IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MINNESOTA
Bradley A. Dunlap,

Civil No. 4-96-1035

Plaintiff,

-vs-

AFFIDAVIT
OF

Chubb Life Insurance

DAVID VOSS

Company of America,
Defendant and
Third-Party Plaintiff,

-vsDonn P. Barber, personal
representative of the Estate of
Anne L. Dunlap,

Third-Party Defendant

STATEOFMINNESOTA
COUNTY OF HENNEPIN

)
)ss.
)

DAVID VOSS, being first duly sworn on oath, deposes and states as follows:
1. I am a sergeant in the Homicide Division of the Minneapolis Police Department
and I have had primary responsibility for the investigation of the homicide of Anne
Dunlap.
2. Bradley Dunlap has been the only plausible suspect in the Anne Dunlap
homicide since January 1, 1996 when he subjected himself to a video taped interview at
Minneapolis Police Department headquarters. It was Mr. Dunlap's conduct during this
video taped interview which prompted me to consider him as a suspect in the homicide.

 3. After extensive investigation, Bradley Dunlap remams the only plausible
suspect in the Anne Dunlap homicide.

Mr. Dunlap had the motive in the form of

$1,000,000.00 in life insurance benefits through the Chubb Life policy and $745,000.00 in
group life insurance on Anne Dunlap's life through her employment at Pillsbury. Bradley
Dunlap is the beneficiary on all of this life insurance.

4. That forensic evidence indicates that the murder of Anne Dunlap occurred at
approximately 2:30 p.m. to 3:00 p.m. on December 30, 1995. Dr. Daniel Davis, Assistant
Medical Examiner for Hennepin County, conducted an autopsy of Anne Dunlap and
concludes that she died between 2:30 p.m. to 3:00 p.m. on December 30, 1995. The
forensic evidence also indicates that the murder of Anne Dunlap occurred in the garage of
her parents' home. This is the home where Anne and Bradley Dunlap were living and
where Bradley Dunlap acknowledged that he was on December 30, 1995 from 2:30 p.m.
to 3:00 p.m.. Forensic evidence indicates that the murder of Anne Dunlap occurred in the
garage of her parents' home because Anne Dunlap's blood is found in three locations in
the garage. Furthermore, there were positive presumptive indicators of blood found in the
washtub and lint trap located in the laundry room of Anne Dunlap's parents' home. This
forensic evidence suggests a clean-up by the murderer.
5. Bradley Dunlap has been unable to corroborate through independent and
reliable sources what his activities were during the afternoon of December 30, 1995. By
his own admissions to me, Mr. Dunlap places himself on December 30, 1995 in an area
near where the body of Anne Dunlap and her vehicle were subsequently located on
January 1, 1996.

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 6. There is no plausible alternative explanation to Anne Dunlap's death other than
the conclusion that Bradley Dunlap is the murderer.
FURTHER AFFIANT SAITH NOT.

Dated this

}:j__ day of May, 1997

Sergeant David Voss

/

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