CORONER'S INQUEST | justiceforshanetodd

Condition Statement - Rick Todd (father)

Highlights from testimony:

15 In the two months prior to Shane's death, he had constantly made statements in his conversations with us that seemed to depict his life in some form of danger. In every conversation Mary and I had with him, from February to the time of his death, Shane would mention how he was afraid he would never see us again. As a father, I was alarmed and told him to keep in touch with us.

16 Shane had told Mary and I that he would call us every week, and if we did not hear from him, to call the US Embassy immediately. Initially, we had both thought that this was an exaggeration. One time he did not call and Mary emailed him to ask him if he was okay, he apologized and said that he had just gotten busy.

18 Sometime in June before his death, Shane (who had been looking for jobs in the US) received a job offer from Nuvotronics in Virginia. He had also asked us to hold off on Father's Day and Dylan's 21st birthday celebration until he returned to USA.

19 I last spoke to Shane on Father's day on 18th June 2012 when he called me. He told me how excited he was to come back to the US. He also emailed me on 18th June 2012 to ask me for bank information, so that he could wire his money from Singapore back to the USA. This was the last I heard from him. I set it up for him to transfer the money in my mother's Well Fargo account. He never made the transfer.

(Click to see emails between Shane and Rick)

23 Mary and I spoke to Traci in private about our suspicions regarding Shane's death and that we believed he had been murdered. We told Traci about everything Shane told us (him being uncomfortable and being in fear for his life, etc). Traci called the Embassy to discuss our situation and to get advice on what and how much we should tell the Police. After their discussion, Traci advised us to tell the police everything we know.

25 To the best of my memory, I0 Muhd Khaldun told me and my wife (in the presence of Traci Gains) that Shane had used an electric screwdriver to drill holes in his bathroom walls. Shane had then supposedly screwed bolts into the wall, to which he attached ropes and pulleys. The rope was wrapped around the toilet seat and slung over the bathroom door. According to I0 Muhammad Khaldun, he said Shane fashioned a noose, put it around his neck, stood on a chair on the outside of his bathroom door facing the bedroom, and jumped off the chair, killing himself by asphyxia.

26 Afterwards, Mary and I were handed what Khaldun described as Shane's suicide note. It was a two-paged typed paper. IO Khaldun who was present together with WSGT Rajina Sharma d/o Rajandran (C31) informed us that no one had read the letter yet, and requested for permission to make copies of the note for Traci, and himself.

31 This time Shane was genuinely concerned for his safety. I believe sometime in March or early April 2013, we received a medical record from the University of Florida, the first page was very difficult to read as the handwriting was not clear. The second page outlined that the doctor would have prescribed something but Shane refused. Shane decided to handle his condition through a discipline of diet and exercise. As far as I am aware, Shane never had seen any mental health professional until Spring of 2012.

39 On June 29th 2012, I went to Shane's apartment with my family for the first time. There, Mary noticed several irregularities with the condition of the apartment and the description that IO Muhd Khaldun had given us. The apartment did not look like a crime scene at all as there was no tape stopping entry to the premises. From the looks of the premises, it was obvious that Shane was in the middle of packing. Clothes were neatly stacked and getting ready to box. Laundry was obviously being done. There was furniture marked for sale.

40 Shane's laptops and mobile phone had been removed from his apartment by the Singapore Police. We then spent the rest of the day packing up his personal belongings, including a hard disk drive that the Police did not remove from his apartment. Mary asked me if it was a MAC Speaker. Shirley Sarrniento, Shane's girlfriend also heard this exchange. I did not answer her that question, but I said, "put it in the bag." There was also a Sony LAN and an entertainment system that was designed to take the back-up hard-disk drive. However, it was later in July that I discovered it was a hard-disk drive.
(Click to see picture of hard drive)

46 We commented on the wounds on Shane's body at the wake when his body was lying in the casket. Even though his body was heavy with make-up, they were clearly visible. The embalmer, David Martinez was the director at the visitation and was also a licensed embalmer. He mentioned that at he noticed the wounds as well whilst tending to the preparation of Shane's body.

47 During the memorial service, two separate doctors and other relatives also commented on Shane's hands bearing signs of defensive wounds. My daughter- in-law, Corynne Todd, took pictures of the wounds on his hands and on his head. We buried Shane in Pomona, California.

51 After the funeral and arrival in Montana, Mary and I began our investigation of Shane's death. During our investigations I remembered the backup hard-disk drive that I had told Mary to "put in the bag." I thought that that could have been a hard drive. I retrieved it from the bag and plugged it into my Macbook Pro just to verify that it was a hard-disk drive. No files were opened.

52 My brother-in-law, Richard Elwell, told me to get a computer expert to have a look at the hard-disk drive. I immediately told my son, John Todd to take it to one Ashraf Massoud ("Ash") in Southern California.

53 The following establishes the chain of custody prior to making an Encase Image of the hard drive: Chain of Custody of Shane Todd's Hard Drive:

6/28/2012 Rick and Mary Todd take possession of hard drive from Dr Shane Todd's apartment
7/23/2012 John Todd Takes Possession and delivers it to Ashraf Massoud in Ontario, California.

54 I directed Ash to access the hard drive and pull out documents related to IME-Huawei-GaN project. He was able to access and pull out the following documents for which he referred to in his Conditioned Statement exhibited as

(Click to see actual documents from Shane's hard drive)

Tabs 1-10:

The said documents give insight to the nature of work Shane has been involved with since April 2011, acuminating to a work trip to Huawei the following year.

59 The file that was accessed on 27th June 2012 was particularly telling as it was done three days after his Shane's body was found.

65 I further emailed to I0 Khaldun telling him on 8th October 2012, that I had Dr Adelstein review the HSA report and this was countered by his report of 8th October 2012.

(Click to see email from Dr Adelstein)

(Click to see email to IO Khaldun)

69 Traci Goins informed us that the Singapore police had said that they had provided us the hard disk drive. I kept this in mind as I wanted to ask them personally what Traci claimed they were saying was true. We met with the US Ambassador about what we had experienced.

71 We met with the police again on 13 December 2013. We went to the interrogation room and we met with Craig Bryant, US Counsel, IO Mohammed Khaldun and I believe DSP Sukhdev Singh. I cannot remember if Gurchan Singh was there at the time. He was there earlier. I immediately confronted them about the story IO Khaldun told us in the way Shane hung himself during his first interview. They said that was their initial impression and was not true. I also confronted them about IO Khaldun about telling us that he gave us the hard-disk drive. He said he did and I said no he did not.

72 He then presented us with an inventory sheet with my wife, Mary's, signature at the bottom. There was an item on the bottom of the sheet titled "hard disk". There was not a description of this item even though all there was detailed descriptions of other items. My assumption was that the hard disk, if indeed real, was a cd or DVD. I asked IO Khaldun to give me the serial number and the make and model. He said that he did not have it. I then asked him to describe it. He kind of shrugged and said that it laid flat, was black and maybe had a wire hanging out of it. I refer to Tab 2. It is not the same as described by the said IO.

(Click to see picture of hard drive found by Mary Todd)

73 I then sought another expert opinion on the nature of Shane's work. I contacted one Steve Huettner, an expert on the applications of GaN technology who was engaged in order to give a perspective on the implications of Shane's work.

76 I have faith and strong belief in the opinions of both Mr Ashraf and Dr Adelstein. I also sought an opinion from Dr Porntip Rojanasunan, a top Thai forensic pathologist. I had a Skype conference call with her together with Peter Ong (one of my team of lawyers) when he flew to Bangkok on Friday evening, 17th May 2013. Dr Porntip was shown the reports from HSA, photographs taken from the scene, and mortuary, in Singapore, and when Shane's body was lying in the casket in USA for the memorial service. Dr Porntip was also shown the reports from Dr David Fowler and Dr Valerie Rao. She was not shown the report put up by Dr Adelstein as I wanted to have an objective report. She had indicated to me that she has seen more murder cases as compared to Dr Wee of HSA and that her conclusion was — it is not suicide. I shall in my supplemental conditioned statement put up her opinion. I am now convinced that a 2nd autopsy should have been done, and I have to consider obtaining an opinion from another expert who can come to Singapore to testify or to have Shane's body exhumed.

Condition Statement - Mary Todd (mother)

Highlights from testimony:

6 Shane was a unique individual, somewhat of a renaissance man. Not only was he brilliant, he was also athletic and witty. I have never met a person who did not respect Shane. Since Shane's death, the Singapore police have tried to characterise Shane as a depressed person. This could not be further from the truth. Shane loved life and lived it to the fullest.

8 About two months prior to his death, Shane had constantly made statements in his conversations with Rick and I that seemed to suggest that his life was in some form of danger. He mentioned that he was afraid for his life and instructed me to call the US Embassy if I did not hear anything from him. I then told him that he was going to be fine. He also told me that he may not be able to see me again and, if he was able to get out of the mess, he would give all the glory to God. I did not truly understand what he was talking about. In retrospect,
I wish I had asked more questions.

9 From the brief accounts given, I came to the understanding that Shane had corresponded with a Chinese company that he was extremely uncomfortable with. He told us that he was being asked by the IME to collaborate with a Chinese company, and this extreme discomfort was because he felt like he was being asked to compromise the US security. He felt that he, was also in danger.

10 There have been only two incidents in his 31 years of life where Shane sought help for depression and anxiety. One was in 2003, when Shane was at the University of Florida where he worked on his Masters degree, served in the
US Air Force, worked as a Resident Assistant (RA), and played rugby. He went on anti-depressant medication. He did not eat well and did not exercise. With the help of the family, he managed to overcome his depression.

12 The second time Shane called to tell me he needed help was in April2012. I asked Shane if it was anything like the episode in 2003. His reply was: ''No, I am not depressed, I am anxious because hate my job, I'm being asked to do things that compromise US security, and I feel my life is in danger.''

18 Ever since Shane expressed his fear of being murdered and upon his return to Singapore from Veeco training in January 2012, he kept in touch and communicated at least weekly with me via Skype.

23 Rick and I pleaded with Shane again to leave Singapore right away. Rick said, "Shane,if you truly feel that your life is in danger, you need to come home right now." Shane told us that he was a professional, and that he had agreed in his contract to give 60 days' notice. He felt it would look bad to other companies if he did not keep his word. He was also worried about getting his money out of Singapore. During this time Shane sent me an email that he had composed to his former Ph.D advisor, John Bowers, telling him of his dissatisfaction with IME.

(Click to see email correspondence between Shane and Bowers)

27 We arrived in Singapore late evening on 2nd June 2012. We met Traci Goins who took us to the police station. Rick told Traci before meeting the police that Shane was extremely anxious because he was afraid that he was going to be murdered. Traci then called the US Embassy for advice. They advised her that we should trust the police and tell them everything.

28 On that same evening of 29th June 2012, I met IO Khaldun at the police station in Singapore. My husband and Traci Goins from the US Embassy were with me. There, I was firstly told of the existence of a suicide note, then informed by IO Muhd Khaldun with regards to the circumstances of my son's death. IO Khaldun began our meeting by reading a detailed description of how Shane hung himself. It was an extremely detailed and complex explanation, that included holes and bolts drilled in the wall, attached to ropes and pulleys slung around the toilet and over the door to form a noose. Next, IO Khaldun told us that Shane wrote a suicide note on his computer. He informed us that no one had read the note before. As he handed us a printed copy of the note, IO Khaldun asked for permission for a copy to be given to Tracy and one for himself. From the moment I read that supposed suicide note, I knew that my son did not take his own life rather his life was taken from him.

(Click here to see Mary's breakdown of the "suicide note")

33 Upon entering the apartment, I noticed that his apartment looked normal, like a place that had been packed up. There were clean and folded clothes on the couch, dirty clothes piled up in front of the washer and some clothes in the dryer.

34 The bathroom in the apartment was also not how IO Muhd Khaldun had described it to us: the toilet was in the wrong place and the marble wall was in perfect condition (with no holes, screws or ropes). I also noticed that the door was a standard size, with a towel hanging neatly from the towel rack. There was an upright chair in the bedroom, about 5 feet from the bathroom door, and a plastic bag on the floor of the doorway.

35 IO Khaldun and another man then came over and assured us that they would explain everything to us. At first, they denied all the details I had vividly remembered him reading to us. He told me that I must have misunderstood what he said. I was puzzled and asked IO Khaldun for a copy or transcript of what he had read previously, so that I could compare what I remembered with physical evidence. He then told me that he could not do so because the investigations were still ongoing. I then called Traci Goins (from the US Embassy, and who was with me during the first meeting with IO Muhd Khaldun) and asked her if she had the same understanding as I did. She answered,"Yes".

36 IO Khaldun then tried to explain the discrepancies by using three different scenarios of how Shane could have hung himself. He insisted that Shane used a wide strap like on a computer bag to hang himself. My son, John, also tried to re-create these scenarios, but it became obvious that none of them were feasible. I asked Khal if the police had taken pictures of Shane hanging from the door. Khal said they had not taken pictures of him hanging because they were more worried about saving his life. This did not make sense because we had
been told that Shane had been dead for at least one to two days when he was found. Pictures were taken of Shane's body lying on the bedroom floor. We were not allowed to see these pictures.

38 By then, the police had removed Shane's laptops and mobile phone from the apartment. We then spent the rest of the day packing up his personal belongings, including a hard drive that the police did not remove from his apartment. However, I was unaware at that time that it was a hard drive. I had thought that it was a speaker but it was Rick who realized that it was in fact a hard drive. We did not access it and immediately had it flown to Southern California to be analysed by a computer forensics expert, one Mr Ashraf Masoud with Data-Chasers. It took several weeks to get the results, but when we did we started to piece together what happened to our son.

41 Why did the written explanation of how Shane hung himself not match the physical evidence of Shane's bathroom? Why were we told that Shane jumped off a chair to hang himself? He was 6'1". We have pictures of Shane's standard size bathroom door. If he had jumped off a chair, his feet would be touching the ground. Why wouldn't the police allow us to compare the wireless back up hard drive that we found in Shane's apartment with Shane's two computers? Why, if this is a true investigation, would the police not welcome all the evidence we have compiled?

(Click to see email request to compare the hard drive with the computers)

Condition Statement - John Todd (brother)

Highlights from testimony:

5 As soon we entered Shane's apartment at 56 Spottiswoode Park, my mother, Mary Todd, walked straight toward Shane's room/bathroom. I followed behind her. At first, we started examining the wall and overall bathroom layout and appearance. We were looking for signs of holes and bolts in the walls that pulleys could be attached to because IO Khaldun had given us an intricate description on how Shane had drilled holes in the walls with pulleys wrapped around various parts of the bathroom. I touched every inch of the bathroom with my hand, looking for any holes that may have been drilled, or any sign that matched IO Khaldun's explanation of my brother's death. I then moved back and started to examine the door. At this point, my mother asked me to position myself by the door in the way IO Khaldun had described Shane to be hanging from. She then called IO Khaldun to come over to Shane's apartment to get a detailed description of what exactly transpired.

6 When IO Khaldun arrived, we asked him a series of questions, namely regarding the inconsistencies between his story and what we observed, i.e.

the lack of pulleys and holes in the wall. As I was of the same height as Shane, I asked IO Khaldun to explain how Shane had used the chair and hung himself from the door. IO Khaldun tried to explain, but I would demonstrate that it would not have been possible. IO Khaldun did not have an answer for any of the questions that we asked. He told us that he would get back to us, but he never did.

7 Sometime in July 2012, my father, Rick Todd, remembered the hard disk drive he had retrieved from Shane's apartment. He intended to take it to a forensic computer analyst, Ashraf Massoud in Southern California to have it analyzed. As I am an airline pilot, I can "jump seat" or fly at will, hence I volunteered to fly from Kalispell Montana to Ontario, CA to personally deliver the hard disk drive. The next morning, I woke up at 4:15am to catch the 6:05am flight to get to Ontario by 9:40am to meet Ashraf Massoud. It was a quick exchange out of security just 20 feet outside the airport doors, because I had to quickly rush back to my gate for my return flight.

Condition Statement - Charles Todd (brother)

Highlights from testimony:

7 There were also several times that Shane expressed his excitement to come home over our Skype conversations. He told us that he wanted to put off Father's Day and our youngest brother's, Dylan's 21st birthday celebrations so that he could be with us. During those conversations, Shane showed concern over his working conditions and made comments that made me think of espionage-type circumstances once again.

9 Upon learning about his death, my family left Singapore almost immediately, while my wife and I stayed home in the United States. During the time that my family was in Singapore to retrieve Shane's body, I talked to them very often through Skype. My mother, Mary Todd, told me about IO Khaldun's testimony about how Shane had hung himself, with ropes and pulleys, holes in the wall and around the toilet. They also told me about visiting Shane's apartment and noticing the inconsistencies in the story IO Khaldun provided them. When they called IO Khaldun, he was embarrassed as he could not explain away the inconsistencies.

11 When I saw Shane's lifeless body for the first time, the things that I
noticed almost immediately were the wounds on his hands and the contusion on his forehead. Shane was a trained fighter and had once discussed with me about how the head can be a useful tool if one were to find himself in a fight, specifically, head butting. I believe that a defensive head butt may have caused the contusion on Shane's head. The wounds that I noticed were later confirmed by two different medical doctors, Dr. Randy Karu and Dr. Harold Williamson, at the viewing of Shane's body. They commented to me about the obvious wounds on both the hands and the forehead.

12 Sometime in July 2012, I recall my father, Rick Todd, rediscovering the hard disk drive that they had retrieved from Shane's apartment. At this point, our suspicion began to solidify and manifest in hard evidence. My brother, John Todd, hand-carried the hard disk drive to a computer forensic specialist in Southern California for it to be analyzed.

Condition Statement - Dylan Todd (brother)

Highlights for testimony:

3 We are a unique family, bonded together by our love for each other and our respect for truth, honesty and integrity. The moment we heard that Shane had hung himself, I had a problem believing it. It was not until I remembered the concerns he had expressed to my parents about his life being in danger that I thought that my brother could have been murdered. When I heard that there was a suicide note, I thought to myself, "good", because I would know whether my brother wrote it or not. When I saw the note, I knew he did not write it.

6 The last time I was able to spend time with Shane was during the Christmas of 2011. I was fascinated when Shane told me about the different things that he was working on at his job. He told me about a current project, which required him to go to New Jersey to learn how to operate a multimillion dollar machine. He said that the machine is particularly useful if you have certain recipes to go along with it, and it allows you to do different things related to GaN. Shane also said that the company was not allowed to give the recipes directly, but he could look at them on his own and write down anything he wanted. I told him that this sounded "kind of shady", and he agreed, but adding "I guess that is how they do it". It seemed to me that Shane was following the protocol that was explained to him. It did not seem like it was his idea to copy the recipes.

7 We arrived at Shane's apartment after a meeting that my parents had with the Singapore police. My mother, Mary Todd, said that the police had told her that Shane had set up a series of pulleys, which included screws in the marble walls of the toilet. I remember thinking to myself that he must have put a lot of work into researching how to hang himself. When we got to his apartment, the bathroom was the first place we looked. There were no pulleys, no ropes, and no holes in the walls. When IO Khaldun showed up with another police officer, my mother asked him where were the pulleys he had told her about. He had no answer. My mother was very upset and kept questioning IO Khaldun. I remember thinking if my mother was not managing her anger well, but decided that she was justified because IO Khaldun simply could not provide her with the answers she sought. IO Khaldun then suggested different ways in which Shane could have hung himself.

8 As we were gathering things in Shane's apartment, I noticed a hard disk drive that I had seen him use many different times. My parents had rediscovered this hard disk drive when they were sorting through the things we had collected from Shane's apartment. The reason why I could remember this particular hard disk drive is because this particular hard disk drive had two different male ends and I had always wondered why it was designed that way.

Condition Statement - Romen Cabillio (co-worker)

Highlights for testimony:

9 Shane was always concemed about violating American intellectual property law and import/expmi policy, whether he was working on the Aunion Project or while he was with the GaN Group. Shane once told me that Dr Lo had, on a few occasions, pressured him to ask very intimate details of the technology employed by Aunion, with the aim of understanding such technology, copying it for IME. I think it was in early 2011. I wish to state that I cannot confirm the date as I could not remember. It was only once. But dming the time that he told me this, I remembered that Shane was almost moved to tears. Shane told me that Patrick had verbally asked him for the GDS files. (the "Aurrion Information Requests"). Dr Lo had also told Shane to ask Aunion for its GDS files on the Aunion Laser. Since these GDS files would contain all the technological data in relation to the Aunion Laser, the surrender of these files would effectively mean the surrender of intellectual property in the Amrion Laser. GDS files are the complete design of a chip. For example, if you want a company in Taiwan to build a chip which you want, you would send over this GDS file. I told Shane, many times, that if he provided these details, his professional reputation, amongst the small research community, would be ruined. I recall one occasion, sometime in December 2011, when Shane approached me and told me that he wanted to resign from the !ME because Dr Lo had asked him to obtain the GDS files on the Aurrion Laser. Although Shane was extremely upset, I managed to persuade him not to resign. I simply told Shane to reject Dr Lo 's request. The management should not be asking for such confidential information because it is tantamount to breaking the law. The management in this instance was Dr Patrick Lo. Shane told me this.

10 At the IME, scientists are often involved in several projects at the same time. These projects, which can be defence-related, often involve different countries. Where a scientist is involved in different non-classified defence-related projects with different countries, there is a risk for the scientist to reveal the infon11ation gathered in one project concerning one country when dealing with a different project conceming another country. This is called organizational conflict of interest. Why I would say that Shane was upset is due to the fact that he was involved in a project which had conflict of interest. Conflict of interest meaning that he was working in a project with Huawei and Veeco at the same time. Veeco provided the US machinery which had dual use while Huawei was a Chinese company.

13 Apart from a project with Rolls Royce, Shane also worked on a very small project with Huawei Technologies Co., Ltd. (China) ("Huawei") while he was in the GaN Group (the "Huawei Project"). I do not know what the project with Rolls Royce was as Shane did not tell me. The small project I was refen·ing with Huawei was prior to Galium Nitrite program, Huawei together with

!ME was in a project to test and measure a small chip. It was a very small project. Shane only told me that it was Huawei but he did not explicitly explain whether it was a subsidiary company or not. I remembered Shane asking me to review a math calculation of some measurement. This was when he told me. The IME had approached Huawei to collaborate on high perfom1ance GaN chips capable of military applications. For the Huawei Project, I knew that Shane had several meetings with representatives from Huawei. During these meetings, these representatives spoke Chinese frequently. Shane was unhappy with the use of Chinese during these meetings as he did not understand the language. I know all of this because I have spoken with Luis Alejandro Andia Montes ("Luis"). Luis, who worked at the !ME was supposed to design the GaN amplifier and he knew the precise specifications of the GaN amplifier the !ME and Huawei wished to manufacture. Luis also had the business cards of the representatives from Huawei who were involved in teclmical discussions in relation to the GaN amplifier. Luis has since resigned from the !ME and he returned to France, Paris sometime in early Aptil 2013.

14 On 21 June 2012 (a Thursday), Shane had lunch with Vincent Pott ("Pott"). Shane and Pott had swapped places when Shane was transfened to the GaN Group. Although lunch period usually lasted for about an hour, Pott's lunch with Shane lasted for only about 15 minutes. During this lunch, Shane spoke little and went to the toilet three times. Pott believed that Shane had gone to the toilet to answer phone calls. Pott told me that Shane was behaving very unusually that day. After Shane passed away, Pott told me this. This was in August 2012. Pott was a friend of mine and we met during work all the time.

15 Shane's last day at the IME was on 22 June 2012 (a Friday). On that day, there was a farewell lunch for Shane. Apmi from Shane's colleagues in the GaN Group, I was also at this lunch. I recall bidding Shane farewell at the end of the day. We had also discussed if I could buy some of the items in his apartment since he was returning to America. Shane appeared normal on this day.

17 Shane also told me, on numerous occasions, that he felt trapped. I think Shane felt trapped because while he wished to resign from the IME, he also wanted to finish his projects. I cannot comment what he meant because I personally do not know what he meant by that. He only told me that he felt trapped.

18 In addition, Shane was very upset with the style employed by the management at the IME. He only said top management without refening to anyone in particular. I advised Shane, many times, that he should tell me if he ever felt he was doing something illegal that was putting his life at risk. Shane, however, never told me if anything was bothering him. I am very sad I did not spend enough time to understand what Shane was going through. Shane never told me he was depressed. I do not know if Shane was on any medication or suffering from any illness. However, T knew that:

(a) Shane was happy living in Singapore;

(b) Shane was happy to retum to his parents in America; this was after he had resigned, Shane told me that he wanted to go back in Montana. This was in June 2012. and

19 I knew that Shane was extremely stressed because he was involved in something secretive. He used to talk all the time but he changed and refused to share. He became secretive. I recall asking him about this while we were having lunch at the IME on or about 17 June 2012. Shane had looked tensed during lunch and I had asked him if he had something to say. Shane, however, replied that he could not tell me and that he did not want to talk. In response, I told Shane it was alright and that I understood. I wish to state that it was secretive because he changed from being a person who would always share to a person who would not say anything and just kept quiet and secretive. We did not talk to each other about projects anymore.

20 Shane had been stressed since February 2012. This was when I noted that he became secretive about all his projects. Shane had also approached me many times, telling me that he made the biggest mistake in his life when he joined the !ME. When Shane said this, I understood him to be referring to the bad work culture at the !ME. Shane was always telling me he was not happy what he did in the GaN Group. However, I do not really know what Shane meant when he made these statements because he does not go into any detail. I do not really know about the scope of Shane's work at the !ME, especially his work in relation to GaN. Shane never told me that he was working with Huawei on a project in relation to GaN. I do not know if Shane was working on any defence-related projects at the IME.

22 I have read the article, "Is it suicide or is it murder?" by Feng Zengkun, which was published in the Sunday Times on 17 February 2013 (the "ST Article"). According to paragraph five of the ST A1ticle, Dr Raj Thampuran, the Managing Director of the Agency for Science, Technology and Research (A*STAR), had stated that "the agency does not conduct any military related research". This is completely untrue because, as stated on the website of the IME, the IME does have contracts with the Defence from US and Israel. The IME is involved in defence-related projects that are not classitled.

23 The IME has infom1ed the Financial Times that it is involved in healthcare research. This article was the response to the first FT article which was published. I remembered that it was Prof Kwong who provided the reply. This is untrue because the IME is involved in defence-related contracts. IME is a public institution after all. On this note, 1 would not be surprised if the work Shane did in the GaN Group had military specifications. GaN can potentially have many military applications and is registered as a dual usage technology (both for commercial or military specifications)

Condition Statement - Dylan Todd (brother)

ondition Statement - Dylan Todd (brother)

Condition Statement - Khaldun (Investigating Officer)

Highlights for testimony:

18 The following were not seized as exhibits but brought back by me to Central Police Division for safekeeping:

(a) the Laptop Bag which contained:

(i) two thumb-drives; and

(ii) one hard-disk drive; and

34 On 28 June 2012, at about 5:00p.m., I met with the subject's parents and the Vice Consul at the Central Police Division. I recorded conditioned statements from the subject's parents. After doing so, I spoke with my overall-in-charge, Inspector Gm·charn Singh (the "OC"), and we decided that the subject's personal belongings should be returned to the subject's parents. The subject's mother acknowledged the return of the following items by affixing her signature to an acknowledgement slip bearing Report No. A/20120624/0125 (the "Acknowledgement Slip"):

(a) the Laptop Bag which contained:

(i) two thumb-drives; and

(ii) the HDD; and
(b) the wallet which contained:

(i) one World USAA Mastercard;

(ii) one Adult EZ-Link card;
(iii) one "USAA Cash" rewards debit mastercard;

(iv) one SMRT Citibank VISA Platinum;

(v) one Premier miles Citibank VISA signature card;

(vi) one Citibank ATM Card;
(vii) one California driver license;

(viii) one namecard;
(ix) one 24-hour fitness USA card; and

(x) cash amounting to S$25 (two S$10 notes and one S$5 note).