that I could not leave a voice message. This

automated rrressage was not Ms. Halbach's typical voiceurail greeting.

I had previously observed Ms. Halbach check her voiceurail fi'equently uumcrous tintes

throughout the day. Under normal circurnstances, I would not expect her to let her'

voicenrail box filI1o capacity.

1. When Ms. I-lalbach did not arrive at the studio on Thursday, November'3, I decided to

call her nrother', Karen I-lalbaclr, to ask aftel Ms. i{albach's whereabouts. Karen l-lalbach

inibrmed me that she had not sceu Ms. I-lalbach since Slrnday, October 30, and that sl-re

would begin calling Ms. Flalbach's friends to find out il'any of tl-rem knewwhele Ms.

I Ialbach was.

8. I was aware that Ms. I{albacli was getting phone calls {r'om someoue who was hatassing

her.
 9. In March 2005, Ms. Halbach told me that a male AutoTrader client made scxual advances

toward her and invited her into his residence. 'l'eresa told me that this advance made her

fbel uncomfortable. Afler this incident, Ms. Halbach did not mention any problems with

AutoTradcr clicnts. Specifically, Ms. Halbach never expressed concern about going to

the Avery property.

10. Ms. Halbach told me on October 29 that she ir.rterrded to go out to a parly on Halloween.

I know that most of the time when Ms. Halbach went out to a party, shc went to Green

Bay or Appleton.

1 1. Ms. Halbach informed me, when she was working fbr me as an intern, that she had been

in a verbally and physically abusive romantic relationship when she was in college with a

male. It is my understanding that she tcrrninated that rclationship.

12. I have reviewed Ms. Halbach's online business listing (attached and incorporate herein as

Exhibit A to the Allidavit of '['homas IJ. Pearce). Based upon my personal knowledge of

Ms. Halbaclr's business, Exhibit A is an accurate depiction of the services offered by Ms.

Halbach in the regular course of her bursiness.

I 3. I gave rny permission to Ms. Halbach, on a number of occasions, to use my photography

studio fbr nude portraits of hcr clients. ln l-act, a porlion of my own business was taking

nude photographs of my clients.

i4. Nothing has been pronrised to me in cxchange fbr this aflldavit,

FUII.TI{ER AFFIANT SAYETH NAUGHT

I .-44
l'homas E. Pcarcc

J
Subscribcd and sworn befbre rne
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