Name: Tarana Khan — Direct/Cross/Redirect - Day 7 - Donna Adelson
Uploaded: 2025-09-02
Description: Defense private investigator Tarana Khan testifies about her January 2025 jail interview of prosecution jailhouse informant Patricia Byrd, denying that she offered Byrd any inducements — land, a trailer, dental veneers, or a vehicle — and denying that Byrd reported any confession by Donna Adelson.

Defense private investigator Tarana Khan testifies about her January 2025 jail interview of prosecution jailhouse informant Patricia Byrd, denying that she offered Byrd any inducements — land, a trailer, dental veneers, or a vehicle — and denying that Byrd reported any confession by Donna Adelson.

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Proceedings

Direct Tarana Khan - Direct Line 1

Cross Tarana Khan - Cross Line 79

Redirect Tarana Khan - Redirect Line 103

Direct Tarana Khan Joshua D. Zelman

1 4:36:44

JUDGE EVERETT: Please call your next witness.

2 4:36:49

MR. ZELMAN: The defense would call Tarana Khan.

3 4:38:02

JUDGE EVERETT: Do you swear or affirm the testimony you will give today will be the truth?

4 4:38:06

TARANA KHAN: I do.

5 4:38:06

JUDGE EVERETT: You may take your seat. Please speak loudly and clearly for the jurors. You can adjust the microphone as you need.

6 4:38:17

MR. ZELMAN: Thank you, Your Honor. Good afternoon. Can you please introduce yourself to the jury and spell your last name?

7 4:38:22

TARANA KHAN: Yes. My name is Tarana Khan. Last name is K-H-A-N.

8 4:38:27

MR. ZELMAN: And Ms. Khan, how are you employed currently?

9 4:38:32

TARANA KHAN: I'm a mitigation specialist slash paralegal for the Federal Defenders of the Middle District of Georgia.

10 4:38:32

MR. ZELMAN: And what is that job? What do those job responsibilities entail?

11 4:38:32

TARANA KHAN: What I do is, I go down — the maternal and paternal side of the families — and I investigate all of the issues. I do a fact investigation, and I also do the mental evaluations — well, not the evaluations, but I go back, you know, do all the records and get all the things together, presented to the courts so we can try to get a lesser sentence for our clients.

12 4:39:10

MR. ZELMAN: Okay. And that's with a habeas unit?

13 4:39:14

TARANA KHAN: Not right now. I'm just with the Middle District of Florida — I'm sorry, of Georgia. But I was doing that with the habeas here in Tallahassee.

14 4:39:22

MR. ZELMAN: Okay. And how long have you been in your current role in the Middle District of Georgia?

15 4:39:29

TARANA KHAN: One year in Georgia.

16 4:39:31

MR. ZELMAN: Okay. Prior to that, did you work for the Federal Defender's Office here in the Northern District of Florida?

17 4:39:40

TARANA KHAN: I did, the Capital Habeas Unit.

18 4:39:43

MR. ZELMAN: And can you tell us what you did there, please?

19 4:39:45

TARANA KHAN: Yes. I did investigation, went to talk to clients, all their families. It was more of a fact investigation at that point.

20 4:39:54

MR. ZELMAN: Okay. And so that entailed you going out at the direction of the attorneys that you worked with, interviewing individuals, correct?

21 4:40:10

TARANA KHAN: Correct.

22 4:40:10

MR. ZELMAN: Gathering records?

23 4:40:11

TARANA KHAN: Yes.

24 4:40:11

MR. ZELMAN: Um, and that included individuals that were in custody, correct?

25 4:40:14

TARANA KHAN: Correct.

26 4:40:15

MR. ZELMAN: And preparing reports?

27 4:40:16

TARANA KHAN: Correct.

28 4:40:16

MR. ZELMAN: And presenting that to whom?

29 4:40:17

TARANA KHAN: The attorneys.

30 4:40:19

MR. ZELMAN: Okay. Did it also bring you to have occasion to testify in court, ever?

31 4:40:22

TARANA KHAN: No, no.

32 4:40:24

MR. ZELMAN: Um, now how long were you employed with the Northern District of Florida, um, Federal Defender's Office?

33 4:40:33

TARANA KHAN: From 2016 until July 2022.

34 4:40:38

MR. ZELMAN: And can you tell us a little bit about your educational background?

35 4:40:44

TARANA KHAN: Yes, I have an associate's in paralegal, a bachelor's in legal studies, and I've studied sociology and I've earned a certificate in that.

36 4:40:54

MR. ZELMAN: And when did you complete your bachelor's?

37 4:40:56

TARANA KHAN: In 2000 — around 2014, maybe.

38 4:41:02

MR. ZELMAN: Now, in between working for the Federal Defender's Office in the Northern District of Florida and the Federal Defender's Office in the Middle District of Georgia, did you work as a licensed private investigator in Florida?

39 4:41:18

TARANA KHAN: After I left the Federal Defender's Office in Tallahassee, yes.

40 4:41:24

MR. ZELMAN: Okay. And how long did you do that for?

41 4:41:27

TARANA KHAN: Since 2022.

42 4:41:30

TARANA KHAN: And I never — I never, I guess, stopped. I just took the job for the Federal Middle District of Georgia and left.

43 4:41:30

MR. ZELMAN: Okay. And as a licensed private investigator, were you retained by my office to interview an individual by the name of Patricia Byrd?

44 4:41:49

TARANA KHAN: Yes.

45 4:41:50

MR. ZELMAN: And where was she located?

46 4:41:52

TARANA KHAN: In the Leon County Jail.

47 4:41:54

MR. ZELMAN: Okay. How many times did you meet with Ms. Byrd?

48 4:41:57

TARANA KHAN: Once.

49 4:41:59

MR. ZELMAN: And that was at the Leon County Jail?

50 4:42:01

TARANA KHAN: Yes.

51 4:42:01

MR. ZELMAN: And do you remember when that was?

52 4:42:05

TARANA KHAN: I want to say January.

53 4:42:07

TARANA KHAN: Can I look?

54 4:42:33

MR. ZELMAN: If it'll help refresh your memory, Miss— Byrd was on January 24th, 2025, correct?

55 4:42:40

TARANA KHAN: Sorry, yes.

56 4:42:40

MR. ZELMAN: And when you interviewed Miss Byrd, did you tell Miss Byrd that Mrs. Adelson was going to pay her for her testimony?

57 4:42:51

TARANA KHAN: No.

58 4:42:51

MR. ZELMAN: Specifically, did you tell Miss Byrd that Donna Adelson was gonna buy her a piece of land?

59 4:42:57

TARANA KHAN: No.

60 4:42:58

MR. ZELMAN: What about a trailer?

61 4:42:59

TARANA KHAN: No.

62 4:43:00

MR. ZELMAN: What about veneers for her teeth?

63 4:43:02

TARANA KHAN: No.

64 4:43:02

MR. ZELMAN: What about a small vehicle for her and her children?

65 4:43:06

TARANA KHAN: No.

66 4:43:09

MR. ZELMAN: Did Ms. Byrd tell you that Mrs. Adelson had offered those items to her?

67 4:43:13

TARANA KHAN: No.

68 4:43:21

MR. ZELMAN: Did Ms. Byrd tell you that Mrs. Adelson confessed to any portion of the crimes with which Mrs. Adelson is charged in this case?

69 4:43:32

MR. ZELMAN: Did she tell you that?

70 4:43:34

TARANA KHAN: I'm sorry, can you read that for me?

71 4:43:35

MR. ZELMAN: Did Ms. Byrd tell you that Mrs. Adelson confessed to her?

72 4:43:40

TARANA KHAN: No.

73 4:43:40

MR. ZELMAN: Just a moment, Your Honor.

74 4:43:58

MR. ZELMAN: Ms.— Khan, prior to interviewing Ms. Byrd on January 24, 2025, did you meet with or speak with Donna Adelson?

75 4:44:08

TARANA KHAN: No.

76 4:44:09

MR. ZELMAN: Have you ever met with or spoken with Donna Adelson?

77 4:44:12

TARANA KHAN: No.

78 4:44:20

MR. ZELMAN: Nothing further, Your Honor.

Cross Tarana Khan Sarah Kathryn Dugan

79 4:44:21

JUDGE EVERETT: Cross-examination.

80 4:44:23

MS. DUGAN: Why did you interview Ms. Byrd?

81 4:44:38

TARANA KHAN: I was given a list of names to interview by defense counsel.

82 4:44:42

MS. DUGAN: Correct. Okay. And she was not a state witness at that time, right?

83 4:44:52

TARANA KHAN: I wouldn't know.

84 4:44:53

MS. DUGAN: Wouldn't know. Would it refresh your memory to see a copy of the state's amended discovery when we did list her as a witness?

85 4:45:01

TARANA KHAN: I wouldn't— I didn't see that. I would have never seen that.

86 4:45:01

MS. DUGAN: Okay. So that wouldn't help you to know when she was amended as a witness in the case?

87 4:45:10

TARANA KHAN: I wouldn't have known.

88 4:45:27

MS. DUGAN: Okay. So you were not asked to go there because she was a state's witness. I'll just put it that way. And— Did you record your interview with Miss Byrd?

89 4:45:29

TARANA KHAN: No.

90 4:45:29

MS. DUGAN: The SAO investigators were able to record their interview with her. Why didn't you when you interviewed her?

91 4:45:29

TARANA KHAN: I wasn't asked to do that.

92 4:45:29

MS. DUGAN: Asked by who?

93 4:45:29

TARANA KHAN: The attorneys.

94 4:45:29

MS. DUGAN: So they didn't ask you to do it?

95 4:45:29

TARANA KHAN: They didn't ask me to record it, no.

96 4:45:49

MS. DUGAN: Okay. Could you have taken a recorder and recorded it though?

97 4:45:53

TARANA KHAN: Had I requested for the jail to permit me to take a recorder in there? The jail does allow that.

98 4:46:00

TARANA KHAN: I don't know. I didn't ask.

99 4:46:01

MS. DUGAN: Okay. If you get permission, in your experience, is it typical for jails to allow you to do that?

100 4:46:07

TARANA KHAN: Yes.

101 4:46:07

MS. DUGAN: Okay. Just a second.

102 4:46:07

MS. DUGAN: That's all I have. Thank you.

Redirect Tarana Khan Joshua D. Zelman

103 4:46:28

JUDGE EVERETT: Redirect examination.

104 4:46:52

MR. ZELMAN: Ms. Khan, since you didn't ask for permission to take a recording device into the jail when you met with Ms. Byrd, how did you take accurate notes?

105 4:47:03

TARANA KHAN: As I was speaking with them, I wrote everything down that they were saying to me.

106 4:47:07

TARANA KHAN: So I did pen to paper.

107 4:47:09

MR. ZELMAN: Pen to paper.

108 4:47:14

MR. ZELMAN: And had the state requested those through the discovery process, you would have been able to produce those?

109 4:47:21

TARANA KHAN: Correct.

110 4:47:21

MR. ZELMAN: Nothing further.

111 4:47:22

JUDGE EVERETT: Will this witness need to be recalled or retained for any reason? We—

112 4:47:32

MR. ZELMAN: We'll retain her, but she's free to go about her business.

113 4:47:34

JUDGE EVERETT: You may step down, Miss Khan. If you're called by the attorneys, they will let you know. Do not discuss your testimony with any other person.

Insights

Direct Tarana Khan

Defense private investigator denies offering Patricia Byrd any inducements—land, trailer, dental veneers, or a vehicle—during a January 2025 jail interview, and denies Byrd ever reported that Donna Adelson confessed or made any such offers.

Case Significance

Directly contests the credibility of prosecution jailhouse informant Patricia Byrd by placing a defense investigator on the stand to deny specific inducement allegations and deny any confession reporting—a focused credibility battle over a witness whose value to the state depends on those claims.

Patricia Byrd testified as a prosecution jailhouse informant, making her credibility a live issue
Khan's specific, itemized denials (land, trailer, veneers, vehicle) suggest Byrd made equally specific claims about defense misconduct
Denial that Byrd reported any Donna confession directly undercuts the most damaging thing a jailhouse informant could offer

Highlights

“When you interviewed Miss Byrd, did you tell Miss Byrd that Mrs. Adelson was going to pay her for her testimony?”

— Joshua D. ZelmanOpens the inducement denial sequence, framing the entire purpose of Khan's testimony: rebutting any claim by jailhouse informant Byrd that the defense promised payment in exchange for her account.Testimony

Khan denies offering or being told about any of four specific inducements allegedly promised to Byrd on Donna Adelson's behalf: a piece of land, a trailer, dental veneers, and a small vehicle for her and her children.

Testimony

Khan denies that Byrd told her Donna Adelson confessed to any portion of the charged crimes—the single most consequential thing a jailhouse informant could offer and the claim the defense most needed to rebut.

“Did Ms. Byrd tell you that Mrs. Adelson confessed to her?”

— Joshua D. ZelmanThe highest-stakes question of the examination—a flat denial that Byrd reported any confession by Donna Adelson, directly targeting the core evidentiary value a jailhouse informant would provide.Testimony

Khan confirms she has never met or spoken with Donna Adelson at any point, foreclosing any suggestion that Khan acted as a conduit between Donna and Byrd.

People Mentioned

Patricia Byrd

Locations Mentioned

Leon County Jail

Deep Analysis

Attorney Strategy

Catalog-and-Deny Structure

Zelman uses a methodical item-by-item structure rather than a single omnibus denial—mirroring the specificity of Byrd's apparent claims to make each denial as concrete and memorable as the allegation it targets. The sequence (land, trailer, veneers, vehicle) signals the defense has Byrd's claims mapped and is rebutting each individually.

Case Theory Connections

Jailhouse Informant Credibility Attack

The defense must discredit prosecution witnesses who claim incriminating statements from Donna Adelson. Khan's testimony directly attacks Byrd's credibility by denying the inducement claims that would motivate fabrication and denying that any confession was communicated—leaving Byrd's account unsupported by the one defense-side person who met with her.

Credibility Observations

Unequivocal Denials

Khan answers every substantive question with an unqualified denial and shows no hedging or confusion. The one moment of uncertainty—needing to confirm the January 24 date—is trivial and quickly resolved. Her professional background (federal defender mitigation work, paralegal credentials, jail interview experience) supports the impression of a witness accustomed to this type of work.

Followup Questions Or Open Threads

Cross-Examination Anticipated

The prosecution will likely cross Khan on the specifics of the Byrd interview—what was discussed, whether any benefit to Byrd was ever implied, and the scope of the defense investigative mandate. The direct establishes only denials; cross may probe the texture of the conversation.

Testimony Themes

Itemized Inducement Denial

Zelman structures the examination around four specific alleged inducements—land, trailer, veneers, vehicle—eliciting a flat denial to each. The specificity suggests the defense is preempting or neutralizing equally specific claims Byrd made or is expected to make about what she was promised.

No Confession Reported

Khan denies Byrd ever told her Donna Adelson confessed to any charged crime. This is the examination's highest-value denial: it targets the core reason jailhouse informants are called—to relay incriminating statements by the defendant.

Witness Role And Importance

Witness Role And Importance

Khan is a defense-retained private investigator called solely to rebut prosecution jailhouse informant Patricia Byrd. Her testimony is narrow: she denies offering any inducements during her January 2025 jail interview with Byrd, denies Byrd reported any confession from Donna Adelson, and denies all personal contact with Donna Adelson. She is a functional rebuttal witness, not a character or fact witness.

Cross Tarana Khan

Prosecution cross-examines defense private investigator on her unrecorded January 2025 jail interview of jailhouse informant Patricia Byrd, establishing that defense counsel chose not to request a recording.

Case Significance

Short cross that chips at the credibility of the defense's Byrd rebuttal by highlighting the absence of a recording defense counsel could have requested.

Cross limited to two topics: Byrd's witness-status knowledge and recording methodology
Prosecution contrast with SAO's recorded interview implies a deliberate defense methodological choice, not a logistical constraint

Highlights

Testimony

Prosecution establishes that defense private investigator did not record her Byrd interview — unlike SAO investigators who did — and that the decision not to record was defense counsel's, not Khan's.

“I wasn't asked to do that.”

— Tarana KhanKhan attributes the absence of a recording to defense counsel's choice rather than her own, implicitly placing the decision not to preserve a record of the Byrd interview with the attorneys who retained her.

People Mentioned

Patricia Byrd

Locations Mentioned

Leon County Jail

Deep Analysis

Attorney Strategy

Contrast with SAO recorded interview

Dugan draws an unfavorable contrast with SAO investigators who recorded their Byrd interview, framing the defense's failure to record as a deliberate choice rather than a logistical constraint — implicitly casting doubt on the completeness of Khan's account.

Credibility Observations

No recording — defense counsel's choice

Khan acknowledges she was not instructed to record the Byrd interview despite recording being feasible with jail authorization, placing that methodological decision with the attorneys who retained her and limiting the weight of her denials.

Notable Admissions

Defense counsel did not request a recording

Khan confirms that defense attorneys did not ask her to record the Byrd interview, and that recording would have been permissible with advance jail authorization.

Witness Role And Importance

Witness Role And Importance

Tarana Khan is a licensed Florida private investigator hired by the defense to interview jailhouse informant Patricia Byrd. Her direct testimony denied offering any inducements to Byrd; the cross targets methodological gaps in that unrecorded interview to undercut the reliability of her account.

Redirect Tarana Khan

Single-point redirect establishes that Khan took handwritten notes during her unrecorded jail interview with Patricia Byrd and that those notes were available for discovery had the state requested them.

Case Significance

Brief rehabilitative redirect that blunts the prosecution's unrecorded-interview implication without introducing new facts.

Single narrow point addressed — handwritten notes as substitute for recording
No new admissions, rulings, or contested exchanges
Closes the Tarana Khan examination sequence with minor clarification

Highlights

Testimony

Zelman rehabilitates Khan's unrecorded jail interview by establishing she took real-time handwritten notes and those notes were available for discovery, countering the prosecution's cross implication.

“As I was speaking with them, I wrote everything down that they were saying to me. So I did pen to paper.”

— Tarana KhanDirect rehabilitation of the cross-examination's implication that the absence of a recording undermines Khan's denials — establishes a contemporaneous written record existed.

People Mentioned

Patricia Byrd

Deep Analysis

Attorney Strategy

Note-taking rehabilitation

Zelman addresses the one vulnerability the prosecution's cross created — no recording — by eliciting that contemporaneous handwritten notes exist and were discoverable, restoring the evidentiary foundation for Khan's denial testimony.

Witness Role And Importance

Witness Role And Importance

Tarana Khan is a defense private investigator retained to interview prosecution jailhouse informant Patricia Byrd. Her redirect is a brief single-point rehabilitation, not substantive new testimony.

Summary

Defense private investigator and mitigation specialist Tarana Khan takes the stand as a rebuttal witness to prosecution jailhouse informant Patricia Byrd. On direct, defense attorney Joshua Zelman walks Khan through a specific catalog of alleged inducements — a piece of land, a trailer, dental veneers, and a small vehicle — that Byrd apparently claimed were offered during a January 24, 2025, interview Khan conducted at Leon County Jail. Khan denies offering any of them, denies that Byrd made those claims during the interview, and denies that Byrd reported any confession by Donna Adelson. She also confirms she has never met or spoken with Donna Adelson. On cross, Assistant State Attorney Sarah Kathryn Dugan establishes that Khan was unaware Byrd was a state's witness when she requested the interview, having obtained Byrd's name from the defense witness list. Dugan's more pointed focus is the absence of a recording: SAO investigators recorded their own Byrd interview, but Khan did not record hers, acknowledging that jail recordings are permitted with advance authorization and that she simply was not asked to record by defense counsel. On redirect, Zelman rehabilitates the evidentiary weight of Khan's denials by eliciting that she documented the interview contemporaneously in handwritten notes, which would have been subject to discovery. The judge gives Khan standard retention instructions before she is excused.

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