Richard Smith (prosecuting) said a Home Office pathologist who examined Catherine's remains wasable to determine that she had died before the car fire.
Fabric was found under Catherine's body. It was analysed and The Crown says it was a pair of grey shorts, the type you wear in bed.
The family of Catherine Wells-Burr has written to the Prime Minister after hearing her killers could end up serving a shorter sentence.
The parents of Catherine Wells-Burr have described how they comforted her alleged killer - as her burned corpse lay in a nearby field.